Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 1 of 26 PageID #: 1

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

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JUL OD 2020

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LONG ISLAND OFFICE

-------------------X
INDICTMENT

UNITED STATES OF AMERICA

Cr.£
R 20 2 5
{T. 18, U.S.C., §§ 924(c){l)(A)(i),

- against CARLOS ALFARO,
also known as "Russo,"
JOSE MOISES BLANCO,
also known as "Cuervo,"
OSEAS GONZALEZ,
also known as "Manota" and "Cordero,"
JOSE JONATHAN GUEVARA-CASTRO,
also known as "S uspechoso,"
VICTOR LOPEZ-MORALES,
also known as "Persa,"
EVER MORALES-LOPEZ,
also known as "Kien," "Inke" and
"White Boy,"
DAVID SOSA-GUEVARA,
also known as "Risky," and
KEVIN TORRES,
also known as "Inquieto" and "Quieto,"

924( c)( 1)(A)(ii), 924(c)( 1)(A)(iii),
9240)(1 ), 1959(a){l), 1959(a)(3),
1959(a)(5), 1962(c), 1962(d), 1963, 2, 3
and 3551 et~.; T. 21, U.S.C., §§ 846,
841(b)(l)(C) and 841(b){l){D))

AZRACK,J.

LOCKE,M.J.

Defendants.

-------------------X
THE GRAND JURY CHARGES:
INTRODUCTION
At all times relevant to this Indictment, unless otherwise indicated:
The Enterprise
1.

f

La Mara Salvatrucha, also known as the MS-13, (hereinafter the "MS-

13" or the "enterprise") was a transnational criminal organization with members located

-·

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throughout Long Island, New York, Queens, New York and elsewhere. Members and
associates of the MS-13 have engaged in acts of violence, including murder, attempted
murder, robbery, kidnapping and assault, as well as other criminal activity, including
narcotics trafficking, extortion, witness tampering and witness retaliation.
2.

The defendants CARLOS ALF ARO, also known as "Russo," JOSE

MOISES BLANCO, also known as "Cuervo," OSEAS GONZALEZ, also known as
"Manota" and "Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as
"Suspechoso," VICTOR LOPEZ-MORALES, also known as "Persa," EVER MORALES­
LOPEZ, also known as "Kien," "Inke" and "White Boy," DAVID SOSA-GUEVARA,
also known as "Risky," and KEVIN TORRES, also known as "Quieto" and "Inquieto,"
were members and associates of the MS-13.
3.

The MS-13, including its leadership, membership and associates,

constituted an "enterprise" as defined by Title 18, United States Code, Section 1961 (4 ), that
is, a group of individuals associated in fact. The enterprise constituted an ongoing
organization whose members functioned as a continuing unit for a common purpose of
achieving the objectives of the enterprise. The enterprise was engaged in, and its activities
affected, interstate and foreign commerce.
Purposes of the Enterprise
4.

The purposes of the enterprise included the following:
a.

Promoting and enhancing the prestige, reputation and position

of the enterprise with respect to rival criminal organizations.

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b.

Preserving and protecting the power, territory and criminal

ventures of the enterprise through the use of intimidation, threats of violence and acts of
violence, including assault and murder.
c.

Keeping victims and rivals in fear of the enterprise and its

members and associates.
d.

Enriching the members and associates of the enterprise through

criminal activity, including robbery, extortion and narcotics trafficking.
e.

Ensuring discipline within the enterprise and compliance with

the enterprise's rules by members and associates through threats of violence and acts of
violence.
Means and Methods of the Enterprise
5.

Among the means and methods by which the defendants and their

associates conducted and participated in the conduct of the affairs of the enterprise were the
following:
a.

Members of the MS-13 and their associates committed,

attempted to commit and threatened to commit acts of violence, including murder, attempted
murder, robbery, kidnapping and assault, to enhance the enterprise's prestige and protect and
expand the enterprise's criminal operations.
b.

Members of the MS-13 and their associates used and threatened

to use physical violence against various individuals, including members of rival criminal
organizations and MS-13 members who violated the enterprise's rules.

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c.

Members of the MS-13 and their associates used, attempted to

use and conspired to use robbery, extortion and narcotics trafficking as means of obtaining
money.
COUNT ONE
(Racketeering)
6.

The allegations contained in paragraphs one through five are realleged

and incorporated as if fully set forth in this paragraph.
7.

On or about and between January 1, 2015 and the date of this

Indictment, both dates being approximate and inclusive, within the Eastern District of New
York and elsewhere, the defendants CARLOS ALF ARO, also known as "Russo," JOSE
MOISES BLANCO, also known as "Cuervo," OSEAS GONZALEZ, also known as
"Manota" and "Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as
"Suspechoso," VICTOR LOPEZ-MORALES, also known as "Persa," EVER MORALES­
LOPEZ, also known as "Kien," "Inke" and "White Boy," DAVID SOSA-GUEVARA, also
known as "Risky," and KEVIN TORRES, also known as "Quieto" and "Inquieto," together
with others, being persons employed by and associated with the MS-13, an enterprise
engaged in, and the activities of which affected, interstate and foreign commerce, did
knowingly and intentionally conduct and participate, directly and indirectly, in the conduct of
the affairs of the MS-13 through a pattern of racketeering activity, as defined by Title 18,
United States Code, Sections 1961(1) and 1961(5), consisting of the racketeering acts set
forth below.

