February UNITED STATES OF AMERICA, Plaintiff, v. RAUL BALBINO aka ?Manuel,? ANTONIO ZAMORA, aka JESUS GARCIA, aka ?Chuy,? ERNESTO ALONZO FLORES, aka ?Negro," JESUS RAMIREZ GRANADOS, aka ?Chuy2,? DANIEL KENNETH DALPEZZO, CHARMAINE RAYGINA FLORIO, TRACY CROSS, ALEJANDRO JOSE ROJAS, aka ?Alex,? ANTHONY OSTEEN, ROLAND ROE, WARREN BARRY, JASON SILLS, and RUBEN ARREDONDO-DIAZ, aka ?Jaras,? Defendants*1lamramz UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA 2018 Grand Jury 8 -178 iryigirsii [21 U.S.C. 846: Conspiracy to Distribute and to Possess with Intent to Distribute Controlled Substances; 21 U.S.C. 841(a) (A) Possession With Intent to Distribute and Distribution of Methamphetamine; 18 U.S.C. Possession of Firearms in Furtherance of a Drug Trafficking Crime; 18 U.S.C. 922(g)(5): Illegal Alien in Possession of Firearms] The Grand Jury charges: COUNT ONE [21 U.S.C. 846} .A. OBJECTS OF THE CONSPIRACY Beginning on a date unknown and continuing until or about December 2016, in Riverside County, within the Central District of California, and elsewhere, defendants RAUL BALBINO also known as ?Manuel? ANTONIO ZAMORA, aka JESUS GARCIA, aka ?Chuy? ERNESTO ALONZO FLORES, aka ?Negro? JESUS RAMIREZ GRANADOS, aka ?Chuy2? DANIEL KENNETH DALPEZZO CHARMAINE RAYGINA FLORIO TRACY CROSS ALEJANDRO JOSE ROJAS, aka ?Alex? ANTHONY OSTEEN ROLAND ROE WARREN BARRY JASON SILLS and RUBEN ARREDONDO- DIAZ, aka ?Jaras? and others known and unknown to the Grand Jury, conspired and agreed with each other to knowingly and intentionally commit the following offenses: to distribute, and to possess with intent to distribute, at least 50 grams of methamphetamine, a Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l), B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE ACCOMPLISHED The objects of the conspiracy were to be accomplished, in substance, as follows: 1. Defendant would acquire methamphetamine for further distribution from suppliers, including defendants ZAMORA, GARCIA, and FLORES. Defendants and VALENZUELA-VERDUGO would coordinate the sale, and receipt of proceeds from the sale, of methamphetamine to customers, including defendants DALPEZZO, FLORIO, CROSS, ROJAS, OSTEEN, ROE, SILLS, and ARREDONDO-DIAZ for further distribution. 3. Defendants GRANADOS and BARRY would assist with the delivery of methamphetamine supplied by defendants and VALENZUELA-VERDUGO to customers. 4. Defendants and would possess firearms to protect their drugs. C. OVERT ACTS In furtherance of the conspiracy and to accomplish the objects of the conspiracy, on or about the following dates, defendants VALENZUELA, VALENZUELA-VERDUGO, ZAMORA, GARCIA, FLORES, GRANADOS, DALPEZZO, FLORIO, CROSS, ROJAS, OSTEEN, ROE, BARRY, SILLS, and DIAZ, and others known and unknown to the Grand Jury, committed various overt acts in Riverside County, within the Central District of California, and elsewhere, including, but not limited to, the following? 1. On December 17, 2015, using coded language in a telephone conversation, defendant arranged to provide twelve pounds of methamphetamine to an unindicted coconspirator for further distribution. 2. On December 18, 2015, using coded language in a telephone conversation, defendant confirmed with UCC #1 that LOPEZHVALENZUELA believed he had secured the methamphetamine that he was to provide to defendant DIAZ, who was located in Nebraska, and that the total quantity of methamphetamine was now fourteen pounds instead of twelve. 3. On December 19, 2015, using coded language in a telephone conversation, defendant informed UCC #1 that he was going to meet with defendant ZAMORA to obtain the methamphetamine to be supplied to defendant DIAZ. On December 19, 2015, using coded language in a telephone conversation, defendant arranged with UCC #1 to jointly inspect the methamphetamine that defendant had obtained and that was to be distributed to defendant DIAZ. 5. On December 20, 2015, using coded language in a telephone conversation, defendant DIAZ instructed UCC #1 not to share unnecessary information about defendant DIAZ with the courier (defendant BARRY), who would be transporting the fourteen pounds of methamphetamine to defendant DZAZ. 6. On December 20, 2015, using coded language in a telephone conversation, defendant BARRY projected that he would be able to transport the methamphetamine intended for defendant DIAZ before Christmas. 