pomona meth sweep - indictment

63
1 2 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 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA June 2012 Grand Jury UNITED STATES OF AMERICA, Plaintiff, v. JOSE JUAN GARCIA BARRON, aka “Tokes,” MARTIN BARRON ALCAZAR, aka “Quiniki,” aka “Quini,” aka “Martin Garcia Barron,” RUDY ARMA, JOSE CHAVEZ ESPINOSA, aka “Guerrin,” ENRIQUE CENTENO REYES, aka “Gordo,” aka “Gordito,” JORGE LUIS BARRON ZARATE, aka “Qoi,” aka “Coyote,” TONY LNU, JOSE MARIA CHAVEZ JR., aka “Jose M. Chavez Valencia,” aka “Chema,” JOSE MARIA CHAVEZ, aka “Chemita,” DANIEL LUPIAN, aka “Yogi,” aka “Nariz de Chupon,” INES CASTILLION JOYA, FNU LNU, aka “Borrachin,” aka “Borrachillo,” ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CR 12- I N D I C T M E N T [21 U.S.C. § 846: Conspiracy to Manufacture, Possess with Intent to Distribute, and Distribute Methamphetamine; 21 U.S.C. §§ 841(a)(1), (b)(1)(A), (b)(1)(B), (b)(1)(C): Distribution of and Possession with Intent to Distribute Methamphetamine; 21 U.S.C. § 856(a)(1): Maintaining Drug Involved Premises]

Upload: scprweb

Post on 18-Apr-2015

12.017 views

Category:

Documents


7 download

TRANSCRIPT

Page 1: Pomona Meth Sweep - Indictment

1

2

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

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

June 2012 Grand Jury

UNITED STATES OF AMERICA,

Plaintiff,

v.

JOSE JUAN GARCIA BARRON, aka “Tokes,”MARTIN BARRON ALCAZAR, aka “Quiniki,” aka “Quini,” aka “Martin Garcia Barron,”RUDY ARMA, JOSE CHAVEZ ESPINOSA, aka “Guerrin,”ENRIQUE CENTENO REYES, aka “Gordo,” aka “Gordito,”JORGE LUIS BARRON ZARATE, aka “Qoi,” aka “Coyote,”TONY LNU,JOSE MARIA CHAVEZ JR., aka “Jose M. Chavez Valencia,” aka “Chema,”JOSE MARIA CHAVEZ, aka “Chemita,”DANIEL LUPIAN, aka “Yogi,” aka “Nariz de Chupon,”INES CASTILLION JOYA,FNU LNU, aka “Borrachin,” aka “Borrachillo,”

))))) ) ) ) ) )))))))))))))))))))))))))))

No. CR 12-

I N D I C T M E N T

[21 U.S.C. § 846: Conspiracy to Manufacture, Possess withIntent to Distribute, andDistribute Methamphetamine; 21U.S.C. §§ 841(a)(1), (b)(1)(A),(b)(1)(B), (b)(1)(C):Distribution of and Possessionwith Intent to DistributeMethamphetamine; 21 U.S.C. § 856(a)(1): Maintaining DrugInvolved Premises]

Page 2: Pomona Meth Sweep - Indictment

1

2

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

JORGE RUELAS, aka “Fat Boy,”RUDY ZEPEDA, aka “Virolo,” aka “Ojon,”JOSE ALVARADO,DAVID AGUILAR,RAFAEL FAVELA, aka “Chito,”SARA GARRIDO,OSCAR ROBLES, aka “Squeaks,” aka “Squeaky,”MIGUEL SAUCEDO, aka “Blackie,” aka “Blacks,”ANDRES YEPEZ,DANIEL YEPEZ, aka “Chamboogie,”MIGUEL ZARAGOZA, aka “Grumpy,”PETE LNU,CHRISTOPHER ALVARADO,ISAAC CERVANTES, aka “Bill,” aka “Wild Bill,” andMARCOS OREJEL, aka “Piolin,”

Defendants._____________________________

)))))))))))))))))))))))))))))))

The Grand Jury charges:

COUNT ONE

[21 U.S.C. § 846]

A. OBJECTS OF THE CONSPIRACY

Beginning on an unknown date, and continuing to on or about

June 7, 2012, in Los Angeles County, San Bernardino County,

Orange County, and Riverside County, within the Central District

of California, and elsewhere, defendants JOSE JUAN GARCIA BARRON,

also known as (“aka”) “Tokes” (“BARRON”), MARTIN BARRON ALCAZAR,

aka “Quiniki,” aka “Quini,” aka “Martin Garcia Barron”

(“ALCAZAR”), RUDY ARMA (“ARMA”), JOSE CHAVEZ ESPINOSA, aka

2

Page 3: Pomona Meth Sweep - Indictment

1

2

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

“Guerrin” (“ESPINOSA”), ENRIQUE CENTENO REYES, aka “Gordo,” aka

“Gordito” “REYES”), JORGE LUIS BARRON ZARATE, aka “Qoi,” aka

“Coyote” (“ZARATE”), TONY LNU (“TONY”), JOSE MARIA CHAVEZ JR.,

aka “Jose M. Chavez Valencia,” aka “Chema” (“CHAVEZ JR.”), JOSE

MARIA CHAVEZ, aka “Chemita” (“CHAVEZ”), DANIEL LUPIAN, aka

“Yogi,” aka “Nariz de Chupon” (“LUPIAN”), INES CASTILLION JOYA

(“JOYA”), FNU LNU, aka “Borrachin,” aka “Borrachillo”

(“BORRACHIN”), JORGE RUELAS, aka “Fat Boy” (“RUELAS”), RUDY

ZEPEDA, aka “Virolo,” aka “Ojon” (“ZEPEDA”), JOSE ALVARADO (“J.

ALVARADO”), DAVID AGUILAR (“AGUILAR”), RAFAEL FAVELA, aka “Chito”

(“FAVELA”), SARA GARRIDO (“GARRIDO”), OSCAR ROBLES, aka

“Squeaks,” aka “Squeaky” (“ROBLES”), MIGUEL SAUCEDO, aka

“Blackie,” aka “Blacks” (“SAUCEDO”), ANDRES YEPEZ (“A. YEPEZ”),

DANIEL YEPEZ, aka “Chamboogie” (“D. YEPEZ”), MIGUEL ZARAGOZA, aka

“Grumpy” (“ZARAGOZA”), PETE LNU (“PETE”), CHRISTOPHER ALVARADO

(“C. ALVARADO”), ISAAC CERVANTES, aka “Bill,” aka “Wild Bill”

(“CERVANTES”), and MARCOS OREJEL, aka “Piolin” (“OREJEL”), and

others known and unknown to the Grand Jury, conspired and agreed

with each other to knowingly and intentionally commit the

following offenses defined in Subchapter I of Chapter 13, Title

21, United States Code, namely:

1. To manufacture, possess with intent to distribute, and

distribute at least 500 grams of a mixture or substance

containing a detectable amount of methamphetamine, a Schedule II

controlled substance, in violation of Title 21, United States

Code, Sections 841(a)(1) and (b)(1)(A)(viii);

2. To manufacture, possess with intent to distribute, and

distribute at least 50 grams of methamphetamine, a Schedule II

3

Page 4: Pomona Meth Sweep - Indictment

1

2

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

controlled substance, in violation of Title 21, United States

Code, Sections 841(a)(1) and (b)(1)(A)(viii);

3. To manufacture, possess with intent to distribute, and

distribute at least 50 grams of a mixture or substance containing

a detectable amount of methamphetamine, a Schedule II controlled

substance, in violation of Title 21, United States Code, Sections

841(a)(1) and (b)(1)(B)(viii);

4. To manufacture, possess with intent to distribute, and

distribute at least five grams of methamphetamine, a Schedule II

controlled substance, in violation of Title 21, United States

Code, Sections 841(a)(1) and (b)(1)(B)(viii);

5. To manufacture, possess with intent to distribute, and

distribute methamphetamine, a Schedule II controlled substance,

in violation of Title 21, United States Code, Sections 841(a)(1)

and (b)(1)(C); and

6. To maintain a drug-involved premises, in violation of

Title 21, United States Code, Section 856(a)(1).

