IS:/ 1 2 3 4 5 - (") ~ C":>r- c::::J ~!;] -;;:;:;:; 6 6?1::::: UJ-t-~/l 7 UNITED STATES DISTRICT COURT 8 June 2013 Grand Jury 10 11 UNITED STATES OF AMERICA, ) 12 Plaintiff, 13 v. 14 15 16 17 18 19 20 21 22 24 25 26 27 28 ) No. 1 5 - .. -. - I N D I C T M E N T ) LEONEL LAREDO, aka "Wizard," aka "Wiz," aka "WI aka "Leo," aka "Brother-in-Law," JESUS CERVANTES, .aka "B-Bad," aka "Jessica," aka "Estela," MARCOS LOPEZ, aka "Marcia,". aka "Monica," HECTOR MARTINEZ, aka "Liar-Liar," MARIANA LAREDO VICTOR ESPINOZA, aka "Terco," MAX MAESTAS aka "Snow, " RENE JUAREZ, aka "Scrappy," ALBERTO SIFUENTES, aka "Bluebird," JAVIER MANUEL ULLOA, aka "Yogi," II I 23 ) I I c: (;"} -o ::Jc .r::- j FOR THE CENTRAL DISTRICT OF CALIFORNIR 9 ~ ;b. I ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )' ) ) ) ) ) ) ) [18 U.S.C. ? 1962(d): Racketeer Influenced and Corrupt Organizations Conspiracy; 18 u.s.c. ? 1959(a): Violent Crime in Aid of Racketeering; 21 U.S.C. ? 846: Conspiracy Distribute and Possess with Intent to Distribute Methamphetamine, Marijuana, Heroin, and Cocaine; 21 U.S.C. ?? 841 (a) (1), 841 (b) (1) (A)- (D): Distribution of, and Possession with Intent to Distribute, Methamphetamine, Marijuana, Heroin, and Cocaine; 18 U.S.C. ? 922(a) (1) (A): Engaging in the Business of Dealing in Firearms Without a License; 18 u.s.c. ? 922 (g) (1): Felon in Possession of a Firearm and/or Ammunition; 18 U.S.C. ? 922 (g) (5): Alien in Possession of a Firearm and/or Ammunition; 18 U.S.C. ? 922 (g) (9): Domestic Violence Misdemeanant in Possession of Firearm and/or Ammunition; 26 U.S.C. ? 5861(d): Possession ""1) -... ,r- rq c; 25 CELINA ARANAr JESSENIA MEDINA 1 JOSE DORAD0 1 aka "Yogi r rr TANNOUS FAZAH 1 aka "Terist 1 11 JOSUE ROJAS 1 aka "Chino 1 11 JOSE GALVEZr aka "PecaS 1 11 EDUARDO AYALA 1 aka "Lal0 1 11 ELEASAR ACOSTA 1 aka "Lucky 1 11 JOSE GRANADOS 1 aka "Tricky 1 11 JOSE CAZERESr aka "Pelon 11 JOSE MANDUJAN0 1 aka "Chuchi 1 11 ARTURO MENDEZ 1 aka "Picachu 1 rr OSCAR OLIVERA AVILA 1 aka "Ruben Ramirez r rr aka "Oscar Olvera 11 aka "Rigo Perez Suarez JOSE SANCHEZ 1 aka "Trouble 1 11 JULIAN BECERRA 1 aka "Julio 1 rr aka "Juan Pablo Perez 1 rr JESSE BARRAZA 1 aka "ChapitOr 11 aka "Chap0 11 GISELLE CAS~ZillO aka "Guera 1 11 BEATRIZ TAVIRAr aka "Betty r rr JESUS MEZAr aka "Chana 1 rr HAYDEE MEDINAr and DAVID PROOr aka "D 1 11 26 Defendants. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 1 15 16 17 18 19 20 1 1 I 21 22 23 24 27 of an Unregistered Firearm; 18 U.S.C. ? 1343: Wire Fraud; 18 U.S.C. ? 2: Aiding and Abetting; 18 U.S.C. ? 1963 1 18 U.S.C. ? 981(a) (1) (C) r 21 u.s.c. ?? 853 and 881 and 28 U.S.C. ? 2461(c): Criminal Forfeiture] 11 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ~~---------------------------) 28 2 1 TABLE OF CONTENTS 2 PAGE 3 Introductory Allegations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 4 A. The Racketeering Enterprise . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5 B. Background of the F13 Gang . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 6 C. Purposes of the Enterprise . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 7 D. The Means and Methods of the Enterprise ............. 10 8 9 Count One ( 18 U. S . C . A. Means by which the Object of the Conspiracy Was to be Accomplished . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 10 11 19 6 2 (d) ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 ? B. Overt Acts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 1. 12 Day-to-Day Management of the F13 Gang Criminal Enterprise . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 13 14 2. The March 2010 Killing of Victim R.A .......... 47 15 3. Drug Trafficking and Unlawful Possession of Firearms . . . . . . . . . . . . . . . . . . . . . . . . 50 16 17 4. Smuggling of Drugs into the LACJ System ....... 62 18 5. Fraudulent Scheme to Obtain Free Telephone Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 19 20 C. Special Sentencing Allegations . . . . . . . . . . . . . . . . . . . . . . 72 21 Counts Two and Three (18 U.S.C. 22 Count Four (21 U.S.C. 23 Counts Five through Twenty-Two (21 U.S.C. 24 Counts Twenty-Three through Forty-One (18 U.S.C. 25 Count Forty-Two (26 U.S.C. 26 Counts Forty-Three through Forty-Five (18 U.S.C. .29 Forfeiture Allegations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116 ? ? 1959(a)) . . . . . . . . . . . . . . . . . . . . 75 846) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78 ? ? 841) .............. 82 ? 922) ...... 100 5861(d)) . . . . . . . . . . . . . . . . . . . . . . . . 111 28 3 ? 1343) ..... 112 The Grand Jury charges: 1 2 3 4 INTRODUCTORY ALLEGATIONS A. THE RACKETEERING ENTERPRISE 1. At all times relevant to this Indictment, defendants 5 LEONEL LAREDO, also known as ("aka") "Wizard," .aka "Wiz," aka 6 "W," aka "Leo," aka "Brother-in-Law" ("L. LAREDO"), JESUS 7 CERVANTES, aka "B-Bad," aka "Jessica," aka "Estela" 8 ("CERVANTES"), MARCOS LOPEZ, aka "Marcia," aka "Monica" 9 ("LOPEZ"), HECTOR MARTINEZ, aka "Liar-Liar" ("MARTINEZ"), 10 MARIANA LAREDO ("M. LAREDO"), VICTOR ESPINOZA, aka "Terco" 11 ("ESPINOZA") , MAX MAESTAS, aka "Snow" 12 aka "Scrappy" ("JUAREZ"), ALBERTO SIFUENTES, aka "Bluebird" 13 ("SIFUENTES"), JAVIER MANUEL ULLOA, aka "Yogi" ("MAESTAS") , RENE JUAREZ, ("ULLOA"), CELINA 14 ARANA ("ARANA") , JESSENIA MEDINA ( "J. MEDINA") , JOSE DORADO, aka 15 "Yogi" 16 GALVEZ, aka "Pecas" 17 ("AYALA") , ELEASAR ACOSTA, aka "Lucky" 18 GRANADOS, aka "Tricky" 19 ("CAZERES"), JOSE MANDUJANO, aka "Chuchi" 20 MENDEZ, aka "Picachu" 21 "Ruben Ramirez," aka "Oscar Olvera," aka "Rigo Perez Suarez" 22 ("AVILA"), JOSE SANCHEZ, aka "Trouble" 23 BECERRA, aka "Julio," aka "Juan Pablo Perez" 24 BARRAZA, aka "Chapito," aka "Chapo" ("BARRAZA"), GISELLE CASADO, 25 aka "Guera" 26 ("TAVIRA") 27 unknown to the Grand Jury; were members and associates of a 28 criminal organization engaged in, among other things, murder, ("DORADO"), TANNOUS FAZAH, aka "Terist" ("FAZAH"), JOSE ("GALVEZ"), EDUARDO AYALA, aka "Lalo" ("ACOSTA") , JOSE ("GRANADOS"), JOSE CAZERES, aka "Pelon" ("MANDUJANO"), ARTURO ("MENDEZ"), OSCAR OLIVERA AVILA, aka ("SANCHEZ"), JULIAN ("BECERRA"), JESSE ("CASADO"), and BEATRIZ TAVIRA, aka "Betty" (collectively, "defendants"), and others known and 4 1 trafficking in narcotics and controlled substances, illegal 2 gambling, wire fraud, and extortion. 3 this organization, known as the Florencia 13 criminal street 4 gang (hereinafter, the "F13 Gang"), operated in the Central 5 District of California and elsewhere. 6 its leadership, members, and associates, constituted an 7 "enterprise," as that term is 8 States Code, Section 1961(4); that is, a group of individuals 9 associated in fact, although not a legal entity, which is At all relevant times, The F13 Gang, including defined in Title 18, United 10 engaged in, and the activities of which affect, interstate and 11 foreign commerce. 12 organization whose members function as a continuing unit for a 13 common purpose of achieving the objectives of the enterprise. 14 B. 15 The enterprise constitutes an ongoing BACKGROUND OF THE F13 GANG 2. The Fl3 Gang is a multi-generational gang founded in 16 Los Angeles, California in the early 1950s. The gang began as a 17 small group of individuals who lived in and around the area of 18 Florence Boulevard, in and near Los Angeles, California. 19 Initially, the gang was primarily involved in street robberies, 20 drug sales, and fighting with rival gang members in "turf 21 battles." 22 increased its membership by absorbing smaller, less powerful 23 local gangs. 24 3. Through the years, however, the gang has dramatically There are at least 22 cliques, or subsets, of the F13 25 Gang that together control an area of approximately three square 26 miles in and around the unincorporated areas of South Los 27 Angeles County. 28 Gangsters, 64th Street, the Termites, the Tiny Locos, Bear Examples of these cliques include the 5 1 Street, the Malditos, and the HP (Huntington Park) Locos. The 2 overall number of F13 Gang cliques has changed over the years as 3 new cliques have been allowed to join the gang, and others have 4 been expelled. 5 changed over time, it is generally understood to be contained 6 within the area bordered by the 10 freeway to the North, 7 Imperial Highway to the South, the 110 freeway to the West, and 8 the 710 freeway to the East; and it now includes at least the 9 unincorporated Florence-Firestone neighborhood (also known as While the F13 Gang's "territory" therefore has 10 Florence-Graham) and parts of several nearby cities, such as 11 Huntington Park, South Gate, Maywood, Bell, and Lynwood. 12 on the strength of its numbers and its reputation for violence, 13 the F13 Gang controls drug trafficking and other illegal 14 activities within this territory. 15 4. Based The F13 Gang is continually engaged in the 16 distribution of multiple controlled substances, including, but 17 not limited to, methamphetamine. 18 using customers, members and associates of the gang regularly 19 sell distributable amounts of drugs to each other and to others 20 who they believe to be "street-level" drug dealers. 21 members and associates also engage in efforts to smuggle 22 controlled substances into California State Prisons and the Los 23 Angeles County Jail ("LACJ") system. 24 5. In addition to supplying drug- F13 Gang To support their drug trafficking and to maintain 25 control over their claimed "territory," F13 Gang members and 26 associates maintain a ready supply of firearms, including 27 handguns, shotguns, rifles, and machineguns. 28 these weapons for profit, using the proceeds from such sales to 6 They also sell 1 purchase drugs and additional firearms, or to pay the required 2 tribute to members of the Mexican Mafia, as discussed below. 3 Such weapons are frequently stolen or unregistered to make it 4 difficult to connect them to the gang member who either used the 5 weapon or obtained it.? 6 destroyed after being used to commit acts of violence on behalf 7 of the enterprise, so continued gun trafficking ensures that the 8 gang maintains ready access to firearms in the future. 9 same time, being publicly known to sell, and therefore possess, Firearms also are often discarded or At the 10 numerous firearms serves the additional purpose of supporting 11 the F13 Gang,s reputation for violence and intimidation. 12 6. The F13 Gang is controlled by members and associates 13 of the "Mexican Mafia,,, or "La Erne.,, The Mexican Mafia is an 14 organized group of individuals that controls much of the drug 15 distribution and other criminal activities within California 16 State Prisons, local county jails, and some federal prisons. 17 Members of the Mexican Mafia come from the ranks of local street 18 gangs, including the F13 Gang. 19 local street gangs to maintain control over their purported 20 territories and for protecting the gangs, members and associates 21 once they enter prison or jail, the Mexican Mafia requires the 22 gangs to collect and pay "taxes,, on all drug trafficking and 23 other illegal activities taking place in those territories 24 (hereinafter, "extortionate taxes"). 25 intended to be controlled by, and are often held in trust by 26 gang members and associates for, the Mexican Mafia member(s) in 27 charge of a particular area. 28 Gang, therefore, regularly pay extortionate taxes to the In return for allowing these These illicit funds are Members and associates of the F13 7 1 incarcerated Mexican Mafia member(s) who oversee the gang; and 2 the collection of extortionate taxes from drug dealers and 3 others engaging in criminal activities within the F13 Gang's 4 territory is a primary task of the gang's leadership on the 5 streets, as is punishing individuals who fail to pay the 6 requisite extortionate taxes. 7 7. Unindicted co-conspirator Arturo Castellanos, aka 8 "Tablas," aka "T" ("Castellanos"), is a Mexican Mafia member and 9 the undisputed leader?of the F13 Gang. Castellanos is serving a 10 term of life imprisonment without the possibility of parole in 11 Pelican Bay State Prison. 12 "reglas," or rules, from his prison cell at Pelican Bay State 13 Prison that were intended to govern all F13 Gang members and 14 associates. 15 Castellanos commanded certain senior gang members and other 16 select individuals to assume leadership positions within the F13 17 Gang's "territory." 18 coordinate the illegal distribution of drugs and other criminal 19 activities, to ensure that extortionate taxes were collected, 20 and otherwise to oversee their respective portions of the gang's 21 territory, such as by resolving disputes both among F13 Gang 22 members and associates and with members of other Los Angeles 23 gangs. 24 punishing F13 Gang members, as well as others residing in F13 25 Gang-controlled territory, who were identified as having 26 cooperated with law enforcement. 27 28 8. In 2004, Castellanos issued written By way of these rules and later directives, These "shot callers" were then ordered to Shot callers were likewise charged with exposing and In 2007, numerous members and associates of the F13 Gang were indicted by a Federal Grand Jury. 8 Following the 1 subsequent conviction and imprisonment of many of the gang's 2 senior members, a leadership vacuum was created. 3 transitional period, defendants CERVANTES and LOPEZ became the 4 F13 Gang's two primary shot callers in or around early 2009; and 5 they assumed control of the gang's territory in South Los 6 Angeles County on behalf of Castellanos. 7 L. LAREDO, who had been a cellmate of Castellanos, was chosen by 8 Castellanos to become the operational leader of the F13 Gang. 9 As such, defendant L. LAREDO became the gang's second-in- After a brief Thereafter, defendant 10 command; and he communicated with defendants CERVANTES and 11 LOPEZ from inside Pelican Bay State Prison, where L. LAREDO was 12 incarcerated, to oversee all criminal activities being committed 13 by F13 Gang members and associates. 14 9. The members of the leadership of the F13 Gang who are 15 incarcerated are able to disseminate instructions to the gang's 16 membership and to maintain control over drug trafficking and 17 other criminal activities within the gang's territory in and 18 around South Los Angeles County through arranged visits by gang 19 associates (generally female) to defendant L. LAREDO and 20 Castellanos in Pelican Bay State Prison, via coded instructions 21 written in letters and "kites" (that is, notes passed among 22 inmates in custodial facilities), and, when possible, by 23 telephone calls from inmates to out-of-custody members and 24 associates (i.e., "jail calls"). 25 c. PURPOSES OF THE ENTERPRISE 10. 26 The purposes of the Fl3 Gang criminal enterprise 27 include, but are not limited to, the following: 28 Ill 9 a. 1 Enriching Castellanos and defendant L. LAREDO 2 through, among other things, the remittance of the proceeds of 3 extortionate taxes to family members, friends, and associates of 4 these two top leaders of the F13 Gang. b. 5 Enriching the members and associates of the F13 6 Gang through, among other things, the control of and 7 participation in the trafficking of controlled. substances and 8 firearms in F13 Gang territory and elsewhere, the operation of 9 illegal gambling establishments (hereinafter referred to as 10 "casitas"), and the collection of extortionate taxes. 11 c. Smuggling controlled substances to F13 Gang 12 members and associates housed in California State Prisons and 13 the LACJ system to be distributed to incarcerated individuals. d. 14 Enabling incarcerated F13 Gang members and 15 associates to fraudulently obtain access to telephone services 16 in order to aid their efforts to smuggle drugs and otherwise to 17 conduct criminal activities. 18 e. Maintaining control over all F13 Gang territory. 19 f. Preserving, protecting, and expanding the power 20 of the F13 Gang through the use of intimidation, violence, 21 threats of violence, assault, and murder. 22 D. 23 THE MEANS AND METHODS OF THE ENTERPRISE 11. The means and methods by which the defendants and 24 other members and associates of the F13 Gang criminal enterprise 25 conduct and participate in the? conduct of the affairs of the F13 26 Gang include: 27 28 a. Members and associates of the F13 Gang commit, attempt to commit, conspire to commit, and threaten to commit 10 1 acts of violence, including, without limitation, murder, 2 assaults, intimidation, and extortion, to preserve, protect, and 3 expand the enterprise's criminal operations. b. 4 Members and associates of the F13 Gang promote a 5 climate of fear through acts of violence and threats to commit 6 acts of violence. c. 7 Leaders of the F13 Gang disseminate rules and 8 orders to be followed by all participants in the F13 Gang 9 criminal enterprise. d. 10 Members and associates of the F13 Gang use the 11 enterprise to commit, attempt to commit, and threaten to commit 12 acts of violence, including, without limitation, murder and 13 assaults, to promote discipline and enforce the rules of the F13 14 Gang. 15. e. Members and associates of the F13 Gang engage in 16 the trafficking of controlled substances and firearms, as well 17 as the collection of extortionate taxes, in order to generate 18 income for the enterprise. 19 f. Members and associates of the F13 Gang, with the 20 permission of the gang's leaders, "tax" drug sales, firearms 21 trafficking, and other profitable illegal activity within F13 22 Gang-controlled territory in order to generate income and 23 control the criminal activity undertaken within such territory. 24 g. Leaders and shot callers within the F13 Gang 25 criminal enterprise control the collection and payment of 26 extortionate taxes to the Mexican Mafia in order to preserve, 27 protect, and expand the enterprise's control of criminal 28 activity undertaken within its territory and to ensure the 11 1 protection of F13 Gang members and associates who are 2 incarcerated. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12 COUNT ONE 1 [18 2 3 1. u.s.c. ? 1962 (d)] Paragraphs One through Eleven of the Introductory 4 Allegations are hereby re-alleged and incorporated by reference 5 as though fully set forth herein. 