7. On December 21, 2015, using coded language in a telephone conversation, defendant and UCC #1 discussed when defendant BARRY would leave to transport the methamphetamine to defendant DIAZ. 8. On December 22, 2015, using coded language in a telephone voicemail, defendant BARRY updated UCC #1 on his progress in transporting the methamphetamine to defendant DIAZ. December 23, 2015, using coded language in a telephone conversation, defendant DIAZ and UCC #1 discussed the route defendant BARRY was taking to transport methamphetamine to defendant DIAZ. 10. On December 24, 2015, using coded language in a telephone conversation, defendant and UCC #1 discussed providing payment to defendant BARRY for transporting the methamphetamine to defendant DIAZ. 11. On December 26, 2015, using coded language in a telephone conversation, defendant BARRY informed UCC #1 that he had arrived at the predetermined meet location, namely, a Walmart parking lot at 200 Heartland Drive, Lexington, Nebraska (the ?Nebraska Walmart?). 12. On December 26, 2015, using coded language in a telephone conversation, defendant DIAZ discussed with UCC #1 that defendant BARRY was at the Nebraska Walmart to complete the methamphetamine transaction. 13. On December 26, 2015, using coded language in a telephone conversation, defendant DIAZ instructed UCC #1 to direct defendant BARRY to follow defendant vehicle to a trailer, where defendant BARRY was to deliver the methamphetamine and obtain payment for the methamphetamine. 14. On December 26, 2015, defendant DIAZ drove to the Nebraska Walmart and parked next to defendant vehicle. 15. On December 26, 2015, using coded language in a telephone conversation, defendant BARRY spoke to UCC who instructed defendant BARRY to follow defendant vehicle to a trailer, where defendant BARRY would deliver the methamphetamine and collect payment. December 26, 2015, using coded language in a telephone conversation, defendant DIAZ informed UCC #1 that the police stopped defendant DIAZ after defendant DIAZ had met with defendant BARRY. 17. On December 26, 2015, defendant BARRY possessed approximately 4,747;6 grams of methamphetamine. 18. On January 27, 2016, using coded language in a telephone conversation, defendant agreed to meet with defendant DALPEZZO to collect drug proceeds. 19. On January 27, 2016, using coded language in a text message, defendant DALPEZZO ordered three pounds of methamphetamine from defendant 20. On January 27, 2016, using coded language in a telephone conversation, defendant confirmed that he would accompany defendant to Agua Caliente Casino in Rancho Mirage, California (?Agua Caliente Casino?) to conduct the drug transaction that defendant had previously arranged with defendant DALPEZZO. 21. On January 27, 2016, using coded language in a telephone conversation, defendant DALPEZZO confirmed with defendant VALENZUELA that defendant DALPEZZO had at least $7,000 to pay for methamphetamine and that defendants DALPEZZO and FLORIO would meet defendant at the Agua Caliente Casino to complete the purchase. 22. On January 27, 2016, defendants and provided methamphetamine in exchange for cash to defendant DALPEZZO at the Agua Caliente Casino. January 28, 2016, using coded language in a telephone conversation, defendant ordered three pounds of methamphetamine from defendant GARCIA. 24. On January 28, 2016, defendant met with defendant GARCIA at defendant residence to obtain the methamphetamine he had ordered. 25. On January 29, 2016, using coded language in a telephone conversation, defendant DALPEZZO advised defendant that defendant DALPEZZO had a payment for defendant and ordered an additional halpround of methamphetamine from defendant I 26. On January 29, 2016, using coded language in a telephone conversation, defendants and DALPEZZO confirmed that they would meet at Harbor Freight Tools, 31833 Date Palm Drive, Cathedral City, California (the ?Cathedral City Harbor Freight Tools") to conduct the previously discussed methamphetamine transaction. 27. On January 29, 2016, defendant FLORIO drove defendant DALPEZZO to the Cathedral City Harbor Freight Tools parking lot to conduct the methamphetamine transaction. 