AUSA Nicole M Kim 312 886-7635 AO 91 Rev 11 11 Criminal Complaint UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CASE NUMBER v PABLO VEGA CUEVAS ARTURO MARTINEZ ALEXANDER FIGUEROA ELISEO BETANCOURT-PEREIRA WILFREDO FLORES-SANTOS ROBERTO SANCHEZ JOSE RODRIGUEZ and ISAIAS MANDUJANO UNDER SEAL CRIMINAL COMPLAINT I the complainant in this case state that the following is true to the best of my knowledge and belief Count One Code Section Offense Description 21 U S C §§ 846 and 841 a 1 Beginning no later than August 2013 and continuing to in or about November 2014 in the Northern District of Illinois and elsewhere defendants PABLO VEGA CUEVAS ARTURO MARTINEZ ALEXANDER FIGUEROA ELISEO BETANCOURT-PEREIRA WILFREDO FLORES-SANTOS ROBERTO SANCHEZ and JOSE RODRIGUEZ did conspire with each other and with others known and unknown to knowingly and intentionally possess with intent to distribute and distribute a controlled substance namely 1 kilogram or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance Count Two Code Section Offense Description 21 U S C § 841 a 1 On or about April 29 2014 in the Northern District of Illinois ISAIAS MANDUJANO did knowingly and intentionally possess with intent to distribute a controlled substance namely 100 grams or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance This criminal complaint is based upon these facts X Continued on the attached sheet ADAM J STACHECKI Special Agent Drug Enforcement Administration Sworn to before me and signed in my presence Date December 8 2014 Judge’s signature City and State Chicago Illinois Sidney I Schenkier U S Magistrate Judge Printed name and Title UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS ss I Adam J Stachecki being duly sworn state as follows INTRODUCTION 1 I am a Special Agent with the Drug Enforcement Administration and have been so employed since approximately May 2012 2 Since becoming a DEA Special Agent my duties have included the investigation of criminal violations of federal narcotics laws including but not limited to 21 U S C §§ 841 a 843 b and 846 along with violations of 18 U S C §§ 1956 and 1957 money laundering I am an “investigative or law enforcement officer” within the meaning of 18 U S C § 2510 7 that is an officer of the United States who is empowered by law to conduct investigation of and to make arrests for offenses enumerated in 18 U S C § 2516 In addition I have been involved in various types of electronic surveillance including the interception of wire and electronic communications and the debriefing of defendants witnesses and informants as well as others who have knowledge of the distribution and transportation of controlled substances Through my training education and experience I have become familiar with the manner in which illegal narcotics are transported stored and distributed and the methods of payments for those narcotics 3 Because this Affidavit is for the limited purpose of establishing probable cause to support the criminal complaint and the issuance of arrest warrants against the proposed defendants as well as the proposed search and seizure warrants it contains only a summary of relevant facts I have not included each and every fact known to me concerning the entities individuals and events described in this Affidavit 4 This Affidavit is made in support of a multi-count complaint that charges as follows a Count One Beginning no later than August 2013 and continuing to in or about November 2014 in the Northern District of Illinois and elsewhere defendants PABLO VEGA CUEVAS ARTURO MARTINEZ ALEXANDER FIGUEROA ELISEO BETANCOURT-PEREIRA WILFREDO FLORES-SANTOS ROBERTO SANCHEZ and JOSE RODRIGUEZ did conspire with each other and with others known and unknown to knowingly and intentionally possess with intent to distribute and distribute a controlled substance namely 1 kilogram or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance in violation of 21 U S C § 841 a 1 all in violation of 21 U S C § 846 b Count Two On or about April 29 2014 in the Northern District of Illinois ISAIAS MANDUJANO did knowingly and intentionally possess with intent to distribute a controlled substance namely 100 grams or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance in violation of 21 U S C § 841 a 1 5 The statements contained in this Affidavit are based in part on a my personal participation in this investigation b information provided by other 2 federal and local law enforcement officers “LEOs” c review of consensually recorded conversations and conversations intercepted pursuant to orders authorizing the interception of wire and electronic communications d laboratory analysis reports e physical surveillance and surveillance reports f criminal history records g information from a cooperating source h telephone records and i my training and experience and the training and experience of other law enforcement agents FACTS SUPPORTING PROBABLE CAUSE I BACKGROUND OF THE NARCOTICS TRAFFICKING INVESTIGATION AND SUMMARY OF PROBABLE CAUSE 6 The complaint is based on an investigation by the DEA of individuals involved in the trafficking of narcotics from Mexico to the Chicago Illinois area During the investigation LEOs developed evidence that the defendants were involved in a drug trafficking organization “DTO” operating in Mexico and the Chicago area The investigation included the court-authorized interceptions of communications over various cellular telephones and Blackberry devices used by the following individuals 1 Target Phone Target Phone 1 Target Phone 1 Phone PIN Number 630 770-8920 630 770-8920 PIN 333FF6A7 User Intercept Period Pablo VEGA Cuevas 10 18 13 to 11 15 13 Pablo VEGA Cuevas 11 15 13 to 12 14 13 The interception orders for Target Phone 1 were authorized by Judge Paul Biebel Jr of the Circuit Court of Cook County Illinois The remaining interception orders were signed by Chief Judge Ruben Castillo and Acting Chief Judges of the Northern District of Illinois who authorized 30-day interception periods for each of the Target Devices 1 3 Target Phone User Intercept Period Target Device 1 Phone PIN Number PIN 2A72474D Arturo MARTINEZ Target Device 2 Target Device 3 PIN 2823BC76 PIN 2A922D8E Pablo VEGA Cuevas Roberto SANCHEZ 3 20 14 to 4 18 14 4 28 14 to 5 1 14 4 25 14 to 5 2 14 4 25 14 to 5 4 14 Target Device 4 PIN 333F1B34 Pablo VEGA Cuevas Target Device 5 Target Device 6 PIN 2824C71E PIN 2A10655C Target Device 7 Target Device 8 331 755-7275 PIN 333E56DF PIN 2B7586E0 5 28 14 to 6 26 14 7 3 14 to 7 15 14 FNU LNU a k a “STAR” 7 7 14 to 7 10 14 FNU LNU a k a “LOBO al 7 3 14 to 7 7 14 MILLON” Alexander FIGUEROA 7 1 14 to 7 22 14 7 3 14 to 7 22 14 Pablo VEGA Cuevas 8 5 14 to 9 2 14 Target Device 9 PIN 3329D00E Pablo VEGA Cuevas 9 24 14 to 10 24 14 10 25 14 to 11 3 14 Target Device 10 PIN 2A0AA879 FNU LNU a k a “SILVER” 9 24 14 to 10 9 14 A The Defendants’ Drug Trafficking Operation and Their Roles 7 Members of the VEGA DTO include PABLO VEGA CUEVAS ARTURO MARTINEZ ALEXANDER FIGUEROA ELISEO BETANCOURTPEREIRA WILFREDO FLORES-SANTOS ROBERTO SANCHEZ and other individuals Members of the VEGA DTO transported drugs from Mexico to the Chicago area stored drugs at warehouses in Aurora Illinois and Batavia Illinois and distributed drugs to narcotics customers As discussed in this Affidavit the VEGA DTO distributed