6 2. Beginning on a date unknown to the Grand Jury, and 7 continuing to on or about August 1, 2013, in Los Angeles County, 8 within the Central District of California, and elsewhere, 9 defendants L. LAREDO, CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, 10 ESPINOZA, MAESTAS, JUAREZ, SIFUENTES, ULLOA, ARANA, J. MEDINA, 11 DORADO, FAZAH, GALVEZ, AYALA, ACOSTA, GRANADOS, CAZERES, 12 MANDUJANO, MENDEZ, AVILA, SANCHEZ, BECERRA, BARRAZA, CASADO, and 13 TAVIRA, and others known and unknown to the Grand Jury, being 14 persons employed by and associated. with the F13 Gang criminal 15 enterprise described in Paragraphs One through Eleven of the 16 Introductory Allegations of this Indictment, which constitutes 17 an "enterprise," as defined in Title 18, United States Code, 18 Section 1961(4), which enterprise engaged in, and the activities 19 of which affected, interstate and foreign commerce, unlawfully 20 and knowingly combined, conspired, confederated, and agreed 21 together and with each other to violate Title 18, United States 22 Code, ?section 1962(c), that is, to conduct and participate, 23 directly and indirectly, in the conduct of the affairs of the 24 enterprise through a pattern of racketeering activity, as that 25 term is defined in Title 18, United States Code, Sections 26 1961(1) and 1961(5), consisting of multiple acts involving: 27 28 (a) the distribution of, possession with intent to distribute, and conspi?racy to distribute and/or possess with 13 1 intent to distribute, controlled substances, in violation of 2 Title 21, United States Code, Sections 841(a) (1), 843(b), and 3 846; (b) 4 5 21a, 31, 182, "187, 189, 190, and 664; and (c) 6 7 murder, in violation of California Penal Code Sections extortion, in violation of California Penal Code Sections 31, 182, 518, 519, 520, 664; 8 and multiple acts indictable under: 9 (d) 10 gambling); and (e) 11 12 Title 18, United States Code, Section 1955 (illegal Title 18, United States Code, Section 1343 (wire fraud). 13 It was a further part of the conspiracy that each defendant 14 agreed that a conspirator would commit at least two acts of 15 racketeering in the conduct of the affairs of the enterprise. 16 A. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE 17 ACCOMPLISHED 18 The object of the conspiracy was to be accomplished, in 19 20 substance, as follows: 1. Castellanos and defendant L. LAREDO, from within 21 Pelican Bay State Prison, would exercise leadership over the F13 22 Gang on behalf of the Mexican Mafia by issuing rules and orders 23 to defendants CERVANTES and LOPEZ, and others known and unknown 24 to the Grand Jury, regarding, among other things, the collection 25 of extortionate taxes and who held positions of authority within 26 the criminal enterprise out on the streets. 27 28 2. Defendants CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, and CASADO, and others known and unknown to the Grand Jury, would 14 1 correspond in writing with Castellanos, defendant L. LAREDO, 2 and/or other inmates at Pelican Bay State Prison in order to 3 receive direction regarding the business of' the F13 Gang 4 criminal enterprise. 3. 5 Defendants CASADO and TAVIRA, and others known and 6 unknown to the Grand Jury, would visit Castellanos, defendant L. 7 LAREDO, and/or other inmates incarcerated at Pelican Bay State 8 Prison in order to relay messages to and from other F13 Gang .9 members and associates . 10 4. Defendants CERVANTES, LOPEZ, MARTINEZ, and ULLOA, and 11 others known and unknown to the Grand Jury, would direct drug 12 trafficking, acts of 13 the enterprise within the territory controlled by the F13 Gang, 14 as well as supervise the collection of extortionate taxes and 15 mediate disputes both among the gang's members and associates 16 and with members of other gangs. 17 5. viole~ce, and other criminal activities of Defendants CERVANTES, LOPEZ, MARTINEZ, MAESTAS, 18 JUAREZ, SIFUENTES, ULLOA, DORADO, MANDUJANO, MENDEZ, and AVILA, 19 and others known and unknown to the Grand Jury, would supply F13 20 Gang members and associates with distributable amounts of 21 controlled substances, including, but not limited to, 22 methamphetamine, marijuana, heroin, and cocaine. 23 6. Defendants JUAREZ and SIFUENTES would sell firearms, 24 including machineguns, shotguns, rifles, and handguns, to 25 members and associates of the F13 Gang. 26 7. Defendants CERVANTES, LOPEZ, ESPINOZA, JUAREZ, 27 SIFUENTES, FAZAH, MANDUJANO, AVILA, and SANCHEZ would possess 28 Ill 15 1 firearms and ammunition in order to further the drug trafficking 2 and other criminal activities of the enterprise. 3 8. Defendants M. LAREDO, BECERRA, and BARRAZA would 4 assist other members of the enterprise by, among other things, 5 distributing and storing illegal controlled substances. 6 9. Defendants CERVANTES, MAESTAS, GRANADOS, CAZERES, 7 MENDEZ, AVILA, and SANCHEZ, and others known and unknown to the 8 Grand Jury, would operate "casitas" within the territory 9 controlled by the F13 Gang and elsewhere, from which F13 Gang 10 members and associates could distribute illegal controlled 11 substances and engage in other illegal activities, including 12 illegal gambling. 13 10. Defendants CERVANTES, LOPEZ, MARTINEZ, ESPINOZA, 14 MAESTAS, ULLOA, DORADO, and FAZAH, and others known and unknown 15 to the Grand Jury, would participate in the disciplining of 16 members and associates of the F13 Gang - or others who are 17 deemed to have interfered with the gang's criminal activities - 18 including, without limitation, through the planning of assaults 19 and murders of such individuals. 20 11. Defendants LOPEZ, MARTINEZ, ULLOA, ARANA, DORADO, 21 FAZAH, GALVEZ, and AYALA, and others known and unknown to the 22 Grand Jury, would participate in efforts by F13 Gang members and 23 associates to smuggle controlled substances, such as 24 methamphetamine, marijuana, heroin, and cocaine, into California 25 State Prisons and the LACJ system, specifically including the 26 North County Correctional Facility located in Castaic, 27 California (hereinafter, "NCCF"). 28 16 l l2. Defendants CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, 2 ESPINOZA, MAESTAS, JUAREZ, ULLOA, ACOSTA, GRANADOS, and CASADO 3 would collect extortionate taxes from the sales of controlled 4 substances, firearms trafficking, and other profitable illegal 5 activities within Fl3 Gang-controlled territory. 6 l3. Defendants ULLOA, ARANA, and J. MEDINA, and others 7 known and unknown to the Grand Jury, would participate in a 8 fraudulent scheme involving the use of false identities to 9 obtain free telephone service for members and associates of the lO Fl3 Gang. ll B. l2 OVERT ACTS In furtherance of the racketeering conspiracy and to l3 accomplish the object of the racketeering conspiracy, defendants l4 L. LAREDO, CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, ESPINOZA, l5 MAESTAS, JUAREZ, SIFUENTES, ULLOA, ARANA, J. MEDINA, DORADO, l6 FAZAH, GALVEZ, AYALA, ACOSTA, GRANADOS, CAZERES, MANDUJANO, l7 MENDEZ, AVILA, SANCHEZ, BECERRA, BARRAZA, CASADO, and TAVIRA, l8 and others known and unknown to the Grand Jury, committed and l9 caused to be committed various overt acts, on or about the 20 following dates, within the Central District of California, and 2l elsewhere, including, but not limited to, the following: 22 Day-to-Day Management of the Fl3 Gang Criminal Enterprise 23 l. On January ll, 2009, defendant L. LAREDO, using coded 24 language in correspondence, told an unindicted co-conspirator 25 that L. LAREDO was waiting for notification as to whether he had 26 become an official member of the Mexican Mafia. 27 28 2. On June ll, 2009, defendant L. LAREDO, using coded language in correspondence, instructed an unindicted col7 1 conspirator to follow up with defendants CERVANTES, LOPEZ, and 2 M. LAREDO regarding correspondence L. LAREDO sent to each of 3 them. 4 3. On September 13, 2009, defendant L. LAREDO, using 5 coded language in correspondence, directed an unindicted co- 6 conspirator to call defendants CERVANTES and LOPEZ and to 7 inquire whether they received L. LAREDO's most recent 8 correspondence. 9 4. On December 14, 2009, defendant JUAREZ, speaking in 10 coded language during a telephone conversation with defendant 11 LOPEZ, inquired as to the status of an unindicted Mexican Mafia 12 member and stated that LOPEZ would know due his status as a shot 13 caller for the F13 Gang. 14 5. On December 14, 2009, defendant LOPEZ, speaking in 15 coded language over the telephone, advised defendant JUAREZ that 16 LOPEZ had received a message from Castellanos and defendant L. 17 LAREDO regarding an unindicted Mexican Mafia member and another 18 unidentified individual, and. directed JUAREZ not to get involved 19 in gang politics within the LACJ system. 20 6. On January 15, 2010, defendant SIFUENTES, speaking in 21 coded language, advised a confidential informant ("CI-1") that 22 Castellanos, who was incarcerated, was in charge of the criminal 23 activities of the F13 Gang on the streets and that SIFUENTES was 24 part of Castellanos's criminal organization. 25 7. On January 15, 2010, defendant SIFUENTES, speaking in 26 coded language over the telephone, informed a CI-1 that 27 incarcerated Mexican Mafia members, like Castellanos, have shot 28 callers who represent them on the streets. 18 1 8. On January 28, 2010, defendant ESPINOZA, speaking in 2 coded language over the telephone, asked defendant SIFUENTES 3 whether an unindicted co-conspirator was the shot caller for the 4 F13 Gang in charge of Huntington Park, California. 5 9. On January 28, 2010, defendant SIFUENTES, speaking in 6 coded language over the telephone, advised defendant ESPINOZA 7 that an unindicted co-conspirator was not one of the F13 Gang's 8 shot callers and that anyone who wanted to know who was in 9 charge of Huntington Park for the gang could call SIFUENTES. 10 10. On January 29, 2010, defendant ESPINOZA, speaking in 11 coded language over the telephone, told defendant SIFUENTES that 12 an unindicted co-conspirator should be assaulted as punishment -13 if he is incorrectly claiming to be a shot caller of the F13 ? 14 Gang. 15 16 . 17 18 11. On F.ebruary 17, 2010, defendant ULLOA, speaking in coded language over the telephone, instructed defendant DORADO to assault an F13 Gang member. 12. On February 17, 2010, defendant DORADO, speaking in 19 coded language .during a telephone conversation with defendant 20 ULLOA, agreed to assault an F13 Gang member. 21 13. On February 17, 2010, defendant ULLOA, speaking in 22 coded language over the telephone, told an unindicted co- 23 conspirator that defendant ARANA serves as an intermediary for 24 ULLOA and that she would immediately relay any information she 25 received to ULLOA. 26 14. On February 17, 2010, defendant LOPEZ, speaking in 27 coded language over the telephone, informed defendant ULLOA that 28 LOPEZ had taken care of a problem relating to the F13 Gang by 19 1 contacting defendant L. LAREDO, who would be sending 2 instructions to incarcerated members of the gang. 3 15. On February 17, 2010, defendant LOPEZ, speaking in 4 coded language over the telephone, advised defendant ULLOA that 5 an Armenian inmate was to be protected while in custody at NCCF. 6 16. On February 18, 2010, defendant ARANA, speaking in 7 coded language over the telephone, relayed to defendant ULLOA 8 the name of the Armenian inmate who was to be protected while in 5 custody at NCCF, which had been provided to ARANA by defendant 10 11 LOPEZ. 17. On February 18, 2010, defendant ULLOA, speaking in 12 coded language over the telephone, told defendant LOPEZ that 13 ULLOA would make sure that an Armenian inmate would be protected 14 at NCCF and that ULLOA would discipline anyone who bothered the 15 inmate?. 16 18. On February 18, 2010, defendant ULLOA, speaking in 17 coded language over the telephone, asked an unindicted co- 18 conspirator to spread the word to other inmates at NCCF that 19 ULLOA wanted an Armenian inmate to be protected while in custody 20 at that facility. 21 19. On February 19, 2010, defendant ULLOA, speaking in 22 coded language over the telephone, informed defendant LOPEZ that 23 ULLOA had asked the inmate in charge of an NCCF dormitory to 24 protect an Armenian inmate who was housed there and that ULLOA 25 had just spoken to defendant CERVANTES. 26 20. On February 22, 2010, an unindicted co-conspirator, 27 speaking in coded language over the telephone, reported to 28 defendant ULLOA that an incarcerated gang member who ULLOA and 20 1 the unindicted co-conspirator had wanted disciplined had been 2 assaulted. 3 21. On February 22, 2010, defendant ULLOA, speaking in 4 coded language over the telephone, confirmed to defendant ARANA 5 that an incarcerated gang member had been violently disciplined. 6 22. On February 24, 2010, defendant ULLOA, speaking in 7 coded language over the telephone, told defendant LOPEZ that 8 ULLOA would be incarcerated for a couple more years and would 9 continue to make money during that time by trafficking drugs 10 inside NCCF. 11 23. On February 26, 2010, an unindicted co-conspirator, 12 speaking in coded language over the telephone, alerted defendant 13 ULLOA that an incarcerated gang member had been telling other 14 inmates that ULLOA and his associates were cooperating with law 15 enforcement. 16 24. On March 14, 2010, defendant ULLOA, speaking in coded 17 language over the telephone, instructed defendant ARANA to relay 18 a message to an unindicted co-conspirator to have a member of 19 the 18th Street gang assaulted. 20 25.. On March 18, 2010, defendant ULLOA, speaking in coded 21 language over the telephone, advised defendant ARANA that 22 defendant CERVANTES outranked defendant LOPEZ within the power 23 structure of the Fl3 Gang. 24 26. On April 8, 2010, defendant LOPEZ, speaking in coded 25 language over the telephone, advised an unindicted co- 26 conspirator who had inquired about the status of a recently- 27 incarcerated individual that LOPEZ could quickly find out what 28 was happening with the individual in custody. 21 1 27. On April 8, 2010, defendant LOPEZ, speaking in coded 2 language over the telephone, instructed an unindicted co- 3 conspirator to tell an inmate in a state prison facility that 4 the inmate could communicate with LOPEZ using the unindicted co- S conspirator as an intermediary. 6 28. On April 15, 2010, defendant MARTINEZ, speaking in 7 coded language over the telephone, told defendant LOPEZ that an 8 unindicted co-conspirator owed MARTINEZ money for the sale of 9 controlled substances. 10 29. On April 15, 2010, defendant MARTINEZ, speaking in 11 coded language over the telephone, advised defendant LOPEZ that 12 MARTINEZ only just now received drugs to sell and would not be 13 able to pay extortionate taxes. 14 30. On April 15, 2010, defendant LOPEZ, speaking in coded 15 language over the telephone, instructed defendant MARTINEZ to 16 collect proceeds of drug sales from an unindicted 17 conspirator, which would be taken by LOPEZ and others. 18 31. co~ On April 15, 2010, defendant MARTINEZ, speaking in 19 coded language over the telephone, told defendant LOPEZ that 20 MARTINEZ was paid back the money he had been owed by an 21 unindicted co-conspirator and that MARTINEZ was going to meet 22 LOPEZ right now. 23 32. On April 15, 2010, defendant MARTINEZ, speaking in 24 coded language over the telephone, asked defendant LOPEZ if 25 LOPEZ had received authorization to discipline an unknown . 26 individual. 27 28 33. On April 15, 2010, defendant LOPEZ, speaking in coded language over the telephone, informed defendant MARTINEZ that 22 1 LOPEZ had spoken to an unindicted co-conspirator and received 2 approval for an unknown individual to be disciplined. 3 34. On April 15, 2010, defendant LOPEZ, speaking in coded 4 language over the telephone, reminded defendant MARTINEZ that an 5 unindicted co-conspirator from Ironwood State Prison who sought 6 to purchase heroin from them would have to pay extortionate 7 taxes to LOPEZ. 8 9 35. On April 21, 2010, defendant L. LAREDO, using coded language in correspondence, advised defendant LOPEZ that L. 10 LAREDO was aware that collections?of extortionate taxes were not 11 going well and that L. LAREDO expected these collections to 12 improve. 13 36. On April 21, 2010, defendant L. LAREDO, using coded 14 language in correspondence, instructed defendant LOPEZ to have 15 defendant CERVANTES meet with any F13 Gang members who were not 16 making sufficient extortionate tax payments. 17 37. On May 7, 2010, defendant LOPEZ, speaking in coded 18 language over the telephone, asked defendant MAESTAS to contact 19 a member of the 18th Street gang who had attempted to meet with 20 defendant ESPINOZA at ESPINOZA's store located on Pacific 21 Boulevard, in Huntington Park, California, within the territory 22 controlled by the F13 Gang. 23 38. On May 7, 2010, defendant MAESTAS, speaking in coded 24 language during a telephone conversation with defendant LOPEZ, 25 agreed to contact an 18th Street gang member who had attempted to 26 meet with defendant ESPINOZA and assured LOPEZ that MAESTAS 27 would resolve the gang member's problem. 28 23 1 39. On May 7, 2010, defendant LOPEZ, speaking in coded 2 language over the telephone, asked defendant GRANADOS whether he 3 knew an unindicted co-conspirator who had an "F13" tattoo on her 4 face. 5 40. On May 7, 2010, defendant GRANADOS, speaking in coded 6 language over the telephone, told defendant LOPEZ that an 7 unindicted co-conspirator who was using GRANADOS's name to give 8 orders, without authorization, needed to be disciplined. 9 41. On May 8, 2010, defendant ACOSTA, speaking in coded 10 language over the telephone from a state prison facility, 11 informed defendant LOPEZ that ACOSTA had collected $1,150 in 12 extortionate taxes for LOPEZ. 13 42. On May 8, 2010, defendant LOPEZ, speaking in coded 14 language over the telephone, directed defendant ACOSTA to have 15 extortionate tax payments collected from within the state prison 16 facility in which ACOSTA was incarcerated delivered directly to 17 LOPEZ. 18 43. On May 8, 2010, defendant ACOSTA, speaking in coded 19 language over the telephone, informed defendant LOPEZ that 20 ACOSTA might lose the use of his cellular telephone in prison 21 because the inmates were expecting correctional officers to 22 search their cells soon. 23 44. On May 8, 2010, defendant ACOSTA, speaking in coded 24 language over the telephone from a state prison facility, 25 confirmed with defendant LOPEZ that an unindicted co-conspirator 26 would deliver extortionate tax proceeds to LOPEZ that same day. 27 28 45. On May 8, 2010, defendant MARTINEZ, speaking in coded language over the telephone, informed defendant LOPEZ that an 24 8 9 47. On May 8, 2010, defendant MARTINEZ, speaking in coded language during a telephone conversation with defendant LOPEZ, 10 agreed to assault an individual who was causing a disruption at 11 defendant ESPINOZA's store. 12 48. On May 8, 2010, defendant MARTINEZ, speaking in coded 13 language over the telephone, apprised defendant LOPEZ of the 14 presence of law enforcement officers in the vicinity of 15 defendant ESPINOZA's store, but noted that the individual who 16 had caused a disruption at ESPINOZA's store needed to be 17 assaulted. 18 49. On May 8, 2010, defendant MARTINEZ, speaking in coded 19 language during a telephone conversation with defendant LOPEZ, 20 explained that MARTINEZ had instructed defendant ESPINOZA to 21 assault an individual who had been was causing a disruption at 22 ESPINOZA's store if the disruptive behavior continued. 23 50. Ort May 9, 2010, defendant ACOSTA, speaking in coded 24 language over the telephone, reported to defendant LOPEZ that 25 ACOSTA was having trouble collecting extortionate taxes within 26 the state prison in which he was housed. 27 28 51. On May 9, 2010, defendant ACOSTA, speaking in coded language over the telephone from a state prison facility, told 25 1 defendant LOPEZ that LOPEZ would receive $600 in extortionate 2 taxes that same day. 3 52. On May 9, 2010, defendant ACOSTA, using a telephone 4 from a state prison facility, read a letter from another inmate 5 regarding the F13 Gang to defendant LOPEZ. 6 53. On May 9, 2010, defendant ACOSTA, speaking in coded 7 language over the telephone from a state prison facility, 8 explained to defendant LOPEZ that a letter from another inmate 9 was suggesting that LOPEZ had allowed other Mexican Mafia 10 members to gain influence in custodial facilities under the 11 control of Castellanos. 12 54. On May 9, 2010, defendant ACOSTA, speaking in coded 13 language during a telephone conversation with defendant LOPEZ, 14 explained that ACOSTA had read a letter from another inmate and, 15 realizing the message it contained was incorrect, knew he had to 16 bring it to the attention of LOPEZ. 17 55. On May 9, 2010, defendant ACOSTA, speaking in coded 18 language over the telephone from a state prison facility, 19 informed defendant LOPEZ that ACOSTA had a way of smuggling 20 contraband into the state prison in which ACOSTA was 21 incarcerated. 22 56. On May 9, 2010, defendant ACOSTA, speaking in coded 23 language over the telephone from a state prison facility, told 24 defendant LOPEZ that communication from the prison in which 25 ACOSTA was housed was limited because correctional officers had 26 confiscated inmates' cellular telephones. 27 28 57. On May 9, 2010, defendant ACOSTA, speaking in coded language over the telephone from a state prison facility, 26 1 reported to defendant LOPEZ that ACOSTA possessed confirmation 2 numbers for wired payments of extortionate taxes, but that the 3 payments had been directed to defendant CASADO. 4 58. On May 11, 2010, defendant LOPEZ, speaking in coded 5 language over the telephone, asked defendant GRANADOS to inquire 6 whether an unindicted co-conspirator knew a particular 7 individual from the "Maywood Locos" gang. 8 59. On May 13, 2010, defendant MAESTAS, speaking in coded 9 language over the telephone, apprised defendant LOPEZ of the 10 status of an unindicted co-conspirator who owed extortionate 11 taxes. 12 60. On May 13, 2010, defendant MAESTAS, speaking in coded 13 language over the telephone, told defendant LOPEZ that the 14 following day MAESTAS would pressure an unindicted co- 15 conspirator to pay extortionate taxes. 16 61. On May 13, 2010, an unindicted co-conspirator, 17 speaking in coded language over the telephone, informed 18 defendant LOPEZ that defendant ESPINOZA had collected 19 extortionate taxes. 20 62. On May 18, 2010, defendant LOPEZ, speaking in coded 21 language over the telephone, confirmed to defendant MARTINEZ 22 that LOPEZ would meet with MARTINEZ and defendant SIFUENTES 23 shortly. 24 63. On May 19, 2010, defendant LOPEZ, speaking in coded 25 language over the telephone, informed 26 LOPEZ had received inmate correspondence from Pelican Bay State 27 Prison, including a letter from defendant L. LAREDO. 28 27 def~ndant CERVANTES that 1 64. On May 19, 2010, defendant LOPEZ, speaking in coded 2 language during a telephone conversation with defendant 3 CERVANTES, explained that one of the inmate letters LOPEZ had 4 received inquired as to why CERVANTES had not responded to 5 correspondence from members of the Mexican Mafia. 6 65. On May 19, 2010, defendant LOPEZ, speaking in coded 7 language over the telephone, advised defendant CERVANTES that 8 Castellanos and defendant L. LAREDO believed that LOPEZ and 9 CERVANTES were not working together to run the F13 Gang. 10 66. On May 19, 2010, defendant LOPEZ, speaking in coded 11 language over the telephone, told defendant CERVANTES that 12 defendant M. LAREDO had complained about LOPEZ's leadership of 13 the F13 Gang. 14 67. On May 19~ 2010, defendant LOPEZ, speaking in coded 15 language during a telephone conversation with defendant 16 CERVANTES, recounted advising defendant M. LAREDO that defendant 17 L. LAREDO should communicate with LOPEZ directly and that L. 18 LAREDO had four different addresses to which he could send 19 letters for LOPEZ. 20 68. On May 19, 2010, defendant CERVANTES, speaking in 21 coded language over the telephone, told defendant LOPEZ that 22 CERVANTES would follow written orders from Castellanos and 23 defendant L. LAREDO, but not orders relayed by defendant M. 24 LAREDO. 25 69. On May 19, 2010, defendant LOPEZ, speaking in coded 26 language over the telephone, informed defendant CERVANTES that 27 LOPEZ had told defendant M. LAREDO not to interfere with his 28 efforts to lead the F13 Gang. 28 70. 1 On May 19, 2010, defendant LOPEZ, speaking in coded 2 language over the telephone, told defendant CERVANTES that LOPEZ 3 had received inmate correspondence from defendant L. LAREDO that 4 same day. 71. 5 On May 21, 2010, defendant MAESTAS, speaking in coded 6 language over the telephone, advised defendant LOPEZ that 7 MAESTAS would tell the family of an unindicted co-conspirator 8 who owed extortionate taxes and was in hiding that F13 Gang 9 members in jail would assault the unindicted co-conspirator's 10 incarcerated brother if the required extortionate taxes were not 11 paid. 12 72. On May 21, 2010, defendant LOPEZ, speaking in coded 13 language over the telephone, informed defendant MAESTAS that a 14 delivery of methamphetamine they had received was of poor 15 quality. 16 73. On May 21, 2010, defendant MAESTAS, speaking in coded 17 language over the telephone, described to defendant LOPEZ a 18 method by which MAESTAS normally tested drugs supplied to him. 19 74. On May 21, 2010, defendants LOPEZ and MAESTAS, 20 speaking in coded language over the telephone, agreed to supply 21 one ounce of methamphetamine each to three unindicted co- 22 conspirators. 23 75. On May 21, 2010, defendant MAESTAS, speaking in coded 24 language over the telephone, told defendant LOPEZ that MAESTAS 25 would bring three unindicted co-conspirators as backup the 26 following day when MAESTAS went to collect extortionate taxes. 27 28 29 1 76. On May 22, 2010, defendant MARTINEZ, speaking in coded 2 language over the telephone, alerted defendant LOPEZ that 3 defendants BECERRA and BARRAZA were not following instructions. 4 77. On May 23, 2010, defendant LOPEZ, speaking in coded 5 language over the telephone, told an unindicted co-conspirator 6 that LOPEZ has been working with the Mexican Mafia for the last 7 15 years. 8 9 78. On June 18, 2010, an unindicted co-conspirator who was incarcerated at Pelican Bay State Prison, using coded language 10 in correspondence, advised defendant LOPEZ of defendant L. 11 LAREDO's efforts to obtain extortionate taxes. 12 79 . . On July 3, 2010, defendant MARTINEZ, speaking in coded 13 language over the telephone, informed defendant LOPEZ, who was 14 incarcerated, that MARTINEZ had collected approximately $10,000 15 in extortionate taxes in order to raise bail money for LOPEZ, 16 with defendant ESPINOZA giving MARTINEZ the largest sum. 17 80. On July 3, 2010, defendants LOPEZ and MARTINEZ, 18 speaking in coded language during a telephone conversation, 19 discussed how letters had been sent from Pelican Bay State 20 Prison informing the recipients that defendant L. LAREDO had 21 lost inmate privileges and therefore could not receive mail at 22 this time. 23 81. On July 3, 2010, defendant LOPEZ, speaking in coded 24 language over the telephone, told defendant MARTINEZ that gang 25 members were approaching LOPEZ while he was incarcerated and 26 paying their respects. 27 28 82. On July 3, 2010, an unindicted co-conspirator, speaking in coded language over the telephone, told defendant 30 1 ?LOPEZ that defendant L. LAREDO was not being allowed to receive 2 mail at Pelican Bay State Prison. 3 83. On July 3, 2010, defendant LOPEZ, speaking in coded 4 language over the telephone, explained to an unindicted co- S conspirator that LOPEZ had previously received a letter from 6 Pelican Bay State Prison saying Castellanos was not allowed to 7 receive correspondence. 8 9 84. On July 3, 2010, an unindicted co-conspirator, speaking in coded language over the telephone, told defendant 10 LOPEZ that defendant L. LAREDO had instructed the unindicted co- 11 conspirator to send $300 to defendant BECERRA and to deposit 12 money into L. LAREDO's inmate account in Pelican Bay State 13 Prison. 14 85. On July 5, 2010, defendant CERVANTES, speaking in 15 coded language over the telephone, informed defendant LOPEZ that 16 CERVANTES had lost a letter sent by an inmate. 17 86. On July 5, 2010, defendant LOPEZ, speaking in coded 18 language over the telephone, told defendant CERVANTES that there 19 would have been serious consequences if CERVANTES had lost an 20 inmate letter sent by defendant L. LAREDO or any influential 21 individuals associated with the Mexican Mafia. 22 87. On July 9, 2010, defendant BECERRA, speaking in coded 23 language over the telephone, told defendant LOPEZ that BECERRA 24 had collected $1,000 in extortionate taxes from two individuals 25 and gave the money to defendant CASADO. 26 27 88. On July 9, 2010, defendant LOPEZ, speaking in coded language over the telephone, directed defendant BECERRA to ask 28 31 1 defendant ESPINOZA to whom extortionate taxes collected by 2 ESPINOZA were being given. 3 89. On July 9, 2010, defendant ESPINOZA, speaking in coded 4 language over the telephone, confirmed to defendant LOPEZ that 5 all of the extortionate taxes ESPINOZA collected that day would 6 be delivered to defendant CASADO. 7 90. On July 9, 2010, defendant LOPEZ, speaking in coded 8 language over the telephone, informed defendant ESPINOZA that 9 defendant CASADO knew how to record collections of extortionate 10 taxes and what to do with these illicit proceeds after they were 11 collected. 12 91. On July 9, 2010, defendant MARTINEZ, speaking in coded 13 language over the telephone, informed defendant LOPEZ that 14 MARTINEZ received money from defendant SIFUENTES that SIFUENTES 15 owed to LOPEZ and that MARTINEZ was going to deliver the money 16 to defendant CASADO. 17 92. On July 9, 2010, defendant MARTINEZ, speaking in coded 18 language over the telephone, reported to defendant LOPEZ that 19 MARTINEZ was going to give defendant CASADO approximately $1,500 20 in extortionate taxes. 21 9.3. On July 9, 2010, defendant MARTINEZ, speaking in coded 22 language over the telephone, told defendant LOPEZ that MARTINEZ 23 was going to provide all of the extortionate taxes MARTINEZ 24 collected to 25 94. de~endant CASADO. On August 28, 2010, defendant CAZERES, speaking in 26 coded language over the telephone, told defendant CERVANTES that 27 defendant SANCHEZ was not doing what he was supposed to be doing 28 at a "casita" and was not listening to defendant GRANADOS. 32 1 95. On August ~0, 2010, defendant MARTINEZ, speaking in 2 coded language during a telephone conversation with defendant 3 CERVANTES, explained that MARTINEZ had given $1,300 in 4 extortionate taxes to defendant BECERRA and $200 of such 5 proceeds to defendant M. LAREDO. 6 96. On August 30, 2010, defendant MARTINEZ, speaking in 7 coded language over the telephone, told defendant CERVANTES that 8 defendant L. LAREDO had sent a letter ordering MARTINEZ to keep 9 an eye on an unindicted co-conspirator. 10 97. On August 30, 2010, defendant MARTINEZ, speaking in 11 coded language over the telephone, advised defendant CERVANTES 12 that defendant M. LAREDO was sending letters to L. LAREDO at 13 Pelican Bay State Prison apprising L. LAREDO of the current 14 status of the F13 Gang. 15 98. On August 30, 2010, defendant CASADO, speaking in 16 coded language over the telephone, told defendant CERVANTES that 17 CASADO had not continued to write letters to defendant L. LAREDO 18 concerning the affairs of the F13 Gang since defendant LOPEZ had 19 been arrested. 20 99. On August 30, 2010, defendant CASADO, speaking in 21 coded language over the telephone, told defendant CERVANTES that 22 defendant M. LAREDO did not want CERVANTES or defendant LOPEZ to 23 be in charge of the F13 Gang. 24 100. On August 30, 2010, defendant CASADO, speaking in 25 coded language during a telephone conversation with defendant 26 CERVANTES, explained that defendant ULLOA had a means of 27 allowing them to communicate inexpensively with defendant LOPEZ. 28 33 1 101. On September 1, 2010, defendant CERVANTES, speaking in 2 coded language over the telephone, told an unindicted co- 3 conspirator that CERVANTES had previously written a letter to 4 Castellanos discussing CERVANTES's leadership of the F13 Gang 5 out on the streets. 6 102. On September 2, 2010, defendant M. LAREDO, speaking in 7 coded language over the telephone, told defendant CERVANTES that 8 she had received a letter from defendant L. LAREDO and asked if 9 CERVANTES wanted to see it. 10 103. On September 2, 2010, defendant CERVANTES, speaking in 11 coded language during a telephone conversation with defendant M. 12 LAREDO, agreed to go toM. LAREDO's residence to read a letter 13 from defendant L. LAREDO. 14 104. On September 4, 2011, defendant TAVIRA entered Pelican 15 Bay State Prison, in Crescent City, California, for the purpose 16 of meeting with defendant L. LAREDO to discuss the business of 17 the F13 Gang criminal enterprise. 18 105. On September 6, 2010, defendant CERVANTES, speaking in 19 coded language over the telephone, instructed defendant CAZERES 20 to bring CERVANTES $1,000 in extortionate taxes. 21 106. On September 16, 2010, defendant MARTINEZ, speaking in 22 coded language over the telephone, reported to defendant 23 CERVANTES that defendant M. LAREDO had called to tell MARTINEZ 24 that she had received a letter from Pelican Bay State Prison. 25 107. On September 16, 2010, defendant MARTINEZ, speaking in 26 coded language during a telephone conversation with defendant 27 CERVANTES, explained that defendant M. LAREDO wanted CERVANTES 28 34 1 to go to her residence to review a letter from Pelican Bay State 2 Prison and that M. LAREDO had asked MARTINEZ to call CERVANTES. 3 108. On September 16 1 2010 1 defendant CERVANTES 1 speaking 4 in coded language during a telephone conversation with defendant 5 MARTINEZ 1 agreed to go to defendant M. LARED0 1 6 review a letter she had received from Pelican Bay State Prison. 7 S residence to 109. On September 23 1 2010 1 defendant MARTINEZ 1 speaking in 8 coded language during a telephone conversation with defendant 9 CERVANTES 1 explained that MARTINEZ had given money to defendant 10 M. LAREDO because M. LAREDO was sending defendant TAVIRA to 11 visit defendant L. LAREDO the following day. 12 110. On September 24 1 2010 1 defendant CERVANTES 1 speaking 13 in coded language over the telephoner told an unindicted co- 14 conspirator that after defendant TAVIRA completed her visit to 15 defendant L. LAREDO at Pelican Bay State Prison 1 defendant M. 16 LAREDO would relay the message from L. LAREDO back to members 17 and associates of the F13 Gang. 18 111. On September 25r 2010 1 defendant TAVIRA entered 19 Pelican Bay State Prison 1 in Crescent Cityr California 1 for the 20 purpose of meeting with defendant 21 business of the F13 Gang.criminal enterprise. 22 L. LAREDO to discuss the 112. On September 25r 2010 1 defendant TAVIRA 1 speaking in 23 coded language during an inmate visit with defendant L. LARED0 1 24 relayed a message from defendant M. LAREDO regarding defendant 25 CERVANTES 1 s actions as a shot caller for the F13 Gang. 26 27 113. On September 25r 2010 1 defendant L. LARED0 1 speaking in coded languager advised defendant TAVIRA that 1 based on a 28 35 1 message she had relayed from defendant M. LAREDO, L. LAREDO was 2 going to write a letter reprimanding defendant CERVANTES. 3 114. On September 25, 2010, defendant TAVIRA, speaking in 4 coded language during an inmate visit with defendant L. LAREDO, 5 confirmed that L. LAREDO knew that defendant LOPEZ had been 6 deported to El Salvador. 7 115. On September 25, 2010, defendant TAVIRA, speaking in 8 coded language during an inmate visit with defendant L. LAREDO, 9 relayed a message from defendant M. LAREDO inquiring whether L. 10 LAREDO knew the individual who was taking defendant LOPEZ's 11 place in the F13 Gang upon his deportation. 12 116. On September 25, 2010, defendant L. LAREDO, speaking 13 in coded language, told defendant TAVIRA that he was aware 14 defendant CERVANTES had not been following L. LAREDO's 15 instructions. 16 117. On September 25, 2010, defendant L. LAREDO, speaking 17 in coded language, instructed defendant TAVIRA to relay a 18 message to defendant M. LAREDO regarding the leadership of the 19 F13 Gang. 20 118. On September 25, 2010, defendant L. LAREDO, speaking 21 in coded language, ordered defendant TAVIRA to relay individual 22 messages to defendants CERVANTES, LOPEZ, and MARTINEZ. 23 119. On September 30, 2010, defendant L. LAREDO, using 24 coded language in correspondence to defendant CERVANTES, 25 identified himself as the Mexican Mafia member running the F13 26 Gang. 27 120. On October 10, 2010, defendant L. LAREDO, using coded 28 language in correspondence, advised defendant CERVANTES of what 36 1 CERVANTES needed to do to remain in a leadership position in the 2 F13 Gang. 3 121. On October 10, 2010, defendant L. LAREDO, using coded 4 language in correspondence, instructed defendant CERVANTES to 5 follow orders and obey L. LAREDO. 6 122. On October 15, 2010, defendant CERVANTES, speaking in 7 coded language over the telephone, informed defendant LOPEZ that 8 defendant L. LAREDO had obtained approval for defendants CASADO 9 and TAVIRA to visit L. LAREDO at Pelican Bay State Prison. 10 123. On October 15, 2010, defendants CERVANTES and LOPEZ, 11 speaking in coded language during a telephone conversation, 12 discussed who would be running the F13 Gang's "casitas" in the 13 future. 14 124. On October 15, 2010, defendant LOPEZ, speaking in 15 coded language over the telephone, advised defendant CERVANTES 16 that they would not be replaced as shot callers for the F13 Gang 17 because they had the support of Castellanos. 18 125. On October 15, 2010, defendant LOPEZ, speaking in 19 coded language over the telephone, explained to defendant 20 CERVANTES that an unindicted co-conspirator was being brought in 21 as another F13 Gang shot caller because defendant M. LAREDO was 22 trying to have CERVANTES and LOPEZ replaced. 23 126. On October 15, 2010, defendant GRANADOS, speaking in 24 coded language during a telephone conversation with defendant 25 LOPEZ, confirmed that GRANADOS knew that a power struggle was 26 going on within the F13 Gang and that GRANADOS would support 27 LOPEZ and defendant CERVANTES. 28 37 1 127. On October 16, 2010, defendant LOPEZ, speaking in 2 coded language over the telephone, informed defendant CERVANTES 3 that defendant M. LAREDO had collected extortionate taxes from 4 an unindicted co-conspirator. 5 128. On October 16, 2010, defendant LOPEZ, speaking in 6 coded language over the telephone, told defendant CERVANTES to 7 write a letter to Castellanos to explain what was happening and 8 that Castellanos would keep members and associates of the F13 9 Gang in line. 10 129. On October 16, 2010, defendant CERVANTES, speaking in 11 coded language during a telephone conversation with defendant 12 LOPEZ, explained that CERVANTES was collecting extortionate 13 taxes, but had not collected very much money. 