28. On January 29, 2016, defendant provided methamphetamine to defendant DALPEZZO at the Cathedral City Harbor Freight Tools parking lot. 29. On January 29, 2016, using coded language in a telephone conversation, defendant on behalf of defendant LOPEZ-VALENZUELA, accepted an order from defendant ROJAS for a half? pound of methamphetamine. January 30, 2016, using coded language in a text message, defendant OSTEEN informed defendant that defendant OSTEEN was working with defendant ROJAS and confirmed an order that defendant ROJAS previously placed with defendant VALENZUELA. 31. On January 30, 2016, using coded language in a telephone conversation, defendants ROJAS and negotiated a future one-pound methamphetamine transaction for $2,800. 32. On January 30, 2016, using coded language in a telephone conversation, defendant ROJAS instructed defendant to provide methamphetamine to defendant OSTEEN. 33. On January 30, 2016, defendant met with defendant OSTEEN at defendant apartment in Palm Springs, California to deliver methamphetamine, as requested by defendant ROJAS. 34. On January 31, 2016, using coded language in a text message, defendant OSTEEN informed defendant that he had $1,550 in partial payment for the prior night?s methamphetamine transaction. 35. On January 31, 2016, using coded language in a text message, defendant informed defendant OSTEEN that he would send defendant to pick up the payment. 36. On January 31, 2016, using coded language in a telephone conversation, defendant ZAMORA informed defendant LOPEZHVALENZUELA that a methamphetamine delivery had been delayed. 37. On January 31, 2016, using coded language in a telephone conversation, defendant LOPEZMVALENZUELA informed defendant ZAMORA that he had a customer interested in purchasing six pounds of methamphetamine from defendant 38. On January 31, 2016, using coded language in a telephone conversation, defendant ZAMORA told defendant that the methamphetamine would be ready in an hour and discussed arrangements for its delivery. 39. On January 31, 2016, using coded language in a telephone conversation, defendant advised defendant ZAMORA that he would be purchasing additional methamphetamine from defendant ZAMORA and asked defendant ZAMORA to maintain an adequate supply. 40. On January 31, 2016, using coded language in a telephone conversation, defendants and ZAMORA agreed to pick up the methamphetamine together. 41. On January 31, 2016, defendant went to the residence of defendant ZAMORA and the two traveled as planned to pick up methamphetamine. "42. On January 31, 2016, using coded language in a telephone conversation, defendant advised defendant DALPEZZO that defendant would provide defendant DALPEZZO methamphetamine later that evening. 43. On January 31, 2016, using coded language in a telephone conversation, defendants and DALPEZZO agreed to meet at an AMPM convenience store, located at 27900 Date Palm Drive, Cathedral City, California (the ?Cathedral City to complete the methamphetamine transaction. 44. On January 31, 2016, defendant FLORIO drove defendant DALPEZZO to the Cathedral City AMPM. 1'January 31, 2016, defendants and arrived at the Cathedral City AMPM and parked next to defendants DALPEZZO and FLORIO. 46. On January 31, 2016, defendants and provided methamphetamine to defendants DALPEZZO and FLORIO. 47. On January 31, 2016, defendants DALPEZZO and FLORIO possessed approximately six pounds, 2,645 grams, of methamphetamine. 48. On January 31, 2016, defendants DALPEZZO and FLORIO possessed, in a safe in their car, approximately 214.8 grams of methamphetamine and three digital scales. 49. On January 31, 2016, using coded language in a telephone conversation, defendant confirmed with defendant ZAMORA that the methamphetamine delivery to defendants DALPEZZO and FLORIO had occurred. 50. On February 1, 2016, using coded language in a text message, defendant ordered six pounds of methamphetamine from defendant GARCIA and stated that he would provide payment. 51. On February 1, 2016, defendant drove to defendant residence to obtain the methamphetamine that he previously ordered. 52. On February 1, 2016, using coded language in a telephone conversation, defendant GARCIA requested from defendant VALENZUELA an outstanding drug payment. 53. On February 1, 2016, using coded language in a telephone conversation, defendant instructed defendant to deliver the drug payment to defendant GARCIA. 10 February 4, 2016, using coded language in a telephone conversation, defendant ROJAS asked to borrow a firearm from defendant 55. On February 4, 2016, using coded language in a telephone conversation, defendant defendant ROJAS that he would provide the firearm when he met with defendants ROJAS and OSTEEN. 