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RACKETEERING ACT ONE
(Conspiracy to Murder Oscar Acosta and Murder of Oscar Acosta)
8.

The defendant KEVIN TORRES, together with others, committed the

following acts, either one of which alone constitutes Racketeering Act One:
A.

Conspiracy to Murder Oscar Acosta
9.

In or about April 2016, within the Eastern District of New York and

elsewhere, the defendant KEVIN TORRES, together with others, did knowingly and
intentionally conspire to cause the death of Oscar Acosta, in violation of New York Penal
Law Sections 125.25(1) and 105.15.

B.

Murder of Oscar Acosta
10.

On or about April 29, 2016, within the Eastern District ofNew York

and elsewhere, the defendant KEVIN TORRES, together with others, with intent to cause the
death of another person, to wit: Oscar Acosta, did knowingly and intentionally cause his
death, in violation of New York Penal Law Sections 125.25(1) and 20.00.
RACKETEERING ACT TWO
(Conspiracy to Murder Kerin Pineda and Murder of Kerin Pineda)
11.

The defendants OSEAS GONZALEZ, JOSE JONATHAN

GUEVARA-CASTRO, VICTOR LOPEZ-MORALES, EVER MORALES-LOPEZ, DAYID
SOSA-GUEVARA and KEVIN TORRES, together with others, committed the following
acts, either one of which alone constitutes Racketeering Act Two:

A.

Conspiracy to Murder Kerin Pineda
12.

In or about and between April 2016 and May 2016, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the

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defendants OSEAS GONZALEZ, JOSE JONATHAN GUEVARA-CASTRO, VICTOR
LOPEZ-MORALES, EVER MORALES-LOPEZ, DAYID SOSA-GUEVARA and KEVIN
TORRES, together with others, did knowingly and intentionally conspire to cause the death
of Kerin Pineda, in violation of New York Penal Law Sections 125.25(1) and 105.15.
B.

Murder of Kerin Pineda
13.

On or about May 21, 2016, within the Eastern District of New York

and elsewhere, the defendants OSEAS GONZALEZ, JOSE JONATHAN GUEVARA­
CASTRO, VICTOR LOPEZ-MORALES, EVER MORALES-LOPEZ, DAVID SOSA­
GUEVARA and KEVIN TORRES, together with others, with intent to cause the death of
another person, to wit: Kerin Pineda, did knowingly and intentionally cause his death, in
violation of New York Penal Law Sections 125.25(1) and 20.00.
RACKETEERING ACT THREE
(Conspiracy to Murder Rival Gang Members and
Attempted Murders of John Doe #1 and John Doe #2)
14.

The defendants CARLOS ALFARO and OSEAS GONZALEZ,

together with others, committed the following acts, any one of which alone constitutes
Racketeering Act Three:

A.

Conspiracy to Murder
15.

In or about July 2016, within the Eastern District of New York and

elsewhere, the defendants CARLOS ALF ARO and OSEAS GONZALEZ, together with
others, did knowingly and intentionally conspire to cause the death of rival gang members, in
violation of New York Penal Law Sections 125.25(1) and 105.15.

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B.

Attempted Murder of John Doe # 1
16.

On or about July 18, 2016, within the Eastern District of New York, the

defendants CARLOS ALF ARO and OSEAS GONZALEZ, together with others, did
knowingly and intentionally attempt to cause the death of another person, to wit: John Doe
#1, an individual whose identity is known to the Grand Jury, in violation of New York Penal
Law Sections 125.25(1), 110.00 and 20.00.
C.

Attempted Murder of John Doe #2
17.

On or about July 18, 2016, within the Eastern District ofNew York, the

defendants CARLOS ALF ARO and OSEAS GONZALEZ, together with others, did
knowingly and intentionally attempt to cause the death of another person, to wit: John Doe
#2, an individual whose identity is known to the Grand Jury, in violation of New York Penal
Law Sections 125.25(1), 110.00 and 20.00.
RACKETEERING ACT FOUR
(Conspiracy to Murder Josue Amaya-Leonor and Murder of Josue Amaya-Leonor)
18.

The defendants CARLOS ALFARO, JOSE MOISES BLANCO,

OSEAS GONZALEZ and VICTOR LOPEZ-MORALES, together with others, committed
the following acts, either one of which alone constitutes Racketeering Act Four:

A.

Conspiracy to Murder Josue Amaya-Leonor
19.

In or about and between August 2016 and September 2016, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants CARLOS ALFARO, JOSE MOISES BLANCO, OSEAS GONZALEZ and
VICTOR LOPEZ-MORALES, together with others, did knowingly and intentionally

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conspire to cause the death of Josue Amaya-Leonor, in violation of New York Penal Law
Sections 125.25(1) and 105.15.
B.