14 130. On October 16, 2010, defendant GRANADOS, speaking in 15 coded language over the telephone, explained to defendant 16 CERVANTES that defendant CAZERES had told GRANADOS that an 17 unindicted co-conspirator had gone to a "casita" that CAZERES 18 was running for CERVANTES and that the unindicted co-conspirator 19 claimed to be taking over control of the illegal gambling 20 establishment. 21 131. On October 16, 2010, defendant CERVANTES, speaking in 22 coded language over the telephone, told defendant GRANADOS that 23 defendant L. LAREDO had sent a message resolving an issue 24 relating to gang politics involving defendants MARTINEZ and M. 25 LAREDO. 26 132. On October 17, 2010, defendant AVILA, speaking in 27 coded language over the telephone, told defendant CERVANTES that 28 AVILA had gone to a "casita" to check on an issue with a 38 1 gambling machine and that, while there, AVILA spoke to an 2 unindicted co-conspirator who claimed to be taking over control 3 of the F13 Gang's "casitas." 4 133. On October 17, 2010, defendant MARTINEZ, speaking in 5 coded language during a telephone conversation with defendant 6 CERVANTES, explained that defendants M. LAREDO and ESPINOZA were 7 going to an unindicted 8 dispute regarding extortionate taxes. 9 co~conspirator's.residence to discuss a 134. On October 17, 2010, defendant MARTINEZ, speaking in telephone~ 10 coded language over the 11 that an F13 Gang member from the Malditos clique owed MARTINEZ 12 nearly 13 informed defendant CERVANTES $29,000~ 135. On October 19, 2010, defendant GRANADOS, speaking in 14 coded language over the telephone, reported to defendant 15 CERVANTES that a gambling machine was not working properly and 16 that defendant MAESTAS was going to fix it. 17 136. On October 20, 2010, defendant AVILA, speaking in 18 coded language over the telephone, informed told defendant 19 CERVANTES that AVILA had tested a gambling machine at one of the 20 "casitas." 21 137. On October 23, 2010, defendant CASADO entered Pelican 22 Bay State Prison, in Crescent City, California, for the purpose 23 of meeting with defendant L. LAREDO to discuss the business of 24 the F13 Gang criminal enterprise. 25 138. On October 23, 2010, defendant L. LAREDO, speaking in 26 coded language, told defendant CASADO that defendant CERVANTES 27 needed to understand that CERVANTES had to follow orders. 28 39 1 139. On October 23, 2010, defendant CASADO, speaking in 2 coded language, informed defendant L. LAREDO that defendant 3 CERVANTES had paid for her trip up to Pelican Bay State Prison. 4 140. On October 23, 2010, defendant L. LAREDO, speaking in 5 coded language, explained to defendant CASADO that defendants 6 CERVANTES and LOPEZ had to obey L. LAREDO's orders. 7 141. On October 23, 2010, defendant L. LAREDO, speaking in 8 coded language, reminded defendant CASADO that she worked for 9 him. 10 142. On October 24, 2010, defendant CASADO entered Pelican 11 Bay State Prison, in Crescent City, California, for the purpose 12 of meeting with defendant L. LAREDO to discuss the business of 13 the F13 Gang criminal enterprise. 14 143. On October 24, 2010, defendant L. LAREDO, speaking in 15 coded language, instructed defendant CASADO to tell defendant 16 CERVANTES to listen to an unindicted co-conspirator who had been 17 promoted to be a shot caller of the F13 Gang. 18 144. On October 24, 2010, defendant L. LAREDO, speaking in 19 coded language, directed defendant CASADO to tell defendant 20 CERVANTES and an unindicted co-conspirator to pay for CASADO to 21 return to Pelican Bay State Prison for another visit. 22 145. On October 24, 2010, defendants CERVANTES and LOPEZ, 23 speaking in coded language during a telephone conversation, 24 discussed that defendant L. LAREDO had accused them of taking 25 money collected from extortionate taxes that belonged to L. 26 LAREDO. 27 28 146. On October 24, 2010, defendant LOPEZ, speaking in coded language over the telephone, explained to defendant 40 1 CERVANTES that defendant L. LAREDO appeared to believe that 2 every dollar of extortionate taxes collected by the F13 Gang 3 belonged to L. LAREDO. 4 147. On October 24, 2010, defendants CERVANTES and LOPEZ, 5 speaking in coded language during a telephone conversation, 6 discussed an upcoming visit to defendant L. LAREDO at Pelican 7 Bay State Prison by defendant CASADO. 8 148. On October 24, 2010, defendant LOPEZ, speaking in 9 coded language over the telephone, explained to defendant 10 CERVANTES that defendant L. LAREDO wanted all members and 11 associates of the F13 Gang to obey him. 12 149. On October 24, 2010, defendant LOPEZ, speaking in 13 coded language over the telephone, asked defendant CERVANTES 14 whether defendant CASADO had relayed to CERVANTES what defendant 15 L. LAREDO had said during CASADO's visit at Pelican Bay State 16 Prison. 17 150. On October 24, 2010, defendant CERVANTES, speaking in 18 coded language over the telephone, told defendant LOPEZ that a 19 recent inmate letter from defendant L. LAREDO had instructed 20 CERVANTES to help LOPEZ, but did not say how to do so. 21 151. On October 24, 2010, defendant LOPEZ, speaking in 22 coded language over the telephone, told defendant CERVANTES that 23 defendant L. LAREDO wanted them to obey L. LAREDO in every way 24 without question. 25 152. On October 27, 2010, defendant CERVANTES, speaking in 26 coded language over the telephone, explained to defendant 27 GRANADOS that defendant CAZERES had to provide more money from 28 the "casita" that CAZERES was running for the F13 Gang. 41 1 153. On October 31, 2010, defendant GRANADOS, speaking in 2 coded language over the telephone, instructed defendant MENDEZ 3 to go to the F13 Gang's "casita" on West 65u Street, in Los 4 Angeles, California. 5 154. On November 1, 2010, defendants CERVANTES, GRANADOS, 6 CAZERES, and SANCHEZ, and others known and unknown to the Grand 7 Jury, possessed eight illegal gambling machines, 11 small 8 baggies containing methamphetamine, and a loaded Smith & Wesson 9 .38 caliber revolver at a "casita" located at a residence on 10 11 West 70th Street, in Los Angeles, California. 155. On November 1, 2010, defendant CAZERES, speaking in 12 coded language over the telephone, reported to defendant 13 GRANADOS that law enforcement had entered the F13 Gang's 14 "casita" located at a residence on West 70th Street, in Los 15 Angeles, California. 16 156. On November 1, 2010, defendant GRANADOS, speaking in 17 coded language over the telephone, informed defendant CAZERES 18 that GRANADOS had just gone by the "casita" on West 70th Street, 19 in Los Angeles, California, and observed law enforcement at the 20 location. 21 157. On November 1, 2010, defendant CAZERES, speaking in 22 coded language over the telephone, informed defendant GRANADOS 23 that defendant SANCHEZ had been at the "casita" on West 70th 24 Street, in Los Angeles, California. 25 158. On November 2, 2010, an unindicted co-conspirator, 26 speaking in coded language over the telephone, informed 27 defendant GRANADOS that the unindicted co-conspirator was with 28 defendant CAZERES at the F13 Gang's other "casita" located at a 42 1 residence on 59th Street, in Los Angeles, California, and that, 2 while they wanted to open the "casita" that night, "everything 3 went to hell" and there were no gambling machines at the 4 "casita." 5 159. On November 9, 2010, defendants MARTINEZ and M. 6 LAREDO, speaking in coded language during a telephone 7 conversation, discussed setting up a meeting with defendants 8 CERVANTES and LOPEZ and an unindicted co-conspirator because the 9 unindicted co-conspirator had received a letter from Pelican Bay 10 11 State Prison. 160. On November 9, 2010, defendant MARTINEZ, speaking in 12 coded language over the telephone, informed defendant M. LAREDO 13 that MARTINEZ had learned of a location in the territory 14 controlled by the F13 Gang from which drugs were being sold and 15 that defendant ESPINOZA was going to collect extortionate taxes 16 from the location. 17 161. On November 12, 2010, defendant M. LAREDO, speaking in 18 coded language over the telephone, informed defendant MARTINEZ 19 that defendant L. LAREDO had instructed them to send defendant 20 TAVIRA to visit L. LAREDO at Pelican Bay State Prison. 21 162. On November 17, 2010, an unindicted co-conspirator, 22 speaking in coded language over the telephone, told defendant 23 MARTINEZ that defendant M. LAREDO was essentially in control of 24 the F13 Gang out on the streets. 25 163. On November 17, 2010, defendant MARTINEZ, speaking in 26 coded language over the telephone, advised an unindicted co- 27 conspirator that the F13 Gang had found someone who would take 28 43 1 the blame for the drugs found at defendant M. LAREDO's 2 residence. 3 164. On November 17, 2010, defendant MARTINEZ, speaking in 4 coded language over the telephone, informed an unindicted co- 5 conspirator that defendant M. LAREDO had claimed to be in charge 6 of the F13 Gang out on the streets. 7 165. On November 17, 2010, defendants CERVANTES and 8 MANDUJANO, speaking in coded language during a telephone 9 conversation, discussed the circumstance surrounding the arrest 10 11 of defendant MENDEZ. 166. On November 19, 2010, defendants CERVANTES, GRANADOS, 12 and CAZERES, and others known and unknown to the Grand Jury, 13 possessed nine illegal gambling machines, "pay and owe" sheets, 14 and approximately 2.0 grams of a mixture and substance 15 containing a detectable amount of cocaine and 10.4 grams of 16 methamphetamine packaged for distribution at a "casita" located 17 at a residence on West 65th Street, in Los Angeles, California. 18 167. On November 19, 2010, defendants CERVANTES, GRANADOS, 19 CAZERES, and SANCHEZ, and others known and unknown to the Grand 20 Jury, possessed six illegal gambling machines at a "casita" 21 located at a residence on West 59th Place, in Los Angeles, 22 California. 23 168. On November 23, 2010, defendants CERVANTES and 24 GRANADOS possessed two illegal gambling machines, approximately 25 5.6 grams of methamphetamine contained in 33 plastic baggies, 26 and approximately 19.9 grams of a mixture and substance 27 containing a detectable amount of cocaine at a "casita" on 28 44 1 Duarte Avenue, in Los Angeles, California, within the territory 2 controlled by the F13 Gang. 3 169. On November 23, 2010, defendant CERVANTES possessed 4 two illegal gambling machines, a large bundle of marijuana 5 (gross weight of approximately 3,239 grams), packaging 6 materials, a large digital scale, and written correspondence 7 from defendant L. LAREDO at CERVANTES's residence on Duarte 8 Avenue, in Los Angeles, California, within the territory 9 controlled by the F13 Gang. 10 170. On November 23, 2010, defendant ESPINOZA, speaking in 11 coded language over the telephone, told defendant MARTINEZ that 12 ESPINOZA had apprised defendant M. LAREDO of recent law 13 enforcement activities. 14 171. On November 26, 2010, defendant TAVIRA entered Pelican 15 Bay State Prison, in Crescent City, California, for the purpose 16 of meeting with defendant L. LAREDO to discuss the business of 17 the F13 Gang criminal.enterprise. 18 172. On November 27, 2010, defendant TAVIRA entered Pelican 19 Bay State Prison, in Crescent City, California, for the purpose 20 of meeting with defendant L. LAREDO to discuss the business of 21 the F13 Gang criminal enterprise. 22 173. On November 27, 2010, defendants CERVANTES and 23 CAZERES, speaking in coded language during a telephone 24 conversation, discussed a gambling machine at one of the 25 ucasitas" run by the F13 Gang. 26 27 174. On November 28, 2010, defendant TAVIRA entered Pelican Bay State Prison, in Crescent City, California, for the purpose 28 45 1 of meeting with defendant L. LAREDO to discuss the business of 2 the F13 Gang criminal enterprise. 3 175. On July 6, 2011, defendant JUAREZ, speaking in coded 4 language, advised another confidential informant ("CI-2") that 5 JUAREZ had previously collected extortionate taxes for the F13 6 Gang. 7 176. On July 6, 2011, defendant JUAREZ, speaking in coded 8 language, recounted to CI-2 that multiple associates of the F13 9 Gang, including defendant LOPEZ, had been with JUARE.Z just prior 10 to a recent arrest, but JUAREZ had told the individuals to leave 11 the location to avoid apprehension by law enforcement. 12 177. On July 6, 2011, defendant JUAREZ, speaking in coded 13 language, told CI-2 that the F13 Gang had tried to put a "green 14 light" on JUAREZ when he was young because JUAREZ had killed two 15 other members of the gang. 16 178. On July 6, 2011, defendant JUAREZ, speaking in coded 17 language, told CI-2 that JUAREZ had a job working with a gang 18 ?intervention group, but that the job did not prevent JUAREZ from 19 conducting his criminal activities. 20 179. On July 6, 2011, defendant JUAREZ, speaking in coded 21 language, 22 the F13 Gang's activities on the streets and was a member of the 23 Mexican Mafia. 24 to~d CI-2 that defendant L. LAREDO was in charge of 180. On September 3, 2011, defendant TAVIRA entered Pelican 25 Bay State Prison, in Crescent City, California, for the purpose 26 of 27 Gang criminal enterprise. ~eeting with Castellanos to discuss the business of the F13 28 46 1 181. On September 3, 2011, Castellanos and defendant 2 TAVIRA, using coded language during an inmate visit at Pelican 3 Bay State Prison, discussed a "green light" order that 4 Castellanos wished TAVIRA to relay to F13 Gang members and 5 associates on the streets. ?6 182. On September 4, 2011, defendant TAVIRA entered Pelican 7 Bay State Prison, in Crescent City, California, for the purpose 8 of meeting with defendant L. LAREDO to discuss the business of 9 the F13 Gang criminal enterprise. 10 183. On September 18, 2011, defendants CASADO and TAVIRA 11 entered Pelican Bay State Prison, in Crescent City, California, 12 for the purpose of meeting with defendant L. LAREDO to discuss 13 the business of the F13 Gang criminal enterprise. 14 The March 2010 Killing of Victim R.A. 15 184. On March 13, 2010, defendant DORADO, speaking in coded 16 language over the telephone, reported to defendant ULLOA that 17 victim R.A. had told other F13 Gang members that ULLOA was 18 cooperating with law enforcement. 19 185. On March 13, 2010, defendant ULLOA, speaking in coded 20 language over the telephone, directed defendant DORADO to have 21 victim R.A. violently disciplined. 22 186. On March 13, 2010, de.fendant DORADO, speaking in coded 23 language during a telephone conversation with defendant ULLOA, 24 agreed to have F13 Gang members violently discipline victim R.A. 25 187. On March 13, 2010, defendant FAZAH, speaking in coded 26 language over the telephone, confirmed to defendant ULLOA that 27 victim R.A. had been talking "some stupid shit" about ULLOA to 28 other F13 Gang members. 47 1 188. On March 13, 2010, defendant ULLOA, speaking in coded 2 language over the telephone, ordered defendant FAZAH to 3 violently discipline victim R.A. 4 189. On March 13, 2010, defendant FAZAH, speaking in coded 5 language during a telephone conversation with defendant ULLOA, 6 agreed that FAZAH would use violence to discipline victim R.A. 7 190. On March 13, 2010, defendant DORADO, speaking in coded 8 language over the telephone, assured defendant ULLOA that 9 defendant FAZAH could be trusted to discipline victim R.A. 10 191. On March 13, 2010, defendant ULLOA, speaking in coded 11 language over the telephone, threatened victim R.A. with violent 12 retribution for telling other F13 Gang members that ULLOA had 13 cooperated with law enforcement. 14 192. On March 13, 2010, having listened to a conversation 15 between defendant ULLOA and victim R.A., defendant ARANA advised 16 ULLOA that "that fool [victim R.A.] was scared" when ULLOA 17 threatened R.A. with violence. 18 193. On March 13, 2010, defendant ULLOA, speaking in coded 19 language over the telephpne, alerted defendant LOPEZ that victim 20 R.A. had accused ULLOA of cooperating with law enforcement and 21 that ULLOA had himself told R.A. that R.A. would be disciplined. 22 194. On March 13, 2010, defendant LOPEZ, speaking in coded 23 language over the telephone, told defendant ULLOA that LOPEZ 24 would have other F13 Gang members look for victim R.A. so that 25 LOPEZ could discipline him. 26 27 195. On March 13, 2010, defendant DORADO, speaking in coded language over the telephone, told defendant ULLOA that DORADO 28 48 1 and his associates did not need any help from defendant LOPEZ to 2 find and discipline victim R.A. 3 196. On March 14, 2010, defendant Josue Rojas, aka "Chino," 4 and other F13 Gang members assaulted victim R.A. in an alley 5 between Stafford Street and Templeton Street, in Huntington 6 Park, California, within the territory controlled by the F13 7 Gang. 8 9 197. On March 14, 2010, victim R.A. was killed by a single gunshot to the head in an alley between Stafford Street and 10 Templeton Street, in Huntington Park, California, within the 11 territory controlled by the F13 Gang. 12 198. On March 14, 2010, defendant ARANA, speaking in coded 13 language over the telephone, told defendant ULLOA that defendant 14 DORADO had asked ARANA to check the streets around her residence 15 for the presence of law enforcement and wanted to hide out at 16 ARANA's residence. 17 199. On March 14, 2010, defendant DORADO, speaking in coded 18 language over the telephone, reported to defendant ULLOA that 19 victim R.A. had been killed and that DORADO could not go to his 20 own residence for fear of being apprehended by law enforcement. 21 200. On March 18, 2010, defendant CERVANTES, speaking in 22 coded language over the telephone, asked defendant ULLOA who 23 gave the order for victim R.A. to be killed. 24 201. On March 18, 2010, defendant ULLOA, speaking in coded 25 language over the telephone, told defendants CERVANTES and LOPEZ 26 that ULLOA had ordered victim R.A. to be assaulted, but not to 27 be killed. 28 49 1 202. On March 18, 2010, defendant ULLOA, speaking in coded 2 language over the telephone, informed defendant CERVANTES that 3 defendant GALVEZ was present when victim R.A. was killed and 4 knew what happened. 5 203. On March 20, 2010, defendant LOPEZ, speaking in coded 6 language over the telephone, reminded defendant ULLOA that only 7 defendant L. LAREDO and Castellanos have the authority to order 8 the killing of F13 Gang members. 9 Drug Trafficking and Unlawful Possession of Firearms 10 204. On October 7, 2009, defendant SIFUENTES sold 11 approximately 11.3 grams of methamphetamine, in the parking lot 12 of a restaurant on Eastern Avenue, in Bell Gardens, California. 13 205. On October 8, 2009, defendant SIFUENTES sold a .Smith & 14 wesson 9mm pistol, with a loaded, is-round ammunition magazine, 15 in the parking lot of a restaurant on Florence Avenue, in 16 Huntington Park, California, within the territory controlled by 17 the F13 Gang . 