narcotics to wholesale narcotics customers ROBERTO SANCHEZ ISAIAS MANDUJANO and others in the Northern District of Illinois The VEGA DTO also distributed narcotics to and picked up narcotics proceeds from JOSE RODRIGUEZ a narcotics courier 4 8 PABLO VEGA CUEVAS was a narcotics importer and distributor based in the Aurora Illinois area VEGA was the leader of the Chicago cell of the Guerrero Unidos DTO in Mexico “GUDTO” VEGA worked with various narcotics sources in Mexico to import wholesale amounts of heroin and cocaine from Mexico to Illinois and coordinated the distribution of heroin and cocaine and the collection of narcotics proceeds in the Chicago area on behalf of the GUDTO VEGA also worked with individuals in Mexico and the Chicago area to transport and distribute narcotics that were concealed in commercial passenger buses that traveled between Mexico and Chicago VEGA’s wholesale narcotics customers included ROBERTO SANCHEZ and others VEGA also directed the narcotics trafficking activities of ALEXANDER FIGUEROA ELISEO BETANCOURT-PEREIRA WILFREDO FLORES-SANTOS and others Additional information concerning VEGA’s acts on behalf of the DTO is in paragraphs 20-262 infra 9 ARTURO MARTINEZ was a Mexico-based narcotics trafficker who worked with VEGA to coordinate the deliveries and pick-ups of narcotics and narcotics proceeds in the Chicago area MARTINEZ arranged for various customers including ROBERTO SANCHEZ to receive wholesale amounts of heroin and cocaine from the VEGA DTO MARTINEZ also arranged for the collection and delivery of drug proceeds including by sending SANCHEZ to deliver proceeds to Individual A who built hidden compartments in vehicles used by the VEGO DTO to transport narcotics and narcotics proceeds 5 Additional information concerning MARTINEZ’s acts on behalf of the VEGA DTO is in paragraphs 23-73 105 120 259-262 infra 10 ALEXANDER FIGUEROA was a narcotics courier for the VEGA DTO FIGUEROA was responsible for delivering kilogram quantities of narcotics to various wholesale customers of the VEGA DTO including ROBERTO SANCHEZ and to narcotics couriers for these customers including JOSE RODRIGUEZ and others FIGUEROA also delivered and picked up narcotics proceeds from customers of the VEGA DTO including SANCHEZ and others FIGUEROA along with ELISEO BETANCOURT-PEREIRA and WILFREDO FLORES-SANTOS also worked to unload narcotics concealed in commercial passenger buses that traveled from Mexico to warehouses in Aurora Illinois and Batavia Illinois Additional information concerning FIGUEROA’s acts on behalf of the VEGA DTO is in paragraphs 31-34 72-91 130-165 170-258 infra 11 ELISEO BETANCOURT-PEREIRA “BETANCOURT” was a narcotics courier for the VEGA DTO BETANCOURT worked with ALEXANDER FIGUEROA and WILFREDO FLORES-SANTOS to deliver and pick up narcotics and narcotics proceeds from various customers of the VEGA DTO Additional information concerning BETANCOURT’s acts on behalf of the VEGA DTO is in paragraphs 145-225 infra 12 DTO WILFREDO FLORES-SANTOS was a narcotics courier for the VEGA FLORES-SANTOS worked with ALEXANDER FIGUEROA and ELISEO BETANCOURT-PEREIRA to deliver and pick up narcotics and narcotics proceeds 6 from various customers of the VEGA DTO Additional information concerning FLORES-SANTOS’ acts on behalf of the VEGA DTO is in paragraphs 134-225 infra 13 ROBERTO SANCHEZ purchased wholesale amounts of heroin and cocaine from the VEGA DTO SANCHEZ received the narcotics from various narcotics runners working on behalf of the VEGA DTO and in turn distributed the narcotics to his own customers including ISAIAS MANDUJANO SANCHEZ also acted as a courier for the VEGA DTO by delivering narcotics proceeds to various individuals at the direction of MARTINEZ Additional information concerning SANCHEZ is in paragraphs 25-71 82-127 infra 14 ISAIAS MANDUJANO purchased wholesale amounts of heroin from ROBERTO SANCHEZ On April 29 2014 MANDUJANO received one kilogram of heroin from SANCHEZ Additional information concerning MANDUJANO is in paragraphs 98-126 infra 15 JOSE RODRIGUEZ is a narcotics courier for a narcotics customer of the VEGA DTO RODRIGUEZ delivered narcotics proceeds to and obtained narcotics from the VEGA DTO Additional information concerning RODRIGUEZ is in paragraphs 162-173 202-203 infra B Law Enforcement’s Seizures of Narcotics and Narcotics Proceeds 16 The Probable Cause section of this Affidavit sets forth chronological detail of certain of the narcotics-related activities by the defendants and includes detailed information regarding the following seizures of narcotics and narcotics proceeds 7 a On August 21 2013 LEOs seized approximately 12 kilograms of heroin and 9 kilograms of cocaine from Individual B after Individual B received the narcotics from a confidential source “CS-1” who prior to CS-1’s cooperation worked as a narcotics courier for the VEGA DTO see paragraphs 17-19 b On August 21 2013 LEOs seized approximately $460 861 in narcotics proceeds from the VEGA DTO see paragraph 17 c On October 16 2013 LEOs seized approximately $8 238 in narcotics proceeds from the VEGA DTO see paragraph 44 footnote 23 d On June 7 2014 LEOs seized approximately 25 kilograms of heroin and 60 grams of cocaine from JOSE RODRIGUEZ after ALEXANDER FIGUEROA and ELISEO BETANCOURT-PEREIRA distributed the heroin to RODRIGUEZ see paragraphs 201-203 e On June 10 2014 LEOs seized approximately 31 kilograms of heroin from Individual C after ALEXANDER FIGUEROA and ELISEO BETANCOURT-PEREIRA distributed the heroin to Individual C see paragraph 225 II INFORMATION RECEIVED FROM THE CONFIDENTIAL SOURCE 17 On August 21 2013 LEOs conducted a traffic stop of Individual B’s vehicle in which LEOs discovered approximately $200 000 in United States currency Pursuant to a consent search of Individual B’s residence in Chicago Illinois LEOs discovered an additional approximately $231 000 in United States currency 12 kilograms of heroin and 9 kilograms of cocaine According to Individual B Individual B delivered and picked up these narcotics and narcotics 8 proceeds on CS-1’s behalf At Individual B’s residence LEOs encountered CS-1 and arrested CS-1 for narcotics-trafficking offenses 2 CS-1 agreed to cooperate with LEOs and consented to a search of CS-1’s residence where LEOs found an additional $30 000 in United States currency which CS-1 identified as drug proceeds that CS-1 had previously collected from a narcotics customer 3 18 According to CS-1 since February 2013 CS-1 has picked up and delivered multi-kilogram quantities of narcotics as well as narcotics proceeds on behalf of ARTURO MARTINEZ and an individual known to CS-1 as FNU LNU a k a “TRANSFORMER ”4 According to CS-1 at MARTINEZ’s direction CS-1 picked up the narcotics and narcotics proceeds that LEOs found in Individual B’s vehicle and residence on August 21 2013 CS-1 then directed Individual B to deliver and pick up these narcotics and narcotics proceeds on behalf of the VEGA DTO 2 CS-1 also identified ROBERTO SANCHEZ as a narcotics customer of No charges have been filed against CS-1 in connection with this arrest CS-1 is cooperating in exchange for consideration on what if any charges CS-1 faces in connection with CS-1’s arrest on August 21 2013 To date CS-1 has been paid approximately $8 647 by the DEA for operational expenses CS-1 has at least one prior