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UNITED STATES DISTRICT COURT
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FOR THE CENTRAL DISTRICT OF CALIFORNIA
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June 2004 Grand Jury
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UNITED STATES OF AMERICA,
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Plaintiff,
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v.
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RAFAEL YEPIZ,
aka Ralph,
aka Sneaky,
ARNOLD SANDOVAL,
aka Big Barney,
aka Anthony Cesto,
HORACIO YEPIZ,
aka Alberto Rodriguez,
aka Horse,
ESPIRIDION ARANDA,
aka Pete Josui,
aka Antonio Marmolejo,
aka Peety,
JESUS SANDOVAL,
aka Chuy,
aka the Barney Twins,
LUIS SANDOVAL,
aka the Barney Twins,
MANUEL YEPIZ,
aka Martin Sanchez,
aka Pony,
CARLOS ABLE CASILLAS,
aka Tetiro,
IGNACIO HARO,
aka Nose,
JAVIER COVARRUBIUS,
aka Coco,
aka Cokes,
MAY:may
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CR 05-_____________
I N D I C T M E N T
[18 U.S.C. § 1962(c):
Racketeer Influenced and
Corrupt Organizations; 18
U.S.C. § 1962(d): Racketeer
Influenced and Corrupt
Organizations Conspiracy;
21 U.S.C. §§ 846, 841(a)(1),
841(b)(1)(A): Conspiracy;
18 U.S.C. § 1959(a): Violent
Crimes in Aid of Racketeering;
21 U.S.C. §§ 841(a)(1),
841(b)(1)(A) and (B) and 846:
Possession with Intent to
Distribute and Distribution of
Cocaine, Methamphetamine, and
Marijuana, and Attempted
Possession With Intent To
Distribute; 21 U.S.C. §
841(c)(2): Illegal Possession
of Listed Chemical; 21 U.S.C.
§ 848(e)(1)(B): Murder of a
Police Officer in Relation to
a Drug Trafficking Crime;
18 U.S.C. § 924(c): Use or
Carrying and Possession of
Firearm During and in
Furtherance of Drug
Trafficking Crime and Crime of
Violence;
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GUSTAVO RODRIGUEZ,
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aka Noid,
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ALONZO SAENZ RANGEL,
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aka Choncho,
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JOEL HARO,
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AMEER KHAN,
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RICARDO AVILA,
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DAVID GARCIA,
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aka Davey Crockett,
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JOSE LEDESMA,
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aka Peps,
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BALDEMAR HERNANDEZ,
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aka Casper,
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aka Baldy,
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RAUL ROBLEDO,
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aka Clown,
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CLETO VASQUEZ,
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aka Carlos,
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JESUS CONTRERAS,
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aka Yuck,
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GILBERTO CARRASCO,
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aka Beto,
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CARLOS CAMPOS,
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aka Blackie
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RICARDO BARBA,
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aka Cartoon,
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aka Tunes,
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RUBEN AYALA,
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aka Fat Boy,
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aka Shy Boy,
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JAIME BAUTISTA,
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aka Nick Nack
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aka Nigger,
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ALBERTO SANCHEZ,
aka Hector Rodriguez Marin,)
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aka Beto,
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RUBEN MEDINA,
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aka Camaron,
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aka Juan Luna Risos,
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JOE MORIN RANGEL,
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aka Little Joe,
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MARCELINO MACIAS,
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ERNESTO OROZCO MENDEZ,
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aka Gordo,
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LUIS GARCIA,
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ERIK AVINA,
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AGUSTIN RODRIGUEZ,
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aka Dog,
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aka Stranger,
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FRANCISCO ZAMBRANO,
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aka Noc,
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SERGIO MEJIA,
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aka Jaws,
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JOSE LUIS MEJIA,
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aka Cheech,
18 U.S.C. §§ 924(c), (j)(1)
Use of a Firearm During and in
Furtherance of Drug
Trafficking Crime and Crime of
Violence Resulting in Death;
31 U.S.C. § 5324(a)(3):
Structuring Financial
Transactions; 18 U.S.C. § 2:
Aiding and Abetting and
Causing an Act to be Done;
18 U.S.C. § 3: Accessory After
the Fact; 21 U.S.C. § 853:
Criminal Forfeiture]
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DEFENDANTS,
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______________________________)
JOSE DE JESUS AGREDANO,
HILDA RODRIGUEZ YEPIZ,
SAIGN MAHAYA CHARLSESTEIN,
aka Shawn,
JUAN CEDENO GOMEZ,
JUAN SALINAS,
aka Pickles
LUZ MARIA RANGEL,
aka Lucy,
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The Grand Jury charges:
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INTRODUCTORY ALLEGATIONS
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THE RACKETEERING ENTERPRISE
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1.
At all relevant times, defendants RAFAEL YEPIZ, also
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known as (“aka”) Ralph, aka Sneaky (“R. YEPIZ”), ARNOLD SANDOVAL,
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aka Big Barney (“A. SANDOVAL”), HORACIO YEPIZ, aka Alberto
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Rodriguez, aka Horse (“H. YEPIZ”), ESPIRIDION ARANDA, aka Pete
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Josui, aka Antonio Marmolejo, aka Peety (“ARANDA”), JESUS
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SANDOVAL, aka Chuy, aka the Barney Twins (“J. SANDOVAL”), LUIS
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SANDOVAL, aka the Barney Twins (“L. SANDOVAL”), MANUEL YEPIZ, aka
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Martin Sanchez, aka Pony (“M. YEPIZ”), CARLOS ABLE CASILLAS, aka
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Tetiro (“CASILLAS”), IGNACIO HARO, aka Nose, (“I. HARO”), JAVIER
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COVARRUBIUS, aka Coco, aka Cokes (“COVARRUBIUS”), GUSTAVO
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RODRIGUEZ, aka Noid (“G. RODRIGUEZ”), ALONZO SAENZ RANGEL, aka
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Choncho (“SAENZ”), JOEL HARO (“J. HARO”), AMEER KHAN (“KHAN”),
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RICARDO AVILA (“AVILA”), DAVID GARCIA, aka Davey Crockett
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(“GARCIA”), JOSE LEDESMA, aka Peps (“LEDESMA”), BALDEMAR
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HERNANDEZ, aka Casper, aka Baldy (“HERNANDEZ”), RAUL ROBLEDO, aka
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Clown (“ROBLEDO”), CLETO VASQUEZ (“C. VASQUEZ”), JESUS CONTRERAS,
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aka Yuck (“CONTRERAS”), GILBERTO CARRASCO, aka Beto (“CARRASCO”),
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CARLOS CAMPOS, aka Blackie (“CAMPOS”), RICARDO BARBA, aka Cartoon
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(“BARBA”), RUBEN AYALA, aka Fat Boy, aka Shy Boy (“AYALA”), JAIME
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BAUTISTA, aka Nick Nack, aka Nigger, (“BAUTISTA”), ALBERTO
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SANCHEZ, aka Hector Rodriguez Marin, aka Beto (“SANCHEZ”), RUBEN
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MEDINA, aka Camaron, aka Juan Luna Risos (“MEDINA”), JOE MORIN
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RANGEL, aka Little Joe (“MORIN”), MARCELINO MACIAS (“MACIAS”),
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ERNESTO OROZCO MENDEZ, aka Gordo (“MENDEZ”), LUIS GARCIA (“L.
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GARCIA”), ERIK AVINA (“AVINA”), AGUSTIN RODRIGUEZ, aka Dog, aka
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Stranger (“A. RODRIGUEZ”), FRANCISCO ZAMBRANO, aka Noc
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(“ZAMBRANO”), and others were members and associates of an
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organization engaged in, among other things, murder, conspiracy
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to commit murder, attempted murder, conspiracy to traffic in
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narcotics, narcotics trafficking, money laundering, and
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intimidation of witnesses.
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organization, which is known as the Vineland Boys (“VBS”) Gang
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operated in the Central District of California and elsewhere.
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The VBS Gang, including its leadership, membership and
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associates, constituted an “enterprise,” as defined by Title 18,
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United States Code, Section 1961(4), that is a group of
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individuals associated in fact.
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its activities affected, interstate and foreign commerce.
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enterprise constituted an ongoing organization whose members
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functioned as a continuing unit for a common purpose of achieving
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the objectives of the enterprise.
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At all relevant times, this
The enterprise engaged in, and
The
GENERAL BACKGROUND OF THE VBS
2.
The VBS Gang was founded in the late 1980's by members
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of a San Fernando Valley area football team.
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the VBS Gang had absorbed several other local street gangs and
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Within a few years,
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had established itself as one of the most violent street gangs in
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the San Fernando Valley.
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controls a large area in the San Fernando Valley area of the City
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of Los Angeles as well as inside the City of Burbank.
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3.
To date, the VBS Gang operates and
Until 1999, the VBS Gang was controlled by one of its
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founding members, who was killed in 1999.
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other senior gang members who are known as “shot callers” have
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regulated VBS Gang activities.
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activities of the VBS Gang including ordering other gang members
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to conduct the VBS Gang’s illegal activities and controlling the
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illegal distribution of narcotics within the VBS Gang area.
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These illegal activities often are referred to as “work” for the
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neighborhood.
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discipline among its members and associates by murdering,
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attempting to murder, conspiring to murder, assaulting, and
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threatening those members and associates who violate the rules or
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pose a threat to the enterprise.
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4.
Since then, several
Shot callers direct the
The VBS Gang enforces its rules and promotes
Shot callers also control admission to the VBS Gang.
A
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person can be admitted to the VBS Gang only after the approval of
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the shot callers.
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person has participated in a significant number of acts on behalf
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of the VBS Gang.
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has “put in” enough “work” for the neighborhood.
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individuals, however, are admitted to the VBS Gang based upon an
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older relative’s position within the gang or through their long-
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time association with senior VBS Gang members.
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individuals, as with full-fledged VBS Gang members, will “claim”
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VBS Gang membership.
Membership typically depends upon whether the
This often is referred to as whether the person
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Some
These
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The VBS appears to be concentrated mainly in the North
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Eastern end of the San Fernando Valley with Vineland Avenue
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running directly through the heart of their turf.
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enforcement has identified eight distinct cliques of the VBS,
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each of which has its own internal hierarchy.
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the Jokers, Night Owls, Pequenos, Winos, Locos, Dukes, Tiny
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Dukes, and Lake View Terrace.
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6.
Law
These cliques are
The VBS Gang controls drug distribution and other
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illegal activities within the Sun Valley area of Los Angeles.
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addition, shot callers of the VBS have partnered with various
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Mexican national drug trafficking organizations in the VBS area.
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In return for a steady supply of low-priced narcotics, the VBS
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allows these Mexican national organizations to operate within VBS
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territory and provides these organizations with protection from
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other drug traffickers and gang members.
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callers order other narcotics dealers in the area to pay a
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percentage of the proceeds from the sales of narcotics to the VBS
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Gang.
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In
At times, VBS Gang shot
This practice is known as “taxing.”
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Historically, the VBS Gang refused to pay “taxes” to an
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organization known as the “Mexican Mafia,” or “La Eme.”
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Mexican Mafia is an organized group of individuals that controls
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the narcotics and other criminal activities in California’s state
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prisons.
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local street gangs.
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VBS Gang, will pay “taxes” to the Mexican Mafia in order to
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maintain control over their territory and in order to assure
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protection for VBS Gang members incarcerated in California’s
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state prisons.
The
Members of the Mexican Mafia come from the ranks of
Typically, local street gangs, such as the
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Because the VBS Gang historically has failed to pay the
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Mexican Mafia “taxes,” the Mexican Mafia has given other local
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gang members permission to murder or assault VBS Gang members
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without any repercussions or punishment from the Mexican Mafia.
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Such authorization is known as having “green-lighted” the VBS
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Gang.
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overt signs of gang membership, including modes of dress or
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grooming habits that typically would signify belonging to a
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street gang.
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In order to protect themselves, the VBS Gang abandoned
More recently, the VBS Gang has ended the Mexican
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Mafia’s “green-light” by agreeing to pay taxes to the Mexican
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Mafia for their sales of narcotics and by putting in “work”
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(performing illegal activities) for the Mexican Mafia inside
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California State prisons.
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PURPOSES OF THE ENTERPRISE
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The word “member” below refers to a full member of the
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VBS Gang.
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who assist the members are referred to as “associates” of the VBS
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Gang.
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participants in the VBS criminal enterprise.
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Individuals who are affiliated with the VBS Gang and
Both members of the VBS Gang and their associates are
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The purposes of the VBS criminal enterprise includes,
but are not limited to, the following:
a.
Enriching the members of the VBS through, among
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other things, control and participation in the distribution of
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narcotics in VBS territory and elsewhere.
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b.
Expanding the sales of narcotics to different
cities and states within the United States.
c.
Maintaining control over all VBS territory.
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d.
Preserving, protecting, and expanding the power of
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the VBS Gang through the use of intimidation, violence, threats
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of violence, assaults, and murders.
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activities of its members and associates.
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Promoting and enhancing the VBS Gang and the
THE MEANS AND METHODS OF THE ENTERPRISE
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The means and methods by which the defendants and their
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co-racketeers conduct and participate in the conduct of the
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affairs of the VBS criminal enterprise include:
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a.
Members of the VBS Gang use the VBS criminal
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enterprise to commit, and attempt and threaten to commit, acts of
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violence, including murder, to protect and expand the
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enterprise’s criminal operations, which includes the murder of
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police officers and the intimidation of witnesses in criminal
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cases.
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b.
Members of the VBS Gang use the VBS criminal
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enterprise to promote a climate of fear through violence and
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threats of violence.
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c.
Members of the VBS Gang promulgate certain rules
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to be followed by all participants in the VBS criminal
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enterprise, including the rule that a participant in the
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enterprise not act as an informant to law enforcement authorities
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regarding the activities of the enterprise.
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d.
To enforce the rules of the VBS criminal
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enterprise and to promote discipline, the members of the VBS Gang
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use the enterprise to murder, attempt to murder, assault, and
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threaten those participants in the enterprise and others who
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violate the rules or pose a threat to the enterprise.
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e.
To generate income, participants in the VBS
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criminal enterprise are entitled to conduct, and in fact conduct,
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illegal activities under the protection of the enterprise.
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f.
To generate income, participants in the VBS
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criminal enterprise engage in the trafficking of controlled
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substances.
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g.
To further the trafficking of controlled
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substances, the VBS criminal enterprise allies itself with
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Mexican national drug trafficking organizations that operate
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within VBS territory.
h.
To further the trafficking of controlled
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substances, shot callers within the VBS criminal enterprise
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agreed to pay taxes to the Mexican Mafia, thereby removing the
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danger that other gangs would attack members of the VBS criminal
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enterprise as a result of the Mexican Mafia “green light.”
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i.
To perpetuate the VBS criminal enterprise,
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participants in the enterprise attempt to conceal from law
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enforcement the existence of the VBS Gang, the identity of its
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participants, the ways in which it conducts its affairs, and the
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locations at which it discusses and conducts its affairs.
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COUNT ONE
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[18 U.S.C. § 1962(c)]
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1.
Paragraphs One through Twelve of the Introductory
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Allegations are realleged and incorporated by reference as though
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fully set forth herein.
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THE RACKETEERING OFFENSE
2.
Beginning on a date unknown to the Grand Jury, and
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continuing until approximately June 21, 2005, in the Central
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District of California and elsewhere, defendants R. YEPIZ, A.
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SANDOVAL, H. YEPIZ, ARANDA, J. SANDOVAL, L. SANDOVAL, M. YEPIZ,
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CASILLAS, I. HARO, COVARRUBIUS, G. RODRIGUEZ, SAENZ, J. HARO,
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KHAN, AVILA, D. GARCIA, LEDESMA, HERNANDEZ, ROBLEDO, C. VASQUEZ,
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CONTRERAS, CARRASCO, CAMPOS, BARBA, AYALA, BAUTISTA, SANCHEZ,
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MEDINA, MORIN, MACIAS, MENDEZ, L. GARCIA, AVINA, and others known
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and unknown to the Grand Jury, being persons employed by and
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associated with the VBS criminal enterprise described above,
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which was an enterprise engaged in, and the activities of which
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affected, interstate commerce, unlawfully, willfully, and
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knowingly did conduct and participate, directly and indirectly,
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in the conduct of the affairs of that enterprise, through a
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pattern of racketeering activity, that is, through the commission
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of the acts set forth below.
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THE PATTERN OF RACKETEERING ACTIVITY
3.
The pattern of racketeering activity, as defined in
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Title 18, United States Code, Sections 1961(1) and 1961(5),
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consisted of the following acts:
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Racketeering Act One
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Conspiracy to Distribute and Manufacture Narcotics
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4.
Beginning on a date unknown to the Grand Jury and
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continuing to on or about June 21, 2005, in Los Angeles County,
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within the Central District of California, and elsewhere,
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defendants R. YEPIZ, A. SANDOVAL, H. YEPIZ, ARANDA, J. SANDOVAL,
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L. SANDOVAL, M. YEPIZ, CASILLAS, I. HARO, COVARRUBIUS, G.
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RODRIGUEZ, SAENZ, J. HARO, KHAN, AVILA, D. GARCIA, LEDESMA,
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HERNANDEZ, ROBLEDO, C. VASQUEZ, CONTRERAS, CARRASCO, CAMPOS,
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BARBA, AYALA, BAUTISTA, SANCHEZ, MEDINA, MORIN, MACIAS, MENDEZ,
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L. GARCIA, AVINA, and others known and unknown to the Grand Jury,
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conspired and agreed with each other to knowingly and
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intentionally commit the following offenses:
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1.
To distribute at least five kilograms of a mixture
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or substance containing a detectable amount of cocaine, a
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schedule II narcotic drug controlled substance, in violation of
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Title 21, United States Code, Sections 841(a)(1) and
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841(b)(1)(A);
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2.
To distribute at least 500 grams of a mixture or
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substance containing a detectable amount of methamphetamine, or
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at least 50 grams of actual methamphetamine, a schedule II
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controlled substance, in violation of Title 21, United States
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Code, Sections 841(a)(1) and 841(b)(1)(A);
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3.
To distribute at least 1,000 kilograms of a
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mixture or substance containing a detectable amount of marijuana,
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a schedule I controlled substance, in violation of Title 21,
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United States Code, Sections 841(a)(1) and 841(b)(1)(A); and
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4.
To manufacture at least 1,000 marijuana plants, a
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schedule I controlled substance, in violation of Title 21, United
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States Code, Sections 841(a)(1) and 841(b)(1)(A).
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Racketeering Act Two
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Possession with Intent to Distribute Cocaine
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5.
On or about October 13, 1992, in Los Angeles County,
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within the Central District of California, defendants R. YEPIZ
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and H. YEPIZ, knowingly and intentionally possessed with intent
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to distribute approximately 50 grams of a mixture or substance
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containing a detectable amount of cocaine, a schedule II narcotic
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drug controlled substance, in violation of Title 21, United
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States Code, Sections 841(a)(1).
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Racketeering Act Three
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Armed Robbery of JS
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6.
On or about August 16, 1993, in the Central District of
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California, defendants KHAN and AVILA committed an act involving
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robbery, namely, the armed robbery of victim JS at a Bank of
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America Automated Teller Machine, in violation of California
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Penal Code Section 211.
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Racketeering Act Four
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Possession with Intent to Distribute Cocaine
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7.
On or about March 23, 1994, in Los Angeles County,
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within the Central District of California, defendant R. YEPIZ
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knowingly and intentionally possessed with intent to distribute
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at least 500 grams, that is approximately one kilogram, of a
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mixture or substance containing a detectable amount of cocaine, a
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schedule II narcotic drug controlled substance, in violation of
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Title 21, United States Code, Sections 841(a)(1) and
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841(b)(1)(B).
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Racketeering Act Five
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Possession with Intent to Distribute Marijuana
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8.
On or about September 28, 1995, in Los Angeles County,
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within the Central District of California, defendant M. YEPIZ
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knowingly and intentionally possessed with intent to distribute
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approximately 170 pounds of a mixture or substance containing a
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detectable amount of marijuana, a schedule I controlled
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substance, in violation of Title 21, United States Code, Section
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841(a)(1).
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Racketeering Act Six
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Possession with Intent to Distribute Cocaine
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9.
On or about September 18, 1996, in Los Angeles County,
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within the Central District of California, defendant SAENZ
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knowingly and intentionally possessed with intent to distribute
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at least 500 grams, that is, approximately one kilogram, of a
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mixture or substance containing a detectable amount of cocaine, a
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schedule II narcotic drug controlled substance, in violation of
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Title 21, United States Code, Sections 841(a)(1) and
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841(b)(1)(B).
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Racketeering Act Seven
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Possession with Intent to Distribute Cocaine
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10.
On or before July 27, 1999, in the Western District of
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Kentucky, defendants H. YEPIZ and ARANDA knowingly and
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intentionally possessed with intent to distribute more than 500
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grams, that is, approximately three kilograms, of a mixture or
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substance containing a detectable amount of cocaine, a schedule
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II narcotic drug controlled substance, in violation of Title 21,
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United States Code, Sections 841(a)(1) and 841(b)(1)(B).
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Racketeering Act Eight
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Possession with Intent to Distribute Cocaine
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11.
On or about February 21, 2000, in Los Angeles County,
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within the Central District of California, defendant AVINA
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knowingly and intentionally possessed with intent to distribute
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more than 500 grams, that is, approximately 811 grams, of a
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mixture or substance containing a detectable amount of cocaine, a
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schedule II narcotic drug controlled substance, in violation of
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Title 21, United States Code, Sections 841(a)(1) and
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841(b)(1)(B).
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Racketeering Act Nine
12.
The defendants named below committed the following acts
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involving narcotics trafficking, either of which constitute the
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commission of Racketeering Act Nine.
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a.
Possession with Intent to Distribute Cocaine
On or about April 21, 2001, in Los Angeles County, within
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the Central District of California, defendant CARRASCO knowingly
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and intentionally possessed with intent to distribute a mixture
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or substance containing a detectable amount of cocaine, that is,
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approximately 25 grams of cocaine, a schedule II narcotic drug
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controlled substance, in violation of Title 21, United States
2
Code, Sections 841(a)(1).
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b.
Possession with Intent to Distribute Marijuana
On or about April 21, 2001, in Los Angeles County, within
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the Central District of California, defendant CARRASCO knowingly
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and intentionally possessed with intent to distribute a mixture
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or substance containing a detectable amount of marijuana, a
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schedule I controlled substance, in violation of Title 21, United
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States Code, Sections 841(a)(1).
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Racketeering Act Ten
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Attempted Possession with Intent to Distribute Cocaine
13
13.
On or about May 30, 2001, in Los Angeles County, within
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the Central District of California, defendant BAUTISTA knowingly
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and intentionally attempted to possess with intent to distribute
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more than 500 grams, that is, approximately two kilograms, of a
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mixture or substance containing a detectable amount of cocaine, a
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schedule II narcotic drug controlled substance, in violation of
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Title 21, United States Code, Sections 846, 841(a)(1) and
20
841(b)(1)(B).
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Racketeering Act Eleven
14.
The defendant named below committed the following acts
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involving narcotics trafficking, either of which constitute the
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commission of Racketeering Act Eleven.
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a.
Conspiracy to Manufacture Methamphetamine
Beginning on a date unknown to the Grand Jury and continuing
until February 25, 2002, within the Central District of
- 15 -
1
California and elsewhere, defendant G. RODRIGUEZ and others,
2
knowingly and willfully conspired and agreed with each other to
3
commit an offense against the United States, namely, to
4
manufacture at least 500 grams of a mixture or substance
5
containing a detectable amount of methamphetamine, a Schedule II
6
controlled substance, in violation of Title 21, United States
7
Code, Sections 841(a)(1) and 841(b)(1)(A).
8
9
b.
Possession of a Listed Chemical
On or about February 25, 2002, in Los Angeles County, within
10
the Central District of California, defendant G. RODRIGUEZ
11
knowingly and intentionally possessed pseudoephedrine, a list I
12
chemical, knowing and having reasonable cause to believe that the
13
pseudoephedrine would be used to manufacture a controlled
14
substance, namely, methamphetamine, a schedule II controlled
15
substance, in violation of Title 21, United States Code, Sections
16
841(c)(2).
17
18
Racketeering Act Twelve
19
Possession with Intent to Distribute Methamphetamine
20
15.
On or about June 27, 2002, in Los Angeles County,
21
within the Central District of California, defendant A. SANDOVAL
22
knowingly and intentionally possessed with intent to distribute
23
more than 500 grams, that is, approximately five pounds, of a
24
mixture or substance containing a detectable amount of
25
methamphetamine, a schedule II controlled substance, in violation
26
of Title 21, United States Code, Sections 841(a)(1) and
27
841(b)(1)(A).
