Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.5 Page 1 of 11 ■K““ fr?. i ’0 MAY 23 PM 3'S3 2 3 4 5 6 7 \ 8 UNITED STATES DISTRICT COURT 9 I SOUTHERN DISTRICT OF CALIFORNIA September 2016 Grand Jury 10 t- 11 UNITED STATES OF AMERICA, Plaintiff, 12 13 14 15 16 17 18 19 20 21 22 23 v. JIMMY,JOSUE MARTINEZ (1), aka Motas, MARIO ALBERTO ECHEVERRIA-IBARRA (2), aka Cifre, HENRY IRENIO PULIDO (3), ALEJANDRO GUZMAN (4), aka Polio, 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), 24 Defendants. 25 26 27 The grand jury charges: 28 AJGA:JSGR(l) mlvrSan Diego 5/23/17 Case No. I N D C T M E N T I Title 18, U.S.C., Sec. 371 Conspiracy; Title 18, U.S.C., Secs. 982(a)(5) and 982(b) Criminal Forfeiture Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.6 Page 2 of 11 1 Count 1 2 18 U.S.C. § 371 3 CONSPIRACY 4 The 1. Hooligans Motorcycle Club, based in Tijuana, Mexico, 5 consisted of motorcycle riders who regularly traveled between the United 6 States and Mexico. 7 Hooligans - held a weekly meeting in Tijuana during which, among other 8 things, they engaged in group motorcycle riding. 9 2. Members of the Hooligans Motorcycle Club - known as Defendants JIMMY JOSUE aka Motas, ECHEVERRIA-IBARRA, 11 aka Polio, NARCISO ZAMORA BANUELOS, 12 AGUIRRE, 13 RODRIGUEZ, 14 were members of the Hooligans Motorcycle club and operated their club 15 as a transnational criminal organization involved in various criminal 16 activities, including vehicle thefts. 17 3. Guerito, aka Edwin, HENRY IRENIO PULIDO, MARIO ALBERTO 10 aka aka Cifre, MARTINEZ, SALVADOR aka Chi Chi, ADAN ESTEBAN SANCHEZ ISAY aka Ed-Rod, ALEJANDRO GUZMAN, CASTILLO, aka Guero, and SEBASTIAN PONCE, REYNALDO among others, Beginning on a date unknown, but no later than January 2014, 18 and continuing through the date of this Indictment, within the Southern 19 District of California and elsewhere, defendants JIMMY JOSUE MARTINEZ, 20 aka Motas, 21 PULIDO, ALEJANDRO GUZMAN, 22 Chi, ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, 23 aka Guero, 24 PONCE knowingly and intentionally conspired and agreed with each other, 25 and with persons known and unknown to the grand jury, 26 offense against the United States 27 vehicles in foreign commerce, 28 Code, Section 2312. MARIO ALBERTO ECHEVERRIA-IBARRA, aka Polio, REYNALDO RODRIGUEZ, aka Cifre, NARCISO ZAMORA BANUELOS, aka Edwin, aka to wit, Ed-Rod, IRENIO aka Chi and SEBASTIAN to commit an transportation of stolen in violation of Title 18, 2 HENRY United States Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.7 Page 3 of 11 METHODS AND MEANS 1 3 In furtherance 4. 2 of this conspiracy, object, the following manners and means were used, among others: 4 The defendants stole vehicles - typically motorcycles and a. within 5 Jeep 6 transported them to Mexico. Wranglers the Southern District of California and The defendants organized themselves into various theft b. 7 Each defendant was a member of at least one theft crew and acted 8 crews. 9 in at least one of the following roles: 10 scout; or key cutter. 11 c. 12 and to' accomplish its leader; thief; transporter; The defendants would follow a multi-step process to steal and transport motorcycles: i. 13 First, scouts would travel throughout the Southern 14 District of California to identify motorcycles to steal. 15 locate motorcycles in the parking structures and parking garages of 16 apartment complexes and shopping centers, among other places. ii. 17 18 Second, thieves iii. to Third, 20 motorcycles 21 vehicles' lawful owners. Mexico iv. 22 stolen transporters without the on the motorcycles would knowledge or drive the permission stolen of the Fourth, leaders would sell or Otherwise dispose of 23 the 24 indirectly 25 transportation of the motorcycles. 27 turn without a key by bypassing the ignition switch. 19 26 would Scouts would motorcycles. Leaders would pay either directly or the other individuals who participated in the theft and d. The defendants would follow a similar multi-step process to steal and transport Jeep Wranglers: 28 3 Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.8 Page 4 of 11 i. 1 of First, 2 District California 3 identifying 4 Identification Number 5 location. a Jeep ii. 6 scouts would travel throughout the Southern to identify Wrangler, (VIN) Second, Jeep scouts Wranglers would to steal. obtain from the dashboard or the the Upon Vehicle secondary VIN scouts would send the VIN to leaders, 7 in turn, would send the VIN to key cutters. 