12.07.2015 Views

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ...

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ...

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ...

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728AFFIDAVIT OF CLINTON LINDSLYI, Clinton Lindsly, hereby swear and affirm as follows:IINTRODUCTION1. I have been a Special Agent (SA) for the Department ofHomeland Security (DHS), Immigration and Customs Enforcement (ICE),Homeland Security Investigations (HSI), since August <strong>20</strong><strong>10</strong>. I amcurrently assigned to Financial Group I, which investigates drugtrafficking and money laundering organizations that operate in theUnited States. As such, I am an investigator or law enforcementofficer of the United States, within the meaning of Title <strong>18</strong>,United States Code, Section <strong>25</strong><strong>10</strong>(7), and I am empowered by law toconduct investigations of, and to make arrests for, the offensesenumerated in Title <strong>18</strong>, United States Code, Section <strong>25</strong><strong>16</strong>.Furthermore, per the Interagency Cooperation Agreement between theDrug Enforcement Administration (DEA) and ICE/HSI, I am across-designated agent authorized to investigate violations ofTitle <strong>21</strong>, United States Code. I am certified by the CaliforniaAttorney General to conduct wiretaps as authorized in CaliforniaPenal Code Section 629.50 et seq.2. As a Special Agent, I attended the Federal LawEnforcement Training Center (FLETC) from August <strong>20</strong><strong>10</strong> to February<strong>20</strong><strong>11</strong> and completed the Criminal Investigator Training Program(CITP) and ICE Special Agent Training (ICE SAT). I haveparticipated in many drug trafficking and money launderinginvestigations as a case agent or in a subsidiary role, involvingdrug trafficking and money laundering organizations operating inthe United States and in other countries. I have participated in


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728the debriefing of informants who had personal knowledge regardingmajor narcotics trafficking/money laundering organizations.Additionally, I have participated in many aspects of drug/bulk cashsmuggling investigations including undercover operations,conducting surveillance, search warrants, and arrests. Based on mytraining and experience, I have become familiar with the methodsused by traffickers to smuggle drugs into the United States fordistribution to other traffickers in the country. I am alsofamiliar with how traffickers and launderers use cell phones andother electronic devices to communicate, including the code wordsand jargon used to disguise the drug related nature of theirconversations. I am the case agent for the investigation describedherein.3. I make this affidavit based upon personal knowledgederived from my participation in this investigation and frominformation obtained from the following sources:a. Oral and written reports about this and otherinvestigations which I have received from various federal and locallaw enforcement agencies;b. Physical surveillance conducted by investigators,which I have participated in or was reported to me either directlyor indirectly;c. Wire interceptions, Global Positioning System (GPS)data, pen registers and trap and trace information, telephone tollrecords, and subscriber information;d. Financial and public records; and/ore. Confidential informants.4. Unless otherwise noted, wherever in this affidavit I2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728assert that a statement was made, the information was provided byanother law enforcement officer (who may have either direct orindirect knowledge of the statement) to whom I have spoken or whosereport I have reviewed.5. This affidavit is in support of criminal complaints andthe issuance of arrests warrants and search warrants as listedbelow.IICRIMINAL COMPLAINTS AND ARREST WARRANTS <strong>16</strong>. I believe that probable cause exists for the issuance ofarrest warrants for the following individuals: 2a. Gerardo Celis Gaytan, aka “Cholo,” aka “Gera”(“GAYTAN”): male; date of birth (DOB) 6/<strong>20</strong>/71; height 5'7"; weight<strong>19</strong>5 pounds; black hair; brown eyes. GAYTAN resides at 77<strong>24</strong> TujungaAvenue, Sun Valley, California, and operates an automobile shopnamed “Campos Auto Repair” located at <strong>11</strong>6<strong>22</strong> Vanowen Street unit 6,North Hollywood, California. GAYTAN is a Mexican citizen and aLawful Permanent Resident (LPR) with family currently in Mexico.In <strong>20</strong>04, GAYTAN was convicted in Utah for illegal possession and/or1 The defendant names and search locations are set forth below inbold print. A table summarizing the evidence against thedefendants is included as Attachment C to this Affidavit.2 Information about the defendants listed below was obtained fromthe following information sources and criminal indices: CaliforniaDepartment of Motor Vehicles (DMV), National Crime InformationCenter (NCIC), Customs and Border Protection (CBP) records, ICErecords, California Law Enforcement Tracking System (CLETS), DEArecords, Federal Bureau of Investigation (FBI) records, Bureau ofAlcohol, Tobacco, Firearms & Explosives (ATF) records,conversations with other agents and officers participating in thisinvestigation, and my own participation in the investigation.3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728use of a controlled substance.b. David Trujillo, aka “Pajaro Negro” (“TRUJILLO”):male; DOB 8/3/72; height 5'8"; weight <strong>23</strong>0 pounds; black hair; browneyes. TRUJILLO resides at <strong>13</strong>956 Weidner Street, Pacoima, and 5655Beckford Avenue, Tarzana, California. TRUJILLO is a United Statescitizen. In <strong>19</strong>91, TRUJILLO was convicted of possession of cocainefor sale. In <strong>19</strong>95, TRUJILLO was convicted of evading a policeofficer. In <strong>19</strong>98, TRUJILLO was convicted of sale andtransportation of a controlled substance. TRUJILLO works atGAYTAN’s auto shop.c. Jose Daniel Lopez, aka “El Chofer” (“LOPEZ”): male;DOB 1/6/79; height 5'8"; weight <strong>17</strong>5 pounds; black hair; brown eyes.LOPEZ operates a mason shop located at <strong>17</strong>0 Mace Street D3, ChulaVista, California, which is used to store drugs. LOPEZ is a UnitedStates citizen and primarily resides in Mexico. LOPEZ crosses intothe United States from Mexico daily.d. Carlos David Martinez Galvan (“GALVAN”): male; DOB1/<strong>12</strong>/89; height 5'6"; weight <strong>17</strong>0 pounds; black hair; brown eyes.GALVAN resides at <strong>12</strong><strong>25</strong> E. Frontage Road #<strong>19</strong>, Chula Vista,California. GALVAN is a Mexican citizen with a Border CrossingCard (BCC).e. Benjamin Avalos Zarate (“ZARATE”): male; DOB 4/5/60;height 5'5"; weight <strong>17</strong>5 pounds; gray hair; brown eyes. ZARATEresides at 805 E. Almond Avenue, Lompoc, California. ZARATE is aMexican citizen and is an illegal alien. In <strong>19</strong>90, ZARATE wasconvicted for possession of marijuana with intent to distribute.ZARATE is currently unemployed.4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728f. Roberto Murillo Sanchez, aka “Rigo” (“MURILLO”):male; DOB <strong>10</strong>/2/61; height 5'6"; weight 2<strong>10</strong> pounds; black hair;brown eyes. MURILLO resides at 2<strong>14</strong>8 Moonlight Court, Palmdale,California. MURILLO is a Mexican citizen and is an illegal alienwith family in Mexico. In <strong>19</strong>80, MURILLO was convicted ofpossession of a dangerous weapon. In <strong>19</strong>82, MURILLO was convictedof burglary. In <strong>19</strong>87, MURILLO was convicted of providing falseinformation to a peace officer. In <strong>19</strong>91, MURILLO was convicted ofselling marijuana and possession of a controlled substance. In<strong>19</strong>91, MURILLO was also convicted of corporal injury to a spouse orcohabitant. In <strong>19</strong>94, MURILLO was convicted for possession andpurchase of a controlled substance for sale. In <strong>20</strong>06, MURILLO wasconvicted for manufacture of a controlled substance.g. Nora Millan (“MILLAN”): female; DOB <strong>10</strong>/<strong>24</strong>/73; height5'2"; weight <strong>14</strong>9 pounds; black hair; brown eyes. MILLAN resides at2<strong>14</strong>8 Moonlight Court, Palmdale, CA. MILLAN is the wife of MURILLO.MILLAN is a Mexican citizen with family currently residing inMexico, and she is an illegal alien. MILLAN is currentlyunemployed.h. Sergio Ramos Ibarra, aka “Beto” (“IBARRA”): male;DOB <strong>10</strong>/8/88; height 5'<strong>10</strong>"; weight 300 pounds; black hair; browneyes. IBARRA resides at <strong>15</strong>037 Carrolton Street, Adelanto,California. IBARRA is a Mexican citizen and an illegal alien.IBARRA’s employment is unknown.i. Florencio Fernandez Galarza (“FERNANDEZ”): male; DOB<strong>10</strong>/<strong>13</strong>/66; height 5'2"; weight <strong>19</strong>0 pounds; black hair; brown eyes.FERNANDEZ resides at 84<strong>18</strong> 5th Street, Hesperia, California.FERNANDEZ is a Mexican citizen and currently a LPR. FERNANDEZ5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728primarily resides in Mexico and crosses into the United States fromMexico several times a week. FERNANDEZ’s wife currently resides inTijuana. FERNANDEZ is currently in federal custody pendingjudicial proceedings.j. Jaime Galarza, aka “El Malito,” aka “Gordo”(“GALARZA”): male; DOB 2/<strong>23</strong>/68; height 5'<strong>11</strong>"; weight 260 pounds;brown hair; hazel eyes. GALARZA resides at <strong>15</strong>856 Ute Road, AppleValley, California. GALARZA is a United States citizen and hasfamily currently residing in Mexico. GALARZA frequently crossesthe border into the United States from Mexico. GALARZA iscurrently unemployed.k. Jasmin Elisa Parra Barraza (“PARRA”): female; DOB4/<strong>20</strong>/80; height 5'6"; weight <strong>20</strong>0 pounds; black hair; brown eyes.PARRA resides at 9<strong>16</strong> Alamitos Avenue, Long Beach, California.PARRA is a Mexican citizen and is an illegal alien. PARRA iscurrently unemployed.l. Charro (“CHARRO”): male; not further identified.CHARRO resides in Mexico.m. FNU LNU <strong>11</strong>56, aka “Zaabtuff,” aka “AAA”(“ZAABTUFF”): male; not further identified. ZAABTUFF resides at anunknown location.n. Pancho (“PANCHO”): male; not further identified.PANCHO lives in the greater Los Angeles area.o. Miguel (“MIGUEL”): male; not further identified.MIGUEL resides in Mexico.p. Rodolfo Raygoza Tiznado, aka “Popo” (“RAYGOZA”):male; DOB <strong>11</strong>/<strong>13</strong>/78; height 5'6"; weight <strong>17</strong>0 pounds; black hair;brown eyes. RAYGOZA is a Mexican citizen and an illegal alien.6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728RAYGOZA was deported to Mexico on 5/<strong>21</strong>/<strong>12</strong>.q. Herculano Medina Rosales, aka “Iglesias”(“ROSALES”): male; DOB 7/<strong>17</strong>/68; height 6'1"; weight <strong>22</strong>5 pounds;black hair; brown eyes. ROSALES currently resides at <strong>12</strong>693 KumquatAvenue, Chino, California. ROSALES is a Mexican citizen and has aBCC.r. Joel Ahumada Pacheco, aka “El Jeuz” (“AHUMADA”):male; DOB 3/28/64; height 5'7"; weight <strong>15</strong>0 pounds; black hair;brown eyes. AHUMADA is a Mexican citizen and does not have animmigration status in the United States. AHUMADA resides inTijuana, Mexico, and does not currently cross into the UnitedStates. In <strong>19</strong>96, AHUMADA was convicted of possession of acontrolled substance. In <strong>19</strong>99, AHUMADA attempted to smuggle 7.8pounds of cocaine through the San Ysidro, California Port of Entryin a car. Upon inspection, AHUMADA fled back to Mexico on footleaving the car and cocaine.s. Amador Herrera Cosio (“COSIO”): male; DOB 4/<strong>17</strong>/75;height 5'5"; weight <strong>14</strong>0 pounds; black hair; black eyes. COSIOresides at <strong>13</strong><strong>19</strong> W. Summit Street Apartment #3, Long Beach,California. COSIO is a Mexican citizen and has an immigrant visa.After the seizure of drugs on 4/<strong>25</strong>/<strong>12</strong>, COSIO fled back to Mexico.t. Gera (“GERA”): male; not further identified. GERAresides in Mexico.u. Candelario Elias-Camacho, aka “Cande” (“ELIAS-CAMACHO”): male; DOB 2/2/<strong>19</strong>65. ELIAS-CAMACHO resides in Mexico.v. Jorge Fernando Bermudez, aka “Juan” (“BERMUDEZ”):male; DOB 6/7/81; height 5'8"; weight <strong>18</strong>0 pounds; black hair; browneyes. BERMUDEZ currently resides at <strong>12</strong>071 Wilken Way, Garden7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Grove, California. BERMUDEZ is a Mexican citizen and is a LPR.BERMUDEZ frequently crosses the border into the United States fromMexico. BERMUDEZ is currently employed at Engineered IndustrialProducts in the city of Cerritos, California. In <strong>20</strong>04, BERMUDEZwas convicted for possession of marijuana.w. Jonas Carrillo Partida, aka “Jonas” (“PARTIDA”):male; DOB 9/<strong>21</strong>/75; height 5'7"; weight <strong>15</strong>0 pounds; black hair;brown eyes. PARTIDA is a Mexican citizen and does not have animmigration status in the United States. PARTIDA resides inTijuana, Mexico, and does not appear to be crossing into the UnitedStates.x. Hermila Moreno (“MORENO”): female; DOB 3/2/76;height 4'1"; weight <strong>13</strong>0 pounds; black hair; brown eyes. MORENOresides at <strong>23</strong>2 N. Clifford Street, Rialto, California. MORENO is aMexican citizen and LPR. In May <strong>20</strong><strong>12</strong>, MORENO was arrested at theOtay Mesa, California, Port of Entry (POE) for attempting tosmuggle <strong>16</strong> kilograms of crystal methamphetamine into the UnitedStates in a car. MORENO is currently in federal custody pendingjudicial proceedings.y. Caluchas, aka “Cande” (“CALUCHAS”): male; notfurther identified. CALUCHAS resides in Mexico.z. Ricardo Bazua Perez (“BAZUA”): male; DOB 9/<strong>21</strong>/72;height 5'6"; weight <strong>25</strong>0 pounds; black hair; brown eyes. BAZUAresides at 7<strong>13</strong>6 36 th Street, Riverside, California. BAZUA is aMexican citizen and is an illegal alien. BAZUA was deported toMexico on 5/<strong>23</strong>/<strong>12</strong>.aa. Nereyda Benetiz (“BENETIZ”): female; DOB 7/<strong>15</strong>/72;height 5'4"; weight <strong>17</strong>0 pounds; brown hair; brown eyes. BENETIZ8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728resides at 7<strong>13</strong>6 36 th Street, Riverside, California. BENETIZ is aMexican citizen and LPR.bb. Chuma, aka “Raul” (“CHUMA”): male; not furtheridentified. CHUMA resides in Mexico.cc. Vicente Sanchez Hernandez (“SANCHEZ”): male; DOB7/<strong>19</strong>/72; height 5'6"; weight <strong>18</strong>5 pounds; black hair; brown eyes.SANCHEZ currently resides at <strong>11</strong>454 Eldridge Avenue, Sylmar,California. SANCHEZ is a Mexican citizen and an illegal alien.SANCHEZ was deported to Mexico on 5/7/<strong>12</strong>.dd. Juan Machado Martinez (“MARTINEZ”): male; DOB3/<strong>17</strong>/79; height 5'7"; weight <strong>17</strong>1 pounds; black hair; brown eyes.MARTINEZ currently resides at <strong>11</strong>501 Brussels Avenue, Sylmar,California. MARTINEZ is an illegal alien and was born in Mexico.ee. Chilipiquin (“CHILIPIQUIN”): male; not furtheridentified. CHILIPIQUIN resides in the greater Los Angeles area.ff. Gregorio Martinez Rios, aka “Goyo” (“RIOS”): male;DOB 6/9/70; height 5'7"; weight <strong>18</strong>0 pounds; brown hair; brown eyes.RIOS currently resides at 7733 Irvine Avenue, North Hollywood,California, and operates a business called “House of Tacos” locatedat <strong>13</strong>5<strong>21</strong> Sherman Way, Van Nuys, California. Agents have beenunable to locate or identify RIOS’s immigration status. In <strong>19</strong>90,RIOS was convicted of carrying a loaded firearm in a public place.gg. Maria Cardenas Machado (“MACHADO”): female; DOB<strong>11</strong>/<strong>20</strong>/61; height 5'7"; weight <strong>25</strong>0 pounds; brown hair; brown eyes.MACHADO resides at <strong>20</strong>95 Genevieve Street, San Bernardino,California. MACHADO is a Cuban citizen and is a LPR. In <strong>20</strong>02,MACHADO was convicted of possession of controlled substanceparaphernalia. In <strong>20</strong>04, MACHADO was arrested twice for alien9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728smuggling but prosecution was declined on both occasions. In <strong>20</strong>07,MACHADO was arrested for alien smuggling but prosecution wasdeclined. In <strong>20</strong>09, MACHADO attempted to smuggle 96 pounds ofmarijuana into the United States from Mexico and was subsequentlyarrested and convicted. In <strong>20</strong><strong>11</strong>, MACHADO was convicted forpossession of a controlled substance for sale and for maintaining aplace to sell a controlled substance.hh. Tony (“TONY”): male; not further identified. TONYresides in the greater Los Angeles area.ii. Juan Manuel Ruiz, Jr., aka “Junior” (“RUIZ”): male;DOB <strong>12</strong>/<strong>20</strong>/83; height 5'9"; weight <strong>20</strong>0 pounds; black hair; browneyes. RUIZ resides at 3401 Altadena Avenue, San Diego, California.RUIZ is a United States citizen and frequents Mexico.jj. Rogelio Ramon Bohon Chao, aka “Ramon” (“BOHON”):male; DOB 8/30/71; height 5'9"; weight 2<strong>20</strong> pounds; black hair;brown eyes. BOHON resides at 580A Florida Street, Imperial Beach,California. BOHON is a Mexican citizen and a LPR. BOHONfrequently crosses the border into the United States and alsoresides in Mexico. BOHON is currently in federal custody pendingjudicial proceedings.kk. BRAULIO (“BRAULIO”): male; not further identified.BRAULIO resides in Mexico.ll. Abejas (“ABEJAS”): male; not further identified.ABEJAS resides in Mexico.mm. El Musico (“EL MUSICO”): male; not furtheridentified. EL MUSICO resides in the greater Los Angeles area.nn. Jesus Jacobo Escobar (“ESCOBAR”): male; DOB 5/<strong>20</strong>/60;height 5'9"; weight <strong>17</strong>5 pounds; gray hair; brown eyes. ESCOBAR<strong>10</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728resides in Mexico. ESCOBAR is a Mexican citizen and possesses aBCC. In May <strong>20</strong><strong>12</strong>, ESCOBAR was arrested at the Calexico,California, POE attempting to smuggle approximately 31 kilograms ofcrystal methamphetamine in a car. ESCOBAR is currently in federalcustody pending judicial proceedings.oo. UM3<strong>18</strong> (“FNU LNU 3<strong>18</strong>”): male; not further identified.FNU LNU 3<strong>18</strong> resides in Mexico.pp. UM348 (“FNU LNU 348”): male; not further identified.FNU LNU 348 resides in the greater Los Angeles area, most likelySan Bernardino, California.qq. El Tigre (“EL TIGRE”): male; not further identified.EL TIGRE resides in the greater San Diego area.IIISEARCH WARRANTS: LOCATIONS TO BE SEARCHED7. Based on my training and experience, and the factscontained within this affidavit, there is probable cause to believethat the following locations (including vehicles parked in thedriveway, yard, garage, or designated parking space at thoselocations) (collectively the SUBJECT PREMISES) contain evidence,instrumentalities, and fruits of violations of the followingoffenses:a. Conspiracy to distribute, and possession with intentto distribute, controlled substances, in violation of <strong>21</strong> U.S.C.§§ 846 and 841(a)(1); andb. Conspiracy to import, and importation of, controlledsubstances, in violation of <strong>21</strong> U.S.C. §§ 963, 960, and 952(a).8. THE SUBJECT PREMISESa. 77<strong>24</strong> Tujunga Avenue, Sun Valley, California (“Tujunga<strong>11</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Residence”): According to surveillance, wiretaps, utility records,and other evidence, this location is GAYTAN’s primary residence.This residence is a single family residence on the north eastcorner of Tujunga Avenue and Wixom Street. The residence is offwhitestucco with brown trim. The front yard is covered in smallwhite rocks and is enclosed by a four foot brick and white wroughtiron fence. The door to the house faces north and opens inwardfrom east to west. The numbers “77<strong>24</strong>” are painted on the curb inblack against a white background. There is a rear alley thatallows access to the rear of the location. There is also a whitesix-foot wall that runs along the north side of the residenceattached to a white wrought iron gate that could allow access toboth a vehicle and a pedestrian. The garage is detached, and thereis access to the garage through the alley. It is possible that thegarage is being used as sleeping quarters. There is also a shedlikestructure located on the northeast corner of the lot.b. <strong>11</strong>6<strong>22</strong> Vanowen Street, unit 6, North Hollywood, CA(“Vanowen Auto Shop”): According to surveillance, wiretaps, andother evidence, this location is GAYTAN’s automobile business.This business is located within a multi-unit business dwellingoccupied by several auto repair businesses. The location is on thesoutheast corner of Vanowen Street and Irvine Avenue. The buildingis a gray brick “L” shaped building. The location to be searchedis located in the corner of the “L” under a blue sign with “CamposAuto Body & Repair” written in yellow. The numbers “<strong>11</strong>6<strong>22</strong>” are inred and affixed to the east facing wall on the north side of thebuilding. The location is surrounded by a fence that isapproximately seven feet high. The first three feet of the fence<strong>12</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728are gray brick, followed by a four foot black wrought iron gate.On top of the wrought iron gate is concertina wire.c. <strong>13</strong>956 Weidner Street, Pacoima, California (“WeidnerResidence”): According to surveillance, wiretaps, and otherevidence, this location is one of TRUJILLO’s residences. Thisresidence is a single family residence. The location is the firstresidence south of Laurel Canyon Road on the east side of WeidnerStreet. The numbers “<strong>13</strong>956” are marked on the curb in blackagainst a white background. In front of the property there is afour foot black wrought iron fence that leads to a four foot blackwrought iron gate that swings open and allows access for bothvehicles and pedestrians. The residence is further described aspeach stucco with white trim. There are two doors visible from thestreet, both facing east. The northern door is a white wroughtiron door that opens south to north. The southern door is also awhite metal door that opens north to south.d. 5655 Beckford Avenue, Tarzana, California (“BeckfordResidence”): According to surveillance, wiretaps, and otherevidence, this location is TRUJILLO’s primary residence. Thisresidence is a single family residence on the west side of BeckfordAvenue. Beckford Avenue south of Hatteras is a cul-de-sac.Located on the east side of Beckford Avenue is a park, and on thewest side are homes. There is an approximately eight foot wroughtiron gate in front of the residence. There is a white mailbox withthe numbers “5655” faintly written in black on the mailbox door.There appear to be several vehicles parked on the property behindthe gate.<strong>13</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728e. <strong>13</strong>5<strong>21</strong> Sherman Way, Suite G, Van Nuys, California(“Taco Shop”): According to surveillance, wiretaps, and otherevidence, this location is RIOS’s restaurant called “House ofTacos” and is a stash location for drugs. This business is in astrip mall located on the northeast corner of Sherman Way andAllott Avenue. The business is on the north part of the buildingwith the door facing south. It is the third business east ofAllott Avenue. “House of Tacos” is affixed in red letters abovethe business. There is a glass door that opens east to west with ametal security gate on the interior of the business. The letter“G” is marked above the glass door in white. The numbers “<strong>13</strong>5<strong>21</strong>”are affixed in black to the marquee located in front of the stripmall.f. <strong>17</strong>0 Mace Street, Suite D, Chula Vista, California(“Chula Vista Shop”): According to surveillance, wiretaps, andother evidence, this location is LOPEZ’s business. The business islocated on the west side of the street and is contained in amulti-suite commercial rental building complex having a primarilylight brownish grey stucco exterior. There are black letter andnumber combinations “D3” affixed to the dark brown office door onthe east side of the building. The office doors of the buildingare wood and are painted brown with a small window on the rightside with an awning over the office door and window, which itshares with the neighboring unit’s office door to the north. Thereare also brown metal roll-up doors for each suite.g. 2<strong>14</strong>8 Moonlight Court, Palmdale, California(“Moonlight Residence”): According to surveillance, wiretaps,utility records, and other evidence, this location is MURILLO’s and<strong>14</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728MILLAN’s primary residence. The premises is located at the end ofthe cul-de-sac on the south side of Moonlight Court, east ofFullmoon Street. The house is a two-story residence with tanstucco and white trim. The front door is white and faces north.The numbers “2<strong>14</strong>8” are affixed in black on the eave over thegarage. There is also a water fountain with dolphins in the frontyard of the location.h. <strong>15</strong>037 Carrolton Street, Adelanto, California(“Carrolton Residence”): According to surveillance, wiretaps, andother evidence, this residence is owned by MURILLO. The residenceis a single family residence, and it is the second residence southof Maryland Street on the east side of Carrolton Street. Thenumbers “<strong>15</strong>037” are affixed in black numbers to the wall north ofthe white garage door. The front door is blue and opens south tonorth. The house is further described as grey stucco with a darkergrey trim and grey tile roof.i. <strong>15</strong>856 Ute Road, Apple Valley, California (“UteResidence”): According to surveillance, wiretaps, and otherevidence, this location is GALARZA’s primary residence. Theresidence is located mid block on the west side of Ute Road betweenOtoe Road and Zuni Road. The house is further described as anoff-white stucco house with white trim. The numbers “<strong>15</strong>856” areaffixed to the eave over the garage door. There are no shingles onthe roof; it appears to be only plywood. The front door has awhite wrought iron security door that opens south to north. Thereis a white wrought iron security door on the south side of theresidence that is accessible through the backyard.<strong>15</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728j. 84<strong>18</strong> 5th Street, Hesperia, California (“5th StreetResidence”): According to surveillance, wiretaps, and otherevidence, this location is FERNANDEZ’s primary residence. Thisresidence is a single family residence located on the northeastcorner of 5th Avenue and Joshua Street, further described as asingle story residence, with a peach colored stucco exterior, withwhite trim, and a brown shingle roof. The residence is constructedwith an east-facing front security door, and the property issurrounded by a gray cinder-block perimeter wall. White windowplanter boxes are located below each east-facing window, and awhite mailbox is situated on a post on the easternmost portion ofthe lot, adjacent 5th Avenue, which displays “84<strong>18</strong>” in blacknumbers. On the south side of the property is a white cargo trailerwith the number “<strong>18</strong>0” in black lettering on the upper portion ofthe container.k. 580A Florida Street, Imperial Beach, California(“Florida Residence”): According to surveillance, wiretaps, andother evidence, this location is BOHON’s primary residence and is astash location used by FERNANDEZ. This is a single storyresidential duplex with the exterior painted primarily pink, abrown shingle roof, and with white trim. The unit 580A is on thenorth side of the duplex with a white door. There is an awningabove the door with black numbers “580” affixed to the white trimof the awning. A portion of the patio is shaded by white lattice.The front yard of the residence consists of grass with a large palmtree in the north east corner and a fence completely surroundingthe grass. Parked in the driveway is a white enclosed trailer.<strong>16</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728l. 3401 Altadena Avenue, San Diego, California(“Altadena Residence”): According to surveillance, wiretaps, andother evidence, this location is RUIZ’s primary residence and is astash location used by RUIZ. This is a green one-story singlefamily residence with a brown shingled roof. The house is L-shaped, and the front door of the residence is located on the northside of the residence with a visible large butterfly statueattached to the wall. There is a beige stucco wall with a brownrebar fence that extends several feet and runs along the sidewalk.There is a rod iron gate across the driveway. The gate can bepushed open to give vehicles access to the driveway or pulledclosed to restrict access. Next to the driveway there is also agate to give access to the front yard from the street. The housenumbers “3401” are painted in black lettering with a whitebackground on the curb in front of the pedestrian gate access.There are three windows facing the street which are visible fromthe front of the residence. The residence is on the east side ofthe street, and the front door of the residence faces west.IVPROBABLE CAUSE FOR ARREST AND SEARCH WARRANTS9. Because the purpose of this affidavit is to set forthonly those facts necessary to establish probable cause for theissuance of criminal complaints, arrest warrants, and searchwarrants, I have not described all of the relevant facts andcircumstances of which I am aware. In addition, when I rely onstatements made by others, such statements are set forth in partand in substance unless otherwise indicated. Facts not stated inthis affidavit are not being relied upon to reach my conclusion<strong>17</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728that criminal complaints, arrest and search warrants should beissued.<strong>10</strong>. This investigation involved the court-authorizedinterception of wire communications of the defendants listed aboveand other targets of the investigation. The following is a list ofthe pertinent wiretap applications and orders for phones used byGAYTAN, TRUJILLO, MURILLO, AHUMADA, and FERNANDEZ, which wereintercepted during this investigation:a. On <strong>11</strong>/<strong>18</strong>/<strong>11</strong>, United States District Judge Dolly M.Gee, Central District of California, signed an order in CR Misc.No. <strong>11</strong>-309-DMG (Extensions A-D were filed in this matter)authorizing the initial interception of wire communications over8<strong>18</strong>-<strong>20</strong>0-5001 (“Target Telephone 1"), used by GAYTAN. Interceptionbegan on <strong>11</strong>/<strong>18</strong>/<strong>11</strong> and concluded on 4/<strong>10</strong>/<strong>12</strong>.b. On <strong>12</strong>/<strong>15</strong>/<strong>11</strong>, Judge Gee signed an order in CR Misc. No.<strong>11</strong>-309(A)-DMG authorizing the initial interception of wirecommunications over 8<strong>18</strong>-355-8339 (“Target Telephone 2"), used byTRUJILLO. Interception began on <strong>12</strong>/<strong>15</strong>/<strong>11</strong> and concluded 1/<strong>13</strong>/<strong>12</strong>.c. On 1/<strong>12</strong>/<strong>12</strong>, Judge Gee signed an order in CR Misc. No.<strong>11</strong>-309(B)-DMG authorizing the initial interception of wirecommunications over 8<strong>18</strong>-<strong>20</strong>0-7<strong>10</strong>9 (“Target Telephone 3"), used byTRUJILLO. Interception began on 1/<strong>12</strong>/<strong>12</strong> and concluded 2/<strong>10</strong>/<strong>12</strong>.d. On 2/<strong>13</strong>/<strong>12</strong>, Judge Gee signed an order in CR Misc. No.<strong>11</strong>-309(C)-DMG authorizing the initial interception of wirecommunications over 8<strong>18</strong>-<strong>20</strong>0-5069 (“Target Telephone 4"), used byTRUJILLO. Interception began on 2/<strong>13</strong>/<strong>12</strong> and concluded 3/<strong>13</strong>/<strong>12</strong>.e. On 3/<strong>12</strong>/<strong>12</strong>, Judge Gee signed an order in CR Misc. No.<strong>11</strong>-309(D)-DMG authorizing the initial interception of wire<strong>18</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728communications over 661-<strong>23</strong>3-4775 (“Target Telephone 5"), used byMURILLO, and the initial interception for <strong>15</strong>2*9*<strong>13</strong>45, with IMSI3340<strong>10</strong>00<strong>17</strong>807<strong>23</strong> (“Target Telephone 6"), used by AHUMADA.Interceptions began on 3/<strong>12</strong>/<strong>12</strong> and concluded 4/<strong>10</strong>/<strong>12</strong>.f. On 4/<strong>18</strong>/<strong>12</strong>, Judge Gee signed an order in CR Misc. No.<strong>11</strong>-309(E)-DMG authorizing the initial interception of wirecommunications over <strong>15</strong>2*<strong>10</strong>30*<strong>18</strong>6, with IMSI 3340<strong>10</strong>00<strong>18</strong>00<strong>16</strong>7(“Target Telephone 7"), used by AHUMADA, the initial interceptionof wire communications over 6<strong>19</strong>-649-5297 (“Target Telephone 8"),used by FERNANDEZ, and the initial interception of wirecommunications over 661-265-5446 (“Target Telephone 9"), used byMURILLO. Interception began on 4/<strong>18</strong>/<strong>12</strong> and concluded on 5/<strong>17</strong>/<strong>12</strong>.<strong>11</strong>. During the intercepted conversations, cryptic or codedlanguage to discuss drug trafficking was often used. Throughtraining and experience and subsequent drug seizures based onwiretap calls, I have determined that many of the terms useddescribe narcotics. For example, some of the terms used todescribe drugs and drug cash include the use of pronouns like “it,”“that,” “those,” and “them.” Based upon my experience in this andother drug investigations, I know that drugs and drug cash are alsoreferred to as “girls,” “guys,” “batteries,” “clothes,” “boxes offish,” “blueprints,” “paper,” and “utensils,” as well as other codewords. Moreover, the wiretap calls described below are some of thepertinent conversations that were selected to demonstrate the scopeof the drug trafficking organization and to identify some of theco-conspirators in that organization. The listed conversations arenot exhaustive of all of the pertinent conversations interceptedduring the wiretap investigation. Moreover, because many of the<strong>19</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728relevant calls contain some non-pertinent conversations, I havetried to describe only the pertinent portions without altering thecontext of the calls.<strong>12</strong>. The identities of the suspects were ascertained through avariety of methods. Some of these methods included names used bythe speakers themselves during intercepted conversations andsurveillance activity revealing that a co-conspirator was at aparticular location being called by one of the individualsintercepted. Observations were made, with respect to each subject,on occasions when the subjects were doing things consistent withwhat they had discussed during intercepted conversations. Bylistening to the conversations, verbally identifying theparticipants in the conversations, and then conducting surveillancein the areas where it was believed the conversations were located,the investigators were able to identify the participants in theconversation visually and, therefore, to confirm the participantsin the narcotics trafficking conspiracy. The interceptedconversations referred to below were primarily in Spanish. Thespeakers have been identified by subscriber information,surveillance, court-authorized GPS location data information, voiceidentification by agents and monitors who have compared voices, bythe speakers’ own identification of themselves, or by arresting theindividuals after drug transactions were completed and finding thetelephone device on the suspect.A. Overview of Investigation<strong>13</strong>. Between November <strong>20</strong><strong>11</strong> and April <strong>20</strong><strong>12</strong>, agents conducted afederal wiretap on Target Telephone 1, used by GAYTAN. During thewiretap, agents intercepted calls which helped them identify<strong>20</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728GAYTAN’s drug associate and street distributor, TRUJILLO, andGAYTAN’s sources of supply, AHUMADA and LOPEZ. During the wiretap,agents intercepted calls in which GAYTAN, TRUJILLO, AHUMADA, andLOPEZ discussed drug operations. The wiretaps also revealed thatGAYTAN agreed to supply AHUMADA with cars fitted with secretcompartments to smuggle drugs into the United States from Mexico.Furthermore, the calls over this phone aided agents to identify abank account that GAYTAN used to transfer drug cash to LOPEZ andaided surveillance efforts which resulted in the seizure ofapproximately 500 grams of heroin that was supplied by LOPEZ andtransported by GALVAN to be delivered to GAYTAN on 3/31/<strong>12</strong>.<strong>14</strong>. On <strong>12</strong>/<strong>15</strong>/<strong>11</strong>, agents began interception of TargetTelephone 2, used by TRUJILLO. However, TRUJILLO discontinued theuse of the phone after only eight days of interception. During thewiretap, agents intercepted calls that confirmed that TRUJILLOdistributed street level quantities of drugs to include cocaine,methamphetamine, and heroin and conducted drug operations withGAYTAN.<strong>15</strong>. On 1/<strong>12</strong>/<strong>12</strong>, agents began interception of Target Telephone3, used by TRUJILLO. However, TRUJILLO discontinued the use of thephone after only <strong>12</strong> days of interception. The calls over thisphone also aided surveillance efforts which resulted in the seizureof one ounce of crystal methamphetamine and one ounce of cocainefrom ZARATE on 1/<strong>16</strong>/<strong>12</strong>.<strong>16</strong>. On 2/<strong>13</strong>/<strong>12</strong>, agents began interception of Target Telephone4, used by TRUJILLO. During the wiretap, agents intercepted callswhich helped identify TRUJILLO’s source of pound quantities ofcrystal methamphetamine and cocaine, MURILLO.<strong>21</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728<strong>17</strong>. On 3/<strong>12</strong>/<strong>12</strong>, agents began interception of Target Telephone5, used by MURILLO, and the interception of Target Telephone 6,used by AHUMADA. During the wiretap, agents intercepted callswhich helped to identify multiple sources of pound quantities ofcrystal methamphetamine and cocaine for MURILLO, to include CHARROand ZAABTUFF. As described below, the calls over Target Telephone5 also aided surveillance efforts which resulted in the seizure ofapproximately 3.3 kilograms of crystal methamphetamine and 4.9kilograms of cocaine from MURILLO, MILLAN, and IBARRA. The wiretapcalls confirmed that the drugs were supplied by CHARRO and weresmuggled into the United States and delivered to MURILLO byFERNANDEZ and GALARZA. Furthermore, the calls over TargetTelephone 5 aided surveillance efforts which resulted in theseizure of approximately 2.2 kilograms of crystal methamphetaminefrom PARRA. The wiretap calls confirmed that the drugs, suppliedby ZAABTUFF, were delivered to MURILLO by PARRA. The surveillanceof PARRA also led to the identification of a drug loadtransportation vehicle and driver, identified as ESCOBAR. On5/7/<strong>12</strong>, based on border crossing records, ESCOBAR was arrested atthe Calexico, California POE after attempting to smuggleapproximately 31.98 kilograms (gross weight) of crystalmethamphetamine in a car. The intercepted calls over TargetTelephone 6 helped agents confirm that AHUMADA was responsible forcoordinating drug shipments into the United States. However, thephone was discontinued after only 90 minutes of interception.<strong>18</strong>. On 4/<strong>18</strong>/<strong>12</strong>, agents began interception of Target Telephone7, used by AHUMADA and GERA, the interception of Target Telephone8, used by FERNANDEZ, and the interception of Target Telephone 9,<strong>22</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728used by MURILLO. During the wiretap, agents intercepted calls thathelped to identify multiple sources of pound quantities of crystalmethamphetamine for AHUMADA and GERA, including CHUMA.Furthermore, the calls over Target Telephone 7 led to theidentification of AHUMADA’s and GERA’s primary drug loadcoordinator, ELIAS-CAMACHO. ELIAS-CAMACHO then hired MORENO tosmuggle drugs into the United States and deliver the drugs toAHUMADA’s and GERA’s drug customers. As described below, the callsover Target Telephone 7 also aided surveillance efforts, whichresulted in multiple seizures of drugs from COSIO, SANCHEZ,MARTINEZ, and MORENO.<strong>19</strong>. The calls over Target Telephone 8 helped agents identifymultiple Mexican-based sources of multi-kilogram quantities ofcrystal methamphetamine and cocaine for FERNANDEZ, includingMIGUEL, FNU LNU 3<strong>18</strong>, CHARRO, and CALUCHAS. MIGUEL, FNU LNU 3<strong>18</strong>,CHARRO, and CALUCHAS hired FERNANDEZ, BOHON, GALARZA, and otherdrug associates to smuggle and deliver large quantities of drugsinto the United States from Mexico. As described below, the callsover Target Telephone 8 also aided surveillance efforts, whichresulted in multiple seizures of drugs from RAYGOZA, ROSALES,BAZUA, and BENETIZ. The calls over Target Telephone 9 helpedagents to identify properties and assets owned by MURILLO.<strong>20</strong>. The wiretaps, along with other evidence obtained duringthe investigation, revealed the large-scale and intertwined natureof the drug operations controlled by GAYTAN, MURILLO, AHUMADA andFERNANDEZ. Specifically, the wiretaps revealed that GAYTANcontrolled an organization which received smuggled loads of heroinand other drugs from Mexico, using cars fitted with secret<strong>23</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728compartments and other innovative concealment methods. GAYTANdirected the distribution of the drugs to customers within the LosAngeles area using his automobile shop as a storefront. GAYTANwould then send the drug profits to LOPEZ using bank accounts andcouriers to smuggle the drug cash into Mexico.<strong>21</strong>. The wiretaps revealed that MURILLO controlled anorganization which received smuggled loads of crystalmethamphetamine and cocaine from multiple sources in Mexico,including CHARRO and ZAABTUFF. MURILLO would then have his stashhouse operator and drug courier, IBARRA, stash and deliver thedrugs in pound or kilogram quantities to several drug associatesincluding EL MUSICO, TONY, and others. The calls also revealedthat MURILLO’s organization is a tight-knit group of individualsand that MURILLO has been involved in the drug business for a longperiod of time. MURILLO then used the drug profits to purchaseproperties and other valuable assets.<strong>22</strong>. The wiretaps revealed that AHUMADA and GERA controlled anorganization which supplied pound quantities of crystalmethamphetamine to drug customers in Mexico and the United States.AHUMADA and GERA received the drugs from several high-ranking drugsources including CHUMA. AHUMADA and GERA then smuggled the drugsinto the United States using vehicles and body carriers. AHUMADAand GERA would then have the drug cash smuggled back into Mexico byunidentified couriers.<strong>23</strong>. The wiretaps revealed that FERNANDEZ controlled anorganization that was responsible for smuggling pound and kilogramquantities of drugs from Mexico into the United States. FERNANDEZ,and his drug associates, BOHON, and GALARZA, smuggled the drugs<strong>24</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728into the United States using vehicles with hidden compartments andwould then deliver the drugs to various drug customers includingRAYGOZA, BENETIZ, ROSALES, EL TIGRE, FNU LNU 348, BAZUA, and RUIZ.FERNANDEZ smuggled drugs for several drug sources including MIGUEL,FNU LNU 3<strong>18</strong>, CHARRO, and CALUCHAS. Although each of theseorganizations had its own members, the wiretaps revealed that theorganization members often supplied or received drugs from otherorganizations, within the same conspiracy. 3B. Significant Drug Transactions in this CaseGAYTAN and TRUJILLO sold cocaine and methamphetamine to ZARATE(GAYTAN, TRUJILLO, ZARATE, and CHILIPIQUIN) 4<strong>24</strong>. Between 1/<strong>14</strong>/<strong>12</strong> and 1/<strong>16</strong>/<strong>12</strong>, agents intercepted callsover Target Telephones 1 and 3 in which GAYTAN, TRUJILLO, andCHILIPIQUIN coordinated the delivery of drugs to a drug customeridentified as ZARATE. The following is a sampling of those calls:January <strong>14</strong>, <strong>20</strong><strong>12</strong><strong>24</strong>-a. At 9:<strong>10</strong> a.m., Target Telephone 3 received a callfrom 805-944-0457, used by ZARATE. TRUJILLO asked ZARATE what didhe “need.” ZARATE asked TRUJILLO if he had “batteries” and that heneeded “one and one.” TRUJILLO asked ZARATE if he had money for“both.” ZARATE told TRUJILLO that he had the money. TRUJILLO toldZARATE that he would call another “guy” to see if he had any “good3The intercepted wiretap calls described below is followed by myinterpretation of the calls, based on my knowledge as the caseagent in this investigation, as well as my training and experience,and conversations with other experienced narcotics investigators.4This subheading reflects identified defendants involved in thedrug transaction.<strong>25</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728work.”- In this call, TRUJILLO asked ZARATE what did he “need,” orcoded jargon referring to the quantity and type of drugs. ZARATEasked TRUJILLO if he had “batteries,” or coded jargon for thequantity of drugs, most likely one ounce, and that he needed “oneand one,” or coded jargon for drugs, most likely crystalmethamphetamine and cocaine. TRUJILLO asked ZARATE if he had moneyfor “both,” or the drugs. ZARATE told TRUJILLO that he had themoney. TRUJILLO told ZARATE that he would call another “guy” tosee if he had any “good work.”January <strong>16</strong>, <strong>20</strong><strong>12</strong><strong>24</strong>-b. At 6:00 a.m., according to court-authorized GPSlocation information, ZARATE traveled from Lompoc, California, tothe greater Los Angeles area.<strong>24</strong>-c. At 7:35 a.m., Target Telephone 3 called TargetTelephone 1, used by GAYTAN. TRUJILLO asked GAYTAN if he was goingto order “parts” from the “boss” so they could order it together toget “it” cheaper. GAYTAN told TRUJILLO that he would later andthat he would let him know.- In this call, TRUJILLO asked GAYTAN if he was going to order“parts,” or drugs, from the “boss,” or unidentified drug supplier,so they could order it together to get “it,” or the drugs, cheaper.GAYTAN told TRUJILLO that he would later and that he would let himknow.<strong>24</strong>-d. At <strong>11</strong>:42 a.m., Target Telephone 3 received a callfrom 805-944-0457, used by ZARATE. TRUJILLO asked ZARATE if hestill wanted the “two.” ZARATE told TRUJILLO that he did and atwhat time. TRUJILLO asked ZARATE how much did “he” give him.26