56. On February 4, 2016, using coded language in a telephone conversation, defendant OSTEEN ordered a half?pound of methamphetamine from defendant 57. On February 4, 2016, defendants and arrived at defendant OSTEEN's residence and met with defendants OSTEEN and ROJAS to deliver the firearm. 58. On February 4, 2016, defendant OSTEEN possessed, on his person, approximately 54.6 grams of methamphetamine. 59. On February 4, 2016, defendant OSTEEN possessed, in his residence, approximately 431 grams of methamphetamine. 60. On February 5, 2016, using coded language in a telephone conversation, defendant agreed to provide methamphetamine to defendant OSTEEN for further distribution. 61. On February 5, 2016, using coded language in a telephone conversation, defendant arranged to sell a half: pound of methamphetamine to defendant OSTEEN that would be delivered by defendant 62. On February 5, 2016, using coded language in a text message, defendant OSTEEN confirmed with defendant that the two would meet the following day to complete the methamphetamine transaction. 11 February 6, 2016, defendant provided defendant OSTEEN with methamphetamine and collected payment. 64. On February 6, 2016, using coded language in a telephone conversation, defendant confirmed with defendant that he sold methamphetamine to defendant OSTEEN and collected partial payment for the drugs. 65. On February 8, 2016, using coded language in_a text message mm. exchange, defendant SILLS agreed to sell methamphetamine to a DEA undercover agent. 66. On February 8, 2016, using coded language in a text message exchange, defendant SILLS agreed to sell one pound of methamphetamine to a DEA undercover agent for $4,100 later that day. 67. On February 9, 2016, using coded language in a text message, defendant ROE, on defendant behalf, ordered from defendant LOPEZ-VALENZUELA one pound of methamphetamine. 68. On February 9, 2016, using coded language in a telephone conversation, defendants and ROE agreed to meet in a Home Depot parking lot, located at 5200 East Ramon Road, Palm Springs, California (the ?Palm Springs Home Depot?). 69. On February 9, 2016, defendants and ROE met at the parking lot of the Palm Springs Home Depot. 70. On February 9, 2016, defendants and ROE drove to defendant residence to distribute methamphetamine. 71. On February 24, 2016, using coded language in a text message, defendant CROSS ordered methamphetamine from defendant 72. On February 24, 2016, using coded language in a text message, defendant confirmed that he would meet 12 with defendant CROSS at a Big Lots, located 69026 East Palm Canyon Drive, Cathedral City, California (the ?Cathedral City Big Lots?) to deliver the methamphetamine that defendant CROSS ordered. 73. On February 24, 2016, defendant distributed methamphetamine to defendant CROSS at the parking lot of the Cathedral City Big Lots. 74. On February 24, 2016, defendant CROSS possessed approximately 254.6 grams of methamphetamine. 75. On February 26, 2016, using coded language in a telephone conversation, defendant CROSS ordered an additional half?pound of methamphetamine from defendant and the two agreed to meet later that day to complete the transaction. 76. On February 26, 2016, using coded language in a telephone conversation, defendant GRANADOS, using defendant phone, confirmed with defendant CROSS that this transaction also would take place at the Cathedral City Big Lots parking lot. 77. On February 26, 2016, defendant VALENZUELA-VERDUGO distributed methamphetamine to defendant CROSS in the Cathedral City Big Lots parking lot. 78. On February 27, 2016, using coded language in a text message, defendant discussed with an unindicted co? conspirator a drug payment that UCC #2 owed defendant VALENZUELA-VERDUGO. 79. On February 27, 2016, using coded language in a text message, defendant LOPEZ-VALENZUELA and UCC #2 discussed defendant providing a firearm to UCC 80. On February 27, 2016, using coded language in a telephone conversation, defendant instructed defendant 13 provide a firearm and a box of ammunition to UCC 81. On March 8, 2016, defendant FLORIO reserved room 332 at the Agua Caliente Casino for use in a drug transaction. 