Murder of Josue Amaya-Leonor
20.

On or about September 4, 2016, within the Eastern District of New

York and elsewhere, the defendants CARLOS ALF ARO, JOSE MOISES BLANCO,
OSEAS GONZALEZ and VICTOR LOPEZ-MORALES, together with others, with intent to
cause the death of another person, to wit: Josue Amaya-Leonor, did knowingly and
intentionally cause his death, in violation of New York Penal Law Sections 125.25(1) and
20.00.
RACKETEERING ACT FIVE
(Conspiracy to Murder Javier Castillo and Murder of Javier Castillo)
21.

The defendant KEVIN TORRES, together with others, committed the

following acts, either one of which alone constitutes Racketeering Act Five:
A.

Conspiracy to Murder Javier Castillo
22.

In or about October 2016, within the Eastern District ofNew York and

elsewhere, the defendant KEVIN TORRES, together with others, did knowingly and
intentionally conspire to cause the death of Javier Castillo, in violation of New York Penal
Law Sections 125.25(1) and 105.15.

B.

Murder of Javier Castillo
23.

On or about October 10, 2016, within the Eastern District of New York

and elsewhere, the defendant KEVIN TORRES, together with others, with intent to cause the
death of another person, to wit: Javier Castillo, did knowingly and intentionally cause his
death, in violation ofNew York Penal Law Sections 125.25(1) and 20.00.
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RACKETEERING ACT SIX
(Conspiracy to Murder Carlos Ventura-Zelaya and Murder of Carlos Ventura-Zelaya)
24.

The defendant CARLOS ALF ARO, together with others, committed

the following acts, either one of which alone constitutes Racketeering Act Six:
A.

Conspiracy to Murder Carlos Ventura-Zelaya
25.

In or about and between September 2016 and October 2016, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant CARLOS ALF ARO, together with others, did knowingly and intentionally
conspire to cause the death of Carlos Ventura-Zelaya, in violation of New York Penal Law
Sections 125.25(1) and 105.15.

B.

Murder of Carlos Ventura-Zelaya
26.

On or about October 14, 2016, within the Eastern District of New York

and elsewhere, the defendant CARLOS ALF ARO, together with others, with intent to cause
the death of another person, to wit: Carlos Ventura-Zelaya, did knowingly and intentionally
cause his death, in violation of New York Penal Law Sections 125.25(1) and 20.00.
RACKETEERING ACT SEVEN
(Conspiracy to Murder Angel Soler and Murder of Angel Soler)
27.

The defendants VICTOR LOPEZ-MORALES and DAVID SOSA-

GUEVARA, together with others, committed the following acts, either one of which alone
constitutes Racketeering Act Seven:

A.

Conspiracy to Murder Angel Soler
28.

In or about July 2017, within the Eastern District of New York and

elsewhere, the defendants VICTOR LOPEZ-MORALES and DAVID SOSA-GUEVARA,

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together with others, did knowingly and intentionally conspire to cause the death of Angel
Soler, in violation of New York Penal Law Sections 125.25(1) and 105.15.

B.

Murder of Angel Soler
29.

On or about July 21, 2017, within the Eastern District ofNew York, the

defendants VICTOR LOPEZ-MORALES and DAYID SOSA-GUEVARA, together with
others, with intent to cause the death of another person, to wit: Angel Soler, did knowingly
and intentionally cause his death, in violation of New York Penal Law Sections 125.25(1)
and 20.00.
RACKETEERING ACT EIGHT
(Kidnapping Conspiracy)
30.

In or about August 2017, within the Eastern District of New York and

elsewhere, the defendants VICTOR LOPEZ-MORALES and DAYID SOSA-GUEVARA,
together with others, did knowingly and intentionally conspire to kidnap John Doe #3, an
individual whose identity is known to the Grand Jury, in violation of New York Penal Law
Sections 135.20 and 105.15.
RACKETEERING ACT NINE
(Conspiracy to Distribute Marijuana)
31.

In or about and between January 2016 and the date of this Indictment,

both dates being approximate and inclusive, within the Eastern District of New York and
elsewhere, the defendants CARLOS ALFARO, JOSE MOISES BLANCO, OSEAS
GONZALEZ, JOSE JONATHAN GUEVARA-CASTRO, VICTOR LOPEZ-MORALES
and DAVID SOSA-GUEVARA, together with others, did knowingly and intentionally
conspire to distribute and possess with intent to distribute a controlled substance, which

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offense involved a substance containing marijuana, a Schedule I controlled substance, for
remuneration, in violation of Title 21, United States Code, Sections 846 and 841(b)(l)(D).
RACKETEERING ACT TEN
(Conspiracy to Distribute Cocaine and Marijuana)
32.