8 authorization, 9 create and program duplicate keys for Jeep Wranglers. who Key cutters would, without access a proprietary database containing codes used to Key cutters would 10 obtain two codes for the Jeep Wrangler targeted by scouts. 11 would use one of the codes to create a duplicate key for the targeted 12 Jeep Wrangler. 13 along with the second code, which thieves would need in order to program 14 the microchip within the key at the time of the theft. 15 Leaders would provide the duplicate key to thieves or transporters. Key cutters would provide the duplicate key to leaders iii. 16 Key cutters Third, thieves and transporters would return to the 17 targeted Jeep Wrangler with the key and the programming code and would 18 disable certain features of the Jeep Wrangler's alarm system, including 19 the horn and emergency flashers. 20 to access the Jeep Wrangler's passenger compartment and would then use 21 a handheld key programmer and the code received from the key cutters to 22 program the duplicate key to the Jeep Wrangler. iv. 23 Fourth, Thieves would use the duplicate key thieves would exit the Jeep Wrangler's 24 passenger compartment and the transporters would drive the Jeep Wrangler 25 to Tijuana, Mexico without the knowledge or permission of the vehicle's 26 lawful owner. 27 28 v. the Fifth, stolen Jeep Wranglers. leaders would sell or otherwise dispose of Leaders 4 would pay either directly or Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.9 Page 5 of 11 1 indirectly 2 transportation of the Jeep Wranglers. 3 the other individuals who participated in the theft and e. At various 4 aka Motas, 5 leaders of theft crews. 6 f. times, defendants and MARIO ALBERTO ECHEVERRIA-IBARRA, 28 vehicles worth approximately $800,000. 8 OVERT ACTS 5. MARTINEZ, aka Cifre, acted as In furtherance of this conspiracy, and to carry out its object, 10 the following 11 Southern District of California and elsewhere: 12 JOSUE The defendants stole or attempted to steal approximately 7 9 JIMMY a. acts, among others, On or about January 14, and ZAMORA the defendants JIMMY JOSUE 14 communicated via Facebook about obtaining a key for a 2007 Jeep Wrangler 15 with a VIN ending in -8776. On or about NARCISO 2014, committed within MARTINEZ, b. Motas, were 13 16 aka overt January 15, BANUELOS, 2014, aka Chi Chi, defendant JIMMY JOSUE 17 MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler 18 with a VIN ending in -8776 located in Pacific Beach, San Diego. 19 c. On or about January 19, 2014, defendant JIMMY JOSUE 20 MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler 21 with a VIN ending in -4578 located near Serra Mesa, San Diego. 22 d. On or about February 12, 2014, defendant ALEJANDRO 23 GUZMAN, aka Polio, attempted to steal a 2012 Suzuki GSXR-750 motorcycle 24 located 'in Chula Vista. 25 e. On or about March 20, 2014, defendant JIMMY JOSUE 26 MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler 27 with a VIN ending in -1405 located in Chula Vista. 28 5 Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.10 Page 6 of 11 f. 1 On or about April 2, 2014, defendant JIMMY JOSUE 2 MARTINEZ, aka Motas, participated in the theft of a 2014 Jeep Wrangler 3 with a VIN ending in -4496 located in Mission Valley, San Diego. 4 g- On or about May 2, 2014, defendant ALEJANDRO GUZMAN, 5 aka Polio, stole a 2014 Suzuki GSXR-750 motorcycle with a VIN ending in 6 -2020 located in Mira Mesa, San Diego. h. 7 On or about May 2, 2014, defendant ALEJANDRO GUZMAN, aka 8 Polio, .transported a 2014 Suzuki GSXR-750 motorcycle with a VIN ending 9 in -2020 to Mexico. i. 10 On or about June 10, 2014, defendant JIMMY JOSUE 11 MARTINEZ, aka Motas, participated in the theft of a 2008 Jeep Wrangler 12 with a VIN ending in -0879 located in Ocean Beach, San Diego. 7 13 1• On or about July 30, 2014, defendant JIMMY JOSUE 14 MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler 15 with a VIN ending in -4548 located in Mission Valley, San Diego. k. 16 On or about August Guerito, and defendants ADAN ESTEBAN SANCHEZ 18 communicated via Facebook about stealing a Suzuki GSXR motorcycle. 