B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE

ACCOMPLISHED

The objects of the conspiracy were to be accomplished, in

substance, as follows:

1. Defendant BARRON would obtain methamphetamine from a

supplier in Mexico.

2. Defendant BARRON would arrange for the methamphetamine

to be shipped from Mexico to Southern California.

3. Defendant ALCAZAR would coordinate the receipt of the

methamphetamine from Mexico into Southern California.

4. Defendant ALCAZAR would direct the re-crystallization

4

Page 5: Pomona Meth Sweep - Indictment

1

2

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

of methamphetamine and the conversion of liquid methamphetamine

into crystallized methamphetamine upon its arrival in California.

5. Defendant ESPINOSA would coordinate the distribution of

methamphetamine to defendant BORRACHIN and other customers.

6. Defendants REYES and ZARATE would maintain a storage

location for methamphetamine at 952 East Nocta Street, Unit B, in

Ontario, California (the “Nocta Street Stash House”).

7. Defendant ZARATE would manufacture methamphetamine at

the direction of defendants ALCAZAR and ESPINOSA by re-

crystallizing the methamphetamine shipped from Mexico to Southern

California.

8. Defendants REYES, ZARATE, and CHAVEZ JR. would

manufacture methamphetamine by converting liquid methamphetamine

into crystallized methamphetamine.

9. Defendant ALCAZAR would direct defendant ZARATE to

distribute methamphetamine to defendants REYES, CHAVEZ JR., and

ZEPEDA.

10. Defendant ALCAZAR would manage the distribution of

methamphetamine to defendants CHAVEZ JR., JOYA, BORRACHIN,

RUELAS, and ZEPEDA.

11. Defendant TONY would distribute methamphetamine to

defendant LUPIAN.

12. Defendant LUPIAN would distribute methamphetamine to

defendants CHAVEZ JR., CHAVEZ, CERVANTES, and OREJEL, and other

unknown customers.

13. Defendant CHAVEZ JR. would distribute methamphetamine

to defendants CHAVEZ, RUELAS, ZEPEDA, J. ALVARDO, AGUILAR,

FAVELA, GARRIDO, ROBLES, SAUCEDO, A. YEPEZ, D. YEPEZ, ZARAGOZA,

5

Page 6: Pomona Meth Sweep - Indictment

1

2

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

and PETE, and other unknown customers, which they, in turn, would

redistribute.

14. Defendant CHAVEZ would distribute methamphetamine to

defendants CHAVEZ JR. and LUPIAN, and other unknown customers.

15. Defendants JOYA, BORRACHIN, RUELAS, ZEPEDA, J.

ALVARADO, AGUILAR, FAVELA, S. GARRIDO, ROBLES, SAUCEDO, A. YEPEZ,

D. YEPEZ, ZARAGOZA, and PETE would distribute methamphetamine to

unknown customers.

16. Defendant C. ALVARADO would arrange methamphetamine

transactions for defendant OREJEL.

17. Defendant TONY would collect drug proceeds from

defendant LUPIAN for defendant ALCAZAR.

18. Defendants ALCAZAR and ESPINOSA would coordinate the

shipment of drug proceeds to defendant BARRON in Mexico through

defendant ARMA.

19. Defendant ARMA would collect drug proceeds from

defendants ALCAZAR and ESPINOSA on behalf of defendant BARRON.

C. OVERT ACTS

In furtherance of the conspiracy and to accomplish the

objects of the conspiracy, on or about the following dates,

defendants BARRON, ALCAZAR, ARMA, ESPINOSA, REYES, ZARATE, TONY,

CHAVEZ JR., CHAVEZ, LUPIAN, JOYA, BORRACHIN, RUELAS, ZEPEDA, J.

ALVARADO, AGUILAR, FAVELA, GARRIDO, ROBLES, SAUCEDO, A. YEPEZ, D.

YEPEZ, ZARAGOZA, PETE, C. ALVARADO, CERVANTES, and OREJEL, and

others known and unknown to the Grand Jury, committed various

overt acts within the Central District of California, and

elsewhere, including, but not limited to, the following:

1. On April 15, 2011, in coded language during telephone

6

Page 7: Pomona Meth Sweep - Indictment

1

2

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

calls and text messages, defendant ZEPEDA told a confidential

informant working for the Federal Bureau of Investigation (“the

CI”) that he would sell methamphetamine to the CI for a price of

$1,200 per ounce.

2. On April 15, 2011, in coded language during a telephone

call, defendant ZEPEDA told the CI that defendant ZEPEDA’s

brother-in-law would be bringing the methamphetamine to defendant

ZEPEDA.

3. On April 15, 2011, defendant CHAVEZ JR. supplied

approximately 26.7 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

26.4 grams of actual methamphetamine) to defendant ZEPEDA for

sale to the CI.

4. On April 15, 2011, defendant ZEPEDA sold approximately

26.7 grams of a mixture or substance containing a detectable

amount of methamphetamine (containing approximately 26.4 of grams

of actual methamphetamine) to the CI in exchange for $1,200.

5. On May 11, 2011, defendant ZEPEDA sold approximately

13.9 grams of a mixture or substance containing a detectable

amount of methamphetamine (containing approximately 13.7 grams of

actual methamphetamine) to the CI in exchange for $600.

6. On June 3, 2011, defendant C. ALVARADO, in coded

language during telephone calls and text messages, arranged to

sell approximately one-half ounce of methamphetamine to the CI.

7. On June 3, 2011, defendant OREJEL drove defendant C.

ALVARADO to pick up the CI to complete the methamphetamine

transaction.

8. On June 3, 2011, defendant OREJEL drove defendant C.

7

Page 8: Pomona Meth Sweep - Indictment

1

2

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

ALVARADO and the CI to defendant LUPIAN’s ranch in Ontario,

California, to complete the methamphetamine transaction.

9. On June 3, 2011, defendant LUPIAN supplied

approximately 12.5 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

12.3 grams of actual methamphetamine) to defendant OREJEL so it

could be sold to the CI.

10. On June 3, 2011, defendant OREJEL sold approximately

12.5 grams of a mixture or substance containing a detectable

amount of methamphetamine (containing approximately 12.3 grams of

actual methamphetamine) to the CI in exchange for $600.

11. On June 3, 2011, defendant OREJEL paid defendant C.

ALVARADO $50 for arranging the methamphetamine transaction with

the CI.

12. On June 3, 2011, defendant OREJEL told the CI to obtain

his phone number from defendant C. ALVARADO so the CI could

contact him to conduct future methamphetamine transactions.

13. On June 3, 2011, defendant C. ALVARADO gave defendant

OREJEL’S phone number to the CI so the CI could contact defendant

OREJEL to conduct future methamphetamine transactions.

14. On July 6 and 7, 2011, defendant OREJEL, in coded

language during telephone calls, agreed to sell approximately one

ounce of methamphetamine to the CI for $1,000.

15. On July 7, 2011, defendant OREJEL, accompanied by

defendant J. ALVARADO, sold approximately 27.5 grams of a mixture

or substance containing a detectable amount of methamphetamine

(containing approximately 27.2 grams of actual methamphetamine)

to the CI in exchange for $1,000.

8

Page 9: Pomona Meth Sweep - Indictment

1

2

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

16. From July 9 through July 13, 2011, defendant J.

ALVARADO, in coded language during telephone calls and text

messages, arranged to sell approximately one ounce of

methamphetamine to the CI for $1,000.

17. On July 13, 2011, defendant J. ALVARADO sold

approximately 27.4 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

26.6 grams of actual methamphetamine) to the CI in exchange for

$1,000.

18. On July 20 and 21, 2011, defendant OREJEL, in coded

language during telephone calls, arranged to sell approximately

one and one-half ounces of methamphetamine to the CI.