28
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1
Racketeering Act Thirteen
2
Possession with Intent to Distribute Cocaine
3
16.
On or about August 1, 2002, in Los Angeles County,
4
within the Central District of California, defendant CAMPOS
5
knowingly and intentionally possessed with intent to distribute
6
at least five kilograms, that is, approximately five kilograms,
7
of a mixture or substance containing a detectable amount of
8
cocaine, a schedule II narcotic drug controlled substance, in
9
violation of Title 21, United States Code, Sections 841(a)(1) and
10
841(b)(1)(A).
11
12
Racketeering Act Fourteen
13
Possession with Intent to Distribute Methamphetamine
14
17.
On or about April 24, 2003, in Los Angeles County,
15
within the Central District of California, defendant I. HARO
16
knowingly and intentionally possessed with intent to distribute,
17
at least 50 grams, that is, approximately 101.5 grams, of actual
18
methamphetamine, a schedule II controlled substance, in violation
19
of Title 21, United States Code, Sections 841(a)(1) and
20
841(b)(1)(A).
21
22
23
Racketeering Act Fifteen
18.
The defendants named below committed the following acts
24
involving murder, either one of which constitutes the commission
25
of Racketeering Act Fifteen:
26
27
28
a.
Conspiracy to Murder MP
Beginning on a date unknown to the Grand Jury and continuing
until May 12, 2003, in the Central District of California and
- 17 -
1
elsewhere, defendants L. SANDOVAL, COVARRUBIUS, LEDESMA, ROBLEDO,
2
and others, conspired to murder MP, and a co-conspirator
3
committed an overt act in furtherance of the conspiracy, in
4
violation of California Penal Code Sections 182 and 187.
5
b.
Murder of MP
6
On or about May 12, 2003, in the Central District of
7
California and elsewhere, defendants L. SANDOVAL, COVARRUBIUS,
8
LEDESMA, ROBLEDO, and others, unlawfully, willfully,
9
deliberately, maliciously, and with premeditation and malice
10
aforethought, did aid, abet, advice, encourage, and otherwise
11
willfully participate in the murder of MP, in violation of
12
California Penal Code Sections 31 and 187.
13
14
15
Racketeering Act Sixteen
19.
The defendants named below committed the following acts
16
involving murder, either one of which constitutes the commission
17
of Racketeering Act Sixteen:
18
19
a.
Conspiracy to Murder EC
Beginning on a date unknown to the Grand Jury and continuing
20
until August 12, 2003, in the Central District of California and
21
elsewhere, defendants H. YEPIZ, G. RODRIGUEZ, and others,
22
conspired to murder EC, and a co-conspirator committed an overt
23
act in furtherance of the conspiracy, in violation of California
24
Penal Code Sections 182 and 187.
25
26
b.
Murder of EC
On or about August 12, 2003, in the Central District of
27
California and elsewhere, defendants H. YEPIZ and G. RODRIGUEZ,
28
unlawfully, willfully, deliberately, maliciously, and with
- 18 -
1
premeditation and malice aforethought, did aid, abet, advice,
2
encourage and otherwise willfully participate in the murder of
3
EC, in violation of California Penal Code Sections 31 and 187.
4
5
Racketeering Act Seventeen
6
Murder of a Burbank Police Department Officer MP
7
20.
On or about November 15, 2003, in the Central District
8
of California, defendant D. GARCIA and deceased co-conspirator RA
9
unlawfully, willfully, deliberately, maliciously, and with
10
premeditation and malice aforethought, did aid, abet, advise,
11
encourage, and otherwise willfully participate in the murder of
12
Burbank Police Department Officer MP, in violation of California
13
Penal Code Sections 31 and 187.
14
15
Racketeering Act Eighteen
16
Attempted Murder of Burbank Police Department Officer GC
17
21.
On or about November 15, 2003, in the Central District
18
of California and elsewhere, defendant D. GARCIA and deceased co-
19
conspirator RA unlawfully with malice aforethought did aid, abet
20
advise, encourage, and otherwise willfully participate in the
21
attempted murder of Burbank Police Officer GC, in violation of
22
California Penal Code Sections 21a, 31, 664, and 187.
23
24
Racketeering Act Nineteen
25
Possession with Intent to Distribute Methamphetamine
26
22.
On or about November 15, 2003, in Los Angeles County,
27
within the Central District of California, defendant D. GARCIA
28
knowingly and intentionally possessed with intent to distribute
- 19 -
1
at least 50 grams, namely, approximately 101 grams, of actual
2
methamphetamine, a schedule II controlled substance, in violation
3
of Title 21, United States Code, Sections 841(a)(1) and
4
841(b)(1)(A).
5
6
Racketeering Act Twenty
7
Possession With Intent To Distribute Marijuana
8
9
23.
On or about November 16, 2003, in Los Angeles County,
within the Central District of California, defendant AVILA
10
knowingly and intentionally possessed with intent to distribute
11
approximately 131 grams of a mixture or substance containing a
12
detectable amount of marijuana, a schedule I controlled
13
substance, in violation of Title 21, United States Code, Sections
14
841(a)(1).
15
16
Racketeering Act Twenty-One
17
Attempted Manufacture of Marijuana
18
24.
On or about November 26, 2003, in Los Angeles County,
19
within the Central District of California, defendant L. SANDOVAL
20
knowingly and intentionally attempted to manufacture at least
21
1,000 marijuana plants, a Schedule I controlled substance, in
22
violation of Title 21, United States Code, Sections 846,
23
841(a)(1) and 841(b)(1)(A).
24
25
26
Racketeering Act Twenty-Two
25.
The defendant named below committed the following acts
27
involving narcotics trafficking, any of which constitute the
28
commission of Racketeering Act Twenty-Two:
- 20 -
1
2
a.
Possession with Intent to Distribute Cocaine
On or about March 16, 2004, in Los Angeles County, within
3
the Central District of California, defendant HERNANDEZ knowingly
4
and intentionally possessed with intent to distribute
5
approximately 10 grams of a mixture or substance containing a
6
detectable amount of cocaine, a schedule II narcotic drug
7
controlled substance, in violation of Title 21, United States
8
Code, Sections 841(a)(1) and 841(b)(1)(C).
9
10
b.
Possession with Intent to Distribute Marijuana
On or about March 16, 2004, in Los Angeles County, within
11
the Central District of California, defendant HERNANDEZ knowingly
12
and intentionally possessed with intent to distribute
13
approximately 33 pounds of a mixture or substance containing a
14
detectable amount of marijuana, a schedule I controlled
15
substance, in violation of Title 21, United States Code, Sections
16
841(a)(1) and 841(b)(1)(C).
17
18
c.
Possession with Intent to Distribute Heroin
On or about March 16, 2004, in Los Angeles County, within
19
the Central District of California, defendant HERNANDEZ knowingly
20
and intentionally possessed with intent to distribute
21
approximately 37 grams of a mixture or substance containing a
22
detectable amount of heroin, a schedule I narcotic drug
23
controlled substance, in violation of Title 21, United States
24
Code, Section 841(a)(1).
25
26
27
28
- 21 -
1
Racketeering Act Twenty-Three
2
Possession with Intent to Distribute Methamphetamine; Aiding and
3
Abetting
4
26.
On or about September 24, 2004, in Los Angeles County,
5
within the Central District of California, defendant ARANDA
6
knowingly and intentionally possessed with intent to distribute
7
at least 50 grams of actual methamphetamine, a schedule II
8
controlled substance, in violation of Title 21, United States
9
Code, Sections 841(a)(1) and 841(b)(1)(A).
10
Defendant CASILLAS knowingly and intentionally aided,
11
abetted, counseled, commanded, induced, and procured the
12
commission of this offense, in violation of Title 18, United
13
States Code, Section 2.
14
15
16
Racketeering Act Twenty-Four
27.
The defendants named below committed the following acts
17
involving narcotics trafficking, any of which constitute the
18
commission of Racketeering Act Twenty-Four:
19
a.
Distribution of Cocaine; Aiding and Abetting
20
On or about September 28, 2004, in Los Angeles County,
21
within the Central District of California, defendant J. SANDOVAL
22
knowingly and intentionally distributed more than 500 grams, that
23
is, approximately four kilograms, of a mixture or substance
24
containing a detectable amount of cocaine, a schedule II narcotic
25
drug controlled substance, in violation of Title 21, United
26
States Code, Sections 841(a)(1) and 841(b)(1)(B).
27
28
Defendant R. YEPIZ knowingly and intentionally aided,
abetted, counseled, commanded, induced, and procured the
- 22 -
1
commission of this offense, in violation of Title 18, United
2
States Code, Section 2.
3
b.
4
5
Possession with Intent to Distribute Cocaine;
Aiding and Abetting
On or about September 28, 2004, in Los Angeles County,
6
within the Central District of California, defendant MORIN
7
knowingly and intentionally possessed with intent to distribute
8
at least 500 grams, that is approximately four kilograms, of a
9
mixture or substance containing a detectable amount of cocaine, a
10
schedule II narcotic drug controlled substance, in violation of
11
Title 21, United States Code, Sections 841(a)(1) and
12
841(b)(1)(B).
13
Defendant R. YEPIZ knowingly and intentionally aided,
14
abetted, counseled, commanded, induced, and procured the
15
commission of this offense, in violation of Title 18, United
16
States Code, Section 2.
17
c.
18
19
Attempted Possession with Intent to Distribute
Cocaine
On or about September 28, 2004, in Los Angeles County,
20
within the Central District of California, defendant AYALA
21
knowingly and intentionally attempted to possess with intent to
22
distribute more than 500 grams, that is, approximately one
23
kilogram, of a mixture or substance containing a detectable
24
amount of cocaine, a schedule II narcotic drug controlled
25
substance, in violation of Title 21, United States Code, Sections
26
846, 841(a)(1) and 841(b)(1)(B).
27
28
- 23 -
1
2
Racketeering Act Twenty-Five
28.
The defendants named below committed the following acts
3
involving narcotics trafficking, either of which constitute the
4
commission of Racketeering Act Twenty-Five:
5
a.
Distribution of Cocaine
6
On or about October 3, 2004, in Los Angeles County, within
7
the Central District of California, defendant SANCHEZ knowingly
8
and intentionally distributed more than 500 grams, that is,
9
approximately one kilogram, of a mixture or substance containing
10
a detectable amount of cocaine, a schedule II narcotic drug
11
controlled substance, in violation of Title 21, United States
12
Code, Sections 841(a)(1) and 841(b)(1)(B).
13
Defendant R. YEPIZ knowingly and intentionally aided,
14
abetted, counseled, commanded, induced, and procured the
15
commission of this offense, in violation of Title 18, United
16
States Code, Section 2.
17
b.
18
19
Possession with Intent to Distribute Cocaine;
Aiding and Abetting
On or about October 3, 2004, in Los Angeles County, within
20
the Central District of California, defendant AYALA knowingly and
21
intentionally possessed with intent to distribute at least 500
22
grams, that is approximately one kilogram, of a mixture or
23
substance containing a detectable amount of cocaine, a schedule
24
II narcotic drug controlled substance, in violation of Title 21,
25
United States Code, Sections 841(a)(1) and 841(b)(1)(B).
26
Defendant R. YEPIZ knowingly and intentionally aided,
27
abetted, counseled, commanded, induced, and procured the
28
commission of this offense, in violation of Title 18, United
- 24 -
1
States Code, Section 2.
2
3
Racketeering Act Twenty-Six
4
Distribution of Cocaine
5
29.
On or about October 11, 2004, in Los Angeles County,
6
within the Central District of California, defendants R. YEPIZ,
7
SANCHEZ, and MORIN knowingly and intentionally distributed more
8
than 500 grams, that is, approximately three kilograms, of a
9
mixture or substance containing a detectable amount of cocaine, a
10
schedule II narcotic drug controlled substance, in violation of
11
Title 21, United States Code, Sections 841(a)(1) and
12
841(b)(1)(B).
13
14
Racketeering Act Twenty-Seven
15
Attempted Murder of MM
16
30.
On or about October 20, 2004, in the Central District
17
of California and elsewhere, defendant COVARRUBIUS unlawfully
18
with malice aforethought did aid, abet, advise, encourage and
19
otherwise willfully participate in the attempted murder of MM, in
20
violation of California Penal Code Sections 21a, 31, 664, and
21
187.
22
23
24
Racketeering Act Twenty-Eight
31.
The defendants named below committed the following acts
25
involving narcotics trafficking, either of which constitute the
26
commission of Racketeering Act Twenty-Eight:
27
28
a.
Distribution of Cocaine
On or about November 5, 2004, in Los Angeles County, within
- 25 -
1
the Central District of California, defendant SAENZ knowingly and
2
intentionally distributed more than 500 grams, that is,
3
approximately one kilogram, of a mixture or substance containing
4
a detectable amount of cocaine, a schedule II narcotic drug
5
controlled substance, in violation of Title 21, United States
6
Code, Sections 841(a)(1) and 841(b)(1)(B).
7
8
9
b.
Distribution of Cocaine
On or about November 5, 2004, in Los Angeles County, within
the Central District of California, defendant MORIN knowingly and
10
intentionally distributed more than 500 grams, that is,
11
approximately 509 grams, of a mixture or substance containing a
12
detectable amount of cocaine, a schedule II narcotic drug
13
controlled substance, in violation of Title 21, United States
14
Code, Sections 841(a)(1) and 841(b)(1)(B).
15
16
Racketeering Act Twenty-Nine
17
Distribution of Cocaine; Aiding and Abetting
18
On or about November 16, 2004, in Los Angeles County, within
19
the Central District of California, defendant J. SANDOVAL
20
knowingly and intentionally distributed more than 500 grams, that
21
is, approximately one kilogram, of a mixture or substance
22
containing a detectable amount of cocaine, a schedule II narcotic
23
drug controlled substance, in violation of Title 21, United
24
States Code, Sections 841(a)(1) and 841(b)(1)(B).
25
Defendant BARBA knowingly and intentionally aided, abetted,
26
counseled, commanded, induced, and procured the commission of
27
this offense, in violation of Title 18, United States Code,
28
Section 2.
- 26 -
1
2
Racketeering Act Thirty
32.
The defendants named below committed the following acts
3
involving narcotics trafficking, either of which constitute the
4
commission of Racketeering Act Thirty:
5
6
a.
Possession With Intent to Distribute Cocaine
On or about November 19, 2004, in Los Angeles County, within
7
the Central District of California, defendants MACIAS and L.
8
GARCIA knowingly and intentionally possessed with intent to
9
distribute at least five kilograms, that is, approximately five
10
kilograms, of a mixture or substance containing a detectable
11
amount of cocaine, a schedule II narcotic drug controlled
12
substance, in violation of Title 21, United States Code, Sections
13
841(a)(1) and 841(b)(1)(A).
14
b.
15
Use of a Communication Facility to Facilitate
Narcotics Distribution on November 19, 2004
16
On or about November 19, 2004, within the Central District
17
of California and elsewhere, defendants CASILLAS, MACIAS and L.
18
GARCIA knowingly and intentionally used a communication facility,
19
namely, a telephone, in causing or facilitating the commission of
20
acts constituting a felony under the Controlled Substances Act,
21
that is, possession with intent to distribute a controlled
22
substance, in violation of Title 21, United States Code, Section
23
841(a)(1), all in violation of Title 21, United States Code,
24
Section 843(b).
25
26
27
28
- 27 -
1
Racketeering Act Thirty-One
2
Use of a Communication Facility on November 29, 2004 to
3
Facilitate Narcotics Distribution
4
33.
On or about November 29, 2004, within the Central
5
District of California and elsewhere, defendants CASILLAS and
6
HERNANDEZ knowingly and intentionally used a communication
7
facility, namely, a telephone, in causing or facilitating the
8
commission of acts constituting a felony under the Controlled
9
Substances Act, that is, distribution of a controlled substance,
10
in violation of Title 21, United States Code, Section 841(a)(1),
11
all in violation of Title 21, United States Code, Section 843(b).
12
13
Racketeering Act Thirty-Two
14
Possession with Intent to Distribute Methamphetamine; Aiding and
15
Abetting
16
34.
On or about November 30, 2004, in Los Angeles County,
17
within the Central District of California, defendant ARANDA
18
knowingly and intentionally possessed with intent to distribute
19
at least 500 grams, that is approximately two pounds, of a
20
mixture or substance containing a detectable amount of
21
methamphetamine, a schedule II controlled substance, in violation
22
of Title 21, United States Code, Sections 841(a)(1) and
23
841(b)(1)(A).
24
Defendant CASILLAS knowingly and intentionally aided,
25
abetted, counseled, commanded, induced, and procured the
26
commission of this offense, in violation of Title 18, United
27
States Code, Section 2.
28
- 28 -
1
Racketeering Act Thirty-Three
2
Use of a Communication Facility to Facilitate Narcotics
3
Distribution on December 19, 2004
4
35.
On or about December 19, 2004, within the Central
5
District of California and elsewhere, defendant CARRASCO
6
knowingly and intentionally used a communication facility,
7
namely, a telephone, in causing or facilitating the commission of
8
acts constituting a felony under the Controlled Substances Act,
9
that is, distribution of a controlled substance, in violation of
10
Title 21, United States Code, Section 841(a)(1), all in violation
11
of Title 21, United States Code, Section 843(b).
12
13
14
Racketeering Act Thirty-Four
36.
The defendant named below committed the following acts
15
involving narcotics trafficking, either of which constitute the
16
commission of Racketeering Act Thirty-Four:
17
18
a.
Possession with Intent to Distribute Cocaine Base
On or about December 21, 2004, in Los Angeles County, within
19
the Central District of California, defendant MEDINA knowingly
20
and intentionally possessed with intent to distribute more than
21
50 grams, that is, approximately 51 grams, of a mixture or
22
substance containing a detectable amount of cocaine base (crack),
23
a schedule II narcotic drug controlled substance, in violation of
24
Title 21, United States Code, Sections 841(a)(1) and
25
841(b)(1)(A).
26
27
28
b.
Possession with Intent to Distribute
Methamphetamine
On or about December 21, 2004, in Los Angeles County, within
- 29 -
1
the Central District of California, defendant MEDINA knowingly
2
and intentionally possessed with intent to distribute more than 5
3
grams, that is, approximately 5 grams, of actual methamphetamine,
4
a schedule II controlled substance, in violation of Title 21,
5
United States Code, Sections 841(a)(1) and 841(b)(1)(B).
6
7
8
9
10
11
12
Racketeering Act Thirty-Five
37.
The defendants named below committed the following acts
involving narcotics trafficking, either of which constitute the
commission of Racketeering Act Thirty-Five:
a.
Distribution of Cocaine
On or about December 23, 2004, in Los Angeles County, within
13
the Central District of California, defendant KHAN knowingly and
14
intentionally distributed approximately eight grams of a mixture
15
or substance containing a detectable amount of cocaine, a
16
schedule II narcotic drug controlled substance, in violation of
17
Title 21, United States Code, Section 841(a)(1).
18
19
b.
Distribution of Methamphetamine
On or about December 23, 2004, in Los Angeles County, within
20
the Central District of California, defendant KHAN knowingly and
21
intentionally distributed approximately three grams of a mixture
22
or substance containing a detectable amount of methamphetamine, a
23
schedule II controlled substance, in violation of Title 21,
24
United States Code, Section 841(a)(1).
25
26
27
28
- 30 -
1
Racketeering Act Thirty-Six
2
Possession With Intent to Distribute Methamphetamine
3
38.
On or about January 6, 2005, in Los Angeles County,
4
within the Central District of California, defendants R. YEPIZ,
5
J. SANDOVAL, and I. HARO knowingly and intentionally possessed
6
with intent to distribute at least 50 grams, that is,
7
approximately two pounds, of actual methamphetamine, a schedule
8
II controlled substance, in violation of Title 21, United States
9
Code, Sections 841(a)(1) and 841(b)(1)(A).
10
11
12
Racketeering Act Thirty-Seven
39.
The defendants named below committed the following acts
13
involving narcotics trafficking, any of which constitute the
14
commission of Racketeering Act Thirty-Seven:
15
a.
Possession with Intent to Distribute Cocaine
16
On or about January 17, 2005, in Los Angeles County, within
17
the Central District of California, defendants CASILLAS, MACIAS,
18
MENDEZ, and L. GARCIA knowingly and intentionally possession with
19
intent to distribute at least five kilograms, that is
20
approximately 53 kilograms, of a mixture or substance containing
21
a detectable amount of cocaine, a schedule II narcotic drug
22
controlled substance, in violation of Title 21, United States
23
Code, Sections 841(a)(1) and 841(b)(1)(A).
24
b.
Possession With Intent to Distribute Cocaine
25
On or about January 18, 2005, in Los Angeles County, within
26
the Central District of California, defendants CASILLAS, MACIAS,
27
MENDEZ, and L. GARCIA knowingly and intentionally possessed with
28
intent to distribute at least 500 grams, that is, approximately
- 31 -
1
one kilogram, of a mixture or substance containing a detectable
2
amount of cocaine, a schedule II narcotic drug controlled
3
substance, in violation of Title 21, United States Code, Sections
4
841(a)(1) and 841(b)(1)(B).
5
6
c.
Distribution of Marijuana
On or about January 18, 2005, in Los Angeles County, within
7
the Central District of California, defendant L. GARCIA knowingly
8
and intentionally distributed approximately 5 pounds of a mixture
9
or substance containing a detectable amount of marijuana, a
10
schedule I controlled substance, in violation of Title 21, United
11
States Code, Sections 841(a)(1).
12
d.
Possession With Intent to Distribute Marijuana
13
On or about January 18, 2005, in Los Angeles County, within
14
the Central District of California, defendants CASILLAS, MACIAS,
15
and L. GARCIA knowingly and intentionally possessed with intent
16
to distribute approximately 111 pounds of a mixture or substance
17
containing a detectable amount of marijuana, a schedule I
18
controlled substance, in violation of Title 21, United States
19
Code, Sections 841(a)(1).
20
21
Racketeering Act Thirty-Eight
22
Attempted Murder of OG
23
40.
On or about January 19, 2005, in the Central District
24
of California and elsewhere, defendant ARANDA, and others,
25
unlawfully with malice aforethought did aid, abet advise,
26
encourage and otherwise willfully participate in the attempted
27
murder of OG, in violation of California Penal Code Sections 21a,
28
31, 664, and 187.
- 32 -
1
Racketeering Act Thirty-Nine
2
Attempt to Intimidate Witness TM
3
41.
On or about January 20, 2005, in Los Angeles County,
4
within the Central District of California, an unindicted co-
5
conspirator intimidated another person, witness TM, by the
6
threatened use of physical force, with intent to influence,
7
delay, or prevent the testimony of witness TM in an official
8
proceeding, in violation of Title 18, United States Code,
9
Sections 1512(a)(2).
10
11
Defendant LEDESMA willfully caused the commission of this
offense, in violation of Title 18, United States Code, Section 2.
12
13
Racketeering Act Forty
14
Possession with Intent to Distribute Methamphetamine; Aiding and
15
Abetting
16
42.
On or about January 25, 2005, in Los Angeles County,
17
within the Central District of California, defendant ARANDA
18
knowingly and intentionally possessed with intent to distribute
19
at least 500 grams, that is approximately two pounds, of a
20
mixture or substance containing a detectable amount of
21
methamphetamine, a schedule II controlled substance, in violation
22
of Title 21, United States Code, Sections 841(a)(1) and
23
841(b)(1)(A).
24
Defendant CASILLAS knowingly and intentionally aided,
25
abetted, counseled, commanded, induced, and procured the
26
commission of this offense, in violation of Title 18, United
27
States Code, Section 2.
28
- 33 -
1
2
Racketeering Act Forty-One
43.
The defendants named below committed the following acts
3
involving narcotics trafficking, either of which constitute the
4
commission of Racketeering Act Forty-One:
5
6
a.
Distribution of Methamphetamine
On or before February 24, 2005, in Los Angeles County,
7
within the Central District of California, defendant I. HARO
8
knowingly and intentionally distributed more than 50 grams, that
9
is, approximately 112 grams, of a mixture of substance containing
10
a detectable amount of methamphetamine, a schedule II controlled
11
substance, in violation of Title 21, United States Code, Sections
12
841(a)(1) and 841(b)(1)(B).
13
b.
14
15
Possession with Intent to Distribute
Methamphetamine
On or about February 24, 2005, in Los Angeles County, within
16
the Central District of California, defendant CASILLAS knowingly
17
and intentionally possessed with intent to distribute more than
18
50 grams, that is, approximately 112 grams, of a mixture of
19
substance containing a detectable amount of methamphetamine, a
20
schedule II controlled substance, in violation of Title 21,
21
United States Code, Sections 841(a)(1) and 841(b)(1)(B).