1. aka 2014, 17 19 AGUIRRE, 5, On or about August 24, ALEJANDRO 2014, GUZMAN, aka Polio, defendant MARIO ALBERTO 20 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2012 Jeep 21 Wrangler with a VIN ending in -2791 located in Vista. 22 m. On or about September 13, 2014, defendant JIMMY JOSUE 23 MARTINEZ, aka Motas, participated in the theft of a 2013 Jeep Wrangler 24 with a VIN ending in -3692 located in University Heights, San Diego. 25 n. On or about September 18, 2014, defendant MARIO ALBERTO 26 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2008 Jeep 27 Wrangler with a VIN ending in -5185 located in Vista. 28 6 Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.11 Page 7 of 11 1 o. On or about September 20, 2014, 2 MARTINEZ, 3 participated in the theft of a 2013 Jeep Wrangler with a VIN ending in 4 -9587 located in Pacific Beach, San Diego. 5 aka Motas, defendants JIMMY JOSUE P- and ADAN ESTEBAN SANCHEZ AGUIRRE, On or about September 20, 2014, aka. Motas, aka Guerito, defendants JIMMY JOSUE 6 MARTINEZ, 7 participated in the theft of a 2007 Jeep Wrangler with a VIN ending in 8 -1018 located in Pacific Beach, San Diego. q- 9 and ADAN ESTEBAN SANCHEZ AGUIRRE, aka Guerito, On or about September 30, 2014, defendant MARIO ALBERTO 10 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2009 Jeep 11 Wrangler with a VIN ending in -6025 located in Ocean View Hills, San 12 Diego. 13 r. On or about 2014, defendants MARTINEZ, 15 participated in the theft of a 2014 Jeep Wrangler with a VIN ending in 16 -8266 located in Hillcrest, San Diego. s. and ADAN ESTEBAN SANCHEZ AGUIRRE, JIMMY JOSUE 14 17 aka Motas, October 3, On or about October 3, 2014, aka Guerito, defendant MARIO ALBERTO 18 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2011 Jeep 19 Wrangler with a VIN ending in -8006 located in Point Loma, San Diego. 20 t. On or about October 16, 2014, defendant MARIO ALBERTO 21 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2009 Jeep 22 Wrangler VIN ending in -9465 located in Ocean Beach, San Diego. 23 u. On or about October 22, 2014, defendant MARIO ALBERTO 24 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2013 Jeep 25 Wrangler VIN ending in -9106 located in Scripps Ranch, San Diego. 26 v. On or about October 25, 2014, defendant JIMMY JOSUE 27 MARTINEZ, aka Motas, participated in the theft of a 2007 Jeep Wrangler 28 VIN ending in -7511 located in Escondido. 7 Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.12 Page 8 of 11 1 w. On or about October 28, defendants JIMMY JOSUE 2 MARTINEZ, 3 participated in the theft of a 2014 Jeep Wrangler VIN ending in -0624 4 located in North Park, San Diego. 5 aka Motas, 2014, x. and ADAN ESTEBAN SANCHEZ AGUIRRE, On or about November 5, aka Guerito, 2014, defendant NARCISO ZAMORA 6 BANUELOS, aka Chi Chi, attempted to steal a 2 008 Jeep Wrangler VIN ending 7 in -6353 located in Otay Mesa West, San Diego. y- 8 9 10 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. 11 z. On or about November 13, defendants JIMMY JOSUE 12 MARTINEZ, 13 participated in the theft of a 2014 Jeep Wrangler VIN ending in -8256 14 located in Mira Mesa, San Diego. 15 aka Motas, 2014, aa. and ADAN ESTEBAN SANCHEZ AGUIRRE, On or about November 18, aka Guerito, 2014, defendant MARIO ALBERTO 16 ECHEVERRIA-IBARRA, aka Cifre, participated in the theft of a 2014 Jeep 17 Wrangler VIN ending in,-5094 located in Grantville, San Diego. ■ bb. 18 On or about November 20, 2014, defendant MARIO ALBERTO 19 ECHEVERRIA-IBARRA, aka Cifre, attempted to steal a 2 007 Jeep Wrangler 20 VIN ending in -0985 located in Golden Hill, San Diego. cc. 21 On or about February 19, 2015, defendant REYNALDO 22 RODRIGUEZ, aka Edwin, aka Ed-Rod, participated in the theft of a 2007 23 Jeep Wrangler VIN ending in -2988 located in Spring Valley. 