11.1: 23 PH 3' 53 5 meme: ceua?t MM UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF 5 September 2016 Grand Ju UNITED STATES OF AMERICA, Plaintiff, V. JIMMY JOSUE MARTINEZ (1), aka Motas, MARIO ALBERTO (2), aka Cifre, HENRY IRENIO PULIDO (3), ALEJANDRO GUZMAN (4), aka Pollo, NARCISO ZAMORA BANUELOS (5), aka Chi Chi, ADAN ESTEBAN SANCHEZ AGUIRRE (6), aka Guerito, SALVADOR ISAY CASTILLO (7), aka Guero, REYNALDO RODRIGUEZ (8), aka Edwin, aka Ed?Rod, SEBASTIAN PONCE (9), Defendants. The grand jury charges: AJGA: :nlv: San Diego 5/23/17 176R1314JAH ENQECTMENT Case No. Title 8, U.S.C., Sec. 371 Conspiracy; Title 18, U.S.C., Secs. 982(a)(5) and 982(b) Criminal Forfeiture Count 1 18 U.S.C. 371 CONSPIRACY 1. The Hooligans Club, based. in. Tijuana, Mexico, consisted of riders who regularly traveled between.the United States and Mexico. Members of the Hooligans Club known as Hooligans held a weekly meeting in Tijuana during which, among other things, they engaged in group riding. 2. Defendants JIMMY JOSUE MARTINEZ, aka Motas, MARIO ALBERTO aka Cifre, HENRY IRENIO PULIDO, ALEJANDRO GUZMAN, aka P0110, NARCISO ZAMORA BANUELOS, aka Chi Chi, ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, aka Guero, REYNALDO RODRIGUEZ, aka Edwin, aka Ed?Rod, and SEBASTIAN PONCE, among others, were members of the Hooligans club and operated their club as a transnational criminal organization involved in various criminal activities, including vehicle thefts. 3. Beginning on a date unknown, but no later than January 2014, and continuing through the date of this Indictment, within the Southern District of California and elsewhere, defendants JIMMY JOSUE MARTINEZ, aka Motas, MARIO ALBERTO ECHEVERRIA-IBARRA, aka Cifre, HENRY IRENIO PULIDO, ALEJANDRO GUZMAN, aka P0110, NARCISO BANUELOS, aka Chi Chi, ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, aka Guero, REYNALDO RODRIGUEZ, aka Edwin, aka Ed?Rod, and SEBASTIAN PONCE knowingly and intentionally conspired and agreed with each other, and with persons known and unknown to the grand jury, to commit an offense against the United States - to wit, transportation of stolen vehicles in foreign commerce, in violation of Title 18, United States Code, Section 2312. METHODS AND MEANS 4. In furtherance of this conspiracy, and to? accomplish its object, the following manners and means were used, among others: a. The defendants stole vehicles and Jeep Wranglers within the Southern District of California and transported them to Mexico. b. The defendants organized themselves into various theft crews. Each defendant was a member of at least one theft crew and acted in at least one of the following roles: leader; thief; transporter; scout; or key cutter. c. The defendants would follOW'a'multi?step process to steal and transport i. First, scouts would travel throughout the Southern District of California to identify to steal. Scouts would locate in the parking structures and parking garages of apartment complexes and shopping centers, among other places.' ii. Second, thieves would turn on the without a key by bypassing the ignition switch. Third, transporters would drive the stolen to Mexico without' the knowledge or permission of the vehicles? lawful owners. iv. Fourth, leaders would sell or Otherwise dispose of the stolen Leaders would. pay - either directly' or indirectly the other individuals who participated in the theft and transportation of the d. The defendants would follow a similar multi-step process to steal and transport Jeep Wranglers: First, scouts would travel throughout the Southern District of California to identify Jeep Wranglers to steal. Upon identifying a Jeep Wrangler, scouts would obtain the vehicle Identification Number (VIN) from the dashboard or the secondary VIN location. ii. Second, scouts would send the VIN to leaders, who in turn, would send the VIN to key cutters. Key cutters would, without authorization, access a proprietary database containing codes used to create and program duplicate keys for Jeep Wranglers. Key cutters would obtain two codes for the Jeep Wrangler targeted by scouts. Key cutters would use one of the codes to create a duplicate key for the targeted Jeep Wrangler. Key cutters would provide the duplicate key to leaders along with the second code, which thieves would need in order to program the microchip within the key at the time of the theft. Leaders would provide the duplicate key to thieves or transporters. Third, thieves and transporters would return to the targeted Jeep Wrangler with the key and the programming code and would disable certain features of the Jeep Wrangler?s alarm system, including the horn and emergency flashers. Thieves would use the duplicate key to access the Jeep Wrangler's passenger compartment and would then use a handheld key programmer and the code received from the key cutters to program the duplicate key to the