22
23
Racketeering Act Forty-Two
24
Possession with Intent to Distribute Cocaine
25
44.
On or about February 28, 2005, in Los Angeles County,
26
within the Central District of California, defendants SAENZ and
27
C. VASQUEZ knowingly and intentionally possessed with intent to
28
distribute at least five kilograms, that is approximately 13
- 34 -
1
kilograms, of a mixture or substance containing a detectable
2
amount of cocaine, a schedule II narcotic drug controlled
3
substance, in violation of Title 21, United States Code, Sections
4
841(a)(1) and 841(b)(1)(A).
5
6
7
Racketeering Act Forty-Three
45.
The defendants named below committed the following acts
8
involving narcotics trafficking, any of which constitute the
9
commission of Racketeering Act Forty-Three:
10
11
a.
Possession with Intent to Distribute Marijuana
On or about March 1, 2005, in Los Angeles County, within the
12
Central District of California, defendant R. YEPIZ knowingly and
13
intentionally possessed with intent to distribute more than 100
14
kilograms, that is approximately 300 pounds of a mixture or
15
substance containing a detectable amount of marijuana, a schedule
16
I controlled substance, in violation of Title 21, United States
17
Code, Sections 841(a)(1) and 841(b)(1)(B).
18
19
b.
Distribution of Marijuana
On or about March 1, 2005, in Los Angeles County, within the
20
Central District of California, defendant R. YEPIZ knowingly and
21
intentionally aided, abetted, counseled, commanded, induced,
22
procured, and willfully caused another to distribute
23
approximately 78 pounds of a mixture or substance containing a
24
detectable amount of marijuana, a schedule I controlled
25
substance, in violation of Title 21, United States Code, Section
26
841(a)(1) and Title 18, United States Code, Section 2.
27
28
c.
Possession with Intent to Distribute Marijuana
On or about March 1, 2005, in Los Angeles County, within the
- 35 -
1
Central District of California, defendant C. VASQUEZ knowingly
2
and intentionally possessed with intent to distribute
3
approximately 78 pounds of a mixture or substance containing a
4
detectable amount of marijuana, a schedule I controlled
5
substance, in violation of Title 21, United States Code, Section
6
841(a)(1).
7
8
9
Racketeering Act Forty-Four
46.
The defendants named below committed the following acts
10
involving narcotics trafficking, either of which constitute the
11
commission of Racketeering Act Forty-Four:
12
13
a.
Possession with Intent to Distribute Cocaine
On or about March 2, 2005, in Los Angeles County, within the
14
Central District of California, defendants SAENZ and C. VASQUEZ
15
knowingly and intentionally possessed with intent to distribute
16
at least five kilograms, that is approximately eight kilograms,
17
of a mixture or substance containing a detectable amount of
18
cocaine, a schedule II narcotic drug controlled substance, in
19
violation of Title 21, United States Code, Sections 841(a)(1) and
20
841(b)(1)(A).
21
22
b.
Possession with Intent to Distribute Cocaine
On or about March 2, 2005, in Los Angeles County, within the
23
Central District of California, defendants R. YEPIZ and CAMPOS
24
knowingly and intentionally possessed with intent to distribute
25
at least 500 grams, that is approximately two kilograms, of a
26
mixture or substance containing a detectable amount of cocaine, a
27
schedule II narcotic drug controlled substance, in violation of
28
Title 21, United States Code, Sections 841(a)(1) and
- 36 -
1
841(b)(1)(B).
2
3
Racketeering Act Forty-Five
4
Possession with Intent to Distribute Methamphetamine
5
47.
On or about March 4, 2005, in Los Angeles County,
6
within the Central District of California, defendant CONTRERAS
7
knowingly and intentionally possessed with intent to distribute
8
at least 50 grams, that is approximately 100 grams, of actual
9
methamphetamine, a schedule II controlled substance, in violation
10
of Title 21, United States Code, Sections 841(a)(1) and
11
841(b)(1)(A).
12
13
Racketeering Act Forty-Six
14
Distribution of Marijuana; Aiding and Abetting
15
48.
On or about March 19, 2005, in Los Angeles County,
16
within the Central District of California, defendant MEDINA
17
knowingly and intentionally distributed approximately one pound
18
of a mixture or substance containing a detectable amount of
19
marijuana, a schedule I controlled substance, in violation of
20
Title 21, United States Code, Sections 841(a)(1).
21
Defendants CASILLAS and BAUTISTA knowingly and intentionally
22
aided, abetted, counseled, commanded, induced, and procured the
23
commission of this offense, in violation of Title 18, United
24
States Code, Section 2.
25
26
27
28
- 37 -
1
Racketeering Act Forty-Seven
2
Use of a Communication Facility to Facilitate Narcotics
3
Distribution on March 24, 2005
4
49.
On or about March 24, 2005, within the Central District
5
of California and elsewhere, defendants CASILLAS and BARBA
6
knowingly and intentionally used a communication facility,
7
namely, a telephone, in causing or facilitating the commission of
8
acts constituting a felony under the Controlled Substances Act,
9
that is, conspiracy to distribute a controlled substance, in
10
violation of Title 21, United States Code, Sections 846 and
11
841(a)(1), all in violation of Title 21, United States Code,
12
Section 843(b).
13
14
Racketeering Act Forty-Eight
15
Possession with Intent to Distribute Methamphetamine
16
50.
On or about March 30, 2005, within the Central District
17
of California and elsewhere, defendants M. YEPIZ and CONTRERAS
18
knowingly and intentionally used a communication facility,
19
namely, a telephone, in causing or facilitating the commission of
20
acts constituting a felony under the Controlled Substances Act,
21
that is, conspiracy to distribute a controlled substance, in
22
violation of Title 21, United States Code, Sections 846 and
23
841(a)(1), all in violation of Title 21, United States Code,
24
Section 843(b).
25
26
Racketeering Act Forty-Nine
27
Distribution of Cocaine; Aiding and Abetting
28
51.
On or about April 1, 2005, in Los Angeles County,
- 38 -
1
within the Central District of California, defendant MEDINA
2
knowingly and intentionally distributed at least 500 grams, that
3
is, approximately one-half kilogram, of a mixture or substance
4
containing a detectable amount of cocaine, a schedule II narcotic
5
drug controlled substance, in violation of Title 21, United
6
States Code, Sections 841(a)(1) and 841(b)(1)(B).
7
Defendant CASILLAS knowingly and intentionally aided,
8
abetted, counseled, commanded, induced, and procured the
9
commission of this offense, in violation of Title 18, United
10
States Code, Section 2.
11
12
Racketeering Act Fifty
13
Possession with Intent to Distribute Methamphetamine
14
52.
On or about April 25, 2005, in Los Angeles County,
15
within the Central District of California, and elsewhere,
16
defendant J. SANDOVAL, I. HARO, and J. HARO knowingly and
17
intentionally possessed with intent to distribute at least 500
18
grams, that is, approximately two pounds, of a mixture or
19
substance containing a detectable amount of methamphetamine, a
20
schedule II controlled substance, in violation of Title 21,
21
United States Code, Sections 841(a)(1) and 841(b)(1)(A).
22
23
Racketeering Act Fifty-One
24
Use of a Communication Facility to Facilitate Narcotics
25
Distribution on April 28, 2005
26
53.
On or about April 28, 2005, within the Central District
27
of California and elsewhere, defendants I. HARO and J. HARO
28
knowingly and intentionally used a communication facility,
- 39 -
1
namely, a telephone, in causing or facilitating the commission of
2
acts constituting a felony under the Controlled Substances Act,
3
that is, conspiracy to distribute a controlled substance, in
4
violation of Title 21, United States Code, Sections 846 and
5
841(a)(1), all in violation of Title 21, United States Code,
6
Section 843(b).
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 40 -
1
COUNT TWO
2
[18 U.S.C. § 1962(d)
3
1.
Paragraphs one through Twelve of the Introductory
4
Allegations of this Indictment are realleged and incorporated by
5
reference as though fully set forth herein.
6
2.
Beginning on a date unknown to the Grand Jury, and
7
continuing until June 21, 2005, in the Central District of
8
California and elsewhere, defendants R. YEPIZ, A. SANDOVAL, H.
9
YEPIZ, ARANDA, J. SANDOVAL, L. SANDOVAL, M. YEPIZ, CASILLAS, I.
10
HARO, COVARRUBIUS, G. RODRIGUEZ, SAENZ, J. HARO, KHAN, AVILA, D.
11
GARCIA, LEDESMA, HERNANDEZ, ROBLEDO, C. VASQUEZ, CONTRERAS,
12
CARRASCO, CAMPOS, BARBA, AYALA, BAUTISTA, SANCHEZ, MEDINA, MORIN,
13
MACIAS, MENDEZ, L. GARCIA, AVINA, A. RODRIGUEZ, ZAMBRANO, and
14
others, being persons employed by and associated with the VBS
15
criminal enterprise described in Paragraphs One through Twelve of
16
the Introductory Allegations of this indictment, which
17
constitutes an “enterprise,” as defined in Title 18, United
18
States Code, Section 1961(4), which enterprise affected
19
interstate and foreign commerce, unlawfully, willfully, and
20
knowingly combined, conspired, confederated, and agreed together
21
and with each other to violate Title 18, United States Code,
22
Section 1962(c), that is to conduct and participate, directly and
23
indirectly, in the conduct of the affairs of the enterprise
24
through a pattern of racketeering activity, as that term is
25
defined in Title 18, United States Code, Sections 1961(1) and
26
1961(5), consisting of multiple acts involving murder, in
27
violation California Penal Code Sections 31 and 187; distribution
28
of controlled substances, including cocaine, methamphetamine, and
- 41 -
1
marijuana, in violation of Title 21, United States Code, Sections
2
841(a)(1), 843(b), and 846; money laundering, in violation of
3
Title 18, United States Code, Sections 1956 and 1957, and witness
4
intimidation, in violation of Title 18, United States Code
5
Section 1512.
6
defendants agreed that a conspirator would commit at least two
7
acts of racketeering in the conduct of the affairs of the
8
enterprise.
9
10
It was a further part of the conspiracy that the
OVERT ACTS
In furtherance of the conspiracy and to accomplish the
11
objects of the conspiracy, the defendants and their
12
coconspirators committed the following overt acts in Los Angeles
13
County, within the Central District of California, unless
14
otherwise specified, on or about the dates set forth below:
15
1.
On October 13, 1992, defendants R. YEPIZ and H. YEPIZ
16
possessed approximately two ounces of cocaine, five pounds of
17
marijuana, a gun, and $5,525 in United States currency at their
18
residence.
19
2.
On August 16, 1993, defendant AVILA approached victim
20
JS, brandished a firearm, and told him to remove money from an
21
automatic teller machine (“ATM”).
22
3.
On August 16, 1993, defendant AVILA tapped victim JS on
23
the back of his head with a handgun and told him to hurry up in
24
withdrawing money from an ATM.
25
4.
On August 16, 1993, while defendant AVILA was taking
26
approximately $300 in United States currency from victim JS,
27
defendant KHAN removed a handgun from his waistband and pulled
28
the slide to the gun, which placed a bullet into the chamber.
- 42 -
1
2
3
4
5
5.
On August 17, 1993, defendants KHAN and AVILA each
carried semi-automatic guns.
6.
On March 23, 1994, defendant R. YEPIZ possessed
approximately one kilogram of cocaine.
7.
On March 23, 1994, defendant R. YEPIZ drove to a
6
parking lot where he delivered one kilogram of cocaine to an
7
unindicted co-conspirator.
8
9
10
11
12
13
8.
On August 24, 1995, defendant H. YEPIZ drove a car,
with defendant G. RODRIGUEZ as a passenger, with a handgun hidden
underneath the center console.
9.
On September 28, 1995, defendant M. YEPIZ transported
approximately 30 pounds of marijuana in the bed of a grey truck.
10.
On September 28, 1995, defendant M. YEPIZ stored
14
approximately 150 pounds of marijuana, a Sigarms P230 semi-
15
automatic pistol, and a scale at his residence.
16
11.
On September 18, 1996, defendants M. YEPIZ and SAENZ
17
transported approximately one kilogram of cocaine hidden inside a
18
secret compartment of defendant SAENZ’ vehicle.
19
20
21
22
23
12.
On July 27, 1999, defendants ARANDA and H. YEPIZ and an
unindicted co-conspirator traveled from Los Angeles to Kentucky.
13.
On July 28, 1999, while in Kentucky, defendants ARANDA
and H. YEPIZ possessed approximately three kilograms of cocaine.
14.
On July 31, 1999, while in Kentucky, defendants ARANDA
24
and H. YEPIZ possessed approximately two kilograms of cocaine and
25
approximately $17,500 in proceeds from the sale of cocaine.
26
15.
On February 21, 2000, defendant AVINA possessed at his
27
residence approximately 657 grams of cocaine inside a gym bag and
28
approximately 155 grams of cocaine and 13 grams of heroin inside
- 43 -
1
2
a safe, along with a scale and ziplock baggies.
16.
On April 21, 2001, defendant CARRASCO, with defendant
3
AVINA as a passenger, threw two plastic bags containing marijuana
4
out of the vehicle he was driving, while being chased by law
5
enforcement.
6
17.
On May 30, 2001, at a Bank of America parking lot,
7
defendant BAUSTISTA showed a confidential informant (“CI”)
8
$31,000 in U.S. Currency.
9
18.
On May 30, 2001, defendant BAUTISTA showed an
10
undercover police officer (“UC”) approximately $29,000 in U.S.
11
currency and told the UC that he wanted two kilograms of cocaine.
12
13
14
19.
On February 25, 2002, defendant G. RODRIGUEZ drove to
the Nite Inn, 10612 Ventura Boulevard, Studio City, California.
20.
On February 25, 2002, defendant G. RODRIGUEZ, while at
15
the Nite Inn received approximately 108,100 pseudoephedrine
16
tablets.
17
21.
In early 2002, defendant CASILLAS and deceased co-
18
conspirator EC (“EC”) met with representatives from the Mexican
19
Mafia, who instructed defendant CASILLAS and EC to collect taxes
20
for the Mexican Mafia.
21
22.
Prior to June 2002, defendant H. YEPIZ contacted a
22
member of the Mexican Mafia at Pelican Bay State Prison and
23
requested permission to kill EC and take over the VBS gang.
24
23.
Prior to June 2002, defendant H. YEPIZ told unindicted
25
co-conspirators that he had permission from a member of the
26
Mexican Mafia to kill EC.
27
28
24.
In approximately June 2002, defendants CASILLAS, H.
YEPIZ, and M. YEPIZ attended a meeting with representatives from
- 44 -
1
2
the Mexican Mafia.
25.
On June 23, 2002, defendant R. YEPIZ purchased a 2002
3
Ford F-350 with a $9,000 down payment that was paid with proceeds
4
from the sale of illegal drugs.
5
26.
On June 27, 2002, defendant A. SANDOVAL possessed
6
approximately 5 pounds of methamphetamine packaged in five one-
7
pound shrink-wrapped plastic bags, and approximately 31 ounces of
8
crystal methamphetamine packaged in 31 one-ounce ziplock bags.
9
27.
On July 23, 2002, defendants L. SANDOVAL, I. HARO, and
10
LEDESMA, and co-conspirator RA (“RA”) (now deceased) traveled
11
together in a limousine with a loaded .25 caliber semi-automatic
12
pistol, a loaded Sig-Sauer semi-automatic pistol, and a loaded
13
Smith and Wesson semi-automatic pistol.
14
15
16
17
18
28.
On August 1, 2002, defendant R. YEPIZ ordered defendant
CAMPOS to count narcotics proceeds.
29.
On August 1, 2002, defendant CAMPOS counted
approximately $500,000 in proceeds from the sale of narcotics.
30.
On August 1, 2002, defendant R. YEPIZ directed
19
defendant CAMPOS and an unindicted co-conspirator to collect five
20
kilograms of cocaine.
21
31.
On August 1, 2002, defendant CAMPOS opened an
22
electronically-activated secret compartment inside a Chevrolet
23
Camaro in order for an unindicted co-conspirator to place one
24
kilogram of cocaine inside the compartment.
25
32.
On October 6, 2002, and after displaying VBS gang
26
signs, defendant J. SANDOVAL and other unindicted co-conspirators
27
kicked and punched three victims, knocking one of the victims
28
unconscious.
- 45 -
1
2
3
33.
On November 23, 2002, defendants A. SANDOVAL and
LEDESMA visited a deceased VBS member’s grave.
34.
On November 23, 2002, and after visiting the deceased
4
VBS member’s grave, defendant LEDESMA shot and killed a rival
5
gang member, EA.
6
35.
On November 23, 2002, after killing EA, defendants A.
7
SANDOVAL and LEDESMA, and an unindicted co-conspirator drove to
8
defendant CASILLAS’ residence where they had fingerprints and gun
9
residue removed from their car.
10
36.
On approximately November 28, 2002, defendant LEDESMA
11
told an unindicted co-conspirator that MP had witnessed defendant
12
LEDESMA murder another individual.
13
37.
On approximately November 28, 2002, defendant I. HARO
14
drove defendant LEDESMA, an unindicted co-conspirator, and co-
15
conspirator RA to Mexico.
16
38.
On approximately November 29, 2002, defendant J.
17
SANDOVAL met with defendant I. HARO and co-conspirator RA in
18
Mexico.
19
39.
On approximately December 1, 2002, defendants J.
20
SANDOVAL and I. HARO and co-conspirator RA drove from Mexico to
21
the United States in order to raise money for an attorney for
22
defendant LEDESMA.
23
40.
On approximately December 2, 2002, using coded language
24
in a telephone conversation, defendant LEDESMA told an unindicted
25
co-conspirator to have defendant I. HARO and others collect money
26
for an attorney.
27
28
41.
On approximately December 2, 2002, using coded language
in a telephone conversation, defendant LEDESMA told defendant
- 46 -
1
COVARRUBIUS that he wanted witness MP killed as soon as possible.
2
42.
On approximately December 2, 2002, defendant LEDESMA
3
told an unindicted co-conspirator that he was going to use
4
defendant COVARRUBIUS to kill witness MP.
5
43.
On February 13, 2003, defendants ARANDA, COVARRUBIUS,
6
and CARRASCO drove away from 7850 Ferncola Avenue, Sun Valley,
7
California together in one vehicle.
8
9
10
44.
On March 2, 2003, defendant L. SANDOVAL removed a blue-
steel semi-automatic handgun from his waistband and placed it on
the floorboard on the passenger side of his car.
11
45.
On March 2, 2003, defendant CARRASCO possessed a 9mm
12
semi-automatic handgun in the rear of defendant L. SANDOVAL’s
13
car.
14
46.
On April 18, 2003, defendant MEDINA possessed
15
approximately 3 grams of cocaine base (crack) inside a plastic
16
bag and 4 grams of methamphetamine.
17
47.
On approximately April 20, 2003, defendant I. HARO had
18
an unindicted co-conspirator rent room number 106 at the Ramada
19
Inn, 2900 North San Fernando Boulevard, Burbank, California (the
20
“Ramada Inn”) from April 20, 2003, until May 1, 2003.
21
48.
On April 24, 2003, defendant I. HARO stored
22
approximately 101.5 grams of methamphetamine, 82 grams of
23
cocaine, two pounds of marijuana, $2,670 in U.S. currency, and a
24
measuring scale inside room 106 at the Ramada Inn.
25
49.
In approximately May 2003, defendant L. SANDOVAL
26
arranged for an unindicted co-conspirator to rent a warehouse
27
located on N. San Fernando Boulevard in Burbank, California (the
28
“San Fernando Address”) for the purpose of growing marijuana.
- 47 -
1
2
3
50.
On May 11, 2003, defendants L. SANDOVAL, COVARRUBIUS,
and ROBLEDO attempted to locate MP.
51.
On May 12, 2003, defendant L. SANDOVAL drove a black
4
Honda Accord with defendants COVARRUBIUS and ROBLEDO as
5
passengers to an alley in the vicinity of MP’s residence.
6
52.
On May 12, 2003, after asking whether the victim
7
recognized him, defendant ROBLEDO shot and killed MP with a 9mm
8
handgun.
9
53.
On May 12, 2003, defendant COVARRUBIUS told defendants
10
J. SANDOVAL, AVINA, and co-conspirator JV (“JV”) (now deceased)
11
that they had just killed MP.
12
54.
On May 28, 2003, using coded language in a telephone
13
conversation, defendant LEDESMA told defendant KHAN that
14
defendant J. SANDOVAL would pay $10,000 for defendant LEDESMA’s
15
attorney and defendant KHAN agreed to assist in paying for
16
defendant LEDESMA’s attorney.
17
55.
On May 30, 2003, using coded language in a telephone
18
conversation, defendant LEDESMA told defendant COVARRUBIUS to
19
kill a witness, TM.
20
56.
In approximately June 2003, defendant L. SANDOVAL
21
directed Saign Charlsestein to build an indoor marijuana grow at
22
the San Fernando Address.
23
57.
In approximately June 2003, defendants R. YEPIZ, H.
24
YEPIZ, CASILLAS and others met with representatives of the
25
Mexican Mafia in order to discuss defendant H. YEPIZ’ attempts to
26
take over VBS and his threats to kill EC.
27
28
58.
On June 20, 2003, using coded language in a telephone
conversation, defendant LEDESMA asked an unindicted co-
- 48 -
1
conspirator to tell defendant CASILLAS to have witness TM killed
2
by August 1, 2003.
3
59.
On June 21, 2003, defendant COVARRUBIUS possessed a 9mm
4
semi-automatic handgun and a gun cleaning cloth that removed
5
fingerprints from firearms.
6
60.
On June 26, 2003, co-conspirator JV, who was in
7
Washington State, sent $2,000 in proceeds from the sale of
8
narcotics to defendant J. SANDOVAL by two Western Union wire
9
transfers.
10
11
12
61.
On August 12, 2003, defendant G. RODRIGUEZ met with EC
at a Mobil Gas Station, 4801 Laurel Canyon Boulevard.
62.
On August 12, 2003, defendant G. RODRIGUEZ, driving a
13
blue BMW (the “BMW”), and EC, the passenger, agreed to pick up H.
14
YEPIZ.
15
16
17
18
19
63.
On August 12, 2003, defendant H. YEPIZ entered the BMW
and shot EC in the head twice.
64.
On August 12, 2003, defendant G. RODRIGUEZ removed EC’s
body from the BMW.
65.
On August 12, 2003, defendant R. YEPIZ gave defendant
20
G. RODRIGUEZ a car to drive instead of the BMW, because the
21
interior of the BMW was stained with EC’s blood and brains.
22
23
24
66.
Sometime after August 12, 2003, defendant G. RODRIGUEZ
arranged for the BMW to be destroyed.
67.
In approximately October, 2003, defendant KHAN was
25
given a 2003 black Cadillac Escalade (“Escalade”) by unindicted
26
co-conspirator Eric Mejia as payment for a prior drug debt.
27
28
68.
On or before November 15, 2003, defendant KHAN gave co-
conspirator RA the Escalade.
- 49 -
1
69.
On or before November 15, 2003, defendant D. GARCIA
2
agreed to sell crystal methamphetamine with co-conspirator RA for
3
defendants J. SANDOVAL and others.
4
70.
Sometime before November 15, 2003, co-conspirator RA
5
told defendant CASILLAS that co-conspirator RA would kill any
6
police officer who attempted to detain him.
7
71.
Sometime before November 15, 2003, defendant I. HARO
8
told defendant SALINAS that defendant D. GARCIA and co-
9
conspirator RA were distributing crystal methamphetamine.
10
72.
Sometime before November 15, 2003, co-conspirator RA
11
told defendant D. GARCIA that if they were stopped by the police,
12
defendant D. GARCIA should open a backpack that contained
13
numerous weapons, including a fully automatic assault rifle.
14
73.
On November 15, 2003, defendant D. GARCIA and co-
15
conspirator RA possessed approximately 101 grams of actual
16
methamphetamine inside the Escalade, along with numerous weapons.
17
74.
On November 15, 2003, co-conspirator RA got out of the
18
Cadillac and shot Burbank Police Department (“BPD”) Officers MP
19
and GC.
20
21
22
75.
On November 15, 2003, defendant D. GARCIA shot and
killed BPD Officer MP.
76.
On November 15, 2003, defendant D. GARCIA called
23
defendant SALINAS and told defendant SALINAS that co-conspirator
24
RA had been shot and killed.