In or about and between April 2016 and October 2017, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants EVER MORALES-LOPEZ and KEVIN TORRES, together with others, did
knowingly and intentionally conspire to distribute and possess with intent to distribute one or
more controlled substances, which offense involved (a) a substance containing cocaine, a
Schedule II controlled substance, contrary to Title 21, United States Code, Sections 84l(a)(l)
and 84l(b)(l)(C); and (b) a substance containing marijuana, a Schedule I controlled
substance, for remuneration, in violation of Title 21, United States Code, Sections 846 and
84l(b)(l)(D).
(Title 18, United States Code, Sections 1962(c), 1963 and 3551 et seg.)
COUNT TWO
(Racketeering Conspiracy)
33.

The allegations contained in paragraphs one through five are realleged

and incorporated as if fully set forth in this paragraph.
34.

On or about and between January 1, 2015 and the date of this

Indictment, both dates being approximate and inclusive, within the Eastern District of New
York and elsewhere, the defendants CARLOS ALFARO, also known as "Russo," JOSE
MOISES BLANCO, also known as "Cuervo," OSEAS GONZALEZ, also known as
"Manota" and "Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as
"Suspechoso," VICTOR LOPEZ-MORALES, also known as "Persa," EVER MORALES11

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LOPEZ, also known as "Kien," "Inke" and "White Boy," DAVID SOSA-GUEVARA, also
known as "Risky," and KEVIN TORRES, also known as "Quieto" and "Inquieto," together
with others, being persons employed by and associated with the MS-13, an enterprise
engaged in, and the activities of which affected, interstate and foreign commerce, did
knowingly and intentionally conspire to violate Title 18, United States Code, Section
1962(c), that is, to conduct and participate, directly and indirectly, in the conduct of the
affairs of the MS-13 through a pattern of racketeering activity, as that tennis defined in Title
18, United States Code, Sections 1961(1) and 1961(5).
35.

The pattern of racketeering activity through which the defendants

CARLOS ALFARO, JOSE MOISES BLANCO, OSEAS GONZALEZ, JOSE JONATHAN
GUEVARA-CASTRO, VICTOR LOPEZ-MORALES, EVER MORALES-LOPEZ, DAVID
SOSA-GUEVARA and KEVIN TORRES, together with others, agreed to conduct and
participate in the conduct of the affairs of the MS-13 consisted of the racketeering acts set
forth in paragraphs eight through thirty-two of Count One of this Indictment, as Racketeering
Acts One through Ten, which are realleged and incorporated as if fully set forth in this
paragraph. Each defendant agreed that a conspirator would commit at least two acts of
racketeering in the conduct of the affairs of the enterprise.
(Title 18, United States Code, Sections 1962(d), 1963 and 3551 et seq.)
COUNT THREE
(Conspiracy to Murder Oscar Acosta)
36.

At all times relevant to this Indictment, the MS-13, as more fully

described in paragraphs one through five, which are realleged and incorporated as if fully set
forth in this paragraph, including its leadership, membership and associates, constituted an
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"enterprise" as defined in Section 1959(b)(2) of Title 18, United States Code, that is, a group
of individuals associated in fact that was engaged in, and the activities of which affected,
interstate and foreign commerce. The enterprise constituted an ongoing organization whose
members functioned as a continuing unit for a common purpose of achieving the objectives
of the enterprise.
37.

At all times relevant to this Indictment, the MS-13, through its

members and associates, engaged in racketeering activity, as defined in Title 18, United
States Code, Sections 1959(b)(l) and 1961(1), that is, acts and threats involving murder,
extortion and robbery, that are chargeable under New York Penal Law and punishable by
imprisonment for more than one year, acts indictable under Title 18, United States Code,
Sections 1512 (relating to tampering with a witness, victim or informant) and 1513 (relating
to retaliating against a witness, victim or informant), and offenses involving narcotics
trafficking, punishable under Title 21, United States Code, Sections 841 and 846.
38.

In or about and between March 2016 and April 2016, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant KEVIN TORRES, also known as "Quieto" and "Inquieto," together with others,
for the purpose of gaining entrance to and maintaining and increasing position in the MS-13,
an enterprise engaged in racketeering activity, did knowingly and intentionally conspire to
murder Oscar Acosta, in violation of New York Penal Law Sections 125.25(1) and 105.15.
(Title 18, United States Code, Sections 1959(a)(5) and 3551 et seq.)

13

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COUNTFOUR
(Murder of Oscar Acosta)
39.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
40.

On or about April 29, 2016, within the Eastern District of New York

and elsewhere, the defendant KEVIN TORRES, also known as "Quieto" and "Inquieto,"
together with others, for the purpose of gaining entrance to and maintaining and increasing
position in the MS-13, an enterprise engaged in racketeering activity, did knowingly and
intentionally murder Oscar Acosta, in violation of New York Penal Law Sections 125.25(1)
and 20.00.
(Title 18, United States Code, Sections 1959(a)(l), 2 and 3551 et seq.)
COUNT FIVE
(Conspiracy to Murder Kerin Pineda)
41.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
42.