19. On July 21, 2011, defendant OREJEL sold approximately

41.5 grams of a mixture or substance containing a detectable

amount of methamphetamine (containing approximately 40.6 grams

of actual methamphetamine) to the CI in exchange for $1,500.

20. On July 27 and 28, 2011, defendant ZEPEDA, in coded

language during telephone calls, arranged to sell approximately

one-half ounce of methamphetamine to the CI for $500.

21. On July 28, 2011, defendant CHAVEZ JR. supplied

approximately 13.9 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

13.7 grams of actual methamphetamine) to defendant ZEPEDA so it

could be sold to the CI.

22. On July 28, 2011, defendant ZEPEDA sold approximately

13.9 grams of a mixture or substance containing a detectable

amount of methamphetamine (containing approximately 13.7 grams of

actual methamphetamine) to the CI in exchange for $500.

9

Page 10: Pomona Meth Sweep - Indictment

1

2

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

23. On July 28, 2011, defendant CHAVEZ JR. called the CI,

provided the CI with his phone number, and told the CI that he

could provide whatever amount of methamphetamine that the CI

needed.

24. On August 18 and 19, 2011, defendant CHAVEZ JR., in

coded language during telephone calls, arranged to sell

approximately two ounces of methamphetamine to the CI for $1,700.

25. On August 19, 2011, defendant CHAVEZ JR. distributed

approximately 48.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

46.8 grams of actual methamphetamine) to the CI in exchange for

$1,700.

26. On August 31 and September 1, 2011, defendant J.

ALVARADO, in coded language during telephone calls and text

messages, arranged to sell approximately seven grams of

methamphetamine to the CI for $280.

27. On September 1, 2011, defendant J. ALVARADO sold

approximately 4.6 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

4.5 grams of actual methamphetamine) to the CI in exchange for

$280.

28. On September 13 and 14, 2011, defendant ZEPEDA, in

coded language during telephone calls, arranged to sell

approximately one ounce of methamphetamine to the CI for $750.

29. On September 14, 2011, defendant ZEPEDA sold

approximately 24.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

23.9 grams of actual methamphetamine) to the CI in exchange for

10

Page 11: Pomona Meth Sweep - Indictment

1

2

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

$750.

30. From September 20 through September 22, 2011, defendant

CHAVEZ JR., in coded language during telephone calls and text

messages, arranged to sell approximately one and one-half ounces

of methamphetamine to the CI for $1,090.

31. On September 22, 2011, defendant CHAVEZ JR. sold

approximately 36.5 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

35.4 grams of actual methamphetamine) to the CI in exchange for

$1,090.

32. On September 27 and 28, 2011, defendant CHAVEZ JR., in

coded language during telephone calls and text messages, arranged

to sell approximately one ounce of methamphetamine to the CI for

$725.

33. On September 28, 2011, defendant CHAVEZ JR. sold

approximately 24.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

23.5 grams of actual methamphetamine) to the CI in exchange for

$725.

34. On October 6 and 7, 2011, defendant CHAVEZ JR., in

coded language during telephone calls and text messages, arranged

to sell approximately one and one-half ounces of methamphetamine

to the CI for $1,100.

35. On October 7, 2011, defendant CHAVEZ JR. sold

approximately 49 grams of a mixture or substance containing a

detectable amount of methamphetamine to the CI in exchange

$1,100.

36. On October 7, 2011, defendant CHAVEZ JR., in coded

11

Page 12: Pomona Meth Sweep - Indictment

1

2

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

language during telephone calls and text messages, told the CI

that there was a problem with the quality of the methamphetamine

defendant CHAVEZ JR. had previously sold to the CI and offered to

exchange it for new, better quality methamphetamine.

37. On October 7, 2011, defendant CHAVEZ JR. distributed

approximately 49.0 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

48.2 grams of actual methamphetamine) to the CI in exchange for

the previously distributed 49 grams of poor quality

methamphetamine and an additional $180.

38. On October 18 and 19, 2011, defendant CHAVEZ JR., in

coded language during telephone calls and text messages, arranged

to sell approximately one ounce of methamphetamine to the CI for

$725.

39. On October 19, 2011, defendant CHAVEZ JR. sold

approximately 26.0 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

25.5 grams of actual methamphetamine) to the CI in exchange for

$725.

40. On October 27 and 28, 2011, defendant CHAVEZ JR., in

coded language during telephone calls, arranged to sell

approximately two ounces of methamphetamine to the CI for $1,450.

41. On October 28, 2011, defendant CHAVEZ JR. sold

approximately 53.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

51.6 grams of actual methamphetamine) to the CI in exchange for

$1,450.

42. On November 10, 2011, defendant CHAVEZ JR., in coded

12

Page 13: Pomona Meth Sweep - Indictment

1

2

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

language during telephone calls and text messages, arranged to

sell $600 worth of methamphetamine to the CI.

43. On November 10, 2011, defendant CHAVEZ JR. sold

approximately 17.0 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

16.5 grams of actual methamphetamine) to the CI in exchange for

$600.

44. On November 30 and December 1, 2011, defendant CHAVEZ

JR., in coded language during telephone calls and text messages,

arranged to sell approximately three and one-half ounces of

methamphetamine to the CI for $2,360.

45. On December 1, 2011, defendant CHAVEZ JR. sold

approximately 83.9 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

81.8 grams of actual methamphetamine) to the CI in exchange for

$2,360.

46. On December 15 and 16, 2011, defendant CHAVEZ JR., in

coded language during telephone calls and text messages, arranged

to sell approximately one-half pound of methamphetamine to the CI

for $2,900.

47. On December 16, 2011, defendant CHAVEZ JR. sold

approximately 111.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

111.1 grams of actual methamphetamine) to the CI in exchange for

$2,900.

48. From December 19 through December 21, 2011, defendant

CHAVEZ JR., in coded language during telephone calls and text

messages, arranged to sell approximately two and one-half ounces

13

Page 14: Pomona Meth Sweep - Indictment

1

2

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

of methamphetamine to the CI for $1,600.

49. On December 21, 2011, defendant CHAVEZ JR. sold

approximately 62.2 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

61.9 grams of actual methamphetamine) to the CI in exchange for

$1,600.

50. On January 5 and 6, 2012, defendant CHAVEZ JR., in

coded language during telephone calls and text messages, arranged

to sell approximately one-quarter pound of methamphetamine to the

CI for $2,900.

51. On January 6, 2012, defendant CHAVEZ JR. sold

approximately 110.6 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

110.4 grams of actual methamphetamine) to the CI in exchange for

$2,900.

52. On January 6, 2012, defendant CHAVEZ JR. advised the CI

that defendant CHAVEZ JR. would give the CI a discount in price

for orders of methamphetamine in one-quarter pound quantities or

higher.

53. From January 23 through January 25, 2012, defendant

CHAVEZ JR., in coded language during telephone calls and text

messages, arranged to sell approximately one-quarter pound of

methamphetamine to the CI for $2,700.

54. On January 25, 2012, defendant CHAVEZ JR. sold

approximately 111.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

110.1 grams of actual methamphetamine) to the CI in exchange for

$2,900, which included an additional $200 that defendant CHAVEZ

14

Page 15: Pomona Meth Sweep - Indictment

1

2

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

JR. claimed the CI owed to him.

55. From February 1 through February 6, 2012, defendant

CHAVEZ JR., in coded language during telephone calls and text

messages, arranged to sell approximately two and one-quarter

ounces of methamphetamine to the CI for $1,600.

56. On February 6, 2012, defendant CHAVEZ JR. sold

approximately 62.2 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

62.0 grams of actual methamphetamine) to the CI in exchange for

$1,600.

57. On February 16, 2012, defendants CHAVEZ JR. and FAVELA

arranged to meet so that defendant CHAVEZ JR. could provide

defendant FAVELA with approximately one-half ounce of

methamphetamine.

58. On February 16, 2012, defendant CHAVEZ JR. distributed

approximately one-half ounce of methamphetamine to defendant

FAVELA for redistribution by defendant FAVELA.