Jeep Wrangler. iv. Fourth, thieves would exit the Jeep Wrangler's passenger compartment and the transporters would drive the Jeep_Wrangler to Tijuana, Mexico without the knowledge or permission of the vehicle?s lawful owner. v. Fifth, leaders would sell or otherwise dispose of the. stolen Jeep Wranglers. Leaders would pay either directly or 4 indirectly - the other individuals who participated in the theft and transportation of the Jeep Wranglers. e. At various times, defendants JIMMY JOSUE MARTINEZ, aka Motas, and MARIO ALBERTO ECHEVERRIA-IBARRA, aka Cifre, acted as leaders of theft crews. I f. The defendants stole or attempted to steal approximately 28 vehicles worth approximately $800,000. ACTS 5. In furtherance of this conspiracy, and to carry'out its object, the following' overt. acts, among' others, were committed. within. the Southern District of California and elsewhere: a. On or about January 14, 2014, defendants JIMMY JOSUE MARTINEZ, aka Motas, and NARCISO ZAMORA BANUELOS, aka Chi Chi, communicated via Facebook about obtaining a key for a 2007 Jeep Wrangler with a VIN ending in ?8776. b. On _or about January 15, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler with a VIN ending in ?8776 located in Pacific Beach, San Diego. c. On or about January 19, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler with a VIN ending in -4578 located near Serra Mesa, San Diego. d. On or about February 12, 2014, defendant .ALEJANDRO GUZMAN, aka Pollo, attempted to steal a 2012 Suzuki GSXR-750 located in Chula Vista. e. On or about March 20, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler with a VIN ending in -1405 located in Chula Vista. about April 2, 2014, defendant JIMMY MARTINEZ, aka Motas, participated in the theft of a 2014 Jeep Wrangler with a VIN ending in ?4496 located in Mission Valley, San Diego. g. On or about May 2, 2014, defendant ALEJANDRO GUZMAN, aka Pollo, stole a 2014 Suzuki with a VIN ending in ?2020 located in Mira Mesa, San Diego. h. On or about May 2, 2014, defendant ALEJANDRO GUZMAN, aka Pollo,.transported a 2014 Suzuki with a VIN ending in ~2020 to Mexico. 1. On or about June 10, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2008 Jeep Wrangler with a VIN ending in ?0879 located in Ocean Beach, San Diego. j. On or about July 30, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler with a VIN ending in -4548 located in Mission Valley, San Diego. k. On or about August 5, 2014, defendants ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, and ALEJANDRO GUZMAN, aka Pollo, communicated via Facebook about stealing a Suzuki GSXR 1. On or about August 24, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2012 Jeep Wrangler with a VIN ending in ?2791 located in Vista. m. On or about September 13, 2014, defendant JIMMY JOSUE MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler with a VIN ending in ?3692 located in University Heights, San Diego. n. On or about September 18, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2008 Jeep Wrangler with a VIN ending in ?5185 located in Vista. about September 20, 2014, defendants JIMMY JOSUE MARTINEZ, aka Motas, and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, participated in the theft of a 2013 Jeep Wrangler with a VIN ending in -9587 located in Pacific Beach, San Diego. p. On or about September 20, 2014, defendants JIMMY JOSUE MARTINEZ, aka.MotaS, and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, participated in the theft of a 2007 Jeep Wrangler with a VIN ending in ?1018 located in Pacific Beach, San Diego. q. On or about September 30, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2009 Jeep Wrangler with a VIN ending in -6025 located in Ocean View Hills, San Diego. r. On. or? about. October 3, 2014, defendants JOSUE MARTINEZ, aka Motas, and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, participated in the theft of a 2014 Jeep Wrangler with a VIN ending in ?8266 located in Hillcrest, San Diego. 3. (M1 or about October 3, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2011 Jeep Wrangler with a VIN ending in ?8006 located in Point Loma, San Diego. t. On or about October 16, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2009 Jeep Wrangler VIN ending in -9465 located in Ocean Beach, San Diego. u. (M1 or about October 22, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2013 Jeep Wrangler VIN ending in ?9106 located in Scripps Ranch, San Diego. v. On. or' about October 25, 2014, defendant JOSUE MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler VIN ending in -7511 located in Escondido. 