25
77.
On November 15, 2003, defendants J. SANDOVAL, L.
26
SANDOVAL, CARRASCO, and SALINAS met with defendant D. GARCIA and
27
brought defendant D. GARCIA to a residence on Cohasset Avenue in
28
Sun Valley, California (the “Cohasset Address”).
- 50 -
1
78.
On November 15, 2003, while at the Cohasset Address,
2
defendants J. SANDOVAL, L. SANDOVAL, I. HARO, CARRASCO, and
3
SALINAS collected money in order to assist defendant D. GARCIA
4
flee to Mexico.
5
79.
On November 15, 2003, and after the murder of BPD
6
Officer MP, defendants J. SANDOVAL, I. HARO, and CARRASCO
7
collected money for defendant D. GARCIA, in order for defendant
8
D. GARCIA to escape to Mexico.
9
80.
On November 15, 2003, defendant GARCIA told defendant
10
SALINAS that BPD Officer MP was “crying like a bitch” and
11
“yelling for help” before defendant D. GARCIA shot Officer MP.
12
81.
On November 15, 2003, defendant L. SANDOVAL called an
13
unindicted co-conspirator and directed that individual to meet
14
with defendant L. SANDOVAL at a nearby gas station in order to
15
take defendant D. GARCIA to defendant AVINA in Mexico.
16
82.
On November 15, 2003, defendants L. SANDOVAL, CARRASCO,
17
and SALINAS drove defendant D. GARCIA to a meeting with an
18
unindicted co-conspirator for the purpose of having defendant D.
19
GARCIA driven to defendant AVINA in Mexico.
20
21
22
83.
On November 15, 2003, an unindicted co-conspirator
drove defendant D. GARCIA to defendant AVINA in Mexico.
84.
On November 16, 2003, defendant AVILA stored two boxes
23
of .357 caliber ammunition, two boxes of .45 caliber ammunition,
24
two gun magazine clips, approximately 131 grams of marijuana, an
25
electronic scale, and ziplock baggies inside the bedroom of his
26
residence.
27
28
85.
On November 16, 2003, defendant AVILA had a .357
caliber Rugber GP 100 revolver stored inside a hidden compartment
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1
2
of his vehicle.
86.
On November 17, 2003, defendant BARBA stored parts that
3
are used to convert Fabrique National F.A.L. rifles into fully
4
automatic rifles.
5
87.
On November 18, 2003, defendant L. SANDOVAL ordered an
6
unindicted co-conspirator to remove a fully automatic MAK-90
7
Sporter 7.62 caliber machine gun from the San Fernando Address
8
because defendant L. SANDOVAL was wanted by law enforcement.
9
88.
On November 18, 2003, defendants J. SANDOVAL and L.
10
SANDOVAL possessed at their residence the DMV registration for
11
the Escalade, a receipt for $2,700 of hydroponic growing
12
equipment (that can be used to grow marijuana), $536 in U.S.
13
currency, several large empty plastic bags with marijuana
14
residue, and numerous bullets and bullet magazines for an AK-47
15
assault rifle, a Ruger handgun, a 9mm handgun, a .40 caliber
16
handgun, and a .45 caliber handgun.
17
89.
On November 26, 2003, defendant C. VASQUEZ drove
18
defendant L. SANDOVAL to a meeting with an unindicted co-
19
conspirator in order to deliver $1,200 as payment for the San
20
Fernando Address.
21
90.
On February 10, 2004, defendant A. RODRIGUEZ stored at
22
his residence approximately one kilogram of cocaine, 64 pounds of
23
marijuana, three scales, body armor, plastic baggies, 9mm
24
ammunition, and .38 caliber ammunition.
25
26
27
28
91.
On March 16, 2004, defendant HERNANDEZ loaded
approximately 33 pounds of marijuana into his vehicle.
92.
On March 16, 2004, defendant HERNANDEZ possessed at his
residence approximately 10 grams of cocaine, which was packaged
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1
into small ziplock bags, 37 grams of tar heroin, and one pound of
2
marijuana.
3
93.
On August 13, 2004, using coded language in a telephone
4
conversation, defendant MORIN told defendant R. YEPIZ that he
5
would have approximately $31,000 in proceeds from sale of
6
narcotics for defendant R. YEPIZ.
7
94.
On August 14, 2004, using coded language in a telephone
8
conversation, defendant J. SANDOVAL told defendant R. YEPIZ that
9
crystal methamphetamine cost $7,300 a pound.
10
95.
On August 14, 2004, using coded language in a telephone
11
conversation, defendant R. YEPIZ directed defendant CAMPOS to
12
deliver a sample of cocaine to an unindicted co-conspirator.
13
96.
On August 15, 2004, using coded language in a telephone
14
conversation, defendant CASILLAS told defendant R. YEPIZ that he
15
had received information from a VBS member in jail that law
16
enforcement was targeting VBS members.
17
97.
On August 16, 2004, using coded language in a telephone
18
conversation, defendant MORIN told defendant R. YEPIZ that he had
19
$21,000 in proceeds from the sale of cocaine, but that he had
20
paid defendant CONTRERAS $14,000 for poor quality cocaine.
21
22
23
98.
On August 17, 2004, defendants R. YEPIZ and J. SANDOVAL
met in order to inspect cocaine.
99.
On August 17, 2004, using coded language in a telephone
24
conversation, defendant R. YEPIZ instructed an unindicted co-
25
conspirator to pick up proceeds from the sale of narcotics from
26
defendant MORIN.
27
28
100. On August 19, 2004, using coded language in a telephone
conversation, defendant J. SANDOVAL told defendant R. YEPIZ that
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1
he had 10 kilograms of cocaine that defendant R. YEPIZ could
2
inspect.
3
101. On August 23, 2004, using coded language in a telephone
4
conversation, defendant MORIN told defendant R. YEPIZ that he was
5
attempting to collect proceeds from the sale of narcotics from
6
his customers, including defendant CONTRERAS, and that he wanted
7
approval from defendant R. YEPIZ to assault defendant CONTRERAS.
8
9
10
102. On August 25, 2004, using coded language in a telephone
conversation, defendant MORIN asked defendant R. YEPIZ for 10
kilograms of good quality cocaine.
11
103. On August 26, 2004, using coded language in a telephone
12
conversation, defendant SAENZ told defendant R. YEPIZ that he had
13
10 kilograms of cocaine available for $14,000 a kilogram.
14
104. On August 27, 2004, using coded language in a telephone
15
conversation, defendant R. YEPIZ told defendant SAENZ that he had
16
high quality marijuana available for $500 a pound.
17
105. On August 29, 2004, using coded language in a telephone
18
conversation, defendant J. SANDOVAL told defendant R. YEPIZ that
19
his customers had cash for illegal drugs.
20
106. On September 1, 2004, using coded language in a
21
telephone conversation, defendant R. YEPIZ agreed to sell cocaine
22
to defendant SAENZ for $14,100 per kilogram.
23
107. On September 8, 2004, using coded language in a
24
telephone conversation, defendant R. YEPIZ informed defendant
25
CASILLAS that defendant M. YEPIZ had been arrested and that
26
despite M. YEPIZ’ use of a false driver’s license, law
27
enforcement had discovered defendant M. YEPIZ’s true identity.
28
108. In approximately mid-September 2004, defendants ARANDA
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1
and COVARRUBIUS packaged approximately one pound of crystal
2
methamphetamine into smaller quantities for sale to customers.
3
109. On September 16, 2004, using coded language in a
4
telephone conversation, defendant MORIN told an unindicted co-
5
conspirator that he had been ordered to kill another individual
6
who was believed to have cooperated with law enforcement and that
7
he would lure the suspected cooperator to the garage of his
8
residence to kill him.
9
110. On September 18, 2004, using coded language in a
10
telephone conversation, defendant CONTRERAS told defendant MORIN
11
that he had gone to defendant MORIN’s residence in order to pick
12
up proceeds from the sale of narcotics for defendant R. YEPIZ.
13
111. On September 21, 2004, using coded language in a
14
telephone conversation, defendant CONTRERAS told defendant MORIN
15
that he needed 10 pounds of methamphetamine.
16
112. On September 24, 2004, using coded language in a
17
telephone conversation, defendant CASILLAS told defendant ARANDA
18
that he was inspecting good quality methamphetamine, and that
19
defendant ARANDA could purchase one pound of methamphetamine for
20
between $7,100 and $7,500.
21
113. On September 25, 2004, using coded language in a
22
telephone conversation, after defendant MEDINA told defendant
23
CASILLAS that one pound of crystal methamphetamine was $8,000,
24
defendant CASILLAS agreed to inspect the illegal drugs for
25
defendant ARANDA.
26
114. On September 25, 2004, using coded language in a
27
telephone conversation, defendant C. VASQUEZ asked defendant R.
28
YEPIZ whether defendant MORIN had illegal drugs available.
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1
115. On September 25, 2004, using coded language in a
2
telephone conversation, defendant R. YEPIZ told defendant AYALA
3
to bring proceeds from the sale of cocaine to him.
4
116. On September 25, 2004, using coded language in a
5
telephone conversation, defendant R. YEPIZ told defendant C.
6
VASQUEZ that defendants SAENZ, MORIN, or CONTRERAS would be able
7
to supply defendant C. VASQUEZ with illegal drugs.
8
9
117. On September 26, 2004, using coded language in a
telephone conversation, defendant CASILLAS told defendant ARANDA
10
that defendant MEDINA was going to bring defendant CASILLAS a
11
sample of crystal methamphetamine.
12
118. On September 27, 2004, using coded language in a
13
telephone conversation, defendant R. YEPIZ told defendant MORIN
14
that he would see if his source had cocaine available.
15
119. On September 27, 2004, using coded language in a
16
telephone conversation, defendant J. SANDOVAL agreed to meet with
17
defendant R. YEPIZ at a house where defendant J. SANDOVAL stored
18
cocaine (“stash house”).
19
20
120. On September 27, 2004, defendant R. YEPIZ followed
defendant J. SANDOVAL to the stash house.
21
121. On September 27, 2004, using coded language in a
22
telephone conversation, defendant C. VASQUEZ asked defendant R.
23
YEPIZ for a Colt handgun.
24
122. On September 27, 2004, using coded language in a
25
telephone conversation, defendant MORIN told defendant CONTRERAS
26
that he had $15,000 in proceeds from the sale of cocaine.
27
123. On September 28, 2004, using coded language in a
28
telephone conversation, defendant R. YEPIZ asked defendant
- 56 -
1
2
CONTRERAS whether he had any Colt handguns.
124. On September 28, 2004, using coded language in a
3
telephone conversation, defendant J. SANDOVAL agreed to supply
4
defendant R. YEPIZ with four kilograms of cocaine.
5
125. On September 28, 2004, at the direction of defendant R.
6
YEPIZ, defendant J. SANDOVAL delivered approximately four
7
kilograms of cocaine to defendant MORIN at defendant MORIN’s
8
residence.
9
126. On September 28, 2004, using coded language in a
10
telephone conversation, defendant R. YEPIZ asked defendant MORIN
11
whether defendant AYALA could pick up one of the four kilograms
12
of cocaine that were at defendant MORIN’s residence.
13
127. On September 28, 2004, using coded language in a
14
telephone conversation, defendant AYALA told defendant R. YEPIZ
15
that the four kilograms of cocaine at defendant MORIN’s residence
16
were not good quality.
17
128. On September 28, 2004, using coded language in a
18
telephone conversation, defendant R. YEPIZ told defendant J.
19
SANDOVAL that defendant AYALA needed one kilogram of better
20
quality cocaine.
21
22
129. On September 28, 2004, defendant AYALA possessed at
least approximately $15,000 in U.S. currency.
23
130. On September 28, 2004, using coded language in a
24
telephone conversation, defendant SAENZ told defendant CASILLAS
25
that illegal drugs had arrived and to inform defendant MEDINA.
26
131. On September 28, 2004, using coded language in a
27
telephone conversation, defendant CASILLAS told defendant MEDINA
28
that defendant SAENZ had good quality cocaine.
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1
132. On September 29, 2004, using coded language in a
2
telephone conversation, defendant R. YEPIZ told defendant J.
3
SANDOVAL that he would receive proceeds from the sale of four
4
kilograms of cocaine that day.
5
133. On September 29, 2004, using coded language in a
6
telephone conversation, defendant CONTRERAS told defendant R.
7
YEPIZ that he needed four kilograms of cocaine and that he would
8
pay cash on delivery.
9
134. In late September 2004, defendants ARANDA and
10
COVARRUBIUS packaged approximately one pound of crystal
11
methamphetamine into smaller quantities for sale to customers.
12
135. On October 1, 2004, using coded language in a telephone
13
conversation, defendant R. YEPIZ told defendant J. SANDOVAL that
14
he had $21,000 in proceeds from the sale of cocaine.
15
136. On October 2, 2004, using coded language in a telephone
16
conversation, defendant SANCHEZ told defendant R. YEPIZ that he
17
had four kilograms of cocaine available for sale at $13,500 per
18
kilogram.
19
137. On October 2, 2004, using coded language in a telephone
20
conversation, defendant R. YEPIZ told defendant AYALA that
21
defendant SANCHEZ had cocaine available.
22
138. On October 2, 2004, using coded language in a telephone
23
conversation, defendant R. YEPIZ told defendant J. SANDOVAL to
24
pick up narcotics proceeds at defendant MORIN’s residence.
25
139. On October 2, 2004, using coded language in a telephone
26
conversation, defendant SANCHEZ told defendant R. YEPIZ that
27
defendants M. YEPIZ and H. YEPIZ could help defendant R. YEPIZ
28
distribute illegal drugs.
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1
140. On October 2, 2004, defendant J. SANDOVAL picked up
2
$21,000 in proceeds from the sale of cocaine from defendant MORIN
3
at defendant MORIN’s residence.
4
141. On October 3, 2004, at the direction of defendant R.
5
YEPIZ, defendant AYALA met with defendant SANCHEZ and inspected
6
cocaine.
7
142. On October 4, 2004, using coded language in a telephone
8
conversation, defendant R. YEPIZ instructed defendant AYALA to
9
pay defendant R. YEPIZ $300 for brokering a cocaine transaction.
10
143. On October 4, 2004, using coded language in a telephone
11
conversation, defendant R. YEPIZ told defendant AYALA that
12
defendant CAMPOS would go to defendant AYALA’s residence in order
13
to receive money from defendant AYALA.
14
144. On October 4, 2004, using coded language in a telephone
15
conversation, defendant CASILLAS told co-conspirator MG (“MG”)
16
(now deceased) that defendant ARANDA wanted one pound of
17
methamphetamine.
18
145. On October 4, 2004, using coded language in a telephone
19
conversation, co-conspirator MG told defendant CASILLAS that the
20
methamphetamine for defendant ARANDA would cost $7,100 a pound.
21
146. On October 4, 2004, using coded language in a telephone
22
conversation, defendant ARANDA told defendant CASILLAS that he
23
had received the full amount of methamphetamine.
24
147. On October 5, 2004, using coded language in a telephone
25
conversation, defendant SAENZ told defendant R. YEPIZ that he had
26
cocaine available for $14,000 per kilogram.
27
148. On October 5, 2004, using coded language in a telephone
28
conversation, defendant SAENZ told defendant R. YEPIZ that he had
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1
2
crystal methamphetamine available for sale for $6,800 per pound.
149. On October 5, 2004, using coded language in a telephone
3
conversation, defendant MACIAS told defendant CASILLAS that
4
defendant L. GARCIA would provide him with five pounds of
5
marijuana at $350 a pound.
6
150. On October 6, 2004, using coded language in a telephone
7
conversation, defendant MORIN told defendant R. YEPIZ that he had
8
received another $28,000 in proceeds from the sale of cocaine.
9
151. On October 6, 2004, using coded language in a telephone
10
conversation, defendant R. YEPIZ agreed to take five kilograms of
11
cocaine from defendant SANCHEZ.
12
152. On October 6, 2004, using coded language in a telephone
13
conversation, defendant CASILLAS told co-conspirator MG that he
14
would deliver proceeds from the sale of illegal drugs to co-
15
conspirator MG.
16
153. On October 6, 2004, using coded language in a telephone
17
conversation, defendant CASILLAS told defendant MACIAS that co-
18
conspirator MG needed 50 pounds of marijuana.
19
154. On October 6, 2004, using coded language in a telephone
20
conversation, defendant MENDEZ told defendant CASILLAS that their
21
customer wanted one-half of a kilogram of cocaine.
22
155. On October 6, 2004, using coded language in a telephone
23
conversation, defendant MEDINA told defendant CASILLAS that he
24
needed a new gun following a shoot-out with individuals who had
25
stolen illegal drugs from him.
26
156. On October 7, 2004, using coded language in a telephone
27
conversation, defendant MACIAS told defendant CASILLAS that he
28
had two kilograms of cocaine available for sale at $13,900 per
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1
kilogram and methamphetamine available for sale at $7,400 per
2
pound.
3
157. On October 7, 2004, using coded language in a telephone
4
conversation, defendant CASILLAS told defendant MEDINA that
5
defendant MACIAS had two kilograms of cocaine available for sale
6
and that they could be inspected.
7
158. On October 7, 2004, using coded language in a telephone
8
conversation, defendant AVILA told defendant CASILLAS that he
9
needed one pound of marijuana.
10
159. On October 8, 2004, using coded language in a telephone
11
conversation, defendant AVILA requested additional quantities of
12
illegal drugs from defendant CASILLAS, and asked that the illegal
13
drugs be from the same source as a prior drug transaction.
14
160. On October 9, 2004, using coded language in a telephone
15
conversation, defendant SAENZ told defendant MORIN that defendant
16
C. VASQUEZ would deliver one pound of methamphetamine to
17
defendant MORIN.
18
161. On October 11, 2004, using coded language in a
19
telephone conversation, defendant SANCHEZ told defendant R. YEPIZ
20
that an unindicted co-conspirator needed defendant H. YEPIZ and
21
others to commit acts of violence.
22
23
24
162. On October 11, 2004, using coded language in a
telephone three kilograms of cocaine.
163. On October 11, 2004, using coded language in a
25
telephone conversation, defendant MORIN told defendant J. MEJIA
26
that he had three kilograms of cocaine for defendant J. MEJIA.
27
164. On October 11, 2004, using coded language in a
28
telephone conversation, defendant J. MEJIA told defendant MORIN
- 61 -
1
that defendant CEDENO would deliver $10,000 in proceeds from the
2
sale of cocaine and pick up three kilograms of cocaine.
3
165. On October 11, 2004, using coded language in a
4
telephone conversation, defendant MORIN told defendant SAENZ that
5
proceeds from the sale of cocaine would arrive from Bakersfield
6
within three days.
7
166. On October 11, 2004, using coded language in a
8
telephone conversation, defendant SANCHEZ told defendant R. YEPIZ
9
that he had delivered three kilograms of cocaine to defendant
10
MORIN on defendant R. YEPIZ’ behalf and that defendant MORIN was
11
satisfied with the quality of the cocaine because it could be
12
converted into cocaine base (crack).
13
167. On October 13, 2004, using coded language in a
14
telephone conversation, defendant ARANDA told defendant CASILLAS
15
that he had met with co-conspirator MG and received crystal
16
methamphetamine.
17
168. On October 14, 2004, using coded language in a
18
telephone conversation, defendant R. YEPIZ told defendant SANCHEZ
19
that he needed additional cocaine.
20
169. In approximately mid-October 2004, defendants ARANDA
21
and COVARRUBIUS packaged approximately one pound of crystal
22
methamphetamine into smaller sales quantities for sale to
23
customers.
24
170. On October 15, 2004, using coded language in a
25
telephone conversation, defendant CASILLAS told defendant MEDINA
26
to deliver one ounce of cocaine to one customer, one-half of an
27
ounce of cocaine to second customer, and one-eighth of an ounce
28
to a third customer.
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1
171. On October 18, 2004, using coded language in a
2
telephone conversation, defendant ARANDA asked defendant CASILLAS
3
whether he could supply him with two pounds of methamphetamine.
4
172. On October 18, 2004, using coded language in a
5
telephone conversation, defendant ARANDA told defendant CASILLAS
6
that he had gone to defendant LEDESMA’s court hearing and that
7
unindicted co-conspirator MC, whom they believed was cooperating,
8
would not look at defendant ARANDA.
9
173. On October 18, 2004, using coded language in a
10
telephone conversation, defendants R. YEPIZ and MORIN discussed
11
defendant CEDENO’s arrest with three kilograms of cocaine, and
12
defendant CEDENO’s subsequent release from jail.
13
174. On October 19, 2004, using coded language in a
14
telephone conversation, defendant MORIN agreed to supply
15
defendant CONTRERAS with two pounds of methamphetamine that day.
16
175. On October 19, 2004, using coded language in a
17
telephone conversation, defendant ZAMBRANO asked defendant
18
CASILLAS whether a witness against defendant LEDESMA still needed
19
to be killed.
20
176. On October 20, 2004, at defendant ARANDA’s direction,
21
defendant COVARRUBIUS shot unindicted co-conspirator MM (“MM”).
22
177. On October 20, 2004, using coded language in a
23
telephone conversation, defendant MENDEZ told defendant CASILLAS
24
that co-conspirator MG had told him that the illegal drugs had
25
not crossed from Mexico into the United States.
26
178. On October 20, 2004, using coded language in a
27
telephone conversation, defendant CASILLAS told defendant ARANDA
28
that co-conspirator MG had not yet brought illegal drugs into the
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1
2
United States.
179. On October 20, 2004, using coded language in a
3
telephone conversation, defendant CASILLAS told defendant ARANDA
4
that he was collecting money to assist with the burial of another
5
VBS member.
6
180. On October 22, 2004, using coded language in a
7
telephone conversation, after defendant J. SANDOVAL accused
8
defendant ARANDA of taking a handgun from defendant J. SANDOVAL’s
9
car, defendant J. SANDOVAL agreed to deliver two pounds of
10
11
methamphetamine to defendant ARANDA.
181. On October 22, 2004, using coded language in a
12
telephone conversation, an unindicted co-conspirator told
13
defendant ARANDA that the unindicted co-conspirator would supply
14
defendant ARANDA with a handgun, an AR-15 assault rifle, and a
15
bullet-proof vest.
16
182. On October 24, 2004, using coded language in a
17
telephone conversation, defendant MENDEZ sang to defendant
18
CASILLAS a song glorifying co-conspirator RA’s killing of BPD
19
Officer MP and told defendant CASILLAS that three to four more
20
police officers would be killed if they interfered with the VBS.
21
183. On October 24, 2004, using coded language in a
22
telephone conversation, defendant MORIN told defendant R. YEPIZ
23
that he had another $10,000 for defendant R. YEPIZ, and as a
24
result, he would have paid defendant R. YEPIZ over $100,000 in
25
proceeds from the sale of cocaine.
26
184. On October 25, 2004, using coded language in a
27
telephone conversation, defendant CASILLAS agreed with defendant
28
KHAN to supply defendant AVILA with one pound of marijuana.
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1
185. On October 25, 2004, using coded language in a
2
telephone conversation, defendant CONTRERAS told defendant MORIN
3
that he could borrow a firearm, but if defendant MORIN used the
4
gun, he would have to pay defendant CONTRERAS for it.
5
186. On October 27, 2004, using coded language in a
6
telephone conversation, defendant MORIN told an unindicted co-
7
conspirator to kill another individual who was “taxing” them.
8
187. On October 27, 2004, using coded language in a
9
telephone conversation, defendant ARANDA updated an unindicted
10
co-conspirator on the status of various VBS members, including
11
defendants J. SANDOVAL, A. SANDOVAL, H. YEPIZ, COVARRUBIUS, and
12
BAUTISTA.
13
188. On October 28, 2004, using coded language in a
14
telephone conversation, defendant J. SANDOVAL asked defendant
15
ARANDA whether he wanted an additional two pounds of
16
methamphetamine.
17
189. On October 29, 2004, using coded language in a
18
telephone conversation, defendant ARANDA told an unindicted co-
19
conspirator that defendant COVARRUBIUS would travel to Tennessee.
20
190. On October 29, 2004, using coded language in a
21
telephone conversation, defendant ARANDA told defendant
22
COVARRUBIUS that he should be paid between $5,000 and $10,000 for
23
traveling to Tennessee in order to collect an outstanding
24
narcotics debt.
25
191. On October 29, 2004, using coded language in a
26
telephone conversation, defendant COVARRUBIUS told defendant
27
ARANDA that he would bring defendant ZAMBRANO with him to
28
Tennessee.
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1
192. On October 29, 2004, using coded language in a
2
telephone conversation, defendant ZAMBRANO told defendant ARANDA
3
that he would call defendant COVARRUBIUS.