206. On January 12, 2010, defendant David Proo, aka "D" 18 19 ("Proo"), speaking in coded language over the telephone, asked 20 defendant SIFUENTES to deliver a quantity of drugs to a 21 restaurant where Proo worked, on Florence Avenue, in Huntington 22 Park, California, within the territory controlled by the F13 23 Gang. 24 207. On January 15, 2010, defendant SIFUENTES sold a Sten- 25 type 9mm caliber machinegun and approximately 29 rounds of 9mm 26 ammunition in the parking lot of a restaurant on Florence 27 Avenue, in Huntington Park, California, within the territory 28 controlled by the F13 Gang. 50 1 208. On January 16, 2010, defendant Proo, speaking in coded 2 language over the telephone, inquired as to the price of a 3 quantity of methamphetamine. 4 209. On January 16, 2010, defendant SIFUENTES, speaking in 5 coded language over the telephone, told defendant Proo that 6 SIFUENTES possessed the quantity of drugs requested by Proo and 7 would bring the drugs to Proo in 10-15 minutes. 8 210. On February 26, 2010, defendant ULLOA, speaking in 9 coded language over the telephone, told defendant ARANA that 10 ARANA should sell the methamphetamine they possessed, after 11 which defendant MAESTAS would supply additional drugs. 12 211. On February 26, 2010, defendant ARANA, speaking in 13 coded language over the telephone, confirmed with defendant 14 ULLOA that she could sell their methamphetamine and that she 15 would steal a scale from her work to weigh the drugs. 16 212. On February 26, 2010, defendant ULLOA, speaking in 17 coded language over the telephone, reminded defendant ARANA that 18 a drug user who ARANA previously supplied had said that ULLOA 19 and ARANA's methamphetamine was "bomb" 20 (high quality). 213. On March 2, 2010, defendant Proo, speaking in coded 21 language over the telephone, informed defendant SIFUENTES that a 22 prior drug customer wanted to buy methamphetamine from them 23 again. 24 214. On March 2, 2010, defendant SIFUENTES, speaking in 25 coded language over the telephone, directed defendant Proo to 26 tell a drug customer that she was receiving a discount because 27 Proo was part of the same organization as SIFUENTES. 28 51 1 215. On March 2, 2010, defendants SIFUENTES and Proo sold 2 approximately 2.3 grams of methamphetamine inside the 3 restaurant where Proo worked, on Florence Avenue, in Huntington 4 Park, California, within the territory controlled by the F13 5 Gang. 6 216. On March 4, 2010, defendant ARANA, speaking in coded 7 language over the telephone, confirmed to defendant ULLOA that 8 ARANA had previously sold their methamphetamine. 9 217. On March 14, 2010, defendant FAZAH possessed 10 approximately 16.9 grams of methamphetamine packaged for 11 distribution, a digital scale, "pay and owe" sheets, over $1,000 12 in cash, two police scanner radios, a loaded .22 caliber rifle, 13 10 rounds of .44 caliber ammunition, a 30-round ammunition 14 magazine containing 10 hollow-point 9mm caliber bullets, and 15 paperwork displaying the words "Florencia," "Bear Street," and 16 "F13," at his residence on Stafford Avenue, in Huntington Park, 17 California, within the territory controlled by the F13 Gang. 18 218. On March 19, 2010, defendant SIFUENTES possessed 19 approximately 11.5 grams of methamphetamine, 689.7 grams of 20 marijuana packaged for distribution, 5.3 grams of a mixture and 21 substance containing a detectable amount of cocaine, 3.4 grams 22 of cocaine base in the form of crack cocaine contained in 13 23 different plastic baggies, 16 individually-packaged tablets of 24 3,4-methylenedioxy-methamphetamine ("MDMA"), three digital 25 scales, plastic packaging material, and six rounds of .38 26 caliber ammunition, at his residence on Stafford Avenue in 27 Huntington Park, California, within the territory controlled by 28 the F13 Gang. 52 1 219. On April 15, 2010, defendant MARTINEZ, speaking in 2 coded language over the telephone, confirmed to defendant LOPEZ 3 that a drug deal had been completed and that MARTINEZ was going 4 to drive down to San Diego to oversee the arrival and 5 transportation of the drugs. 6 220. On April 18, 2010, defendant BARRAZA, speaking in 7 coded language over the telephone, informed defendant LOPEZ that 8 BARRAZA was going to give an unindicted co-conspirator a sample 9 of drugs. 10 221. On April 18, 2010, defendant BARRAZA, speaking in 11 coded language over the telephone, told defendant LOPEZ that 12 BARRAZA gave a drug sample to an unindicted co-conspirator, who 13 was going to have a third party test it. 14 222. On April 18, 2010, defendant MARTINEZ, speaking in 15 coded language over the telephone, apprised defendant LOPEZ of 16 an unindicted co-conspirator who wished to purchase drugs. 17 223. On April 18, 2010, defendant BARRAZA, speaking in 18 coded language over the telephone, asked defendant LOPEZ what 19 steps should be taken to complete a drug deal once an unindicted 20 co-conspirator tested a drug sample and agreed to purchase a 21 larger quantity of the drug. 22 224. On April 21, 2010, defendants LOPEZ and MARTINEZ, 23 speaking in coded language during a telephone conversation, 24 agreed that defendant BARRAZA would go to LOPEZ's residence to ? 25 26 27 pick up a firearm. 225. On May 7, 2010, defendant MARTINEZ, speaking in coded language over the telephone, told defendant LOPEZ that a 28 53 1 customer did not like the drug sample they had provided and 2 asked LOPEZ to provide another sample. 3 226. On May 10, 2010, defendant LOPEZ, speaking in coded 4 language over the telephone, advised defendant CERVANTES that 5 LOPEZ possessed a .45 caliber firearm and asked whether 6 CERVANTES possessed ammunition for the gun. 7 227. On May 10, 2010, defendant CERVANTES, speaking in 8 coded language during a telephone conversation with defendant 9 LOPEZ, agreed to check to see whether he possessed .45 caliber 10 11 ammunition that he could provide to LOPEZ. 228. On May 11, 2010, defendant MARTINEZ, speaking in coded 12 language over the telephone, informed defendant LOPEZ of the 13 price that particular customers were willing to pay for high 14 quality drugs. 15 229. On May 17, 2010, defendant? MARTINEZ, speaking in coded 16 language over the telephone, informed defendant LOPEZ that drug 17 customers had arrived and that they wanted to purchase drugs. 18 230. On May 17, 2010, defendant MARTINEZ, speaking in coded 19 language over the telephone, told defendant LOPEZ about a drug 20 customer who had discussed purchasing a large amount of drugs. 21 231. On June 15, 2010, defendant BARRAZA, speaking in coded 22 language over the telephone, advised defendant M. LAREDO that 23 BARRAZA and defendant MARTINEZ were leaving M. LAREDO's home and 24 that they had removed the drugs from the premises. 25 ' 26 232. On June 28, 2010, defendants MARTINEZ, M. LAREDO, and BARRAZA possessed approximately 12 bundles of marijuana (gross 27 weight of approximately 108,729 grams), a digital scale, and 28 plastic packaging materials atM. LAREDO's residence on East 61st 54 1 Street, in Los Angeles, California, within the territory 2 controlled by the F13 Gang. 3 233. On July 9, 2010, defendant MARTINEZ, speaking in coded 4 language over the telephone, told defendant LOPEZ that MARTINEZ 5 possessed drugs to sell. 6 234. On August 30, 2010, defendant MARTINEZ, speaking in 7 coded language over the telephone, told defendant CERVANTES that 8 a source of supply had just shown MARTINEZ a sample of high 9 quality drugs. 10 235. On September 8, 2010, defendants CERVANTES and 11 MARTINEZ, speaking in coded language during a telephone 12 conversation, discussed upcoming drug orders. 13 236. On September 12, 2010, defendants CERVANTES and 14 MANDUJANO, speaking in coded language during a telephone 15 conversation, discussed making a purchase of methamphetamine 16 from a source of supply. 17 237. On September 12, 2010, defendant MANDUJANO, speaking 18 in coded language over the telephone, informed defendant 19 CERVANTES that MANDUJANO's source of supply possessed drugs in 20 Riverside and suggested that they go there together to inspect 21 the drugs. 22 238. On September 14, 2010, defendant MANDUJANO, speaking 23 in coded language over the telephone, told defendant CERVANTES 24 that MANDUJANO would check with a source of supply regarding 25 purchasing methamphetamine. 26 239. On September 25, 2010, defendants CERVANTES and 27 MANDUJANO, speaking in coded language during a telephone 28 conversation, discussed prices for drugs. 55 1 240. On October 8, 2010, defendant CERVANTES, speaking in 2 coded language over the telephone, told defendant MARTINEZ about 3 a potential source of supply of marijuana and methamphetamine. 4 241. On November 8, 2010, defendant MARTINEZ, speaking in 5 coded language over the telephone, told an unindicted co- 6 conspirator that MARTINEZ wanted to continue selling drugs to a 7 customer. 8 242. On November 8, 2010, defendant Jesus Meza, aka "Chana" 9 ("Meza"), speaking in coded language over the telephone, told 10 defendant CERVANTES that Meza possessed a sample of drugs and 11 had been waiting for CERVANTES to complete a drug transaction. 12 243. On November 8, 2010, defendant Meza, speaking in coded 13 language during a telephone conversation with defendant 14 CERVANTES, explained that Meza had held a sample of drugs for 15 CERVANTES for three days, but that the drugs were of good 16 quality. 17 244. On November 8, 2010, defendant Meza, speaking in coded 18 language over the telephone, informed defendant CERVANTES that 19 Meza was going to go pick up 100 pounds of marijuana from a 20 source of supply. 21 245. On November 8, 2010, defendants CERVANTES and Meza 22 possessed multiple large bundles of marijuana (gross weight of 23 approximately 49,897 grams), 24 digital scales at his residence on Orange Avenue, in Paramount, 25 California. "pay and owe" sheets, and two 26 246. On November 9, 2010, defendant MANDUJANO, speaking in 27 coded language over the telephone, informed defendant CERVANTES 28 that defendant BECERRA had taken MANDUJANO's drugs to try to 56 1 sell them, but that MANDUJANO would be supplied more drugs the 2 following day. 3 247. On November 11, 2010, defendant MARTINEZ, speaking in 4 coded language over the telephone, reported to defendant LOPEZ 5 that customers went to see drugs that defendant BECERRA was 6 selling for them, but did not purchase anything. 7 248. On November 16, 2010, defendant MENDEZ, speaking in 8 coded language over the telephone, told defendant CERVANTES that 9 MENDEZ .was waiting to receive a sample of drugs. 10 249. On November 16, 2010, defendants CERVANTES and MENDEZ, 11 speaking in coded language during a telephone conversation, 12 discussed whether MENDEZ's source of supply could bring 13 additional drugs for CERVANTES when making a delivery to MENDEZ. 14 250. On November 16, 2010, defendant MENDEZ and an 15 unindicted F13 Gang member possessed five large bundles of 16 marijuana and a bag of marijuana (total gross weight of 17 approximately 25,134 grams) at MENDEZ's residence on Maie 18 Avenue, in Los Angeles, California, within the territory 19 controlled by the F13 Gang. 20 251. On November 17, 2010, defendant MARTINEZ, speaking in 21 coded language over the telephone, advised an unindicted co- 22 conspirator that law enforcement had found a stash of MARTINEZ 23 and defendant BARRAZA's drugs that were being stored in 24 defendant M. LAREDO's .residence. 25 252. On November 18, .2010, defendant BECERRA possessed 26 marijuana prepared for distribution (gross weight of 27 approximately 12,940 grams) and a large electronic scale at his 28 57 1 residence on Cudahy Street, in Huntington Park, California, 2 within the territory controlled by the F13 .Gang. 3 253. On November 18, 2010, defendant ESPINOZA possessed an 4 SKS rifle, a 9mm handgun, and ammunition, at his residence on 5 Flower Street, in Bellflower, California. 6 254. On November 19, 2010, defendant SANCHEZ possessed a 7 loaded 9mm caliber handgun, additional 9mm caliber ammunition, 8 and methamphetamine at the F13 Gang's "casita" located at a 9 residence on West 59th Place, in Los Angeles, California. 10 255. On November 20, 2010( defendant MARTINEZ, speaking in 11 coded language over the telephone, advised an unindicted co- 12 conspirator that law enforcement had found defendant BECERRA to 13 be in possession of marijuana. 14 256. On November 22, 2010, defendant.AVILA possessed 15 approximately 14.6 grams of methamphetamine, "pay and owe" 16 sheets, a digital scale, plastic baggies, a loaded 9mm ca+iber 17 pistol, and a loaded .38 caliber revolver at his residence on E. 18 41 5 t Street, in Los Angeles, California. 19 257. On November 24, 2010, defendant Meza, speaking in 20 coded language over the telephone, accused defendant CERVANTES 21 of owing Meza $1,000 from past drug transactions. 22 258. On November 24, 2010, defendant CERVANTES, speaking in 23 coded language over the telephone, asserted to defendant Meza 24 that CERVANTES always paid for the drugs he received from Meza. 25 259. On December 2, 2010, defendant MANDUJANO possessed a 26 loaded .38 caliber revolver, a .40 caliber handgun with two 27 magazines and nine rounds of ammunition, two digital scales, 28 plastic packaging material, and $1,351 in cash, including 58 1 methamphetamine in his vehicle, at his residence on Wall Street, 2 in Los Angeles, 3 Cali~ornia. 260. On February 25, 2011, defendant MAESTAS sold 4 approximately 13.7 grams of methamphetamine at a residence on 5 Whitsett Avenue, in Los Angeles, California, within the 6 territory controlled by the F13 Gang. 7 261. On March 14, 2011, defendant MAESTAS, speaking in 8 coded language over the telephone, advised a law enforcement 9 officer acting in an undercover capacity ("UC") that one ounce 10 11 of methamphetamine would cost $1,000. 262. On March 14, 2011, defendant MAESTAS, speaking in 12 coded language over the telephone, informed the UC that MAESTAS 13 regularly possessed methamphetamine for sale. 14 263. On March 18, 2011, defendant MAESTAS sold 15 approximately 27.6 grams of methamphetamine at a residence on 16 Whitsett Avenue, in Los Angeles, California, within the 17 territory controlled by the F13 Gang. 18 264. On April 15, 2011, defendants MAESTAS and JUAREZ sold 19 approximately 27.5 grams of methamphetamine at a residence on 20 Whitsett Avenue, in Los Angeles, California, within the 21 territory controlled by the F13 Gang. 22 265. On May 18, 2011, defendant JUAREZ sold an AK-style 23 rifle loaded with 20 rounds of ammunition at an apartment 24 complex on Templeton Street, in Huntington Park, California, 25 within the territory controlled by the F13 Gang. 26 27 266. On May 18, 2011, defendants MAESTAS and JUAREZ sold approximately 80 grams of methamphetamine at an apartment 28 59 1 complex on Templeton Street, in Huntington Park, California, 2 within the territory controlled by the F13 Gang. 3 267. On June 27, 2011, defendant SIFUENTES sold 4 approximately 56 grams of methamphetamine in the parking lot of 5 a bowling alley on Gage Avenue, in Huntington Park, California. 6 268. On July 6, 2011, defendant JUAREZ and an unindicted' 7 co-conspirator sold three shotguns at a residence on 8th Street, 8 in Buena Park, California. 9 10 269. On July 6, 2011, defendant JUAREZ, speaking in coded language, told a CI about a source of supply of methamphetamine. 11 270. On July 6, 2011, defendant JUAREZ sold approximately 12 109.7 grams of methamphetamine on Miramonte Boulevard, in Los 13 Angeles, California, within the territory controlled by the F13 14 gang. 15 271. On July 6, 2011, defendant JUAREZ, speaking in coded 16 language, asked CI-2 if CI-2 wanted to order an additional 17 quarter pound of methamphetamine from JUAREZ. 18 272. On July 11, 20i1, defendant SIFUENTES sold a Ruger .22 19 caliber pistol, loaded with four rounds of ammunition, in the 20 parking lot of a restaurant on Florence Avenue, in Huntington 21 Park, California, within the territory controlled by the F13 22 Gang. 23 273. On July 12, 2011, defendant SIFUENTES sold a Glock .40 24 caliber pistol and three other handguns in the parking lot of a 25 restaurant on Eastern Avenue, in Bell Gardens, California. 26 27 274. On August 3, 2011, defendant SIFUENTES sold a Walther P38 9mm pistol and a Smith & Wesson .22 caliber handgun in the 28 60 1 parking lot of a restaurant on Eastern Avenue, in Bell Gardens, 2 California. 3 275. On August 9, 2011, defendant SIFUENTES sold a loaded 4 .40 caliber pistol in the parking lot of a restaurant on Eastern 5 Avenue, in Bell Gardens, California. 6 276. On August 18, 2011, defendant SIFUENTES sold a Smith & 7 Wesson .38 caliber revolver, with six rounds of ammunition, in 8 the parking lot of a restaurant on Eastern Avenue, in Bell 9 Gardens, California. 10 277. On August 30, 2011, defendant SIFUENTES sold a rifle 11 and 27 rounds of ammunition in the parking lot of a restaurant 12 on Eastern Avenue, in Bell Gardens, California. 13 278. On September 2, 2011, defendant SIFUENTES sold a 14 Norinco North China Industries 7.62 caliber rifle, a loaded 15 ammunition magazine, and 38 rounds of ammunition in the parking 16 lot of a restaurant on Eastern Avenue, in Bell Gardens, 17 California . . 18 279. On September 8, 2011, defendant SIFUENTES sold a .40 19 caliber Desert Eagle pistol, two other handguns, and ammunition 20 in the parking lot of a shopping mall in Cerritos, California. 21 280. On October 11, 2011, defendant SIFUENTES sold two .40 22 caliber handguns and four ammunition magazines in the parking 23 lot of a shopping mall in Cerritos, California. 24 281. On October 14, 2011, defendant SIFUENTES sold a 25 Beretta 9mm rifle and a Mossberg 12-gauge shotgun in the parking 26 lot of a shopping mall in Cerritos, California. 27 28 61 1 Smuggling of Drugs into the LACJ System 2 282. On February 25, 2010, defendant ULLOA, speaking in 3 coded language over the telephone, told defendant ARANA that 4 defendant DORADO would deliver drugs for ULLOA on March 18, 5 2010. 6 283. On February 26, 2010, defendant ULLOA, speaking in 7 coded language over the telephone, instructed defendant ARANA to 8 deliver drugs to an unindicted co-conspirator planning to turn 9 himself in to the authorities, which was to be separate from the 10 drugs ULLOA had scheduled to be smuggled into NCCF on March 18, 11 2010. 12 284: On February 26, 2010, defendant ARANA, speaking in 13 coded language over the telephone, described for defendant ULLOA 14 the appearance of drugs that were to be smuggled into NCCF. 15 285. On March 3, 2010, defendant ARANA, speaking in coded 16 language over the telephone, told defendant ULLOA that she had 17 retrieved methamphetamine from the garage and had weighed the 18 methamphetamine. 19 286. On March 4, 2010, defendant ARANA, speaking in coded 20 language over the telephone, reported to defendant ULLOA that a 21 drug user had tested their methamphetamine and determined it to 22 be of high quality. 23 287. On March 4, 2010, defendant ULLOA, speaking in coded 24 language over the telephone, told defendant LOPEZ that ULLOA had 25 lined up an individual to turn himself in to the authorities to 26 smuggle heroin to ULLOA in NCCF. ? 27 28 288. On March 4, 2010, defendant ULLOA, speaking in coded language over the telephone, asked defendant LOPEZ to provide 62 1 ULLOA with additional heroin to be smuggled into the LACJ 2 system. 