arrest for larceny and no known criminal convictions The information provided by CS-1 to LEOs was proven reliable in that it was corroborated by consensually recorded telephone communications court-authorized wire and electronic communications surveillance and law enforcement records 3 CS-1 subsequently identified an unmarked Illinois driver’s license and surveillance photographs of PABLO VEGA CUEVAS as the individual CS-1 knows as “TRANSFORMER ” CS-1 also informed LEOs that “TRANSFORMER” is the Blackberry messenger screen name for VEGA 4 9 MARTINEZ and VEGA 5 According to CS-1 CS-1 previously picked up from and delivered narcotics proceeds to SANCHEZ on behalf of the VEGA DTO 19 According to CS-1 when narcotics or narcotics proceeds needed to be picked up or delivered CS-1 would receive a call from MARTINEZ and or VEGA who gave CS-1 further instructions on how and where to pick up and deliver the narcotics and narcotics proceeds According to CS-1 MARTINEZ resides in Mexico from where he coordinates the delivery of narcotics to the Chicago Illinois area On or about August 21 2013 CS-1 consented to a search of CS-1’s Blackberry device Pursuant to this consent search LEOs observed the following PIN-to-PIN conversations between CS-1 and VEGA as described below in paragraphs 20-21 6 20 On August 16 2013 between approximately 7 12 p m and 10 39 p m CS-1 using a Blackberry device had the following BBM conversation with VEGA 7 CS-1 subsequently identified an unmarked Illinois driver’s license photograph of ROBERTO SANCHEZ as the individual CS-1 knows as ROBERTO SANCHEZ According to Illinois Secretary of State records ROBERTO SANCHEZ is the president and registered agent of R Sanchez Landscaping Inc 5 6 After CS-1’s arrest on August 21 2013 LEOs seized CS-1’s Blackberry device PIN-to-PIN communications are asynchronous messages messages that do not require both parties to be connected and “present” at the same time similar to a text message but transmitted via Blackberry’s proprietary communication network Thus the holder of a Blackberry “BB” device cannot have a PIN-to-PIN communication with someone who does not have a BB device A PIN-to-PIN communication is addressed directly to a BB PIN As the PIN is unique to each device Blackberry regulates the steady state of connection of the PIN to ensure that PIN-to-PIN traffic reaches only its intended destination Furthermore BB users may also communicate via the Blackberry Messenger “BBM” system which is Blackberry’s proprietary instant messaging service Like PIN-to-PIN communications BBM uses device PINs for addressing again ensuring that BBM traffic only reaches its intended destination Reference is made in this Affidavit to consensually recorded and unrecorded telephone conversations BBM conversations observed in CS-1’s telephone by LEOs and courtauthorized interception of BBM conversations over Target Devices used by the defendants 7 10 who was using Blackberry PIN 333FF6A7 “Vega Device 1” 8 In that conversation VEGA stated “Dude take care of the guy deliver narcotics to chika Have him tell you what he needs ” CS-1 replied “Okay no problem ” VEGA further stated “All right thank you Let me know what narcotics you give him ” CS-1 responded “Okay they want three big ones three kilograms of narcotics and two small ones collectively the “Communications” In certain instances these Communications are summarized and placed in context in brackets The bracketed comments are my understanding of the Communications and coded language used during the Communications My understanding is based on my training and experience and investigation to date my discussions with other LEOs the experience of other LEOs in this investigation and other evidence developed during the course of the investigation including information obtained from CS-1 and CS-1’s explanation of the language used in the Communications The times listed for the Communications are approximate Unless otherwise noted the Communications are in Spanish and were translated by Spanish speaking agents or interpreters contracted by DEA Further summaries of the Communications described herein do not represent finalized transcripts and may not represent the entire conversation that occurred between the identified individuals In addition all of the voice identifications in the consensually recorded telephone conversations are preliminary In most cases voice identifications are based on names used during the recorded conversations information obtained by the investigative agents and CS-1 and voice recognition that has been accomplished to date by LEOs Italicized words appearing in such summaries were spoken in English or have been left in Spanish for emphasis Unless otherwise noted LEOs used one or more of the following methods to verify that each of the consensually recorded and unrecorded calls text messages and Blackberry PIN-toPIN messages summarized in the Affidavit in which CS-1 participated in was to or from the telephone number or Blackberry PIN specified in the Affidavit analysis of toll records LEOs viewing incoming or outgoing texts and PIN-to-PIN messages on the screen of CS-1's cell phone and LEOs’ review of call detail in CS-1’s cell phone The identification of VEGA as the user of Vega Device 1 is based on the following a based on telephone location information for Vega Device 1 which was authorized by a judge of the Circuit Court of Cook County Illinois on August 23 2013 on August 26 2013 the user of Vega Device 1 was located at 641 Grand Avenue Aurora Illinois b according to Illinois Secretary of State records a PABLO VEGA CUEVAS is associated with 641 Grand Avenue Aurora Illinois c LEOs compared a photograph of the individual seen during surveillance at 641 Grand Avenue on August 26 2013 to an Illinois driver’s license photograph of PABLO VEGA CUEVAS and determined that the same person is depicted in both photographs 8 11 two kilograms of narcotics early tomorrow ” According to CS-1 CS-1 delivered these amounts of narcotics shortly after this conversation with VEGA 21 On August 20 2013 between approximately 7 16 p m to 7 17 p m CS- 1 using a Blackberry device had a BBM conversation with VEGA who was using Vega Device 1 During that conversation VEGA stated “I just gave your telephone number for you to deliver two hundred thousand dollars today They are going to tell you that they are calling on behalf of Transformer VEGA ” CS-1 replied “Okay ” 22 Based on the above-described BBM communications I believe that VEGA gave CS-1’s telephone number to an unknown person who was to call CS-1 to coordinate the pickup of $200 000 in narcotics proceeds on behalf of VEGA According to CS-1 Individual B attempted to deliver the $200 000 but the money was seized by LEOs on August 21 2013 A CS-1’s Consensually Recorded Calls with MARTINEZ and SANCHEZ in August and September 2013 Regarding Narcotics Trafficking Activities Call with MARTINEZ Regarding Law Enforcement Seizure 23 On August 21 2013 at approximately 8 45 p m at the direction of law enforcement CS-1 had a consensually recorded telephone conversation with MARTINEZ who was using Mexican telephone number 5217332947475 “Mexico Phone 1” 9 During that call MARTINEZ asked “Explain to me exactly what After CS-1’s arrest on August 21 2013 CS-1 identified two Mexican telephone numbers