In or about and between April 2016 and May 2016, within the Eastern

District of New York and elsewhere, the defendants OSEAS GONZALEZ, also known as
"Manota" and "Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as
"Suspechoso," VICTOR LOPEZ-MORALES, also known as "Persa," EVER MORALESLOPEZ, also known as "Kien," "Ink.e" and "White Boy," DAVID SOSA-GUEVARA, also
known as "Risky," and KEVIN TORRES, also known as "Quieto" and "Inquieto," together
with others, for the purpose of gaining entrance to and maintaining and increasing position in
the MS-13, an enterprise engaged in racketeering activity, did knowingly and intentionally

14

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conspire to murder Kerin Pineda, in violation of New York Penal Law Sections 125.25(1)
and 105.15.
(Title 18, United States Code, Sections 1959(a)(5) and 3551 et seq.)
COUNT SIX
(Murder of Kerin Pineda)
43.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
44.

On or about May 21, 2016, within the Eastern District of New York

and elsewhere, the defendants OSEAS GONZALEZ, also known as "Manota" and
"Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as "Suspechoso,"
VICTOR LOPEZ-MORALES, also known as "Persa," EVER MORALES-LOPEZ, also
known as "Kien," "Inke" and "White Boy," DAVID SOSA-GUEVARA, also known as
"Risky," and KEVIN TORRES, also known as "Quieto" and "Inquieto," together with
others, for the purpose of gaining entrance to and maintaining and increasing position in the
MS-13, an enterprise engaged in racketeering activity, did knowingly and intentionally
murder Kerin Pineda, in violation of New York Penal Law Sections 125.25(1) and 20.00.
(Title 18, United States Code, Sections 1959(a)(l), 2 and 3551 et seq.)
COUNT SEVEN
(Conspiracy to Murder Rival Gang Members)
45.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
46.

In or about July 2016, within the Eastern District of New York and

elsewhere, the defendants CARLOS ALF ARO, also known as "Russo," and OSEAS

15

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GONZALEZ, also known as "Manota" and "Cordero," together with others, for the purpose
of gaining entrance to and maintaining and increasing position in the MS-13, an enterprise
engaged in racketeering activity, did knowingly and intentionally conspire to murder one or
more rival gang members, in violation of New York Penal Law Sections 125.25(1) and
105.15.
(Title 18, United States Code, Sections 1959(a)(5) and 3551 et seq.)
COUNT EIGHT
(Attempted Murder of John Doe # 1)
47.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
48.

On or about July 18, 2016, within the Eastern District of New York, the

defendants CARLOS ALF ARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, for the purpose of gaining entrance
to and maintaining and increasing position in the MS-13, an enterprise engaged in
racketeering activity, did knowingly and intentionally attempt to murder John Doe #1, in
violation of New York Penal Law Sections 125.25(1), 110.00 and 20.00.
(Title 18, United States Code, Sections 1959(a)(5), 2 and 3551 et seq.)
COUNT NINE
(Assault of John Doe #1 with Dangerous Weapons)
49.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
50.

On or about July 18, 2016, within the Eastern District of New York, the

defendants CARLOS ALF ARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, for the purpose of gaining entrance
16

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to and maintaining and increasing position in the MS-13, an enterprise engaged in
racketeering activity, did knowingly and intentionally assault John Doe #1 with one or more
dangerous weapons, to wit: one or more firearms and a machete, in violation of New York
Penal Law Sections 120.05(2) and 20.00.
(Title 18, United States Code, Sections 1959(a)(3), 2 and 3551 et seq.)
COUNT TEN
(Brandishing and Discharge of Firearms During Crimes of Violence:
Attempted Murder and Assault of John Doe # 1)
51.

The allegations contained in paragraphs one through five, 3 6 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
52.

On or about July 18, 2016, within the Eastern District ofNew York, the

defendants CARLOS ALF ARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, did knowingly and intentionally
use and carry one or more firearms during and in relation to one or more crimes of violence,
to wit: the crimes charged in Counts One, Eight and Nine, and did knowingly and
intentionally possess one or more firearms in furtherance of such crimes of violence, one or
more of which firearms was brandished and discharged.
(Title 18, United States Code, Sections 924(c)(l)(A)(i), 924(c)(l)(A)(ii),
924(c)(l)(A)(iii), 2 and 3551 et~.)
COUNT ELEVEN
(Attempted Murder of John Doe #2)
53.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.

17

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 18 of 26 PageID #: 18

54.

On or about July 18, 2016, within the Eastern District of New York, the

defendants CARLOS ALFARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, for the purpose of gaining entrance
to and maintaining and increasing position in the MS-13, an enterprise engaged in
racketeering activity, did knowingly and intentionally attempt to murder John Doe #2, in
violation of New York Penal Law Sections 125.25(1), 110.00 and 20.00.
(Title 18, United States Code, Sections 1959(a)(5), 2 and 3551 et seq.)
COUNT TWELVE
(Assault of John Doe #2 with Dangerous Weapons)
55.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
56.