59. On February 16, 2012, defendant ALCAZAR directed

defendant CHAVEZ JR. to leave $1,500 in drug proceeds with

defendant CHAVEZ JR.’s father to give to defendant BARRON.

60. On February 16, 2012, defendant CHAVEZ JR. delivered

$1,500 in drug proceeds to his father.

61. On February 16, 2012, defendant LUPIAN distributed

approximately one pound of methamphetamine to defendant CHAVEZ

JR. for redistribution by defendant CHAVEZ JR.

62. On February 17, 2012, in coded language during a

telephone call, defendant CHAVEZ JR. offered to sell one-half

ounce of methamphetamine to defendant FAVELA, and defendant

15

Page 16: Pomona Meth Sweep - Indictment

1

2

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

FAVELA agreed to purchase the methamphetamine from defendant

CHAVEZ JR.

63. On February 17, 2012, defendant CHAVEZ JR. distributed

approximately one-half ounce of methamphetamine to defendant

FAVELA in the area of 285 West Center Street, Pomona, California,

for distribution by defendant FAVELA.

64. On February 18, 2012, in coded language during

telephone calls, defendant SAUCEDO ordered one ounce of

methamphetamine from defendant CHAVEZ JR.

65. On February 19, 2012, defendant CHAVEZ JR. distributed

approximately one ounce of methamphetamine to defendant SAUCEDO

for redistribution by defendant SAUCEDO.

66. On February 19, 2012, in coded language during a

telephone call, defendant ALCAZAR advised defendant CHAVEZ JR.

that defendant ALCAZAR possessed approximately one-half pound of

methamphetamine.

67. On February 20, 2012, defendant SAUCEDO sold

approximately one ounce of methamphetamine to an unknown

customer.

68. On February 20, 2012, defendant SAUCEDO ordered one

ounce of methamphetamine from defendant CHAVEZ JR.

69. On February 20, 2012, defendant CHAVEZ JR. distributed

approximately one ounce of methamphetamine to defendant SAUCEDO

for redistribution by defendant SAUCEDO.

70. On February 20, 2012, in coded language during a

telephone call, defendant CHAVEZ JR. offered one-half ounce of

methamphetamine to defendant FAVELA, and defendant FAVELA agreed

to purchase the methamphetamine from defendant CHAVEZ JR.

16

Page 17: Pomona Meth Sweep - Indictment

1

2

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

71. On February 21, 2012, in coded language during

telephone calls, defendant ROBLES ordered approximately

one-quarter pound of methamphetamine from defendant CHAVEZ JR.,

and defendant CHAVEZ JR. agreed to sell the methamphetamine to

defendant ROBLES.

72. On February 21, 2012, in coded language during

telephone calls, defendant CHAVEZ JR. arranged to purchase

approximately one-quarter pound of methamphetamine from defendant

LUPIAN for further sale to defendant ROBLES.

73. On February 21, 2012, defendant CHAVEZ JR. obtained

approximately one-quarter pound of methamphetamine from defendant

LUPIAN’s ranch in Ontario, California.

74. On February 21, 2012, defendant CHAVEZ JR. sold

approximately one-quarter pound of methamphetamine to defendant

ROBLES in exchange for $1,700 for redistribution by defendant

ROBLES.

75. From February 17 through February 21, 2012, in coded

language during telephone calls and text messages, defendant

CHAVEZ JR. agreed to sell $3,000 worth of methamphetamine to the

CI.

76. On February 20, 2012, in coded language during a

telephone call, defendant CHAVEZ JR. arranged to obtain

approximately one-quarter pound of methamphetamine from defendant

ALCAZAR for sale to the CI.

77. On February 21, 2012, defendant ALCAZAR distributed

approximately one-quarter pound of methamphetamine to defendant

CHAVEZ JR. in the area of 285 West Center Street, Pomona,

California.

17

Page 18: Pomona Meth Sweep - Indictment

1

2

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

78. On February 21, 2012, defendant CHAVEZ JR. sold

approximately 124.7 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing 124.7 grams of

actual methamphetamine) to the CI in exchange for $3,000.

79. On February 23, 2012, in coded language during a

telephone call, defendant CHAVEZ JR. offered to sell

approximately one ounce of methamphetamine to defendant SAUCEDO.

80. On February 23, 2012, in coded language during a

telephone call, defendant SAUCEDO asked defendant CHAVEZ JR.

about the quality of the one ounce of methamphetamine that

defendant CHAVEZ JR. had offered for sale, and when defendant

CHAVEZ JR. responded that the methamphetamine was “fire” (good

quality), defendant SAUCEDO agreed to purchase the

methamphetamine.

81. On February 24, 2012, defendant GARRIDO paid $300 to

defendant CHAVEZ JR. in exchange for methamphetamine.

82. On February 24, 2012, defendant FAVELA ordered

approximately one-half ounce of methamphetamine from defendant

CHAVEZ JR.

83. On February 24, 2012, defendant CHAVEZ JR. distributed

approximately one-half ounce of methamphetamine to defendant

FAVELA for redistribution by defendant FAVELA.

84. On February 24, 2012, in coded language during a

telephone call, defendant AGUILAR asked to purchase approximately

one ounce of methamphetamine from defendant CHAVEZ JR. and told

defendant CHAVEZ JR. that he had money for the methamphetamine.

85. On February 24, 2012, defendant CHAVEZ JR. sold

approximately one ounce of methamphetamine to defendant AGUILAR

18

Page 19: Pomona Meth Sweep - Indictment

1

2

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

for redistribution by defendant AGUILAR.

86. On February 29, 2012, defendant GARRIDO paid $200 to

defendant CHAVEZ JR. for methamphetamine.

87. On March 2, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. asked defendant CHAVEZ for

methamphetamine and advised that he needed approximately two or

two and one-half ounces of methamphetamine.

88. On March 3, 2012, in coded language during a telephone

call, defendant CHAVEZ advised defendant CHAVEZ JR. that he had

approximately one ounce of methamphetamine available to sell to

defendant CHAVEZ JR.

89. On March 3, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. agreed to purchase approximately one

ounce of methamphetamine from defendant CHAVEZ.

90. On March 3, 2012, defendant CHAVEZ distributed

approximately one ounce of methamphetamine to defendant CHAVEZ

JR. for redistribution by defendant CHAVEZ JR.

91. On March 4, 2012, defendant CHAVEZ JR. distributed

approximately one ounce of methamphetamine to defendant SAUCEDO

for redistribution by defendant SAUCEDO.

92. On March 4, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. offered to sell methamphetamine to

defendant GARRIDO, and defendant GARRIDO agreed to purchase

methamphetamine from defendant CHAVEZ JR.

93. From March 3 through March 4, 2012, in coded language

during telephone calls and text messages, defendant J. ALVARADO

asked defendant CHAVEZ JR. for $350 worth of methamphetamine.

94. On March 4, 2012, defendant CHAVEZ JR. sold

19

Page 20: Pomona Meth Sweep - Indictment

1

2

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

approximately one-quarter ounce of methamphetamine to defendant

J. ALVARADO for redistribution by defendant J. ALVARADO.

95. On March 4, 2012, in coded language during a telephone

call, defendant ROBLES asked to purchase approximately

one-quarter pound of methamphetamine from defendant CHAVEZ JR.

96. On March 4, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. asked to purchase approximately one-

quarter pound of methamphetamine from defendant ALCAZAR to sell

to defendant ROBLES.

97. On March 4, 2012, in coded language during a telephone

call, defendant ALCAZAR advised that he could provide one-quarter

pound of methamphetamine to defendant CHAVEZ JR. in two hours.

98. On March 4, 2012, at the direction of defendant

ALCAZAR, defendant CHAVEZ JR. picked up approximately one-quarter

pound of methamphetamine from the Nocta Street Stash House.