used by MARTINEZ one of which was Mexico Phone 1 Based on information provided by CS-1 the context of this call and the seizure of narcotics and narcotics proceeds at 9 12 happened what happened earlier that day when drugs and drug proceeds were seized by LEOs ” CS-1 replied “Yesterday Transformer VEGA sent me a message at night ” CS-1 added “That they VEGA’s narcotics associates were going to call on behalf of Transformer VEGA … to deliver two hundred pickup of $200 000 in narcotics proceeds from VEGA’s narcotics customers ” CS-1 asked “But I mean is Transformer VEGA or one of you guys going to do something because you are mad ” CS-1 added “It’s a lot of money ” MARTINEZ responded “I already told you … they narcotics associates of VEGA and MARTINEZ are not those types of people that will do something over money … You need to trust me ” MARTINEZ later added “Remember that I told you that if you do any shit to me and betray me I will be the one held responsible not you They narcotics associates of VEGA and MARTINEZ are going to talk to me not to you ” MARTINEZ stated “I told you that since the beginning when I was over there that last time MARTINEZ was in Chicago ” 24 Based on the above-described telephone conversation I believe that MARTINEZ asked CS-1 about the law enforcement seizure of narcotics and narcotics proceeds on August 21 2013 CS-1 asked MARTINEZ whether there would be any consequences to CS-1 losing the drugs and money MARTINEZ replied that he not CS-1 would be held responsible for the loss Individual B’s residence on August 21 2013 I believe MARTINEZ was a participant in this call and inquired about the law enforcement seizure 13 Calls with SANCHEZ Regarding the Pick Up of Narcotics Proceeds 25 On September 4 2013 at approximately 6 48 p m at the direction of law enforcement CS-1 had a consensually recorded telephone conversation with SANCHEZ who was using telephone number 773 301-4087 the “Sanchez Phone” 10 During that call CS-1 stated “I got to do something real quick ” SANCHEZ replied “You have to wait for me bro You have to wait I cannot … back and forth with this shit the drug proceeds ” CS-1 asked “You cannot come in an hour ” SANCHEZ responded “No Now bro … I have to do this And I have to right now ” SANCHEZ added “I am right here close to ya ” CS-1 replied “Okay cool I will be here then ” 26 Continuing on September 4 2013 at approximately 7 00 p m SANCHEZ met CS-1 in the 4000 block of N Monticello Chicago Illinois This meeting was not observed or recorded by LEOs According to CS-1 during that meeting SANCHEZ gave CS-1 approximately $302 855 in cash Also according to CS-1 this money was payment for the kilogram quantities of cocaine that CS-1 previously delivered to SANCHEZ at MARTINEZ’s direction prior to CS-1’s cooperation with LEOs Approximately fifteen minutes after CS-1 received the The identification of SANCHEZ as the user of the Sanchez Phone is based on the following a based on telephone location information for the Sanchez Phone which was authorized by Judge Nicholas Ford of the Circuit Court of Cook County Illinois on or about August 30 2013 on September 5 and September 9 2013 the user of the Sanchez Phone was located at 2241 Monitor Avenue Chicago Illinois which CS-1 identified as SANCHEZ’s residence and b LEOs showed CS-1 an unmarked Illinois driver’s license photograph of SANCHEZ and CS-1 identified the individual in the photograph as the person CS-1 knows as SANCHEZ and the individual who delivered approximately $302 855 of narcotics proceeds to CS-1 on September 4 2013 10 The September 4 2013 call was in English 14 money from SANCHEZ LEOs met with CS-1 and took custody of the $302 855 which was contained inside a black plastic trash bag B On September 4 2013 VEGA and MARTINEZ Directed CS-1 to Deliver $263 000 in Narcotics Proceeds to FIGUEROA 27 On September 4 2013 at approximately 9 53 p m at the direction of law enforcement CS-1 made consensually recorded telephone call to VEGA who was using Vega Device 1 During that call VEGA stated “They are telling me over at … That I’m going to send my guy VEGA’s narcotics courier early ” VEGA added “This one that guy VEGA’s narcotics courier that’s going is trustworthy He is my brother in law ” Later in the conversation VEGA stated “Perfect I’m going to give this number then I’m going to give this number CS-1’s telephone number to my guy to my brother in law husband ” He is my sister’s Individual H’s VEGA further stated “Don’t feel like you can’t trust him VEGA’s brother in law If anything happens there I will be held responsible because that’s my guy VEGA’s brother in law ” VEGA also stated “In other words he is my brother in law and is family ” 28 Continuing on September 4 2013 at approximately 10 21 p m at the direction of law enforcement CS-1 made a consensually recorded telephone call to MARTINEZ who was using Mexican telephone number 5217331337174 “Mexican Phone 2” 11 During that call MARTINEZ asked “What happened ” CS-1 replied The identification of MARTINEZ as the user of Mexico Phone 2 is based on the following LEOs listened to the voice of the user of Mexico Phone 2 and compared it to the voice of the individual consensually recorded using Mexico Phone 1 and determined that it was the same person 11 15 “Okay it’s the money SANCHEZ previously delivered to CS-1 … three hundred two eighty-fifty $302 850 ”12 MARTINEZ further asked “Okay how much was he SANCHEZ short ” CS-1 responded “He SANCHEZ was short five thousand $5 000 ” MARTINEZ stated “He SANCHEZ told me that you CS-1 were calling him and said he SANCHEZ was short four $4 000 … He SANCHEZ said that he SANCHEZ was going to drop them narcotics proceeds off early in the morning ” CS-1 asked “Okay listen what do I do with the earnings MARTINEZ’s profits from the narcotics proceeds ” MARTINEZ replied “Okay from there our earnings MARTINEZ and CS-1’s cut are twenty $20 000 ” MARTINEZ then added “I’ll call you back dude Let me do the math and that way I can tell you how much how much … ” 29 Continuing on September 4 2013 at approximately 10 48 p m CS-1 had a consensually recorded conversation with MARTINEZ who was using Mexican Phone 3 During that call MARTINEZ stated “8 small ones times 31 equals 248 8 kilograms of cocaine at $31 000 per kilogram equals a total of $248 000 ” MARTINEZ further stated “Give from eight 8 kilograms of cocaine which is equal to 248 $248 000 plus an additional 22 000 $22 000 that gives you 270 $270 000 Then from there we get our profit MARTINEZ stating that their profit will be taken from the $270 000 ” CS-1 inadvertently quoted the amount of proceeds that SANCHEZ previously delivered to CS-1 as $302 850 and not $302 855 which is the amount LEOs recovered from CS-1 earlier that day 12 16 30 Based on the above-described consensually recorded telephone calls I believe that VEGA instructed CS-1 to pick up narcotics proceeds from his brotherin-law CS-1 then reported to MARTINEZ that SANCHEZ was short $5 000 when SANCHEZ previously delivered $302 855 in narcotics proceeds to CS-1 on September 4 2013 MARTINEZ instructed CS-1 to take $270 000 out of the $302 855 delivered by SANCHEZ and deliver the $270 000 of narcotics proceeds to VEGA’s brother in law 31 On September 5 2013 at approximately 9 23 a m CS-1 had a consensually recorded telephone conversation