On or about July 18, 2016, within the Eastern District of New York, the

defendants CARLOS ALFARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, for the purpose of gaining entrance
to and maintaining and increasing position in the MS-13, an enterprise engaged in
racketeering activity, did knowingly and intentionally assault John Doe #2 with one or more
dangerous weapons, to wit: one or more firearms and a machete, in violation of New York
Penal Law Sections 120.05(2) and 20.00.
(Title 18, United States Code, Sections 1959(a)(3), 2 and 3551 et seq.)
COUNT THIRTEEN
(Brandishing and Discharge of Firearms During Crimes of Violence:
Attempted Murder and Assault of John Doe #2)
57.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
18

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 19 of 26 PageID #: 19

58.

On or about July 18, 2016, within the Eastern District ofNew York, the

defendants CARLOS ALF ARO, also known as "Russo," and OSEAS GONZALEZ, also
known as "Manota" and "Cordero," together with others, did knowingly and intentionally
use and carry one or more firearms during and in relation to one or more crimes of violence,
to wit: the crimes charged in Counts One, Eleven and Twelve, and did knowingly and
intentionally possess one or more firearms in furtherance of such crimes of violence, one or
more of which firearms was brandished and discharged.
(Title 18, United States Code, Sections 924(c)(l)(A)(i), 924(c)(l)(A)(ii),
924(c)(l)(A)(iii), 2 and 3551 et~.)
COUNT FOURTEEN
(Conspiracy to Murder Josue Amaya-Leonor)
59.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
60.

In or about and between August 2016 and September 2016, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants CARLOS ALFARO, also known as "Russo," JOSE MOISES BLANCO, also
known as "Cuervo," OSEAS GONZALEZ, also known as "Manota" and "Cordero," and
VICTOR LOPEZ-MORALES, also known as "Persa," together with others, for the purpose
of gaining entrance to and maintaining and increasing position in the MS-13, an enterprise
engaged in racketeering activity, did knowingly and intentionally conspire to murder Josue
Amaya-Leonor, in violation ofNew York Penal Law Sections 125.25(1) and 105.15.
(Title 18, United States Code, Sections l 959(a)(5) and 3551 et seq.)

19

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 20 of 26 PageID #: 20

COUNT FIFTEEN
(Murder of Josue Amaya-Leonor)
61.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
62.

On or about September 4, 2016, within the Eastern District of New

York and elsewhere, the defendants CARLOS ALFARO, also known as "Russo," JOSE
MOISES BLANCO, also known as "Cuervo," OSEAS GONZALEZ, also known as
"Manota" and "Cordero," and VICTOR LOPEZ-MORALES, also known as "Persa,"
together with others, for the purpose of gaining entrance to and maintaining and increasing
position in the MS-13, an enterprise engaged in racketeering activity, did knowingly and
intentionally murder Josue Amaya-Leonor, in violation of New York Penal Law Sections
125.25(1) and 20.00.
(Title 18, United States Code, Sections 1959(a)(l), 2 and 3551 et seq.)
COUNT SIXTEEN
(Accessory After the Fact)
63.

On or about September 4, 2016, within the Eastern District of New

York and elsewhere, the defendants JOSE MOISES BLANCO, also known as "Cuervo," and
VICTOR LOPEZ-MORALES, also known as "Persa/' knowing that one or more offenses
against the United States had been committed, to wit: the offenses charged in Counts
Fourteen and Fifteen, did knowingly and intentionally receive and assist one or more
offenders, in order to hinder and prevent the offenders' apprehension, trial and punishment.
(Title 18, United States Code, Sections 3 and 3551 et seq.)

20

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 21 of 26 PageID #: 21

COUNT SEVENTEEN
(Conspiracy to Murder Javier Castillo)
64.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
65.

In or about October 2016, within the Eastern District of New York and

elsewhere, the defendant KEVIN TORRES, also known as "Quieto" and "Inquieto," together
with others, for the purpose of gaining entrance to and maintaining and increasing position in
the MS-13, an enterprise engaged in racketeering activity, did knowingly and intentionally
conspire to murder Javier Castillo, in violation ofNew York Penal Law Sections 125.25(1)
and 105.15.
(Title 18, United States Code, Sections 1959(a)(5) and 3551 et seq.)
COUNT EIGHTEEN
(Murder of Javier Castillo)
66.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
67.

On or about October 10, 2016, within the Eastern District of New York

and elsewhere, the defendant KEVIN TORRES, also known as "Quieto" and "lnquieto,"
together with others, for the purpose of gaining entrance to and maintaining and increasing
position in the MS-13, an enterprise engaged in racketeering activity, did knowingly and
intentionally murder Javier Castillo, in violation of New York Penal Law Sections 125.25(1)
and 20.00.
(Title 18, United States Code, Sections 1959(a)(l), 2 and 3551 et seq.)

21

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 22 of 26 PageID #: 22

COUNT NINETEEN
(Conspiracy to Murder Carlos Ventura-Zelaya)
68.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
69.

In or about and between September 2016 and October 2016, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendant CARLOS ALFARO, also known as "Russo," together with others, for the purpose
of gaining entrance to and maintaining and increasing position in the MS-13, an enterprise
engaged in racketeering activity, did knowingly and intentionally conspire to murder Carlos
Ventura-Zelaya, in violation ofNew York Penal Law Sections 125.25(1) and 105.15.
(Title 18, United States Code, Sections 1959(a)(5) and 3551 et seq.)
COUNT TWENTY
(Murder of Carlos Ventura-Zelaya)
70.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
71.