4
193. On October 29, 2004, using coded language in a
5
telephone conversation, defendant MORIN told defendant CONTRERAS
6
to use $12,000 in proceeds from the sale of narcotics to pay off
7
an outstanding drug debt owed to defendant SAENZ.
8
9
10
11
12
194. On October 30, 2004, defendant COVARRUBIUS flew to
Nashville, Tennessee.
195. On October 31, 2004, defendant COVARRUBIUS and an
unindicted co-conspirator drove to North Carolina.
196. On October 31, 2004, using coded language in a
13
telephone conversation, defendant COVARRUBIUS told defendant
14
ARANDA that unindicted co-conspirators in Tennessee had given
15
defendant COVARRUBIUS a cheap .380 caliber handgun.
16
197. On October 31, 2004, using coded language in a
17
telephone conversation, defendant SAENZ told defendant MORIN that
18
he wanted money from a prior delivery of one kilogram of cocaine
19
as well as money from a delivery of methamphetamine.
20
198. On November 2, 2004, using coded language in a
21
telephone conversation, defendant CONTRERAS told defendant MORIN
22
that he needed 10 kilograms of cocaine at $13,700 a kilogram.
23
199. On November 3, 2004, using coded language in a
24
telephone conversation, defendant COVARRUBIUS told defendant
25
ARANDA that defendant LEDESMA had a court hearing that day.
26
200. On November 4, 2004, using coded language in a
27
telephone conversation, defendant ZAMBRANO told defendant ARANDA
28
that an unindicted co-conspirator had the parts for two assault
- 66 -
1
rifles for defendant ARANDA.
2
201. On November 5, 2004, using coded language in a
3
telephone conversation, defendant A. RODRIGUEZ asked defendant
4
CASILLAS what he knew about the attempted murder of MM.
5
202. On November 5, 2004, using coded language in a
6
telephone conversation with defendant CASILLAS, defendant ARANDA
7
agreed to help defendant MEDINA retrieve illegal drugs that had
8
been stolen from him.
9
203. On November 5, 2004, using coded language in a
10
telephone conversation, defendant SAENZ told defendant MORIN that
11
he would deliver one kilogram of cocaine to defendant MORIN in 25
12
minutes.
13
204. On November 5, 2004, using coded language in a
14
telephone conversation, defendant CASILLAS told defendant MEDINA
15
to give defendant ARANDA one kilogram of good quality cocaine for
16
$13,800 and that defendant ARANDA would deliver a handgun to
17
defendant MEDINA.
18
19
20
205. On November 5, 2004, defendant MORIN delivered
approximately one-half of a kilogram of cocaine to Sergio Mejia.
206. On November 6, 2004, using coded language in a
21
telephone conversation, defendant ARANDA, who was with co-
22
conspirator MG, told defendant CASILLAS that co-conspirator MG
23
was giving them crystal methamphetamine for $7,000 a pound.
24
207. On November 10, 2004, using coded language in a
25
telephone conversation, defendants CASILLAS and ZAMBRANO
26
discussed locating other VBS members, including defendant
27
COVARRUBIUS, in order to engage in gang activity.
28
208. On November 11, 2004, using coded language in a
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1
telephone conversation, defendant J. SANDOVAL warned defendant
2
ARANDA that law enforcement was in the area.
3
209. On November 12, 2004, using coded language in a
4
telephone conversation, defendant I. HARO told defendant J.
5
SANDOVAL that money would be sent to defendant J. SANDOVAL via
6
Western Union and that crystal methamphetamine cost $6,000 a
7
pound.
8
9
210. On November 13, 2004, using coded language in a
telephone conversation, defendant J. SANDOVAL agreed to supply an
10
unindicted co-conspirator with an additional three pounds of
11
methamphetamine after the unindicted co-conspirator informed
12
defendant J. SANDOVAL that he had just delivered two pounds of
13
methamphetamine to unindicted co-conspirators in Las Vegas.
14
211. On November 14, 2004, using coded language in a
15
telephone conversation, defendants CASILLAS and I. HARO agreed to
16
meet in order to celebrate co-conspirator RA’s murder of BPD
17
Officer MP.
18
212. On November 15, 2004, using coded language in a
19
telephone conversation, defendant R. YEPIZ told an unindicted co-
20
conspirator that he would supply him with two assault rifles.
21
213. On November 16, 2004, using coded language in a
22
telephone conversation, defendant R. YEPIZ asked defendant J.
23
SANDOVAL whether defendant I. HARO had a .45 caliber handgun.
24
214. On November 16, 2004, using coded language in a
25
telephone conversation, defendant ARANDA agreed with an
26
unindicted co-conspirator who was in jail to intimidate a victim
27
into dropping charges against the unindicted co-conspirator.
28
215. On November 17, 2004, using coded language in a
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1
telephone conversation, defendant R. YEPIZ asked defendant J.
2
SANDOVAL whether he had inspected a shipment of illegal drugs.
3
216. On November 17, 2004, using coded language in a
4
telephone conversation, defendant J. SANDOVAL told defendant I.
5
HARO that he was receiving via Western Union additional proceeds
6
from the sale of narcotics.
7
217. On November 17, 2004, defendants J. SANDOVAL and BARBA
8
traveled to a Western Union store in order to collect the
9
proceeds from the sale of narcotics.
10
218. On November 17, 2004, defendants J. SANDOVAL and BARBA
11
met with two unindicted co-conspirators at a restaurant located
12
at 8742 Glenoaks Boulevard.
13
14
15
219. On November 17, 2004, defendant BARBA collected $24,000
in proceeds from the sale of narcotics.
220. On November 17, 2004, after a police patrol car
16
attempted to conduct a traffic stop, defendants J. SANDOVAL, who
17
was carrying a large white plastic bag that contained $24,000 in
18
U.S. currency, and defendant BARBA ran from their car.
19
221. On November 17, 2004, using coded language in a
20
telephone conversation, defendant J. SANDOVAL told defendant I.
21
HARO to remove methamphetamine from a location where it was
22
stored because he had been arrested.
23
222. On November 17, 2004, using coded language in a
24
telephone conversation, defendant J. SANDOVAL told defendant I.
25
HARO to remove proceeds from the sale of narcotics from a
26
location where it was stored.
27
28
223. On November 17, 2004, using coded language in a
telephone conversation, defendant J. SANDOVAL told defendant I.
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1
HARO that defendant BARBA had $24,000 with him and that the
2
police would find the stash house because he had documents
3
identifying its location inside his car.
4
224. On November 19, 2004, using coded language in a
5
telephone conversation, defendants MACIAS and L. GARCIA informed
6
defendant CASILLAS that they had good quality cocaine, and that
7
they would put five kilograms of cocaine aside for defendant
8
CASILLAS.
9
225. On November 19, 2004, using coded language in a
10
telephone conversation, defendant AYALA told defendant R. YEPIZ
11
that defendant J. SANDOVAL had been arrested.
12
226. On November 21, 2004, using coded language in a
13
telephone conversation, defendant AVILA told defendant CASILLAS
14
that he would deliver proceeds from the sale of narcotics.
15
227. On November 21, 2004, using coded language in a
16
telephone conversation, after defendant R. YEPIZ asked for eight
17
pounds of crystal methamphetamine, defendant CONTRERAS told
18
defendant R. YEPIZ that the methamphetamine would cost between
19
$7,000 and $7,100 per pound.
20
228. On November 24, 2004, using coded language in a
21
telephone conversation, defendant A. SANDOVAL instructed
22
defendant ARANDA to get defendant I. HARO’s telephone number and
23
to tell defendant I. HARO that he was failing to take care of the
24
drug trafficking business.
25
229. On November 29, 2004, using coded language in a
26
telephone conversation, defendant HERNANDEZ told defendant
27
CASILLAS that he needed to contact defendant MACIAS regarding an
28
outstanding narcotics debt.
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1
230. On November 29, 2004, using coded language in a
2
telephone conversation, defendant MACIAS told defendant CASILLAS
3
that defendant HERNANDEZ wanted to collect a disputed $50,000
4
narcotics debt.
5
231. On November 30, 2004, using coded language in a
6
telephone conversation, defendant ARANDA told defendant CASILLAS
7
that he wanted two pounds of crystal methamphetamine that co-
8
conspirator MG had available.
9
232. On November 30, 2004, using coded language in a
10
telephone conversation, defendant ARANDA told defendant CASILLAS
11
that he would meet with co-conspirator MG in order to receive two
12
pounds of methamphetamine.
13
233. On November 30, 2004, defendant ARANDA received two
14
pounds of crystal methamphetamine from co-conspirator MG.
15
234. On November 30, 2004, using coded language in a
16
telephone conversation, co-conspirator MG told defendant CASILLAS
17
that methamphetamine had been delivered to defendant ARANDA, and
18
that defendant ARANDA would have a difficult time matching the
19
color of the methamphetamine if he added additional chemicals to
20
the methamphetamine.
21
235. On December 1, 2004, using coded language in a
22
telephone conversation, defendant ARANDA told defendant CASILLAS
23
that law enforcement was chasing defendant COVARRUBIUS and that
24
defendant COVARRUBIUS had told defendant ARANDA that he had
25
thrown a gun out of the car during the chase.
26
236. On December 1, 2004, defendants J. SANDOVAL, I. HARO,
27
and COVARRUBIUS moved defendant J. SANDOVAL’s belongings from a
28
stash house located at 14629 Bledsoe Street, Sylmar, California.
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1
237. On December 1, 2004, using coded language in a
2
telephone conversation, defendant ARANDA told defendant CASILLAS
3
that defendant J. SANDOVAL had been released from jail.
4
238. On December 4, 2004, using coded language in a
5
telephone conversation, an unindicted co-conspirator told
6
defendant KHAN to retrieve the SIM cards from the cellular
7
telephones so that they could be exchanged for new ones.
8
239. On December 5, 2004, using coded language in a
9
telephone conversation, defendant I. HARO told defendant KHAN
10
that he had been supplied with five SIM chips for telephones
11
being used by defendants J. SANDOVAL, I. HARO, and J. HARO.
12
240. On December 6, 2004, using coded language in a
13
telephone conversation, defendant MEDINA told defendant CASILLAS
14
that defendant CASILLAS owed defendant MEDINA money for the sale
15
of two kilograms of cocaine, and that defendant MEDINA would
16
supply defendant CASILLAS with an additional kilogram of cocaine.
17
241. On December 8, 2004, defendants CASILLAS, ARANDA, and
18
MEDINA met at a Ralph’s Market in order to deliver 4 ½ ounces of
19
cocaine to a customer.
20
242. On December 10, 2004, defendant CASILLAS drove a
21
vehicle containing a one-pound sample of marijuana and
22
approximately $4,489 in U.S. currency to a meeting with a
23
customer.
24
25
26
243. On or about December 11, 2004, defendant ARANDA gave
his cellular telephone to defendant CARRASCO.
244. On December 11, 2004, using coded language in a
27
telephone conversation, defendant BARBA told defendant CASILLAS
28
that he would put defendant CASILLAS in contact with defendant
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1
2
MACIAS.
245. On December 12, 2004, using coded language in a
3
telephone conversation, defendant CARRASCO agreed to contact
4
defendant ARANDA so that defendant COVARRUBIUS could talk to
5
defendant ARANDA.
6
246. On December 12, 2004, using coded language in a
7
telephone conversation, defendant CASILLAS told defendant A.
8
RODRIGUEZ that he had been arrested with one pound of marijuana
9
and U.S. currency, but that law enforcement had not found a gun
10
11
that was hidden in a secret compartment of the car.
247. On December 12, 2004, using coded language in a
12
telephone conversation, defendant CASILLAS told defendant A.
13
RODRIGUEZ that his attorney had asked defendant CASILLAS where
14
defendant I. HARO and co-conspirator JV were located in order to
15
assist co-conspirator MC.
16
248. On December 12, 2004, using coded language in a
17
telephone conversation, defendant A. SANDOVAL told defendant
18
CASILLAS to tell other VBS members that defendant I. HARO may be
19
assisting co-conspirator MC.
20
249. On December 19, 2004, using coded language in a
21
telephone conversation, an unindicted co-conspirator told
22
defendant CARRASCO that the crystal methamphetamine was three
23
grams short.
24
25
26
250. On December 21, 2004, defendants CASILLAS, ARANDA,
CARRASCO, and SAENZ met at a restaurant.
251. On December 21, 2004, using coded language in a
27
telephone conversation, defendant MEDINA told defendant CASILLAS
28
that he would meet with defendant CASILLAS as soon as he had
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1
2
finished measuring illegal drugs.
252. On December 21, 2004, defendant MEDINA drove to a
3
meeting with defendant CASILLAS with approximately 51 grams of
4
cocaine base (crack), approximately 31 grams of cocaine, and
5
approximately 5 grams of crystal methamphetamine.
6
253. On December 23, 2004, defendant KHAN sold to an
7
unindicted co-conspirator approximately 8 grams of cocaine and 3
8
grams of methamphetamine.
9
254. On December 26, 2004, using coded language in a
10
telephone conversation, an unindicted co-conspirator told
11
defendants AVILA and KHAN that he had proceeds from the sale of
12
illegal drugs to give them.
13
255. On December 26, 2004, using coded language in a
14
telephone conversation, defendant ARANDA agreed to supply one
15
ounce of cocaine to defendant KHAN.
16
256. On December 28, 2004, using coded language in a
17
telephone conversation, defendant C. VASQUEZ told defendant R.
18
YEPIZ that he needed 200 pounds of marijuana.
19
257. On December 28, 2004, using coded language in a
20
telephone conversation, defendant I. HARO told defendant KHAN
21
that he would pick up two telephones from defendant KHAN.
22
258. On December 28, 2004, using coded language in a
23
telephone conversation, defendant CASILLAS told defendant R.
24
YEPIZ that defendant I. HARO had told him that federal law
25
enforcement agents were in the area.
26
259. On December 29, 2004, using coded language in a
27
telephone conversation, defendant KHAN told defendant AVILA to
28
deliver cocaine to an unindicted customer.
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1
260. On January 5, 2005, using coded language in a telephone
2
conversation, defendant J. SANDOVAL told defendant CASILLAS that
3
he had 80 pounds of high-quality marijuana that he would sell to
4
defendant CASILLAS for $350 per pound.
5
261. On January 5, 2005, using coded language in a telephone
6
conversation, defendant R. YEPIZ told defendant CONTRERAS that
7
defendant J. SANDOVAL had 80 pounds of marijuana.
8
262. On January 6, 2005, using coded language in a telephone
9
conversation, defendant I. HARO agreed to store at his mother’s
10
residence two pounds of crystal methamphetamine, which belonged
11
to defendant J. SANDOVAL, for defendant R. YEPIZ.
12
263. On January 6, 2005, using coded language in a telephone
13
conversation, defendant R. YEPIZ told defendant AYALA to deliver
14
a backpack to defendant H. YEPIZ’s car.
15
264. On January 6, 2005, using coded language in a telephone
16
conversation, defendant CASILLAS told defendant MEDINA that a
17
customer was arrested after defendant CASILLAS had delivered
18
marijuana to him.
19
265. On January 12, 2005, using coded language in a
20
telephone conversation, defendant CASILLAS told defendant I. HARO
21
that he would attempt to broker the sale of 10 pounds of
22
methamphetamine.
23
266. On January 12, 2005, using coded language in a
24
telephone conversation, defendant CASILLAS told defendant MEDINA
25
that he had sent $5,000 to an unindicted co-conspirator who had
26
been arrested in Mexico while attempting to bring marijuana from
27
Mexico into the United States.
28
267. Sometime before January 14, 2005, defendant KHAN
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1
2
traveled to Hawaii.
268. On January 14, 2005, using coded language in a
3
telephone conversation, defendant J. SANDOVAL told defendant
4
ARANDA that defendant KHAN and an unindicted co-conspirator would
5
locate a stash house in Hawaii.
6
269. On January 14, 2005, using coded language in a
7
telephone conversation, defendant J. SANDOVAL told defendant
8
ARANDA that defendant KHAN and an unindicted co-conspirator
9
needed $7,300 in a California bank account, and that they already
10
had spent $8,000 of proceeds from the sale of methamphetamine
11
that defendant J. SANDOVAL had left in Hawaii.
12
270. On January 15, 2005, using coded language in a
13
telephone conversation, defendant J. SANDOVAL told defendant
14
ARANDA to send one pound of methamphetamine to Hawaii.
15
271. On January 15, 2005, using coded language in a
16
telephone conversation, defendant J. SANDOVAL told defendant
17
ARANDA that defendant J. SANDOVAL had left proceeds from the sale
18
of methamphetamine in Hawaii, and that the money from Hawaii was
19
defendant J. SANDOVAL’s and co-conspirator RA’s money.
20
272. On January 17, 2005, using coded language in a
21
telephone conversation, defendant MACIAS asked defendant CASILLAS
22
to contact defendants M. YEPIZ and ARANDA for him.
23
273. On January 17, 2005, using coded language in a
24
telephone conversation, defendant MACIAS told defendant ARANDA
25
that he wanted to meet with him to discuss future narcotics
26
activities.
27
28
274. On or before January 18, 2005, defendants MACIAS and L.
GARCIA removed 53 kilograms of cocaine from a residence located
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1
on Bradley Avenue in Los Angeles, California.
2
275. On January 18, 2005, defendants MACIAS and L. GARCIA
3
stored approximately one kilogram of cocaine, approximately 111
4
pounds of marijuana, one .38 caliber handgun, and a bullet-proof
5
vest at the Bradley Address.
6
276. On January 18, 2005, defendant L. GARCIA left the
7
Bradley Address with five pounds of marijuana hidden inside a
8
bag.
9
277. On January 18, 2005, using coded language in a
10
telephone conversation, defendant CASILLAS warned defendant
11
ARANDA not to go to the Bradley Address.
12
13
14
278. On January 19, 2005, defendant ARANDA shot victim OG
twice in his abdomen after leaving a bar.
279. On January 20, 2005, using coded language in a
15
telephone conversation, an unindicted co-conspirator told
16
defendant I. HARO that the unindicted co-conspirator would tax
17
other individuals in order to provide defendant I. HARO with
18
money.
19
280. On January 21, 2005, using coded language in a
20
telephone conversation, defendant CASILLAS told defendant MEDINA
21
that law enforcement had seized illegal drugs at MACIAS’
22
residence.
23
281. On January 21, 2005, using coded language in a
24
telephone conversation, an unindicted co-conspirator asked
25
defendant CASILLAS to confirm that defendant CONTRERAS had paid
26
$1,500 that had been owed to defendant A. RODRIGUEZ.
27
28
282. On January 22, 2005, using coded language in a
telephone conversation, defendant MEDINA told defendant CASILLAS
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1
that defendant MACIAS wanted defendants MEDINA and CASILLAS to
2
run his illegal drug business while defendant MACIAS hid from law
3
enforcement.
4
283. On January 24, 2005, using coded language in a
5
telephone conversation, defendant R. YEPIZ told defendant I. HARO
6
that he would be collecting proceeds from the sale of narcotics.
7
284. On January 25, 2005, using coded language in a
8
telephone conversation, defendant I. HARO told an unindicted co-
9
conspirator that he was going to give a shotgun to another VBS
10
11
member.
285. On January 25, 2005, using coded language in a
12
telephone conversation, an unindicted co-conspirator told
13
defendant I. HARO that defendant I. HARO could not purchase a
14
specific handgun because it already had been used to commit a
15
crime.
16
286. On January 25, 2005, using coded language in a
17
telephone conversation, defendant CASILLAS told co-conspirator MG
18
that defendant ARANDA needed methamphetamine.
19
287. On January 25, 2005, using coded language in a
20
telephone conversation, defendant ARANDA told defendant CASILLAS
21
that he would meet with co-conspirator MG and that he had $4,000
22
in U.S. currency with him.
23
288. On January 25, 2005, using coded language in a
24
telephone conversation, defendant ARANDA told defendant CASILLAS
25
that he had received methamphetamine from co-conspirator MG.
26
289. On January 26, 2005, using coded language in a
27
telephone conversation, defendant CASILLAS told an unindicted co-
28
conspirator that co-conspirator MC was cooperating with law
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1
2
enforcement and would testify at trial against defendant LEDESMA.
290. On January 27, 2005, using coded language in a
3
telephone conversation, defendant ZAMBRANO told defendant
4
CASILLAS that he would inspect co-conspirator MC’s residence and
5
asked defendant CASILLAS for bullets for a 9mm handgun.
6
291. On January 27, 2005, using coded language in a
7
telephone conversation, defendant ZAMBRANO told defendant
8
CASILLAS that he had driven by co-conspirator MC’s residence and
9
again asked for 9mm bullets.
10
292. On January 27, 2005, defendant ARANDA met with
11
defendant M. YEPIZ at defendant M. YEPIZ’ residence, 10249
12
Wheatland Avenue, Sun Valley, California.
13
293. On January 27, 2005, after police officers attempted to
14
stop defendant ARANDA’s car, defendant ARANDA removed a 9mm
15
handgun from his waist and dropped the handgun onto the
16
floorboard of his truck.
17
18
19
294. On January 27, 2005, defendant ARANDA possessed
approximately 7 grams of crystal methamphetamine.
295. On January 30, 2005, using coded language in a
20
telephone conversation, defendant CASILLAS told defendant MENDEZ
21
that defendant ARANDA had not paid co-conspirator MG for a prior
22
shipment of methamphetamine.
23
296. On January 30, 2005, using coded language in a
24
telephone conversation, defendant CASILLAS agreed to purchase one
25
kilogram of cocaine from defendant SAENZ for $13,700 and told
26
defendant SAENZ that the cocaine was for defendant MENDEZ.
27
28
297. On February 1, 2005, using coded language in a
telephone conversation, defendants CASILLAS and MENDEZ discussed
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1
purchasing approximately 40 kilograms of cocaine with defendant
2
MEDINA.
3
298. On February 2, 2005, using coded language in a
4
telephone conversation, defendant CASILLAS told defendant MEDINA
5
that defendant ARANDA was arrested as a result of defendant
6
ARANDA’s drug trafficking activities in Hawaii.
7
299. On February 7, 2005, using coded language in a
8
telephone conversation, defendant ZAMBRANO told defendant
9
CASILLAS of an ongoing gang war with Blood gang members.
10
300. On February 9, 2005, using coded language in a
11
telephone conversation, defendant M. YEPIZ agreed to locate
12
pounds of marijuana for defendant SANCHEZ.
13
301. On February 12, 2005, using coded language in a
14
telephone conversation, an unindicted co-conspirator told
15
defendant C. VASQUEZ that he had a Sig Sauer .45 caliber handgun
16
for sale for $750.
17
302. On February 17, 2005, using coded language in a
18
telephone conversation, an unindicted co-conspirator told
19
defendant M. YEPIZ that a court case against defendant J.
20
SANDOVAL had been dropped.
21
303. On February 17, 2005, using coded language in a
22
telephone conversation, an unindicted co-conspirator told
23
defendant C. VASQUEZ that defendant G. RODRIGUEZ had cocaine
24
available for $13,500 per kilogram.
25
304. On February 17, 2005, using coded language in a
26
telephone conversation, defendant C. VASQUEZ told an unindicted
27
co-conspirator that defendant C. VASQUEZ’s associate wanted to
28
purchase high-tech weapons, including grenade launchers, M—1 or
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1
2
AR-15 assault rifles, and Sig Sauer or Glock handguns.
305. On February 19, 2005, using coded language in a
3
telephone conversation, defendant MACIAS told defendant CASILLAS
4
to have defendant BARBA call defendant MACIAS when the illegal
5
drugs had arrived.
6
306. On February 23, 2005, using coded language in a
7
telephone conversation, defendant I. HARO told defendant CASILLAS
8
that he had seven pounds of methamphetamine available for sale
9
for $4,500 per pound.
10
307. On February 24, 2005, using coded language in a
11
telephone conversation, defendant C. VASQUEZ told defendant R.
12
YEPIZ that an unindicted co-conspirator needed 500 pounds of
13
marijuana.
14
308. On February 24, 2005, using coded language in a
15
telephone conversation, defendant R. YEPIZ told defendant C.
16
VASQUEZ to inspect a sample of marijuana.
17
309. On February 24, 2005, using coded language in a
18
telephone conversation, defendant CASILLAS told defendant I. HARO
19
that he wanted to inspect defendant I. HARO’s methamphetamine.
20
21
22
310. On February 24, 2005, defendant CASILLAS possessed
approximately 112 grams of methamphetamine.
311. On February 24, 2005, using coded language in a
23
telephone conversation, defendant CASILLAS told defendant I. HARO
24
that one of the four ounces of methamphetamine had weighed less
25
than an ounce.