24 // 25 // 26 // 27 // 28 // 8 Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.13 Page 9 of 11 dd. 1 On or about April 4, 2015, defendant ADAM ESTEBAN SANCHEZ 2 AGUIRRE, aka Guerito, and co-conspirator J.C. communicated via Facebook 3 about 4 Anticipating the response to the thefts, SANCHEZ wrote: "They're going ' 5 6 a group ■ of Hooligans planning to steal multiple to say 'damn hooligans. / n finish us off, dude." SANCHEZ responded: "Mexico vs usa.” 7 ee. J.C. responded: "We're a plague. On or about May 22, 2015, defendant vehicles. They can't SEBASTIAN PONCE 8 participated in the theft of a 2010 Honda CBR1000 motorcycle with VIN 9 ending in -0037 located on the San Diego State University campus. ff. 10 On or about June 13, 2015, defendant ADAN ESTEBAN SANCHEZ 11 AGUIRRE, aka Guerito, wrote to co-conspirator J.C. via Facebook: "What's 12 up, dog? 13 those poor people up." 14 outside anymore. 15 walls." 16 All you do is steal from the Americans. 'You've already cleaned J.C. responded: Only garage. "They don't leave me anything I have to go around jumping fences and SANCHEZ responded: "Hahaha, even with that they can't stop us." gg- On or about June 19, 2015, defendant SEBASTIAN PONCE 17 participated in the theft of a 2012 Kawasaki Ninja motorcycle with VIN 18 ending in -5562 located in La Mesa. hh. 19 On or about June 28, 2015, defendants HENRY IRENIO 20 PULIDO, and SALVADOR ISAY CASTILLO, aka Guero, attempted to transport a 21 stolen Honda CBR 600RR motorcycle and a stolen Yamaha YZF-RI motorcycle 22 to Mexico, with VINs ending in -0031 and -3133, respectively. ii. 23 On or about November 18, 2015, defendants MARIO ALBERTO 24 ECHEVERRIA-IBARRA, aka Cifre, and 25 Facebook about paying another individual to assist in stealing a vehicle. 26 All in violation of Title 18, United States Code, Section 371. 27 // 28 // 9 SEBASTIAN PONCE communicated via Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.14 Page 10 of 11 FORFEITURE ALLEGATIONS 1 The allegations contained in Count 1 of this Indictment are 12 . 2 3 re-alleged and incorporated by reference for the purpose of alleging 4 forfeiture to the United States pursuant 5 Code, Sections 982(a)(5) Upon 13 . 6 to Title 18, and 982(b). conviction of the offense of conspiracy 7 transportation of stolen vehicles in foreign commerce, 8 Title 18, 9 defendants JIMMY JOSUE MARTINEZ, United States Code, aka Cifre, United States Section 371, to commit in violation of as set forth in Count 1, aka Motas, MARIO ALBERTO ECHEVERRIA- 10 IBARRA, 11 NARCISO ZAMORA BANUELOS, 12 aka Guerito, 13 aka Edwin, aka Ed-Rod, and SEBASTIAN PONCE, 14 States any property, real and personal, which represents or is traceable 15 to 16 violation. 17 sum 18 directly or indirectly as a result of the offense. the proceeds aka Chi ISAY Chi, CASTILLO, obtained ALEJANDRO GUZMAN, aka Polio, ADAN ESTEBAN SANCHEZ AGUIRRE, aka directly Guero, REYNALDO RODRIGUEZ, shall forfeit to the United and indirectly, from the The property to be forfeited includes, but not limited to a money 14. 19 SALVADOR gross of HENRY IRENIO PULIDO, equal to the total amount of gross proceeds obtained If any of the above-described forfeited property, as a result 20 of any act or omission of defendants JIMMY JOSUE MARTINEZ, 21 MARIO 22 ALEJANDRO GUZMAN, aka Polio, NARCISO ZAMORA BANUELOS, aka Chi Chi, ADAN 23 ESTEBAN SANCHEZ AGUIRRE, aka Guerito, SALVADOR ISAY CASTILLO, aka Guero, 24 REYNALDO RODRIGUEZ, 25 be located upon the exercise of due diligence; has been transferred or 26 sold to, or deposited with, a third person; has been placed beyond the 27 jurisdiction of the Court; has been substantially diminished in value; 28 or has been commingled with other property which cannot be subdivided ALBERTO ECHEVERRIA-IBARRA, aka Edwin, aka Cifre, aka Ed-Rod, 10 HENRY aka Motas, IRENIO or SEBASTIAN PONCE, PULIDO, cannot Case 3:17-cr-01314-JAH Document 1 Filed 05/23/17 PageID.15 Page 11 of 11 1 without difficulty, it is the intent of the United States, pursuant to 2 Title 18, United States Code, Section 982(b), to seek forfeiture of any 3 other property of 4 described above as subject to forfeiture. 5 All 6 and 982(b). pursuant to the1 defendants Title 18, up United States Code, A TRUE BILL: 8 4 9 r 10 Foreperson ALANA W. ROBINSON Acting United States Attorney 12 13 14 Assistant U.S. Attorney 15 16 By: 17 the value of DATED: May 23, 2017. 7 11 to JOSEPiTS. GREEN Assistant U.S. Attorney 18 19 20 21 22 23 24 25 26 27 28 11 the property Sections 982(a)(5)