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728ZARATE told TRUJILLO that he had “1,357" and that he would“complete” the “<strong>14</strong>00.” TRUJILLO told ZARATE that he would call himback.-In this call, TRUJILLO asked ZARATE if he still wanted the“two,” or coded jargon for drugs, most likely crystalmethamphetamine and cocaine. ZARATE told TRUJILLO that he did andat what time. TRUJILLO asked ZARATE how much did “he,” or anunidentified drug associate, give him. ZARATE told TRUJILLO thathe had “<strong>13</strong>57,” or $<strong>13</strong>57, and that he would “complete,” or get therest, the “<strong>14</strong>00,” or $1,400, for the drugs. TRUJILLO told ZARATEthat he would call him back.<strong>24</strong>-e. At <strong>12</strong>:<strong>25</strong> p.m., Target Telephone 1 called 8<strong>18</strong>-982-<strong>10</strong>66, used by CHILIPIQUIN. GAYTAN asked CHILIPIQUIN how much forthe “four micheladas” and “half for a girl.” CHILIPIQUIN toldGAYTAN to tell “him” that it was “two, eight, two, eight” and askedif he should send “it.” GAYTAN told CHILIPIQUIN that he shouldsend it later.-In this call, GAYTAN asked CHILIPIQUIN how much for the “fourmicheladas,” or coded jargon for drugs, and “half for a girl,” orcoded jargon for drugs, most likely methamphetamine. CHILIPIQUINtold GAYTAN to tell “him,” or TRUJILLO, that it was “two, eight,two, eight,” or coded jargon for the amount of drugs, most likely28 grams and 28 grams, and asked if he should send “it.” GAYTANtold CHILIPIQUIN that he should send it later. I believe thatGAYTAN told CHILIPIQUIN to send the drugs to the Vanowen Auto Shop,which is consistent with multiple other drug deals GAYTAN hasarranged to take place at this location.<strong>24</strong>-f. At 2:<strong>21</strong> p.m., Target Telephone 3 called Target27


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Telephone 1, used by GAYTAN. TRUJILLO asked GAYTAN what did his“friend” tell him. GAYTAN told TRUJILLO that “he” had not arrivedyet. TRUJILLO told GAYTAN to hurry up because “he” was coming from“far” and “he” had to leave.-In this call, TRUJILLO asked GAYTAN what his “friend” (drugsupplier) told him. GAYTAN told TRUJILLO that “he,” or anunidentified drug courier, had not arrived yet to the Vanowen AutoShop. TRUJILLO told GAYTAN to hurry up because “he,” or ZARATE,was coming from “far,” or Lompoc, California, and “he,” or ZARATE,had to leave.<strong>24</strong>-g. At 3:08 p.m., Target Telephone 3 called 805-944-0457, used by ZARATE. TRUJILLO asked ZARATE where he was going andthat he was “passing” him. TRUJILLO told ZARATE that he was“behind” him.-In this call, TRUJILLO asked ZARATE where he was going andthat he was “passing,” or driving past, him. TRUJILLO told ZARATEthat he was behind him.<strong>24</strong>-h. At 3:<strong>15</strong> p.m., according to court-authorized GPScell phone location data, ZARATE traveled from Los Angeles to hisresidence located in Lompoc, California. As described above,wiretap calls confirmed that TRUJILLO met with ZARATE atapproximately 3:08 p.m. Detectives arrived at ZARATE’s residenceshortly after GPS location information confirmed that ZARATE was atthe residence. Several minutes later, agents directed the trafficstop of a vehicle that left the residence and confirmed that ZARATEwas driving the car. ZARATE provided conflicting information aboutwhere he was that day. ZARATE agreed to a consensual search of hisvehicle and residence, and told agents that he had drugs at his28


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728FERNANDEZ and GALARZA, was going to go early tomorrow and that“it,” or the courier, was one that he already knew. MURILLO toldCHARRO to let him know so he (MURILLO) could have the “receipts,”or drug cash, ready. CHARRO told MURILLO that it was two“brothers,” or FERNANDEZ and GALARZA, but “they” were going to“go,” or smuggle the load in two parts, separately. CHARRO toldMURILLO that “one” would “go” first and then the “other,” orFERNANDEZ and GALARZA would smuggle the load in two parts,separately. MURILLO told CHARRO that he would be waiting.March <strong>17</strong>, <strong>20</strong><strong>12</strong><strong>25</strong>-b. At 7:56 p.m., Target Telephone 5 called<strong>12</strong>5*<strong>13</strong>4<strong>24</strong>1*7, used by GALARZA. 5 GALARZA told MURILLO that he wasin “Tijuana” and currently on his way “there.” GALARZA toldMURILLO that he had not “crossed” yet, but would in a little while.MURILLO asked if the one “there” or the one “here.” GALARZA toldMURILLO the “big one.” MURILLO then asked GALARZA how many “boxesof fish” was he bringing. GALARZA told MURILLO “3" and “2" of the“other.”-In this call, GALARZA told MURILLO that he was in “Tijuana,”5 I believe this phone is used by GALARZA for several reasons.First, as described below in paragraph <strong>25</strong>-k, agents observedGALARZA deliver a drug shipment to the Carrolton Residence inconjunction with intercepted calls. Furthermore, theseobservations coincided with court-authorized GPS cell location datafrom the telephone that was being used by GALARZA. Second, thephone is subscribed to “Tony Atlas” at GALARZA’s residence (UteResidence.) Agents believe that “Tony Atlas” is a fictitious nameto avoid detection by law enforcement. Third GALARZA’s bordercrossing on 3/<strong>17</strong>/<strong>12</strong> coincides with an intercepted call indicatingthat he had successfully crossed from Mexico into the UnitedStates.30


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728or Tijuana, Mexico, and currently on his way “there,” or to theUnited States, or more specifically the Carrolton Residence.GALARZA told MURILLO that he had not “crossed,” or made entry intothe United States, yet, but would in a little while. MURILLO askedif the one “there,” or the Port of Entry at the Mexico and UnitedStates border, or the one “here,” that is, the checkpoint locatedon I-5 north of San Diego, California. GALARZA told MURILLO the“big one,” or coded jargon referring to the Port of Entry at theMexico and United States border. MURILLO then asked GALARZA howmany “boxes of fish,” or coded jargon referring to the quantity ofdrugs, was he (GALARZA) bringing. GALARZA told MURILLO “3" and “2"of the “other,” or coded jargon referring to drugs, either cocaineor methamphetamine.<strong>25</strong>-c. According to border crossing information, on3/<strong>17</strong>/<strong>12</strong> at <strong>10</strong>:46 p.m., GALARZA drove across the border from Mexicointo the United States at the Port of Entry at San Ysidro,California, driving a white Jeep. According to CaliforniaDepartment of Motor Vehicles (DMV) records, the Jeep is registeredto GALARZA at the Ute Residence. On 3/<strong>18</strong>/<strong>12</strong>, at 2:<strong>14</strong> a.m.,FERNANDEZ drove across the border in a Honda from Mexico into theUnited States at the Port of Entry at Otay Mesa, California.March <strong>18</strong>, <strong>20</strong><strong>12</strong><strong>25</strong>-d. At 9:47 a.m., Target Telephone 5 received a callfrom <strong>12</strong>5*<strong>14</strong>6*8855, used by EL MUSICO, an unidentified drug customerof MURILLO’s who is identified in several intercepted phone callsonly as “El Musico.” EL MUSICO told MURILLO to tell “CHARRO” that“they” should start heading over “there.” EL MUSICO told MURILLOthat if there were more than “five” then he really needed “seven,”31


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728but the “guy” that needed “some” wasn’t answering. EL MUSICO toldMURILLO that “they” would only be able to pay for “four” and thathe “left there” for “four,” but needed “seven.” MURILLO told ELMUSICO that he only had a “hand” and that he would call EL MUSICOif “they” were “headed out.”-In this call, EL MUSICO told MURILLO to tell “CHARRO” that“they,” or the drug couriers FERNANDEZ and GALARZA, should startheading over “there,” or the Carrolton Residence. EL MUSICO toldMURILLO that if there were more than “five,” or five units of anunspecified drug, most likely cocaine, then he really needed“seven,” or seven units of drugs, but the “guy,” or unidentifieddrug customer, that needed “some,” or drugs, wasn’t answering. ELMUSICO told MURILLO that “they,” or the drug customers, would onlybe able to pay for “four,” or four units of drugs, most likelykilograms of cocaine, and that he “left there,” or coded jargon forleaving the drug cash, for “four,” or four units of drugs, butneeded “seven,” or seven units of drugs. MURILLO told EL MUSICOthat he only had a “hand,” or coded jargon for five units of drugs,and that he would call EL MUSICO if “they,” or MURILLO and IBARRA,were “headed out,” or headed to deliver the drugs to EL MUSICO.<strong>25</strong>-e. At <strong>10</strong>:43 a.m., Target Telephone 5 received a callfrom 3<strong>16</strong>0<strong>10</strong><strong>15</strong>4998439, used by FERNANDEZ. 6 MURILLO told FERNANDEZthat he was waiting for him to take “it” up “there” and was waiting6 I believe this phone is used by FERNANDEZ for several reasons.First, on 3/26/<strong>12</strong> during surveillance, FERNANDEZ’s movementscoincided with court-authorized GPS cell location data from theintercepted telephone. Secondly, during surveillance inconjunction with intercepted calls, agents observed FERNANDEZdeliver drugs on 4/<strong>24</strong>/<strong>12</strong> and 4/29/<strong>12</strong>.32


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728at “Adelanto.” FERNANDEZ told MURILLO that he was doing another“job” and had the car keys, but would call his “brother” to get the“stuff” at the house. MURILLO told FERNANDEZ that EL MUSICO waswaiting to get the “ones” that arrived. FERNANDEZ told MURILLOthat he would get the “guy” to open the trunk of the car and wouldsend “him” right now. FERNANDEZ told MURILLO that he had the carkeys but it wouldn’t be that hard to get into the “Honda.”-In this call, MURILLO told FERNANDEZ that he was waiting forhim to take “it,” or the drugs, up “there,” or the CarroltonResidence, and was waiting at “Adelanto,” or the CarroltonResidence, a residence owned by MURILLO located in Adelanto,California, that is used by MURILLO as a stash location. FERNANDEZtold MURILLO that he was doing another “job,” or delivering anotherdrug load, and had the car keys, but would call his “brother,” orGALARZA, to get the “stuff,” or drugs, at the house, or the UteResidence or the 5th Street Residence. MURILLO told FERNANDEZ that“EL MUSICO” was waiting to get the “ones,” or the drugs, thatarrived. FERNANDEZ told MURILLO that he would get the “guy,” orGALARZA, to open the trunk of the car and would send “him,” orGALARZA, right now. FERNANDEZ told MURILLO that he had the carkeys, but it wouldn’t be that hard to get into the “Honda,”referring to a load vehicle. (Additionally, as noted previously inparagraph <strong>25</strong>-c, on 3/<strong>17</strong>/<strong>12</strong> at <strong>10</strong>:46 p.m., GALARZA drove across theborder from Mexico into the United States at the Port of Entry atSan Ysidro, California driving a white Jeep, and FERNANDEZ drove aHonda across the border from Mexico into the United States throughPOE Otay Mesa, California on 3/<strong>18</strong>/<strong>12</strong>, at 2:<strong>14</strong> a.m.)<strong>25</strong>-f. At <strong>10</strong>:56 a.m., Target Telephone 5 received a call33


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728from 3<strong>16</strong>0<strong>10</strong><strong>16</strong>4507663, used by GALARZA. MURILLO told GALARZA thathe was waiting at the house in “Adelanto.” GALARZA told MURILLOthat “they” were getting “everything.” GALARZA told MURILLO that“he” told him to go and open the trunk, and he would get the“rest.”-In this call, MURILLO told GALARZA that he was waiting at thehouse in “Adelanto,” or the Carrolton Residence. GALARZA toldMURILLO that “they,” or GALARZA and FERNANDEZ, were getting“everything,” or the drugs. GALARZA told MURILLO that “he,” orFERNANDEZ, told him to go and open the trunk, and he would get the“rest,” or the drugs. According to toll information, FERNANDEZcalled GALARZA five times between <strong>10</strong>:50 a.m. and <strong>10</strong>:54 a.m.Furthermore, based on GPS information as described in the nextparagraph, I believe that GALARZA retrieved the drugs from the UteResidence and the 5th Street Residence.<strong>25</strong>-g. At <strong>12</strong>:<strong>20</strong> p.m., Target Telephone 5 received a callfrom 3<strong>16</strong>0<strong>10</strong><strong>16</strong>4507663, used by GALARZA. MURILLO asked GALARZA if hewas in the area. GALARZA told MURILLO that they were on their wayand should be “there” in 35 minutes.-In this call, MURILLO asked GALARZA if he was in the area.GALARZA told MURILLO that they were on their way and should be“there,” or the Carrolton Residence, in 35 minutes. According tocourt-authorized GPS data information, GALARZA then traveled to the5th Street Residence and Ute Residence. I believe that GALARZAretrieved the drugs from the 5th Street Residence and Ute Residenceand then delivered the drugs to MURILLO at the Carrolton Residence.<strong>25</strong>-h. At <strong>12</strong>:32 p.m., Target Telephone 5 called92*<strong>10</strong>40302*1, used by CHARRO. CHARRO told MURILLO that it was one34


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“job.” MURILLO told CHARRO that it was “five guys” and “fivegirls.” MURILLO told CHARRO that “each” brought “half,” eitherthree “girls” or two “guys” or something like that. MURILLO askedCHARRO if it was going to be “five” and “five” and if he had toturn in “nine.”-In this call, CHARRO told MURILLO that it was one “job,” orcoded jargon for the delivery of drugs. MURILLO told CHARRO thatit was “five,” or units of drugs, “guys,” or coded jargon fordrugs, most likely cocaine, and “five,” or units, “girls,” or codedjargon for drugs, most likely methamphetamine. MURILLO told CHARROthat “each,” or FERNANDEZ and GALARZA, brought “half,” or half ofthe drug load, either three “girls,” or three units ofmethamphetamine, or two “guys,” or two units of cocaine, orsomething like that. MURILLO asked CHARRO if it was going to be“five,” units of drugs, and “five,” units of drugs, and if he hadto turn in “nine,” or $9,000 for drug transportation fees.<strong>25</strong>-i. At 1:<strong>18</strong> p.m., Target Telephone 5 received a callfrom <strong>12</strong>5*<strong>14</strong>6*8855, used by EL MUSICO. MURILLO told EL MUSICO thatthe “guy” would be “there” in <strong>10</strong> minutes. EL MUSICO told MURILLOto bring the “frame” or “hand” and if there was time tomorrow hecould send him “two” more and that he would pay tomorrow. ELMUSICO told MURILLO that he could use “two” more tomorrow and thatif he brought the “four,” the “four” was for “sure.” MURILLO toldEL MUSICO that he would call the “friend” to confirm if he couldtake “them” all, but the “other” wasn’t going anywhere. EL MUSICOtold MURILLO that he shouldn’t leave “them” sitting around.MURILLO told EL MUSICO that he would talk to the “old guy” out“there” so that “he” knew.35


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728-In this call, MURILLO told EL MUSICO that the “guy,” orGALARZA, would be “there,” or the Carrolton Residence, in <strong>10</strong>minutes. EL MUSICO told MURILLO to bring the “frame,” drug jargonfor four units of an unspecified drug, or “hand,” or drug jargonfor five units of an unspecified drug, and if there was timetomorrow he could send him “two,” or two units of an unspecifieddrug, more and that he would pay tomorrow. EL MUSICO told MURILLOthat he could use “two,” or two units of an unspecified drug, moretomorrow and that if he brought the “four,” the “four” was for“sure,” or coded jargon for having the drug cash ready. MURILLOtold EL MUSICO that he would call the “friend,” or CHARRO, toconfirm if he could take “them,” or the drugs, most likely cocaine,all, but the “other,” or drugs, most likely methamphetamine, wasn’tgoing anywhere. EL MUSICO told MURILLO that he shouldn’t leave“them,” or drugs, “sitting around,” or keeping the drugs in oneplace for a long time to avoid detection by law enforcement.MURILLO told EL MUSICO that he would talk to the “old guy,” orCHARRO, out “there,” or an undisclosed location in Mexico, so that“he,” or CHARRO, knew. As described below, and based onintercepted calls, detectives detained MURILLO and two drugassociates outside the Carrolton Residence with five kilograms ofcocaine that were going to be delivered to EL MUSICO.<strong>25</strong>-j. At 1:33 p.m., Target Telephone 5 called760-6<strong>17</strong>-79<strong>17</strong>, used by IBARRA. MURILLO told IBARRA to take out thetruck because “he” was behind him, and they were about to arrive.-In this call, MURILLO told IBARRA to drive the truck out ofthe garage of the Carrolton Residence because “he,” or GALARZA, wasbehind him, and they were about to arrive with the drugs.36


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728<strong>25</strong>-k. On 3/<strong>18</strong>/<strong>12</strong>, based on intercepted callsdescribed above, agents conducted surveillance at the CarroltonResidence in anticipation of the drug load delivery. Specifically,CHARRO supplied a drug load to MURILLO, which would contain five“guys” and five “girls,” that were smuggled from Mexico and thatFERNANDEZ and GALARZA delivered to MURILLO and IBARRA at theCarrolton Residence. During surveillance, agents observed MURILLOleave the Carrolton Residence and meet with GALARZA in a white Jeepseveral blocks away. Surveillance then observed MURILLO and theJeep travel in tandem back to the Carrolton Residence, and the Jeepentered the garage after IBARRA drove a truck out of the garage tomake space for the Jeep. Several minutes later, the Jeep left theresidence. Shortly after, MURILLO and MILLAN were observed leavingthe Carrolton Residence with MURILLO carrying a blue backpack.Because intercepted calls indicated that MURILLO would bedelivering five kilograms of cocaine to EL MUSICO, surveillanceunits subsequently detained MURILLO, MILLAN, and IBARRA (who waslocated inside of the residence during a protective sweep of thepremises) while agents obtained a California state search warrantfor the Carrolton Residence located in Adelanto, California.During a frisk for weapons, three kilograms of cocaine werediscovered taped to MILLAN’s body. After a California state searchwarrant was obtained, agents discovered an additional two kilogramsof cocaine in the blue backpack. During a search of the CarroltonResidence, five packages of crystal methamphetamine were discoveredin the garage and an additional three pounds of crystalmethamphetamine were discovered inside an ice cooler in IBARRA’sbedroom. Also located inside IBARRA’s bedroom were drug packaging37


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728materials, bowls, and strainers, which are consistent with itemsused during the production of crystal methamphetamine. Thepackages of cocaine discovered on MILLAN’s body and in the bluebackpack had identical packaging to the five packages of crystalmethamphetamine discovered in the garage. MURILLO, MILLAN, andIBARRA were subsequently arrested and released to protect theinvestigation. MURILLO and IBARRA possessed cell phones withnumbers 661-<strong>23</strong>3-4775 (Target Telephone 5) and 760-6<strong>17</strong>-79<strong>17</strong>,respectively, which they used to coordinate the delivery of theseized drugs (as described in the calls above). Furthermore,property records indicate that the Carrolton Residence is owned byMURILLO.<strong>25</strong>-l. Agents interviewed MURILLO, MILLAN, and IBARRAafter they waived their Miranda rights. MURILLO told agents thatthe cocaine was his, but claimed that he knew nothing about themethamphetamine discovered in the Carrolton Residence. MILLAN toldagents that an unknown man taped the kilograms of cocaine to herbody and that she believed they were “pillows.” MILLAN then toldagents that she was to deliver the “pillows” to an unknown locationand to an unknown individual. IBARRA told agents that the fivepackages of methamphetamine discovered in the garage were justdelivered by an unknown vehicle and that the packages ofmethamphetamine discovered in his bedroom were his. IBARRA toldagents that he works at the stash house and receives phone callsfrom unknown individuals who then come to pick up the drugs. Intotal, on 3/<strong>18</strong>/<strong>12</strong>, law enforcement seized and recoveredapproximately 3.3 kilograms of crystal methamphetamine and 4.9kilograms of cocaine.38


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728LOPEZ arranged delivery of heroin to GAYTAN(LOPEZ, GAYTAN, and GALVAN)26. Between 3/27/<strong>12</strong> and 3/31/<strong>12</strong>, agents intercepted callsover Target Telephone 1 in which LOPEZ agreed to supply GAYTAN adrug shipment containing heroin delivered by GALVAN from the ChulaVista Shop to GAYTAN near the Vanowen Auto Shop. The following isa sampling of those calls:March 29, <strong>20</strong><strong>12</strong>26-a. At 1:02 p.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. 7 LOPEZ told GAYTAN that he wanted to“throw” those “zacudas” and that there are “<strong>20</strong> pieces.” GAYTANtold LOPEZ he would call him back and would let him know “who” hewould send.-In this call, LOPEZ told GAYTAN that he wanted to “throw,” ordeliver, those “zacudas,” or coded jargon for drugs, most likelyheroin, and that there are “<strong>20</strong> pieces,” or coded jargon for <strong>20</strong>units of heroin, most likely <strong>20</strong> Mexican ounces, which is <strong>25</strong> gramseach for a total of 500 grams. GAYTAN told LOPEZ he would call himback and would let him know “who,” or which drug courier, he wouldsend to pick up the drugs.26-b. At 6:30 p.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. LOPEZ told GAYTAN that he would sendthis “fool” on “Saturday” because it would be “calmer.”-In this call, LOPEZ told GAYTAN that he would send this“fool,” or GALVAN, on “Saturday” (3/31/<strong>12</strong>) because it would be7Agents identified LOPEZ as the user of this phone when, inconjunction with intercepted calls, agents observed LOPEZ travel tothe Vanowen Auto Shop on <strong>11</strong>/29/<strong>11</strong>.39