26
312. On February 25, 2005, using coded language in a
27
telephone conversation, defendant C. VASQUEZ ordered 500 grams of
28
cocaine from defendant SAENZ.
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1
313. On February 25, 2005, using coded language in a
2
telephone conversation, defendant R. YEPIZ told defendant C.
3
VASQUEZ that he had 100 pounds of marijuana available for
4
defendant C. VASQUEZ.
5
314. On February 25, 2005, using coded language in a
6
telephone conversation, defendant MENDEZ told defendant CASILLAS
7
that he had been with defendant CONTRERAS, who had 80 pounds of
8
marijuana inside his car.
9
315. On February 25, 2005, using coded language in a
10
telephone conversation, defendant ZAMBRANO asked defendant
11
CASILLAS for a gun for other VBS members who were engaged in gang
12
activity without a gun.
13
316. On February 26, 2005, using coded language in a
14
telephone conversation, defendant C. VASQUEZ agreed to supply 30
15
to 40 kilograms of cocaine to a customer for $13,650 per
16
kilogram.
17
317. On February 28, 2005, defendant C. VASQUEZ met with
18
Jose De Jesus Agredano in a 7-11 parking lot in Reseda,
19
California, where defendant C. VASQUEZ inspected cocaine.
20
318. On February 28, 2005, using coded language in a
21
telephone conversation, defendant C. VASQUEZ told defendant SAENZ
22
that he had inspected kilogram quantities of high-quality cocaine
23
that had an Audi symbol on them.
24
319. On February 28, 2005, using coded language in a
25
telephone conversation, defendant SAENZ told defendant C. VASQUEZ
26
to purchase the cocaine.
27
28
320. On February 28, 2005, defendants SAENZ and C. VASQUEZ
possessed approximately 13 kilograms of cocaine.
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1
321. On March 1, 2005, using coded language in a telephone
2
conversation, defendant C. VASQUEZ told defendant SAENZ that he
3
would sell 13 kilograms of cocaine to an unindicted co-
4
conspirator for $15,000 per kilogram.
5
322. On March 1, 2005, defendant R. YEPIZ and an unindicted
6
co-conspirator possessed approximately 300 pounds of marijuana at
7
a residence located on Keith Drive in Whittier, California.
8
323. On March 1, 2005, using coded language in a telephone
9
conversation, defendant R. YEPIZ told defendant C. VASQUEZ that
10
11
defendant C. VASQUEZ could receive 78 pounds of marijuana.
324. On March 1, 2005, and at the direction of defendant R.
12
YEPIZ, defendant C. VASQUEZ met with an unindicted co-conspirator
13
at a gas station in Whittier, California and took possession of a
14
car that contained approximately 78 pounds of marijuana.
15
325. On March 1, 2005, using coded language in a telephone
16
conversation, defendant C. VASQUEZ told defendant R. YEPIZ that
17
there were an additional 220 pounds of marijuana available, which
18
defendant C. VASQUEZ could get the next day.
19
326. On or before March 2, 2005, defendants J. SANDOVAL and
20
I. HARO arranged for the sale of at least two pounds of crystal
21
methamphetamine in Hawaii.
22
327. On or before March 2, 2005, defendants J. SANDOVAL and
23
I. HARO arranged for $44,980 in proceeds from the sale of crystal
24
methamphetamine to be mailed from Hawaii to the Los Angeles area.
25
26
328. On March 2, 2005, defendant SAENZ possessed eight
kilograms of cocaine, which was stored underneath a couch.
27
329. On March 2, 2005, using coded language in a telephone
28
conversation, defendant SAENZ told defendant C. VASQUEZ that he
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1
had eight kilograms of cocaine and that defendant C. VASQUEZ was
2
to give defendant CAMPOS two kilograms of cocaine.
3
330. On March 2, 2005, using coded language in a telephone
4
conversation, defendant R. YEPIZ asked defendant C. VASQUEZ where
5
defendant CAMPOS should go to pick up the cocaine.
6
331. On March 2, 2005, using coded language in a telephone
7
conversation, defendant CAMPOS told defendant C. VASQUEZ that he
8
was arriving to meet with defendant C. VASQUEZ.
9
332. On March 2, 2005, using coded language in a telephone
10
conversation, defendant C. VASQUEZ told defendant SAENZ that he
11
had given two kilograms of cocaine to defendant CAMPOS and had
12
saved one kilogram of cocaine for defendant SAENZ.
13
333. On March 2, 2005, using coded language in a telephone
14
conversation, defendant R. YEPIZ told defendant C. VASQUEZ that
15
law enforcement has seized approximately 220 pounds of marijuana
16
at the Keith Address.
17
18
334. On March 4, 2005, defendant CONTRERAS possessed
approximately 100 grams of methamphetamine.
19
335. On March 7, 2005, using coded language in a telephone
20
conversation, defendant I. HARO told defendant J. SANDOVAL that
21
one of their illegal drug sources, Jose De Jesus Agredano, had
22
been arrested by law enforcement.
23
336. On March 7, 2005, using coded language in a telephone
24
conversation, defendant ZAMBRANO asked defendant CASILLAS for a
25
bullet-proof vest to be worn during a robbery.
26
337. On March 9, 2005, using coded language in a telephone
27
conversation, defendant SAENZ told defendant C. VASQUEZ that he
28
had met with defendant R. YEPIZ regarding whether defendant C.
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1
VASQUEZ had led law enforcement to the Keith Address.
2
338. On March 9, 2005, using coded language in a telephone
3
conversation, defendant I. HARO told an unindicted co-conspirator
4
to find the paperwork for co-conspirator JV’s green Jaguar sedan
5
in order for the car to be registered in another individual’s
6
name.
7
339. On March 10, 2005, using coded language in a telephone
8
conversation, defendant I. HARO admitted to an unindicted co-
9
conspirator that he was involved in the killing of co-conspirator
10
JV.
11
340. On March 10, 2005, using coded language in a telephone
12
conversation, defendant I. HARO told defendant CASILLAS that co-
13
conspirator JV had been murdered.
14
341. On March 10, 2005, using coded language in a telephone
15
conversation, defendant CASILLAS agreed to meet with defendant I.
16
HARO in order to discuss co-conspirator JV’s murder.
17
342. On March 12, 2005, using coded language in a telephone
18
conversation, defendant MACIAS told defendant CASILLAS that while
19
he was out of California, he wanted only defendants CASILLAS and
20
BARBA to receive orders for illegal drugs on his behalf.
21
343. On March 13, 2005, using coded language in a telephone
22
conversation, defendant CASILLAS told defendant I. HARO that he
23
would locate 100 pounds of marijuana for defendant I. HARO’s
24
customer.
25
344. On March 14, 2005, using coded language in a telephone
26
conversation, defendant ZAMBRANO told defendant CASILLAS that he
27
wanted to meet with defendant CASILLAS in person.
28
345. On March 14, 2005, using coded language in a telephone
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1
conversation, defendant CASILLAS threatened to assault a customer
2
of an unindicted co-conspirator who owed money to defendant
3
CASILLAS and to the unindicted co-conspirator for illegal drugs
4
that the customer had received.
5
346. On March 15, 2005, using coded language in a telephone
6
conversation, defendant BAUTISTA asked defendant CASILLAS about
7
the status of defendants R. YEPIZ, A. RODRIGUEZ, and LEDESMA.
8
347. On March 15, 2005, using coded language in a telephone
9
conversation, defendant CASILLAS told defendant MEDINA that they
10
needed to restart their drug trafficking activities and sell
11
illegal drugs to defendant BAUTISTA and others.
12
348. On March 19, 2005, using coded language in a telephone
13
conversation, defendant BAUTISTA told defendant CASILLAS that an
14
unindicted co-conspirator needed one pound of marijuana.
15
349. On March 19, 2005, using coded language in a telephone
16
conversation, defendant CASILLAS asked defendant MEDINA for one
17
pound of marijuana for an unindicted co-conspirator.
18
350. On March 19, 2005, using coded language in a telephone
19
conversation, defendant CASILLAS asked an unindicted co-
20
conspirator whether he had received illegal drugs that defendant
21
CASILLAS and BAUTISTA had sent into prison.
22
351. On March 22, 2005, using coded language in a telephone
23
conversation, defendant SAENZ told defendant C. VASQUEZ that he
24
owed defendant SAENZ $22,000 from the sale of narcotics.
25
352. On March 22, 2005, using coded language in a telephone
26
conversation, defendant M. YEPIZ told defendant SANCHEZ that he
27
owed defendant SANCHEZ $13,000 from the sale of narcotics.
28
353. On March 23, 2005, using coded language in a telephone
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1
conversation, defendant CASILLAS told defendant M. YEPIZ that his
2
source of illegal drugs would deliver illegal drugs to defendant
3
M. YEPIZ.
4
354. On March 24, 2005, using coded language in a telephone
5
conversation, defendant BARBA told defendant CASILLAS that
6
defendant MACIAS had been arrested, but that defendant BARBA had
7
high quality marijuana for defendant CASILLAS.
8
9
10
11
355. On March 29, 2005, using coded language in a telephone
conversation, defendant CASILLAS asked defendant BARBA whether
additional marijuana had arrived.
356. On March 30, 2005, using coded language in a telephone
12
conversation, and after defendant CONTRERAS told defendant M.
13
YEPIZ that he was going to purchase five pounds of crystal
14
methamphetamine for $6,300 per pound from an unindicted co-
15
conspirator, defendant M. YEPIZ told defendant CONTRERAS that he
16
would supply him with an additional two pounds of crystal
17
methamphetamine.
18
357. On March 30, 2005, using coded language in a telephone
19
conversation, defendant CASILLAS told an unindicted co-
20
conspirator to bury money in the backyard because he was being
21
followed by law enforcement.
22
358. On March 31, 2005, using coded language in a telephone
23
conversation, defendant CASILLAS told defendant MEDINA that an
24
unindicted co-conspirator wanted to purchase one-half kilogram of
25
cocaine for $14,000.
26
359. On April 1, 2005, at the direction of CASILLAS,
27
defendant MEDINA delivered approximately 500 grams of cocaine to
28
an unindicted co-conspirator.
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1
360. On April 2, 2005, using coded language in a telephone
2
conversation, defendant I. HARO instructed defendant J. HARO to
3
send $1,000 to defendant KHAN and $1,000 to defendant I. HARO by
4
wire transfer.
5
6
7
361. On April 3, 2005, defendant J. HARO wire transferred
$1,000 to defendant KHAN by Western Union.
362. On April 4, 2005, using coded language in a telephone
8
conversation, defendant MACIAS told defendant CASILLAS that a
9
load of illegal drugs had arrived from Mexico and that defendant
10
11
BARBA would deliver illegal drugs to defendant CASILLAS.
363. On April 4, 2005, using coded language in a telephone
12
conversation, defendant CASILLAS told defendant SAENZ that he had
13
received information from VBS gang members that defendant SAENZ
14
was one of largest narcotics suppliers in the area and that
15
therefore defendant CASILLAS might “tax” defendant SAENZ.
16
364. On April 6, 2005, using coded language in a telephone
17
conversation, defendant CASILLAS told defendant M. YEPIZ that
18
defendant BAUTISTA wanted to contact defendants R. YEPIZ and M.
19
YEPIZ.
20
365. On April 8, 2005, using coded language in a telephone
21
conversation, defendant CONTRERAS agreed to meet defendant M.
22
YEPIZ and supply him with methamphetamine.
23
366. On April 11, 2005, using coded language in a telephone
24
conversation, defendant J. SANDOVAL instructed defendant I. HARO
25
to take a house from a drug customer, who was located in Indiana,
26
in order to pay off that customer’s debt from a prior illegal
27
drug transaction, and to put the customer’s house in an
28
unindicted co-conspirator’s name so that it could be sold.
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1
367. On April 12, 2005, using coded language in a telephone
2
conversation, defendant M. YEPIZ told defendant SANCHEZ that he
3
needed one kilogram of cocaine.
4
368. On April 12, 2005, using coded language in a telephone
5
conversation, defendant MACIAS told defendant CASILLAS that
6
defendant BARBA would show the illegal drugs to defendant
7
CASILLAS.
8
9
10
11
369. On April 15, 2005, using coded language in a telephone
conversation, defendant CASILLAS told defendant M. YEPIZ that his
customer needed illegal drugs.
370. On April 19, 2005, using coded language in a telephone
12
conversation, defendant CASILLAS warned defendant M. YEPIZ that
13
law enforcement was investigating the death of EC.
14
371. On April 19, 2005, using coded language in a telephone
15
conversation, defendants CASILLAS and R. YEPIZ agreed to meet in
16
order to discuss law enforcement’s investigation of EC’s murder.
17
372. On April 20, 2005, using coded language in a telephone
18
conversation, defendant I. HARO told an unindicted co-conspirator
19
located in Indiana that illegal drugs would be sent to Georgia.
20
373. On April 20, 2005, using coded language in a telephone
21
conversation, defendant J. SANDOVAL asked an unindicted co-
22
conspirator located in Indiana how much a house, which was going
23
to be used to pay off an existing drug debt, was worth, and
24
stated that the house would be put in an unindicted co-
25
conspirator’s name.
26
374. On April 20, 2005, using coded language in a telephone
27
conversation, defendant CASILLAS told defendant KHAN that he
28
would have illegal drugs for defendant KHAN in the near future.
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1
375. On April 23, 2005, using coded language in a telephone
2
conversation, defendant I. HARO gave defendant J. HARO flight
3
information for defendant J. HARO’s trip to Indiana.
4
376. On April 23, 2005, using coded language in a telephone
5
conversation, defendant I. HARO told defendant J. SANDOVAL that
6
defendant J. HARO would travel to Indiana to take care of their
7
narcotics business.
8
377. On April 23, 2005, using coded language in a telephone
9
conversation, defendant J. SANDOVAL instructed an unindicted co-
10
11
conspirator to rent an apartment in Hawaii.
378. On April 23, 2005, using coded language in a telephone
12
conversation, defendant I. HARO told defendant J. SANDOVAL that
13
an unindicted co-conspirator needed further directions in order
14
to rent an apartment in Hawaii.
15
16
17
379. On April 24, 2005, defendant J. HARO traveled to
Indiana.
380. On April 25, 2005, using coded language in a telephone
18
conversation, defendant I. HARO told defendant J. HARO that he
19
had sent two pounds of crystal methamphetamine to J. HARO in
20
Indiana and that another five pounds of crystal methamphetamine
21
would be sent the following week.
22
381. On April 27, 2005, using coded language in a telephone
23
conversation, defendant I. HARO told defendant J. SANDOVAL that
24
he would pay him $16,000 in proceeds from the sale of narcotics.
25
382. On April 27, 2005, using coded language in a telephone
26
conversation, defendant I. HARO told defendant CASILLAS that he
27
had beaten up younger VBS gang members who had not shown proper
28
respect to defendant I. HARO.
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1
383. On April 28, 2005, using coded language in a telephone
2
conversation, defendant I. HARO told defendant J. HARO that he
3
and defendant J. SANDOVAL would send 10 pounds of crystal
4
methamphetamine a week to defendant J. HARO in Indiana.
5
384. On April 28, 2005, using coded language in a telephone
6
conversation, defendant BAUTISTA told defendant CASILLAS that he
7
needed methamphetamine.
8
9
10
11
385. On April 28, 2005, using coded language in a telephone
conversation, defendant CASILLAS told defendant MEDINA that
defendant BAUTISTA needed methamphetamine.
386. On April 29, 2005, using coded language in a telephone
12
conversation, defendant J. HARO, who was in Indiana, agreed to
13
send $500 to defendant I. HARO in Los Angeles by wire transfer.
14
387. On April 29, 2005, defendant J. HARO, who was in
15
Indiana, wire transferred $500 to defendant I. HARO in Los
16
Angeles by Western Union.
17
388. On April 29, 2005, using coded language in a telephone
18
conversation, defendant I. HARO told defendant J. HARO that
19
defendant ZAMBRANO would travel to Indiana.
20
389. On April 30, 2005, using coded language in a telephone
21
conversation, defendant J. SANDOVAL told an unindicted co-
22
conspirator that a customer owed him $76,000 from the sale of
23
illegal drugs and that the customer would pay defendant J.
24
SANDOVAL with his house.
25
390. On May 2, 2005, after delivering approximately two
26
pounds of marijuana to an unindicted co-conspirator, defendant
27
CASILLAS possessed $1,487.
28
391. On May 2, 2005, using coded language in a telephone
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1
conversation, defendant KHAN asked defendant I. HARO for cocaine.
2
392. On May 3, 2005, using coded language in a telephone
3
conversation, defendant I. HARO told an unindicted co-conspirator
4
that they had received a letter regarding the March 2, 2005
5
seizure of $44,980, which was the proceeds from the sale of
6
methamphetamine that had been sent from Hawaii.
7
393. On May 3, 2005, using coded language in a telephone
8
conversation, defendant J. SANDOVAL, who was with defendant KHAN,
9
told defendant I. HARO that customers in Indiana needed to pay
10
11
them for prior shipments of crystal methamphetamine.
394. On May 3, 2005, using coded language in a telephone
12
conversation, defendant J. HARO, who was in Indiana, told
13
defendant I. HARO that defendant J. HARO and unindicted co-
14
conspirators located in Indiana had collected $13,000 in proceeds
15
from the sale of narcotics.
16
395. On May 3, 2005, using coded language in a telephone
17
conversation, defendant J. SANDOVAL told an unindicted co-
18
conspirator that a package from Hawaii that was seized by law
19
enforcement contained approximately $50,000 in U.S. currency.
20
396. On May 4, 2005, using coded language in a telephone
21
conversation, defendant I. HARO told an unindicted co-conspirator
22
that law enforcement was following defendant KHAN because of
23
defendant KHAN’s narcotics trafficking activities in Hawaii.
24
397. On May 5, 2005, using coded language in a telephone
25
conversation, defendant J. HARO, who was in Indiana, told
26
defendant I. HARO that unindicted co-conspirators located in
27
Indiana still were waiting for another unindicted co-conspirator
28
to give them $8,000 in proceeds from the sale of crystal
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1
2
methamphetamine.
398. On May 5, 2005, using coded language in a telephone
3
conversation, defendant I. HARO told defendant ZAMBRANO that he
4
was going to have proceeds from the sale of narcotics shipped to
5
defendant ZAMBRANO.
6
399. On May 8, 2005, using coded language in a telephone
7
conversation, defendant R. YEPIZ agreed with defendant SANCHEZ to
8
put pressure on an unindicted co-conspirator who owed money to
9
defendants R. YEPIZ and SANCHEZ from the purchase of illegal
10
11
drugs.
400. On May 10, 2005, defendant J. HARO, who was in Indiana,
12
packaged $15,000 in proceeds from the sale of two pounds of
13
crystal methamphetamine.
14
15
All in violation of Title 18, United States Code, Section
1962(d).
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
The Grand Jury charges:
2
COUNT THREE
3
[21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(A), 841(b)(1)(B)]
4
5
A.
OBJECTS OF THE CONSPIRACY
Beginning on a date unknown to the Grand Jury and continuing
6
to on or about June 21, 2005, in Los Angeles County, within the
7
Central District of California, and elsewhere, defendants RAFAEL
8
YEPIZ, also known as (“aka”) Ralph, aka Sneaky (“R. YEPIZ”),
9
ARNOLD SANDOVAL, aka Big Barney (“A. SANDOVAL”), HORACIO YEPIZ,
10
aka Alberto Rodriguez, aka Horse (“H. YEPIZ”), ESPIRIDION ARANDA,
11
aka Pete Josui, aka Antonio Marmolejo, aka Peety (“ARANDA”),
12
JESUS SANDOVAL, aka Chuy, aka the Barney Twins (“J. SANDOVAL”),
13
LUIS SANDOVAL, aka the Barney Twins (“L. SANDOVAL”), MANUEL
14
YEPIZ, aka Martin Sanchez, aka Pony (“M. YEPIZ”), CARLOS ABLE
15
CASILLAS, aka Tetiro (“CASILLAS”), IGNACIO HARO, aka Nose, (“I.
16
HARO”), JAVIER COVARRUBIUS, aka Coco, aka Cokes (“COVARRUBIUS”),
17
ALONZO SAENZ RANGEL, aka Choncho (“SAENZ”), JOEL HARO (“J.
18
HARO”), AMEER KHAN (“KHAN”), RICARDO AVILA (“AVILA”), DAVID
19
GARCIA, aka Davey Crockett (“GARCIA”), BALDEMAR HERNANDEZ, aka
20
Casper, aka Baldy (“HERNANDEZ”), RAUL ROBLEDO, aka Clown
21
(“ROBLEDO”), CLETO VASQUEZ (“C. VASQUEZ”), JESUS CONTRERAS, aka
22
Yuck (“CONTRERAS”), GILBERTO CARRASCO, aka Beto (“CARRASCO”),
23
CARLOS CAMPOS, aka Blackie (“CAMPOS”), RICARDO BARBA, aka Cartoon
24
(“BARBA”), RUBEN AYALA, aka Fat Boy, aka Shy Boy (“AYALA”), JAIME
25
BAUTISTA, aka Nick Nack, aka Nigger, (“BAUTISTA”), ALBERTO
26
SANCHEZ, aka Hector Rodriguez Marin, aka Beto (“SANCHEZ”), RUBEN
27
MEDINA, aka Camaron, aka Juan Luna Risos (“MEDINA”), JOE MORIN
28
RANGEL, aka Little Joe (“MORIN”), MARCELINO MACIAS (“MACIAS”),
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1
ERNESTO OROZCO MENDEZ, aka Gordo (“MENDEZ”), LUIS GARCIA, aka
2
Huicho, aka Thalia (“L. GARCIA”), ERIK AVINA (“AVINA”), AGUSTIN
3
RODRIGUEZ, aka Dog, aka Stranger (“A. RODRIGUEZ”), FRANCISCO
4
ZAMBRANO, aka Noc (“ZAMBRANO”), SERGIO MEJIA (“S. MEJIA”), JOSE
5
LUIS MEJIA (“J. MEJIA”), JOSE DE JESUS AGREDANO (“AGREDANO”),
6
SAIGN MAHAYA CHARLSESTEIN, aka Shawn (“CHARLESTEIN”), JUAN CEDENO
7
GOMEZ (“CEDENA”), LUZ MARIA RANGEL, aka Lucy (“L. RANGEL”), and
8
others known and unknown to the Grand Jury, conspired and agreed
9
with each other to knowingly and intentionally commit the
10
11
following offenses:
1.
To distribute at least five kilograms of a mixture or
12
substance containing a detectable amount of cocaine, a schedule
13
II narcotic drug controlled substance, in violation of Title 21,
14
United States Code, Sections 841(a)(1) and 841(b)(1)(A);
15
2.
To manufacture at least 50 grams of a mixture or
16
substance containing a detectable amount of cocaine base (crack),
17
a schedule II narcotic drug controlled substance, in violation of
18
Title 21, United States Code, Sections 841(a)(1) and
19
841(b)(1)(A);
20
3.
To distribute at least 500 grams of a mixture or
21
substance containing a detectable amount of methamphetamine, or
22
at least 50 grams of actual methamphetamine, a schedule II
23
controlled substance, in violation of Title 21, United States
24
Code, Sections 841(a)(1) and 841(b)(1)(A);
25
4.
To distribute at least 1,000 kilograms of a mixture or
26
substance containing a detectable amount of marijuana, a schedule
27
I controlled substance, in violation of Title 21, United States
28
Code, Sections 841(a)(1) and 841(b)(1)(A); and
- 95 -
1
5.
To manufacture at least 1,000 marijuana plants, a
2
schedule I controlled substance, in violation of Title 21, United
3
States Code, Sections 841(a)(1) and 841(b)(1)(A).
4
B.
MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
5
ACCOMPLISHED
6
The objects of the conspiracy were to be accomplished in
7
8
substance as follows:
1.
Defendants R. YEPIZ, A. SANDOVAL, H. YEPIZ, ARANDA, J.
9
SANDOVAL, L. SANDOVAL, M. YEPIZ, CASILLAS, I. HARO, COVARRUBIUS,
10
J. HARO, KHAN, AVILA, D. GARCIA, HERNANDEZ, ROBLEDO, C. VASQUEZ,
11
CONTRERAS, CARRASCO, CAMPOS, BARBA, AYALA, BAUTISTA, AVINA, A.
12
RODRIGUEZ, and ZAMBRANO, all of whom were members or associates
13
of the Vineland Boys (“VBS”) street gang, would distribute large
14
quantities of cocaine, methamphetamine, and marijuana on behalf
15
of the VBS.