99. On March 4, 2012, defendant CHAVEZ JR. sold

approximately one-quarter pound of methamphetamine to defendant

ROBLES in Pomona, California, for redistribution by defendant

ROBLES.

100. On March 6, 2012, in coded language during a telephone

call, defendant CHAVEZ asked defendant CHAVEZ JR. if defendant

CHAVEZ JR. had the money to pay defendant CHAVEZ for the

approximately one ounce of methamphetamine that defendant CHAVEZ

had provided to defendant CHAVEZ Jr. on March 3, 2012.

101. On March 7, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. agreed to sell approximately

one-quarter pound of methamphetamine to the CI for $3,000.

102. On March 7, 2012, in coded language during a telephone

20

Page 21: Pomona Meth Sweep - Indictment

1

2

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

call, defendant CHAVEZ JR. told defendant ALCAZAR that he needed

approximately one-quarter pound of methamphetamine and defendant

ALCAZAR agreed to provide it.

103. On March 7, 2012, defendant ALCAZAR distributed

approximately one-quarter pound of methamphetamine to defendant

CHAVEZ JR.

104. On March 7, 2012, defendant CHAVEZ JR. sold

approximately 125.7 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

123.7 grams of actual methamphetamine) to the CI in exchange for

$3,000.

105. On March 7, 2012, in coded language during a telephone

call, defendant RUELAS asked to purchase approximately two ounces

of methamphetamine from defendant CHAVEZ JR. for an unidentified

customer.

106. On March 7, 2012, in coded language during a telephone

call, defendant ROBLES ordered approximately one-quarter pound of

methamphetamine from defendant CHAVEZ JR. and asked defendant

CHAVEZ JR. to “pick some nice ones” (good quality

methamphetamine).

107. On March 7, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. advised defendant ALCAZAR that he

needed approximately one-quarter pound of methamphetamine to sell

to defendant ROBLES and asked defendant ALCAZAR to make sure the

quality of the methamphetamine was “good” because defendant

ROBLES was “picky.”

108. On March 7, 2012, defendant ALCAZAR distributed

approximately six ounces of methamphetamine to defendant CHAVEZ

21

Page 22: Pomona Meth Sweep - Indictment

1

2

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

JR.

109. On March 7, 2012, defendant CHAVEZ JR. sold

approximately one-quarter pound of methamphetamine to defendant

ROBLES for redistribution by defendant ROBLES.

110. On March 8, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. asked defendant RUELAS if defendant

RUELAS still needed approximately two ounces of methamphetamine

to sell to a customer, and defendant RUELAS agreed to meet with

defendant CHAVEZ JR. to pick up the methamphetamine.

111. On March 8, 2012, in coded language during telephone

calls, defendant CHAVEZ JR. offered to introduce defendant RUELAS

to defendant ALCAZAR for future purchases of methamphetamine and

advised that defendant ALCAZAR could sell one-quarter pound

quantities of methamphetamine for approximately $2,200.

112. On March 8, 2012, in coded language during a telephone

call, defendant ZARAGOZA complained to defendant CHAVEZ JR. about

the quality of methamphetamine that defendant CHAVEZ JR. had

previously distributed to defendant ZARAGOZA.

113. On March 9, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. arranged to meet with defendant

ZARAGOZA to provide defendant ZARAGOZA with methamphetamine and

described the methamphetamine as “bigger pieces” and “white”.

114. On March 9, 2012, in coded language during a telephone

call, defendant ZARAGOZA agreed to inspect the quality of the

methamphetamine that defendant CHAVEZ JR. was offering to provide

to him.

115. On March 15, 2012, in coded language during a telephone

call, defendant ROBLES asked to purchase approximately

22

Page 23: Pomona Meth Sweep - Indictment

1

2

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

one-quarter pound of methamphetamine from defendant CHAVEZ JR.

116. On March 15, 2012, in coded language during telephone

calls, defendant CHAVEZ JR. arranged to purchase approximately

one-quarter pound of methamphetamine from defendant ALCAZAR to

sell to defendant ROBLES.

117. On March 15, 2012, in coded language during telephone

calls, defendant ALCAZAR agreed to sell one-quarter pound of

methamphetamine to defendant CHAVEZ JR. and advised defendant

CHAVEZ JR. that defendant ALCAZAR would leave the methamphetamine

at a location on State Street in Montclair, California, for pick

up by defendant CHAVEZ JR.

118. On March 15, 2012, defendant CHAVEZ JR. sold

approximately one-quarter pound of methamphetamine to defendant

ROBLES for redistribution by defendant ROBLES.

119. On March 15, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. arranged to take defendant ROBLES’

payment for the one-quarter pound of methamphetamine to defendant

ALCAZAR.

120. On March 16, 2012, in coded language during a telephone

call, defendant D. YEPEZ asked to purchase approximately one-half

ounce of methamphetamine from defendant CHAVEZ JR.

121. On March 16, 2012, defendant CHAVEZ JR. sold

approximately one-half ounce of methamphetamine to defendant D.

YEPEZ, for redistribution by D. YEPEZ.

122. On March 16, 2012, in coded language during a telephone

call, defendant LUPIAN asked defendant CHAVEZ if defendant CHAVEZ

would “front” defendant LUPIAN approximately one pound of

methamphetamine.

23

Page 24: Pomona Meth Sweep - Indictment

1

2

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

123. On March 17, 2012, in coded language during a series of

consecutive telephone calls, defendants ALCAZAR, ARMA, and

ESPINOSA arranged the transfer of drug proceeds from the Central

District of California to Mexico.

124. On March 17, 2012, in coded language during telephone

calls, defendant LUPIAN arranged to sell approximately two ounces

of methamphetamine to an unindicted co-conspirator.

125. On March 18, 2012, in coded language during telephone

calls, defendant ESPINOSA arranged for defendant ALCAZAR to sell

approximately one-quarter pound of methamphetamine to an

unindicted co-conspirator for $1,000 with the remainder of the

amount due to be paid later.

126. On March 18, 2012, defendant ALCAZAR sold approximately

one-quarter pound of methamphetamine to the unindicted

co-conspirator and accepted $1,000 as partial payment for the

methamphetamine

127. On March 18, 2012, in coded language during a telephone

call, defendant CHAVEZ complained to defendant LUPIAN about the

quality of one of the four one-quarter pound quantities of

methamphetamine that defendant LUPIAN had distributed to

defendant CHAVEZ.

128. On March 18, 2012, in coded language during a telephone

call, defendant LUPIAN directed defendant CHAVEZ to return the

one-quarter pound of poor quality methamphetamine to defendant

LUPIAN and to keep the other three-quarter pounds of good quality

methamphetamine.

129. On March 19, 2012, defendant ESPINOSA accepted

approximately $800 from an unindicted co-conspirator as

24

Page 25: Pomona Meth Sweep - Indictment

1

2

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

additional payment for the approximately one-quarter pound of

methamphetamine that defendant ALCAZAR sold to the unindicted co-

conspirator on March 18, 2012.

130. On March 19, 2012, in coded language during a telephone

call, defendant BORRACHIN asked to purchase methamphetamine from

defendant ALCAZAR and specified that he wanted “bigger rocks” and

for defendant ALCAZAR to “handpick” the methamphetamine to ensure

defendant BORRACHIN was receiving good quality methamphetamine.

131. On March 19, 2012, defendant CHAVEZ returned

approximately one-quarter pound of poor quality methamphetamine

to defendant LUPIAN.

132. On March 20, 2012, in coded language during telephone

calls, defendant BORRACHIN asked defendant ALCAZAR if defendant

BORRACHIN could get “more donuts” (pounds of methamphetamine) for

an unidentified customer and advised that the customer wanted

“bigger” pieces.

133. On March 20, 2012, defendant ALCAZAR distributed

approximately two pounds of methamphetamine to defendant

BORRACHIN at a residence in Baldwin Park, California, for

redistribution by defendant BORRACHIN.

134. On March 20, 2012, in coded language during telephone

calls, defendant A. YEPEZ asked to purchase approximately

one-half ounce of methamphetamine from defendant CHAVEZ JR. to

sell to a waiting unidentified customer.