On or about October 14, 2016, within the Eastern District of New York

and elsewhere, the defendant CARLOS ALFARO, also known as "Russo," together with
others, for the purpose of gaining entrance to and maintaining and increasing position in the
MS-13, an enterprise engaged in racketeering activity, did knowingly and intentionally
murder Carlos Ventura-Zelaya, in violation ofNew York Penal Law Sections 125.25(1) and
20.00.
(Title 18, United States Code, Sections 1959(a)(l), 2 and 3551 et seq.)

22

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 23 of 26 PageID #: 23

COUNT TWENTY-ONE
(Brandishing and Discharge of a Firearm During Crimes of Violence:
Carlos Ventura-Zelaya Murder)
72.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
73.

On or about October 14, 2016, within the Eastern District of New York

and elsewhere, the defendant CARLOS ALFARO, also known as "Russo," together with
others, did knowingly and intentionally use and carry a firearm during and in relation to one
or more crimes of violence, to wit: the crimes charged in Counts One and Twenty, and did
knowingly and intentionally possess a firearm in furtherance of such crimes of violence,
which firearm was brandished and discharged.
(Title 18, United States Code, Sections 924(c)(l)(A)(i), 924(c)(l)(A)(ii),
924(c)(l)(A)(iii), 2 and 3551 et WJ..)
COUNT TWENTY-TWO
(Causing the Death of Carlos Ventura-Zelaya Through the Use of a Firearm)
74.

The allegations contained in paragraphs one through five, 36 and 37 are

realleged and incorporated as if fully set forth in this paragraph.
75.

On or about October 14, 2016, within the Eastern District of New York

and elsewhere, the defendant CARLOS ALFARO, also known as "Russo," together with
others, in the course of a violation of Title 18, United States Code, Section 924(c), to wit: the
crime charged in Count Twenty-One, did knowingly and intentionally cause the death of a
person through the use of a firearm, which killing was a murder as defined in Title 18,
United States Code, Section 111 l(a), in that the defendant, together with others, with

23

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 24 of 26 PageID #: 24

malice aforethought, did unlawfully kill Carlos Ventura-Zelaya willfully, deliberately,
maliciously and with premeditation.
(Title 18, United States Code, Sections 924(j)(l), 2 and 3551 et seq.)
COUNT TWENTY-THREE
(Conspiracy to Distribute Marijuana)
76.

In or about and between January 2016 and the date of this Indictment,

both dates being approximate and inclusive, within the Eastern District of New York and
elsewhere, the defendants CARLOS ALFARO, also known as "Russo," JOSE MOISES
BLANCO, also known as "Cuervo," OSEAS GONZALEZ, also known as "Manota" and
"Cordero," JOSE JONATHAN GUEVARA-CASTRO, also known as "Suspechoso,"
VICTOR LOPEZ-MORALES, also known as "Persa," and DAVID SOSA-GUEVARA, also
known as "Risky," together with others, did knowingly and intentionally conspire to
distribute and possess with intent to distribute a controlled substance, which offense involved
a substance containing marijuana, a Schedule I controlled substance, for remuneration,
contrary to Title 21, United States Code, Section 84l(a)(l).
(Title 21, United States Code, Sections 846 and 84l(b)(l)(D); Title 18, United
States Code, Sections 3551 et seq.)
COUNT TWENTY-FOUR
(Conspiracy to Distribute Cocaine and Marijuana)
77.

In or about and between April 2016 and October 2017, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants EVER MORALES-LOPEZ, also known as "Kien," "Inke" and "White Boy," and
KEVIN TORRES, also known as "Quieto" and "Inquieto," together with others, did

24

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 25 of 26 PageID #: 25

knowingly and intentionally conspire to distribute and possess with intent to distribute one or
more controlled substances, which offense involved (a) a substance containing cocaine, a
Schedule II controlled substance; and (b) a substance containing marijuana, a Schedule I
controlled substance, for remuneration, contrary to Title 21, United States Code, Section
84l(a)(l).
(Title 21, United States Code, Sections 846, 84l(b)(l)(C) and 84l(b)(l)(D);
Title 18, United States Code, Sections 3551 et seq.)

A TRUE BILL

RICHARD P. DONOGHUE
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK

25

 Case 2:20-cr-00251-JFB Document 1 Filed 07/09/20 Page 26 of 26 PageID #: 26

F.f#: 2020ROOS59
FORM.DBD-34
JUN.BS

No.

UNITED STATES DISTRICT COURT
EASTERN District of NEW YORK ..
CRIMINAL DIVISION

THE UNITED STATES OF AMERICA
vs.

· CARLOS ALFARO, JOSE MOISES BLANCO, OSEAS GONZALEZ. JOSE
JONATHAN GUEVARA~CASTRO, VICTOR LOPEZ-MORALES, EVER
MORALES-LOPEZ, DAVID SOSA-GUEVARA, and KEVIN TORRES,

Defendants.