16
2.
Defendants R. YEPIZ, A. SANDOVAL, H. YEPIZ, J.
17
SANDOVAL, M. YEPIZ, and CASILLAS would work with members of
18
Mexican national drug trafficking organizations, including
19
defendants SANCHEZ, MEDINA, MACIAS, L. GARCIA, and AGREDANO, and
20
allow these drug organizations to operate in VBS gang territory
21
in return for an assured supply of cocaine, methamphetamine, and
22
marijuana for distribution.
23
3.
Defendant R. YEPIZ, M. YEPIZ, H. YEPIZ, CASILLAS, and
24
others would meet with representatives of the Mexican Mafia in
25
order to ensure that their drug trafficking activities would be
26
able to continue without interference.
27
28
4.
Defendant H. YEPIZ would attempt to control the VBS
gang in an effort to ensure that the Mexican Mafia kept a “green-
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1
light” off the VBS gang, which would ensure uninterrupted drug
2
trafficking activities.
3
5.
Defendants R. YEPIZ, ARANDA, CASILLAS, and I. HARO
4
would provide firearms to different members of the VBS gang in
5
order to protect the gang and its operations.
6
6.
Defendants ARANDA, CASILLAS, and ZAMBRANO would
7
intimidate witnesses who could testify against VBS gang members
8
in order to protect the gang and its members.
9
7.
Defendants H. YEPIZ, ARANDA, COVARRUBIUS, D. GARCIA,
10
ROBLEDO, BARBA, MORIN, and ZAMBRANO and other co-conspirators
11
known and unknown to the Grand Jury, would commit, or threaten to
12
commit, acts of violence in order to maintain control over the
13
VBS drug trafficking area.
14
8.
Defendants R. YEPIZ, J. SANDOVAL, M. YEPIZ, CASILLAS,
15
I. HARO, SAENZ, C. VASQUEZ, and CONTRERAS would supply each other
16
with cocaine, methamphetamine, and marijuana for distribution,
17
depending on who had these drugs available.
18
9.
Defendant CASILLAS would broker cocaine,
19
methamphetamine, and marijuana transactions for defendants
20
ARANDA, M. YEPIZ, I. HARO, COVARRUBIUS, KHAN, AVILA, CONTRERAS,
21
BAUTISTA, MENDEZ, and others known and unknown to the Grand Jury.
22
23
24
10.
Defendant R. YEPIZ would supply defendants J. SANDOVAL,
C. VASQUEZ, and MORIN with marijuana for distribution.
11.
Defendant R. YEPIZ would supply defendants CONTRERAS,
25
AYALA, BAUTISTA, MORIN, S. MEJIA, J. MEJIA, and others known and
26
unknown to the Grand Jury with cocaine and methamphetamine for
27
distribution.
28
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1
12.
Defendant J. SANDOVAL would supply defendants R. YEPIZ,
2
ARANDA, I. HARO, COVARRUBIUS, J. HARO, KHAN, AVILA, D. GARCIA,
3
CARRASCO, BARBA, AVINA, MORIN, and others known and unknown to
4
the Grand Jury with cocaine and methamphetamine for distribution.
5
13.
Defendants MEDINA, MACIAS, and L. GARCIA would supply
6
defendant CASILLAS and his customers with cocaine,
7
methamphetamine, and marijuana for distribution.
8
9
10
14.
Defendant SANCHEZ would supply defendants R. YEPIZ and
M. YEPIZ with cocaine and methamphetamine for distribution.
15.
Defendant AGREDANO would supply defendants J. SANDOVAL,
11
I. HARO, SAENZ, and C. VASQUEZ with cocaine and methamphetamine
12
for distribution.
13
16.
Defendant I. HARO would conduct narcotics transactions
14
for defendants A. SANDOVAL and J. SANDOVAL while they were in
15
prison.
16
17
18
19
20
17.
Defendants H. YEPIZ and ARANDA would travel to Kentucky
for the purpose of distributing cocaine.
18.
Defendants ARANDA, J. SANDOVAL, I. HARO, and KHAN would
travel to Hawaii for the purpose of distributing methamphetamine.
19.
Defendants ARANDA, I. HARO, KHAN, and LEDESMA would
21
assist defendant J. SANDOVAL in operating a methamphetamine
22
distribution network in Hawaii.
23
20.
Defendants I. HARO, J. HARO, and ZAMBRANO would assist
24
defendant J. SANDOVAL in the distribution of methamphetamine in
25
Indiana.
26
21.
27
28
Defendant J. SANDOVAL would transport cocaine to
Washington State.
22.
Defendant J. HARO would collect proceeds from the sale
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1
2
3
4
of methamphetamine for defendants J. SANDOVAL and I. HARO.
23.
Defendants I. HARO and BARBA would transport proceeds
from the sale of narcotics for defendant J. SANDOVAL.
24.
Defendant MORIN would transport cocaine and
5
methamphetamine to the Bakersfield, California area for defendant
6
R. YEPIZ.
7
25.
Defendants S. MEJIA and J. MEJIA would distribute
8
cocaine and methamphetamine in the Bakersfield, California area
9
for defendants MORIN and R. YEPIZ.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
26.
Defendants S. MEJIA and J. MEJIA would convert cocaine
into cocaine base (crack) for distribution.
27.
Defendant CEDENO would transport cocaine to the
Bakersfield, California area for defendants MORIN and J. MEJIA.
28.
Defendant L. RANGEL would receive proceeds from the
sale of narcotics for defendant MORIN.
29.
Defendant L. RANGEL would assist defendant MORIN with
keeping records of defendant MORIN’s sale of narcotics.
30.
Defendants J. SANDOVAL and L. SANDOVAL would maintain
stash houses for narcotics and firearms.
31.
Defendant L. SANDOVAL would locate a building to be
used to grow marijuana.
32.
Defendant CHARLSESTEIN would build a fully functioning
indoor marijuana grow for defendant L. SANDOVAL.
33.
Defendants MACIAS and L. GARCIA would import cocaine
25
and marijuana from Mexico for defendant CASILLAS and others to
26
distribute.
27
28
34.
Defendant BARBA would deliver narcotics for defendants
CASILLAS, MACIAS, and L. GARCIA.
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1
2
35.
Defendant CAMPOS would deliver narcotics to others for
defendant R. YEPIZ.
3
36.
Defendants KHAN and AVILA would supply defendant J.
4
SANDOVAL, I. HARO, and others with cellular telephones to be used
5
in their narcotics trafficking activities.
6
C.
OVERT ACTS
7
In furtherance of the conspiracy and to accomplish the
8
objects of the conspiracy, on or about the following dates,
9
defendants R. YEPIZ, A. SANDOVAL, H. YEPIZ, ARANDA, J. SANDOVAL,
10
L. SANDOVAL, M. YEPIZ, CASILLAS, I. HARO, COVARRUBIUS, G.
11
RODRIGUEZ, SAENZ, J. HARO, KHAN, AVILA, D. GARCIA, LEDESMA,
12
HERNANDEZ, ROBLEDO, C. VASQUEZ, CONTRERAS, CARRASCO, CAMPOS,
13
BARBA, AYALA, BAUTISTA, SANCHEZ, MEDINA, MORIN, MACIAS, MENDEZ,
14
L. GARCIA, AVINA, A. RODRIGUEZ, ZAMBRANO, S. MEJIA, J. MEJIA,
15
AGREDANO, CHARLSESTEIN, CEDENO, L. RANGEL and other co-
16
conspirators known and unknown to the Grand Jury committed
17
various overt acts within the Central District of California, and
18
elsewhere, including overt act numbers one and six through 400
19
that are set forth in Count Two and hereby incorporated by
20
reference, and including, but not limited to, the following:
21
1.
In approximately May 2003, defendant L. SANDOVAL asked
22
defendant CHARLESTEIN to assist in the creation of an indoor
23
marijuana grow at the San Fernando Address.
24
25
26
2.
In July 2003, defendant L. SANDOVAL directed an
unindicted co-conspirator to lease the San Fernando Address.
3.
In approximately July 2003, defendant L. SANDOVAL paid
27
$5,000 to defendant CHARLESTEIN in order to set up an indoor
28
marijuana grow at the San Fernando Address.
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1
4.
In approximately September 2003, defendant CHARLESTEIN
2
gave defendant L. SANDOVAL a list of items that he needed to
3
purchase for the marijuana grow at the San Fernando Address.
4
5.
In approximately November 2003, defendant CHARLESTEIN
5
completed building an indoor marijuana grow at the San Fernando
6
Address that was capable of growing 360 marijuana plants at a
7
time.
8
9
10
11
12
13
6.
On approximately November 21, 2003, defendant L.
SANDOVAL gave defendant CHARLESTEIN a cellular telephone for
defendant CHARLESTEIN to contact defendant L. SANDOVAL.
7.
On November 28, 2003, defendant CHARLESTEIN entered the
San Fernando Address.
8.
On November 28, 2003, defendants L. SANDOVAL and
14
CHARLESTEIN possessed a fully operational indoor marijuana grow
15
at the San Fernando Address, including high wattage grow lights,
16
air filtration units, water pumps, and hydro irrigation tubes.
17
9.
On November 28, 2003, defendant CHARLESTEIN possessed
18
at his residence $4,840 in proceeds from the sale of illegal
19
drugs, one-half pound of marijuana, and seeds used to grow high-
20
quality marijuana.
21
10.
On September 22, 2004, using coded language in a
22
telephone conversation, defendant J. MEJIA told defendant MORIN
23
that he had $9,000 in proceeds from the sale of narcotics that he
24
would deliver to defendant L. RANGEL.
25
11.
On September 22, 2004, using coded language in a
26
telephone conversation, defendant J. MEJIA agreed to pick up one
27
kilogram of cocaine from defendant MORIN.
28
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1
12.
On September 24, 2004, using coded language in a
2
telephone conversation, defendant S. MEJIA told defendant MORIN
3
that he had received poor quality cocaine.
4
13.
On September 28, 2004, using coded language in a
5
telephone conversation, after defendant J. SANDOVAL had delivered
6
four kilograms of cocaine to defendant MORIN, defendants MORIN
7
and J. MEJIA discussed testing the quality of the cocaine by
8
converting a small portion of the cocaine into cocaine base
9
(crack).
10
14.
On September 28, 2004, using coded language in a
11
telephone conversation, defendant MORIN told defendant R. YEPIZ
12
that the cocaine was different colors, including off white and
13
yellow, but that defendant J. MEJIA had taken the cocaine to
14
Bakersfield, California.
15
15.
On September 30, 2004, using coded language in a
16
telephone conversation, defendant R. YEPIZ told defendant MORIN
17
that defendant MORIN should have given defendant J. MEJIA two
18
kilograms of cocaine and not four kilograms of cocaine.
19
16.
On October 1, 2004, using coded language in a telephone
20
conversation, defendant MORIN told defendant R. YEPIZ that
21
defendant J. MEJIA was bringing back one kilogram of cocaine and
22
proceeds from the sale of cocaine to defendant MORIN.
23
17.
On October 7, 2004, using coded language in a telephone
24
conversation, defendant MORIN told defendant J. MEJIA that
25
defendant J. MEJIA owed defendant MORIN $59,900 in proceeds from
26
the sale of cocaine.
27
28
18.
On October 9, 2004, using coded language in a telephone
conversation, defendant J. MEJIA told defendant MORIN that he had
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1
$20,000 in proceeds from the sale of narcotics available for
2
defendant MORIN to pick up.
3
19.
On October 11, 2004, using coded language in a
4
telephone conversation, defendant MORIN told defendant J. MEJIA
5
that he had three kilograms of cocaine for defendant J. MEJIA.
6
20.
On October 11, 2004, using coded language in a
7
telephone conversation, defendant J. MEJIA told defendant MORIN
8
that defendant CEDENO would deliver $10,000 in proceeds from the
9
sale of cocaine and pick up three kilograms of cocaine.
10
21.
On October 11, 2004, defendant CEDENO transported three
11
kilograms of cocaine from defendant MORIN’s residence to the
12
Bakersfield, California area.
13
22.
On October 11, 2004, using coded language in a
14
telephone conversation, after defendant R. YEPIZ told defendant
15
MORIN that the cocaine was from a different source, defendant
16
MORIN told defendant R. YEPIZ that the previous shipment of
17
cocaine was converted into good quality cocaine base (crack).
18
23.
On October 11, 2004, using coded language in a
19
telephone conversation, defendant J. MEJIA told defendant MORIN
20
that defendant CEDENO would arrive shortly and that defendant
21
CEDENO would bring $12,000 in proceeds from the sale of
22
narcotics.
23
24.
On October 11, 2004, defendant CEDENO drove three
24
kilograms of cocaine from defendant MORIN’s residence to the
25
Bakersfield, California area.
26
25.
On October 11, 2004, using coded language in a
27
telephone conversation, defendant MORIN told defendant R. YEPIZ
28
that defendant CEDENO had not yet arrived at defendant J. MEJIA’s
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1
2
location.
26.
On October 12, 2004, using coded language in a
3
telephone conversation, defendant J. MEJIA told defendant MORIN
4
that defendant CEDENO had been arrested by law enforcement.
5
27.
On October 21, 2004, using coded language in a
6
telephone conversation, defendant MORIN agreed to supply
7
defendant S. MEJIA with one kilogram of good quality cocaine for
8
$14,300, which defendant MORIN agreed to transport to the
9
Bakersfield, California area.
10
28.
On October 22, 2004, using coded language in a
11
telephone conversation, defendant MORIN agreed to allow an
12
unindicted co-conspirator to deliver proceeds from the sale of
13
narcotics to L. RANGEL.
14
29.
On October 22, 2004, defendant L. RANGEL received
15
proceeds from the sale of narcotics from an unindicted co-
16
conspirator.
17
30.
On October 22, 2004, using coded language in a
18
telephone conversation, defendant L. RANGEL told defendant MORIN
19
that she had received proceeds from the sale of narcotics from an
20
unindicted co-conspirator, but she could not locate defendant
21
MORIN’s drug ledgers.
22
31.
On October 23, 2004, using coded language in a
23
telephone conversation, defendant J. MEJIA told defendant MORIN
24
that he would bring $15,000 in proceeds from the sale of cocaine.
25
26
27
28
32.
On October 23, 2004, defendant MORIN transported two
pounds of methamphetamine to defendant S. MEJIA.
33.
On October 23, 2004, using coded language in a
telephone conversation, defendant S. MEJIA told defendant MORIN
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1
that he needed an additional chemical to complete the conversion
2
of methamphetamine into crystal methamphetamine.
3
34.
On October 25, 2004, using coded language in a
4
telephone conversation, defendant MORIN told defendant CONTRERAS
5
that the crystal methamphetamine cost $7,000 per pound, but that
6
defendant S. MEJIA needed another chemical to complete the
7
manufacture of the crystal methamphetamine.
8
9
35.
On October 27, 2004, using coded language in a
telephone conversation, defendant MORIN told defendant S. MEJIA
10
that one pound of crystal methamphetamine was available, as well
11
as one kilogram of cocaine, which defendant S. MEJIA wanted to
12
convert into cocaine base (crack).
13
36.
On November 3, 2004, using coded language in a
14
telephone conversation, defendant MORIN told defendant R. YEPIZ
15
to take defendant J. MEJIA’s house as payment for the three
16
kilograms of cocaine that were seized by law enforcement.
17
18
19
37.
On November 5, 2004, defendant MORIN delivered
approximately 509 grams of cocaine to defendant S. MEJIA.
38.
On November 5, 2004, defendant S. MEJIA drove a white
20
Toyota Camry with approximately 509 grams of cocaine located
21
inside a brown paper bag underneath the front passenger seat.
22
39.
On November 5, 2004, using coded language in a
23
telephone conversation, after defendant J. MEJIA told defendant
24
MORIN that defendant S. MEJIA had been arrested, defendant MORIN
25
told defendant J. MEJIA that he had given defendant S. MEJIA 500
26
grams of cocaine.
27
28
40.
On November 5, 2004, using coded language in a
telephone conversation, defendant MORIN told defendant J. MEJIA
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1
to steal defendant S. MEJIA’s car from an impound yard before law
2
enforcement could search it.
3
41.
On November 6, 2004, using coded language in a
4
telephone conversation, defendant MORIN told defendant SAENZ that
5
defendant S. MEJIA was arrested by law enforcement after he left
6
defendant MORIN’s house with 500 grams of cocaine.
7
42.
On November 30, 2004, using coded language in a
8
telephone conversation, defendant MORIN told defendant J. MEJIA
9
that he was with defendant R. YEPIZ and that defendant R. YEPIZ
10
had five kilograms of cocaine, but wanted payment for two of the
11
kilograms.
12
43.
On December 4, 2004, using coded language in a
13
telephone conversation, defendant MORIN told defendant J. MEJIA
14
that defendant J. MEJIA owed him $36,500 for prior shipments of
15
narcotics.
16
44.
On December 4, 2004, using coded language in a
17
telephone conversation, defendant J. MEJIA told defendant MORIN
18
that he had converted one ounce of cocaine into cocaine base
19
(crack), but that the cocaine had not converted very well and
20
therefore defendant J. MEJIA wanted to return one kilogram of
21
cocaine.
22
45.
On January 6, 2005, using coded language in a telephone
23
conversation, defendant R. YEPIZ agreed to deliver two pounds of
24
crystal methamphetamine to defendants MORIN and J. MEJIA at
25
defendant MORIN’s residence.
26
46.
On March 1, 2005, defendant AGREDANO possessed
27
approximately 19 kilograms of cocaine, which had the Audi logo on
28
the packaging, 43 pounds of crystal methamphetamine, $95,555 in
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1
U.S. currency, and illegal drug paraphernalia at his residence.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNTS FOUR THROUGH NINE
2
[18 U.S.C. § 1959(a)(1)]
3
1.
At all times relevant to this Indictment, the VBS Gang,
4
as described more particularly in paragraphs One through Twelve
5
of the Introductory Allegations of this Indictment, which
6
paragraphs are incorporated and realleged herein as if set forth
7
in full, has constituted an enterprise as that term is defined in
8
Title 18, United States Code, Section 1959(b)(2), that is, a
9
group of individuals associated in fact, which was engaged in,
10
and the activities of which affected, interstate and foreign
11
commerce.
12
2.
At all times relevant to this Indictment, the VBS Gang,
13
through its members and associates, has been engaged in
14
racketeering activity, as defined in Title 18, United States
15
Code, Sections 1959(b)(1) and 1961(1), that is, among other
16
things, acts involving murder, in violation of California Penal
17
Code, Sections 21a, 31, 182, 664 and 187, narcotics trafficking,
18
in violation of Title 21, United States Code, Sections 841 and
19
846, laundering of monetary instruments, in violation of Title
20
18, United States Code, Section 1956, and obstruction of justice,
21
in violation of Title 18, United States Code, Sections 1512.
22
3.
On or about the dates specified below, the defendants
23
specified below committed the offenses specified below, and each
24
such offense was committed as consideration for the receipt of,
25
and as such consideration for a promise, and an agreement to pay,
26
a thing of pecuniary value from the VBS Gang, and for the purpose
27
of maintaining and increasing the position of the specified
28
defendants in the VBS Gang, an enterprise engaged in racketeering
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1
activity, in violation of Title 18, United States Code, Section
2
1959(a)(1).
3
4
5
6
7
COUNT FOUR
4.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
5.
On or about May 12, 2003, within the Central District
8
of California and elsewhere, defendants LUIS SANDOVAL, also known
9
as (“aka”) the Barney Twins, JAVIER COVARRUBIUS, aka Coco, aka
10
Cokes, JOSE LEDESMA, aka Peps, and RAUL ROBLEDO, aka Clown, and
11
others, unlawfully, willfully, deliberately, maliciously, and
12
with premeditation and malice aforethought did aid, abet, advise,
13
encourage, and otherwise participate in the murder of MP, in
14
violation of California Penal Code, Sections 31 and 187, and
15
Title 18, United States Code, Sections 1512 and 1513.
16
17
18
19
20
COUNT FIVE
6.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
7.
On or about August 12, 2003, within the Central
21
District of California and elsewhere, defendants HORACIO YEPIZ,
22
also known as (“aka”) Alberto Rodriguez, aka Horse, and GUSTAVO
23
RODRIGUEZ, aka Noid, unlawfully, willfully, deliberately,
24
maliciously, and with premeditation and malice aforethought, did
25
aid, abet, advise, encourage, and otherwise participate in the
26
murder of EC, in violation of California Penal Code, Sections 31
27
and 187.
28
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1
2
3
4
COUNT SIX
8.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
9.
On or about November 15, 2003, within the Central
5
District of California and elsewhere, defendant DAVID GARCIA,
6
also known as (“aka”) Davey Crockett, unlawfully, willfully,
7
deliberately, maliciously, and with premeditation and malice
8
aforethought did aid, abet, advise, encourage, and otherwise
9
participate in the murder of Burbank Police Officer MP, in
10
violation of California Penal Code, Sections 31 and 187.
11
12
13
14
15
COUNT SEVEN
10.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
11.
On or about November 15, 2003, within the Central
16
District of California and elsewhere, defendant DAVID GARCIA,
17
also known as (“aka”) Davey Crockett, and others, unlawfully,
18
willfully, deliberately, maliciously, and with premeditation and
19
malice aforethought did aid, abet, advise, encourage, and
20
otherwise participate in the attempted murder of Burbank Police
21
Officer GC, in violation of California Penal Code, Sections 21a,
22
31, 664 and 187.
23
24
25
26
27
28
COUNT EIGHT
12.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
13.
On or about October 20, 2004, within the Central
District of California and elsewhere, defendant JAVIER
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1
COVARRUBIUS, also known as (“aka”) Coco, aka Cokes, and others,
2
did aid, abet, advise, encourage, and otherwise willfully
3
participate in the assault with a firearm of MM, in violation of
4
California Penal Code, Sections 31 and 245(a)(2).
5
6
7
8
9
COUNT NINE
14.
Paragraphs one through three are hereby incorporated
and realleged herein as if set forth in full.
15.
On or about January 19, 2005, within the Central
10
District of California and elsewhere, defendant ESPIRIDION
11
ARANDA, also known as (“aka”) Pete Josui, aka Antonio Marmolejo,
12
aka Peety, and others, did aid, abet, advise, encourage, and
13
otherwise willfully participate in the assault with a firearm of
14
OG, in violation of California Penal Code, Sections 31 and
15
245(a)(2).
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT TEN
2
[21 U.S.C. § 841(c)(2)]
3
On or about February 25, 2002, in Los Angeles County, within
4
the Central District of California, defendant GUSTAVO RODRIGUEZ,
5
also known as Noid, knowingly and intentionally possessed
6
pseudoephedrine, a list I chemical, knowing and having reasonable
7
cause to believe that the pseudoephedrine would be used to
8
manufacture a controlled substance, namely, methamphetamine, a
9
schedule II controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT ELEVEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about November 15, 2003, in Los Angeles County, within
4
the Central District of California, defendant DAVID GARCIA, also
5
known as Davey Crockett, knowingly and intentionally possessed
6
with intent to distribute more than 50 grams, that is,
7
approximately 101 grams, of actual methamphetamine, a schedule II
8
controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT TWELVE
2
[21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(A)]
3
From approximately May 2003 until on or about November 26,
4
2003, in Los Angeles County, within the Central District of
5
California, defendants LUIS SANDOVAL, also known as ("aka") the
6
Barney Twins, and SAIGN MAHAYA CHARLSESTEIN, aka Shawn, knowingly
7
and intentionally attempted to manufacture at least 1,000
8
marijuana plants, a Schedule I controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT THIRTEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A); 18 U.S.C. § 2(a)]
3
On or about September 24, 2004, in Los Angeles County,
4
within the Central District of California, defendant ESPIRIDION
5
ARANDA, also known as (“aka”) Pete Josui, aka Antonio Marmolejo,
6
aka Peety, knowingly and intentionally possessed with intent to
7
distribute at least 50 grams of a mixture or substance containing
8
a detectable amount of methamphetamine, a schedule II controlled
9
substance.
10
Defendant CARLOS ABLE CASILLAS, aka Tetiro, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT FOURTEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about September 28, 2004, in Los Angeles County,
4
within the Central District of California, defendant JESUS
5
SANDOVAL, also known as (“aka”) Chuy, aka the Barney Twins,
6
knowingly and intentionally distributed more than 500 grams, that
7
is, approximately four kilograms, of a mixture or substance
8
containing a detectable amount of cocaine, a schedule II narcotic
9
drug controlled substance.