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“calmer,” that is, there would be less law enforcement working onthe weekend.March 30, <strong>20</strong><strong>12</strong>26-c. At 4:49 p.m., Target Telephone 1 received a callfrom <strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. GAYTAN told LOPEZ that he had“blueprints” for him. LOPEZ told GAYTAN to take the “pieces” and“utensils” first. GAYTAN told LOPEZ that he had “four or fiveblueprints.” LOPEZ told GAYTAN to send the “blueprints” like “lasttime” and that he wanted to send “him” over “there” nearby. GAYTANtold LOPEZ that he would “fax” the “blueprints” on Monday. LOPEZtold GAYTAN he would send the “guy” early.-In this call, GAYTAN told LOPEZ that he (GAYTAN) had“blueprints,” or coded jargon for drug cash, for him (LOPEZ).LOPEZ told GAYTAN to take the “pieces” and “utensils,” or codedjargon for drugs, most likely heroin, first. GAYTAN told LOPEZthat he had “four or five blueprints,” or $4,000 or $5,000 in drugcash payments. LOPEZ told GAYTAN to send the “blueprints,” or drugcash, like “last time,” or deposit the drug cash into apredetermined bank account per a prior transaction modus operandi,and that he wanted to send “him,” or the drug courier (GALVAN),over “there,” or the Vanowen Auto Shop, nearby. GAYTAN told LOPEZthat he would “fax,” that is, deposit, the “blueprints,” i.e., drugcash, on Monday. LOPEZ told GAYTAN he would send the “guy,” orGALVAN, early.March 31, <strong>20</strong><strong>12</strong>26-d. At 8:<strong>15</strong> a.m., agents observed a grey Toyota Tundraarrive at the Chula Vista Shop. GALVAN got out of the Tundra,opened the warehouse, put an unidentified object in the back of the40


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Tundra using both hands, stood leaning into the driver’s seat ofthe Tundra for several minutes, then left the Chula Vista Shop.26-e. At <strong>11</strong>:<strong>25</strong> a.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. LOPEZ told GAYTAN that the “guy” is at“Surfaces USA” located at “Hart” and “Lankershim” and “he” isdriving a “gray Tundra.” GAYTAN told LOPEZ that he was sending his“nephew.”-In this call, LOPEZ told GAYTAN that the “guy,” or GALVAN, isat “Surfaces USA” located at “Hart” Street and “Lankershim”Boulevard in the city of North Hollywood and “he,” or GALVAN, isdriving a “gray Tundra,” or color and make of the car. GAYTAN toldLOPEZ that he was sending his “nephew,” or an unidentified drugassociate, to get the drugs, to bring the drugs back to the VanowenAuto Shop.26-f. At <strong>11</strong>:26 a.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. LOPEZ told GAYTAN that “he” was goingto give him “three tubes of silicone.”-In this call, LOPEZ told GAYTAN that “he,” or GALVAN, wasgoing to give him “three tubes of silicone,” or a description as tohow the heroin was packaged and concealed.26-g. At <strong>11</strong>:47 a.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. GAYTAN told LOPEZ that the car “fell.”-In this call, GAYTAN told LOPEZ that GALVAN “fell,” or wasstopped by law enforcement. As described below in paragraph 26-i,at approximately <strong>11</strong>:45 a.m., law enforcement detained the grayTundra driven by GALVAN.26-h. At <strong>11</strong>:50 a.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. GAYTAN told LOPEZ that he was turning41


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728off his phone. GAYTAN then asked LOPEZ if the “guy,” or GALVAN,knew that he was coming over “here,” or the Vanowen Auto Shop.LOPEZ asked GAYTAN if “they,” or law enforcement, took that “fool,”or GALVAN. GAYTAN told LOPEZ that “they have him,” or lawenforcement had GALVAN detained, and to turn off the phone. GAYTANthen told LOPEZ he was going to get a new phone.26-i. At <strong>11</strong>:45 a.m., based on the wiretapcalls described above, detectives located the gray Tundra at theintersection of Hart Street and Lankershim Boulevard in the city ofNorth Hollywood. Shortly thereafter, since the calls andsurveillance confirmed that GALVAN was transporting drugs in theTundra, I directed unmarked police cars to stop the Tundra, whichsurveillance units had observed at the Chula Vista Shop severalhours earlier. After the truck was searched by a K-9 unit,detectives found tubes of window calking containing approximately500 grams of heroin. The driver, identified as GALVAN, wasreleased to protect the investigation. Based on the interceptedcalls, I believe that GALVAN was going to deliver the heroin toGAYTAN on behalf of LOPEZ.ZAABTUFF arranged the delivery of methamphetamine to MURILLO(ZAABTUFF, ESCOBAR, MURILLO, PANCHO, PARRA, and TONY)27. Between 3/29/<strong>12</strong> and 4/3/<strong>12</strong>, agents intercepted calls overTarget Telephone 5 which revealed that ZAABTUFF sent PARRA todeliver methamphetamine to MURILLO, who then supplied one pound toTONY. The following is a sampling of those calls:March 30, <strong>20</strong><strong>12</strong>27-a. At 1:40 p.m., Target Telephone 5 received a callfrom 661-382-9046, used by TONY, an unidentified customer of42


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728MURILLO’s who is identified in several intercepted phone calls onlyas “Tony.” MURILLO told TONY that he talked to the “guy” alreadyand that he used to “work” with him before. MURILLO told TONY thatit was the same “guy” and he would send “that” in “cases/boxes.”MURILLO told TONY that he had the same “stuff” and “it” was “good”and that he mentioned that he needed “two” for the day aftertomorrow. MURILLO told TONY that they go for “them” at “85" andthat it couldn’t go any lower. MURILLO told TONY that he wasgetting them at “85" and that TONY was getting them at “87.”MURILLO told TONY that he would leave the “two girls” “there.”-In this call, MURILLO told TONY that he talked to the “guy,”or ZAABTUFF, already and that he used to “work,” or conduct drugoperations, with him before. I believe that the “guy” is ZAABTUFFbecause during an intercepted call between MURILLO and ZAABTUFF on3/29/<strong>12</strong>, MURILLO discussed receiving a drug shipment from ZAABTUFFand also confirmed that MURILLO previously conducted drugoperations with ZAABTUFF. MURILLO told TONY that it was the same“guy,” or ZAABTUFF, and he would send “that,” or the drugs, in“cases/boxes,” or a description of how the drugs were packaged.MURILLO told TONY that he had the same “stuff,” or drugs, mostlikely methamphetamine, and “it,” or the drugs, was “good,” or ofhigh quality, and that he mentioned that he needed “two,” or twounits of drugs, for the day after tomorrow. MURILLO told TONY thatthey go for “them,” or the drugs, at “85,” or $8,500 per pound ofdrugs, most likely methamphetamine, and that it couldn’t go anylower. MURILLO told TONY that he was getting them at “85,” or$8,500 per pound of drugs, and that TONY was getting them at “87,”or $8,700 per pound. MURILLO told TONY that he would leave the43


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“two girls” (two pounds of methamphetamine), at the MoonlightResidence.April 1, <strong>20</strong><strong>12</strong>27-b. At <strong>10</strong>:<strong>22</strong> a.m., Target Telephone 5 received a callfrom 3340<strong>10</strong>0<strong>18</strong>8<strong>25</strong>399, used by ZAABTUFF. 8 MURILLO told ZAABTUFFthat he was ready to “work” again and asked “how many” he couldlend him. ZAABTUFF asked MURILLO “how many” did he want and that“they” were “special.” MURILLO asked ZAABTUFF if he could lend hima “hand” and if the “guy” was still “working” with him. ZAABTUFFtold MURILLO that the “guy” is no longer with him and that he has a“girl” that barely drives. MURILLO told ZAABTUFF that he has a“guy” but he doesn’t have a driver’s license and doesn’t want to“lose” the “supply.” ZAABTUFF told MURILLO that “she” doesn’t havea license and does not know how to drive. ZAABTUFF told MURILLO hewould call him back.-In this call, MURILLO told ZAABTUFF that he was ready to“work,” or resume drug operations, again and asked “how many,” orunits of drugs, he could lend him. ZAABTUFF asked MURILLO “howmany,” or units of drugs, did he want and that “they,” or codedjargon for drugs, most likely methamphetamine, were “special,” orof high quality. MURILLO asked ZAABTUFF if he could lend him a“hand,” or coded jargon for five units of drugs, most likelymethamphetamine, and if the “guy,” or unidentified drug courier,was still “working,” or conducting drug operations, with him.8 ZAABTUFF is an unidentified drug supplier of MURILLO’s.ZAABTUFF’s intercepted Push-to-Talk number was saved as a contactunder the name “Zaabtuff” in a cell phone seized on 4/3/<strong>12</strong> fromPARRA.44


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728ZAABTUFF told MURILLO that the “guy,” or drug courier, is no longerwith him and that he has a “girl,” or PARRA, that barely drives.MURILLO told ZAABTUFF that he has a “guy,” or an unidentified drugassociate, but he doesn’t have a driver’s license, and he (MURILLO)doesn’t want to “lose the supply,” or have the drugs seized by lawenforcement. ZAABTUFF told MURILLO that “she,” or PARRA, doesn’thave a license and does not know how to drive. ZAABTUFF toldMURILLO he would call him back. According to DMV records, PARRAdoes not possess a valid driver’s license.27-c. At 3:<strong>22</strong> p.m., Target Telephone 5 called3340<strong>10</strong>0<strong>18</strong>8<strong>25</strong>399, used by ZAABTUFF. MURILLO asked ZAABTUFF if hecould send “it” today and that he would go pick “it” up today.ZAABTUFF told MURILLO that he had to talk to the “girl” and wouldcall him back. MURILLO told ZAABTUFF that he was on the way andwould go to where they used to meet.-In this call, MURILLO asked ZAABTUFF if he could send themethamphetamine today. ZAABTUFF told MURILLO that he had to talkto the “girl” (PARRA), and would call him back. MURILLO toldZAABTUFF that he was on the way and would go to where they used tomeet. Furthermore, according to toll information, PARRA calledZAABTUFF at 3:33 p.m. to further discuss the delivery of the drugs.27-d. At 4:38 p.m., Target Telephone 5 called661-3<strong>17</strong>-0735, used by PANCHO. MURILLO asked PANCHO for hiswhereabouts and told PANCHO to get off on “Soto” and he would bewaiting for him on “Olympic.” MURILLO then told PANCHO that hecould follow him to the “man.”-In this call, MURILLO asked PANCHO for his whereabouts andtold PANCHO to get off on “Soto,” or De Soto Avenue, and he would45


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728be waiting for him on “Olympic,” or Olympic Boulevard.27-e. At 4:43 p.m., Target Telephone 5 received a callfrom <strong>12</strong>4*<strong>13</strong>0*<strong>10</strong><strong>14</strong>9, used by PARRA. PARRA asked MURILLO if hewanted to meet at the freeway exit at the “7<strong>10</strong>" and “Florence.”MURILLO told PARRA to meet him at “Gage” and “California” and thatthere should be a McDonald’s. MURILLO then told PARRA that he waswaiting on “Olympic” for the “guy” that was going to take “them.”-In this call, PARRA asked MURILLO if he wanted to meet at thefreeway exit at the “7<strong>10</strong>" Highway and “Florence” Avenue. MURILLOtold PARRA to meet him at “Gage” Avenue and “California” Avenue andthat there should be a McDonald’s. MURILLO then told PARRA that hewas waiting on “Olympic” Boulevard for the “guy,” or PANCHO, thatwas going to take “them,” referring to the methamphetamine.27-f. At 5:<strong>14</strong> p.m., surveillance units located MURILLOparked at a McDonald’s restaurant located at the intersection ofGage Avenue and California Avenue in the city of Bell, California.MURILLO was observed driving a black Nissan and was parked next toa red Ford Explorer. Agents observed MURILLO speaking on acellular phone off and on. Several minutes later, MURILLO’svehicle and the red Ford Explorer left in tandem. Based on thedescribed intercepted calls between MURILLO and PANCHO, I believethat the red Ford Explorer was being driven by PANCHO.27-g. At 5:<strong>22</strong> p.m., Target Telephone 5 called<strong>12</strong>4*<strong>13</strong>0*<strong>10</strong><strong>14</strong>9, used by PARRA. PARRA told MURILLO that her carbroke down and that she was in a “burgundy Mercury” by the railroadtracks on “Florence.” MURILLO told PARRA that he would see herthere.-In this call, PARRA told MURILLO that her car broke down and46


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728that she was in a “burgundy Mercury” by the railroad tracks onFlorence Avenue. MURILLO told PARRA that he would see her there.27-h. At 5:54 p.m., Target Telephone 5 called<strong>12</strong>4*<strong>13</strong>0*<strong>10</strong><strong>14</strong>9, used by PARRA. PARRA asked MURILLO if he was behindher. MURILLO told PARRA to give the “guy” the “package.” MURILLOthen told PARRA that “he” was inside the “red car” in front of thetruck. PARRA asked MURILLO if she should give “it” to “him.”MURILLO told PARRA to give “it” to “him.”-In this call, PARRA asked MURILLO if he was behind her.MURILLO told PARRA to give the “guy” (PANCHO) the “package”(methamphetamine). MURILLO then told PARRA that “he” (PANCHO) wasinside the “red car” (red Explorer), in front of the truck.MURILLO told PARRA to give the drugs to PANCHO.27-i. At 5:55 p.m., agents located a red Mercury parkedon Florence Avenue in Cudahy, California, based on the locationgiven by PARRA to MURILLO during an intercepted call. Agentsobserved PARRA sitting inside the car using a cell phone. Momentslater, agents observed MURILLO and a red Ford Explorer driving intandem towards PARRA, and they stopped next to the red Mercury.27-j. At 5:55 p.m., Target Telephone 5 called661-3<strong>17</strong>-0735, used by PANCHO. MURILLO told PANCHO that it was the“red car” there and that “she” would give him the “bag” and to put“it” inside the backpack. MURILLO then told PANCHO to be on thesidewalk and take “it,” and they would leave right now.-In this call, MURILLO told PANCHO that it was the “red car,”or the burgundy Mercury that PARRA was inside, there and that“she,” or PARRA, would give him the “bag,” which contained themethamphetamine, and to put the methamphetamine inside the47


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728backpack. MURILLO then told PANCHO to be on the sidewalk and takethe drugs, and they would leave right now.27-k. At 5:58 p.m., Target Telephone 5 called661-3<strong>17</strong>-0735, used by PANCHO. MURILLO asked PANCHO how many“boxes” were there. PANCHO told MURILLO that he was not able tosee how many and asked MURILLO if he should count “them.” MURILLOtold PANCHO to pull over and count “them” before they left and thatway he could let the “guy” know.-In this call, MURILLO told PANCHO to count how many packagesof methamphetamine that he had received from PARRA, and to pullover and count “them” so that he (MURILLO) could tell ZAABTUFF.27-l. At 6:01 p.m., Target Telephone 5 received a callfrom 3340<strong>10</strong>0<strong>18</strong>8<strong>25</strong>399, used by ZAABTUFF. MURILLO asked ZAABTUFF howmany he gave him. ZAABTUFF told MURILLO that “they” gave him “2"and that he could give him “5" or “<strong>10</strong>" tomorrow because “that” wasall he had. MURILLO told ZAABTUFF that “they” came “wrapped” andnot in a “case,” so it was going to be nothing but “powder.”ZAABTUFF told MURILLO that once he opened “them” he would see that“they” were not what he was “saying.” ZAABTUFF told MURILLO thatthe packaging was just what he had but tomorrow he would send “5 to<strong>10</strong>.” ZAABTUFF then told MURILLO to check “those” out because“they” were very “pretty.” MURILLO told ZAABTUFF that he would seebecause if “they” came in “cases” “they” would be “pretty” and hehas had bad experiences with the “wrapped up ones.”-In this call, ZAABTUFF told MURILLO that PARRA delivered“two” (two pounds of crystal methamphetamine), and that he couldgive him “5" or “<strong>10</strong>" pounds tomorrow because the two pounds ofmethamphetamine was all he had. MURILLO told ZAABTUFF that the48


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728methamphetamine was “wrapped” (in tin foil and/or plasticpackaging), and not in a “case” (a plastic or rigid container), soit was going to be nothing but “powder,” or no longer in crystalform. ZAABTUFF told MURILLO that once he opened “them” (thedrugs), he would see that the quality was unaffected by thewrapping. ZAABTUFF told MURILLO that the packaging was just whathe had, but tomorrow he would send “5 to <strong>10</strong>" pounds. ZAABTUFF thentold MURILLO to check the two pounds of crystal methamphetaminewhich he described as very “pretty,” meaning high quality. MURILLOtold ZAABTUFF that if the drugs came in “cases,” the drugs would be“pretty.” MURILLO added that he had a bad experience with the“wrapped” methamphetamine. Furthermore, based on my training andexperience, crystal methamphetamine is normally packaged in rigidplastic containers to better preserve the drugs in crystal form asopposed to becoming crushed into powder.27-m. At 6:36 p.m., Target Telephone 5 received a callfrom 661-382-9046, used by TONY. MURILLO told TONY that he broughtthe “two girls.” MURILLO told TONY that “those” were the “realdeal” and that they already had the number “eight six.” TONY toldMURILLO that he thought that “it” was “half.” MURILLO told TONYthat “eight and a half” was fine, and he would deal with it.MURILLO told TONY that he would “arrive” soon, and he was on hisway up. MURILLO told TONY that he brought “two,” but was going togive him “one” so he could “work it.”-In this call, MURILLO told TONY that he brought the “twogirls,” jargon for two pounds of methamphetamine. MURILLO toldTONY that “those,” or the drugs, were the “real deal,” or of highquality, and that they already had the number “eight six,” or the49


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728price of the drugs was $8,600. TONY told MURILLO that he thoughtthat “it,” or the price of the drugs, was “half,” or $8,500.MURILLO told TONY that “eight and a half,” or $8,500 for a pound ofmethamphetamine, was fine, and he would deal with it. MURILLO toldTONY that he was going to the Moonlight Residence. MURILLO toldTONY that he brought “two,” or two units of drugs, but was going togive him “one” (a pound of methamphetamine), so he could “work it,”or sell the drugs.27-n. At 7:29 p.m., Target Telephone 5 called661-382-9046, used by TONY. MURILLO told TONY that he would waitat the “house” and that the “girl” was at the “house.” TONY toldMURILLO that he would be there in a half hour.-In this call, MURILLO told TONY that he would wait at the“house,” or the Moonlight Residence, and that the “girl,” or codedjargon for drugs, most likely methamphetamine, was at the “house,”or the Moonlight Residence. TONY told MURILLO that he would bethere in a half hour. Based on other intercepted calls describedbelow and GPS phone location data, I believe that the “house” isthe Moonlight Residence.27-o. At 8:<strong>17</strong> p.m., Target Telephone 5 received a callfrom 661-382-9046, used by TONY. TONY told MURILLO he would be“there” in five minutes. MURILLO told TONY that he was at thehouse on “<strong>25</strong>th” and not the one on “<strong>17</strong>.” TONY told MURILLO hewould be “there” soon.-In this call, TONY told MURILLO he would be “there,” or theMoonlight Residence, in five minutes. MURILLO told TONY that hewas at the house on “<strong>25</strong>th,” or the Moonlight Residence as it islocated several blocks west of <strong>25</strong>th Street, and not the one on50


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“<strong>17</strong>,” or the Carrolton Residence located at 38<strong>22</strong>7 <strong>17</strong>th Street.TONY told MURILLO he would be “there,” or the Moonlight Residence,soon. Furthermore, according to court-authorized GPS phonelocation data, at approximately 8:07 p.m., MURILLO was at theMoonlight Residence. Based on the above calls, surveillance, andGPS phone location data, I believe that TONY picked up the drugsfrom MURILLO at the Moonlight Residence.April 2, <strong>20</strong><strong>12</strong>27-p. At 5:<strong>24</strong> p.m., Target Telephone 5 called3340<strong>10</strong>0<strong>18</strong>8<strong>25</strong>399, used by ZAABTUFF. MURILLO asked ZAABTUFF if hecould send him “five” in the morning. ZAABTUFF told MURILLO thathe would send him “five” at whatever time he wanted and that the“girl” he saw yesterday would deliver them. ZAABTUFF told MURILLOhe would send him “five” at “seven three” and that he would tellthe “girl” to call him. MURILLO told ZAABTUFF to tell the “girl”to come around <strong>10</strong> a.m.-In this call, MURILLO asked ZAABTUFF if he could send him“five,” or five units of drugs, most likely crystalmethamphetamine, in the morning. ZAABTUFF told MURILLO that hewould send him “five” units of methamphetamine at whatever time hewanted and that the “girl,” or PARRA, he (MURILLO) saw yesterdaywould deliver them. ZAABTUFF told MURILLO he would send him “five”units at “seven three,” or $7,300 per unit, and that he would tellthe “girl,” or PARRA, to call him. MURILLO told ZAABTUFF to tellthe “girl,” or PARRA, to come around <strong>10</strong> a.m. As explained in moredetail below, agents believe that on or about 3/<strong>24</strong>/<strong>12</strong>, ESCOBARsuccessfully smuggled a drug laden vehicle from Mexico into theUnited States for ZAABTUFF and later delivered the drug laden car51


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728to a parking lot where another drug associate then picked it up anddrove it to PARRA’s house to be offloaded. Specifically, on4/2/<strong>12</strong>, at 6:08 p.m., surveillance units observed a black Chrysler300 pull into the drive way at PARRA’s residence being closelyfollowed by a small grey SUV with Baja California plates. Severalminutes later, the car with Baja California plates was no longervisible, and detectives believed that it entered the garage ofPARRA’s house. This was further confirmed on 4/3/<strong>12</strong> whensurveillance observed PARRA back the car with Baja Californiaplates out of the garage and abandon the car in a nearby shoppingcenter parking lot. Several minutes later, ESCOBAR entered the carwith Baja California plates and drove away. According to bordercrossing information, ESCOBAR drove the car with Baja Californiaplates into the United States from Mexico on 3/<strong>24</strong>/<strong>12</strong>. I believethat ESCOBAR smuggled and delivered a drug shipment to PARRA andthen PARRA supplied a portion of the drug shipment to MURILLO on4/3/<strong>12</strong> as described below.April 3, <strong>20</strong><strong>12</strong>27-q. At <strong>10</strong>:46 a.m., Target Telephone 5 called<strong>12</strong>4*<strong>13</strong>0*<strong>10</strong><strong>14</strong>9, used by PARRA. PARRA asked MURILLO if he wasnearby. MURILLO told PARRA he was at the “happy rat” near the“exit” and asked if she had a “little hand.” PARRA told MURILLOshe was driving a white Toyota Camry.-In this call, PARRA asked MURILLO if he was nearby. MURILLOtold PARRA he was at the “happy rat,” or coded jargon for the ChuckE Cheese Restaurant at 5089 E. Florence Avenue in the city of Bell,CA, near the “exit,” or off highway 7<strong>10</strong> and Florence Avenue, andasked if she had a “little hand,” drug jargon for five pounds of52


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728crystal methamphetamine. PARRA told MURILLO she was driving awhite Toyota Camry.27-r. At <strong>11</strong>:00 a.m., Target Telephone 5 called<strong>12</strong>4*<strong>13</strong>0*<strong>10</strong><strong>14</strong>9, used by PARRA. PARRA told MURILLO that she wasalmost “there.” MURILLO told PARRA that they were in front of“Chuck E Cheese.” (Surveillance confirmed that PARRA was on herway to Chuck E Cheese on Florence Avenue in Bell, California27-s. At <strong>11</strong>:08 a.m., detectives observedPARRA put a white bag that appeared to contain shoe boxes inside awhite Toyota Camry and then leave her house driving the whiteToyota Camry. Shortly thereafter, since the calls confirmed thatPARRA was transporting drugs in the white Toyota Camry to MURILLO,I directed a marked police car to stop the white Toyota Camry if avehicle violation was observed. After a traffic violation wasobserved, a marked police car stopped the white Toyota Camry.During the traffic stop the officer learned that PARRA was drivingwithout a license. The officer subsequently received consent fromPARRA to search the car. Pursuant to the impound of the car andPARRA’s consent to a search of the vehicle that she was illegallydriving, officers found two shoe boxes containing approximatelyfive pounds of crystal methamphetamine inside the trunk. PARRA wassubsequently arrested and refused to cooperate with lawenforcement. When asked about her children, PARRA refused to telllaw enforcement of their whereabouts. During a search incident toarrest, PARRA had a cell phone which had the same Push-to-Talknumber that was intercepted on Target Telephone 5 as describedabove. Because the intercepted calls revealed that a large amountof drugs were delivered to PARRA, agents suspected that the53


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728remaining methamphetamine was still at PARRA’s residence, whichserved as a stash house. However, before PARRA’s arrest,surveilling agents who were watching her house saw a man run out ofthe house. This coincided with a call that PARRA placed from hercar to ZAABTUFF shortly before she was stopped by police (this isconfirmed when agents examined her cell phone memory and found acall to ZAABTUFF’s number). Thus, agents believe that PARRA calledto alert ZAABTUFF that she was being pursued by police. Agentsfurther believe that ZAABTUFF then called the unidentified man atthe house, who fled with the remaining drugs. After PARRA’sarrest, agents went to the stash house and conducted a protectivesweep to determine if there were any occupants in the house.Agents found two boys alone inside the stash house - ages eightand nine. Agents confirmed that the boys are the sons of PARRA.27-t. After obtaining a state search warrant, agentsdiscovered empty drug packaging, hundreds of strings in the garage,car Bondo for automobile body repair, car jacks, car tools, and abowl of mud. Based on my training and experience, the stringslocated in the garage are consistent with smuggling drugs insidehidden compartments in vehicles. Specifically, the strings aretied around drugs so they can be easily retrieved from deepcompartments inside vehicles. Furthermore, the car Bondo materialand bowl of mud are consistent with altering the body of the carand concealing the hidden compartments with mud. In total, on4/3/<strong>12</strong>, law enforcement seized and recovered approximately 2.2kilograms (five pounds) of crystal methamphetamine from PARRA.27-u. On 4/4/<strong>12</strong>, and unrelated to this investigation,the Department of Child and Family Services (DCFS) contacted PARRA54


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728for an interview regarding her recent arrest and the welfare of herchildren. During the interview, PARRA told Child Services Worker(CSW) Lynette Uribe that PARRA knew she was transporting drugs on4/3/<strong>12</strong>. Furthermore, PARRA told CSW Uribe that she has previouslydelivered drugs on <strong>10</strong> separate occasions.RAYGOZA and ROSALES received cocaine from MIGUEL(MIGUEL, FERNANDEZ, ROSALES, and RAYGOZA)28. From 4/<strong>22</strong>/<strong>12</strong> through 4/<strong>24</strong>/<strong>12</strong>, agents intercepted thefollowing calls which revealed that Mexico-based supplier MIGUELhad arranged for FERNANDEZ to deliver a drug load to RAYGOZA andROSALES:April <strong>22</strong>, <strong>20</strong><strong>12</strong>28-a. At 9:56 p.m., Target Telephone 8 called3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. MIGUEL told FERNANDEZ that therewould be a “job” for Monday and that it would be “30" but “he”wanted to start with “<strong>10</strong>.” MIGUEL told FERNANDEZ that there wouldbe a “payment” of “1,000" and that “they” could bring it up to“1,000.” FERNANDEZ told MIGUEL he would take “it” tomorrow.-In this call, MIGUEL told FERNANDEZ that there would be a“job,” or coded jargon for a drug shipment, for Monday and that itwould be “30,” or 30 units, but “he,” or the drug customer, wantedto start with “<strong>10</strong>,” or <strong>10</strong> units of drugs. MIGUEL told FERNANDEZthat there would be a “payment,” or drug transportation fee, of“1,000,” or $1,000, and that “they,” or the drug customers, couldbring it up to “1,000,” or $1,000. FERNANDEZ told MIGUEL he wouldtake “it,” or the drug shipment, tomorrow.April <strong>23</strong>, <strong>20</strong><strong>12</strong>28-b. At 6:<strong>18</strong> p.m., Target Telephone 8 called55


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>2627283340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. FERNANDEZ told MIGUEL that theother “<strong>10</strong>" are “there.” MIGUEL told FERNANDEZ that “half” could goin “one” and the other “half” in another “one.” FERNANDEZ toldMIGUEL that it would have to be just “one” because he is goingalone and asked where are “those heading to.” MIGUEL toldFERNANDEZ that he would find out.-In this call, FERNANDEZ told MIGUEL that the other “<strong>10</strong>,” or<strong>10</strong> units of an unspecified drug, most likely cocaine, are “there,”or an undisclosed stash location in Mexico. MIGUEL told FERNANDEZthat “half,” or five units of drugs, could go in “one,” or codedjargon for smuggling trip, and the other “half,” or five units ofdrugs, in another “one,” or smuggling trip. FERNANDEZ told MIGUELthat it would have to be just “one,” or one smuggling trip, becausehe is going alone and asked where are “those heading to,” or wherethe drugs need to be delivered. MIGUEL told FERNANDEZ that hewould find out.April <strong>24</strong>, <strong>20</strong><strong>12</strong>28-c. At 7:43 a.m., FERNANDEZ drove across the borderfrom Mexico into the United States at the Port of Entry at SanYsidro, California driving a F-<strong>25</strong>0 truck.28-d. At 2:<strong>14</strong> p.m., Target Telephone 8 called3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. FERNANDEZ told MIGUEL that it wasa “done deal.”-In this call, FERNANDEZ told MIGUEL that it was a “donedeal,” meaning that the drugs were delivered.28-e. The wiretap calls confirmed that FERNANDEZsmuggled and delivered drugs for MIGUEL. FERNANDEZ agreed todeliver 30 kilograms of cocaine, which was smuggled in five-56


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728kilogram increments, and was planning to deliver five kilogramseach to two customers of MIGUEL. On 4/<strong>24</strong>/<strong>12</strong>, agents followedFERNANDEZ driving a F-<strong>25</strong>0 truck to an expected drug delivery.FERNANDEZ eventually met with RAYGOZA, who drove a blue pickuptruck. During a subsequent traffic stop for a traffic violation inthe city of San Bernardino, California, officers foundapproximately five kilograms of cocaine in the pickup truck drivenby RAYGOZA. RAYGOZA was arrested and released to protect theinvestigation. During a search incident to arrest, RAYGOZA had acell phone which had the same Push-to-Talk number that wasintercepted on Target Telephone 8, used by FERNANDEZ.28-f. Based on wiretap calls, agents also believe thaton the same day, FERNANDEZ delivered drugs to another customerbefore agents were able to set up surveillance. Using wiretapcalls and court-authorized GPS and cell site data of the phone usedby the customer, agents identified a house in Chino, California,where the drugs delivered by FERNANDEZ might be found in andobtained a state search warrant. During the search of the house,agents found another five kilograms of cocaine concealed in thehidden compartment of a car parked in the garage, as well as drugpackaging material, black electrical tape, and a drug “Pay & Owe”ledger inside the house. ROSALES and Victor Alfonso CardenasCabanillas (“Cardenas”) were arrested. After waiving their Mirandarights, ROSALES and Cardenas were untruthful about their drugoperations, and revealed no information about their drug suppliersor associates. During a search incident to arrest, ROSALES had acell phone which had the same Push-to-Talk number that wasintercepted on Target Telephone 8, used by FERNANDEZ.57


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728AHUMADA and GERA supplied methamphetamine to COSIO and BERMUDEZ(AHUMADA, GERA, PARTIDA, ELIAS-CAMACHO, MORENO, COSIO, andBERMUDEZ)29. The following are samples of calls which revealed theshipment of methamphetamine sent by AHUMADA and GERA in Mexico:April <strong>23</strong>, <strong>20</strong><strong>12</strong>29-a. At 9:51 a.m., Target Telephone 7, used by AHUMADA,received a call from 72*<strong>17</strong><strong>24</strong>46*1, used by PARTIDA. 9 AHUMADA toldPARTIDA that the “things” were over “there” already, and “they” aregoing to leave “them” with some “lady” and for PARTIDA to call the“guy” so they could pick “it” up. AHUMADA told PARTIDA “they” aregoing to leave “them” at the “house” and then “they” will figureout how to pick “them” up. AHUMADA told PARTIDA that the “four”belong to PARTIDA and that “they” were “pretty.” PARTIDA toldAHUMADA that the “lady” could bring “it” to “Long Beach” and“Amador” could figure it out. AHUMADA told PARTIDA he would like“them” to call and figure “it” out so “he” could pick “it” up.AHUMADA told PARTIDA that “they” were his, but “they” were going intwo “parts.” AHUMADA told PARTIDA that the “lady” arrived lateover “there” with “Tia Angela” and was going to a “house” so thatPARTIDA’s “compadre” could pick “her” up.-In this call, AHUMADA told PARTIDA that the “things,” orcoded jargon for drugs, most likely crystal methamphetamine, wereover “there,” or in the greater Los Angeles area, already and9 During many intercepted calls, the user of the phone isidentified by AHUMADA as “Jonas.” Furthermore, during anintercepted call, “Jonas” provided his full name as “Jonas CarilloPARTIDA” to complete a money wire transaction with AHUMADA.58