289. On March 5, 3 2010, defendant ULLOA, speaking in coded 4 language over the telephone, told defendant ARANA that ULLOA 5 would make $6,000 or $7,000 from the drugs that defendant DORADO 6 would be providing them to smuggle into NCCF. 290. On March 5, 2010, defendant ULLOA, 7 speaking in coded 8 language over the telephone, told an unindicted co-conspirator 9 that ULLOA and his associates had a shipment of drugs ready to 10 be smuggled into NCCF on March 18, 2010. 291. On March 6, 11 2010, defendant ULLOA, speaking in coded 12 language over the telephone, directed defendant ARANA to give 13 $1,000 to the person who was going to smuggle drugs into the 14 LACJ system for ULLOA, after ULLOA received the drugs. 292. On March 8, 15 2010, d.efendant DORADO, speaking in coded 16 language over the telephone, informed defendant ULLOA that 17 defendant AYALA was ready to turn himself in to the authorities 18 in order to smuggle drugs into the LACJ system for ULLOA and 19 DORADO. 293. On March 9, 20 2010, defendant ULLOA, speaking in coded 21 language over the telephone, asked defendant LOPEZ to provide 22 additional heroin on March 15, 2010 because ULLOA had someone 23 who was going to smuggle drugs into the LACJ system on March 18, 24 2010. 25 294. On March 10, 2010, defendant DORADO, speaking in coded 26 language over the telephone, advised defendant ULLOA that DORADO 27 would take the drugs from defendant ARANA and have defendant 28 63 1 GALVEZ package the drugs for defendant AYALA to smuggle into the 2 LACJ system. 3 295. On March 10, 2010, defendant DORADO, speaking in coded 4 language over the telephone, informed defendant ULLOA that 5 defendant GALVEZ had packaged drugs for them in the past and 6 would do a good job packaging the drugs being smuggled to ULLOA. 7 296. On March 12, 2010, defendant ULLOA, speaking in coded 8 language over the telephone, reminded defendant ARANA that she 9 needed to know exactly how their drugs were being smuggled into 10 the LACJ system because ARANA was handling all of ULLOA's 11 criminal activities while he was incarcerated. 12 297. On March 13, 2010, defendant FAZAH, speaking in coded 13 language over the telephone, informed defendant ULLOA that FAZAH 14 had an outstanding arrest warrant and could smuggle drugs into 15 the LACJ system. 16 298. On March 13, 2010, defendant LOPEZ, speaking in coded 17 language over the telephone, told defendant ULLOA that LOPEZ 18 possessed additional heroin that could be smuggled into the LACJ 19 system. 20 299. On March 13, 2010, defendant ULLOA, speaking in coded 21 language over the telephone, informed defendant LOPEZ that ULLOA 22 had two different shipments of drugs scheduled to be smuggled to 23 ULLOA in custody. 24 300. On March 16, 2010, defendant ARANA, speaking in coded 25 language over the telephone, told defendant ULLOA that 26 defendants DORADO and GALVEZ and another F13 Gang member would 27 be coming to her residence the following day to assist her 28 preparations for the upcoming drug smuggling operation. 64 301. On March 17, 2010, defendant ARANA, 1 speaking in coded 2 language over the telephone, informed defendant ULLOA that 3 defendant DORADO trusted defendant GALVEZ and wanted GALVEZ to 4 be involved in their efforts to smuggle drugs into the LACJ 5 system on March 18, 2010. 302. On March 17, 2010, defendant GALVEZ, speaking in coded 6 7 language over the telephone, informed defendant ULLOA that 8 GALVEZ was going to meet with defendant AYALA and would make 9 sure that AYALA understood the importance of completing the 10 11 delivery of drugs inside NCCF. 303. On March 17, 2010, defendant ULLOA, speaking in coded 12 language over the telephone, confirmed with defendant GALVEZ 13 that once defendant AYALA delivered drugs inside NCCF, AYALA 14 would receive payment for smuggling these drugs. 15 304. On March 17, 2010, defendant GALVEZ, speaking in coded 16 language over the telephone, advised defendant ULLOA that GALVEZ 17 would accompany defendant AYALA to court when AYALA turned 18 himself in to the authorities with drugs in his possession. 19 20 305. On March 17, 2010, defendant ARANA, speaking in coded language over the telephone, informed defendant ULLOA that 21 ? defendant GALVEZ had arrived at ARANA's residence to package 22 23 drugs. 306. On March 17, 2010, defendant ARANA, speaking in coded 24 language over the telephone, told defendant ULLOA that defendant 25 GALVEZ had not yet finished packaging the methamphetamine. 26 27 307. On March 17, 2010, defendant ARANA, speaking in coded language over the telephone, informed defendant ULLOA that 28 65 1 defendant GALVEZ had finished packaging the drugs that were 2 going to be smuggled into the LACJ system. 3 308. On March 17, 2010, defendant ULLOA, speaking in coded 4 language over the telephone, provided instructions to defendant 5 AYALA regarding what to do upon entering the LACJ system in 6 ?possession of drugs. 7 309. On March 17, 2010, defendant AYALA, speaking in coded 8 language over the telephone, confirmed with defendant ULLOA that 9 their efforts to smuggle drugs into the LACJ system were taking 10 11 place the following day. 310. On March 17, 2010, defendant ULLOA, speaking in coded 12 language over the telephone, told defendant AYALA that defendant 13 ARANA would drive AYALA to court the following day. 14 311. On March 18, 2010, defendants ARANA and GALVEZ and an 15 unindicted co-conspirator entered the Los Angeles Metropolitan 16 Courthouse on Hill Street, in Los Angeles, California, to assist 17 defendant AYALA, who was attempting to smuggle drugs into the 18 LACJ system. 19 312. On March 18, 2010, defendant AYALA possessed 20 approximately 4.3 grams of methamphetamine, 25 grams of a 21 mixture and substance containing a detectable amount of heroin, 22 and 15.1 grams of marijuana at the Los Angeles Metropolitan 23 Courthouse on Hill Street, in Los Angeles, California. 24 313. On March 18, 2010, defendant ARANA, speaking in coded 25 language over the telephone, reported to defendant ULLOA that 26 she and defendant GALVEZ had taken defendant AYALA to court to 27 smuggle drugs into the LACJ system. 28 66 1 314. On March 18, 2010, defendant ULLOA, speaking in coded 2 language over the telephone, advised defendant LOPEZ that 3 defendant AYALA had entered a court facility in possession of 4 drugs that were supposed to be delivered to ULLOA. 5 315. On March 18, 2010, defendant ARANA, speaking in coded 6 language over the telephone, reported to defendant ULLOA that 7 law enforcement had found the drugs that defendant AYALA had 8 been trying to smuggle into the LACJ system. 9 316. On April 1, 2010, defendant ARANA, speaking in coded 10 language over the telephone, informed defendant ULLOA that an 11 unindicted co-conspirator had identified an individual who was 12 wanted by the authorities and could smuggle drugs 13 system for them and that the unindicted co-conspirator could 14 supply them with methamphetamine. 15 in~o the LACJ 317. On April 1, 2010, defendant ULLOA, speaking in coded 16 language over the telephone, directed defendant ARANA to obtain 17 any quantity of methamphetamine she could for smuggling into the 18 LACJ system. 19 318. On April 1, 2010, defendant ULLOA, speaking in coded 20 language over the telephone, asked defendant ARANA to explain to 21 unindicted co-conspirators that defendant GALVEZ could wrap the 22 drugs up in small enough quantities to be swallowed and smuggled 23 into jail. 24 319. On April 15, 2010, defendant MARTINEZ, speaking in 25 coded language over the telephone, informed defendant LOPEZ that 26 an unindicted co-conspirator incarcerated at Ironwood State 27 Prison wanted to order five ounces of heroin from them. 28 67 1 320. On April 15, 2010, defendant LOPEZ, speaking in coded 2 language over the telephone, told defendant MARTINEZ what price 3 to charge for heroin ordered by an inmate at Ironwood State 4 Prison. 5 Fraudulent Scheme to Obtain Free Telephone Service 6 321. On February 18, 2010, defendants ULLOA and ARANA 7 together called a telephone service provider, and ARANA 8 represented that she was victim L.T. and asked the customer 9 service representative to make sure that a telephone number 10 could receive collect calls from correctional institutions. 11 322. On February 19, 2010, defendant ULLOA, using a 12 telephone, informed defendant ARANA that she should keep 13 changing the telephone numbers for each account in order to 14 extend their ability to have free telephone service. 15 323. On February 21, 2010, defendant ULLOA, using a 16 telephone, provided defendant ARANA with personal identifying 17 information for three individuals to use in setting up telephone 18 accounts. 19 324. On February 21, 2010, defendant ULLOA, using a 20 telephone, provided defendant ARANA with seven addresses in 21 Oxnard, California, to use in setting up telephone accounts. 22 325. On February 23, 2010, defendants ULLOA and ARANA 23 together called a telephone service provider, and ARANA 24 represented that she was victim L.T. and requested technical 25 assistance with a telephone account obtained in the name of L.T. 26 27 326. On February 23, 2010, defendant ULLOA called a telephone service provider and, posing as victim R.A.A., checked 28 68 1 on the status of an earlier request to initiate service and 2 requested that calls be forwarded to another telephone number. 3 327. On March 2 1 2010 1 defendant ULLOA called a telephone 4 service provider andr posing as victim R.A.A. 5 status of service to the telephone number obtained in the name 6 of R.A.A. 7 328. On March 2 1 2010 1 1 checked on the defendants ULLOA and ARANA called a 8 telephone service provider 1 and ARANA 1 posing as victim L.T. 9 requested that the telephone line for the account in the name of 10 11 1 L.T. be forwarded to a telephone number designated by ARANA. 329. On March 6 1 2010 1 defendants ULLOA and ARANA called a 12 telephone service provider 1 and ARANA 1 posing as victim A.P. 13 requested that calls to the account in the name of A.P. be 14 forwarded to the telephone number designated by defendant ARANA. 15 330. On March 11 1 2010 1 defendants ULLOA and ARANA called a 1 16 telephone service provider/ and ARANA 1 posing as victim E.M. 17 checked on the status of her prior request that two telephone 18 lines for the account in E.M. 19 number designated by ARANA. 20 1 S 1 name be forwarded to a telephone 331. On March 13r 2010 1 defendant ULLOA 1 using a telephoner 21 offered to allow two unindicted co-conspirators to participate 22 in the plan to obtain free telephone service. 23 332. On March 14 1 2010 1 defendant ULLOA 1 using a telephoner 24 told defendant ARANA to research addresses in Sylmar/ 25 California 1 to use in the plan to obtain free telephone service. 26 27 333. On March 14 1 2010 1 an unindicted co-conspirator provided defendants ULLOA and ARANA with personal identifying 28 69 1 information for three victims to be used in the plan to obtain 2 free telephone service. 3 334. On March 14, 2010, defendant ULLOA, speaking in coded 4 language over the telephone, asked defendant ARANA to call an 5 unindicted co-conspirator in order to obtain additional profiles 6 containing victim identifying information. 7 335. On March 15, 2010, defendant ULLOA, using a telephone, 8 told defendant ARANA to forward one of the previously obtained 9 telephone accounts to a designated telephone number for use by 10 11 an unindicted co-conspirator. 336. On March 18, 2010, defendants ULLOA and ARANA called a 12 telephone service provider, and ARANA, posing as victim L.T., 13 requested that the telephone line .for the account in the name of 14 L.T. be forwarded to a telephone number designated by ARANA. 15 337. On March 21, 2010, defendant ULLOA, using a telephone, 16 pro~ided 17 up future telephone lines. 18 defendant ARANA with five addresses for use in setting 338. On March 21, 2010, defendant ULLOA, using a telephone, 19 provided defendant ARANA with personal identifying information 20 of three victims for use in the plan to obtain free telephone 21 service. 22 339. On March 21, 2010, defendant ULLOA, speaking in coded 23 language over the telephone, requested that defendant ARANA 24 contact an unindicted co-conspirator in order to obtain 25 additional profiles containing victim identifying information. 26 340. On March 22, 2010, defendants ULLOA and ARANA called a 27 telephone service provider, and ARANA, posing as victim E.S., 28 requested a new telephone number under that identity. 70 1 341. On March 22, 2010, defendant ULLOA called a telephone 2 service provider and, posing as victim A.F., requested a new 3 telephone number for the account in the name of A.F. 4 342. On March 22, 2010, defendant ARANA, using a telephone, 5 told defendant ULLOA that she had created three new telephone 6 lines and that they now had a total of six to seven telephone 7 lines available for use. 8 9 10 11 343. On March 22, 2010, defendant ULLOA, using a telephone, informed defendant ARANA that they would keep several of the telephone lines for their own use and would sell the rest. 344. On March 22, 2010, defendants ULLOA and ARANA called a 12 telephone service provider, and ARANA requested that the 13 telephone line in the name of victim L.T. be forwarded to a new 14 telephone number designated by ARANA. 15 345. On March 23, 2010, defendant ULLOA, using a telephone, 16 advised defendant ARANA that she should call a telephone service 17 provider on another telephone line, so that the jail recording 18 system would not capture the call. 19 346. On May 26, 2010, defendant ARANA maintained and 20 possessed a spiral-bound notebook containing addresses and 21 personal information used to set up telephone accounts, 22 telephone numbers that those accounts were forwarded to, and the 23 status of the accounts. 24 347. On May 30, 2011, defendant J. MEDINA, using a 25 telephone, provided defendant ULLOA with the account information 26 for the telephone account in the name of victim G.V. 27 348. On May 30, 2011, defendant J. MEDINA, using a 28 telephone, provided defendant ULLOA with two addresses to be 71 1 used in connection with the plan to obtain free telephone 2 service. 3 349. On May 30, 2011, defendant J. MEDINA, using a 4 telephone, gave defendant ULLOA the personal identifying 5 information of a victim for use in the plan to obtain free 6 telephone service. 7 350. On May 30, 2011, defendant ULLOA called a telephone 8 service provider and, posing as victim G.V., requested that 9 calls to two lines in the name of G.V. be forwarded to telephone 10 numbers designated by ULLOA. 11 351. On July 3, 2011, defendant MEDINA, using a telephone, 12 advised defendant ULLOA ?about the status of a new telephone line 13 she had set up as part of the plan to obtain free telephone 14 service. 15 352. On July 6, 2011, defendant J. MEDINA, using a 16 telephone, reported to defendant ULLOA that J. MEDINA had 17 followed ULLOA's instructions to test one of the telephone lines 18 by calling it to see if her call was forwarding as they had 19 requested. 20 c. SPECIAL SENTENCING ALLEGATIONS 21 The Grand Jury further alleges that: 22 1. Beginning on a date unknown to the Grand Jury, and 23 continuing to on or about August 1, 2013, in Los Angeles County, 24 within the Central District of California, and elsewhere, 25 defendants L. LAREDO, CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, 26 ESPINOZA, MAESTAS, JUAREZ, SIFUENTES, ULLOA, ARANA, J. MEDINA, 27 DORADO, FAZAH, GALVEZ; AYALA, ACOSTA, GRANADOS, CAZERES, 28 MANDUJANO, MENDEZ, AVILA, SANCHEZ, BECERRA, and BARRAZA, and 72 1 others known and unknown to the Grand Jury, conspired and agreed 2 with each other to knowingly and intentionally commit the 3 following offenses: 4 (a) To distribute at least 50 grams of 5 methamphetamine, a Schedule II controlled substance, in 6 violation of Title 21, United States Code, Sections 841(a) (1) 7 and (b) (1) (A) (viii) ; 8 9 (b) To possess with intent to distribute at least 50 grams of methamphetamine, a Schedule II controlled substance, in 10 violation of Title 21, United States Code, Sections 841(a) (1) 11 and (b) (1) (A) (viii); 12 (c) To distribute at least 1000 kilograms of a 13 mixture and substance containing a detectable amount of 14 marijuana, a Schedule I 15 Title 21, United States Code, Sections 841(a) (1) and 16 (b) (1) (A) (vii); 17 (d) controlled substance, in violation of To possess with intent to distribute at least 18 1000 kilograms of a mixture and substance containing a 19 detectable amount of marijuana, a Schedule I 20 substance, in violation of Title 21, United States Code, 21 Sections 841 (a) (1) and (b) (1) (A) (vii); 22 (e) controlled To distribute at least one kilogram of a mixture 23 and substance containing a detectable amount of heroin, a 24 Schedule I narcotic drug controlled substance, in violation of 25 Title 21, United States Code, Sections 841(a) (1) and 26 (b) (1) (A) (i); 27 (f) 28 To possess with intent to distribute at least one kilogram of a mixture and substance containing a detectable 73 1 amount of heroin, a Schedule I narcotic drug controlled 2 substance, in violation of Title 21, United States Code, 3 Sections 841(a) (1) and (b) (1) (A) (i). 4 5 (All in violation of Title 18, United States Code, Section 1,962(d).) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 74 COUNT TWO 1 [18 2 1. 3 u.s.c. ? 1959(a) (3)] At all times relevant to this Indictment, the F13 4 Gang, as described more particularly in Paragraphs One through 5 Eleven of the Introductory Allegations of this Indictment, which 6 paragraphs are hereby re-alleged and incorporated by reference 7 as though fully set forth herein, constituted an enterprise, as 8 that term is defined in Title 18, United States Code, Section 9 1959(b) (2), that is, a group of individuals associated in fact, 10 which was engaged in, and the activities of which affected, 11 interstate and foreign commerce. 12 ongoing organization whose members functioned as a continuing 13 unit for a common purpose of achieving the objectives of the 14 enterprise. 15 2. The enterprise constituted an At all times relevant to this Indictment, the F13 16 Gang, through its members and associates, engaged in 17 racketeering activity, as defined in Title 18, United States 18 Code, Sections 1959(b) (1) and 1961(1), that is, acts involving: 19 (a) the distribution of, possession with intent to 20 distribute, and conspiracy to distribute and/or possess with 21 intent to distribute, controlled substances, in violation of 22 Title 21, United States Code, Sections 841 (a) (1), 843 (b), and 23 846 i 24 25 26 27 28 (b) murder, in violation of California Penal Code Sections 21a, 31, 182, 187, 189, 190, and 664; and (c) extortion, in violation of California Penal Code Sections 31, 182, 518, 519, 520, 664; and acts indictable under: 75 (d) 1 2 Title 18, United States Code, Section 1955 (illegal gambling) ; and 3 (e) 4 fraud). 