82. On March 8, 2016, using coded language in a telephone conversation, defendant confirmed that he could obtain three pounds of methamphetamine from defendant FLORES to distribute later that day. 83. On March 8, 2016, defendants and arrived at Agua Caliente Casino to deliver methamphetamine to defendants DALPEZZO and FLORIO. 84. On March 8, 2016, using coded language in a telephone conversation, defendant instructed defendant GRANADOS to bring an additional pound of methamphetamine to the Agua Caliente Casino for defendants DALPEZZO and FLORIO. 85. On March 8, 2016, using coded language in a telephone conversation, defendant instructed defendant GRANADOS to bring the additional pound of methamphetamine to room 332 of the Agua Caliente Casino. 86. On March 8, 2016, defendants VALENZUELA, and GRANADOS sold defendant DALPEZZO methamphetamine. 87. On March 9, 2016, using coded language in a telephone conversation, defendant DALPEZZO ordered from defendant VERDUGO an additional pound of methamphetamine for distribution. 88. On March 9, 2016, defendant distributed to defendant DALPEZZO the additional pound of methamphetamine that defendant DALPEZZO had ordered from defendant LOPEZ-VALENZUELA. 14 March 15, 2016, using coded language in a telephone conversation, defendant instructed defendant to order ten pounds of methamphetamine from defendant GARCIA. 90. On March 23, 2016, using coded language in an electronic message, defendant FLORES informed defendant he could arrange for the supply of twenty?four pounds of methamphetamine. 91. On March 24, 2016, using coded language in a telephone conversation, defendants and coordinated receiving methamphetamine from defendant FLORES on credit. 92. On March 25, 2016, using coded language in a telephone conversation, defendant inquired of defendant FLORES the status of a pending methamphetamine delivery. 93. On March 25, 2016, using coded language in a telephone conversation, defendant FLORES informed defendant that the methamphetamine was ready. 94. On March 25, 2016, defendant obtained methamphetamine from defendant FLORES. 95. On March 26, 2016, defendant possessed 11,386 grams of methamphetamine, two firearms, ammunition, and a digital scale in a vehicle he used, namely, a gray Plymouth Voyager. 96.? On March 26, 2016, defendant VALENZUELA-VERDUGO possessed 17.9 grams of methamphetamine, one firearm, and ammunition in his residence. 15 March 26, 2016, defendant possessed 27.9 grams of methamphetamine in another vehicle he used, namely, a white Nissan Frontier. 98. On April 4, 2016, defendant FLORIO reserved room 303 at the Agua Caliente Casino for use in a drug transaction. 99. On April 6, 2016, defendant delivered methamphetamine to defendants DALPEZZO and FLORIO in room 303 at the Agua Caliente Casino. 100. On April 6, 2016, defendant LOPEZMVALENZUELA possessed $16,300 in drug proceeds that he had received from defendant DALPEZZO. 101. On June 1, 2016, defendant GARCIA knowingly possessed- 0.5303 grams of methamphetamine, a firearm, ammunition, a digital scale, and a ledger documenting prior drug transactions. 16 COUNT TWO [21 U.S.C. 84l(a)(l), On or about December 26, 2015, in Riverside County, within the Central District of California, and elsewhere, defendants RAUL VALENZUELA, ANTONIO ZAMORA, also known as ?Foca,? WARREN BARRY, and RUBEN aka ?Jaras,? and others known and unknown to the grand jury, knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 4,747.6 grams, of methamphetamine, a Schedule II controlled substance. 17 COUNT THREE [21 U.S.C. 841(a)(1), On or about January 31, 2016, in Riverside County, within the Central District of California, defendants RAUL LOPEZHVALENZUELA, BALBINO also known as ?Manuel,? and ANTONIO ZAMORA, aka ?Foca,? knowingly and intentionally distributed at least fifty grams, that is, 2,645 grams, of methamphetamine, a Schedule II controlled substance. 18 COUNT FOUR [21 U.S.C. 841(a) (1), (1) (A) On or about January 31, 2016, in Riverside County, within the Central District of California, defendants DANIEL KENNETH DALPEZZO, also known as ?Gabacho,? and CHARMAINE RAYGINA FLORIO, knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 2,645 grams, of methamphetamine, a Schedule 1: controlled subStance. 19 COUNT FIVE [21 U.S.C. 84l(a)(l), On or about January 31, 2016, in Riverside County, within the Central District of California, defendants DANIEL KENNETH DALPEZZO, also known as ?Gabacho,? and CHARMAINE RAYGINA FLORIO, knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 214.8 grams, of methamphetamine, a Schedule II controlled substance. 