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“they,” or unidentified drug associates, are going to leave “them,”or the drugs, with some “lady,” or MORENO, and for PARTIDA to callthe “guy,” or COSIO, so they could pick “it,” or the drugs, mostlikely four pounds of crystal methamphetamine, up. AHUMADA toldPARTIDA “they,” or unidentified drug associates, are going to leave“them,” or the drugs, at the “house,” or an unidentified stashlocation, and then “they,” or unidentified drug associates, willfigure out how to pick “them,” or the drugs, up. AHUMADA toldPARTIDA that the “four,” or four pounds, belong to PARTIDA and that“they,” or the drugs, were “pretty,” or coded jargon referring tohigh quality methamphetamine. PARTIDA told AHUMADA that the“lady,” or MORENO, could bring “it,” or the drugs, to “Long Beach,”California, and “Amador,” or Amador Herrera COSIO, could figure itout. AHUMADA told PARTIDA he would like “them,” or COSIO andMORENO, to call and figure “it,” or the drug delivery, out so “he,”or COSIO, could pick “it,” or the drugs, up. AHUMADA told PARTIDAthat “they,” or all the drugs, were his, but “they,” or the drugs,were going in two “parts,” or to two different customers to avoiddetection by law enforcement. AHUMADA told PARTIDA that the“lady,” or MORENO, arrived late over “there,” or an undisclosedlocation, with “Tia Angela,” or coded jargon for Los Angeles, andwas going to a “house,” or an undisclosed stash location, so thatPARTIDA’s “compadre” (a Spanish term meaning buddy or associate),or COSIO, could pick “her,” or MORENO, up. According to bordercrossing information, MORENO entered the United States from Mexicoat <strong>12</strong>:<strong>18</strong> a.m. As mentioned above, I believe that when AHUMADA toldPARTIDA that the “lady” arrived late over “there” with “TiaAngela,” that they were describing MORENO’s early morning entry59


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728into the United States and subsequent arrival into Los Angeles,California.29-b. At <strong>11</strong>:05 a.m., Target Telephone 7, used byAHUMADA, received a call from 3340<strong>10</strong>0<strong>20</strong>9308<strong>19</strong>, used by ELIAS-CAMACHO. <strong>10</strong> AHUMADA told ELIAS-CAMACHO that the “men” were ready andwaiting for “him.” AHUMADA told ELIAS-CAMACHO that the number for“Juan” was “<strong>12</strong>5*<strong>14</strong>2*955" and “they” were going to drop off the“six.” ELIAS-CAMACHO told AHUMADA that he would leave “everything”with the “man” and asked if “he” was going to pay for “six.”AHUMADA told ELIAS-CAMACHO that “they” would give him “4,800.”-In this call, AHUMADA told ELIAS-CAMACHO that the “men,” orBERMUDEZ and other unidentified drug associates, were ready andwaiting for “him,” or ELIAS-CAMACHO’s courier, MORENO. AHUMADAtold ELIAS-CAMACHO that the number for “Juan,” or a fictitious nameused by BERMUDEZ, was “<strong>12</strong>5*<strong>14</strong>2*955,” or a Sprint Push-to-Talknumber, and “they,” were going to drop off the “six,” or six unitsof an unspecified drug, most likely methamphetamine. ELIAS-CAMACHOtold AHUMADA that he would leave “everything,” or the entire drugshipment, with the “man,” or BERMUDEZ and asked if “he,” or<strong>10</strong>I believe that ELIAS-CAMACHO is the user of this phone forseveral reasons. First, during intercepted calls, AHUMADAaddresses the user of the phone as “Candelario,” which is the firstname of Candelario ELIAS-CAMACHO. Second, in an unrelated FBIwiretap investigation, agents were wiretapping a phone used byELIAS-CAMACHO, the same one intercepted during this investigation.Even though ELIAS-CAMACHO discontinued the use of that phone, theFBI investigation identified a new phone being used by ELIAS-CAMACHO and received court authorization to intercept that phone.During that wiretap, agents intercepted a call where ELIAS-CAMACHOprovided his home address that corresponds to the address on ELIAS-CAMACHO’s Mexican driver’s license.60


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728BERMUDEZ, was going to pay for “six,” or six units of drugs.AHUMADA told ELIAS-CAMACHO that “they,” or BERMUDEZ and hisassociates, would give him “4,800,” or $4,800 in drugtransportation fees.29-c. At <strong>11</strong>:<strong>13</strong> a.m., Target Telephone 7, used by GERA,received a call from 3340<strong>10</strong>0<strong>20</strong>9308<strong>19</strong>, used by ELIAS-CAMACHO. GERAtold ELIAS-CAMACHO that it would be “six” for the “man” and “four”for the “buddy.” GERA told ELIAS-CAMACHO that he would give himthe “radio” for the other “person” so that he could call him.ELIAS-CAMACHO told GERA that the “lady” wasn’t answering and to lether wake up. GERA told ELIAS-CAMACHO that “Amador’s” number was“<strong>12</strong>4*856*7062" and to mention that he was calling on behalf of“Pato.”-In this call, GERA told ELIAS-CAMACHO that it would be “six,”or six units of drugs, for the “man,” or BERMUDEZ, and “four,” orfour units of drugs, for the “buddy,” or COSIO. GERA told ELIAS-CAMACHO that he would give him the “radio,” or Push-to-Talk number,for the other “person,” or COSIO, so that he could call him.ELIAS-CAMACHO told GERA that the “lady,” or MORENO, wasn’tanswering and to let her wake up. GERA told ELIAS-CAMACHO that“Amador’s,” or Amador Herrera COSIO’s, number was “<strong>12</strong>4*856*7062,” aPush-to-Talk number, and to mention that he was calling on behalfof “Pato,” or GERA, aka “Pato.”29-d. At 3:<strong>14</strong> p.m., Target Telephone 7, used by AHUMADA,received a call from a telephone with an IMSI of 3<strong>16</strong>0<strong>10</strong><strong>16</strong>4537530,61


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728used by BERMUDEZ. <strong>11</strong> AHUMADA asked BERMUDEZ if “they” communicatedwith him yet. BERMUDEZ told AHUMADA that he just talked to “her.”AHUMADA told BERMUDEZ to come to an “agreement” with the “lady.”-In this call, AHUMADA asked BERMUDEZ if “they,” or MORENO,communicated with him yet. BERMUDEZ told AHUMADA that he justtalked to “her,” or MORENO. AHUMADA told BERMUDEZ to come to an“agreement,” or conduct the drug transaction, with the “lady,” orMORENO. According to toll data, BERMUDEZ called the phone number<strong>12</strong>6*288*4601 used by MORENO at 3:<strong>11</strong> p.m. and 3:<strong>13</strong> p.m., only oneminute before the above described intercepted call. <strong>12</strong>29-e. At 5:<strong>24</strong> p.m., Target Telephone 7, used by GERA,called <strong>12</strong>5*<strong>14</strong>2*955, used by BERMUDEZ. GERA asked if “it” happenedand if “they” saw him. BERMUDEZ told GERA that “she” already left,<strong>11</strong> According to subscriber records, the IMSI corresponds to the samePush-to-Talk number that AHUMADA provided for “Juan” in an earlierintercepted call. I believe that BERMUDEZ uses this phone forseveral reasons. First, during surveillance on 4/26/<strong>12</strong> agentsmonitored court-authorized GPS cell phone location data for thistelephone, and the telephone’s location coincided with BERMUDEZ’smovements for several hours. Second, detectives then directed amarked police car to stop the car, and the stop confirmed thatBERMUDEZ was inside. Furthermore, during the traffic stop agentsmonitored the court-authorized GPS location data of BERMUDEZ’scellular phone. Agents confirmed that according to GPS data, theintercepted telephone was located inside the car stopped by police.<strong>12</strong>I believe this phone is used by MORENO for several reasons.First, during surveillance on several occasions agents monitoredcourt-authorized GPS cell location data that coincided withMORENO’s movements throughout the day. Second, according to phonesubscriber information, the phone is subscribed to “HermilaMORENO.” Third, on 5/<strong>17</strong>/<strong>12</strong>, MORENO was arrested at the San Ysidro,California Port of Entry (POE) attempting to smuggle <strong>16</strong> kilogramsof crystal methamphetamine into the United States. During a searchincident to arrest, agents discovered a cell phone in herpossession with the same phone number as described above.62


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728and “they” were going to check that “everything” was “okay.”-In this call, GERA asked if “it,” or the drug transaction,happened and if “they,” or MORENO, saw him. BERMUDEZ told GERAthat “she,” or MORENO, already left, and “they,” or BERMUDEZ andhis unidentified drug associates, were going to check that“everything,” or the drug shipment, was “okay,” or that thedelivered drugs were of satisfactory quality.29-f. At 5:46 p.m., Target Telephone 7, used by AHUMADA,received a call from 72*<strong>17</strong><strong>24</strong>46*1, used by PARTIDA. PARTIDA toldAHUMADA that “they” got the “girls” and his buddy “Amador” alreadygot “them.” PARTIDA told AHUMADA that “he” already went for“them.”-In this call, PARTIDA told AHUMADA that “they,” or BERMUDEZand COSIO, got the “girls,” or coded jargon for crystalmethamphetamine, and his buddy “Amador,” or Amador Herrera COSIO,already got “them,” or the four pounds of drugs. PARTIDA toldAHUMADA that “he,” or COSIO, already went for “them,” or the drugs.29-g. On April <strong>23</strong>, <strong>20</strong><strong>12</strong>, at 5:50 p.m., Target Telephone7 called <strong>12</strong>4*856*7062, used by COSIO. COSIO told AHUMADA that hegot the “girls.”-In this call, I believe that COSIO told AHUMADA that hereceived the drugs from MORENO. Specifically, COSIO told AHUMADAthat he got the “girls,” or coded jargon for methamphetamine.29-h. As shown by the calls above, AHUMADA and GERA hadarranged for the delivery of four pounds of crystal methamphetamineto COSIO and six pounds of crystal methamphetamine to BERMUDEZ on4/<strong>23</strong>/<strong>12</strong>. When agents located and surveilled COSIO, they conducteda traffic stop, but found no drugs in his car. Subsequent wiretap63


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728calls revealed that the drugs were at his residence. Furthermore,during the traffic stop agents monitored the court-authorized GPSlocation data of COSIO’s cellular phone. Agents confirmed thataccording to several GPS locations of COSIO’s cellular phone, theintercepted telephone was located inside the car stopped by police.Furthermore, subscriber information also confirmed that theintercepted telephone number was subscribed to “Amador Herrera” orthe abbreviated name for “Amador Herrera COSIO,” at “<strong>13</strong><strong>19</strong> WestSummit, unit 3, Long Beach, California.”29-i. On 4/<strong>24</strong>/<strong>12</strong>, I learned from Detective ScottSorrenson with the Long Beach Police Department (LBPD) gang unitthat COSIO’s residence, along with other residences in the area,were going to be searched based on an ongoing investigation into aseries of burglaries and property thefts involving the “WestsideLongo” gang in Long Beach, California. On 4/<strong>25</strong>/<strong>12</strong>, LBPD, inconjunction with HSI, executed a California state search warrant atCOSIO’s primary residence and another residence across the streetlocated in Long Beach, California. During a search of theresidence across the street, detectives found approximately fourpounds (1.8 kilograms) of crystal methamphetamine. Subsequentwiretap calls revealed that COSIO fled to Mexico when he saw thepolice at his house.CALUCHAS hired FERNANDEZ to deliver <strong>10</strong> poundsof methamphetamine to BAZUA and BENETIZ(FERNANDEZ, BOHON, CALUCHAS, BAZUA, and BENETIZ)30. The following calls show that CALUCHAS instructedFERNANDEZ to deliver methamphetamine to BAZUA and BENITEZ:64


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728April <strong>25</strong>, <strong>20</strong><strong>12</strong>30-a. At <strong>10</strong>:27 p.m., Target Telephone 8, used byFERNANDEZ, called 3<strong>16</strong>0<strong>10</strong>0<strong>17</strong>35<strong>22</strong>99, used by a male caller identifiedin intercepted calls as “Caluchas” (hereinafter “CALUCHAS”).CALUCHAS told FERNANDEZ that the “<strong>10</strong> girls” were “there.” CALUCHAStold FERNANDEZ that he wanted to give “them” to him today to“leave” tomorrow morning.-In this call, CALUCHAS told FERNANDEZ that the “ten girls,”drug jargon for <strong>10</strong> units of crystal methamphetamine, were “there,”or an undisclosed location in Mexico. CALUCHAS told FERNANDEZ thathe wanted to give “them,” or the drugs, to him (FERNANDEZ) today to“leave,” or be smuggled into the United States, tomorrow morning.As described below, agents believe that FERNANDEZ and BOHONsmuggled the drugs into the United States from Mexico on 4/29/<strong>12</strong>.April 29, <strong>20</strong><strong>12</strong>30-b. At 4:43 a.m., Target Telephone 8 received a callfrom 3<strong>16</strong>0<strong>10</strong>0037<strong>17</strong><strong>12</strong>8. According to subscriber records this IMSIcorresponds to Push-to-Talk number <strong>12</strong>2*<strong>11</strong>*893, used by BOHON.FERNANDEZ told BOHON to get the “things” “ready.” BOHON askedFERNANDEZ for the “keys.” FERNANDEZ told BOHON “they” were inside.-In this call, FERNANDEZ told BOHON to get the “things,” orthe drugs, most likely methamphetamine, “ready,” or packaged andready for smuggling. BOHON asked FERNANDEZ for the “keys,” or thekeys to the F-<strong>25</strong>0, the vehicle in which the drugs would beconcealed and transported. FERNANDEZ told BOHON “they,” or thekeys, were inside.30-c. According to border crossing information, on4/29/<strong>12</strong>, at 7:07 a.m., FERNANDEZ and BOHON entered the United65


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728States from Mexico in the same F-<strong>25</strong>0 truck at the Port of Entry atSan Ysidro.30-d. At 9:28 a.m., Target Telephone 8, used byFERNANDEZ, received a call from 3<strong>16</strong>0<strong>10</strong>0<strong>17</strong>35<strong>22</strong>99, used by CALUCHAS.CALUCHAS said that it was “<strong>12</strong>6*3<strong>15</strong>403*<strong>10</strong>.” CALUCHAS told FERNANDEZthat it was “De Parte de Inge,” and it was in “Riverside.”-In this call, CALUCHAS said that it was “<strong>12</strong>6*3<strong>15</strong>403*<strong>10</strong>,” orPush-to-Talk number <strong>12</strong>6*3<strong>15</strong>403*<strong>10</strong> to contact the intended drugcustomer. CALUCHAS told FERNANDEZ that it was “De Parte de Inge,”or a code phrase used to complete the drug transaction, and it wasin “Riverside,” or the drug customer was in Riverside, California.30-e. At 3:<strong>16</strong> p.m., Target Telephone 8, used byFERNANDEZ, received a call from <strong>12</strong>6*3<strong>15</strong>403*<strong>10</strong>, used by BAZUA. <strong>13</strong>FERNANDEZ told BAZUA to make a left when he gets off on “State” andthen he should go straight. BAZUA told FERNANDEZ that he was atthe stoplight. FERNANDEZ told BAZUA to continue and that hisbrother would be at the corner on “Porter” waiting for him. BAZUAtold FERNANDEZ that he was getting close. FERNANDEZ told BAZUAthat the “guy” had shorts on.-In this call, FERNANDEZ told BAZUA to make a left when hegets off on “State,” or State Street in the city of San Bernardino,and then he should go straight. BAZUA told FERNANDEZ that he wasat the stoplight. FERNANDEZ told BAZUA to continue and that hisbrother would be at the corner on “Porter,” or Porter Street in thecity of San Bernardino, waiting for him. BAZUA told FERNANDEZ that<strong>13</strong>BAZUA’s use of this phone was confirmed through, among otherinvestigative tools, his subsequent arrest and the discovery of thephone utilizing this number in his possession.66


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728he was getting close. FERNANDEZ told BAZUA that the “guy,” or hisbrother, had shorts on.30-f. As shown by the calls above, FERNANDEZ and BOHONhad agreed to deliver <strong>10</strong> pounds of crystal methamphetamine forCALUCHAS. On 4/29/<strong>12</strong>, agents followed FERNANDEZ and BOHON to ahouse in the city of San Bernardino, California, where they metwith a drug customer for CALUCHAS. This was the same location thatagents followed FERNANDEZ to on 4/<strong>24</strong>/<strong>12</strong> prior to seizing <strong>10</strong>kilograms of cocaine from RAYGOZA and ROSALES. During the agent’ssurveillance on 4/29/<strong>12</strong>, after the customer left, FERNANDEZconfirmed on a phone call with CALUCHAS that he had delivered thedrugs. Shortly thereafter, after the calls confirmed that the drugcustomer had received the drugs, I directed a marked police unit tostop BAZUA’s car if a traffic violation was observed. During asubsequent traffic stop, officers obtained the consent of BENETIZand BAZUA to search the car. During the search, officers found <strong>10</strong>packages of crystal methamphetamine (3.6 kilograms) on the backseat floor by the baby seated in the back, underneath the seat.BAZUA and BENETIZ were arrested. BAZUA had a cell phone that hadthe same Push-to-Talk number that was intercepted on TargetTelephone 8. After waiving his Miranda rights, BAZUA tolddetectives that the drugs were his, and he was doing a favor for anunidentified friend. Furthermore, BAZUA erroneously tolddetectives he got the drugs from a man driving a green truck, whenin fact FERNANDEZ’s truck is brown. When asked about where theymet, BAZUA told detectives that he did not remember. Additionally,BAZUA and BENETIZ were both untruthful about their whereabouts, andrevealed no further information about their drug suppliers or67


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728associates. BENETIZ told detectives that she had no knowledge ofthe drugs and was told to drive BAZUA and not ask questions.AHUMADA and GERA orchestrated the delivery ofmethamphetamine to SANCHEZ and MARTINEZ(AHUMADA, GERA, CHUMA, ELIAS-CAMACHO, MORENO, SANCHEZ, andMARTINEZ)31. The following calls confirm that AHUMADA and GERAinstructed ELIAS-CAMACHO to arrange to smuggle a shipment ofcrystal methamphetamine across the border from Mexico, which wasdelivered to SANCHEZ and MARTINEZ.May 1, <strong>20</strong><strong>12</strong>31-a. At 2:38 p.m., Target Telephone 7 received a callfrom 72*<strong>11</strong>*<strong>18</strong>457, used by a male caller identified in interceptedtelephone calls only as “Chuma” (hereinafter “CHUMA.”) CHUMA toldAHUMADA that he “got” a total of “<strong>20</strong>8 divided by 40" and that itwould be “5,<strong>20</strong>0.”-In this call, CHUMA told AHUMADA that he “got,” orcalculated, a total of “<strong>20</strong>8 divided by 40,” or a total payment fordrugs of $<strong>20</strong>8,000 divided by 40 units of an unspecified drug, mostlikely pounds of crystal methamphetamine, and that it would be“5,<strong>20</strong>0,” or $5,<strong>20</strong>0 per unit of drug.31-b. At 3:<strong>16</strong> p.m., Target Telephone 7, used by GERA,received a call from 3<strong>16</strong>0<strong>10</strong><strong>16</strong>9030654, used by SANCHEZ. <strong>14</strong> GERA told<strong>14</strong>SANCHEZ’s use of this telephone was confirmed by variousinvestigation tools as well as his subsequent arrest, as describedbelow, pursuant to which law enforcement recovered a phone on hisperson utilizing the above-referenced IMSI. According tosubscriber information, the intercepted IMSI coincides with thePush-to-Talk number of the phone recovered from SANCHEZ.68


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728SANCHEZ that tomorrow SANCHEZ would get the “guys” and that “they”were leaving right now. SANCHEZ asked GERA if he could give himtwo days to get everything “arranged.” GERA told SANCHEZ that wasnot a problem, and he would give him two or three days. GERA toldSANCHEZ that he sent him “tripas.” SANCHEZ told GERA that he wouldget ready and see if he could accommodate “everything” quickly.SANCHEZ told GERA that hopefully “it” was “sand-like” or“granulated” but not like “sugar.” GERA told SANCHEZ that “it” wasreally “good” and that he wouldn’t waste a “trip.” SANCHEZ toldGERA that if “it” was like “that,” then they would “work” hard.-In this call, GERA told SANCHEZ that tomorrow SANCHEZwould get the “guys,” or coded jargon for drugs, most likelycrystal methamphetamine, and that “they,” or the drugs, wereleaving right now. SANCHEZ asked GERA if he could give him twodays to get everything “arranged,” or the drug cash ready. GERAtold SANCHEZ that was not a problem, and he would give him two orthree days. GERA told SANCHEZ that he sent him “tripas,” or codedjargon for three units of drugs. SANCHEZ told GERA that he wouldget ready and see if he could “accommodate everything,” or codedjargon for picking the drugs up from the drug courier, quickly.SANCHEZ told GERA that hopefully “it,” or the drugs, was “sandlike”or “granulated,” or coded jargon referring to the crystallike structures of crystal methamphetamine, but not like “sugar,”or coded jargon for poor quality of methamphetamine. GERA toldSANCHEZ that “it,” or the drug shipment, was really “good,” or ofhigh quality, and that he wouldn’t waste a “trip,” or smuggling ofa drug load into the United States. SANCHEZ told GERA that if“it,” or the drugs, was like “that,” or of high quality, then they69


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728would “work,” meaning the drugs would easily sell.31-c. At 6:08 p.m., Target Telephone 7 called72*<strong>11</strong>*<strong>18</strong>457, used by CHUMA. CHUMA asked AHUMADA if “it” left.AHUMADA told CHUMA that the “lady” was going to come from that“side” and they would let him know.- In this call, CHUMA asked AHUMADA if “it” left,referring to the shipment of three pounds of crystalmethamphetamine. AHUMADA told CHUMA that the “lady,” or MORENO,was going to come from “that side,” a reference to the UnitedStates, and they would let him know.31-d. According to border crossing information, at9:30 p.m., MORENO crossed the border from Mexico into the UnitedStates at the Port of Entry at Otay Mesa, California, driving asilver Mitsubishi SUV.31-e. At 9:35 p.m., Target Telephone 7 called72*<strong>11</strong>*<strong>18</strong>457, used by CHUMA. AHUMADA told CHUMA that “it” was done.AHUMADA told CHUMA to be ready tomorrow morning and to have the“phone” ready because it was different “people.”- In this call, AHUMADA told CHUMA that “it,” or the drugshipment, was “done,” or successfully smuggled by MORENO across theborder. AHUMADA told CHUMA to be ready tomorrow morning and tohave the “phone,” or phone number, ready because it was different“people,” or drug customers.31-f. At 9:36 p.m., Target Telephone 7 received a callfrom 3340<strong>10</strong>00<strong>17</strong>9<strong>25</strong><strong>15</strong>, used by GERA. AHUMADA told GERA that the“Cande” “stuff” was “done.” GERA asked AHUMADA if the “family” hadleft yet, and it was good that they went on the “trip.”-In this call, AHUMADA told GERA that ELIAS-CAMACHO had70


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728coordinated the smuggling of the drug shipment across the border.GERA asked AHUMADA if the “family,” a disguised term for the drugcourier and drugs, had left yet, and it was good that they went onthe “trip.” According to border crossing information, MORENOentered the United States from Mexico at approximately 9:30 p.m.May 2, <strong>20</strong><strong>12</strong>31-g. At <strong>11</strong>:53 a.m., Target Telephone 7 called92*<strong>10</strong><strong>25</strong>898*1, used by ELIAS-CAMACHO. ELIAS-CAMACHO told AHUMADAthat the “lady” was asking what was going on because she had the“things” “there” for awhile, and to tell that “guy” to hurry up.AHUMADA told ELIAS-CAMACHO to give the other “three” to “Aria”because “he” came to pick “that” up. AHUMADA told ELIAS-CAMACHO tohave “her” call the “guy” and to give “them” to him. ELIAS-CAMACHOtold AHUMADA that “she” wanted to deliver “everything” at once.-In this call, ELIAS-CAMACHO told AHUMADA that the“lady,” or MORENO, was asking what was going on because she had the“things,” or drugs, “there,” or MORENO’s residence, for awhile, andto tell that “guy,” or SANCHEZ, to hurry up. AHUMADA told ELIAS-CAMACHO to give the other “three,” or three units of an unspecifieddrug, most likely crystal methamphetamine, to “Aria,” or a monikerfor SANCHEZ, because “he,” or SANCHEZ, came to pick “that,” or thedrugs, up. AHUMADA told ELIAS-CAMACHO to have “her,” or MORENO,call the “guy,” or SANCHEZ, and to give “them,” or the drugs, tohim. ELIAS-CAMACHO told AHUMADA that “she,” or MORENO, wanted todeliver “everything,” or all the drugs, at once.May 9, <strong>20</strong><strong>12</strong>31-h. At 6:58 p.m., Target Telephone 7 received a callfrom 3<strong>16</strong>0<strong>10</strong><strong>16</strong>9030654, used by SANCHEZ. SANCHEZ told AHUMADA that71


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“they” were not able to send the “papers” but “it” was showing that“it” was busy. AHUMADA told SANCHEZ to give him a minute.-In this call, SANCHEZ told AHUMADA that “they,” orSANCHEZ and MARTINEZ, were not able to send the “papers” (arrestreports) from 5/2/<strong>12</strong>, but “it” (the fax machine) was busy. AHUMADAtold SANCHEZ to give him a minute. As discussed below in paragraph31-i, MARTINEZ and SANCHEZ were arrested by law enforcement afterreceiving a drug load from MORENO. Based on my training andexperience, after the seizure of drugs by law enforcement, drugtraffickers are required to send arrest reports or seizure reportsto drug bosses in Mexico.31-i. As shown by the calls above, on 5/1/<strong>12</strong>, CHUMAarranged the delivery of 40 pounds of crystal methamphetamine toAHUMADA and his drug associate, GERA. AHUMADA and GERA thendirected ELIAS-CAMACHO to smuggle the drugs into the United Statesusing MORENO. ELIAS-CAMACHO was told to deliver three of the 40pounds to AHUMADA’s customer in Sylmar, California. MORENO thensmuggled the drugs across the border on 5/1/<strong>12</strong> at 9:30 p.m., anddelivered the three pounds to SANCHEZ and MARTINEZ on 5/2/<strong>12</strong> in LosAngeles, California, driving the same silver Mitsubishi that MORENOtraveled across the border in. After detectives observed MORENOmeet with SANCHEZ and MARTINEZ, they were followed to a residencein Sylmar, California. A short while later, several cars attemptedto leave the house, and they were detained pending furtherinvestigation. During a protective sweep of the residence,MARTINEZ ran back inside the house and attempted to flee out of theback of the house.31-j. After obtaining a state search warrant for the72


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728house, agents found approximately three pounds of crystalmethamphetamine (gross weight), 30 grams of cocaine, 1.87 kilogramsof marijuana, and $95,000 in cash. One methamphetamine package wasthrown into the toilet; a second package was tossed from a windowinto the bushes; and the third package was found with theneighbor’s dog. After waiving their Miranda rights, SANCHEZ andMARTINEZ were untruthful about their drug operations. Furthermore,during a search incident to arrest, SANCHEZ had a cell phone thathad the same Push-to-Talk number that was intercepted on TargetTelephone 7.ESCOBAR caught with a large load of methamphetamine at the border(ESCOBAR and ZAABTUFF)32. As discussed in paragraph 27-t, on 4/3/<strong>12</strong>, PARRA wascaught with 2.2 kilograms of crystal methamphetamine that she wasdelivering to MURILLO. During surveillance of PARRA the nightbefore the drug seizure, agents identified a load vehicle thatESCOBAR had used to deliver the drugs to PARRA’s residence. Thefollowing morning on 4/3/<strong>12</strong>, agents observed PARRA return the loadvehicle to a shopping center parking lot. Several minutes later,ESCOBAR entered into the car and drove away. On 5/7/<strong>12</strong>, ESCOBARwas arrested at the Port of Entry in Calexico California, when HSIagents discovered approximately 31.98 kilograms of crystalmethamphetamine (net weight pending) concealed within the same loadvehicle that he picked up on 4/3/<strong>12</strong>. The drugs were concealed inhidden compartments located in the wheel wells of the car. Thepackaging of the drugs, including the attached strings, wereidentical to the packaging and strings found at PARRA’s residenceduring the search on 4/3/<strong>12</strong>.73


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272833. After ESCOBAR waived his Miranda rights, he told agentsthat he worked for a drug boss named “AAA,” and that he hadsuccessfully delivered drug loads on two other occasions.According to border crossing information, ESCOBAR crossed into theUnited States in the same car on 3/7/<strong>12</strong> and 3/<strong>24</strong>/<strong>12</strong>. Furthermore,AAA provided ESCOBAR with a phone to be used by ESCOBAR for drugoperations. ESCOBAR told agents that once he successfullytransported a drug shipment from Mexico to the United States, hewould deliver the load car to a shopping center parking lot offhighway 7<strong>10</strong> and Florence Avenue in the city of Bell, California,where it would be picked up by an unknown drug associate. ESCOBARwould then stay the night in a nearby hotel. AAA would then callESCOBAR when the load car was empty and ready for pick up to bedriven back to Mexico. ESCOBAR had a drug ledger with directionsand a drawing of a map to highway 7<strong>10</strong> and Florence Avenue, the samelocation where agents observed PARRA drop off the car on 4/3/<strong>12</strong>.34. Furthermore, agents obtained the phone number ofESCOBAR’s drug cell phone. According to toll information, thatphone called ZAABTUFF dozens of times between 4/2/<strong>12</strong> and 4/3/<strong>12</strong>,and I believe that “AAA” is ZAABTUFF. Furthermore, I believe thaton 4/2/<strong>12</strong>, ESCOBAR delivered drugs to PARRA, who tried to deliver aportion of the load to MURILLO. The rest of the load was removedfrom PARRA’s house by a male associate around the time of hertraffic stop, after she called ZAABTUFF to alert him that policeofficers were behind her vehicle.MORENO caught with a large load of methamphetamine at the border(MORENO)35. On 5/<strong>17</strong>/<strong>12</strong>, at 8:48 p.m., MORENO attempted to enter the74


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728United States at the Port of Entry in Otay Mesa, California,driving a silver Mitsubishi Montero. During a search of her car atsecondary inspection, agents found approximately <strong>16</strong>.30 kilograms ofcrystal methamphetamine in a spare tire in the trunk of the car.MORENO told agents she did not know the drugs were there. She wassubsequently arrested.36. The silver Mitsubishi Montero is the same car that MORENOdrove when she smuggled drugs into the United States from Mexico on5/1/<strong>12</strong>, as described in paragraph 31-d. Inside the car agentsfound a phone that, according to toll records, was used by MORENOto contact defendants COSIO and BERMUDEZ when she delivered drugsto them on 4/<strong>23</strong>/<strong>12</strong>, as described in paragraphs 29-a through 29-g.In the cell memory, agents located a call from “Amigo de Tij” at<strong>10</strong>:<strong>14</strong> p.m. The direct call number and mobile number for “Amigo deTij” are saved as 92*<strong>10</strong><strong>25</strong>898*1 and 0<strong>11</strong>52<strong>16</strong>643866737. Based onintercepted calls, these numbers are used by defendant ELIAS-CAMACHO.BOHON and FERNANDEZ caught with a large loadof methamphetamine at the border(FERNANDEZ and BOHON)37. On 7/<strong>11</strong>/<strong>12</strong>, at <strong>12</strong>:30 a.m., FERNANDEZ and BOHON attemptedto enter the United States at the San Ysidro, California POE whiledriving a beige F-<strong>25</strong>0 truck. During a search of the truck insecondary inspection, agents discovered approximately 8.98kilograms of methamphetamine hidden in the rear back seat.FERNANDEZ and BOHON told agents that they did not know the drugswere in the vehicle, and they were subsequently arrested.FERNANDEZ and BOHON remain in custody in the Southern District of75


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728California. As noted above, the beige F-<strong>25</strong>0 driven by FERNANDEZand BOHON is the same car that agents observed FERNANDEZ driving todeliver drugs on 4/<strong>24</strong>/<strong>12</strong> and 4/29/<strong>12</strong>.C. Other Significant Drug Trafficking ActivityRIOS went to the Taco Shop to pick up cocaine for GAYTAN(GAYTAN and RIOS)38. On <strong>12</strong>/<strong>12</strong>/<strong>11</strong>, agents intercepted calls over TargetTelephone 1 which confirmed that RIOS supplied GAYTAN with cocainestored at the Taco Shop. The following is a sampling of thosecalls:December <strong>12</strong>, <strong>20</strong><strong>11</strong>38-a. At 1:<strong>18</strong> p.m., Target Telephone 1 called 8<strong>18</strong>-901-6934, used by the Taco Shop.<strong>15</strong> “Guille” answered the phone “LosTacos.” GAYTAN asked Guille if she had “Gollo’s” phone or if hewas around. Guille told GAYTAN that he was not “there.” Guilletold GAYTAN that his number was “8<strong>18</strong>-599-4534.”-In this call, “Guille,” an employee of the Taco Shop, gave“Gollo’s” (a moniker for RIOS) phone number to GAYTAN, 8<strong>18</strong>-599-4534. <strong>16</strong><strong>15</strong> On 6/4/<strong>12</strong>, I placed an unrecorded phone call to 8<strong>18</strong>-901-6934 toconfirm the phone number and address to the Taco Shop. A female,who answered the phone “Los Tacos,” confirmed the phone number andthe address.<strong>16</strong> I believe RIOS is the user of 8<strong>18</strong>-599-4534 for several reasons.First, according to subscriber records the phone is subscribed to“Gregorio Martinez, 7<strong>23</strong>3 Irvine Avenue, North Hollywood,California.” RIOS resides at 7733 Irvine Avenue, North Hollywood,California. Secondly, on <strong>12</strong>/<strong>16</strong>/<strong>12</strong>, agents surveilled RIOS forapproximately <strong>10</strong> hours. During this surveillance, court-authorizedGPS phone location data coincided with RIOS’ various locationsthroughout the day. Thirdly, during the same surveillance, agentsfollowed RIOS to the Taco Shop, the same location that GAYTAN76