5 3. Title 18, United States Code, Section 1343 (wire On or about March 14, 2010, in Los Angeles County, 6 within the Central District of California, for the purpose of 7 maintaining and increasing position in the F13 Gang, an 8 enterprise engaged in racketeering activity, defendant JOSUE 9 ROJAS, also known as "Chino," and others known and unknown to 10 the Grand Jury, assaulted victim R.A. resultiny in serious 11 bodily injury, in. violation of California Penal Code Section 12 245 (a) 13 14 (4) . (All in violation of Title 18, United States Code, Section 1959 (a) (3).) 15 16 17 18 19 20 21 22 23 24 ?25 26 27 28 76 1 COUNT THREE 2 3 [18 U.S.C. ? 1959(a)(6)] 1-2. Paragraphs One and Two of Count Two of this Indictment 4 are hereby re-alleged and incorporated by reference as though 5 fully set forth herein. 6 3. On or about March 14, 2010, in Los Angeles County, 7 within the Central District of California, for the purpose of 8 maintaining and increasing position in the F13 Gang, an 9 enterprise engaged in racketeering activity, defendants JAVIER 10 MANUEL ULLOA, also known as ("aka") 11 "Yogi," TANNOUS FAZAH, aka "Terist," and JOSUE ROJASJ aka 12 "Chino," and others known and unknown to the Grand Jury, did 13 unlawfully conspire to assault victim R.A. resulting in serious 14 bodily injury, in violation of California Penal Code Sections 15 182 and 245 (a) (4). 16 17 "Yogi," JOSE DORADO, aka (All in violation of Title 18, United States Code, Section 1959(a)(6).) 18 19 20 21 22 23 24 25 26 27 28 77 COUNT FOUR 1 [21 u.s.c. 2 ? 846] Paragraphs One through Eleven of the Introductory 3 4 Allegations of this Indictment are hereby re-alleged and 5 incorporated by reference as though fully set forth herein. 6 A. 7 OBJECTS OF THE CONSPIRACY 2. Beginning on a date unknown to the Grand Jury, and 8 continuing to on or about August 1, 2013, in Los Angeles County, 9 within the Central District of California, and elsewhere, 10 defendants L. LAREDO, CERVANTES, LOPEZ, MARTINEZ, M. LAREDO, 11 ESPINOZA, MAESTAS, JUAREZ, SIFUENTES, ULLOA, ARANA, J. MEDINA, 12 DORADO, FAZAH, GALVEZ, AYALA, ACOSTA, GRANADOS, CAZERES, 13 MANDUJANO, MENDEZ, AVILA, SANCHEZ, BECERRA, BARRAZA, JESUS MEZA, 14 aka "Chana" 15 PROO, aka "D" 16 Grand Jury, conspired and agreed with each other to knowingly 17 and intentionally commit the following offenses: 18 (a) ( "MEZA") , HAYDEE MEDINA ("H. MEDINA") , and DAVID ("PROO"), and others known and unknown to the To distribute at least 50 grams of 19 methamphetamine, a Schedule II controlled substance, in 20 violation of Title 21, United States Code, Sections 841(a) (1) 21 and (b) (1) (A) (viii); 22 (b) To possess with intent to distribute at least 50 23 grams of methamphetamine, a Schedule II controlled substance, in 24 violation of Title 21, United States Code, Sections 841(a) (1) 25 and (b) ( 1) (A) (viii) ; 26 (c) To distribute at least 1000 kilograms of a 27 mixture and substance containing a detectable amount of 28 marijuana, a Schedule I controlled substance, in violation of 78 1 Title 21, United States Code, Sections 841(a) (1) and 2 (b) (1) (A) (vii); 3 (d) To possess with intent to distribute at least substan~e 4 1000 kilograms of a mixture and 5 detectable amount of marijuana, a Schedule I 6 substance, in violation of Title 21, United States Code, 7 Sections 841(a) (1) and (b) (1) (A) (vii); 8 9 (e) containing a controlled To distribute at least one kilogram of a mixture and substance containing a detectable amount of heroin, a 10 Schedule I narcotic drug controlled substance, in violation of 11 Title 21, United States Code, Sections 841(a) (1) and 12 (b) (1) (A) (i); 13 (f) To possess with intent to distribute at least one 14 kilogram of a mixture and substance containing a detectable 15 amount of heroin, a Schedule I narcotic drug controlled 16 substance, in violation of Title 21, United States Code, 17 Sections 841(a) (1) and (b) (1) (A) (i); 18 (g) To distribute a mixture and substance containing 19 a detectable amount of cocaine, a Schedule I I narcotic drug 20 controlled substance, in violation of Title 21, United States 21 Code, Sections 841 (a) (1) and (b) (1) (C); 22 (h) To possess with intent to distribute a mixture 23 and substance containing a detectable amount of cocaine, a 24 Schedule I I narcotic drug controlled substance, in violation of 25 Title 21, United States Code, Sections 841(a) (1) and (b) (1) (C). 26 Ill Ill Ill 27 28 79 1 B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE 2 ACCOMPLISHED 3 1-13. The Grand Jury re-alleges and incorporates by 4 reference as though fully set forth herein Paragraphs One 5 through 13 of Section A of Count One of this Indictment. 14. 6 Defendants J. MEDINA and H. MEDINA would obtain 7 controlled substances and transport them across the border from 8 Mexico for distribution in the United States. 9 15. Defendant MEZA, and others known and unknown to the 10 Grand Jury, would supply defendant CERVANTES and other F13 Gang 11 members and associates with distributable amounts of controlled 12 substances. 13 16. Defendant PROO would assist defendant SIFUENTES by 14 brokering drug transactions with prospective customers and would 15 sell controlled substances supplied by SIFUENTES. 16 C. 17 OVERT ACTS In furtherance of the conspiracy, and to accomplish the 18 objects of the conspiracy, defendants L ..LAREDO, CERVANTES, 19 LOPEZ, MARTINEZ, M. LAREDO, ESPINOZA, MAESTAS, JUAREZ, 20 SIFUENTES, ULLOA, ARANA, J. MEDINA, H. MEDINA, DORADO, FAZAH, 21 GALVEZ, AYALA, ACOSTA, GRANADOS, CAZERES, MANDUJANO, MENDEZ, 22 AVILA, SANCHEZ, BECERRA, BARRAZA, MEZA, H. MEDINA, and PROO, and 23 others known and unknown to the Grand Jury, committed and caused 24 to be committed various overt acts, on or about the following 25 dates, within the Central District of California, and elsewhere, 26 including, but not limited to, the following: 27 28 80 1 1-353. The Grand Jury re-alleges and incorporates by 2 reference as though fully set forth herein Paragraphs 1 through 3 353 of Section B of Count One of this Indictment. 4 354. On July 25, 2011, defendant J. MEDINA, speaking in 5 coded language over the telephone, informed defendant ULLOA that 6 she was taking steps to make money they needed and that she had 7 arranged with defendant H. MEDINA to transport methamphetamine 8 from Mexico into the United States approximately a week later. 9 355. On July 30, 2011, defendants J. MEDINA and H. MEDINA 10 left the Los Angeles area and traveled to Mexico in order to 11 bring methamphetamine intoothe United States. 12 356. On or before August 2, 2011, defendants J. MEDINA and 13 H. MEDINA obtained approximately 10,153.6 grams of 14 methamphetamine that they intended to transport into the United 15 States. 16 357. On August 2, 2011, defendants J. MEDINA and H. MEDINA 17 possessed approximately 10,153.6 grams of methamphetamine, in a 18 vehicle belonging to H. MEDINA, at the Otay Mesa port of entry 19 in San Diego, California. 20 358. In or around November 2011, defendant J. MEDINA wrote, 21 and attempted to send, a letter to defendant H. MEDINA seeking 22 to coordinate their statements to law enforcement so that J. 23 MEDINA could take the blame for the methamphetamine seizure on 24 August 2, 2011. 25 26 27 28 81 1 2 COUNT FIVE [21 U.S.C. ?? 841 (a) (1), (b) (1) (B) (viii)] 3 On or about October 7, 2009, in Los Angeles County, within 4 the Central District of California, defendant ALBERT SIFUENTES, 5 also known as "Bluebird," knowingly and intentionally 6 distributed at least five grams, that is, approximately 11.3 7 grams, of methamphetamine, a Schedule II controlled substance. 8 9 10. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 82 COUNT SIX 1 2 3 [21 U.S.C. ?? 841(a) (1), (b) (1) (C)] On or about March 2, 2010, in Los Angeles County, within 4 the Central District of California, defendants ALBERT SIFUENTE~, 5 also known as ("aka") Bluebird, and DAVID PROO, aka "0," 6 knowingly and intentionally distributed approximately 2.3 grams 7 of methamphetamine, a Schedule II controlled substance. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 83 1 2 3 COUNT SEVEN [21 U.S.C. ?? 841(a) (1), (b) (1) (b) (viii)] On or about March 14, 2010, in Los Angeles County, within 4 the Central District of California, defendant TANNOUS FAZAH, 5 also known as "Terist," knowingly and intentionally possessed 6 with intent to distribute at least five grams, that is, 7 approximately 16.9 grams, of methamphetamine, a Schedule II 8 controlled substance. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 84 COUNT EIGHT 1 2 3 [21 u.s.c. ?? 841(a) (1), (b) (1) (C); 18 u.s.c. ? 2(a)] On or about March 18, 2010, in Los Angeles County, within 4 the Central District of California, defendants JAVIER ULLOA, 5 also known as ("aka") 6 "Yogi," JOSE GALVEZ, aka "Pecas," and EDWARD AYALA, aka "Lalo," 7 while aiding and abetting each other, knowingly and 8 intentionally possessed with intent to distribute approximately 9 25 grams of a mixture and substance containing a detectable "Yogi," CELINA ARANA, JOSE DORADO, aka 10 amount of heroin, a Schedule I narcotic drug controlled 11 substance. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 85 1 2 3 COUNT NINE [21 u.s.c. ?? 841 (a) (1), (b) (1) (D); 18 u.s.c. ? 2 (a) J On or about June 28, 2010, in Los Angeles County, within 4 the Central District of California, defendants HECTOR MARTINEZ, 5 also known as ("aka") "Liar-Liar," and JESSE BARRAZA, aka 6 "Chapito," aka "Chapo," while aiding and abetting each other, 7 knowingly and intentionally possessed with intent to distribute 8 a mixture and substance containing a detectable amount of 9 marijuana, a Schedule I controlled substance. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 86 COUNT TEN l 2 3 [2l U.S.C. ?? 84l (a) (l), (b) (l) (D) i l8 U.S.C. ? 2 (a)] On or about November 8, 20l0, in Los Angeles County, within 4 the Central District of California, defendants JESUS CERVANTES, 5 also known as ("aka") 6 JESUS MEZA, aka "Chana," knowingly and intentionally possessed 7 with intent to distribute a mixture and substance containing a 8 detectable amount of marijuana, a Schedule I controlled 9 substance. "B-Bad," aka "Jessica," aka "Estela," and lO ll l2 l3 l4 l5 l6 l7 l8 l9 20 2l 22 23 24 25 26 27 28 87 COUNT ELEVEN 1 2 3 [21 u.s.c. ?? 841(a) (1), (b) (1) (D)] On or about November 16, 2010, in Los Angeles County, 4 within the Central District of California, defendant ARTURO 5 MENDEZ, also known as "Picachu," knowingly and intentionally 6 possessed with intent to distribute a mixture and substance 7 containing a detectable amount of marijuana, a Schedule I 8 controlled substance. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 88 1 2 3 COUNT TWELVE [21 u.s.c. ?? 841(a) (1), (b) (1} (D)] On or about November 18, 2010, in Los Angeles County, 4 within the Central District of California, defendant JULIAN 5 BECERRA, also known as ("aka") "Julio," aka "Juan Pablo Perez," 6 knowingly and intentionally possessed with intent to distribute 7 a mixture and substance containing a detectable amount of 8 marijuana, a Schedule I controlled substance. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26? 27 28 89 1 2 3 COUNT THIRTEEN [21 U.S.C. ?? 841(a) (1), (b) (1) (B) (viii); 18 U.S.C. ? 2(a)] On or about November 19, 2010, in Los Angeles County, 4 within the Central District of California, defendants JESUS 5 CERVANTES, also known as ("aka") "B-Bad," aka "Jessica," aka 6 "Estela," JOSE GRANADOS, aka "Tricky," and JOSE CAZERES, aka 7 "Pelon," while aiding and abetting each other, knowingly and 8 intentionally possessed with intent to distribute at least five 9 grams, that is, approximately 10.4 grams, of methamphetamine, a 10 Schedule II controlled substance. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 90 1 2 COUNT FOURTEEN [21 u.s.c. ?? 841(a) (1), (b) (1) (B) (viii)] 3 On or about November 22, 2010, in Los Angeles County, 4 within the Central District of California, defendant OSCAR 5 OLIVERA AVILA, also known as 6 Olvera," aka "Rigo Perez Suarez," knowingly and intentionally 7 possessed with intent to distribute at least five grams, that 8 is, approximately 14.6 grams, of methamphetamine, a Schedule II 9 controlled substance. ("aka") "Ruben Ramirez," aka "Oscar 10 11 12 13 14 15 16 17 18 19 20 2122 23 24 25 26 27 28 91 1 2 3 COUNT FIFTEEN [21 U.S.C. ?? 841(a) (1), (b) (1) (B) (viii)] On or about November 23, 2010, in Los Angeles County, 4 within the Central District of California, defendants JESUS 5 CERVANTES, also known as ("aka") '"B-Bad," aka "Jessica," aka 6 "Estela," and JOSE GRANADOS, aka "Tricky," knowingly and 7 intentionally possessed with intent to distribute at least five 8 grams, that is, approximately 5.6 grams, of methamphetamine, a 9 Schedule II controlled substance. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 92 1 2 COUNT SIX TEEN [21 U.S.C. ?? 841(a) (1), (b) (1) (D)] 3? On or about November 23, 2010, in Los Angeles County, 4 within the Central District of California, defendant JESUS 5 CERVANTES, also known as ("aka") "B-Ead," aka "Jessica," aka 6 "Estela," knowingly and intentionally possessed with intent to 7 distribute a mixture and substance containing ~ detectable 8 amount of marijuana, a Schedule I controlled substance. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 93 1 2 3 COUNT SEVENTEEN [21 U.S.C. ?? 841(a) (1) On or about February 25 1 (b) (1) (B) (viii)) 2011, in Los Angeles County/ 1 4 within the Central District of California, defendant MAX 5 MAESTAS, also known as "Snow 1 6 distributed at least five grams, that is, approximately 13.7 7 grams, of methamphetamine, a Schedule II controlled substance. " knowingly and intentionally 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 94 1 2 3 COUNT EIGHTEEN [21 U.S.C. ?? 841(a) (1), (b) (1) (B) (viii)] On or about March 18, 2011, in Los Angeles County, within 4 ?the Central District of California, defendant MAX MAESTAS, also 5 known as "Snow," knowingly and intentionally distributed at 6 least five grams, that is, approximately 27.6 grams, of 7 methamphetamine, a Schedule II controlled substance. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 95 1 2 3 COUNT NINTEEN [21 U.S.C. ?? 841(a) (1), (b) (1) (B) (viii)] On or about April 15, 2011, in Los Angeles County, within 4 the Central District of California, defendants MAX MAESTAS, also 5 known as ("aka") 6 knowingly and intentionally distributed at least five grams, 7 that is, approximately 27.5 grams, of methamphetamine, a 8 Schedule II controlled substance. "Snow," and RENE JUAREZ, aka "Scrappy," 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 96 1 2 3 COUNT TWENTY [21 U.S.C. ?? 841(a)(1), (b)(1)(A)(viii)] On or about May 18, 2011, in Los Angeles County, within the 4 Central District of California, defendants 5 known as ("aka") "Snow," and RENE JUAREZ, aka "Scrappy," 6 knowingly and intentionally distributed at least 50 grams, that 7 is, approximately 80 grams, of methamphetamine, a Schedule II 8 controlled substance. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 97 MAX MAESTAS, also COUNT TWENTY-ONE 1 2 3 [21 U.S.C. ?? 841(a) (1), (b) (1) (A) (viii)] On or about June 27, 2011, in Los Angeles County, within 4 the Central District of California, defendant ALBERT SIFUENTES, 5 also known as "Bluebird," knowingly and intentionally 6 distributed at least 50 grams, that is, approximately 56 grams, 7 of methamphetamine, a Schedule II controlled substance. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 98 1 2 3 COUNT TWENTY-TWO [21 U.S.C. ?? 841(a) (1), (b) (1) (A) (viii)] On or about July 6, 2011, in Los Angeles County, within the 4 Central District of California, defendant RENE JUAREZ, also 5 known as "Scrappy," knowingly and intentionally distributed at 6 least 50 grams, that is, approximately 109.7 grams, of 7 methamphetamine, a Schedule I I co~trolled 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 99 substance. 1 COUNT TWENTY-THREE 2 3 [18 U.S.C. ? 922 (a) (1) (A)] Between on or about October 8, 2009, and on or about 4 October 14, 2011, in Los Angeles County, within the Central 5 District of California, defendant ALBERT SIFUENTES, also known 6 as "Bluebird," not being a licensed importer, licensed 7 manufacturer, or licensed dealer, willfully engaged in the 8 business of importing, manufacturing, and dealing in firearms, 9 specifically, the sales of the following firearms on or about 10 11 12 the following dates: DATE October 8j FIREARM 2009 13 14 January 15, 2010 (1) A Luger Sten-type 9mm caliber machinegun, without a serial number. July 11, 2011 (1) A Ruger model MK II Target .22 caliber pistol, bearing serial number 219-74002. July 12, 2011 (1) A Glock model 23 .40 caliber pistol, bearing serial number LTR211i 15 16 (1) A Smith & Wesson model SW9VE 9mm caliber pistol, bearing serial number PBU6848. 17 18 19 (2) A Llama Gabilondo & CIA model Omni 9mm caliber pistol, bearing serial number PA2091i 20 21 (3) An Arcadia Machine & Tool California model Backup .380 caliber pistol, bearing serial number A34185i 22 23 (4) A Ruger model P95DC 9mm caliber pistol, bearing serial number 313-29545. 24 25 26 27 28 August 3, 2011 (1) A Smith & Wesson model 22A .22 caliber pistol, bearing serial number UAY4273i (2) A Walther model P38 9mm caliber pistol, bearing serial number 021806E. 100 (1) A Springfield Armory model XD-40 .40 caliber pistol, bearing serial number US432816. (1) A Smith & Wesson .38 caliber revolver, unknown model, bearing serial number 753514. (1) A Marlin Firearms Company model 336CS 30/3WIN rifle, bearing serial number 10011379. 8 September 2, 2011 (1) A Norinco North China Industries model NHM90 7.62 caliber rifle, bearing serial number MS013867. September 8, 2011 (1) An Israeli Military Industries model Desert Eagle .40 caliber pistol, bearing serial number 32316062; 9 10 11 12 (2) A Beretta USA Corp model 96 .40 caliber pistol, bearing serial number BER221431; 13 (3) A Colt model MKIV/Series '80 Government .380 Auto caliber semiautomatic pistol, bearing serial?number RC06813. 14 15 16 October. 11, 2011 17 A Heckler and Koch model P2000SK .40 ( 1) caliber pistol, bearing serial number 122004997; 18 (2) A Taurus model PT24/7 PRO DS .40 caliber pistol, bearing serial number SCR72435. 19 20 21 22 23 October 14, 2011 (1) A Beretta Pietro S.P.A model CX4 Storm 9mm caliber rifle, bearing serial number CX06762; (2) A Mossberg model 500A 12-gauge shotgun, bearing serial number R904073. 24 25 26 27 28 101 1 COUNTS TWENTY-FOUR THROUGH THIRTY-FIVE 2 [18 3 u.s.c. ? 922(g) (1)] Between on or about October 8, 2009, and on or about 4 October 14, 2011, in Los Angeles County, within the Central 5 District of California, defendant ALBERTO SIFUENTES, also known 6 as "Bluebird" 7 firearms, on or about the following dates, in and affecting 8 interstate and foreign commerce, after defendant SIFUENTES had 9 been convicted of at least one of the following felony crimes, 10 ("SIFUENTES"), knowingly possessed the following each punishable by a term of imprisonment exceeding one year: (1) 11 Possession of Marijuana for Sale, in violation of 12 California Health and Safety Code Section 11359, in the Superior 13 Court of the State of California, County of Los Angeles, case 14 number BA218782, on or about July 16, 2001; (2) 15 Possession of a Controlled Substance, in violation of 16 California Health and Safety Code Section 11350(a), in the 17 Superior Court of the State of California, County of Los 18 Angeles, case number VA103543, on or about January 24, 2008. 