20 COUNT SIX [21 U.S.C. 841(a)(1), On or about February 4, 2016, in Riverside County, within the Central District of California, defendants RAUL and BALBINO also known as ?Manuel,? knowingly and intentionally distributed at least fifty grams, that is, 110.4 grams, of methamphetamine, a Schedule II controlled substance. 21 1o 11 12 13 14COUNT SEVEN [21 U.S.C. 841(a)(l), On or about February 4, 2016, in Riverside County, within the Central District of California, defendant ANTHONY OSTEEN, and others known and unknown to the grand jury,.knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 110.4 grams, of methamphetamine, a Schedule II controlled substance. 22 COUNT EIGHT [21 U.S.C. 84l(a)(l), On or about February 4, 2016, in Riverside County, within the Central District of California, defendant ANTHONY OSTEEN, and others known and unknown to the grand jury, knowingly and intentionally possessed.with intent to distribute at least fifty grams, that is, 431 grams, of methamphetamine, a Schedule II controlled substance. 23 COUNT NINE [21 U.S.C. 841(a)(1), On or about February 4, 2016, in Riverside County, within the Central District of California, defendant ALEJANDRO JOSE ROJAS, also known as ?Alex,? knowingly and intentionally possessed with intent to distribute at least five grams, that is, 25.8 grams, of methamphetamine, a Schedule II controlled substance. 24 COUNT TEN [21 U.S.C. 84l(a)(1), On or about February 24,?2016, in Riverside County, within the Central District of California, defendants RAUL and BALBINO also known as ?Manuel,? knowingly and intentionally distributed at least fifty grams, that is, 254.6 grams, of methamphetamine, a Schedule II controlled substance. 25 COUNT ELEVEN [21 U.S.C. 84l(a)(1), On or about February 24, 2016, in Riverside County, Within the Central District of California, defendant TRACY CROSS knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 254.6 grams, of methamphetamine, a Schedule II controlled substance. 26 COUNT TWELVE [21 S.C. 84l(a)(1), On or about March 26, 2016, in Riverside County, within the Central District of California, defendant ERNESTO FLORES, also known as ?Negro,? knowingly and intentionally distributed at least fifty grams, that is, ll,431.8, grams of methamphetamine, a Schedule II controlled substance. 27 [21 U.S.C. 841(a)(l), On or about March 26, 2016, in Riverside County, within the Central District of California, defendants RAUL and BALBINO also known as ?Manuel," knowingly and intentionally possessed with intent to distribute at least fifty grams, that is, 11,431.8, grams of methamphetamine, a Schedule II controlled substance. 28 COUNT FOURTEEN [21 U.S C. On or about March 26, 2016, in Riverside County, within the Central District of California, defendants RAUL and BALBINO also known as ?Manuel,? knowingly possessed at least one of the below listed firearms in furtherance of a drug trafficking crime, namely, conspiracy to possess with intent to distribute and to distribute methamphetamine, in violation of Title 21, United States Code, Section 846, as charged in Count One of this Indictment, and possession with intent to distribute methamphetamine, in violation of Title 21, United States Code, Sections 84l(a)(1), as charged in Count Thirteen of this Indictment: a Ruger .22 caliber MarkwII MK512 handgun, serial number l9~ 65950; (2) a Ruger .22 caliber Mark?II KMK6 handgun, serial number 224? 70109; and (3) a Glock Model?22 .40 caliber handgun, serial number RFD345. 29 COUNT FIFTEEN [21 U.S.C. On or about March 26, 2016, in Riverside County, within the Central District of California, defendant BALBINO also known as ?Manuel,? then an alien illegally and unlawfully in the United States, knowingly possessed at least one of the following firearms, namely, a Ruger .22 caliber Mark-II MK512 handgun, serial number 19?65950; a Ruger .22 caliber Mark?II KMK6 handgun, serial number 224?70109; and a Glock Model?22 .40 caliber handgun, serial number RFD345. A TRUE BILL rForeperson NICOLA T. HANNA United States Attorney XN LAWRENCE S. MIDDLETON Assistant United States Attorney Chief, Criminal Division KEVIN M. LALLY Assistant United States Attorney Chief, Organized Crime Drug Enforcement Task Force Section PUNEET V. KAKKAR Assistant United States Attorney Organized Crime Drug Enforcement Task Force Section 30