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272838-b. At 1:<strong>21</strong> p.m., Target Telephone 1 called 8<strong>18</strong>-599-4534, used by RIOS. GAYTAN asked RIOS if he could bring him a“full bottle.” RIOS asked GAYTAN if the “same one.” GAYTAN toldRIOS that he wanted “pure tequila” or a “michelada.” RIOS askedGAYTAN which “kind” did he want. GAYTAN told RIOS that he wantedthe “clean one.” RIOS told GAYTAN that he had a “michelada” of the“clean one.” GAYTAN told RIOS that what he gave him the last timewas not very “good.” RIOS asked GAYTAN if he wanted that “half”and that he had to go to the “restaurant” to get “it.” GAYTANasked if he should send someone for “it.” RIOS told GAYTAN not tosend anyone because “they” did not “know.” RIOS asked GAYTAN if“they” could go to the “restaurant.” GAYTAN told RIOS that heneeded “it” right away. RIOS told GAYTAN that he would bring “it”to him in <strong>20</strong> minutes.-In this call, GAYTAN asked RIOS if he could bring him a “fullbottle.” RIOS then confirmed that GAYTAN wanted the “same one.”When GAYTAN told RIOS that he wanted “pure tequila,” he wanted highquality cocaine, but only a “michelada,” a coded reference to thequantity. When RIOS asked GAYTAN which “kind” he wanted, GAYTANwanted the “clean one,” a coded reference to cocaine. However,GAYTAN said that the cocaine he previously received was not very“good.” RIOS told GAYTAN to pick up the cocaine at the“restaurant,” or the Taco Shop. GAYTAN asked if he should sendsomeone for “it.” RIOS told GAYTAN not to send anyone because“they,” or the employees of the Taco Shop, did not know that RIOSstashed drugs at the Taco Shop. RIOS told GAYTAN that he wouldcalled on <strong>12</strong>/<strong>12</strong>/<strong>11</strong>.77


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728bring the cocaine to GAYTAN in <strong>20</strong> minutes.38-c. At 2:<strong>19</strong> p.m., Target Telephone 1 received a callfrom 8<strong>18</strong>-599-4534, used by RIOS. RIOS told GAYTAN that he justarrived at the “restaurant.” GAYTAN told RIOS to come “over.”RIOS asked GAYTAN if he should bring some of the “original one” andif “half.” GAYTAN told RIOS to bring the “original one.”-In this call, when RIOS told GAYTAN that he just arrived tothe “restaurant” (Taco Shop), GAYTAN told him to come “over” to theVanowen Auto Shop. RIOS asked GAYTAN if he should bring some ofthe “original one,” a reference to the cocaine, and agreed to bringthe “half,” or half pound of cocaine.LOPEZ used Reyes’ bank accountto receive drug proceeds from GAYTAN(LOPEZ and GAYTAN)39. Between 1/<strong>16</strong>/<strong>12</strong> and 3/02/<strong>12</strong>, agents intercepted callsover Target Telephone 1 which confirmed that LOPEZ directed GAYTANto deposit cash owed for drugs into a business account for JoseReyes (“Reyes”). Wiretap calls confirmed that GAYTAN hadpreviously ordered approximately 500 grams of heroin from LOPEZthat was seized by police in March <strong>20</strong><strong>12</strong> (see paragraph 26 above).The following is a sampling of the calls concerning the use of thisbusiness account by LOPEZ to receive drug proceeds from GAYTAN:February 2, <strong>20</strong><strong>12</strong>39-a. At <strong>10</strong>:<strong>22</strong> a.m., Target Telephone 1received a call from 3<strong>16</strong>0<strong>10</strong><strong>16</strong>452<strong>13</strong>43, used by LOPEZ. <strong>17</strong> LOPEZ toldGAYTAN that the number was “xxxx-82<strong>11</strong>" to “Bank of America” in the<strong>17</strong>According to subscriber information, this IMSI matches thePush-to-Talk number used by LOPEZ.78


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728name of “Rhino Stone USA.” GAYTAN told LOPEZ he would call as soonas he brought “that,” and his “nephew” would take what he has“there” and send him the “other” once “he” arrived.-In this call, LOPEZ gave GAYTAN a Bank of Americaaccount number “xxxx-82<strong>11</strong>,” in the name of “Rhino Stone USA,” todeposit cash. Bank records confirmed that the account was openedby Reyes in November <strong>20</strong><strong>11</strong>, with very few bank transactions. GAYTANtold LOPEZ that his “nephew” would deposit the cash kept at theVanowen Auto Shop. <strong>18</strong>39-b. At 3:<strong>15</strong> p.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. GAYTAN told LOPEZ that “he” had notarrived yet, but he would send his “nephew” to “deposit” the“three.”-In this call, GAYTAN told LOPEZ that his nephew would deposit$3,000 in drug cash. According to bank records, on 2/<strong>10</strong>/<strong>12</strong>, at aBank of America branch in North Hollywood, California (near wherethe Vanowen Auto Shop is located), an unidentified male deposited$3,000 (cash) in Reyes’ account no. xxxx-82<strong>11</strong>.February <strong>14</strong>, <strong>20</strong><strong>12</strong>39-c. At <strong>10</strong>:<strong>21</strong> a.m., Target Telephone 1 called<strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. LOPEZ told GAYTAN that the number was“xxxx-82<strong>11</strong>" to “Bank of America” in the name of “Rhino Stone USA.”GAYTAN told LOPEZ that once his “friend” came he would “send”another “three.” GAYTAN asked LOPEZ if he “confirmed” the other“ones.” LOPEZ told GAYTAN that he did.<strong>18</strong>According to GPS cell location data at <strong>10</strong>:26 a.m., TargetTelephone 1 was located at the Vanowen Auto Shop when GAYTAN wasintercepted.79


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728-As before, in this call LOPEZ told GAYTAN to deposit$3,000 into Reyes’ account. When GAYTAN asked LOPEZ if he“confirmed” the other “ones,” he was referring to the previous cashdeposits. Later that day, according to bank records, on 2/<strong>14</strong>/<strong>12</strong>,an unidentified male deposited $2,500 in cash into Reyes’ accountat the Bank of America branch in North Hollywood.39-d. Additional deposits were made by GAYTAN intoReyes’ account, as follows: 2/<strong>22</strong>/<strong>12</strong> for $3,000, 3/2/<strong>12</strong> for $5,000,and 4/30/<strong>12</strong> totaling $<strong>17</strong>,500. Bank records and video surveillanceconfirm that Reyes withdrew the deposited funds or transferred thefunds to another account.TRUJILLO sold four grams of crack cocaine to David(TRUJILLO)40. On 2/28/<strong>12</strong>, agents intercepted calls over TargetTelephone 4 which confirmed that TRUJILLO sold four grams of crackcocaine to a customer named “David.” The following is a samplingof those calls:February 28, <strong>20</strong><strong>12</strong>40-a. At <strong>10</strong>:<strong>14</strong> a.m., Target Telephone 4 received a callfrom 8<strong>18</strong>-309-8479, used by David. During the call, David askedTRUJILLO if he could make him “half cooked.” TRUJILLO asked David“half” of “what.” David told TRUJILLO “half” of “Tony” “cooked.”TRUJILLO asked David if he wanted “half a ball cooked.” Davidasked TRUJILLO if he could have it ready today and how much did hewant for the “small ball” so he could tell “him.” TRUJILLO askedDavid how much for “what.” David told TRUJILLO that for “half ballcooked.” TRUJILLO asked David if he wanted “<strong>16</strong>.” David toldTRUJILLO that no, he wanted “four” or a “half” or “four little80


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728balls made.”-In this call, David asked TRUJILLO if he could make him “halfcooked,” drug jargon for the “cooking” process of convertingcocaine to crack cocaine. TRUJILLO asked David for “half” a unitof “TONY,” which is jargon for cocaine. TRUJILLO asked David if hewanted “half a ball cooked,” which on the street is generally 3.5grams of crack cocaine. “Small ball” is a street reference to 1gram of crack cocaine. When TRUJILLO asked David if he wanted“<strong>16</strong>,” TRUJILLO said that he wanted “four,” meaning four “littleballs,” or four grams of crack cocaine.40-b. At <strong>12</strong>:06 p.m., Target Telephone 4 received a callfrom 8<strong>18</strong>-309-8479, used by David. David asked TRUJILLO if he hadthe other “thing.” TRUJILLO told David that “he” was “making”“one” right now and tomorrow “he” would make another “one.” Davidasked TRUJILLO what he had “done” now and what was he going to“make” him. TRUJILLO told David “one.” David asked TRUJILLO why“one” if he only wanted “half.” TRUJILLO told David that the “guy”wanted to make “one by one.” David told TRUJILLO that “one” rightnow was fine. David told TRUJILLO that he would tell “him” that hegot at least “one.”-In this call, David asked TRUJILLO if he had the other“thing,” a reference to crack cocaine. TRUJILLO told David thathis cook was making “one by one,” or one gram at a time. Davidtold TRUJILLO that “one” (gram) right now was fine.40-c. At 2:04 p.m., Target Telephone 4 received a callfrom 8<strong>18</strong>-309-8479, used by David. David asked TRUJILLO if “one”would be ready today or that “thing” they talked about . . . the“tortilla.” TRUJILLO told David that he would call the “guy” right81


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728now to see how far “he” was into “it.”-In this call, TRUJILLO told David that he would check withhis cook to find out when the crack cocaine would be ready.40-d. At 5:<strong>21</strong> p.m., Target Telephone 4 received a callfrom 8<strong>18</strong>-309-8479, used by David. David told TRUJILLO that hewanted to get the “half” and wanted to know how much “it” wouldcost. TRUJILLO told David that he did not have “it.” David askedTRUJILLO if he was going to make “one” today and “one” tomorrow.TRUJILLO told David that to tell “him” that it would be “450.”-In this call, TRUJILLO told David that the crack cocaine wasnot yet ready, and that it would cost $450.40-e. At 5:58 p.m., Target Telephone 4 called 8<strong>18</strong>-309-8479, used by David. TRUJILLO asked David where he was at. Davidtold TRUJILLO that he was at “Laurel Canyon” and would be “there”shortly. David asked TRUJILLO if “450" for the “four” and when hewould have the other “ones” ready. TRUJILLO told David thattomorrow, and he would have “one” ready every day.-In this call, David told TRUJILLO that he was at “LaurelCanyon,” or Laurel Canyon Boulevard in the city of North Hollywood,and would be “there,” or the Weidner Residence, which is located atthe intersection of Weidner Street and Laurel Canyon. TRUJILLOconfirmed that it would cost $450 for four grams of crack cocaine,and that the rest of the crack cocaine would be ready the next day.Wiretap calls confirmed that TRUJILLO met with David later thatevening.MURILLO and MACHADO prepared to deliver a load of methamphetamine(MURILLO and MACHADO)41. On 3/<strong>14</strong>/<strong>12</strong>, agents intercepted calls over Target82


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Telephone 5 which revealed that MURILLO hired MACHADO to deliver aload of methamphetamine. The following is a sampling of thosecalls:March <strong>14</strong>, <strong>20</strong><strong>12</strong>41-a. At <strong>11</strong>:<strong>25</strong> a.m., Target Telephone 5 received a callfrom 3<strong>16</strong>0<strong>10</strong><strong>15</strong>4397853, used by MACHADO. <strong>19</strong> MURILLO told MACHADO thatthe “guy” said that “it” was “alone” and that “they” could stay“there.” MURILLO told MACHADO that there would be “<strong>10</strong> guys and <strong>10</strong>girls” to make the “trip” worth it. MURILLO told MACHADO that the“guys” come “wrapped up” and are the “big ones” and the other“ones” are the “girls.” MURILLO told MACHADO there would be someof “both.” MACHADO asked MURILLO when he needed her (MACHADO) togo. MURILLO told MACHADO that maybe tomorrow but he would let herknow. MURILLO told MACHADO that the “people” get mad when theycall “them” directly. MACHADO told MURILLO that “MIGUEL” knows hervery well and for many years. MURILLO told MACHADO he would havethe “guy” call her.-In this call, MURILLO told MACHADO that CHARRO said that “it”(referring to a stash house), was “alone,” or unoccupied, and that<strong>19</strong> I believe MACHADO is the user of Push-to-Talk number <strong>12</strong>6*288*3<strong>18</strong>2(bearing the above-identified IMSI) for several reasons. First,according to subscriber records the phone is subscribed to “MariaCardenas, 880 W. 41st Street, San Bernardino, California.” This isthe same address that MACHADO has listed on her California driver’slicense, and her full name is Maria MACHADO Cardenas. Secondly,during surveillance on 3/<strong>15</strong>/<strong>12</strong> and 3/<strong>16</strong>/<strong>12</strong>, GPS location dataconfirmed that the cell phone was located at the same locationswhere agents observed MACHADO. Thirdly, during surveillance agentsobserved a car parked at MACHADO’s residence that is registered to“Maria MACHADO Cardenas, 880 W 41st Street, San Bernardino,California.”83


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“they,” or MACHADO and her drug associates, could stay at the stashhouse. (I believe that the “guy” is CHARRO based on a sequence ofadditional intercepted calls between MURILLO, CHARRO, and MACHADO.)MURILLO told MACHADO that there would be “<strong>10</strong> guys and <strong>10</strong> girls,” orcoded jargon for <strong>10</strong> units of two types of drugs, most likelycocaine and crystal methamphetamine, to make the “trip,” or thedrug shipment, worth it. MURILLO told MACHADO that the “guys,” orunits of cocaine, come “wrapped up,” or a description of thepackaging of the drugs, and are the “big ones,” or referring to thesize because, based on my training and experience, cocaine ispackaged in kilogram quantities as opposed to crystalmethamphetamine which is packaged in pound quantities, and theother “ones,” or the drugs, are the “girls,” or crystalmethamphetamine. MURILLO told MACHADO there would be some of“both,” or two types of drugs, most likely cocaine andmethamphetamine. MACHADO asked MURILLO when he needed her to go.MURILLO told MACHADO that maybe tomorrow, but he would let herknow. MURILLO told MACHADO that the “people,” or unidentified drugsources, get mad when they call “them,” or the drug sources,directly. MACHADO told MURILLO that “MIGUEL,” a drug associatethat uses FERNANDEZ to transport drugs, knows her very well and formany years. MURILLO told MACHADO he would have the “guy,” or anunidentified drug associate, call her.41-b. At 4:<strong>21</strong> p.m., Target Telephone 5 called<strong>12</strong>6*288*3<strong>18</strong>2, used by MACHADO. MACHADO asked MURILLO how many were“there.” MURILLO told MACHADO that the “guy” said that there wereabout “<strong>10</strong>" and some “girls.” MURILLO told MACHADO that “he” wouldconfirm tomorrow and would let her know so she could most likely84


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728bring all of “them.” MACHADO told MURILLO that the “ones” thatthey brought the last time barely “fit.” MURILLO told MACHADO thatthe “girls” took a lot of space and there would be “seven.”MURILLO told MACHADO that there would be “five” or “six” of the“big ones.” MURILLO told MACHADO to “fit” what she could and notto worry about it because “eight” of the other “ones” should “fit.”MURILLO told MACHADO that once she is “there” she could figure itout and bring only what “fits.”-In this call, MACHADO asked MURILLO how many packages ofdrugs were at the stash location. MURILLO told MACHADO that the“guy,” or CHARRO, said that there were about “<strong>10</strong>" packages.MURILLO told MACHADO that CHARRO would confirm tomorrow and wouldlet her know so she could most likely bring all of the drugs.MACHADO told MURILLO that the “ones” that they brought the lasttime barely “fit,” which refers to the space for the drugs insidethe compartment of the load car. MURILLO told MACHADO that the“girls” took a lot of space and there would be “seven,” indicatingthat the crystal methamphetamine (and its packaging) occupied a lotof space. MURILLO told MACHADO that there would be “five” or “six”of the “big ones,” referring to the other type of drug - cocaine.MURILLO told MACHADO to “fit” what she could and not to worry aboutit because “eight” of the other “ones” should “fit” in the loadcar. MURILLO told MACHADO that once she was at the stash location,she could figure it out and bring only what “fits.”PANCHO cooked methamphetamine for MURILLO(MURILLO and PANCHO)42. Between 3/<strong>21</strong>/<strong>12</strong> and 3/<strong>23</strong>/<strong>12</strong>, agents intercepted callsover Target Telephone 5 which confirmed that PANCHO “cooked”85


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728methamphetamine for MURILLO at the Moonlight Residence. Thefollowing is a sampling of those calls:March <strong>21</strong>, <strong>20</strong><strong>12</strong>42-a. On 3/<strong>21</strong>/<strong>12</strong> at 8:44 a.m., Target Telephone 5received a call from 661-3<strong>17</strong>-0735, used by PANCHO. During thecall, MURILLO asked PANCHO if he checked and saw how “that” wasdoing. MURILLO told PANCHO to remove the cover that he put on topand see if everything is “white” and not to move “it.” PANCHO toldMURILLO that “it” was not all “white.” MURILLO asked PANCHO if“they” look like “teeth” up and down, and if he could see anythingin the middle. MURILLO then asked PANCHO if the “water” was clear.MURILLO told PANCHO to leave “it” longer and remove the cover fromthe top.-In this call, I believe that MURILLO called PANCHO to checkon the production or “cooking” of methamphetamine at the MoonlightResidence. In a previous call, agents confirmed that PANCHO was atthe Moonlight Residence because he had agreed to watch MURILLO’spets at the residence when MURILLO was going out of town. WhenMURILLO asked PANCHO if he checked and saw how “that” was doing, hewas referring to the methamphetamine, to make sure it was “white,”the color of methamphetamine during the finishing stage ofprocessing, and not to move “it.” PANCHO told MURILLO that themethamphetamine was not all “white.” MURILLO asked PANCHO if themethamphetamine looked like “teeth,” referring to the crystallizedstructure of methamphetamine. MURILLO then asked PANCHO if the“water,” or the liquid containing the solid methamphetamine, wasclear. MURILLO told PANCHO to let the methamphetamine cook longerand to remove the cover from the top.86


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272842-b. At 2:<strong>11</strong> p.m., Target Telephone 5 called 661-3<strong>17</strong>-0735, used by PANCHO. MURILLO told PANCHO to look at the “thing”and see if it’s more “dense.” PANCHO told MURILLO that he lookedawhile ago, and it was getting “white” on top and that it had the“spikes” up and down.-In this call, MURILLO told PANCHO to check if themethamphetamine began to solidify (“dense”) and crystallize.PANCHO told MURILLO that it was getting “white” on top and that ithad the “spikes,” referring to the crystallized structure ofmethamphetamine.March <strong>23</strong>, <strong>20</strong><strong>12</strong>42-c. On 3/<strong>23</strong>/<strong>12</strong> at 8:26 a.m., Target Telephone 5received a call from 661-3<strong>17</strong>-0735, used by PANCHO. PANCHO toldMURILLO that he had checked his “jello.” PANCHO told MURILLO thatthe top and bottom had a thick layer around it and that the middlewas just “juice.” MURILLO told PANCHO to get a clean knife andstart making cuts in the middle, but to make sure “it” didn’t breakmuch. MURILLO then told PANCHO to “drain the chiles” and nothingbut “pretty pieces” will be left and to add a gallon of the “stufffor the nails.”-In this call, PANCHO told MURILLO that he had checked his“jello,” a disguised term for the unfinished methamphetamine.PANCHO told MURILLO that the top and bottom had a thick layeraround it and that the middle was just “juice,” or un-solidifiedchemicals. MURILLO told PANCHO to get a clean knife and startmaking cuts in the middle, but to make sure “it,” or the drugs,didn’t break much. MURILLO then told PANCHO to “drain the chiles,”referring to solid methamphetamine contained in the liquid, and87


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728nothing but “pretty pieces,” or crystallized pieces ofmethamphetamine, will be left, and to add a gallon of the “stufffor the nails,” referring to a chemical used in the manufacturingof methamphetamine.42-d. At 3:58 p.m., Target Telephone 5 received a callfrom 661-3<strong>17</strong>-0735, used by PANCHO. MURILLO asked PANCHO to tellhim the “totals.” PANCHO told MURILLO that with everything it was“<strong>23</strong>3" because MURILLO had left “82,” that the “first” was “77", andthe “second” was “74.” PANCHO told MURILLO that it was “<strong>23</strong>3" andadded the first “one” came out so-so and the second “one” was nicerbut finer. MURILLO told PANCHO to give all of “it” to “him” andtell “him” that it was a “half.”-In this call, PANCHO told MURILLO that the finishedmethamphetamine weighed “<strong>23</strong>3,” or <strong>23</strong>3 grams, because MURILLO hadleft “82,” or 82 grams, that the “first” batch was “77,” or 77grams, and the “second” batch was “74,” or 74 grams. PANCHO toldMURILLO that it was <strong>23</strong>3 grams total, and added that the first“one,” or batch of drugs, came out “so-so” and the second “one” wasbetter. MURILLO told PANCHO to give it to “him,” an unspecifieddrug customer, and tell him that it was a “michelada,” jargon fora half pound. It should be noted that <strong>23</strong>3 grams equalsapproximately 8.<strong>21</strong> ounces or .5<strong>13</strong> pounds.FERNANDEZ and BOHON delivered cocaineand methamphetamine for MIGUEL(FERNANDEZ, BOHON, MIGUEL, EL TIGRE, RUIZ, FNU LNU 3<strong>18</strong>, and FNU LNU348)43. Between 4/<strong>21</strong>/<strong>12</strong> and 4/<strong>22</strong>/<strong>12</strong>, agents interceptedcalls over Target Telephone 8 which revealed that Mexico-based88


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728supplier MIGUEL hired FERNANDEZ to smuggle a drug load across theborder from Mexico and that FERNANDEZ used BOHON to deliver thedrug load to EL TIGRE, FNU LNU 348, and RUIZ for MIGUEL and FNU LNU3<strong>18</strong>. The following is a sampling of those calls:April <strong>21</strong>, <strong>20</strong><strong>12</strong>43-a. At 4:34 p.m., Target Telephone 8 received a callfrom 3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. MIGUEL told FERNANDEZ thathe would give him the number of the “guy” that had the “five.”MIGUEL told FERNANDEZ that the number was “72*<strong>13</strong>4608*3,” and “onbehalf of Rene’s friend.” MIGUEL told FERNANDEZ to “go” with theother guy “El Tigre” (hereinafter “EL TIGRE.”) FERNANDEZ askedMIGUEL if it was “EL TIGRE” or “El Piloto.” FERNANDEZ told MIGUELthat it was “Mario” that received the “boxes” last time. MIGUELtold FERNANDEZ that the number was “<strong>12</strong>5*<strong>13</strong>2*6984" for “EL TIGRE.”-In this call, MIGUEL told FERNANDEZ that he would give himthe number of the “guy” (FNU LNU 3<strong>18</strong>) that had the “five”(kilograms of cocaine). MIGUEL told FERNANDEZ that the number was“72*<strong>13</strong>4608*3,” or the Push-to-Talk number for FNU LNU 3<strong>18</strong>, and “onbehalf of Rene’s friend,” or a code word used to conduct a drugtransaction. MIGUEL told FERNANDEZ to “go,” or conduct the drugdelivery, with the other guy, “EL TIGRE.” FERNANDEZ asked MIGUELif it was “EL TIGRE” or “El Piloto,” or another unidentified drugcustomer. FERNANDEZ told MIGUEL that it was “Mario,” or anotherdrug customer, that received the “boxes,” a disguised term fordrugs, most likely methamphetamine, last time. MIGUEL toldFERNANDEZ that the number for EL TIGRE was “<strong>12</strong>5*<strong>13</strong>2*6984.”43-b. At 8:37 p.m., Target Telephone 8 called3<strong>16</strong>0<strong>10</strong><strong>15</strong>4974075, used by EL TIGRE. FERNANDEZ told EL TIGRE that he89


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728was going to give his (EL TIGRE’s) number to his “brother” so thathe could call him and go over “there.” FERNANDEZ told EL TIGREthat his “brother” would be coming over “there.” EL TIGRE toldFERNANDEZ to have “him” call and they would come to an “agreement,”or make arrangements for the delivery of a drug shipment.-In this call, FERNANDEZ told EL TIGRE that he was going togive his (EL TIGRE’s) number to his “brother,” or BOHON (I believe“brother” refers to BOHON based on previous intercepted callsdiscussed in this affidavit as well as other intercepted callsdescribed below), so that he could call him and go over “there,” oran undisclosed location in the United States. FERNANDEZ told ELTIGRE that BOHON would be coming over “there,” or an undisclosedlocation in the United States. EL TIGRE told FERNANDEZ to have“him,” or BOHON, call and they would come to an “agreement.”43-c. At <strong>10</strong>:51 p.m., Target Telephone 8 called72*<strong>13</strong>4608*3, used by FNU LNU 3<strong>18</strong>. FNU LNU 3<strong>18</strong> told FERNANDEZ thatit was “<strong>12</strong>4*850*7348" and to make sure there were no “mistakes.”FNU LNU 3<strong>18</strong> told FERNANDEZ to say “on behalf of Rene’s friend” andthe “guy” knows what is “going on.” FNU LNU 3<strong>18</strong> asked FERNANDEZ ifthere were “five” going over “there.” FERNANDEZ told FNU LNU 3<strong>18</strong>that “five big guys” and the “guy” would give the “check.”-In this call, FNU LNU 3<strong>18</strong> told FERNANDEZ that it was“<strong>12</strong>4*850*7348,” or Push-to-Talk number used by FNU LNU 348, and tomake sure there were no “mistakes,” or that the drugs were notseized by law enforcement. FNU LNU 3<strong>18</strong> told FERNANDEZ to say “onbehalf of Rene’s friend,” or a code phrase to conduct the drugtransaction, and the “guy,” or FNU LNU 348, knows what is “goingon,” or knows about the pending drug delivery. FNU LNU 3<strong>18</strong> asked90


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728FERNANDEZ if there were “five” (most likely five kilograms ofcocaine), going over “there.” FERNANDEZ told FNU LNU 3<strong>18</strong> that“five big guys,” drug jargon for five kilograms of cocaine, and the“guy,” or FNU LNU 348, would give the “check,” or payment for thedrugs.April <strong>22</strong>, <strong>20</strong><strong>12</strong>43-d. At <strong>12</strong>:48 a.m., Target Telephone 8 called<strong>12</strong>2*<strong>11</strong>*893, used by BOHON. FERNANDEZ told BOHON that it was“<strong>12</strong>4*850*7348" and the “five big ones” go over “there” and the“four boxes” stay with “Tigre.” FERNANDEZ told BOHON to call“Tigre” since “Tigre” was already over “there” waiting. BOHON toldFERNANDEZ that he would call “him” now.-In this call, FERNANDEZ told BOHON that it was“<strong>12</strong>4*850*7348,” or Push-to-Talk number for FNU LNU 348, and the“five big ones,” or coded jargon for drugs, most likely fivekilograms of cocaine, go over “there,” or an undisclosed locationin the United States, and the “four boxes,” or coded jargon fordrugs, most likely four pounds of methamphetamine, stay with“Tigre,” or EL TIGRE. FERNANDEZ told BOHON to call “Tigre,” or ELTIGRE, since “Tigre,” or EL TIGRE, was already over “there,” or anundisclosed location in the United States, waiting. BOHON toldFERNANDEZ that he would call “him,” or EL TIGRE, now.43-e. At <strong>12</strong>:55 a.m., Target Telephone 8 called<strong>12</strong>2*<strong>11</strong>*893, used by BOHON. BOHON told FERNANDEZ that the “guys”answered him, and “Tigre” has not “crossed” yet, and the other“guy” was in “San Bernardino” on the “2<strong>15</strong>" by “Woodland.”-In this call, BOHON told FERNANDEZ that the “guys,” or ELTIGRE and FNU LNU 348, answered him, and “Tigre,” or EL TIGRE, has91


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728not “crossed” (the border) yet, and the other “guy,” or FNU LNU348, was in “San Bernardino” on the “2<strong>15</strong>" by “Woodland,” or in theCity of San Bernardino, California, off highway 2<strong>15</strong> and WoodlandStreet.43-f. At 2:01 a.m., Target Telephone 8 called<strong>12</strong>2*<strong>11</strong>*893, used by BOHON. BOHON told FERNANDEZ that he wanted toconfirm that it was “four” for “Tigre.” FERNANDEZ told BOHON thatit was “four” and the “five big ones” are going up “there.” BOHONtold FERNANDEZ that the “wooden boxes” were for “Tigre.”- In this call, BOHON told FERNANDEZ that he wanted to confirmthat it was “four,” or four units of drugs, most likely four poundsof methamphetamine, for “Tigre,” or EL TIGRE. FERNANDEZ told BOHONthat it was “four,” or four units of drugs, and the “five bigones,” or coded jargon for five units of drugs, most likelykilograms of cocaine, are going up “there,” or to the city of SanBernardino per previous calls. BOHON told FERNANDEZ that the“wooden boxes,” a disguised term for methamphetamine, were for ELTIGRE.43-g. At 3:46 a.m., Target Telephone 8 called3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. MIGUEL asked FERNANDEZ where hewas at. FERNANDEZ told MIGUEL that he was “there,” and his“buddies” were over “there”. MIGUEL asked FERNANDEZ if he did not“go.” FERNANDEZ told MIGUEL that “he” went alone. MIGUEL toldFERNANDEZ that he should have notified him that “he” was on that“side.” FERNANDEZ told MIGUEL that “he” already spoke to “him,”and it was the phone number his “buddy” gave him to deliver the“big boys.” FERNANDEZ told MIGUEL that “it” would happen with“Chapulin” once “he” heads back. FERNANDEZ told MIGUEL that “he”92


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728has a house in “San Ysidro” and left “it” there and that “he” woulddeliver “it” to “Tigre.” FERNANDEZ told MIGUEL that not in “SanYsidro” but in “Imperial Beach” and that “he” lives “there.”FERNANDEZ told MIGUEL that when they have to go “up there” theyleave “it” “there” and on the way back they deliver “it.”-In this call, MIGUEL asked FERNANDEZ where he was at.FERNANDEZ told MIGUEL that he was “there,” or in Mexico based oncourt-authorized GPS cell location data, and his “buddies,” orBOHON and other unidentified drug associates, were over “there,” oran undisclosed location in the United States. MIGUEL askedFERNANDEZ if he did not “go,” or smuggle the drugs. FERNANDEZ toldMIGUEL that “he,” or an unidentified drug associate whosuccessfully smuggled the drugs, went alone. MIGUEL told FERNANDEZthat he should have notified him that “he,” or the drug smuggler,was on that “side,” or in the United States. FERNANDEZ told MIGUELthat “he,” or BOHON, already spoke to “him,” or FNU LNU 348, and itwas the phone number his “buddy,” or FNU LNU 3<strong>18</strong>, gave him todeliver the “big boys,” or coded jargon for drugs, most likelykilograms of cocaine. FERNANDEZ told MIGUEL that “it,” or the drugtransaction, would happen with “Chapulin,” or another nickname usedby EL TIGRE, once “he,” or BOHON, heads back. FERNANDEZ toldMIGUEL that “he,” or BOHON, has a house in “San Ysidro,” or SanYsidro, California, and left “it,” or the methamphetamine drugshipment, there and that “he,” or BOHON, would deliver “it,” or thedrug shipment, or most likely methamphetamine, to “Tigre,” or ELTIGRE. FERNANDEZ told MIGUEL that not in “San Ysidro” but in“Imperial Beach” (California), and that BOHON lives “there” (theFlorida Residence located in the city of Imperial Beach).93


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728FERNANDEZ told MIGUEL that when they have to go “up there” (LosAngeles), they leave “it” (the drug shipment) there,” or at theFlorida Residence, and on the way back they could deliver the drugshipment. I believe that “there” refers to the Florida Residencefor several reasons. First, the Florida Residence is located inImperial Beach as referenced in the call above. Secondly, theFlorida Residence is BOHON’s primary residence. Third, asdescribed within this affidavit, the Florida Residence has beenused on separate occasions to stash drugs.43-h. At 3:55 a.m., Target Telephone 8 called<strong>12</strong>4*850*7348, used by FNU LNU 348. FERNANDEZ asked FNU LNU 348 ifhe would go to the “AM/PM” and that “he” would be coming “there.”FNU LNU 348 told FERNANDEZ that when “he” arrived “there” he wouldgo get “him.” FERNANDEZ told FNU LNU 348 to give “him” the“document” “there.” FERNANDEZ told FNU LNU 348 to call him once hegets “there” so he could call “Miguel.”-In this call, FERNANDEZ asked FNU LNU 348 if he would go tothe “AM/PM,” or an AM/PM convenience store, and that “he,” orBOHON, would be coming “there,” or to the AM/PM store. FNU LNU 348told FERNANDEZ that when “he,” or BOHON, arrived “there,” or theAM/PM store, he would go get “him,” or BOHON. FERNANDEZ told FNULNU 348 to give “him,” or BOHON, the “document,” or payment for thedrug delivery, “there,” or at the AM/PM store. FERNANDEZ told FNULNU 348 to call him once he gets “there,” or an undisclosed stashlocation, so he could call “Miguel,” or MIGUEL.43-i. At 4:<strong>20</strong> a.m., Target Telephone 8 received a callfrom 72*<strong>13</strong>4608*3, used by FNU LNU 3<strong>18</strong>. FERNANDEZ told FNU LNU 3<strong>18</strong>that the “guys arrived and met up.” FERNANDEZ told FNU LNU 3<strong>18</strong>94