19 20 COUNT -- DATE FIREARM 21 TWENTYFOUR October 8, 2009 Smith & Wesson model SW9VE 9mm caliber pistol, bearing serial number PBU6848. TWENTYFIVE January 15, 2010 Luger Sten-type 9mm caliber machinegun, without a serial number. TWENTYSIX July 11, 2011 Ruger model MK II Target .22 caliber pistol, bearing serial number 219-74002. 22 23 24 25 26 27 28 102 1 2 TWENTYSEVEN July 12, 2011 (2) Llama Gabilondo & CIA model Omni 9mm caliber pistol, bearing serial number PA2091; 3 4 (3) Arcadia Machine & Tool California model Backup .380 caliber pistol, bearing serial number A34185; and 5 6 7 (4) Ruger model P95DC 9mm caliber pistol, bearing serial number 313-29545. 8 9 10 TWENTYEIGHT August 3, 2011 (1) Smith & Wesson model 22A .22 caliber pistol, bearing serial number UAY4273; and (2) Walther model P38 9mm caliber pistol, bearing serial number 021806E. 11 12 (1) Glock model 23 .40 caliber pistol, bearing serial number LTR211; August 9, 2011 Springfield Armory model XD-40 .40 caliber pistol, bearing serial number US432816. 13 ?TWENTYNINE 14 THIRTY August 18, 2011 Smith & Wesson .38 caliber revolver, unknown model, bearing serial number 753514. THIRTYONE August 30, 2011 Marlin Firearms Company model 336CS 30/3WIN rifle, bearing serial number 10011379. THIRTYTWO September 2, 20.11 Norinco North China Industries model NHM90 7.62 caliber rifle, bearing serial number MS013867. THIRTYTHREE September 8, 2011 (1) Israeli Military Industries model Desert Eagle .40 caliber pistol, bearing serial number 32316062; 15 16 17 18 19 20 21 22 23 24 25 26 (2) Beretta USA Corp model 96 .40 caliber pistol, bearing serial number BER221431; and (3) Colt model MKIV/Series '80 Government . 380 Auto caliber semiautomatic pistol,? bearing serialnumber RC06813. 27 28 103 1 2 THIRTYFOUR October 11, 2011 3 (2) Taurus model PT24/7 PRO DS .40 caliber pistol, bearing serial number SCR72435. 4 5 6 7 8 (1) Heckler and Koch model P2000SK .40 caliber pistol, bearing serial number 122004997; and THIRTYFIVE October 14, 2011 (1) Beretta Pietro S.P.A model CX4 Storm 9mm caliber rifle, bearing serial number CX06762; and (2) Mossberg model 500A 12-gauge shotgun, bearing serial number R904073. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 104 1 COUNT THIRTY-SIX 2 3 [18 u.s.c. ? 922(g)(1)] On or about March 14, 2010, in Los Angeles County, within 4 the Central District of California, defendant TANNOUS FAZAH, 5 also known as "Terist" 6 following firearms and ammunition, in and affecting interstate 7 and foreign commerce: 8 9 10 11 (1) ("FAZAH"), knowingly possessed the a Marlin Glenfield model 60 .22 caliber semiautomatic rifle, bearing serial number 22428184; (2) two (2) rounds of CCI/Speer Long Rifle .22 caliber ammunition; and 12 (3) 10 rounds of Remington Magnum .44 caliber ammunition. 13 Such possession occurred after defendant FAZAH had been 14 convicted of the following felony crime punishable by a term of 15 imprisonment exceeding one year: Possession of a Controlled 16 Substance, in violation of California Health and Safety Code 17 Section 11350(a), in 18 California, County of Los Angeles, case number VA107994, on or 19 about October 13, 2009. t~e Superior Court of the State of 20 21 22 23 24 25 26 27 28 105 1 COUNT THIRTY-SEVEN 2 [18 3 u.s.c. ? 922(g) (1)] On or about November 19, 2010, in Los Angeles County, 4 within the Central District of California, defendant JOSE 5 SANCHEZ, also known as "Trouble" ("SANCHEZ"), knowingly 6 possessed the following firearms and ammunition, in and 7 affecting interstate and foreign commerce: 8 9 (1) a Hi-Point model C9 9mm caliber semiautomatic pistol, bearing serial number P194467; 10 (2) 19 rounds of Winchester 9mm caliber ammunition; 11 (3) six (6) rounds of Remington 9mm caliber ammunition; 12 (4) nine (9) rounds of Federal 9mm caliber ammunition; 13 (5) three (3) rounds of CCI/Speer 9mm caliber ammunition; 15 (6) six (6) rounds of Fiocchi 9mm caliber ammunition. 16 Such possession occurred after defendant SANCHEZ had been 14 and 17 convicted of the following felony crime punishable by a term of 18 imprisonment exceeding one year: Grand Theft from the Person of 19 Another, in violation of California Penal Code Section 487(C), 20 in the Superior Court of the State of California, County of Los 21 Angeles, case number BA309370, on or about December 12, 2006. 22 23 24 25 2,6 27 28 106 1 COUNT THIRTY-EIGHT. 2 [18 u.s.c. ? 922(g) (1)] 3 On or about November 22, 2010, in Los Angeles County, 4 within the Central District of California, defendant OSCAR 5 OLIVERA AVILA, also known as ("aka") "Ruben Ramirez," aka "Oscar 6 Olvera," aka "Rigo Perez Suarez'' 7 the following firearms and ammunition, in and affecting 8 interstate and foreign commerce: 9 10 11 12 (1) ("AVILA"), knowingly possessed a Bryco Arms model 59 9mm caliber pistol, bearing serial number 942343; (2) a Smith & Wesson model 67 .38 caliber revolver, bearing serial number 6k68119; 13 (3) 15 rounds of 9mm caliber ammunition; and 14 (4) one (1) round of ?Fiocchi .38 caliber ammunition. 15 Such possession occurred after defendant AVILA had been 16 convicted of the following felony punishable by a term of 17 imprisonment exceeding one year: Possession for Sale - Cocaine, 18 in violation of California Health and Safety Code Section 11351, 19 in the Superior Court of the State of California, County of 20 Santa Clara, case number 126340, on or about January 5, 1989. 21 22 23 24 25 26 27 28 107 1 COUNT THIRTY-NINE 2 3 [18 u.s.c. ? 922 (g) (1)] On or about July 6, 2011, in Los Angeles County, within the 4 Central District of California, defendant RENE JUAREZ, also 5 known as "Scrappy" ("JUAREZ"), knowingly possessed the following 6 firearms and ammunition, in and affecting interstate and foreign 7 commerce: 8 9 (1) a Rossi 12-gauge shotgun, unknown model, bearing serial number 84293; 10 (2) 11 serial number; 12 (3) 13 a Savage model 220A .410 bore shotgun, without a a Winchester model 1897 12-gauge shotgun, bearing serial number 449946; and 14 - (4) 15 ammunition. 16 five (5) rounds of Remington 12-gauge shotgun Such possession occurred after defendant JUAREZ had been 17 convicted of at least one of the following felony crimes, each 18 punishable by a term of imprisonment exceeding one year: 19 (1) Carrying a Loaded Firearm, Not Registered, in 20 violation of California Penal Code Section 12031(A) (1), in the 21 Superior Court of the State of California, County of Los 22 Angeles, case number VA106843, on or about December 2, 2008; 23 (2) Possession of Firearm by a Felon, in violation of 24 California Penal Code Section 12021(A) (1), in the Superior Court 25 of the State of California, County of Los Angeles, case number 26 VA113063, on or about January 5, 2010 .. 27 28 108 1 COUNT FORTY 2 [18 3 u.s.c. ? 922(g) (5)] On or about November 18, 2010, in Los Angeles County, 4 within the Central District of California, defendant VICTOR 5 ESPINOZA, also known as "Terco," who was then an alien illegally 6 and unlawfully in the United States, knowingly possessed the 7 following firearms and ammunition, in and affecting interstate 8 and foreign commerce: 9 10 (1) number 1614677; 11 12 (2) 15 a Beretta model M9 9mm caliber pistol, bearing serial number M9-101145; 13 14 a Norinco model SKS 7.62 caliber rifle, bearing serial (3) four (4) rounds of Remington 7.62 caliber ammunition; (4) 10 rounds of Luger 9mm caliber ammunition. and 16 17 18 19 20 21 22 23 24 25 26 27 28 109 1 COUNT FORTY-ONE 2 [18 u.s.c. 3 ? 922 (g) (9)] On or about November 18, 2010, in Los Angeles?county, 4 within the Central District of California, defendant VICTOR 5 ESPINOZA, also known as "Terco" ("ESPINOZA"), knowingly 6 possessed the following firearms and ammunition, in and 7 affecting interstate and foreign commerce: (1) 8 9 number 1614677; (2) 10 11 a Norinco model SKS 7.62 caliber rifle, bearing serial a Beretta model M9 9mm caliber pistol, bearing serial number M9-101145; (3) four (4) rounds of Remington 7.62 caliber ammunition; 14 (4) 10 rounds of Luger 9mm caliber ammunition. 15 Such possession occurred after defendant ESPINOZA had been 12 13 and 16 convicted of a misdemeanor crime of domestic violence, namely, 17 Inflicting Corporal Injury on a Spouse or Cohabitant, in 18 violation of California Penal Code Section 273.5(A), in the 19 Superior Court of the State of California, County of Los 20 Angeles, case number LAM8FF0425601, on or about November 24, 21 2008. 22 23 24 25 26 27 28 110 1 2 COUNT FORTY-TWO [26 u.s.c. ? 5861 (d)] 3 On or about January 15, 2010, in Los Angeles County, within 4 the Central District of California, defendant ALBERTO SIFUENTES, 5 also known as "Bluebird" ("SIFUENTES"), knowingly possessed a 6 firearm, namely, a Luger Sten-type 9mm caliber machinegun, 7 bearing no serial number, which defendant SIFUENTES knew to be a 8 machinegun as defined in Title 26, United States Code, Section 9 5845(b), and which had not been registered to defendant 10 SIFUENTES in the National Firearms Registration and Transfer 11 Record as required by Chapter 53, Title 26, United States Code. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 111 COUNTS FORTY-THREE TO FORTY-FIVE 1 [18 2 3 A. ?? 1343, 2(a)] INTRODUCTORY ALLEGATIONS The Grand Jury hereby re-alleges and incorporates by 1. 4 u.s.c. 5 reference the Introductory Allegations of this Indictment as 6 though fully set forth herein. 7 B. 8 9 THE SCHEME 2. Beginning on a date unknown to the Grand Jury, but by at least in or around January 2010, and continuing to in or. 10 around July 2011, in Los Angeles County, within the Central 11 District of California, and elsewhere, defendants JAVIER MANUEL 12 ULLOA, also known as ("aka") 13 ? ("ARANA") , and JESSENIA MEDINA ( "J. MEDINA") , aided and abetted 14 by others known and unknown to the Grand Jury, knowingly 15 devised, participated in, and executed a scheme to defraud 16 Verizon Telecommunications ("Verizon"), by means of false and 17 fraudulent pretenses, representations, and promises, and 18 transmitted and caused to be transmitted wire communications in 19 interstate and foreign commerce for the purpose of executing the 20 scheme. 21 3. 22 "Yogi" ("ULLOA"), CELINA ARANA The scheme operated as follows: a. The Grand Jury hereby re-alleges and incorporates 23 by reference Paragraph 13 of Section A of Count One of this 24 Indictment. 25 26 27 28 b. Defendant ULLOA, who, at all times relevant to the scheme described herein, was an incarcerated inmate in the custody of the Los Angeles Sheriff's Department in the Los Angeles County Jail System, and defendants ARANA and J. MEDINA, 112 1 and others known and unknown to the Grand Jury, who were not 2 incarcerated, would obtain personal identifying-information -- 3 including names, addresses, dates of birth, and social security 4 numbers -- belonging to victims. 5 c. Defendants ULLOA, ARANA, and J. MEDINA would 6 obtain the addresses of homes that had been or were being 7 foreclosed on and were likely to be vacant. 8 9 d. Defendants ARANA and J. MEDINA would use the telephone and a computer (through the Internet) to contact 10 Verizon and request that an account be established and a home 11 telephone landline be activated at the address of a foreclosed 12 home, in the name of a victim without the victim's consent, 13 knowledge, and authorization. 14 e. Once a fraudulent account was established, 15 defendants ULLOA, ARANA, and J. MEDINA would call Verizon to 16 request that call forwarding be activated for the account, 17 specify the telephone number to which calls should be forwarded, 18 and then make collect calls using the fraudulent account, with 19 the intention that Verizon would not be paid for the collect 20 calls. 21 personal use, sell accounts to other inmates, or allow other 22 inmates to use the accounts free of charge. 23 ULLOA would maintain the fraudulent accounts for his own f. To prevent Verizon from blocking collect calls on 24 the fraudulent accounts, defendants ULLOA, ARANA, and J. MEDINA 25 would call Verizon and request that the telephone number 26 assigned to the fraudulent account be changed, which had the 27 effect of increasing the dollar-limit of collect calls that 28 Verizon would allow the accounts to accept on credit. 113 g. 1 Defendant ARANA would maintain records of the 2 personal identifying information of victims, the addresses used 3 to set up the fraudulent accounts, the telephone numbers 4 assigned by Verizon to the fraudulent accounts and reassigned at 5 the request of ARANA and her co-schemers, the call forwarding 6 telephone numbers for the various accounts, and the status of 7 the fraudulent accounts and the actions that defendant ULLOA and 8 ARANA needed to take with respect to those accounts. 9 c. THE EXECUTION OF THE SCHEME 4. 10 To execute the above-described scheme, on or about the 11 dates set forth below, within the Central District of 12 California, and elsewhere, defendants ULLOA, ARANA, and J. 13 MEDINA, while aiding and abetting each other, transmitted and 14 caused to be transmitted the following communications, from 15 California to another state, by means of wire: 16 COUNT DATE DEFENDANTS WIRE COMMUNICATION DESTINATION 17 FORTYTHREE March 11, 2010 ULLOA ARANA Telephone call to Verizon regarding ARANA's statements identifying herself as victim E.M. and requesting that two telephone lines in the name of E.M. be forwarded to ARANA's telephone. Texas FORTYFOUR March 2 2 , 2010 ULLOA ARANA Telephone call to Verizon regarding ARANA's statements identifying herself as victim L.T. and requesting that the telephone line in the name of L.T. be forwarded. Texas 18 19 20 21 22 23 24 25 26 27 28 114 1 2 3 4 5 FORTYFIVE May 30 2011 I ULLOA J. MEDINA Telephone call to Verizon regarding ULLOA's statements identifying himself as victim G.V. and requesting that two telephone lines in the name of G.V. be forwarded. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 . 21 22 23 24 25 26 27 28 115 Missouri FORFEITURE ALLEGATION ONE 1 [18 2 1. 3 u.s.c. ? 1963] Pursuant to Rule 32.2 of the Federal Rules of Criminal 4 Procedure, notice is hereby given to the defendants that the 5 United States will seek forfeiture as part of any sentence in 6 accordance with Title 18, United States Code, Section 1963, in 7 the eveht of any defendant's conviction under Count One of this 8 Indictment. 9 2. 10 Defendants shall forfeit to the United States the following property: a. 11 12 All right, title and interest in: (1) any and all interest including, without 13 limitation, any and all interest in any and all property (real, 14 pers.onal, tangible, intangible or otherwise) any person acquired 15 or maintained in violation of Title 18, United States Code, 16 Section 1962; 17 (2) any and all interest in, security of, claims 18 against, or property or contractual right of any kind affording 19 a source of influence over, any enterprise which any person 20 established, operated, controlled, conducted or participated in 21 the conduct of, in violation of Title 18, United States Code, 22 Section 1962; and (3) 23 any and all property (real, personal, 24 tangible, intangible or otherwise) constituting, or derived 25 from, any proceeds obtained, directly or indirectly, from 26 racketeering activity or unlawful debt collection in violation 27 of Title 18, United States Code, Section 1962; and 28 Ill 116 b. 1 A sum of money equal to the total value of the 2 property described in subsection a. 3 is found guilty under Count One, each such defendant shall be 4 jointly and severally liable for the entire amount forfeitable 5 pursuant to that Count. 6 3. If more than one defendant Pursuant to Title 18, United States Code, Section 7 1963(m), each defendant shall forfeit substitute property, up to 8 the value of the money and property described in the preceding 9 paragraph, if, as the result of any act or omission of a 10 defendant, the property described in the preceding paragraph, or 11 any portion thereof (a) cannot be located upon the exercise of 12 due diligence; 13 with a third party; 14 of the court; 15 (e) has been commingled with other property that cannot be 16 divided without difficulty. (b) has been transferred, sold to or deposited (c) has been placed beyond the jurisdiction (d) has been substantially diminished in value; or 17 18 19 20 21 22 23 24 25 26 27 28 117 FORFEITURE ALLEGATION TWO 1 [ 18 U. S . C . 2 ? and 28 U.S.C. 3 4 9 81 (a) ( 1) (C) , 21 U. S . C . 1. ? ?? 8 53 and 8 81, 2461(c)] Pursuant to Rule 32.2 of the Federal Rules of Criminal 5 Procedure, notice is hereby given to the defendants that the 6 United States will seek forfeiture as part of any sentence in 7 accordance with Title 18, United States Code, Section 8 981 (a) (1) (C), Title 21, United States Code, Sections 853 and 881 9 and Title 28, United States Code, Section 2461(c), in the event 10 of any defendant's conviction under any of Counts Four through 11 Twenty-Two of this Indictment. 12 13 14 15 2. Defendants shall forfeit to the United States the following property: a. All right, title and interest in any and all property, real or personal: (1) 16 constituting, or derived from, any proceeds 17 obtained, directly or indirectly, as a result of any offense set 18 forth in any of Counts Four through Twenty-Two of this 19 Indictme:tlti and (2) 20 used, or intended to be used, in any manner 21 or part, to commit, or to facilitate the commission of any 22 offense set forth in any of Counts Four through Twenty-Two of 23 this Indictmenti and 24 b. A sum of money equal to the total value of the 25 property described in subsection a. 26 through Twenty-Two for which more than one defendant is found 27 guilty, each such defendant shall be jointly and severally 28 liable for the entire amount forfeited pursuant to that Count. 118 For each of Counts Four .1 3. Pursuant to Title 21, United States Code, Section 2 853(p), as incorporated by Title 28, United States Code, Section 3 2461(c), each defendant shall forfeit substitute property, up to 4 the value of the money and property described in the preceding 5 paragraph, if, as the result of any act or omission of a 6 defendant, the property described in the preceding paragraph, or 7 any portion thereof (a) cannot be located upon the exercise of 8 due diligence; 9 with a third party; (b) has been transferred, sold to or deposited (c) has been placed beyond the jurisdiction 10 of the court; (d) has been substantially diminished in value; or 11 (e) has been commingled with other property that cannot be 12 divided without difficulty. 13 A TRUE BILL 14 Is/ 15 16 Foreperson 17 18 ANDRE BIROTTE JR. 19 u~;;~e~torney 20 21 22 23 24 ROBERT E. DliGDALE Assistant United States Attorney Chief, Criminal Division ELIZABETH R. YANG Assistant United States Attorney Chief, Violent & Organized Crime Section 25 26 27 TERRENCE P. MANN JOSHUA A. KLEIN Assistant United States Attorneys Violent & Organized Crime Section 28 119