7 about October 28, 2014, defendants JIMMY JOSUE MARTINEZ, aka Mbtas, and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, participated in the theft of a 2014 Jeep Wrangler VIN ending in -0624 located in North Park, San Diego. x. On or about November 5, 2014, defendant NARCISO ZAMORA BANUELOS, aka Chi Chi, attempted.to steal a 2008 Jeep Wrangler VIN ending ?in -6353 located in Otay Mesa West, San Diego. y. On or about November 10, 2014, defendant MARIO ALBERTO ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2013 Jeep Wrangler VIN ending in -7638 located in Lake Murray, San Diego. 2. On or about November 13, 2014, defendants JIMMY JOSUE MARTINEZ, aka Motas, and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, participated in the theft of a 2014 Jeep Wrangler VIN ending in ?8256 located in Mira Mesa, San Diego. aa. On or about November 18, 2014, defendant MARIO ALBERTO aka Cifre, participated in the theft of a 2014 Jeep Wrangler VIN ending in,-5094 located in Grantville, San Diego.- bb. On or about November 20, 2014, defendant MARIO ALBERTO ECHEVERRIA-IBARRA, aka Cifre, attempted to steal a 2007 Jeep Wrangler VIN ending in ~0985 located in Golden Hill, San Diego. cc. On or about February 19, 2015, defendant REYNALDO RODRIGUEZ, aka Edwin, aka Ed?Rod, participated in the theft of a 2007 Jeep Wrangler VIN ending in -2988 located in Spring'Valley. 1about April 4, 2015, defendant ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, and co?conspirator J.C. communicated via Facebook about a group 'of Hooligans planning to steal multiple vehicles. Anticipating the response to the thefts, SANCHEZ wrote: ?They're going to say ?damn hooligans.?? J.C. responded: ?We?re a plague. They can?t finish us off, dude.? SANCHEZ responded: ?Mexico vs usa.? ee. On or about May 22, 2015, defendant SEBASTIAN PONCE participated in the theft of a 2010 Honda CBR1000 with VIN ending in -0037 located on the San Diego State University campus. ff. On or about June 13, 2015, defendant ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, wrote to co?conspirator J.C. via Facebook: ?What?s up, dog? .All you do is Steal from the Americans. ?You've already cleaned those poor people up.? J.C. responded: ?They don?t leave me anything outside anymore. Only garage. I have to go around jumping fences and walls.? SANCHEZ responded: ?Hahaha, even with that they can?t stop us.? gg. On or about June 19, 2015, defendant SEBASTIAN PONCE participated in the theft-of a 2012 Kawasaki Ninja with VIN ending in -5562 located in La Mesa. hh. On or about June 28, 2015, defendants IRENIO PULIDO, and SALVADOR ISAY CASTILLO, aka Guero, attempted to transport a stolen Honda CBR 600RR and a stolen Yamaha YZF-RI to Mexico, with VINs ending in ?0031 and ?3133, respectively.- ii. On or about November 18, 2015, defendants MARIO ALBERTO aka Cifre, and SEBASTIAN PONCE communicated. via Facebook about paying another individual to assist in stealing a vehicle. All in violation of Title 18, United States Code, Section 371. FORFEITURE ALLEGATIONS 12. The allegations contained in Count 1 of this Indictment are re?alleged and incorporated by reference for the purpose of alleging forfeiture to the Umited States pursuant to Title 18, United States Code, Sections 982(a)(5) and 982(b). -13. Upon conviction of the offense of conspiracy to commit transportation of stolen vehicles in foreign commerce, in violation of Title 18, United States Code, Section 371, as set forth in Count 1, defendants JIMMY JOSUE MARTINEZ, aka Motas, MARIO ALBERTO ECHEVERRIA- IBARRA, aka Cifre, HENRY IRENIO PULIDO, ALEJANDRO GUZMAN, aka P0110, NARCISO ZAMORA BANUELOS, aka Chi Chi, ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, aka Guero, REYNALDO RODRIGUEZ, aka Edwin, aka Ed-Rod, and SEBASTIAN PONCE, shall forfeit to the United States any property, real and personal, which represents or is traceable to the gross proceeds obtained directly' and indirectly, from the violation. The property to be forfeited includes, but not limited to a sum of money equal to the total amount of gross proceeds obtained directly or indirectly as a result of the offense. 14. If any of the above-described forfeited property, as a result of any act or omission of defendants JIMMY JOSUE MARTINEZ, aka Motas, MARIO ALBERTO aka Cifre, HENRY IRENIO PULIDO, ALEJANDRO GUZMAN, aka P0110, NARCISO ZAMORA aka Chi Chi, ADAN - ESTEBAN SANCHEZ.AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, aka<3uero, REYNALDO RODRIGUEZ, aka Edwin, aka Ed?Rod, or SEBASTIAN PONCE, cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided 10 without difficulty, it is the intent of the United States, pursuant to Title 18, United States Code, Section 982(b), to seek forfeiture of any other property of the: defendants up to the value of the property described above as subject to forfeiture. All pursuant to Title 18, United States Code, Sections 982(a)(5) and 982(b). DATED: May 23, 2017. A TRUE BILL: (:69 I ForEperson ALANA W. ROBINSON Acting United States Attorney [herebyanest my . a CB on That the foregoing document is a hug. trueand correct copy of the o?gi CLERK .S. RICT RT DIST IOWA GREEN Assistant U.S. Attorney 11