with ALEXANDER FIGUEROA who was using telephone number 630 478-1182 the “Figueroa Phone” 13 This call was in English During this call CS-1 stated “You know there is ah K-Mart On Addison ” FIGUEROA responded “Oh off the Pulaski ” CS-1 stated “The Addison exit the Addison street exit of the Kennedy Expressway in Chicago Illinois ” CS-1 further stated “Just in that parking lot bro ” CS-1 added “Real quick I’ll hand it the narcotics proceeds off to you real quick man ” FIGUEROA replied “I am gonna be there in probably in like … 30 minutes ” Based on surveillance information obtained from law enforcement databases trash pulls and the September 4 2013 telephone call between VEGA and CS-1 where VEGA refers to his “brother-in-law ” it is believed that FIGUEROA is VEGA’s brother-in-law 13 The identification of FIGUEROA as the user of the Figueroa Phone is based on the following Based on telephone location information for the Figueroa Phone which was authorized by the Circuit Court of Cook County on or about September 11 2013 LEOs established surveillance at 641 Grand Avenue Aurora Illinois Based on a trash pull at that location LEOs found material addressed to FIGUEROA at 641 Grand Avenue Aurora Illinois FIGUEROA was identified based on a comparison of the individual seen by LEOs driving during surveillance to an Illinois driver’s license photograph of FIGUEROA and LEOs’ determination that they were the same person 17 32 Continuing on September 5 2013 at approximately 9 33 a m CS-1 had a consensually recorded telephone conversation with MARTINEZ who was using Mexican Phone 2 During this call MARTINEZ stated “You’re going to take take seven $7 000 so there won’t be any mistakes ” CS-1 asks “From where ” MARTINEZ replies “From the account … from their account From what you’re going to deliver the $263 000 that CS-1 was to deliver to VEGA’s brother in law ” MARTINEZ added “I’m going to let Transformer VEGA know that you’re going to withdraw seven $7 000 ” MARTINEZ further stated “And call me once you’ve handed it $263 000 in narcotics proceeds over so I can give you the names as to how they’re going to be placed where to send the remaining $7 000 ” 33 On September 5 2013 at approximately 9 50 a m LEOs searched CS- 1 and CS-1’s vehicle for contraband and found none LEOs then provided CS-1 with a recording device and a duffle bag containing $263 000 in United States currency for the purpose of delivering the money to VEGA’s associate LEOs observed CS-1 drive to a K-mart parking lot located at 3443 W Addison Avenue Chicago Illinois LEOs further observed FIGUEROA open the rear passenger door of CS-1’s vehicle and remove a duffle bag which contained $263 000 14 According to the recording of the meeting FIGUEROA asked “Is it all there ”15 CS-1 responded “Yes ” CS-1 further asked “Is Transformer VEGA pissed off ” FIGUEROA replied “No LEOs identified FIGUEROA by his Illinois driver’s license photograph In addition on September 17 2013 CS-1 identified the individual depicted in an unmarked Illinois driver’s license photograph of FIGUEROA as the individual who picked up $263 000 from CS-1 on September 5 2013 14 15 The conversation between CS-1 and FIGUEROA was in English 18 Transformer VEGA is cool ” FIGUEROA later stated “Shit the August 21 2013 seizure by LEOs of the narcotics and $230 000 drug proceeds happens and like that’s happened before ” CS-1 stated “There is seven grand $7 000 out of there so it’s 263 $263 000 ” FIGUEROA responded “Okay I will let him VEGA know ” 34 LEOs then observed FIGUEROA place the duffle bag inside a maroon Acura bearing Illinois license N773755 16 LEOs followed FIGUEROA driving the maroon Acura from the parking lot to a nearby park where FIGUEROA parked the vehicle and reached into the rear side panel area of the vehicle for approximately ten minutes LEOs then observed FIGUEROA leave the park and make numerous turns on side streets before driving into the attached garage of 1744 Shari Lane Aurora Illinois 17 35 Based on the consensually recorded conversations that CS-1 had with VEGA MARTINEZ and FIGUEROA and the surveillance of CS-1’s meeting with FIGUEROA I believe that MARTINEZ instructed CS-1 to take $7 000 from the $270 000 of narcotics proceeds that CS-1 was supposed to deliver to FIGUEROA MARTINEZ further instructed CS-1 that he would give CS-1 instructions on where to send the remaining $7 000 MARTINEZ also indicated that he would tell VEGA According to Illinois Secretary of State records this vehicle is registered to Individual H at 641 Grand Avenue Aurora Illinois According to law enforcement databases FIGUEROA is associated with 641 Grand Avenue Aurora Illinois and Individual H is FIGUEROA’s wife In addition pursuant to a trash pull LEOs found mail addressed to FIGUEROA at that address 16 Based on information from law enforcement databases LEOs’ observations of VEGA coming from and going to the residence dozens of times and location information for Target Devices used by VEGA that showed VEGA at the residence on numerous occasions between August 2013 through November 2014 LEOs determined that VEGA resides at 1744 Shari Lane Aurora Illinois 17 19 that CS-1 was going to take out $7 000 from the narcotics proceeds to be delivered to FIGUEROA CS-1 then delivered $263 000 to FIGUEROA Based on my training and experience the experience of other LEOs and physical surveillance of FIGUEROA I believe that after FIGUEROA received the money from CS-1 FIGUEROA put the money in a hidden compartment of the maroon Acura C In September 2013 MARTINEZ Directed CS-1 to Deliver Narcotics Proceeds to Individual A and Individual D 36 On September 7 2013 at approximately 9 49 a m CS-1 had a consensually recorded telephone conversation with MARTINEZ who was using Mexican Phone 2 During that call MARTINEZ stated “Just take ten tickets $10 000 to my friend with the garage Individual A What happens is that he Individual A is going to look for a truck vehicle with hidden compartments for me For Transformer VEGA ” 37 Continuing on September 9 2013 at approximately 10 58 a m LEOs searched CS-1 and CS-1’s vehicle for contraband and found none LEOs then provided CS-1 with a bag containing $9 998 in United States currency for the purpose of delivering the money to Individual A LEOs observed CS-1 drive to the alley next to 2341 North Monitor Avenue Chicago Illinois 18 At that location Individual A met with CS-1 and took from CS-1 an envelope which contained According to CS-1 in mid-August 2013 at the direction of MARTINEZ CS-1 went to the area near 2341 North Monitor Avenue Chicago Illinois to meet an individual known to CS-1 as the “Garage ” who showed CS-1 how to operate a hidden compartment in a black Jeep According to CS-1 CS-1 was instructed by MARTINEZ and VEGA to use this Jeep to transport narcotics and narcotics proceeds 18 20 $9 998 19 CS-1 left the location shortly thereafter After the transaction LEOs met CS-1 and searched CS-1 and CS-1’s vehicle for contraband and found none 38 Based on CS-1’s consensually recorded telephone call with MARTINEZ and surveillance of CS-1 on September 9 2013 I believe that MARTINEZ instructed CS-1 to deliver approximately $10 000 of narcotics proceeds belonging to MARTINEZ to Individual A The money was to pay Individual A to build a hidden compartment in a vehicle that MARTINEZ and VEGA could use to transport drugs and drug proceeds 39 Continuing on September 11 2013 at approximately 9 30 a m CS-1 had a consensually recorded telephone conversation with MARTINEZ who was using Mexican Phone 2 In that call MARTINEZ instructed CS-1 to deliver $10 000 of drug proceeds to “Primo” Individual D an individual MARTINEZ identified as his cousin 20 40 On September 11 2013 at approximately 11 11 a m CS-1 had a consensually recorded telephone conversation with Individual D who was using telephone number 708 953-4817 In that conversation Individual D asked “What’s up How are you ” CS-1 replied “Good good good Hey we’re supposed to deliver something narcotics proceeds to you today Individual D stated “Oh yeah well my cousin MARTINEZ called me in the morning but uh what time CS-1 identified Individual A as the individual CS-1 knows as “Garage ” The identification of Individual A was made through an April 4 2014 traffic stop of Individual A and LEOs’ comparison of the individual seen on surveillance and a law enforcement photograph of Individual A which LEOs determined to be the same person 19 According to CS-1 prior to CS-1’s cooperation CS-1 delivered narcotics proceeds to “Primo Individual D ” at MARTINEZ’s direction 20 21 could I pass by ” CS-1 responded “If you want about 2 30 ” conversation CS-1 stated “Yeah right there Later in the By that auto parts that’s right there ” Individual D replied “Okay perfect yes I remember ” 41 Continuing on September 11 2013 at approximately 12 52 p m CS-1 had another consensually recorded telephone conversation with Individual D In that conversation Individual D asked “What was I going to ask you Which street ” CS-1 replied “Right there on Lawndale ” Individual D later stated “Okay so then I’ll call you right now when I’m there I’m already close by ” CS-1 replied “Okay ” 42 Later that same day LEOs met CS-1 and searched CS-1 for contraband and found none LEOs then provided CS-1 with a recording device and $10 000 in cash to provide to Individual D At approximately 1 00 p m LEOs observed a green Honda arrive in an alley near Lawndale and Montrose Avenues in Chicago LEOs further observed Individual D in the driver’s seat of the Honda CS1 entered the vehicle and got out shortly afterward After the meeting LEOs met with CS-1 at a predetermined location According to CS-1 CS-1 provided the $10 000 to Individual D in a brown paper bag 21 43 On September 27 2013 CS-1 had several other consensually recorded telephone conversations with Individual D to deliver narcotics proceeds to Individual D on MARTINEZ’s behalf That same day at approximately 4 45 p m LEOs met CS-1 at a predetermined location LEOs also searched CS-1 for Although this meeting was recorded the recording only reflected Individual A and CS-1 engaged in small talk such as discussing the weather 21 22 contraband and found none LEOs provided CS-1 with $11 000 in cash for the purpose of delivering the money to Individual D 22 At approximately 5 12 p m LEOs observed Individual D in the driver’s seat of the Honda arrive at the corner of Lawndale and Montrose Avenues in Chicago LEOs further observed CS-1 enter the front passenger seat of the Honda A few minutes later CS-1 got out of the vehicle and met LEOs LEOs searched CS-1 for contraband and found none According to CS-1 CS-1 delivered the $11 000 to Individual D who was then supposed to wire the proceeds to MARTINEZ in Mexico 44 Based on CS-1’s consensually recorded conversations with Individual D information obtained from CS-1 and physical surveillance I believe that MARTINEZ instructed CS-1 to deliver MARTINEZ’s share of drug proceeds to Individual D 23 CS-1 was also provided with an audio recording device but the device was inadvertently powered off and did not record CS-1’s conversation with Individual D 22 Out of the $302 855 of narcotics proceeds that SANCHEZ delivered to CS-1 on September 4 2013 LEOs used these funds in controlled deliveries by CS-1 and the remaining balance of $8 238 was kept by LEOs for forfeiture on or about October 16 2013 23 23 III THE VEGA DTO ACTIVITIES CAPTURED DURING THE WIRETAP INVESTIGATION A In March and April 2014 SANCHEZ Received Kilogram Quantities of Heroin from the VEGA DTO and Delivered Narcotics Proceeds to Various Individuals at MARTINEZ’s Direction Between on or about March 18 2014 through on or about March 21 2014 SANCHEZ Received Three Kilograms of Heroin from the VEGA DTO 45 On March 20 2014 at approximately 9 23 p m Session #4025137 MARTINEZ using Target Device 1 24 had a BBM conversation with VEGA who was using Blackberry PIN 2B482519 “Vega Device 2” 25 During that conversation MARTINEZ asked “You gave my guy SANCHEZ what he SANCHEZ wanted right And he gave you for one today SANCHEZ paid for one kilogram of heroin cousin ” VEGA responded “He will not be given any heroin until tomorrow ” MARTINEZ stated “No cousin yesterday you gave him SANCHEZ one one The identification of MARTINEZ as the user of Target Device 1 is based on the following a information from CS-1 regarding CS-1’s dealings with MARTINEZ b the content of recorded calls and BBM exchanges between MARTINEZ and CS-1 and c the use of the Blackberry Messenger screen name of “Apaxtla ” which is the name CS-1 told LEOs that MARTINEZ previously used 24 The identification of VEGA as the user of Vega Device 2 is based on the following a consensual interceptions of BBM communications on CS-1’s Blackberry device and pen register data for Target Device 1 showed that VEGA was using Blackberry PIN 334B7A73 in February 2014 and b pen register data showed that the last outgoing message from PIN 334B7A73 was on March 14 2014 and there was no other activity on that PIN since March 14 2014 On March 15 2014 DEA Chicago learned that VEGA’s brother Individual MAVC believed to be one of the leaders of the GUDTO in Mexico drowned in Mexico Periodic surveillance at VEGA’s residence at 1744 Shari Lane Aurora Illinois revealed that VEGA’s vehicle was not at the residence In addition interceptions over Target Device 1 used by MARTINEZ indicated that VEGA was in Mexico Based on pen register data surveillance and a common-call analysis between Blackberry PIN 334B7A73 and Vega Device 2 LEOs identified Vega Device 2 as VEGA’s Blackberry PIN Out of the 35 BBM PINs in contact with Vega Device 2 as of March 14 2014 14 of those PINs were also in contact with VEGA’s previous BBM PIN 334B7A73 25 24 kilogram of heroin and he paid for it today and he will pay for the other another amount of heroin tomorrow The one you gave him four days ago And tomorrow he wants another additional heroin okay Cousin see if you can give it heroin to him SANCHEZ as soon as he gives you the paper money okay cousin 46 Continuing on March 20 2014 at approximately 9 55 p m Session #4025168 MARTINEZ using Target Device 1 had a BBM conversation with VEGA who was using Vega Device 2 During this conversation VEGA stated “Yes it is already going to be arranged with the guy SANCHEZ ” MARTINEZ responded “And hand in one one kilogram of heroin more tomorrow But are you aware that you gave him SANCHEZ one one kilogram of heroin and you were paid right away So you can give the green light provide SANCHEZ with heroin so they’ll take care of him SANCHEZ promptly ” 47 On March 20 2014 at approximately 10 26 p m Session #4025138 