10
Defendant RAFAEL YEPIZ, aka Ralph, aka Sneaks, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT FIFTEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about September 28, 2004, in Los Angeles County,
4
within the Central District of California, defendants RAFAEL
5
YEPIZ, also known as (“aka”) Ralph, aka Sneaky, and JOE MORIN
6
RANGEL, aka Little Joe, knowingly and intentionally possessed
7
with intent to distribute at least 500 grams, that is
8
approximately four kilograms, of a mixture or substance
9
containing a detectable amount of cocaine, a schedule II narcotic
10
11
drug controlled substance.
Defendant RAFAEL YEPIZ, aka Ralph, aka Sneaks, knowingly and
12
intentionally aided, abetted, counseled, commanded, induced, and
13
procured the commission of this offense.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
COUNT SIXTEEN
2
[21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(B)]
3
On or about September 28, 2004, in Los Angeles County,
4
within the Central District of California, defendant RUBEN AYALA,
5
also known as (“aka”) Fat Boy, aka Shy Boy
6
intentionally attempted to possess with intent to distribute more
7
than 500 grams, that is, approximately one kilogram, of a mixture
8
or substance containing a detectable amount of cocaine, a
9
schedule II narcotic drug controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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knowingly and
1
COUNT SEVENTEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about October 3, 2004, in Los Angeles County, within
4
the Central District of California, defendant ALBERTO SANCHEZ,
5
also known as (“aka”) Hector Rodriguez Marin, aka Beto,
6
knowingly and intentionally distributed more than 500 grams, that
7
is, approximately one kilogram, of a mixture or substance
8
containing a detectable amount of cocaine, a schedule II narcotic
9
drug controlled substance.
10
Defendant RAFAEL YEPIZ, aka Ralph, aka Sneaks, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 119 -
1
COUNT EIGHTEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about October 3, 2004, in Los Angeles County, within
4
the Central District of California, defendant RUBEN AYALA, also
5
known as (“aka”) Fat Boy, aka Shy Boy, knowingly and
6
intentionally possessed with intent to distribute at least 500
7
grams, that is approximately one kilogram, of a mixture or
8
substance containing a detectable amount of cocaine, a schedule
9
II narcotic drug controlled substance.
10
Defendant RAFAEL YEPIZ, aka Ralph, aka Sneaky, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 120 -
1
COUNT NINETEEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about October 11, 2004, in Los Angeles County, within
4
the Central District of California, defendant ALBERTO SANCHEZ,
5
also known as (“aka”) Hector Rodriguez Marin, aka Beto, knowingly
6
and intentionally distributed more than 500 grams, that is,
7
approximately three kilograms, of a mixture or substance
8
containing a detectable amount of cocaine, a schedule II narcotic
9
drug controlled substance.
10
Defendant RAFAEL YEPIZ, aka Ralph, aka Sneaks, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 121 -
1
COUNT TWENTY
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about October 11, 2004, in Los Angeles County, within
4
the Central District of California, defendant JOE MORIN RANGEL,
5
aka Little Joe, knowingly and intentionally distributed more than
6
500 grams, that is, approximately three kilograms, of a mixture
7
or substance containing a detectable amount of cocaine, a
8
schedule II narcotic drug controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 122 -
1
COUNT TWENTY-ONE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about October 11, 2004, in Los Angeles County, within
4
the Central District of California, defendant JOSE LUIS MEJIA,
5
also known as Cheech, and JUAN CEDENO GOMEZ knowingly and
6
intentionally possessed with intent to distribute more than 500
7
grams, that is, approximately three kilograms, of a mixture or
8
substance containing a detectable amount of cocaine, a schedule
9
II narcotic drug controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 123 -
1
COUNT TWENTY-TWO
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about November 5, 2004, in Los Angeles County, within
4
the Central District of California, defendant ALONZO SAENZ
5
RANGEL, also known as Choncho, knowingly and intentionally
6
distributed more than 500 grams, that is, approximately one
7
kilogram, of a mixture or substance containing a detectable
8
amount of cocaine, a schedule II narcotic drug controlled
9
substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 124 -
1
COUNT TWENTY-THREE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about November 5, 2004, in Los Angeles County, within
4
the Central District of California, defendant JOE MORIN RANGEL,
5
aka Little Joe, knowingly and intentionally distributed more than
6
500 grams, that is, approximately 509 grams, of a mixture or
7
substance containing a detectable amount of cocaine, a schedule
8
II narcotic drug controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 125 -
1
COUNT TWENTY-FOUR
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about November 5, 2004, in Los Angeles County, within
4
the Central District of California, defendant SERGIO MEJIA, also
5
known as Jaws, knowingly and intentionally possessed with intent
6
to distribute more than 500 grams, that is, approximately 509
7
grams, of a mixture or substance containing a detectable amount
8
of cocaine, a schedule II narcotic drug controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 126 -
1
COUNT TWENTY-FIVE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A); 18 U.S.C. § 2(a)]
3
On or about November 30, 2004, in Los Angeles County, within
4
the Central District of California, defendant ESPIRIDION ARANDA,
5
also known as (“aka”) Pete Josui, aka Antonio Marmolejo, aka
6
Peety, knowingly and intentionally possessed with intent to
7
distribute at least 500 grams, that is approximately two pounds,
8
of a mixture or substance containing a detectable amount of
9
methamphetamine, a schedule II controlled substance.
10
Defendant CARLOS ABLE CASILLAS, aka Tetiro, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 127 -
1
COUNT TWENTY-SIX
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about December 21, 2004, in Los Angeles County, within
4
the Central District of California, defendant RUBEN MEDINA, also
5
known as (“aka”) Camaron, aka Juan Luna Risos, knowingly and
6
intentionally possessed with intent to distribute at least 50
7
grams, that is approximately 51 grams, of a mixture or substance
8
containing a detectable amount of cocaine base (crack), a
9
schedule II narcotic drug controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 128 -
1
COUNT TWENTY-SEVEN
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about December 21, 2004, in Los Angeles County, within
4
the Central District of California, defendant RUBEN MEDINA, also
5
known as (“aka”) Camaron, aka Juan Luna Risos, knowingly and
6
intentionally possessed with intent to distribute at least 5
7
grams, that is approximately 5 grams, of actual methamphetamine,
8
a schedule II controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 129 -
1
COUNT TWENTY-EIGHT
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about January 6, 2005, in Los Angeles County, within
4
the Central District of California, defendants RAFAEL YEPIZ, also
5
known as (“aka”) Ralph, aka Sneaky, JESUS SANDOVAL, aka Chuy, aka
6
the Barney Twins, and IGNACIO HARO, aka Nose, knowingly and
7
intentionally possessed with intent to distribute at least 50
8
grams, that is, approximately two pounds, of actual
9
methamphetamine, a schedule II controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 130 -
1
COUNT TWENTY-NINE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or before January 17, 2005, in Los Angeles County, within
4
the Central District of California, defendants CARLOS ABLE
5
CASILLAS, aka Tetiro, MARCELINO MACIAS, ERNESTO MENDEZ, aka
6
Gordo, and LUIS GARCIA knowingly and intentionally possessed with
7
intent to distribute more than five kilograms, that is,
8
approximately 53 kilograms, of a mixture or substance containing
9
a detectable amount of cocaine, a schedule II narcotic drug
10
controlled substance.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 131 -
1
COUNT THIRTY
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about January 18, 2005, in Los Angeles County, within
4
the Central District of California, defendant CARLOS ABLE
5
CASILLAS, aka Tetiro, MARCELINO MACIAS, ERNESTO MENDEZ, aka
6
Gordo, and LUIS GARCIA knowingly and intentionally possessed with
7
intent to distribute more than 500 grams, that is, approximately
8
one kilogram, of a mixture or substance containing a detectable
9
amount of cocaine, a schedule II narcotic drug controlled
10
substance.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 132 -
1
COUNT THIRTY-ONE
2
[21 U.S.C. §§ 841(a)(1)]
3
On or about January 18, 2005, in Los Angeles County, within
4
the Central District of California, defendant CARLOS CASILLAS,
5
also known as (“aka”) Tetiro, MARCELINO MACIAS, and LUIS GARCIA,
6
knowingly and intentionally possessed with intent to distribute
7
approximately 111 pounds of a mixture or substance containing a
8
detectable amount of marijuana, a schedule I controlled
9
substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 133 -
1
COUNT THIRTY-TWO
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A); 18 U.S.C. § 2(a)]
3
On or about January 25, 2005, in Los Angeles County, within
4
the Central District of California, defendant ESPIRIDION ARANDA,
5
also known as (“aka”) Pete Josui, aka Antonio Marmolejo, aka
6
Peety, knowingly and intentionally possessed with intent to
7
distribute at least 500 grams, that is approximately two pounds,
8
of a mixture or substance containing a detectable amount of
9
methamphetamine, a schedule II controlled substance.
10
Defendant CARLOS ABLE CASILLAS, aka Tetiro, knowingly and
11
intentionally aided, abetted, counseled, commanded, induced, and
12
procured the commission of this offense.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 134 -
1
COUNT THIRTY-THREE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about February 28, 2005, in Los Angeles County, within
4
the Central District of California, defendants CLETO VASQUEZ and
5
ALONZA SAENZ RANGEL, also known as Choncho, knowingly and
6
intentionally possessed with intent to distribute more than five
7
kilograms, that is, approximately 13 kilograms, of a mixture or
8
substance containing a detectable amount of cocaine, a schedule
9
II narcotic drug controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 135 -
1
COUNT THIRTY-FOUR
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about March 1, 2005, in Los Angeles County, within the
4
Central District of California, defendant JOSE DE JESUS AGREDANO
5
knowingly and intentionally possessed with intent to distribute
6
more than five kilograms, that is, approximately 19 kilograms, of
7
a mixture or substance containing a detectable amount of cocaine,
8
a schedule II narcotic drug controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 136 -
1
COUNT THIRTY-FIVE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about March 1, 2005, in Los Angeles County, within the
4
Central District of California, defendant JOSE DE JESUS AGREDANO
5
knowingly and intentionally possessed with intent to distribute
6
more than 500 grams, that is, approximately 43 pounds, of a
7
mixture or substance containing a detectable amount of
8
methamphetamine, a schedule II controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 137 -
1
COUNT THIRTY-SIX
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about March 1, 2005, in Los Angeles County, within the
4
Central District of California, defendant RAFAEL YEPIZ, also
5
known as (“aka”) Ralph, aka Sneaky, knowingly and intentionally
6
possessed with intent to distribute more than 100 kilograms, that
7
is, approximately 300 pounds, of a mixture or substance
8
containing a detectable amount of marijuana, a schedule I
9
controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 138 -
1
COUNT THIRTY-SEVEN
2
[21 U.S.C. §§ 841(a)(1); 18 U.S.C. § 2(a)]
3
On or about March 1, 2005, in Los Angeles County, within the
4
Central District of California, defendant RAFAEL YEPIZ, also
5
known as (“aka”) Ralph, aka Sneaky, knowingly and intentionally
6
aided, abetted, counseled, commanded, induced, and procured the
7
possession with intent to distribute approximately 78 pounds of a
8
mixture or substance containing a detectable amount of marijuana,
9
a schedule I controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 139 -
1
COUNT THIRTY-EIGHT
2
[21 U.S.C. §§ 841(a)(1)]
3
On or about March 1, 2005, in Los Angeles County, within the
4
Central District of California, defendant CLETO VASQUEZ knowingly
5
and intentionally possessed with intent to distribute
6
approximately 78 pounds of a mixture or substance containing a
7
detectable amount of marijuana, a schedule I controlled
8
substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 140 -
1
COUNT THIRTY-NINE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B); 18 U.S.C. § 2(a)]
3
On or about March 2, 2005, in Los Angeles County, within the
4
Central District of California, defendant CLETO VASQUEZ knowingly
5
and intentionally attempted to possess with intent to distribute
6
more than 100 kilograms, that is, approximately 222 pounds, of a
7
mixture or substance containing a detectable amount of marijuana,
8
a schedule I controlled substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 141 -
1
2
3
COUNT FORTY
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
On or about March 2, 2005, in Los Angeles County, within the
4
Central District of California, defendants ALONZO SAENZ RANGEL,
5
also known as Choncho, and CLETO VASQUEZ knowingly and
6
intentionally possessed with intent to distribute more than five
7
kilograms, that is, approximately 8 kilograms, of a mixture or
8
substance containing a detectable amount of cocaine, a schedule
9
II narcotic drug controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 142 -
1
COUNT FORTY-ONE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about March 2, 2005, in Los Angeles County, within the
4
Central District of California, defendants ALONZO SAENZ RANGEL,
5
also known as Choncho, and CLETO VASQUEZ knowingly and
6
intentionally distributed more than 500 grams, that is,
7
approximately two kilograms, of a mixture or substance containing
8
a detectable amount of cocaine, a schedule II narcotic drug
9
controlled substance.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 143 -
1
COUNT FORTY-TWO
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(B)]
3
On or about March 2, 2005, in Los Angeles County, within the
4
Central District of California, defendants RAFAEL YEPIZ, also
5
known as (“aka”) Ralph, aka Sneaky, and CARLOS CAMPOS, aka
6
Blackie, knowingly and intentionally possessed with intent to
7
distribute more than 500 grams, that is, approximately two
8
kilograms, of a mixture or substance containing a detectable
9
amount of cocaine, a schedule II narcotic drug controlled
10
substance.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 144 -
1
COUNT FORTY-THREE
2
[21 U.S.C. §§ 841(a)(1), 841(b)(1)(A)]
3
On or about March 4, 2005, in Los Angeles County, within the
4
Central District of California, defendant JESUS CONTRERAS, also
5
known as Yuck, knowingly and intentionally possessed with intent
6
to distribute more than 50 grams, that is, approximately 100
7
grams, of actual methamphetamine, a schedule II controlled
8
substance.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 145 -
1
COUNT FORTY-FOUR
2
[21 U.S.C. § 848(e)(1)(B)]
3
On or about November 15, 2003, in Los Angeles County, within
4
the Central District of California, defendant DAVID GARCIA, also
5
known as (“aka”) Davey Crockett (“D. GARCIA”), during the
6
commission of the offense alleged in Count Eleven, namely,
7
knowingly and intentionally possessing with intent to distribute
8
more than 50 grams, that is, approximately 101 grams, of actual
9
methamphetamine, a schedule II controlled substance, and while
10
attempting to avoid apprehension, prosecution, and service of a
11
prison sentence for the crime charged in Count Eleven,
12
intentionally killed a law enforcement officer, namely, Burbank
13
Police Department Officer MP, while Officer MP was engaged in, or
14
on account of, the performance of his official duties.
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 146 -
1
COUNT FORTY-FIVE
2
[18 U.S.C. §§ 924(c)(1)(A)(ii) and (iii), (j)(1)]
3
On or about May 12, 2003, in Los Angeles County, within the
4
Central District of California, defendant RAUL ROBLEDO, also
5
known as Clown, used and carried a firearm, during and in
6
relation to a crime of violence, namely Violent Crime in Aid of
7
Racketeering, in violation of Title 18, United States Code,
8
Section 1959(a), as alleged in Count Four of this Indictment,
9
and, in doing so, brandished and discharged said firearm, and in
10
the course of said violation, caused the death of a person
11
through the use of the above-described firearm in circumstances
12
constituting murder as defined in Title 18, United States Code,
13
Section 1111.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 147 -
1
COUNT FORTY-SIX
2
[18 U.S.C. §§ 924(c)(1)(A)(ii) and (iii), (j)(1)]
3
On or about August 12, 2003, in Los Angeles County, within
4
the Central District of California, defendant HORACIO YEPIZ, also
5
known as (“aka”) Alberto Rodriguez, aka Horse, used and carried a
6
firearm, during and in relation to a crime of violence, namely
7
Violent Crime in Aid of Racketeering, in violation of Title 18,
8
United States Code, Section 1959(a), as alleged in Count Five of
9
this Indictment, and, in doing so, brandished and discharged said
10
firearm, and in the course of said violation, caused the death of
11
a person through the use of the above-described firearm in
12
circumstances constituting murder as defined in Title 18, United
13
States Code, Section 1111.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 148 -
1
COUNT FORTY-SEVEN
2
[18 U.S.C. §§ 924(c)(1)(A)(ii) and (iii), (j)(1)]
3
On or about November 15, 2003, in Los Angeles County, within
4
the Central District of California, defendant DAVID GARCIA, also
5
known as (“aka”) Davey Crockett, used and carried a firearm,
6
during and in relation to a crime of violence, namely Violent
7
Crime in Aid of Racketeering, in violation of Title 18, United
8
States Code, Section 1959(a), as alleged in Count Six of this
9
Indictment, and, in doing so, brandished and discharged said
10
firearm, and in the course of said violation, caused the death of
11
a person through the use of the above-described firearm in
12
circumstances constituting murder as defined in Title 18, United
13
States Code, Section 1111.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 149 -
1
COUNT FORTY-EIGHT
2
[18 U.S.C. §§ 924(c)(1)(A) and (B)(ii)]
3
On or about November 18, 2003, in Los Angeles County, within
4
the Central District of California, defendant LUIS SANDOVAL, also
5
known as the Barney Twins, knowingly possessed a machine gun, in
6
furtherance of a drug trafficking crime, namely, the manufacture
7
of marijuana, in violation of Title 21, United States Code
8
Section 841(a)(1), as alleged in Count Twelve of this Indictment.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 150 -
1
COUNT FORTY-NINE
2
[18 U.S.C. §§ 924(c)(1)(A)(ii) and (iii)]
3
On or about October 20, 2004, in Los Angeles County, within
4
the Central District of California, defendant JAVIER COVARRUBIUS,
5
also known as (“aka”) Coco, aka Cokes, used and carried a
6
firearm, during and in relation to a crime of violence, namely
7
Violent Crime in Aid of Racketeering, in violation of Title 18,
8
United States Code, Section 1959(a), as alleged in Count Eight of
9
this Indictment, and, in doing so, brandished and discharged said
10
firearm.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 151 -
1
COUNT FIFTY
2
[18 U.S.C. §§ 924(c)(1)(A)(ii) and (iii)]
3
On or about January 19, 2005, in Los Angeles County, within
4
the Central District of California, defendant ESPIRIDION ARANDA,
5
also known as (“aka”) Pete Josui, aka Antonio Marmolejo, aka
6
Peety, used and carried a firearm, during and in relation to a
7
crime of violence, namely Violent Crime in Aid of Racketeering,
8
in violation of Title 18, United States Code, Section 1959(a), as
9
alleged in Count Nine of this Indictment, and, in doing so,
10
brandished and discharged said firearm.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 152 -
1
COUNT FIFTY-ONE
2
[18 U.S.C. § 924(c)(1)(A)(i)]
3
On or about January 27, 2005, in Los Angeles County, within
4
the Central District of California, defendant ESPIRIDION ARANDA,
5
aka Pete Josui, aka Antonio Marmolejo, aka Peety, knowingly used
6
and carried a firearm, during and in relation to a drug
7
trafficking crime, namely, possession with intent to distribute
8
methamphetamine, in violation of Title 21, United States Code
9
Section 841(a)(1), and possessed that firearm in furtherance of
10
that drug trafficking crime.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 153 -
1
COUNT FIFTY-TWO
2
[18 U.S.C. § 3]
3
On or about November 15, 2003, in Los Angeles County, within
4
the Central District of California, defendants JESUS SANDOVAL,
5
also known as (“aka”) Chuy, aka the Barney Twins, IGNACIO HARO,
6
aka Nose, GILBERTO CARRASCO, aka Beton, ERIK AVINA, and JUAN
7
SALINAS, aka Pickles, knowing that an offense against the United
8
States has been committed, namely, Violent Crime in Aid of
9
Racketeering, in violation of Title 18, United States Code,
10
Section 1959(a), as charged in Count Six of this indictment,
11
received, relieved, comforted, and assisted the offender, David
12
Garcia, aka Davey Crockett, in order to hinder and prevent the
13
offender’s apprehension, trial, and punishment.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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COUNT FIFTY-THREE
2
[18 U.S.C. § 922(o)(1)]
3
On or about November 18, 2003, in Los Angeles County, within
4
the Central District of California, defendant LUIS SANDOVAL, also
5
known as the Barney Twins, knowingly and unlawfully possessed a
6
machine gun, namely, a MAK-90 Sporter 7.62 caliber machine gun.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
FIFTY-FOUR
2
[18 U.S.C. § 922(g)(1)]
3
On or about January 27, 2005, in Los Angeles County, within
4
the Central District of California, defendant ESPIRIDION ARANDA,
5
also known as (“aka”) Pete Josui, aka Antonio Marmolejo, aka
6
Peety, having been convicted on or about December 16, 1999, of a
7
felony punishable by a term of imprisonment exceeding one year,
8
namely, possession with intent to distribute cocaine, in
9
violation of Title 21, United States Code, Sections 841(a)(1),
10
841(b)(1)(B), in the Western District of Kentucky (Case No.
11
99CR-00096-H), knowingly possessed a firearm, namely, a Beretta
12
9mm caliber semi-automatic handgun, in and affecting interstate
13
and foreign commerce.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1
FIFTY-FIVE
2
[31 U.S.C. § 5324(b)(3)]
3
On or about the following dates, in Los Angeles County,
4
within the Central District of California, defendants RAFAEL
5
YEPIZ, also known as (“aka”) Ralph, aka Sneaky (“R. YEPIZ”), and
6
HILDA RODRIGUEZ YEPIZ (“H.R. YEPIZ”), knowingly structured or
7
assisted in structuring the following financial transaction
8
affecting interstate and foreign commerce, for the purpose of
9
evading the reporting requirements of 31 U.S.C. § 5331 and
10
regulations prescribed thereunder, to wit, the purchase of a 2003
11
Chevrolet Monte Carlo (“Monte Carlo”) on February 3, 2003, as
12
follows:
13
14
15
16
17
!
On February 3, 2003, defendant R. YEPIZ paid $500 in
U.S. currency to Rydell Automotive for the Monte Carlo.
!
On February 7, 2003, defendant R. YEPIZ paid $8,500 in
U.S. currency to Rydell Automotive for the Monte Carlo.
!
On February 7, 2003, defendant R. YEPIZ wrote a $9,000
18
check to Rydell Automotive for the Monte Carlo from a Washington
19
Mutual bank account held by defendants R. YEPIZ and H.R. YEPIZ
20
(the “Washington Mutual Account”).
21
!
On February 20, 2003, defendant H.R. YEPIZ deposited
22
$4,000 in U.S. currency into the Washington Mutual Account in
23
order to provide funds to cover the $9,000 check.
24
!
On February 21, 2003, defendant R. YEPIZ deposited
25
$5,000 in U.S. currency into the Washington Mutual Account in
26
order to provide funds to cover the $9,000 check.
27
28
!
On February 25, 2003, the $9,000 check written to
Rydell Automotive cleared the Washington Mutual Account.
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1
COUNT FIFTY-SIX
2
[21 U.S.C. § 853]
3
1.
Pursuant to Title 21, United States Code, Section 853,
4
each defendant who is convicted of the offense set forth in any
5
of Count Three and Counts Ten through Forty-Two shall forfeit to
6
the United States the following property:
7
a.
All right, title, and interest in any and all
8
property --
9
(i)
constituting, or derived from, any proceeds
10
obtained, directly or indirectly, as a result
11
of the offenses described in Counts Three and
12
Counts Eleven through Forty-Nine and
13
(ii) any property, real or personal, used, or
14
intended to be used, in any manner or part,
15
to commit, or to facilitate the commission
16
of, each such offense.
17
b.
A sum of money equal to the total value of the
18
property described in paragraph 1(a)(i),
19
representing the amount of proceeds obtained as a
20
result of the offenses, less the value of actual
21
proceeds forfeited, for which the defendants are
22
jointly and severally liable.
23
2.
Pursuant to Title 21, United States Code, Section
24
853(p), each defendant shall forfeit substitute property, up to
25
the value of the total amount described in paragraph 1.a, if, as
26
the result of any act or omission of said defendant, said
27
property, or any portion thereof, cannot be located upon the
28
exercise of due diligence; has been transferred, sold to or
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1
deposited with a third party; has been placed beyond the
2
jurisdiction of the court; has been substantially diminished in
3
value; or has been commingled with other property which cannot be
4
divided without difficulty.
5
A TRUE BILL
6
7
Foreperson
8
9
DEBRA WONG YANG
United States Attorney
10
11
12
STEVEN D. CLYMER
Special Assistant United States Attorney
Chief, Criminal Division
13
14
15
MARK A. YOUNG
Assistant United States Attorney
Narcotics Section
16
17
18
19
20
21
22
23
24
25
26
27
28
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