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728that “he” met up with the “guy,” and the “five guys” arrived withhim. FERNANDEZ told FNU LNU 3<strong>18</strong> that “they” were headed back tothe “house” to get the “things” out. FERNANDEZ told FNU LNU 3<strong>18</strong>that “he” still needed to go to the house at “Ysidro” and drop offthe “boxes” with “Tigre” at 9:00 a.m. FNU LNU 3<strong>18</strong> told FERNANDEZthat it was “four” and the “five big ones” were for “up there.”FERNANDEZ told FNU LNU 3<strong>18</strong> that the “tomato ones” stayed down“there,” and the “fish” went up “there.”-In this call, FERNANDEZ told FNU LNU 3<strong>18</strong> that the “guysarrived and met up,” or the drug shipment was delivered to FNU LNU348 by BOHON. FERNANDEZ told FNU LNU 3<strong>18</strong> that “he,” or BOHON, metup with the “guy,” or FNU LNU 348, and the “five guys,” or codedjargon for drugs, most likely five kilograms of cocaine, arrivedwith him. FERNANDEZ told FNU LNU 3<strong>18</strong> that “they,” or BOHON, wereheaded back to the “house,” or the Florida Residence per previouscalls, to get the “things,” or the drugs, most likelymethamphetamine, out. FERNANDEZ told FNU LNU 3<strong>18</strong> that “he,” orBOHON, still needed to go to the house at “Isidro,” or San Ysidro,California, and drop off the “boxes” (methamphetamine) with ELTIGRE at 9:00 a.m. FNU LNU 3<strong>18</strong> told FERNANDEZ that it was “four”(four pounds of methamphetamine) and “five big ones” (fivekilograms of cocaine). FERNANDEZ told FNU LNU 3<strong>18</strong> that the “tomatoones” (disguised reference to methamphetamine), stayed down“there,” or at the Florida Residence, and the “fish” (a disguisedterm for cocaine) went up “there” (to a buyer in San Bernardino,California).43-j. At <strong>11</strong>:38 a.m., Target Telephone 8 called3<strong>16</strong>0<strong>10</strong><strong>15</strong>4974075, used by EL TIGRE. EL TIGRE told FERNANDEZ to send95


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“him” to that “guy’s” “house” on “Home Avenue.” EL TIGRE toldFERNANDEZ so “he” could pick “it” up with “Juan.” FERNANDEZ askedfor “his” number because he did not have it. EL TIGRE toldFERNANDEZ that he has “it,” and if not he would give “it” to him.-In this call, EL TIGRE told FERNANDEZ to send BOHON to RUIZ’s“house” at the Altadena Residence, on Home Avenue (located twoblocks away from the Altadena Residence). EL TIGRE told FERNANDEZthat BOHON, could pick “it” up, referring to the payment for thedrug shipment with RUIZ. FERNANDEZ asked for RUIZ’s number becausehe did not have it. I believe that “Juan” is RUIZ for severalreasons. RUIZ’s first name is “Juan.” Secondly, in a subsequentintercepted call, EL TIGRE provided FERNANDEZ with RUIZ’sPush-to-Talk number. Third, the Altadena Residence is RUIZ’sresidence and/or stash location for drugs and drug proceeds.43-k. At <strong>12</strong>:37 p.m., Target Telephone 8 received acall from 3<strong>16</strong>0<strong>10</strong><strong>15</strong>4984868, used by RUIZ. <strong>20</strong> RUIZ told FERNANDEZ thathe would send his “buddy” to pick up the “invoice.” FERNANDEZ toldRUIZ that he got in touch with “him” and he would wait for him<strong>20</strong>I believe this phone is used by RUIZ for several reasons. First,during intercepted calls, the user of the phone is identified as“Juan” and “Junior.” RUIZ’s full name is Juan Manuel RUIZ, Jr.Second, according to court-authorized GPS cell location data, theuser of the phone was located at 4<strong>13</strong>1 S Carpenter Road, Modesto,California, between 5/5/<strong>12</strong> and 5/<strong>12</strong>/<strong>12</strong>, which is the same addresson RUIZ’s driver’s license. Third, during surveillance on a drugtransaction on 4/26/<strong>12</strong> as described in paragraph 44-h, an agentobserved a Hispanic male that matched the physical description ofRUIZ, but because the agent was far away and the agent was tryingto go undetected, the agent was not able to clearly see the male’sface. Fourth, on a drive by of the Altadena Residence on 7/<strong>10</strong>/<strong>12</strong>,agents observed a car parked in the driveway registered to “RuizDetailing and/or Adrian Ruiz.”96


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“there.”-In this call, RUIZ told FERNANDEZ that he would send his“buddy,” or an unidentified drug associate at the AltadenaResidence, to pick up the “invoice,” or drug payment from anotherunidentified stash location. FERNANDEZ told RUIZ that he got intouch with “him,” or BOHON, and he would wait for him “there,” orthe Altadena Residence as confirmed in subsequent calls.43-l. At <strong>12</strong>:37 p.m., Target Telephone 8 called<strong>12</strong>2*<strong>11</strong>*893, used by BOHON. FERNANDEZ told BOHON that it was“Junior” not “Juan.” BOHON told FERNANDEZ that “he” answered andtold him by “Home” one goes “up, a right, and then a left” andthere is his “house.” BOHON told FERNANDEZ that he was headingover “there” right away.-In this call, FERNANDEZ told BOHON that it was “Junior,” or anickname used by RUIZ to avoid detection by law enforcement becauseRUIZ’s full name is Juan Manuel Ruiz Jr., not “Juan,” or RUIZ’sfirst name. BOHON told FERNANDEZ that RUIZ answered and told himby “Home” (near the Altadena Residence). BOHON told FERNANDEZ thathe was heading over to the Altadena Residence. It should be notedthat the directions provided above reflect the exact route oftravel to arrive at the Altadena Residence. If traveling north onHome Avenue in the city of San Diego, one would take a “right” ontoEuclid Avenue, and then take the first “left” on Altadena Avenue toarrive at the Altadena Residence.43-m. At <strong>12</strong>:40 p.m., Target Telephone 8 received acall from 3<strong>16</strong>0<strong>10</strong>0037<strong>17</strong><strong>12</strong>8, used by BOHON. BOHON told FERNANDEZthat “it” was done.-In this call, BOHON told FERNANDEZ that the drug cash pick up97


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728was done.43-n. At 4:38 p.m., Target Telephone 8 called3<strong>16</strong>0<strong>10</strong><strong>15</strong>4974075, used by EL TIGRE. EL TIGRE asked FERNANDEZ if“he” would go for “that.” FERNANDEZ told EL TIGRE “that” arrived,and “it” was ready. FERNANDEZ told EL TIGRE that “he” would be“there” and told him to be “alert.”-In this call, EL TIGRE asked FERNANDEZ if “he,” or BOHON,would go for “that,” or the previously delivered drugs, most likelymethamphetamine. FERNANDEZ told EL TIGRE “that,” or the drugshipment, arrived and “it,” or the drugs, was ready. FERNANDEZtold EL TIGRE that “he,” or BOHON, would be “there,” or to ELTIGRE’s undisclosed stash location, and told him to be “alert,” orready to receive the drug shipment and aware to the presence of lawenforcement.FERNANDEZ and BOHON delivered methamphetamine to RUIZ(MIGUEL, FERNANDEZ, BOHON, and RUIZ)44. Between 4/<strong>25</strong>/<strong>12</strong> and 4/26/<strong>12</strong>, agents intercepted callsover Target Telephone 8 which confirmed that MIGUEL hired FERNANDEZand BOHON to deliver six pounds of crystal methamphetamine to RUIZ.The following is a sampling of those calls:April <strong>25</strong>, <strong>20</strong><strong>12</strong>44-a. At <strong>10</strong>:<strong>14</strong> p.m., Target Telephone 8 received a callfrom 3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. FERNANDEZ asked MIGUEL tofind out so “they” could be moved. MIGUEL told FERNANDEZ that “he”did not want to take “them all at once.” FERNANDEZ asked MIGUEL“how many” did “they” bring and that he could move “five” at a“time.” MIGUEL told FERNANDEZ, “<strong>10</strong>.” FERNANDEZ told MIGUEL that“five” now and “five” tomorrow or whatever “they” wanted.98


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728-In this call, FERNANDEZ asked MIGUEL to check on whether adrug shipment should go out soon. MIGUEL told FERNANDEZ that “he”(referring to the courier, BOHON) did not want to take the drugs“all at once.” FERNANDEZ asked MIGUEL “how many” packages of drugscould be in one shipment, because BOHON could move “five” packagesper shipment. MIGUEL told FERNANDEZ that there would be “<strong>10</strong>"(packages or pounds of methamphetamine). FERNANDEZ told MIGUELthat “five” now and “five,” or five units of drugs, tomorrow orwhatever “they,” or RUIZ, wanted.44-b. At <strong>10</strong>:<strong>21</strong> p.m., Target Telephone 8 received a callfrom 3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. MIGUEL told FERNANDEZ that“he” told him that it was ok to take “six.” FERNANDEZ asked MIGUELwhere “they” would be going and to whom “they” would be going.MIGUEL told FERNANDEZ that he would get him the “number” right now.-In this call, MIGUEL told FERNANDEZ that “he” (BOHON) toldhim that it was ok to take “six” (six pounds of methamphetamine).FERNANDEZ asked MIGUEL where “they” (drugs) would be delivered.MIGUEL told FERNANDEZ that he would get him the “number” right now,referring to the Push-to-Talk Phone number of the drug customerthat FERNANDEZ and BOHON would call to coordinate the delivery ofthe drugs.44-c. At <strong>10</strong>:36 p.m., Target Telephone 8 received a callfrom 3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. MIGUEL told FERNANDEZ thatthe number was “<strong>12</strong>5*<strong>13</strong>9*9<strong>24</strong>6" for “Junior” and that he istrustworthy. MIGUEL told FERNANDEZ to notify him once he arrived“there” and to call the “guy” and “coordinate” with “him.”FERNANDEZ told MIGUEL that “Junior” would “attend” to “them”regardless of what time they “arrived” and that “they” knew how to99


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728get to “him.”-In this call, MIGUEL told FERNANDEZ that the number was“<strong>12</strong>5*<strong>13</strong>9*9<strong>24</strong>6" for “Junior” (RUIZ) who is trustworthy. MIGUEL toldFERNANDEZ to notify him once he arrived “there” (crossed the borderinto the United States) and to call the “guy” (RUIZ) to coordinatethe delivery. FERNANDEZ told MIGUEL that “Junior” (RUIZ) would“attend” (receive the drug shipment), when they “arrived,” and thatFERNANDEZ (and BOHON), knew how to get to “him,” meaning RUIZ atthe Altadena Residence.April 26, <strong>20</strong><strong>12</strong>44-d. At 3:<strong>13</strong> a.m., BOHON crossed the border from Mexicointo the United States at San Ysidro, California, driving a F-<strong>25</strong>0.44-e. At 3:<strong>16</strong> a.m., Target Telephone 8 called<strong>12</strong>2*<strong>11</strong>*893, used by BOHON. FERNANDEZ asked BOHON if he “passed”already. BOHON told FERNANDEZ that he was in “Angel.” FERNANDEZasked BOHON if he wanted to talk to “him.” BOHON told FERNANDEZthat he would be leaving at about 5:00 a.m. in the morning.FERNANDEZ told BOHON that he would give “it” to him once he gothome.-In this call, FERNANDEZ asked BOHON if he “passed,” orcrossed into the United States, already. BOHON told FERNANDEZ thathe was in “Angel,” a short reference to Los Angeles. FERNANDEZasked BOHON if he wanted to talk to “him” (RUIZ). BOHON toldFERNANDEZ that he would be leaving at 5:00 a.m. FERNANDEZ toldBOHON that he would give “it” (the drugs) to him once he got home.44-f. At 4:28 p.m., Target Telephone 8, used byFERNANDEZ, received a call from <strong>12</strong>5*<strong>13</strong>9*9<strong>24</strong>6, used by RUIZ.FERNANDEZ told RUIZ that his “brother” had an “order” for him and<strong>10</strong>0


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728that there were only “five girls.” RUIZ told FERNANDEZ he thoughtthere were “six.” FERNANDEZ told RUIZ that “they” couldn’t bringthe “six” but the “rest” would most likely go today. FERNANDEZasked RUIZ if all the “ones” that were “there” were RUIZ’s. RUIZtold FERNANDEZ that there were “two hands.” FERNANDEZ told RUIZ hethinks they will take “six boxes of tomatoes” over to RUIZ.-In this call, FERNANDEZ told RUIZ that his “brother” (BOHON)had an “order” (a disguised term for a drug shipment) for “fivegirls,” drug jargon for five pounds of crystal methamphetamine.RUIZ told FERNANDEZ that he thought there were “six” pounds.FERNANDEZ told RUIZ that “they” (FERNANDEZ and BOHON) couldn’tbring the “six” but the “rest” of the drug shipment would be sentlater that day. FERNANDEZ asked RUIZ if all the “ones” (drugs)“there” (at the stash location in Mexico, were RUIZ’s. RUIZ toldFERNANDEZ that there were “two hands,” drug jargon for <strong>10</strong> pounds ofkilograms of drugs. FERNANDEZ told RUIZ that he thought they wouldtake “six boxes of tomatoes” to RUIZ, meaning six pounds ofmethamphetamine.44-g. At 6:33 p.m., Target Telephone 8 received a callfrom 3<strong>16</strong>0<strong>10</strong><strong>15</strong>4984868, used by RUIZ. <strong>21</strong> FERNANDEZ asked RUIZ if his“brother” made it “there.” RUIZ told FERNANDEZ yes and that he“stepped out” and an “ugly car” pulled over “there” and then once“he” left the “vehicle” got “close” to “him.” FERNANDEZ asked RUIZif “he” delivered the “things.” RUIZ told FERNANDEZ that “he”delivered the “things” and that everything was “okay.” FERNANDEZ<strong>21</strong>According to subscriber information, this IMSI corresponds withthe Push-to-Talk number used by RUIZ as discussed previously.<strong>10</strong>1


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728asked RUIZ if “he” met him at his “house” where they always meet.RUIZ told FERNANDEZ that five minutes after “he” arrived that the“car” also arrived. FERNANDEZ told RUIZ that there was no problembecause “he” left with “nothing.” FERNANDEZ told RUIZ to put the“things” away or to move “them.”-In this call, FERNANDEZ asked RUIZ if his “brother” (BOHON)made it “there” (the Altadena Residence). RUIZ told FERNANDEZ thathe did, but an “ugly car,” coded jargon for a law enforcementsurveillance vehicle, pulled over “there,” near the AltadenaResidence, and then once BOHON left, the “vehicle” (police vehicle)got “close,” or began to follow BOHON. FERNANDEZ asked RUIZ ifBOHON delivered the “things” (drugs). RUIZ told FERNANDEZ thatBOHON delivered the “things” (drugs), and that everything was“okay.” FERNANDEZ asked RUIZ if BOHON met him at his “house” (theAltadena Residence) where they always meet. RUIZ told FERNANDEZthat five minutes after BOHON arrived, the “car” (police vehicle)also arrived. FERNANDEZ told RUIZ that there was no problembecause BOHON left with “nothing” (no drugs). FERNANDEZ told RUIZto put the “things” (drugs) away or move them.44-h. On 4/26/<strong>12</strong>, based on intercepted calls describedabove and court-authorized GPS location data, agents surveilled theAltadena Residence in anticipation of BOHON’s delivering of thedrugs to RUIZ. Agents observed a man walk out of the house andstand in the driveway on a cell phone. Several minutes later, abrown F-<strong>25</strong>0 arrived. The driver of the F-<strong>25</strong>0 and the man removedan object out of the bed of the truck and then the F-<strong>25</strong>0 left. Itshould be noted that the F-<strong>25</strong>0 observed matched the same color anddescription of the F-<strong>25</strong>0 that delivered five kilograms of cocaine<strong>10</strong>2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728on 4/<strong>24</strong>/<strong>12</strong> as discussed in paragraph 28-e, and that delivered theten packages of methamphetamine on 4/29/<strong>12</strong>, as described inparagraphs 30-c through 30-f. Furthermore, border records showthat the F-<strong>25</strong>0, driven by BOHON, crossed the border from Mexicointo the United States at 3:<strong>13</strong> a.m. on 4/26/<strong>12</strong>. Subsequent wiretapcalls confirmed that the F-<strong>25</strong>0 delivered drugs to RUIZ at theAltadena Residence and that surveillance was detected. RUIZ toldFERNANDEZ that a silver Ford Explorer with no plates followed theF-<strong>25</strong>0 after it delivered the drugs. This matches a surveillancevehicle that was at the residence and followed the F-<strong>25</strong>0.AHUMADA assisted BRAULIO in smuggling drugs from Mexico(AHUMADA and BRAULIO)45. On 5/<strong>11</strong>/<strong>12</strong> agents intercepted calls over Target Telephone7 in which AHUMADA agreed to help BRAULIO smuggle drugs into theUnited States. The following is a sampling of those calls:May <strong>11</strong>, <strong>20</strong><strong>12</strong>45-a. At 2:59 p.m., Target Telephone 7, used by AHUMADA,called 3340<strong>10</strong>00<strong>17</strong>93663, used by BRAULIO. BRAULIO asked AHUMADA ifhe could help him because he needed a “ride” over “there inside.”AHUMADA told BRAULIO that he had “one” for Sunday but right now heneeded to call the “other.” AHUMADA asked BRAULIO for “what.”BRAULIO told AHUMADA that the “other ones” or the “relatives of thewhite ones” because his “buddy” called and he had “<strong>13</strong>.” BRAULIOtold AHUMADA that “they” were “whole ones” and wanted to know ifthere was a way to send “them” over “there” or get a “ride” to that“side.” AHUMADA told BRAULIO that he would call the “man.”BRAULIO asked AHUMADA how much it would be for each “trip” perperson. BRAULIO told AHUMADA that “they” would take “them” the<strong>10</strong>3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728same at “two whole ones.” AHUMADA told BRAULIO that he knew of a“man” that was getting “one” of “them “ at “1,<strong>20</strong>0.” BRAULIO toldAHUMADA that the “guy” that does him the “favor” charges him “onepeso” for the “whiter ones” and “1,<strong>20</strong>0" for the “other.” AHUMADAtold BRAULIO that he had “one” that he went to go see yesterday andthat “he” would be free on Sunday. BRAULIO asked AHUMADA if the“friend” would take “them” all together. AHUMADA told BRAULIO that“it” was an old guy and that he would take “it” all.-In this call, BRAULIO asked AHUMADA if he could help him witha “ride” (to smuggle drugs), over “there inside” (into the UnitedStates). AHUMADA told BRAULIO that he had “one,” referring to adrug shipment, on Sunday but right now he needed to call the“other” (courier). BRAULIO told AHUMADA that he had the “otherones,” believed to be a reference to methamphetamine, which isconsistent with the reference to the “relatives of the white ones.”BRAULIO’s associate had “<strong>13</strong>,” either pounds or kilograms ofmethamphetamine, which is consistent with the reference to the“whole ones,” jargon for kilograms. AHUMADA told BRAULIO that hewould check if his courier would be able to include BRAULIO’s drugsin the next drug shipment. AHUMADA told BRAULIO that he knew of a“man,” or an unidentified drug courier, that was getting “one,” orkilogram, of “them,” or drugs, at “1,<strong>20</strong>0,” or $1,<strong>20</strong>0 fortransportation fees. BRAULIO told AHUMADA that the “guy” (hiscourier charges him “one peso,” or $1,000, for the “whiter ones”(cocaine), and “1,<strong>20</strong>0,” or $1,<strong>20</strong>0, for the “other”(methamphetamine). AHUMADA told BRAULIO that he had “one” (drugcourier) leaving on Sunday.<strong>10</strong>4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728AHUMADA and ELIAS-CAMACHO arranged a drug shipment for ABEJAS(AHUMADA, ELIAS-CAMACHO, and ABEJAS)46. Between 4/<strong>20</strong>/<strong>12</strong> and 5/<strong>12</strong>/<strong>12</strong> agents intercepted calls overTarget Telephone 7 which revealed that AHUMADA and ELIAS-CAMACHOarranged to deliver a drug load to ABEJAS. The following is asampling of those calls:April <strong>23</strong>, <strong>20</strong><strong>12</strong>46-a. At <strong>12</strong>:46 p.m., Target Telephone 7 received a callfrom 3340<strong>10</strong>00<strong>15</strong>59268, used by ABEJAS. AHUMADA asked ABEJAS if hefound out what “they” had. ABEJAS told AHUMADA that one went“down” but wanted “it” over on that “side” with his “uncle Diego.”ABEJAS asked AHUMADA if he had “anything” “there” in order to callthe “guy,” and asked AHUMADA what was the “number.” AHUMADA toldABEJAS he would have to figure out who to send “it” with and askedhow many he wanted. ABEJAS told AHUMADA that “they” wanted an “L”but “he” wanted some every two to three days. AHUMADA asked ABEJASif he knew the “guy” well. ABEJAS told AHUMADA that “he” comes tothat “side” and “it” was one of “them.” AHUMADA told ABEJAS thathe had to find “someone” who could “deviate” in order to leave “it”with “him.” ABEJAS told AHUMADA to check to see if “anybody” couldbring “it” so they didn’t lose the “client.” AHUMADA told ABEJASthat the “ones” that go over “there” go straight to “Angela.”ABEJAS asked AHUMADA to come up with the “numbers.”-In this call, AHUMADA asked ABEJAS if he found out what“they” had, referring to a pending drug shipment. ABEJAS toldAHUMADA that “one” (drug shipment), went “down,” meaning that itwas smuggled across the border, going to his “uncle Diego,” ordisguised reference to San Diego. ABEJAS asked AHUMADA if he had<strong>10</strong>5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728“anything” (or drugs) there or in San Diego, and asked for the“number” (price of drugs), adding that “they,” or his drugcustomer, wanted an “L,” coded jargon for one unit of drugs now,but would order some every two to three days. AHUMADA asked ABEJASif he knew the “guy” (drug customer) well. ABEJAS told AHUMADAthat his customer comes to that “side” (Mexico) and is one of“them” (Mexican national). AHUMADA told ABEJAS that he had to find“someone” (a drug courier), who could “deviate,” meaning deliver toSan Diego. ABEJAS told AHUMADA to check to see if “anybody” (oneof AHUMADA’s couriers) could bring “it.”46-b. At 6:34 p.m., Target Telephone 7 called3340<strong>10</strong>00<strong>15</strong>59268, used by ABEJAS. ABEJAS told AHUMADA that he spoketo his “friend” from the other “side,” and the “guy” needs “one”every three to four days for a maximum of “five” each week. ABEJAStold AHUMADA that once they look at “them” “they” could spread theword around and “promote” “them” but right now “he” only wanted“one.” ABEJAS told AHUMADA that he told “him” to try and “promoteit” so that “it” could be for “three.” AHUMADA told ABEJAS that“it” was “pretty” and that he saw “them.” AHUMADA told ABEJAS thatif “it” was “two” the “guy” would “go.” ABEJAS asked AHUMADA ifthey had “something” to look at. AHUMADA told ABEJAS that from“here to there” but there was nothing over “there.” ABEJAS toldAHUMADA that he would tell “him” that it was “two” for now.-In this call, ABEJAS told AHUMADA that he spoke to his“friend” (drug customer), from the other “side” (United States),who needs “one” (pound or kilogram of methamphetamine) every threeto four days, up to “five” each week. ABEJAS told AHUMADA thatonce they look at [the drugs], “they” could spread the word around<strong>10</strong>6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728and “promote,” or sell, the drugs, but right now his drug customerwanted only “one.” ABEJAS told AHUMADA that he told “him,” or thedrug customer, to try and “promote it,” or sell the drugs, so that“it,” or the next drug order, could be for “three,” or three unitsof drugs. AHUMADA told ABEJAS that the drugs were “pretty,” drugjargon for high quality methamphetamine, and that he saw “them”(drugs). AHUMADA told ABEJAS that if the drug order, were “two,”(two units of drugs), the “guy,” (drug courier) would “go”(smuggle drugs across the border). ABEJAS asked AHUMADA if theyhad “something” (a sample of drugs) to look at. AHUMADA toldABEJAS that from “here to there,” or from Mexico into the UnitedStates, but there was nothing over “there,” or inside the UnitedStates. ABEJAS told AHUMADA that he would tell “him,” or the drugcustomer, that it was “two,” or a minimum order of two units ofdrugs, for now.May <strong>11</strong>, <strong>20</strong><strong>12</strong>46-c. At 6:29 p.m., Target Telephone 7 called3340<strong>10</strong>00<strong>15</strong>59268, used by ABEJAS. ABEJAS asked AHUMADA if there wasany “movement.” AHUMADA told ABEJAS that “he” could take “it”tomorrow. ABEJAS told AHUMADA that he would try and get“organized.” ABEJAS told AHUMADA that “it” was going to be about“300 grams” more. ABEJAS told AHUMADA that “they” were going to dothe “five” and that “it” was about “300 to 350 grams.” ABEJAS toldAHUMADA that there were “six square ones” and “they” were like“4,800 or 4,900.” ABEJAS told AHUMADA that the “guy” told him that“it” was like “4,350" or “400.” ABEJAS told AHUMADA to tell “him”that “it” was “five” together and that was it. ABEJAS askedAHUMADA if “they” were going to do just one “part.” AHUMADA told<strong>10</strong>7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728ABEJAS that he would call the “guy” right now.-In this call, ABEJAS asked AHUMADA if there was any“movement,” or coded jargon for drug couriers who smuggle drugsinto the United States. AHUMADA told ABEJAS that “he,” or hiscourier, could take “it” (the drug load) tomorrow. ABEJAS toldAHUMADA that he would try and get “organized” (prepare for theshipment). ABEJAS told AHUMADA that the drug shipment was going tobe about “300 grams” more. ABEJAS told AHUMADA that “they,”referring to the customers in San Diego, were going to do the“five,” meaning five pounds of crystal methamphetamine, and that“it,” or each drug package, was about “300 to 350 grams.” ABEJAStold AHUMADA that there were “six square ones,” or six square unitsof drugs, and “they,” or the drug units, were like “4,800 or4,900,” or $4,800 or $4,900 per unit. ABEJAS told AHUMADA that the“guy” (drug supplier) told him that “it” was “4,350" or $4,350 perunit, or “400,” or 400 grams. ABEJAS told AHUMADA to tell hiscourier that the drug shipment was “five” or five pounds ofmethamphetamine. ABEJAS asked AHUMADA if the courier was going todo just one “part,” or smuggle the entire drug shipment at once.AHUMADA told ABEJAS that he would call the drug courier right now.46-d. At 7:<strong>22</strong> p.m., Target Telephone 7 called3340<strong>10</strong>00<strong>15</strong>59268, used by ABEJAS. AHUMADA told ABEJAS that he wouldcall the other “guy” and that “everything” was ready. AHUMADA toldABEJAS that he would tell the “man” that “it” would be for themorning and then he would give him the “number” so that they couldcommunicate. ABEJAS told AHUMADA that the black bag smelled butthat was the “part” and to have them package “it” separately.ABEJAS told AHUMADA that the “others” were “squared” so “it” wasn’t<strong>10</strong>8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728a problem. ABEJAS told AHUMADA that he wanted “it” separately andto “work hard” because “it” smelled. ABEJAS told AHUMADA that theyshould “prepare” it well over “there.” AHUMADA told ABEJAS that hewas going to give the “lady” the other so that “it” would be“ready.” AHUMADA told ABEJAS that she would pick “it” up.-In this call, AHUMADA told ABEJAS that he would call theother “guy,” or the drug courier, and that “everything” (the drugs)was ready. AHUMADA told ABEJAS that he would tell the “man”(ELIAS-CAMACHO) <strong>22</strong> that the drug shipment would be for the morningand then he would give him the “number” so that they couldcommunicate. ABEJAS told AHUMADA that the black bag smelled, andthat they should package “it” (the loose drugs) separately. ABEJAStold AHUMADA that the “others,” or other drug packages, were“squared,” or the shape of the packages, so “it,” or repackagingthe drugs, wasn’t a problem. ABEJAS told AHUMADA that he wanted“it,” or the loose drugs, separately and to “work hard,” orcarefully package the drugs as to avoid detection by lawenforcement, because “it,” or the drugs, smelled. ABEJAS toldAHUMADA that they should “prepare” it well over “there” (anundisclosed stash location in Mexico). AHUMADA told ABEJAS that hewas going to give the “lady” (drug courier) the other so that “it,”or the loose drugs, would be “ready,” or packaged and ready forsmuggling. AHUMADA told ABEJAS that she would pick “it,” or thedrugs, up.<strong>22</strong>I believe the “guy” is ELIAS-CAMACHO based on previousintercepted calls not described here pertaining to the sametransaction and other calls described below.<strong>10</strong>9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728May <strong>12</strong>, <strong>20</strong><strong>12</strong>46-e. At 7:42 a.m., Target Telephone 7 called3340<strong>10</strong>00<strong>15</strong>59268, used by ABEJAS. ABEJAS asked AHUMADA if the“movement” was on its way. AHUMADA told ABEJAS that he was aboutto “leave,” but would call the “man” right now. AHUMADA toldABEJAS that he would call to see when “he” was going to go for “it”and when “he” would “leave.” ABEJAS asked AHUMADA if “they” could“leave” in the afternoon.-In this call, ABEJAS asked AHUMADA if the “movement” (thedrug shipment) was on its way. AHUMADA told ABEJAS that he wasabout to “leave,” or head south into Mexico, but would call the“man” (ELIAS-CAMACHO), who AHUMADA subsequently called tocoordinate the delivery of drugs. AHUMADA told ABEJAS that hewould call to find out when the courier was going to move the drugshipment. ABEJAS asked AHUMADA if the courier could “leave” in theafternoon.46-f. At 9:41 a.m., Target Telephone 7 called92*<strong>10</strong><strong>25</strong>898*1, used by ELIAS-CAMACHO. AHUMADA told ELIAS-CAMACHOthat it was “five” but “he” wanted a “break” with “<strong>25</strong>0" so “he”could “make something.” ELIAS-CAMACHO told AHUMADA that was fine.-In this call, AHUMADA told ELIAS-CAMACHO that it was “five,”or five units of drugs, but that “he” (ABEJAS) wanted a “break,” orreduction in drug transportation fees, with “<strong>25</strong>0,” or $<strong>25</strong>0, so thatABEJAS could “make something.” ELIAS-CAMACHO told AHUMADA that wasfine.VADDITIONAL PROBABLE CAUSE TO SEARCH THE SUBJECT PREMISES47. Tujunga Residence. According to surveillance, wiretaps,1<strong>10</strong>


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728utility records, and other evidence, this location is GAYTAN’sprimary residence. Since October <strong>20</strong><strong>11</strong>, GAYTAN has been followed toand observed at the Tujunga Residence on a regular basis, andvehicles GAYTAN has been observed driving are often times parked atthe Tujunga Residence. Furthermore, on an intercepted call onNovember <strong>24</strong>, <strong>20</strong><strong>11</strong>, GAYTAN provided the exact address and statedthat the Tujunga Residence was his home. GAYTAN was seen at theresidence as recently as 6/27/<strong>12</strong> and his vehicles were seen at theresidence as recently as 8/1/<strong>12</strong>. As described below, GAYTAN usedhis Tujunga Residence to facilitate his drug trafficking activity,often times instructing drug customers to come to the TujungaResidence to pick up drugs. These pick-ups occurred, for example,on 2/<strong>10</strong>/<strong>12</strong>, 3/1/<strong>12</strong>, 3/<strong>10</strong>/<strong>12</strong>, and 3/<strong>20</strong>/<strong>12</strong>0, <strong>20</strong><strong>12</strong>. For each of thesereasons, and based on the information set forth herein, I believethat evidence of GAYTAN’s trafficking activity will be found atthis location:47-a. On <strong>11</strong>/27/<strong>11</strong> at 4:<strong>12</strong> p.m., Target Telephone 1received a call from 3<strong>16</strong>0<strong>10</strong><strong>16</strong>9049<strong>25</strong>1, used by TRUJILLO. GAYTANasked TRUJILLO how many. TRUJILLO told GAYTAN “two.” GAYTAN askedTRUJILLO if he should pick “it” up. TRUJILLO told GAYTAN that hewould go to his “house” right now.-In this call, GAYTAN asked TRUJILLO for the quantity ofdrugs. TRUJILLO told GAYTAN “two,” or two units of an unspecifieddrug. GAYTAN asked TRUJILLO if he should pick “it,” or the drugs,up. TRUJILLO told GAYTAN that he would go to his (GAYTAN’s)“house,” or the Tujunga Residence, right now. During theintercepted call described above, GAYTAN’s cell phone was using acell tower within a mile radius of the Tujunga Residence.<strong>11</strong>1