135. On March 20, 2012, defendant CHAVEZ JR. met with

defendant A. YEPEZ and the unidentified customer and distributed

one-half ounce of methamphetamine to the customer.

136. On March 20, 2012, in coded language during telephone

25

Page 26: Pomona Meth Sweep - Indictment

1

2

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

calls, defendants CHAVEZ JR. and A. YEPEZ discussed how much

defendant A. YEPEZ’ customer had paid for the one-half ounce of

methamphetamine, which of defendant CHAVEZ JR.’s phone numbers to

give to the customer, and the fact that the customer had his own

customers waiting to buy methamphetamine.

137. On March 20, 2012, in coded language during a telephone

call, defendant CERVANTES asked defendant LUPIAN how much two

pounds of methamphetamine would cost.

138. On March 20, 2012, in coded language during a telephone

call, defendant LUPIAN told defendant CERVANTES that two pounds

of methamphetamine would cost $9,800 or $9,600 per pound.

139. On March 20, 2012, in coded language during telephone

calls, defendant CERVANTES advised defendant LUPIAN that

defendant CERVANTES had customers who wanted to buy two pounds of

methamphetamine and who wanted to know if $19,200 was the

cheapest price for the two pounds of methamphetamine.

140. On March 20, 2012, defendant LUPIAN picked up two

pounds of methamphetamine from an unindicted co-conspirator.

141. On March 20, 2012, defendant LUPIAN distributed

approximately two-pounds of methamphetamine to defendant

CERVANTES so that defendant CERVANTES could sell it to his

customers.

142. On March 20, 2012, in coded language during a telephone

call, defendant CERVANTES told defendant LUPIAN that defendant

CERVANTES’ customers were unhappy with the quality of the two

pounds of methamphetamine provided by defendant LUPIAN and had

returned to Arizona without buying them.

143. On March 20, 2012, in coded language during telephone

26

Page 27: Pomona Meth Sweep - Indictment

1

2

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

calls, defendant LUPIAN told defendant CERVANTES that he would

take back the two pounds of methamphetamine.

144. On March 21, 2012, in coded language during a telephone

call, defendant LUPIAN told the unindicted co-conspirator that

defendant LUPIAN would be returning the two pounds of

methamphetamine so that the unindicted co-conspirator could “fix

the truck” (improve the quality of the methamphetamine).

145. On March 21, 2012, in coded language during a telephone

call, defendants ALCAZAR and ARMA arranged for the transfer of

approximately $12,013 of drug proceeds from the Central District

of California to Mexico.

146. On March 21, 2012, in coded language during telephone

calls, defendant PETE ordered approximately three ounces of

methamphetamine from defendant CHAVEZ JR. and told defendant

CHAVEZ JR. that he had the money to pay for the methamphetamine.

147. On March 21, 2012, defendant CHAVEZ JR. sold

approximately three ounces of methamphetamine to defendant PETE

for redistribution by defendant PETE.

148. On March 22, 2012, in coded language during telephone

calls, defendant ZARAGOZA asked to purchase approximately

one-quarter ounce of methamphetamine from defendant CHAVEZ JR.

and offered to pay defendant CHAVEZ JR. for a previous one-

quarter ounce of methamphetamine defendant CHAVEZ JR. had

supplied to him.

149. On March 22, 2012, defendant CHAVEZ JR. sold

approximately one-quarter ounce of methamphetamine to defendant

ZARAGOZA for redistribution by defendant ZARAGOZA.

150. On March 22, 2012, in coded language during a telephone

27

Page 28: Pomona Meth Sweep - Indictment

1

2

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

call, defendant ZARAGOZA asked defendant CHAVEZ JR. if the

methamphetamine that defendant CHAVEZ JR. sold to defendant

ZARAGOZA on March 22, 2012, was of the same quality as

methamphetamine defendant CHAVEZ JR. previously sold to defendant

ZARAGOZA because it smelled different.

151. On March 22, 2012, in coded language during a telephone

call, defendant JOYA advised defendant ALCAZAR that a customer

had returned one pound of methamphetamine, defendant JOYA had

exchanged the returned methamphetamine with another pound of

methamphetamine, and defendant JOYA currently possessed two

pounds of methamphetamine.

152. On March 22, 2012, in coded language during a telephone

call, defendants ALCAZAR and ESPINOSA arranged to sell

approximately six ounces of methamphetamine to defendant

BORRACHIN.

153. On March 23, 2012, in coded language during telephone

calls, defendants ALCAZAR and ARMA arranged for the transfer of

$12,583 of drug proceeds from the Central District of California

to Mexico.

154. On March 23, 2012, defendant RUELAS paid approximately

$1,000 in drug proceeds to defendant ZEPEDA for delivery to

defendant ALCAZAR.

155. On March 24, 2012, in coded language during telephone

calls, defendant LUPIAN asked defendant TONY if he had

approximately two pounds of methamphetamine for sale.

156. On March 24, 2012, defendant TONY sold approximately

two pounds of methamphetamine to defendant LUPIAN at a location

on State Street in Montclair, California, for redistribution by

28

Page 29: Pomona Meth Sweep - Indictment

1

2

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

defendant LUPIAN.

157. On March 26, 2012, in coded language during a telephone

call, defendant ZARAGOZA asked to purchase approximately one-

quarter ounce of methamphetamine from defendant CHAVEZ JR.

158. On March 27, 2012, in coded language during a telephone

call, defendant BARRON informed defendant ALCAZAR that defendant

BARRON would be sending five kilograms of methamphetamine from

Mexico to the Central District of California and instructed

defendant ALCAZAR not to purchase any other methamphetamine.

159. On March 27, 2012, in coded language during a telephone

call, defendant ALCAZAR told defendant BARRON that defendant

ALCAZAR had one-half kilogram of methamphetamine left to sell and

asked defendant BARRON to select good quality methamphetamine for

transport because the quality of the prior methamphetamine that

had been provided had caused their customers to complain.

160. On March 27, 2012, in coded language during a telephone

call, defendants BARRON and ALCAZAR discussed how much in drug

proceeds to leave in the United States to pay expenses and how

much in drug proceeds to send to Mexico for investment in Mexican

real estate.

161. On March 28, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. agreed to sell approximately one-half

pound of methamphetamine to the CI.

162. On March 28, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. arranged to purchase approximately

one-half pound of methamphetamine from defendant ALCAZAR.

163. On March 28, 2012, in coded language during a telephone

call, defendant ALCAZAR instructed defendant CHAVEZ JR. to pick

29

Page 30: Pomona Meth Sweep - Indictment

1

2

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

up the approximately one-half pound of methamphetamine from

defendant ZARATE at the Nocta Street Stash House.

164. On March 28, 2012, defendant CHAVEZ JR. sold

approximately 222.3 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

221.6 grams of actual methamphetamine) to the CI in exchange for

$5,000.

165. On March 28, 2012, defendant CHAVEZ JR. delivered

payment for the methamphetamine purchased by the CI to defendant

ALCAZAR.

166. On March 28, 2012, in coded language during telephone

calls, defendant CHAVEZ told defendant LUPIAN that he had money

and was on his way over to defendant LUPIAN’s ranch in Ontario,

California.

167. On March 28, 2012, in coded language during telephone

calls, defendant CHAVEZ told defendant CHAVEZ JR. that he was

picking up two ounces of methamphetamine from defendant LUPIAN

and asked if defendant CHAVEZ JR. wanted any methamphetamine.

168. On March 28, 2012, defendant LUPIAN distributed

approximately 111.5 grams of a mixture or substance containing a

detectable amount of methamphetamine (containing approximately

110.3 grams of actual methamphetamine) to defendant CHAVEZ for

redistribution by defendant CHAVEZ.

169. On March 28, 2012, defendant CHAVEZ possessed with

intent to distribute approximately 111.5 grams of a mixture or

substance containing a detectable amount of methamphetamine

(containing approximately 110.3 grams of actual methamphetamine)

in his car in Ontario, California.