INDICTMENT
(T. 18, U.S.C., §§ 924(c)(l)(A)(i), 924(c)(l)(A)(ii), 924(c)(l)(A)(ili),
924G)(l), 1959(a)(l), 1959(a)(3), 1959(a)(5), 1962(c), 1962(d), 1963, 2, 3
and 3551 et~.; T. 21, U.S.C., §§ 846, 841(b)(l)(C) and 84l(b)(l)(D))

Foreperson
.

.

Filed in open court this _________________ day. of ------------ A.D. 20 ·

·

Bail,$----------. ------------------------- ·. ------

AUSAs Paul Scotti and Justina Geraci, (631) 715-7836/-7835

Clerk

 Case 2:20-cr-00251-JFB Document 1-1 Filed 07/09/20 Page 1 of 1 PageID #: 27

INFORMATION SHEET
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

1.

Title of Case: United States v. Carlos Alfaro. et al.

2.

Related Magistrate Docket Number(s ): NIA._ _...

3.

Arrest Date: NIA

4.

Nature of offense(s):

*

*

JUL 09 2020

LON ..... , ____ ,\:"..)

V,

•

:CE

c--,--IRA---2~o
.....-----'2~--'5~---r
AZRACK,J.

IZl Felony
D

Misdemeanor

LOCKE,M.J.

5.

Related Cases - Title and Docket No(s). (Pursuant to Rule 50.3.2 of the Local
E.D.N.Y. Division of Business Rules): US v. Contreras, et al. (16-cr-403)(S-7)(JFB);
US v. Gomez, (17-cr-104)(JFB); US v. Hernandez-Gomez, (l 7-cr-94)(JFB)

6.

Projected Length of Trial:

Less than 6 weeks

D

More than 6 weeks

llt

7.

County in which crime was allegedly committed: Nassau/Suffolk_ _ _ _ _ __
(Pursuant to Rule 50.l(d) of the Local E.D.N.Y. Division of Business Rules)

8.

Was any aspect of the investigation, inquiry and prosecution giving rise to the case
pending or initiated before March 10, 2012. 1

DYes IZI No

9.

Has this indictment/information been ordered sealed?

IZI Yes D No

10.

Have arrest warrants been ordered?

IZl Yes DNo

11.

Is there a capital count included in the indictment?

IZl Yes DNo

RICHARDP.DONOGHUE
By:
0

Assist
U. . ttomey
(631) 715-7835

Judge Brodie will not accept cases that were initiated before March 10, 2012.
Rev. 10/04/12

 UI JU3llU::

Case 2:20-cr-00251-JFB Document 1-2 Filed 07/09/20 Page 1 of 1 PageID #: 28

TO: Clerk's Office
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

FILED

IN CLF.Rl<'S OFFICE
U.S. DISTRICT COURT c.O.N.Y.

*

'JUL 09 2020

LONG ISLAND OFFICE

APPLICATION FOR LEAVE
TO FILE DOCUMENT UNDER SEAL

A) If pursuant to a prior Court Order:

••••••••••••••••••••••••••••••••
UNITED STATES .
-v.-

CR

CARLOS ALFARO et al.

*

Docket Number of Case in Which Entered:- - - - - - - Judge/Magistrate Judge: _ _ _ _ _ _ _ _ _ _ _ __
Date Entered:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

20
Docket Number

••••••••••••••••••••••••••••••••
SUBMITTED BY: Plaintiff__ Defendant__ DOJ ___{__
Name: AUSA Justina L. Geraci
Firm Name: USAO EDNY
Address: 610 Federal Plaza
Central Islip. NY 11722
Phone Number: (631) 715-7835
E-Mail Address: justina.geraci@usdoj.gov

AZRACK,J.

B) If a rull!'. application, the statute, regulation, or other legal basis that

authorizes filing under seal
Flight risk nfnnt-nf-cnstnd,y defoadaats beiag charged

LOCKE,M.J.

ORDERED SEALED AND PLACED IN THE CLERK'S OFFICE,
AND MAY NOT BE UNSEALED UNLESS ORDERED BY
THE COURT.

INDICATE UPON TIIE PUBLIC DOCKET SHEET: YES
NO ✓
If yes, state description of document to be entered on docket sheet:

DA1ED: Central Islip

, NEW YORK

----,-_L

/s/_ Anne
Y.
July 9, 21c
/_
)_
- _ Shields
____,_ _
U.S. MAGISTRATE JUDGE

C?'

RECEIVED IN CLERK'S OFFICE-=J=ul'"'-y...a.9...:,2=-=0=20=-------DATE
MANDATORY CERTIFICATION OF SERVICE:
A,)_ A copy of this application either has been or wil
the following other statute or regulation:_ _; or C.) .

rties to this action, B.) _ Service is excused by 31 U.S.C. 3730(b), or by
submitted, and flight public safety, or security are significant concerns.

(Checkone)
DATE

SIGN

RE