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272847-b. On 3/<strong>10</strong>/<strong>12</strong> at 3:44 p.m., Target Telephone 1received a call from 8<strong>18</strong>-7<strong>20</strong>-9570, used by CHILIPIQUIN.CHILIPIQUIN told GAYTAN that he had “one” of “those” that wasreally “good.” GAYTAN told CHILIPIQUIN to send the “guy” to see“it” and that “he” was on his way “there.” CHILIPIQUIN told GAYTANthat he would send him a “whole part” so he could see “it” reallywell.-In this call, CHILIPIQUIN told GAYTAN that he had “one,” or ashipment of drugs, of “those,” or cocaine, that was really “good,”or of high quality. GAYTAN told CHILIPIQUIN to send the “guy,” orunidentified drug courier, to see “it,” or the drugs, and that“he,” or TRUJILLO based on other intercepted calls not describedhere, was on his way “there,” or the Tujunga Residence.CHILIPIQUIN told GAYTAN that he would send him a “whole part,” orcoded jargon for an ounce of drugs, so he could see “it,” or thedrugs, really well.47-c. On 3/<strong>10</strong>/<strong>12</strong> at 4:59 p.m., Target Telephone 1 called8<strong>18</strong>-7<strong>20</strong>-9570, used by CHILIPIQUIN. CHILIPIQUIN told GAYTAN that“it” should be ready in half an hour. GAYTAN told CHILIPIQUIN tosend “it” to the “house” and that “David” was “there” too.-In this call, CHILIPIQUIN told GAYTAN that “it,” or thedrugs, should be ready in half an hour. GAYTAN told CHILIPIQUIN tosend “it,” or the drugs, to the “house,” or the Tujunga Residence,and that David, or David TRUJILLO, was “there” too. According tocourt-authorized GPS cell location data, at 4:57 p.m., GAYTAN wasat the Tujunga Residence.47-d. On 3/<strong>20</strong>/<strong>12</strong> at <strong>12</strong>:53 p.m., Target Telephone 1received a call from 8<strong>18</strong>-397-5437, used by GAYTAN’s niece, only<strong>11</strong>2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728identified as UF3<strong>23</strong>7. UF3<strong>23</strong>7 asked GAYTAN if he had “any” of the“black one.” GAYTAN told UF3<strong>23</strong>7 that “it” was the same one, and hecould “double/fold it.”-In this call, UF3<strong>23</strong>7 asked GAYTAN if he had “any” of the“black one,” or coded jargon referring to drugs, most likelyheroin. GAYTAN told UF3<strong>23</strong>7 that “it,” or the drugs, was the sameone and he could “double/fold it,” drug jargon for diluting thedrugs with another chemical to increase the volume for street sale.I believe that GAYTAN had the discussed drugs on this occasion (aswell as prior occasions) at the Tujunga Residence based on otherintercepted calls described above and below, my familiarity withthis investigation, and the seizure of heroin on 3/31/<strong>12</strong> that wasbeing delivered to GAYTAN at the Vanowen Auto Shop.47-e. On 3/<strong>20</strong>/<strong>12</strong> at <strong>12</strong>:58 p.m., Target Telephone 1received a call from 8<strong>18</strong>-397-5437, used by GAYTAN’s niece, onlyidentified as UF3<strong>23</strong>7. UF3<strong>23</strong>7 told GAYTAN that she wanted to puther boyfriend on the phone because he was the one that wanted that“thing” and had questions about “it.” GAYTAN told UF3<strong>23</strong>7 to notdiscuss it over the phone and to stop by later.-In this call, UF3<strong>23</strong>7 told GAYTAN that she wanted to put herboyfriend on the phone because he was the one that wanted that“thing,” or drugs, most likely heroin [per previous call], and hadquestions about “it,” or the drugs. GAYTAN told UF3<strong>23</strong>7 to notdiscuss it over the phone (to avoid detection by law enforcement)and to stop by later. I believe that GAYTAN told UF3<strong>23</strong>7 to stop byhis home, the Tujunga Residence, to discuss and pick up the heroin.(As mentioned previously, in paragraphs 26-d through 26-i, officersseized approximately 500 grams of heroin on 3/31/<strong>12</strong> based on<strong>11</strong>3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728information learned during the interception of GAYTON’s telephone,Target Telephone 1.)47-f. Moreover, it is likely that evidence oftrafficking activity including drugs, drug records, and drug cashare kept at the Tujunga Residence because, based upon my trainingand experience, traffickers keep such evidence within reach tofacilitate their trafficking activity. Furthermore, the evidencedescribed within this affidavit demonstrates that GAYTAN hasengaged in an ongoing pattern of drug trafficking for a significantperiod of time – as early as November <strong>20</strong><strong>11</strong> and as recently as March<strong>20</strong><strong>12</strong>. Moreover, given the large quantities of drugs seized on3/31/<strong>12</strong> (see paragraph 26-i), and GAYTAN’s prior drug conviction in<strong>20</strong>04, I believe that GAYTAN has been involved in drug traffickingfor an extensive period of time that spans several years.48. Vanowen Auto Shop. According to surveillance, wiretaps,utility records, and other evidence, this location is GAYTAN’splace of business, which GAYTAN uses as a storefront to distributeand sell drugs. Since October <strong>20</strong><strong>11</strong>, GAYTAN has been followed toand observed at the Vanowen Auto Shop on a regular basis, andGAYTAN’s vehicles have been observed parked at the Vanowen AutoShop. This was further confirmed with a pole camera that monitoredthe Vanowen Auto Shop from November <strong>20</strong><strong>11</strong> to February <strong>20</strong><strong>12</strong>. Thepole camera confirmed that GAYTAN was at the Vanowen Auto Shopseven days a week from 7:00 a.m. to 6:00 p.m. Furthermore, on anintercepted call on 2/<strong>19</strong>/<strong>12</strong>, GAYTAN provided the exact address andstated that he was the manager at the Vanowen Auto Shop. GAYTANwas seen at the business as recently as 6/27/<strong>12</strong>, and his vehicleswere seen parked outside of the business as recently as 6/27/<strong>12</strong>.<strong>11</strong>4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728Additionally, on 8/1/<strong>12</strong>, detectives observed TRUJILLO, GAYTAN’sdrug associate, sitting inside the Vanowen Auto Shop watchingpassing traffic. Moreover, wiretap calls reveal that GAYTAN usedhis business to store drugs, to facilitate his drug traffickingactivity, including installing hidden compartments in vehicles toconceal and transport drugs, and to serve as a stash location forTRUJILLO. These calls establish that evidence of the GAYTANorganization’s trafficking activity will be found at this location.For example, on <strong>11</strong>/<strong>22</strong>/<strong>11</strong>, detectives observed a car travel to theVanowen Auto Shop. The driver of the car then removed a blackpackage from the trunk of the car and took it inside the VanowenAuto Shop. The package was consistent with the same packaging,shape, and size of the heroin that was seized on 3/31/<strong>12</strong>, asdescribed in paragraphs 26-i and 39. Moreover, during interceptedcalls, GAYTAN and TRUJILLO and other drug associates distributeddrugs from the Vanowen Auto Shop, and AHUMADA agreed to send drugsto this location. For example:48-a. On <strong>11</strong>/26/<strong>11</strong> at 6:07 p.m., Target Telephone 1received a call from 8<strong>18</strong>-489-9748, used by a male caller whomGAYTAN addressed in intercepted phone calls as “Louie.” Louieasked GAYTAN where he was located at. GAYTAN told Louie that hewas at the “shop.” Louie told GAYTAN that he was stopping by andhe wanted “one eight altered.” GAYTAN told Louie to stop by.-In this call, Louie asked GAYTAN where he was at. GAYTANtold Louie that he was at the “shop,” or the Vanowen Auto Shop.Louie told GAYTAN that he was stopping by, and he wanted “one eightaltered,” or coded jargon for 3.5 grams of drugs, most likelycrystal methamphetamine. GAYTAN told Louie to stop by.<strong>11</strong>5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272848-b. Moreover, it is likely that evidence oftrafficking activity, including drugs, drug records, and drug cash,are kept at his Vanowen Auto Shop because, based upon my trainingand experience, traffickers keep such evidence within reach tofacilitate their trafficking activity, and information from thisinvestigation has established that GAYTAN visits the Vanowen AutoShop seven times a week for extended periods of times and that heand his associates store and distribute drugs from this location.Furthermore, the evidence described above and elsewhere in thisaffidavit demonstrates that GAYTAN has engaged in an ongoingpattern of drug trafficking for a significant period of time – asearly as November <strong>20</strong><strong>11</strong> and as recently as March <strong>20</strong><strong>11</strong>. Moreover,given the large quantities of drugs seized on 3/31/<strong>12</strong>, GAYTAN’sprior drug conviction in <strong>20</strong>04, and dozens of other interceptedcalls instructing drug customers to come to the Vanowen Auto Shopto pick up drugs, including calls on 1/<strong>14</strong>/<strong>12</strong>, 1/26/<strong>12</strong>, 1/27/<strong>12</strong>,1/29/<strong>12</strong>, 2/2/<strong>12</strong>, 2/<strong>22</strong>/<strong>12</strong>, and 3/<strong>23</strong>/<strong>12</strong>, I believe that GAYTAN hasbeen consistently involved in drug trafficking for a long period oftime encompassing several years.49. Weidner Residence. According to surveillance, wiretaps,and other evidence, this location is a stash house used byTRUJILLO. Since November <strong>20</strong><strong>11</strong>, TRUJILLO has been followed to andobserved at the Weidner Residence on several occasions, andTRUJILLO’s vehicles have been observed parked at the WeidnerResidence. I believe that TRUJILLO produces methamphetamine, crackcocaine, and also stores drugs at the Weidner Residence.Furthermore, when detectives tried to conduct surveillance at theWeidner Residence on <strong>12</strong>/27/<strong>11</strong>, “look outs,” common with houses used<strong>11</strong>6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728for drug trafficking, alerted TRUJILLO over intercepted calls thatthe Weidner Residence was being watched by law enforcement anddescribed a vehicle that matched the description of a surveillancevehicle used by law enforcement that day. Additionally, on<strong>12</strong>/29/<strong>11</strong>, TRUJILLO told GAYTAN on an intercepted call that he wasgoing to take “everything” out of “there,” or the WeidnerResidence, so if “they,” or law enforcement, dropped by everythingwould be “cleaned up,” or all drugs removed from the WeidnerResidence. I believe that the above call refers to the WeidnerResidence because on <strong>12</strong>/27/<strong>11</strong> surveillance units were detectedconducting covert surveillance at the Weidner Residence. On<strong>12</strong>/30/<strong>11</strong>, TRUJILLO told GAYTAN over several intercepted calls thathe (TRUJILLO) took “everything,” or the drugs, out of his “house,”or the Weidner Residence, including the cars. GAYTAN then toldTRUJILLO that he was on his way to the “shop,” or the Vanowen AutoShop, to go see. Even though the above calls describe TRUJILLOremoving drugs and/or drug evidence from the Weidner Residence, Ibelieve that since no law enforcement action has taken place withTRUJILLO or the Weidner Residence, that TRUJILLO has resumed drugoperations at the Weidner Residence. This was also confirmed whensurveillance units observed TRUJILLO arrive at the WeidnerResidence on 7/5/<strong>12</strong>, where TRUJILLO briefly entered the residencethen after approximately two or three minutes departed. Thisactivity was consistent with TRUJILLO stopping at the drug stashlocation to pick up drugs prior to a delivery, which itself isconsistent with the investigation into TRUJILLO’s drug traffickingrole and the use of the Weidner Residence. Furthermore, accordingto utility records on 6/<strong>11</strong>/<strong>12</strong>, the utility records have remained<strong>11</strong>7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728unchanged since <strong>20</strong>03. TRUJILLO was seen at the residence asrecently as 7/5/<strong>12</strong>, and his vehicles were seen at the WeidnerResidence as recently as 7/5/<strong>12</strong>. Additionally, during surveillanceconducted on 8/1/<strong>12</strong>, detectives observed non-operable vehicles thathad been seen during previous surveillance at this location.Moreover, as discussed above and below, wiretap calls reveal thatTRUJILLO used the Weidner Residence to store drugs and tofacilitate his drug trafficking activity, and, therefore, there isprobable cause to believe that evidence of the organization’strafficking activity will be found at this location. For example:49-a. On <strong>12</strong>/<strong>14</strong>/<strong>11</strong> at 9:54 a.m., Target Telephone 1received a call from 3<strong>16</strong>0<strong>10</strong><strong>16</strong>9049<strong>25</strong>1, used by TRUJILLO. TRUJILLOtold GAYTAN that the “chiclets” were about to arrive and askedGAYTAN if he wanted him to bring him “one” so he could try “it.”GAYTAN told TRUJILLO to bring him one.-In this call, TRUJILLO confirmed that he was expecting a drugshipment at the Weidner Residence. Specifically, TRUJILLO toldGAYTAN that the “chiclets,” drug jargon for drugs, most likelycrystal methamphetamine, were about to arrive at the WeidnerResidence, and asked GAYTAN if he wanted him to bring him “one,” orone unit of an unspecified drug, so he could try the drugs. GAYTANtold TRUJILLO to bring him one. According to court-authorized GPSlocation data, at <strong>10</strong>:05 a.m., TRUJILLO was at the WeidnerResidence.49-b. On <strong>12</strong>/<strong>20</strong>/<strong>11</strong>, at 8:<strong>11</strong> p.m., Target Telephone 2,used by TRUJILLO, received a call from 8<strong>18</strong>-4<strong>19</strong>-0995, used by a malecaller addressed by TRUJILLO during a number of intercepted phonecalls as “Carl.” Carl asked TRUJILLO where he was at and asked if<strong>11</strong>8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728he could drop by his “place.” TRUJILLO told Carl that he could.Carl asked TRUJILLO if “Pacoima” and told TRUJILLO to give him the“good one;” the “one” he gave him earlier in the day. TRUJILLOtold Carl that he would.-In this call, Carl asked TRUJILLO where he was at and askedif he could drop by his “place,” or the Weidner Residence.TRUJILLO told Carl that he could. Carl asked TRUJILLO if“Pacoima,” or the Weidner Residence located in the city of Pacoima,and told TRUJILLO to give him the “good one,” or a disguisedreference to high quality drugs, most likely one ounce ofmethamphetamine, like the “one,” an ounce of drugs of good quality,that TRUJILLO gave him earlier in the day. TRUJILLO told Carl thathe would.49-c. Moreover, it is likely that evidence oftrafficking activity, including drugs, drug records, and drug cash,are kept at the Weidner Residence because, based upon my trainingand experience, traffickers produce methamphetamine or crackcocaine and store cash and drug paraphernalia at stash houses andother locations to avoid detection by law enforcement.Furthermore, the evidence described in this affidavit demonstratesthat TRUJILLO has engaged in an ongoing pattern of drug traffickingfor a significant period of time – as early as November <strong>20</strong><strong>11</strong> and asrecently as May <strong>20</strong><strong>12</strong>.50. Beckford Residence. According to surveillance, wiretaps,utility records, and other evidence, this location is TRUJILLO’sprimary residence and stash location for vehicles used to conductdrug operations. Since December <strong>20</strong><strong>11</strong>, TRUJILLO has been observedat the Beckford Residence on several occasions and/or court-<strong>11</strong>9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728authorized GPS cell location data has confirmed that TRUJILLOresides at the Beckford Residence. TRUJILLO was seen at theresidence as recently as 8/1/<strong>12</strong>, and his vehicles were seen at theresidence as recently as 8/1/<strong>12</strong>.51. Moreover, it is likely that evidence of traffickingactivity including drugs, drug records, and drug cash are kept atthe Beckford Residence because, based upon my training andexperience, traffickers keep such evidence within reach tofacilitate their trafficking activity. Furthermore, the evidencedescribed herein demonstrates that TRUJILLO has engaged in anongoing pattern of drug trafficking for a significant period oftime - as early as November <strong>20</strong><strong>11</strong> and as recently as May <strong>20</strong><strong>12</strong>.During the wiretaps, TRUJILLO was intercepted conducting dozens ofsmall quantity drug transactions involving crystal methamphetamine,cocaine, and heroin on <strong>12</strong>/<strong>16</strong>/<strong>11</strong>, <strong>12</strong>/<strong>17</strong>/<strong>11</strong>, <strong>12</strong>/<strong>19</strong>/<strong>11</strong>, <strong>12</strong>/<strong>20</strong>/<strong>11</strong>,<strong>12</strong>/<strong>21</strong>/<strong>11</strong>, <strong>12</strong>/<strong>22</strong>/<strong>11</strong>, 1/<strong>15</strong>/<strong>12</strong>, 1/<strong>16</strong>/<strong>12</strong>, 1/<strong>17</strong>/<strong>12</strong>, 1/<strong>18</strong>/<strong>12</strong>, 1/<strong>20</strong>/<strong>12</strong>,1/<strong>23</strong>/<strong>12</strong>, 2/<strong>15</strong>/<strong>12</strong>, 2/<strong>16</strong>/<strong>12</strong>, 2/<strong>18</strong>/<strong>19</strong>, 2/<strong>20</strong>/<strong>12</strong>, 2/<strong>21</strong>/<strong>12</strong>, 2/<strong>22</strong>/<strong>12</strong>,2/<strong>23</strong>/<strong>12</strong>, 2/<strong>24</strong>/<strong>12</strong>, 2/<strong>25</strong>/<strong>12</strong>, 2/26/<strong>12</strong>, 2/27/<strong>12</strong>, 2/28/<strong>12</strong>, 2/29/<strong>12</strong>, and3/1/<strong>12</strong>. I believe that TRUJILLO stashes drugs at the BeckfordResidence (along with the Weidner Residence, the Vanowen Auto Shop,and other locations) to facilitate his distribution and sale ofdrugs. Moreover, given the seizure of drugs on 1/<strong>16</strong>/<strong>12</strong> (seeparagraph <strong>24</strong>-h), TRUJILLO’s prior drug convictions in <strong>19</strong>91, <strong>19</strong>98,and <strong>20</strong>06, and TRUJILLO’s counter surveillance techniques to avoidand escape detection by law enforcement, to include elusive drivingand rotating phones every 30 days, I believe that TRUJILLO has beeninvolved in drug trafficking for an extensive period of time thatspans several years and will continue to do so while maintaining a<strong>12</strong>0


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728stash of drugs at the Beckford Residence. Furthermore, wiretapshave confirmed that TRUJILLO is also a user of drugs. Therefore, Ibelieve that personal consumption amounts of narcotics, to includecrystal methamphetamine, cocaine, and heroin will be located at theBeckford Residence.52. Chula Vista Shop. According to surveillance, wiretaps,utility records, lease agreements, and other evidence, thislocation is LOPEZ’s place of business, which LOPEZ uses as astorefront to stash drugs smuggled from Mexico and to store drugcash before it is smuggled into Mexico. Since December <strong>20</strong><strong>11</strong>, LOPEZhas been either followed to and/or observed at the Chula VistaShop. Furthermore, court-authorized GPS cell location data hasalso confirmed that LOPEZ travels to the Chula Vista Shop on aregular basis, and LOPEZ’s vehicles have been observed parked atthe Chula Vista Shop. This was further confirmed when agentsparked a car with surveillance equipment on a public parking lotand monitored LOPEZ’s movements at the Chula Vista Shop for severalweeks in April <strong>20</strong><strong>12</strong>. LOPEZ was seen at the Chula Vista Shop asrecently as 5/9/<strong>12</strong>, and his vehicles were seen at the business asrecently as 8/<strong>15</strong>/<strong>12</strong>. Furthermore, during surveillance on 8/2/<strong>12</strong>,agents observed the roll-up doors open and several people insidethe Chula Vista Shop.53. Moreover, it is likely that evidence of traffickingactivity, including drugs, drug records, and drug cash, are kept atthe Chula Vista Shop because, based upon my training andexperience, traffickers keep such evidence within reach tofacilitate their trafficking activity. As described above inparagraphs 26-d through 26-i, wiretap calls, surveillance, and the<strong>12</strong>1


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728subsequent seizure of approximately 500 grams of heroin confirmedthat on 3/31/<strong>12</strong> GALVAN, a courier used by LOPEZ, picked up a loadof drugs from the Chula Vista Shop and then attempted to deliverthe drugs to GAYTAN. Furthermore, wiretap calls, surveillance, andbank records have also confirmed that GAYTAN uses LOPEZ to launderdrug cash to Mexico. I believe that evidence of the organization’strafficking activity will be found at the Chula Vista Shopincluding drugs, drug records, bank records, and drug cash.Furthermore, the evidence described herein demonstrates that LOPEZhas engaged in an ongoing pattern of drug trafficking for anextended period of time - as early as November <strong>20</strong><strong>11</strong> and as recentlyas March <strong>20</strong><strong>12</strong>. For example:53-a. On <strong>12</strong>/<strong>13</strong>/<strong>11</strong> at approximately <strong>11</strong>:40 a.m., TargetTelephone 1 called <strong>12</strong>5*<strong>13</strong>4*535, used by LOPEZ. LOPEZ told GAYTANthat he was “struggling” because he came to pick up some “sin-sin”and that “it” wasn’t “working” out too well. LOPEZ told GAYTANthat he was going by the “border” and asked GAYTAN if he shouldcome. GAYTAN told LOPEZ that “he” brought him “two pesos”yesterday and that on Friday or Saturday “he” would bring himanother “five.” LOPEZ told GAYTAN that he would stop by.-In this call, GAYTAN told LOPEZ to stop by the Vanowen AutoShop to pick up drug cash. Specifically, LOPEZ told GAYTAN that hewas “struggling,” meaning that the drug business was slow, becausehe came to pick up some “sin-sin,” or drugs, and that “it,” or thedrugs, wasn’t “working out,” meaning the drugs were of low quality.LOPEZ told GAYTAN that he was going by the “border,” or referringto entering the United States, and asked GAYTAN if he should come.GAYTAN told LOPEZ that “he” (a courier) brought him “two pesos,” or<strong>12</strong>2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728$2,000 in drug cash, yesterday and would bring him another “five”or $5,000 in drug cash. LOPEZ told GAYTAN that he would stop by.According to border crossing information, LOPEZ entered the UnitedStates from Mexico on <strong>12</strong>/<strong>13</strong>/<strong>11</strong> at approximately <strong>12</strong>:01 p.m.Furthermore, according to court-authorized GPS cell location data,LOPEZ then traveled to the Chula Vista Shop. Several minuteslater, LOPEZ traveled from the Chula Vista Shop to the Vanowen AutoShop and then back to the Chula Vista Shop. Based on the abovedescribed call and GPS cell phone location data, I believe thatLOPEZ picked up drug cash from GAYTAN at the Vanowen Auto Shop andthen stashed the drug cash at the Chula Vista Shop.54. Moonlight Residence. According to surveillance,wiretaps, utility records, escrow documents, and other evidence,this location is MURILLO’s and MILLAN’s primary residence.Furthermore, as described previously, MURILLO producesmethamphetamine and distributes drugs from the Moonlight Residence.Since March <strong>20</strong><strong>12</strong>, MURILLO has been followed to and observed at theMoonlight Residence on a regular basis, and MURILLO’s vehicles havebeen observed parked at the Moonlight Residence. MURILLO was seenat the residence as recently as 6/<strong>24</strong>/<strong>12</strong>, and his vehicles were seenat the residence during a spot check as recently as 8/1/<strong>12</strong>.Moreover, as described above and below, wiretap calls reveal thatMURILLO used his residence to store drugs and to facilitate hisdrug trafficking activity, and, therefore, evidence of theorganization’s trafficking activity will be found at this location.For example, wiretap intercepts have revealed the following:54-a. On 4/1/<strong>12</strong> at <strong>11</strong>:<strong>24</strong> a.m., Target Telephone 5 called661-3<strong>17</strong>-0735, used by PANCHO. MURILLO asked PANCHO if he wanted to<strong>12</strong>3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728take “two boxes” that he “had” up “there.” MURILLO told PANCHO tocall him later.-In this call, MURILLO asked PANCHO if he wanted to take “twoboxes,” or coded jargon for drugs, most likely kilograms ofcocaine, that he “had,” or had at the Moonlight Residence, up“there,” which I believe refers to the Moonlight Residence, forseveral reasons. First, during surveillance and according to GPScell phone location data, MURILLO resides at the MoonlightResidence. Secondly, based on other intercepted calls notdescribed here, MURILLO used code words to describe his otherresidences including the “Adelanto” house, or the CarroltonResidence, or the house on “<strong>17</strong>th” Street, or 38<strong>22</strong>7 <strong>17</strong>th St. East,which is another property owned by MURILLO that is not used fordrug operations.55. Moreover, it is likely that evidence of traffickingactivity, including drugs, drug records, and drug cash, are kept atthe Moonlight Residence because, based upon my training andexperience, traffickers keep such evidence within reach tofacilitate their trafficking activity. Furthermore, the evidencedescribed herein demonstrates that: (1) MURILLO has engaged in anongoing pattern of drug trafficking for an extended period of time– as early as December <strong>20</strong><strong>11</strong> and as recently as May <strong>20</strong><strong>12</strong>; and (2)MURILLO’s wife, MILLAN, has also engaged in narcotics traffickingactivity (see, for example, paragraph <strong>25</strong>-l). Moreover, given thelarge quantities of drugs seized on 3/<strong>18</strong>/<strong>12</strong> and 4/3/<strong>12</strong>, MURILLO’sprior drug convictions going back to <strong>19</strong>91, and dozens of otherintercepted calls revealing the scope of MURILLO’s drug traffickingactivities, including calls relating to drug distribution which<strong>12</strong>4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728took place between 3/<strong>12</strong>/<strong>12</strong> and 5/<strong>17</strong>/<strong>12</strong>, I believe that MURILLO hasbeen consistently involved in drug trafficking for an extensiveperiod of time, and evidence of such activity is likely to be foundat the Moonlight Residence.56. Carrolton Residence. According to surveillance,wiretaps, escrow documents, drug seizures, and other evidence, thisresidence is owned by MURILLO and is used as a stash house byIBARRA and MURILLO. IBARRA was seen at the residence as recentlyas 3/<strong>18</strong>/<strong>12</strong> and two vehicles that are registered to IBARRA were atthe residence during surveillance conducted on 8/1/<strong>12</strong>. Asdescribed in paragraph <strong>25</strong>-a through <strong>25</strong>-l, wiretap calls and thesubsequent drug seizure on 3/<strong>18</strong>/<strong>12</strong>, revealed that MURILLO andIBARRA used the Carrolton Residence to offload drugs smuggled fromMexico and to facilitate their drug trafficking activity.Accordingly, I have probable cause to believe that evidence of theorganization’s trafficking activity will still be found at thislocation. Moreover, even though law enforcement conducted a searchwarrant at the Carrolton Residence on 3/<strong>18</strong>/<strong>12</strong>, I believe that theCarrolton Residence is still being used by MURILLO and IBARRA toconduct drug operations. For example:56-a. On 5/3/<strong>12</strong>, at <strong>10</strong>:45 a.m., Target Telephone 9called 760-6<strong>17</strong>-79<strong>17</strong>, used by IBARRA. (I know this is IBARRA’sphone because he had this phone at the time of his arrest on3/<strong>18</strong>/<strong>12</strong>). MURILLO asked IBARRA if he wanted “two girls.” IBARRAtold MURILLO that he had “one” already and that there was a lot of“work.” MURILLO told IBARRA that he had to go look for the“people.” IBARRA told MURILLO that right now there was no“movement.” MURILLO told IBARRA that he “prepared two” already.<strong>12</strong>5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728IBARRA told MURILLO that he would take him the “rent” for the “one”he had “there” tomorrow.-In this call, MURILLO asked IBARRA if he wanted “two girls,”drug jargon for two units of crystal methamphetamine. IBARRA toldMURILLO that he had “one” already and that there was a lot of“work” (drugs). MURILLO told IBARRA that he had to go look for the“people,” or drug customers. IBARRA told MURILLO that right nowthere was no “movement,” or drug customers were not buying drugs.MURILLO told IBARRA that he “prepared two,” or produced two unitsof methamphetamine at the Moonlight Residence, already. IBARRAtold MURILLO that he would take him the “rent,” or drug payment,for the “one,” or one unit of drugs that MURILLO provided IBARRA,he had “there,” or the Carrolton Residence, tomorrow. I believethat “there” refers to the Carrolton Residence because as notedabove on 6/29/<strong>12</strong> and 8/1/<strong>12</strong>, IBARRA’s cars were parked at theCarrolton Residence. Furthermore, I believe that MURILLO producedthe two units of drugs at the Moonlight Residence for severalreasons. First, according to court-authorized GPS cell locationdata, at approximately <strong>10</strong>:31 a.m., MURILLO was located at theMoonlight Residence. Second, MURILLO has previously produced (orhad PANCHO produce) methamphetamine at the Moonlight Residence.57. Moreover, it is likely that evidence of traffickingactivity, including drugs, drug records, and drug cash, are kept atthe Carrolton Residence because, based upon my training andexperience, traffickers keep such evidence within reach tofacilitate their trafficking activity. Furthermore, the evidencedescribed herein demonstrates that (1) MURILLO and IBARRA haveengaged in an ongoing pattern of drug trafficking for an extended<strong>12</strong>6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728period of time - as early as December <strong>20</strong><strong>11</strong> and as recently as May<strong>20</strong><strong>12</strong>. Additionally, given the large quantities of drugs seized on3/<strong>18</strong>/<strong>12</strong> and 4/3/<strong>12</strong>, MURILLO’s prior drug convictions going back to<strong>19</strong>91, and dozens of other intercepted calls revealing the scope ofMURILLO’s drug trafficking activities, including calls relating todrug distribution which took place between 3/<strong>12</strong>/<strong>12</strong> and 5/<strong>17</strong>/<strong>12</strong>, Ibelieve that MURILLO has been consistently involved in drugtrafficking for an extensive period of time, and evidence of suchactivity is likely to be found at the Carrolton Residence.58. Ute Residence. According to wiretaps, utility records,court-authorized GPS cell location data, and other evidence, thislocation is GALARZA’s primary residence. Wiretap calls reveal thatGALARZA smuggles large quantities of cocaine and crystalmethamphetamine from Mexico into the United States and then storesthe drugs at the Ute Residence and the 5th Street Residence. Asdescribed above in paragraphs <strong>25</strong>-a through <strong>25</strong>-l, on 3/<strong>18</strong>/<strong>12</strong> wiretapcalls and GPS cell location data confirmed that GALARZA retrieved astash of smuggled drugs from both the Ute Residence and the 5thStreet Residence and then delivered the drugs to MURILLO. SinceMarch <strong>20</strong><strong>12</strong>, court-authorized GPS cell location data has confirmedthat GALARZA is at the Ute Residence on a regular basis andGALARZA’s vehicles have been observed parked at the Ute Residence.GALARZA’s Jeep, the same car that was used to deliver the seizeddrugs on 3/<strong>18</strong>/<strong>12</strong>, was seen at the residence during a spot check asrecently as 8/1/<strong>12</strong> and according to DMV records is registered tothe Ute Residence. Furthermore, GALARZA’s registered address onhis California driver’s license is the Ute Residence. The evidencedescribed in this affidavit demonstrates that GALARZA and FERNANDEZ<strong>12</strong>7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728have engaged in an ongoing pattern of drug trafficking despitemultiple drug seizures over the past several months and have usedand will continue to use the Ute Residence to facilitate drugtrafficking activity.59. Moreover, dozens of other intercepted calls have revealedthe scope of GALARZA’s and FERNANDEZ’s drug trafficking activities,often times including other family members who reside at the UteResidence and other locations, including calls relating to drugdistribution which took place between 3/<strong>18</strong>/<strong>12</strong> and 5/<strong>17</strong>/<strong>12</strong>. Ibelieve, for reasons set forth throughout this affidavit, thatGALARZA and FERNANDEZ have been consistently involved in drugtrafficking for an extensive period of time, and evidence of suchactivity is likely to be found at the Ute Residence, includingdrugs, drug cash, and other evidence that would help identify cars,methods, or other co-conspirators used to smuggle drugs into theUnited States. My belief is based on training, experience, andfamiliarity with this investigation. For example:59-a. On 4/29/<strong>12</strong> at 7:40 p.m., Target Telephone 8,used by “Sonia,” received a call from 3<strong>16</strong>0<strong>10</strong><strong>15</strong>49<strong>24</strong>261, used byGALARZA. GALARZA asked Sonia if the (unintelligible) was “there.”Sonia told GALARZA that “it” was in the garage. Sonia told GALARZAthat she put his “cars” in because “they” had been “playing” with“them” and “they” told her that the neighbor had gotten one of his“cars” recently. Sonia told GALARZA that she put “them” in theroom and put away the “controls.”-In this call, I believe that GALARZA confirmed withSonia that the drug cars were in the garage at the Ute Residence toavoid detection by law enforcement based on the drug seizures as<strong>12</strong>8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728described in paragraphs <strong>25</strong>-k through <strong>25</strong>-l and paragraph 30-f.Specifically, GALARZA asked Sonia if the (unintelligible) was“there,” or the Ute Residence. Sonia told GALARZA that “it,” orthe car used to deliver the seized drugs, was in the garage at theUte Residence. Sonia told GALARZA that she put his “cars” inbecause “they,” or unidentified drug associates, had been“playing,” or operating the hidden compartment used to transportdrugs, with “them,” or the drug cars, and “they,” or unidentifieddrug associates, told her that the neighbor had gotten one of his“cars,” or a car with a hidden compartment used to transport drugs,recently. Sonia told GALARZA that she put “them,” or drug cars, inthe room at the Ute Residence, and put away the “controls,” orcoded jargon for keys and devices used to operate the hiddencompartments. According to court-authorized GPS cell locationdata, at approximately 7:56 p.m., <strong>16</strong> minutes after the abovedescribed call, Target Telephone 8 was located at the UteResidence.60. 5th Street Residence. According to wiretaps, DMVrecords, court-authorized GPS cell location data, and otherevidence, this location is location used by FERNANDEZ and GALARZAfor drug operations. Cars registered to family members, includinga sister, G.F., have been observed at the 5th Street Residence asrecently as 8/1/<strong>12</strong>. Wiretap calls reveal that FERNANDEZ smuggleslarge quantities of cocaine and crystal methamphetamine from Mexicointo the United States and then stores the drugs at the UteResidence and the 5th Street Residence. As described above inparagraphs <strong>25</strong>-i through <strong>25</strong>-l, on 3/<strong>18</strong>/<strong>12</strong> wiretap calls and GPS celllocation data confirmed that GALARZA retrieved a stash of smuggled<strong>12</strong>9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728drugs from the Ute Residence and 5th Street Residence and thendelivered the drugs to MURILLO. Since March <strong>20</strong><strong>12</strong>, court-authorizedGPS cell location data has confirmed that FERNANDEZ frequented the5th Street Residence several times and that the Honda used tosmuggle the drugs into the United States on 3/<strong>18</strong>/<strong>12</strong>, as describedin paragraphs <strong>25</strong>-e through <strong>25</strong>-l, is registered to FERNANDEZ at the5th Street Residence. Furthermore, on immigration documents asrecently as 4/<strong>16</strong>/<strong>12</strong>, FERNANDEZ utilized the 5th Street Residence ashis primary address. The evidence described in this affidavitdemonstrates that GALARZA and FERNANDEZ have engaged in an ongoingpattern of drug trafficking despite multiple drug seizures over thepast several months and have used and will continue to use the 5thStreet Residence to facilitate their drug trafficking activity.Moreover, dozens of other intercepted calls have revealed the scopeof GALARZA’s and FERNANDEZ’s drug trafficking activities includingcalls relating to drug distribution which took place between3/<strong>18</strong>/<strong>12</strong> and 5/<strong>17</strong>/<strong>12</strong>. As explained in prior sections, I believethat GALARZA and FERNANDEZ have been consistently involved in drugtrafficking for an extensive period of time, and evidence of suchactivity is likely to be found at the 5th Street Residenceincluding drugs, drug cash, and other evidence that would helpidentify cars, methods, or other co-conspirators used to smuggledrugs into the United States. Moreover, even though FERNANDEZ andBOHON were arrested on 7/<strong>11</strong>/<strong>12</strong> attempting to smugglemethamphetamine into the United States, I still believe thatevidence of drug trafficking will be found at the 5th StreetResidence because GALARZA was not arrested and will continue to usethe 5th Street Residence for drug operations. Specifically, as<strong>13</strong>0