30

Page 31: Pomona Meth Sweep - Indictment

1

2

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

170. On April 2, 2012, in coded language during a telephone

call and text messages, defendant LUPIAN agreed to sell

approximately one ounce of methamphetamine to an unknown customer

for $600.

171. On April 4, 2012, in coded language during telephone

calls, defendant PETE ordered approximately one ounce of

methamphetamine from defendant CHAVEZ JR. for an unidentified

female customer, but asked defendant CHAVEZ JR. to bring a

different kind because the methamphetamine defendant CHAVEZ JR.

had previously provided “tasted like detergent.”

172. On April 4, 2012, in coded language during telephone

calls, defendant CHAVEZ JR. told defendant PETE that he would

exchange the methamphetamine that “tasted like detergent” for

different methamphetamine.

173. On April 4, 2012, defendant CHAVEZ JR. distributed

approximately one ounce of methamphetamine to defendant PETE for

sale to an unidentified female customer.

174. On April 4, 2012, defendant PETE sold approximately

one-half ounce of methamphetamine to an unidentified female

customer.

175. On April 25, 2012, defendant ZARATE manufactured

methamphetamine.

176. On April 25, 2012, in coded language during a telephone

call, defendant BARRON checked on the quality of the

methamphetamine that defendant ZARATE had manufactured and

defendant ZARATE advised defendant BARRON that most of the

methamphetamine came out in large chunks.

177. On April 26, 2012, defendants REYES and ZARATE obtained

31

Page 32: Pomona Meth Sweep - Indictment

1

2

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

acetone for the production of methamphetamine.

178. On April 27, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to take the

methamphetamine out of the acetone.

179. On April 27, 2012, in coded language during a telephone

call, defendant BARRON directed defendant ZARATE to set aside

approximately one pound of methamphetamine for defendant BARRON.

180. On April 27, 2012, defendant ZARATE manufactured

methamphetamine at the Nocta Street Stash House.

181. On May 2, 2012, in coded language during telephone

calls, defendant ALCAZAR directed defendant ZARATE to drain the

methamphetamine that defendant ZARATE was manufacturing at the

Nocta Street Stash House.

182. On May 5, 2012, defendant ZARATE manufactured

approximately one pound of methamphetamine at the Nocta Street

Stash House.

183. On May 6, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to give

approximately one ounce of the methamphetamine defendant ZARATE

had just manufactured to a customer known as “Michael.”

184. On May 6, 2012, defendant ZARATE distributed

approximately one ounce of methamphetamine to the customer known

as “Michael.”

185. On May 7, 2012, in coded language during a telephone

call, defendant ALCAZAR inquired with defendant ZARATE about the

manufacturing of methamphetamine and directed defendant ZARATE to

put aside approximately two ounces of methamphetamine for

defendant ALCAZAR.

32

Page 33: Pomona Meth Sweep - Indictment

1

2

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

186. On May 7, 2012, defendant ZARATE manufactured

methamphetamine at the Nocta Street Stash House.

187. On May 7, 2012, defendant ZARATE distributed

approximately two ounces of methamphetamine to defendant ALCAZAR.

188. On May 8, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to put aside

approximately six ounces of methamphetamine for defendant ZEPEDA.

189. On May 8, 2012, defendant ZARATE distributed

approximately six ounces of methamphetamine to defendant ZEPEDA

for redistribution by defendant ZEPEDA.

190. On May 14, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to pull out

approximately one ounce of methamphetamine for him.

191. On May 14, 2012, defendant ZARATE distributed

approximately one ounce of methamphetamine to defendant ALCAZAR

for redistribution by defendant ALCAZAR.

192. On May 15, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to bring

approximately one pound of methamphetamine to 285 West Center

Street in Pomona, California.

193. On May 20, 2012, in coded language during a telephone

call, defendant ESPINOSA asked defendant ZARATE to bring

approximately one pound of methamphetamine to 285 West Center

Street in Pomona, California, for a waiting customer.

194. On May 20, 2012, in coded language during a telephone

call, defendant ZARATE told defendant ESPINOSA that he only had

approximately one-half pound of methamphetamine.

195. On May 20, 2012, in coded language during a telephone

33

Page 34: Pomona Meth Sweep - Indictment

1

2

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

call, defendant ESPINOSA agreed to take the one-half pound of

methamphetamine from defendant ZARATE and directed defendant

ZARATE to bring the methamphetamine to him.

196. On May 30, 2012, defendant REYES delivered liquid

methamphetamine to the Nocta Street stash house.

197. On May 30, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendants REYES and ZARATE to

wait for defendant CHAVEZ JR. before converting the liquid

methamphetamine into crystallized methamphetamine.

198. On May 30, 2012, defendants REYES and CHAVEZ JR.

carried the liquid methamphetamine from defendant REYES’ car into

the Nocta Street Stash House.

199. On May 30, 3012, defendants REYES, ZARATE, and CHAVEZ

JR. began converting liquid methamphetamine into crystallized

methamphetamine at the Nocta Street Stash House.

200. On May 31, 2012, in coded language during telephone

calls, defendant ZARATE updated defendant ALCAZAR on the progress

of converting the liquid methamphetamine into crystallized

methamphetamine at the Nocta Street Stash House.

201. On May 31, 2012, in coded language during a telephone

call, defendant CHAVEZ JR. asked defendant ZARATE about the

results of the methamphetamine conversion on May 30, 2012.

202. From June 2, 2012 through June 7, 2012, defendant

ZARATE manufactured methamphetamine at the Nocta Street Stash

House.

203. From June 2, 2012 through June 7, 2012, in coded

language during telephone calls, defendant ALCAZAR directed

defendant ZARATE’s manufacturing of methamphetamine.

34

Page 35: Pomona Meth Sweep - Indictment

1

2

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

204. On June 7, 2012, in coded language during a telephone

call, defendant ALCAZAR directed defendant ZARATE to put aside

approximately one pound of “pretty” methamphetamine for a

customer named “Reynaldo” and approximately one pound of

methamphetamine for defendant REYES.

35

Page 36: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWO

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about April 15, 2011, in Los Angeles County, within

the Central District of California, defendants JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” and RUDY ZEPEDA, aka “Virolo,” aka “Ojon,” knowingly and

intentionally distributed at least five grams, that is,

approximately 26.4 grams, of methamphetamine, a Schedule II

controlled substance.

36

Page 37: Pomona Meth Sweep - Indictment

1

2

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

COUNT THREE

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about May 11, 2011, in Los Angeles County, within the

Central District of California, defendant RUDY ZEPEDA, also known

as (“aka”) “Virolo,” aka “Ojon,” knowingly and intentionally

distributed at least five grams, that is, approximately 13.7

grams, of methamphetamine, a Schedule II controlled substance.

37

Page 38: Pomona Meth Sweep - Indictment

1

2

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

COUNT FOUR

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about June 3, 2011, in San Bernardino County, within

the Central District of California, defendants DANIEL LUPIAN,

also known as (“aka”) “Yogi,” aka “Nariz du Chupon,” CHRISTOPHER

ALVARADO, and MARCOS OREJEL, aka “Piolin,” knowingly and

intentionally distributed at least five grams, that is,

approximately 12.3 grams, of methamphetamine, a Schedule II

controlled substance.

38

Page 39: Pomona Meth Sweep - Indictment

1

2

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

COUNT FIVE

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about July 7, 2011, in Los Angeles County, within the

Central District of California, defendant MARCOS OREJEL, also

known as “Piolin,” knowingly and intentionally distributed at

least five grams, that is, approximately 27.2 grams, of

methamphetamine, a Schedule II controlled substance.

39

Page 40: Pomona Meth Sweep - Indictment

1

2

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

COUNT SIX

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about July 13, 2011, in Los Angeles County, within the

Central District of California, defendant JOSE ALVARADO knowingly

and intentionally distributed at least five grams, that is,

approximately 26.6 grams, of methamphetamine, a Schedule II

controlled substance.