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 26 During this conversation MARTINEZ asked “How much do you have exactly You know how you wanted one one kilogram of heroin yesterday Did they VEGA’s couriers give it to you ” SANCHEZ replied “Yes I already paid him VEGA today ” MARTINEZ stated “And you have one pending right cousin ” SANCHEZ replied “The one one kilogram of heroin they gave me According to CS-1 on February 3 2014 CS-1 met SANCHEZ in the vicinity of the 4300 block of N Sawyer Avenue in Chicago This meeting was not recorded by LEOs According to CS-1 during this meeting SANCHEZ told CS-1 that his Blackberry PIN was 2A922D8E Target Device 3 The identification of SANCHEZ as the user of Target Device 3 was corroborated by the content of the intercepted BBM communications on Target Device 3 26 25 day before yesterday I will pay for tomorrow ” MARTINEZ responded “Thank you because we are doing the math here but take care ” 48 On March 21 2014 at approximately 7 42 p m Session #4028505 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 During this conversation SANCHEZ stated “I have the paper money for the heroin already and they VEGA’s couriers already took care of me again provided SANCHEZ with an additional one kilogram of heroin ” MARTINEZ replied “The one one kilogram of heroin you told me was pending and you paid for another another quantity of heroin aside from that ” SANCHEZ stated “I paid for one one kilogram of heroin yesterday And I have enough enough money for the other one kilogram of heroin received by SANCHEZ on March 18 2014 And they VEGA’s couriers already gave me another another kilogram of heroin today ” MARTINEZ stated “When you told me that you wanted one one kilogram of heroin that you could pay for right away how much of those heroin have you paid for ” SANCHEZ replied “I paid it right away ” 49 Based on the above-described BBM communications I believe that on March 19 2014 VEGA’s narcotics couriers delivered one kilogram of heroin to SANCHEZ who paid for the heroin on March 20 2014 MARTINEZ further requested that VEGA provide SANCHEZ with an additional one kilogram of narcotics on March 21 2014 since SANCHEZ was prompt with his previous payment to VEGA SANCHEZ confirmed that he had already paid VEGA for the one kilogram of heroin he received on March 19 2014 and that he planned to pay 26 for the additional one kilogram of heroin that he received from the VEGA DTO prior to March 19 2014 SANCHEZ also indicated that VEGA’s couriers provided him with an additional one kilogram of heroin on March 21 2014 On March 25 2014 MARTINEZ Directed SANCHEZ to Deliver Narcotics Proceeds to Individual A 50 On March 24 2014 at approximately 2 33 p m Session #4038183 MARTINEZ using Target Device 1 had a BBM conversation with VEGA who was using Vega Device 2 In that conversation VEGA stated “Look tell your guy Individual A to get a move on with the truck thing ” VEGA further stated “I need it the one vehicle with hidden compartments that fits various various amounts of drugs and drug proceeds Call him Individual A ” 51 On March 25 2014 at approximately 3 15 p m Session #4042527 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation SANCHEZ asked “When are you going to send your relative a drug courier for the paper to pick up narcotics proceeds ” MARTINEZ replied “Cousin would you do me the favor of giving it narcotics proceeds to the guy who lives in the same place as you My buddy the mechanic Individual A there Do me a favor if you can please ” SANCHEZ replied “Okay send me his number ” MARTINEZ stated “Okay thank you 7 7 3 7 9 1 3 5 9 4 Tell him Individual A it’s on behalf of the primo ” SANCHEZ responded “I will bring it the narcotics proceeds to him Individual A tomorrow I did not bring my car I will have it deliver the narcotics proceeds to Individual A tomorrow That way there’s no problem since as you know my neighborhood is 27 full of police ” MARTINEZ stated “Thank you Be careful He Individual A is a mechanic have him open your glove box receive it the narcotics proceeds so we don’t look bad You know how things are done ” 52 On March 27 2014 at approximately 7 25 p m Session #4052368 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation SANCHEZ stated “I have already given the paper narcotics proceeds to your buddy Individual A ” 53 On March 28 2014 LEOs reviewed the surveillance footage from the pole camera installed at 2337 N Monitor Ave Chicago Illinois In the surveillance footage from March 27 2014 at approximately 7 21 p m a Jeep Wrangler bearing Illinois license 80028FF and registered to ROBERTO SANCHEZ the “Jeep” arrived in the alley adjacent to the garage associated with 2337 N Monitor Avenue SANCHEZ exited the Jeep opened the hood and walked around to the front passenger side of the vehicle Shortly thereafter Individual A came out of the residence at 2337 N Monitor Avenue and met with SANCHEZ near the front passenger side of the Jeep by the vehicle’s hood 54 Based on the above-described intercepted BBM communications and physical surveillance I believe that VEGA directed MARTINEZ to obtain a vehicle with hidden compartments so the VEGA DTO could transport drugs and drug proceeds MARTINEZ reached out to SANCHEZ and requested that SANCHEZ deliver narcotics proceeds owed to MARTINEZ to Individual A as payment to Individual A for building a truck with hidden compartments for MARTINEZ and 28 VEGA MARTINEZ further instructed SANCHEZ to have Individual A appear to inspect SANCHEZ’s car so the transaction would not look suspicious SANCHEZ and Individual A then met and Individual A took the narcotics proceeds from SANCHEZ On April 4 2014 SANCHEZ Received Heroin from the VEGA DTO and MARTINEZ Directed SANCHEZ to Deliver $5 000 of Narcotics Proceeds to Individual A 55 On April 4 2014 at approximately 12 19 p m Session #4087453 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation SANCHEZ stated “I have the check money for narcotics now ” 56 Continuing on April 4 2014 at approximately 12 40 p m Session #4087686 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 MARTINEZ stated “Okay cousin Could you take out just five $5 000 please ” SANCHEZ replied “I am going to take out the 1 500 $1 500 that you owe me ” 57 Continuing on April 4 2014 at approximately 12 42 p m Session #4087783 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 MARTINEZ stated “Okay cousin ” SANCHEZ stated “Because I need to by buy some engines narcotics and I don’t have enough ” MARTINEZ replied “Yeah cousin that’s fine ” 58 Continuing on April 4 2014 at approximately 1 20 p m Session #4087924 MARTINEZ using Target Device 1 had a BBM conversation with 29 SANCHEZ who was using Target Device 3 In that conversation SANCHEZ stated “I’ve been taken care of again received narcotics from VEGA DTO ” 59 Continuing on April 4 2014 at approximately 4 39 p m Session #4089302 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation MARTINEZ asked “Cousin are you handing in the check paying for heroin today or did they VEGA’s couriers only give you work heroin ” SANCHEZ replied “They VEGA’s couriers are going to come by tomorrow but I have it money for the heroin And they VEGA’s couriers took care of me provided heroin as well ” MARTINEZ stated “Okay don’t forget to take out the five $5 000 of narcotics