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728described in paragraphs <strong>25</strong>-c through <strong>25</strong>-g, GALARZA retrieved astash of drugs from the 5th Street Residence on 3/<strong>18</strong>/<strong>12</strong>.Accordingly, I believe that records of drug trafficking activity,to include “Pay & Owe” ledgers, vehicle records pertaining to loadvehicles, property records, and other evidence to identifyadditional co-conspirators and locations used for drug traffickingare likely to be found at the 5th Street Residence.61. Florida Residence. According to surveillance, wiretaps,and other evidence, this location is BOHON’s primary residence andserves as a stash location for FERNANDEZ, BOHON, and GALARZA aftersmuggling drugs from Mexico. BOHON was seen at the residence asrecently as 5/<strong>12</strong>/<strong>12</strong>, and his vehicles were seen at the residenceduring a spot check as recently as 8/2/<strong>12</strong>. Moreover, wiretap callsreveal that FERNANDEZ, BOHON, and GALARZA used the FloridaResidence to offload drugs smuggled from Mexico and to facilitatetheir drug trafficking activity. Accordingly, I have probablecause to believe that evidence of the organization’s traffickingactivity will be found at this location based on the informationcontained herein, including:61-a. On 4/<strong>22</strong>/<strong>12</strong> at 3:46 a.m., Target Telephone 8 called3340<strong>10</strong>00<strong>17</strong>4<strong>24</strong>45, used by MIGUEL. FERNANDEZ told MIGUEL that “he”“went” alone and that he spoke to the “guy,” and “he” is in “SanBernardino” right now. FERNANDEZ told MIGUEL that “he” alreadyspoke to “him.” FERNANDEZ told MIGUEL that it was the phone numberhis “buddy” gave him to deliver the “big boys.” FERNANDEZ toldMIGUEL that “it” would happen this morning. FERNANDEZ told MIGUELthat “he” has a house in “Imperial Beach” and that “he” left “it”“there” on the way over. FERNANDEZ told MIGUEL that “he” would be<strong>13</strong>1


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728delivering “it” to “Tigre.” FERNANDEZ told MIGUEL that when theyhave to go “up there” they leave “it” “there” and on the way backthey deliver “it.”-In this call, FERNANDEZ told MIGUEL that “he” (BOHON) “went,”or had smuggled a drug load across the border, and that he spoke tothe “guy” (drug customer) in San Bernardino. FERNANDEZ told MIGUELthat BOHON already spoke to he drug customer. FERNANDEZ toldMIGUEL that it was the phone number his “buddy,” or the drugcustomer, gave him to deliver the “big boys,” drug jargon forcocaine. FERNANDEZ told MIGUEL that “it” (the drug delivery) wouldhappen this morning. FERNANDEZ told MIGUEL that BOHON had a housein “Imperial Beach,” or the Florida Residence, and that BOHON left“it” (drug shipment) “there” (at the Florida Residence). FERNANDEZtold MIGUEL that BOHON would deliver the drugs to EL TIGRE.FERNANDEZ told MIGUEL that when they have to go “up there” (LosAngeles), they would leave the drug shipment “there” (at theFlorida Residence).61-b. On 4/<strong>22</strong>/<strong>12</strong> at 4:<strong>20</strong> a.m., Target Telephone 8received a call from 72*<strong>13</strong>4608*3, used by FNU LNU 3<strong>18</strong>. FERNANDEZtold FNU LNU 3<strong>18</strong> that he met up with the “guy,” and the “five guys”arrived. FERNANDEZ told FNU LNU 3<strong>18</strong> that “they” are headed back tothe “house” to get the “things” out. FERNANDEZ told FNU LNU 3<strong>18</strong>that he still needed to go to the house at “Ysidro” and deliver therest. FNU LNU 3<strong>18</strong> told FERNANDEZ that it was “four” and the “fivebig ones” for up “there.” FERNANDEZ told FNU LNU 3<strong>18</strong> that the“tomato ones” stayed down “there” and the “fish” went up “there.”-In this call, FERNANDEZ told FNU LNU 3<strong>18</strong> that he met up withthe “guy,” or drug customer, and the “five guys” (drug jargon for<strong>13</strong>2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728five kilograms of cocaine) had arrived. FERNANDEZ told FNU LNU 3<strong>18</strong>that “they” (FERNANDEZ and BOHON) were headed back to the “house,”(the Florida Residence) to get the “things” (drugs). FERNANDEZtold FNU LNU 3<strong>18</strong> that he still needed to go to the house at“Ysidro,” or San Ysidro, California, and deliver the rest. FNU LNU3<strong>18</strong> told FERNANDEZ that it was “four” (four units of crystalmethamphetamine) and “five big ones” (jargon for five kilograms ofcocaine), for up “there” (Los Angeles). FERNANDEZ told FNU LNU 3<strong>18</strong>that the “tomato ones” (jargon for crystal methamphetamine), stayeddown “there” (San Ysidro), and the “fish” (jargon for cocaine),went up “there” (Los Angeles area).61-c. On 4/29/<strong>12</strong> at 7:29 a.m., Target Telephone 8 called3<strong>16</strong>0<strong>10</strong><strong>15</strong>49539930, used by “Pancho” (“Pancho”). <strong>23</strong> Pancho askedFERNANDEZ where he was at. FERNANDEZ told Pancho he was in“Imperial.” Pancho asked FERNANDEZ how they could do “it” to meetup. FERNANDEZ told Pancho that he would wait for him. Pancho toldFERNANDEZ that he would get to “University” and will “pay” him.FERNANDEZ asked Pancho if he was coming. Pancho told FERNANDEZthat he was on his way. FERNANDEZ told Pancho to not have a “tail”on him.-In this call, Pancho asked FERNANDEZ where he was at.FERNANDEZ told Pancho he was in “Imperial” (the Florida Residence,which is located in Imperial Beach, California). Pancho askedFERNANDEZ how they could do “it,” or complete the drug cashdelivery, to meet up. FERNANDEZ told Pancho that he would wait forhim, or wait for him at the Florida Residence. Pancho told<strong>23</strong>Law enforcement believes this Pancho is a different individualthan MURILLO’s drug associate, PANCHO, discussed previously.<strong>13</strong>3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728FERNANDEZ that he would get to “University,” or an unspecifiedlocation, and will “pay” him, or give FERNANDEZ the drug cash.FERNANDEZ asked Pancho if he was coming. Pancho told FERNANDEZthat he was on his way. FERNANDEZ told Pancho to not have a “tail”on him, or coded jargon for being followed by law enforcement.62. The evidence described in this affidavit demonstratesthat FERNANDEZ, BOHON, and GALARZA have engaged in an ongoingpattern of drug trafficking despite multiple drug seizures over thepast several months and have continued to use the Florida Residenceto facilitate drug trafficking activity. Furthermore, because ofthe premises’ close proximity to the Mexican border, FERNANDEZ,BOHON, and GALARZA can smuggle drugs from Mexico into the UnitedStates and offload them at the Florida Residence quickly beforebeing detected by local law enforcement. Even though FERNANDEZ andBOHON were arrested on 7/<strong>11</strong>/<strong>12</strong> attempting to smugglemethamphetamine into the United States, I still believe thatevidence of drug trafficking will be found at the Florida Residencebecause GALARZA was not arrested and will continue to use theFlorida Residence for drug operations. Moreover, records of drugtrafficking, to include “Pay & Owe” ledgers, vehicle records,property records, or other evidence to help identify additionalco-conspirators and locations used for drug trafficking are likelyto be found at the Florida Residence. During his arrest, BOHONprovided the Florida Residence as his address and the F-<strong>25</strong>0 thatBOHON and FERNANDEZ were attempting to smuggle the drugs inside wasalso registered to the Florida Residence.63. Altadena Residence. According to surveillance, wiretaps,and other evidence, this location is RUIZ’s primary residence, and<strong>13</strong>4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728RUIZ uses this residence as a stash location. A vehicle registeredto “Ruiz’s Detailing and/or Adrian Ruiz” was seen at the residenceduring a spot check as recently as 7/<strong>13</strong>/<strong>12</strong>. Furthermore, between8/7/<strong>12</strong> and 8/9/<strong>12</strong>, agents parked a “drop car,” that is, a carequipped with surveillance equipment, on a public street near theAltadena Residence. Through this surveillance, agents observedRUIZ and a vehicle driven by RUIZ at the Altadena Residence asrecently as 8/8/<strong>12</strong>. Additionally, as described previously, wiretapcalls confirmed that BOHON picked up drug cash from the AltadenaResidence on 4/<strong>22</strong>/<strong>12</strong>. Moreover, as described above in paragraph44-h, wiretap calls and surveillance confirmed that on 4/26/<strong>12</strong>BOHON delivered a drug load to RUIZ at the Altadena Residence. Ibelieve that evidence of the organization’s trafficking activitywill be found at this location, including drugs, drug records, anddrug cash.64. Taco Shop. According to surveillance, wiretaps, andother evidence, this location is RIOS’s restaurant, and RIOS usesthis business as a stash location. A vehicle registered to RIOSand his home residence was seen at the residence during a spotcheck as recently as 8/1/<strong>12</strong>. Additionally, as described inparagraphs 38-a through 38-c, wiretap calls confirmed that RIOSpicked up a cocaine shipment from the Taco Shop and delivered it toGAYTAN at the Vanowen Auto Shop on <strong>12</strong>/<strong>12</strong>/<strong>11</strong>. In light of RIOS’scontinuous involving in drug trafficking and the facts set forththroughout this affidavit, I believe that evidence of theorganization’s trafficking activity will be found at this location,including drugs, drug records, drug cash, or other evidence thatwould assist investigators in identifying other co-conspirators.<strong>13</strong>5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728VINEED FOR SEARCH WARRANTS65. It is highly probable that the records and items soughtwill provide evidence corroborating the information set forth aboveand implicating other persons who should be arrested and chargedwith drug trafficking and related crimes. Based upon my trainingand experience, and my conversations with experienced narcoticsinvestigators involved in this investigation, I know that:65-a. Drug traffickers use various locations to servedifferent functions so that customers, thieves, and law enforcementpersonnel do not learn about any one location where largequantities of cocaine, money, and/or other drug related assets arestored. Therefore, one or more locations are often used to storelesser amounts of narcotics, money, and/or drug related assets, andadditional locations are used to meet customers and/or are used assafe houses;65-b. Persons involved in large-scale drug traffickingorganizations conceal, in various locations, caches of drugs, drugparaphernalia, amounts of jewelry, automobiles, automobile titles,deeds to property, and other items of value and/or proceeds of drugtransactions and evidence of financial transactions relating toobtaining, transferring, secreting or spending large sums of moneyacquired from engaging in narcotics trafficking activities;65-c. Drug traffickers store and maintain at theirlocations, including the residences where they live and/or “stashhouses,” money ledgers, narcotics supplier lists, correspondence,notations, logs, receipts, journals, books, records and otherdocuments noting the price, quantity, and/or times when narcotics<strong>13</strong>6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728were obtained, transferred, sold, distributed, and/or concealed.Drug traffickers also maintain drug paraphernalia such as “cutting”materials, weighing devices, miscellaneous containers, andmeasuring devices, which are used to facilitate the distribution ofnarcotics. Additionally, traffickers frequently possess DMVregistration and ownership records of “load cars” used to transportnarcotics. These items are maintained and kept by the narcoticstrafficker in much the same way legitimate profit-orientedbusinesses will maintain their “tools of the trade” and/or businessrecords, whether or not there is contraband on the premises on agiven day;65-d. When drug traffickers amass large quantities ofcash from the sale of drugs, the drug traffickers often attempt totransfer and/or legitimize these profits through the use of banksand financial institutions and their attendant services thatinclude accounts, securities, traveler’s checks, cashier’s checks,money orders, wire transfers, stock certificates, bonds,certificates of deposit, and safety deposit boxes. These assets,and financial records concerning such assets, are often stored atsafe houses and/or residences that drug traffickers frequent andhave access to;65-e. Drug traffickers often place assets in the namesof relatives and close friends in order to avoid detection and/orseizure of those assets by law enforcement agencies. However, eventhough these assets may be placed in other persons’ names, the drugdealers retain records, documents, and deeds reflecting thepurchase of those assets while continuing to use those assets andexercise dominion and control over them;<strong>13</strong>7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272865-f. It is common practice for large-scale narcotictraffickers to travel to their purchase and distribution areas tofacilitate their trafficking operations. After purchasing drugs,narcotic traffickers will transport or cause to be transporteddrugs, including cocaine and methamphetamine, to areas in whichthey will distribute the drugs to customers. Known methods oftransportation include commercial airlines, private airplanes,trains, rental and private automobiles, and government and contractmail carriers, and records of such transportation methods are oftenfound at traffickers’ residences and/or stash locations;65-g. As described throughout this affidavit, thesubjects of the investigation extensively used cellular telephonesto facilitate their drug trafficking activity. Drug traffickersfrequently use telephones, portable cellular telephones, SIM cards,pagers and other communication devices and maintain telephone andaddress books, telephone bills, and other books and papers, whichreflect names, addresses, and/or telephone numbers of theirassociates in the narcotic trafficking organization and customersof narcotics;65-h. Drug traffickers often times take or cause to betaken photographs of themselves, their associates, their propertyand their product; and these traffickers usually maintain thesephotographs at their premises where the photographs can be safelyconcealed and where access can be limited to only trustedrelatives, friends, and associates;65-i. Drug traffickers commonly have in theirpossession, that is, on their persons, at their residences, and/orat their stash houses, firearms, including handguns, pistols,<strong>13</strong>8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728revolvers, rifles, shotguns, machine guns and other weapons, thatare used to protect and secure the drug traffickers’ property,including narcotics, narcotic paraphernalia, currency, jewelry, andrecords.Review of Computer Media66. Based upon my experience conducting drug traffickinginvestigations and financial crime (e.g., money laundering)investigations, I know that computers and other electronicequipment, including cell phones, are often used to maintaincommunications pertaining to, and records of, drug traffickers’legal and illegal businesses. Based upon my training, experience,and information related to me by agents and others involved in theforensic examination of computers, I know that computer data can bestored on a variety of systems and storage devices including harddisk drives, floppy disks, compact disks, magnetic tapes, andmemory chips. I also know that during the search of the premisesit is not always possible to search computer equipment and storagedevices for data for a number of reasons, including the following:66-a. Searching digital devices can be a highlytechnical process that requires specific expertise and specializedequipment. There are so many types of digital devices and softwarein use today that it is impossible to bring to the search site allof the necessary technical manuals and specialized equipmentnecessary to conduct a thorough search. In addition, it may alsobe necessary to consult with specially trained personnel who havespecific expertise in the type of digital device, softwareapplication, or operating system that is being searched.<strong>13</strong>9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272866-b. Searching digital devices can require the use ofprecise, scientific procedures that are designed to maintain theintegrity of the evidence and to recover “hidden,” erased,compressed, encrypted, or password-protected data. Digital devicesmay contain “booby traps” that destroy or alter data if certainprocedures are not scrupulously followed. Since digital data isparticularly vulnerable to inadvertent or intentional modificationor destruction, a controlled environment, such as a law enforcementlaboratory, is essential to conducting a complete and accurateanalysis of the digital devices from which the data will beextracted.66-c. The volume of data stored on many digital deviceswill typically be so large that it will be highly impractical tosearch for data during the execution of the physical search of thepremises. A single megabyte of storage space is the equivalent of500 double-spaced pages of text. A single gigabyte of storagespace, or 1,000 megabytes, is the equivalent of 500,000 doublespacedpages of text. Storage devices capable of storing 500gigabytes (GB) of data are now commonplace in desktop computers.Consequently, each non-networked, desktop computer found during asearch can easily contain the equivalent of <strong>24</strong>0 million pages ofdata, that, if printed out, would completely fill three 35' x 35' x<strong>10</strong>' rooms to the ceiling. Further, a 500 GB drive could contain asmany as approximately 450 full run movies or 450,000 songs.66-d. Electronic files or remnants of such files can berecovered months or even years after they have been downloaded ontoa hard drive, deleted or viewed via the Internet. Electronic filessaved to a hard drive can be stored for years with little or no<strong>14</strong>0


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728cost. Even when such files have been deleted, they can berecovered months or years later using readily-available forensicstools. Normally, when a person deletes a file on a computer, thedata contained in the file does not actually disappear; rather,that data remains on the hard drive until it is overwritten by newdata. Therefore, deleted files, or remnants of deleted files, mayreside in free space or slack space, i.e., space on the hard drivethat is not allocated to an active file or that is unused after afile has been allocated to a set block of storage space for longperiods of time before they are overwritten. In addition, acomputer’s operating system may also keep a record of deleted datain a swap or recovery file. Similarly, files that have been viewedvia the Internet are automatically downloaded into a temporaryInternet directory or cache. The browser typically maintains afixed amount of hard drive space devoted to these files, and thefiles are only overwritten as they are replaced with more recentlyviewed Internet pages. Thus, the ability to retrieve residue of anelectronic file from a hard drive depends less on when the file wasdownloaded or viewed than on a particular user’s operating system,storage capacity, and computer habits. Recovery of residue ofelectronic files from a hard drive requires specialized tools and acontrolled laboratory environment.66-e. Although some of the records called for by thiswarrant might be found in the form of user-generated documents(such as word processor, picture, and movie files), digital devicescan contain other forms of electronic evidence as well. Inparticular, records of how a digital device has been used, what ithas been used for, who has used it, and who has been responsible<strong>14</strong>1


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728for creating or maintaining records, documents, programs,applications and materials contained on the digital devices are, asdescribed further in the attachments, called for by this warrant.Those records will not always be found in digital data that isneatly segregable from the hard drive image as a whole. Digitaldata on the hard drive not currently associated with any file canprovide evidence of a file that was once on the hard drive but hassince been deleted or edited, or of a deleted portion of a file(such as a paragraph that has been deleted from a word processingfile). Virtual memory paging systems can leave digital data on thehard drive that show what tasks and processes on the computer wererecently used. Web browsers, e-mail programs, and chat programsstore configuration data on the hard drive that can revealinformation such as online nicknames and passwords. Operatingsystems can record additional data, such as the attachment ofperipherals, the attachment of USB flash storage devices, and thetimes the computer was in use. Computer file systems can recorddata about the dates files were created and the sequence in whichthey were created. This data can be evidence of a crime, indicatethe identity of the user of the digital device, or point toward theexistence of evidence in other locations. Recovery of this datarequires specialized tools and a controlled laboratory environment.66-f. Further, evidence of how a digital device has beenused, what it has been used for, and who has used it, may be theabsence of particular data on a digital device. For example, torebut a claim that the owner of a digital device was notresponsible for a particular use because the device was beingcontrolled remotely by malicious software, it may be necessary to<strong>14</strong>2


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728show that malicious software that allows someone else to controlthe digital device remotely is not present on the digital device.Evidence of the absence of particular data on a digital device isnot segregable from the digital device. Analysis of the digitaldevice as a whole to demonstrate the absence of particular datarequires specialized tools and a controlled laboratory environment.66-g. Digital device users can attempt to conceal datawithin digital devices through a number of methods, including theuse of innocuous or misleading filenames and extensions. Forexample, files with the extension “.jpg” often are image files;however, a user can easily change the extension to “.txt” toconceal the image and make it appear that the file contains text.Digital device users can also attempt to conceal data by usingencryption, which means that a password or device, such as a“dongle” or “keycard,” is necessary to decrypt the data intoreadable form. In addition, digital device users can conceal datawithin another seemingly unrelated and innocuous file in a processcalled “steganography.” For example, by using steganography adigital device user can conceal text in an image file that cannotbe viewed when the image file is opened. Therefore, a substantialamount of time is necessary to extract and sort through data thatis concealed or encrypted to determine whether it is evidence,contraband, or an instrumentality of a crime.66-h. Other than what has been described herein, to myknowledge the United States has not attempted to obtain this databy other means.<strong>14</strong>3


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728VIIITEMS TO BE SEIZED67. Based on the foregoing, I respectfully submit that thereis probable cause to believe that the following items, whichconstitute evidence and/or instrumentalities of violations of <strong>21</strong>U.S.C. §§ 846, 843(b), 841(a)(1), 963, 960 and 952(a), will befound at the locations and vehicles identified above:A. Drug-Related Evidence67-a. Controlled substances including cocaine,methamphetamine, heroin, and residue or precursor chemicals of saidcontrolled substances; paraphernalia associated with controlledsubstances including scales, measuring devices, and weighingdevices;67-b. Diluting or cutting agents used to dilute or cutcontrolled substances;67-c. Packaging or manufacturing materials includingwrappers, plastics, tin foil, cellophane, jars, plastic bags,strings, balloons and containers used to conceal, manufacture orpackage controlled substances and chemicals used to manufacturecontrolled substances;67-d. Load vehicles, hidden compartments, containersincluding boxes, bags, briefcases, suitcases, or containers whichcould be used to carry controlled substances, currency, andchemicals used to manufacture controlled substances;67-e. Quantities of currency derived from the sale ofcontrolled substances and chemicals used to manufacture controlledsubstances;<strong>14</strong>4


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272867-f. Money counting machines, money wrappers, andrubber bands;67-g. Bank account records, wire transfer records, bankstatements, safe deposit box keys and records, money containers,financial records and notes showing payment, receipt, concealment,transfer, or movement of money generated from the sale ofcontrolled substances or chemicals used to manufacture controlledsubstances;67-h. Drug or money ledgers, drug distribution orcustomer lists, drug supplier lists, correspondence, notations,logs, receipts, journals, books, records and other documents notingthe price, quantity, and/or times when controlled substances orchemicals used to manufacture controlled substances were obtained,transferred, sold, distributed, and/or concealed;67-i. Personal telephone books, address books, telephonebills, photographs, letters, cables, telegrams, facsimiles,personal notes, documents and other items or records reflectingnames, addresses, telephone numbers, addresses and communicationsregarding illegal activities among and between members andassociates involved in drug trafficking activities;67-j. Documents and deeds reflecting the purchase orlease of real estate, vehicles, precious metals, jewelry, or otheritems obtained with the proceeds of drug trafficking activities;67-k. Records of off-site locations to store items andrecords, including safe deposit box keys, records and receipts andrental agreements for storage facilities;67-l. Records of mail and communications services,telephone pagers, answering machines, telephone paging devices,<strong>14</strong>5


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728beepers, car telephones, cellular telephones, and othercommunication devices which containing evidence of an individual’sparticipation in drug trafficking activity;67-m. Records, items, and documents reflecting travelfor the purpose of participating in drug trafficking activities,including passports, border crossing documents, airline tickets,vehicle rental receipts, DMV registration and ownership records,credit card receipts, hotel and restaurant receipts, cancelledchecks, and maps and records of long distance calls reflectingdomestic and foreign travel;67-n. Firearms including pistols, handguns, shotguns,rifles, assault weapons, machine guns, magazines used to holdammunition silencers, components of firearms including componentsor tools which can be used to modify firearms, ammunition andammunition components including gunpowder, primers, bullets,shells, wads, shot, and the tools used for the manufacture ofammunition including reloading devices, dies, scales, books,pamphlets and documentation, which may be used to facilitate moneylaundering and drug trafficking activities;67-o. Indicia of occupancy, residency or ownership ofthe premises and things described in the warrant, including utilitybills, telephone bills, loan payment receipts, rent receipts, trustdeeds, lease of rental agreements, addressed envelopes, and escrowdocuments and keys;67-p. Mementos including photographs, videos, and otherhistorical keepsake items which document or demonstrate theassociation of the individuals involved in drug trafficking and/orthe possession of contraband; and<strong>14</strong>6


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272867-q. With respect to any digital devices containingevidence falling within the scope of the foregoing searchcategories, records, documents, programs, applications ormaterials, or evidence of the absence of same, sufficient to showthe actual user(s) of the digital device during the time periodbetween January <strong>20</strong><strong>11</strong> and August <strong>22</strong>, <strong>20</strong><strong>12</strong>.B. Handling of Computer-related Evidence68. As used above, the terms records, documents, programs,applications, or materials include records, documents, programs,applications or materials created, modified, or stored in any form,including in digital form on any digital device. As used bothabove and below, the term “digital device” includes any electronicsystem or device capable of storing and/or processing data indigital form, including: central processing units; laptop ornotebook computers; personal digital assistants; wirelesscommunication devices such as telephone paging devices, beepers,and mobile telephones; SIM cards; peripheral input/output devicessuch as keyboards, printers, scanners, plotters, monitors, anddrives intended for removable media; related communications devicessuch as modems, cables, and connections; storage media such as harddisk drives, floppy disks, compact disks, magnetic tapes used tostore digital data (excluding analog tapes such as VHS), and memorychips; and security devices.69. In searching digital data stored on digital devices, lawenforcement personnel executing this search warrant will employ thefollowing procedures:69-a. Law enforcement personnel or otherindividuals assisting law enforcement personnel will, in their<strong>14</strong>7


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728discretion, either search the digital device(s) on-site or seizeand transport the device(s) to an appropriate law enforcementlaboratory or similar facility to be searched at that location.The team of law enforcement personnel, which may include theinvestigating agent(s), and/or individuals assisting lawenforcement personnel searching the digital device(s) shallcomplete the search as soon as is practicable but not to exceed 60days from the date of the execution of the warrant. If additionaltime is needed, the government may seek an extension of this timeperiod from the Court within the original 60 day period from thedate of execution of the warrant.69-b. The team searching the digital devices willdo so only by using search protocols specifically chosen toidentify only the specific items to be seized under this warrant.69-b(i). The team may subject all of the datacontained in the digital device capable of containing items to beseized as specified in this warrant to the protocols to determinewhether the digital device and any data falls within the items tobe seized as set forth herein. The team searching the digitaldevice may also search for and attempt to recover “deleted,”“hidden” or encrypted data to determine, pursuant to the protocols,whether the data falls within the list of items to be seized as setforth herein.69-b(ii). The team searching the digitaldevice also may use tools to exclude normal operating system filesand standard third-party software that do not need to be searched.69-c. When searching a digital device pursuant tothe specific protocols selected, the team searching the digital<strong>14</strong>8


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728device shall make and retain notes regarding how the search wasconducted pursuant to the selected protocols.69-d. If the team searching a digital devicepursuant to the selected protocols encounters immediately apparentcontraband or other evidence of a crime outside the scope of theitems to be seized, the team shall immediately discontinue itssearch of that digital device pending further order of Court andshall make and retain notes detailing how the contraband or otherevidence of a crime was encountered, including how it wasimmediately apparent contraband or evidence of a crime.69-e. If the search determines that a digitaldevice does not contain any data falling within the list of itemsto be seized pursuant to this warrant, the government will as soonas practicable return the device and delete or destroy all theforensic copies thereof.69-f. If the search determines that the digitaldevice does contain data falling within the list of the items to beseized pursuant to this warrant, the government will either (I)within the time period authorized by the Court for completing thesearch, return to the Court for an order authorizing retention ofthe digital device; or (ii) retain only a copy of the data found tofall within the list of the items to be seized pursuant to thiswarrant and return the digital device and delete or destroy all theforensic copies thereof.70. In order to search for data that is capable of being reador interpreted by a digital device, law enforcement personnel areauthorized to seize the following items, subject to the proceduresset forth above:<strong>14</strong>9


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>26272870-a. Any digital device capable of being used tocommit, further or store evidence of the offense listed above;70-b. Any equipment used to facilitate thetransmission, creation, display, encoding or storage of digitaldata, including word processing equipment, modems, dockingstations, monitors, printers, plotters, encryption devices andoptical scanners;70-c. Any magnetic, electronic or optical storagedevice capable of storing data, such as floppy disks, hard disks,tapes, CD-ROMs, CD-R, CD-RWs, DVDs, optical disks, printer ormemory buffers, smart cards, PC cards, memory calculators,electronic dialers, electronic notebooks, cellular telephones, SIMcards, and personal digital assistants;70-d. Any documentation, operating logs andreference manuals regarding the operation of the digital device orsoftware used in the digital device;70-e. Any applications, utility programs,compilers, interpreters and other software used to facilitatedirect or indirect communication with the digital device;70-f. Any physical keys, encryption devices,dongles and similar physical items that are necessary to gainaccess to the digital device or data stored on the digital device;and70-g. Any passwords, password files, test keys,encryption codes or other information necessary to access thedigital device or data stored on the digital device.71. The special procedures relating to digital media found inthis warrant govern only the search of digital media pursuant to<strong>15</strong>0


<strong>12</strong>3456789<strong>10</strong><strong>11</strong><strong>12</strong><strong>13</strong><strong>14</strong><strong>15</strong><strong>16</strong><strong>17</strong><strong>18</strong><strong>19</strong><strong>20</strong>2<strong>12</strong><strong>22</strong>3<strong>24</strong><strong>25</strong>262728the authority conferred by this warrant and do not apply to anysearch of digital media pursuant to any other court order.72. Digital devices to be searched include computers, anymagnetic, electronic or optical storage device capable of storingdata, such as floppy disks, hard disks, tapes, CD-ROMs, CD-R, CD-RWs, DVDs, optical disks, printer or memory buffers, smart cards,SIM cards, PC cards, memory calculators, electronic dialers,electronic notebooks, cellular telephones and personal digitalassistants.VIIICONCLUSION73. Based upon the facts herein and my training andexperience, I believe there is probable cause to arrest thedefendants for conspiracy to distribute controlled substances, inviolation of <strong>21</strong> U.S.C. § 846.73. Furthermore, based upon the facts herein and my trainingand experience, I believe there is probable cause to search theSUBJECT PREMISES described in Attachment A for the items describedin Attachment B, which attachments are both incorporated herein,and to believe that the fruits, instrumentalities, and evidence ofviolations described herein will be found on the premises to besearched.Dated: ___________________Sworn to and subscribed to before me on_____________, <strong>20</strong><strong>12</strong>._________________________________UNITED STATES MAGISTRATE JUDGE________________________________Clinton LindslySpecial AgentHomeland Security Investigations<strong>15</strong>1

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!