40

Page 41: Pomona Meth Sweep - Indictment

1

2

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

COUNT SEVEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about July 21, 2011, in Los Angeles County, within the

Central District of California, defendant MARCOS OREJEL, also

known as “Piolin,” knowingly and intentionally distributed at

least five grams, that is, approximately 40.6 grams, of

methamphetamine, a Schedule II controlled substance.

41

Page 42: Pomona Meth Sweep - Indictment

1

2

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

COUNT EIGHT

21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about July 28, 2011, in Los Angeles County, within the

Central District of California, defendants JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” and RUDY ZEPEDA, aka “Virolo,” aka “Ojon,” knowingly and

intentionally distributed at least five grams, that is,

approximately 13.7 grams, of methamphetamine, a Schedule II

controlled substance.

42

Page 43: Pomona Meth Sweep - Indictment

1

2

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

COUNT NINE

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about August 19, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 46.8 grams, of methamphetamine, a

Schedule II controlled substance.

43

Page 44: Pomona Meth Sweep - Indictment

1

2

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

COUNT TEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(C)]

On or about September 1, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE ALVARADO

knowingly and intentionally distributed approximately 4.5 grams

of methamphetamine, a Schedule II controlled substance.

44

Page 45: Pomona Meth Sweep - Indictment

1

2

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

COUNT ELEVEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about September 14, 2011, in Los Angeles County,

within the Central District of California, defendant RUDY ZEPEDA,

also known as (“aka”) “Virolo,” aka “Ojon,” knowingly and

intentionally distributed at least five grams, that is,

approximately 23.9 grams, of methamphetamine, a Schedule II

controlled substance.

45

Page 46: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWELVE

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about September 22, 2011, in Los Angeles County,

within the Central District of California, defendant JOSE MARIA

CHAVEZ, JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 35.4 grams, of methamphetamine, a

Schedule II controlled substance.

46

Page 47: Pomona Meth Sweep - Indictment

1

2

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

COUNT THIRTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about September 28, 2011, in Los Angeles County,

within the Central District of California, defendant JOSE MARIA

CHAVEZ, JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 23.5 grams, of methamphetamine, a

Schedule II controlled substance.

47

Page 48: Pomona Meth Sweep - Indictment

1

2

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

COUNT FOURTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about October 7, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 48.2 grams, of methamphetamine, a

Schedule II controlled substance.

48

Page 49: Pomona Meth Sweep - Indictment

1

2

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

COUNT FIFTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about October 19, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 25.5 grams, of methamphetamine, a

Schedule II controlled substance.

49

Page 50: Pomona Meth Sweep - Indictment

1

2

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

COUNT SIXTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about October 28, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 51.6 grams, of methamphetamine, a

Schedule II controlled substance.

50

Page 51: Pomona Meth Sweep - Indictment

1

2

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

COUNT SEVENTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)]

On or about November 10, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least five

grams, that is, approximately 16.5 grams, of methamphetamine, a

Schedule II controlled substance.

51

Page 52: Pomona Meth Sweep - Indictment

1

2

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

COUNT EIGHTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about December 1, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 81.8 grams, of methamphetamine, a

Schedule II controlled substance.

52

Page 53: Pomona Meth Sweep - Indictment

1

2

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

COUNT NINETEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about December 16, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 111.1 grams, of methamphetamine, a

Schedule II controlled substance.

53

Page 54: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about December 21, 2011, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 61.9 grams, of methamphetamine, a

Schedule II controlled substance.

54

Page 55: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-ONE

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about January 6, 2012, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 110.4 grams, of methamphetamine, a

Schedule II controlled substance.

55

Page 56: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-TWO

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about January 25, 2012, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 110.1 grams, of methamphetamine, a

Schedule II controlled substance.

56

Page 57: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-THREE

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about February 6, 2012, in Los Angeles County, within

the Central District of California, defendant JOSE MARIA CHAVEZ,

JR., also known as (“aka”) “Jose M. Chavez Valencia,” aka

“Chema,” knowingly and intentionally distributed at least fifty

grams, that is, approximately 62.0 grams, of methamphetamine, a

Schedule II controlled substance.

57

Page 58: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-FOUR

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about February 21, 2012, in Los Angeles County, within

the Central District of California, defendants MARTIN BARRON

ALCAZAR, also known as (“aka”) “Quiniki,” aka “Quini,” aka

“Martin Garcia Barron,” and JOSE MARIA CHAVEZ, JR., aka “Jose M.

Chavez Valencia,” aka “Chema,” knowingly and intentionally

distributed at least fifty grams, that is, approximately 124.7

grams, of methamphetamine, a Schedule II controlled substance.

58

Page 59: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-FIVE

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about March 7, 2012, in Los Angeles County, within the

Central District of California, defendants MARTIN BARRON ALCAZAR,

also known as (“aka”) “Quiniki,” aka “Quini,” aka “Martin Garcia

Barron,” and JOSE MARIA CHAVEZ, JR., aka “Jose M. Chavez-

Valencia,” aka “Chema,” knowingly and intentionally distributed

at least fifty grams, that is, approximately 123.7 grams, of

methamphetamine, a Schedule II controlled substance.

59

Page 60: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-SIX

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about March 28, 2012, in Los Angeles County, within

the Central District of California, defendants MARTIN BARRON

ALCAZAR, also known as (“aka”) “Quiniki,” aka “Quini,” aka

“Martin Garcia Barron,” JORGE LUIS BARRON ZARATE, aka “Qoi,” aka

“Coyote,” and JOSE MARIA CHAVEZ, JR., aka “Jose M. Chavez

Valencia,” aka “Chema,” knowingly and intentionally distributed

at least fifty grams, that is, approximately 221.6 grams, of

methamphetamine, a Schedule II controlled substance.

60

Page 61: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-SEVEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about March 28, 2012, in San Bernardino County, within

the Central District of California, defendant DANIEL LUPIAN, also

known as (“aka”) “Yogi,” aka “Nariz du Chupon,” knowingly and

intentionally distributed at least fifty grams, that is,

approximately 110.3 grams, of methamphetamine, a Schedule II

controlled substance.

61

Page 62: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-EIGHT

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)]

On or about March 28, 2012, in San Bernardino and Los

Angeles Counties, within the Central District of California,

defendant JOSE MARIA CHAVEZ, also known as “Chemita,” knowingly

and intentionally possessed with intent to distribute at least

fifty grams, that is, approximately 110.3 grams, of

methamphetamine, a Schedule II controlled substance.

62

Page 63: Pomona Meth Sweep - Indictment

1

2

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

COUNT TWENTY-NINE

[21 U.S.C. § 856(a)(1)]

Beginning on a date unknown, and continuing until at least

on or about June 7, 2012, in Los Angeles County, within the

Central District of California, defendants JOSE JUAN GARCIA

BARRON, also known as (“aka”) “Tokes,” MARTIN BARRON ALCAZAR, aka

“Quiniki,” aka “Quini,” aka “Martin Garcia Barron,” ENRIQUE

CENTENO REYES, aka “Gordo,” aka “Gordito,” and JORGE LUIS BARRON

ZARATE, aka “Qoi,” aka “Coyote,” knowingly opened, leased,

rented, used, and maintained a place, permanently and

temporarily, to wit, the residence at 952 Nocta Street in Pomona,

California, for the purpose of manufacturing, distributing, and

using methamphetamine, a Schedule II controlled substance.

A TRUE BILL

Foreperson

ANDRÉ BIROTTE JR. United States Attorney

ROBERT E. DUGDALEAssistant United States AttorneyChief, Criminal Division

ELIZABETH R. YANGAssistant United States AttorneyChief, Violent & Organized Crime Section

JOEY L. BLANCHAssistant United States AttorneyDeputy Chief, Violent & Organized Crime Section

SHAWN J. NELSONAssistant United States AttorneysViolent & Organized Crime Section

63