proceeds cousin Please if you can do me the favor ” SANCHEZ replied “Okay cousin you got it Should I give it $5 000 of narcotics proceeds to the same guy Individual A ” MARTINEZ responded “If you can do me a huge favor I would appreciate it When are you going to give it $5 000 of narcotics proceeds to my buddy Individual A cousin ” SANCHEZ stated “Tomorrow afternoon ” 60 Continuing on April 6 2014 at approximately 4 12 p m Session #4102413 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 SANCHEZ stated “Tomorrow I will leave it $5 000 of narcotics proceeds with your friend Individual A what you ordered me to do ” 61 Continuing on April 7 2014 at approximately 7 01 p m Session #4110477 MARTINEZ using Target Device 1 had a BBM conversation with 30 SANCHEZ who was using Target Device 3 SANCHEZ stated “I dropped the order $5 000 of narcotics proceeds off with your buddy already ” 62 Pole camera surveillance footage of 2337 N Monitor Avenue Chicago Illinois showed that on April 7 2014 at approximately 6 54 p m the Jeep arrived in the alley next to the garage of 2337 N Monitor Avenue Chicago Illinois Individual A exited the gate of the residence and walked up to the front passenger side door of the Jeep The front passenger side door of the vehicle opened and closed and Individual A returned inside the gate of the residence The Jeep then left the area 63 Based on the above-described intercepted BBM communications and physical surveillance I believe that SANCHEZ indicated that he had money to pay MARTINEZ for heroin and that he also received a quantity of narcotics from the VEGA DTO MARTINEZ requested that SANCHEZ take $5 000 out of the drug proceeds owed to MARTINEZ and deliver the money to Individual A as payment to Individual A for building a truck with hidden compartments for MARTINEZ and VEGA SANCHEZ then delivered MARTINEZ’s narcotics proceeds to Individual A On April 4 2014 MARTINEZ Directed SANCHEZ to Deliver $20 000 in Narcotics Proceeds to VEGA’s Nephew 64 On April 4 2014 at approximately 4 56 p m Session #4089412 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 MARTINEZ stated “Cousin check it the heroin out properly before you open it cousin so you can see what it actually is Cousin don’t take it the wrong way Only if they the heroin are short then let the guy VEGA’s 31 courier see that they the heroin are short okay And the doves cocaine are on their way cousin You’ll have it from two sides cocaine and heroin with me It’s from the same company the GUDTO only you know that they the GUDTO only bring up two by three 23 kilograms of narcotics ” SANCHEZ replied “The thing is they the narcotics lose weight when you take them out of the box They come kind of fresh it lowers when it the narcotics dries ” 65 Continuing on April 4 2014 at approximately 5 04 p m Session #4089467 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation MARTINEZ stated “Exactly so tell your guy VEGA’s courier so they the GUDTO won’t get upset over here with me Look you know I don’t get upset anyway you know it cousin when I give you the white kind the cocaine ” SANCHEZ responded “Ninja VEGA 27 already took it down decreased the price of the cocaine for me ” MARTINEZ stated “I am here with him VEGA cousin He VEGA is asking that you give us a hand and when the doves cocaine arrive he VEGA won’t let you down cousin Okay ” MARTINEZ further stated “Cousin could I send a guy to pick up twenty $20 000 over there with Individual E 28 It’s just to pick up only ” SANCHEZ asked “Who is it The same guy who picks up That way he could take all of it at once ” MARTINEZ responded “The thing is it is a guy who is going to pay some money from the company over here the $20 000 is for an individual associated with the GUDTO in Mexico who is going to purchase narcotics with the 27 VEGA’s previous Blackberry screen names included “Ninja ” 28 According to CS-1 Individual E is a mutual friend of CS-1 and SANCHEZ’s 32 money and also make a separate narcotics payment to the GUDTO in Mexico ” SANCHEZ replied “Twenty big ones $20 000 ” MARTINEZ stated “Yeah cousin ” SANCHEZ responded “Okay what time will he come by ” MARTINEZ stated “Well look I am going to call him right now ” 66 Continuing on April 4 2014 at approximately 5 18 p m Session #4089588 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation MARTINEZ stated “He’s the nephew of Ninja the individual who will pick up the $20 000 from Individual E is VEGA’s nephew He says he’ll arrive in an hour so he won’t let you down ” SANCHEZ stated “Let me know so I can let Individual E know He Individual E lives in back now ” MARTINEZ replied “I’ll have him VEGA’s nephew courier go behind the cermack Cermack ”29 SANCHEZ stated “Yes that’s fine The code for him VEGA’s nephew courier to ask for Porfirio ” 67 Based on the above-described intercepted BBM communications I believe that MARTINEZ directed SANCHEZ to check the amount of heroin that SANCHEZ received from the VEGA DTO MARTINEZ also indicated that he would supply SANCHEZ with heroin and cocaine MARTINEZ then requested that SANCHEZ arrange for Individual E to deliver $20 000 of narcotics proceeds owed The garage associated with Individual E’s residence at 4221 N Sawyer Avenue Chicago Illinois is adjacent to a store called Cermack Produce Based on the intercepted BBM communications between MARTINEZ and SANCHEZ I believe that VEGA’s courier planned to wait near or in Cermack Produce for Individual E to deliver the $20 000 of narcotics proceeds 29 33 by SANCHEZ to MARTINEZ to VEGA’s nephew so that MARTINEZ’s narcotics associate in Mexico could use the money to obtain narcotics in Mexico Between April 9 2014 and April 17 2014 SANCHEZ Received Narcotics from the VEGA DTO 68 On April 9 2014 at approximately 7 07 p m Session #4125226 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation SANCHEZ stated “They VEGA’s narcotics couriers took care of me ” MARTINEZ replied “Okay cousin be careful ” 69 Continuing on April 17 2014 at approximately 8 16 p m Session #4181362 MARTINEZ using Target Device 1 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation MARTINEZ stated “Cousin I went to bring some things What’s up ” SANCHEZ replied “I already handed in the check paid for narcotics and they VEGA’s narcotics couriers took care of again provided SANCHEZ with narcotics ” MARTINEZ stated “Okay all set cousin We’ll be in touch ” 70 Continuing on April 17 2014 at approximately 8 18 p m Session #4181363 MARTINEZ using Target Device 1 had a BBM conversation with VEGA who BBM PIN 2823BC76 “Target Device 2” 30 MARTINEZ stated “Cousin my guy SANCHEZ delivered paid for narcotics received from the VEGA DTO ” The identification of VEGA as the user of Target Device 2 is based on the content of intercepted BBM conversations over Target Device 1 common call analysis between VEGA’s previous BBM PIN Vega Device 2 and Target Device 2 and the fact that Target Device 2 had the same Blackberry screen name – “Comando” – that was used for Vega Device 2 30 34 71 Based on the above-described intercepted BBM communications I believe that SANCHEZ informed MARTINEZ that he was provided narcotics by VEGA’s narcotics couriers and that he also paid VEGA’s couriers for the narcotics he received B In April 2014 VEGA and MARTINEZ Directed Couriers FIGUEROA BETANCOURT and FLORES-SANTOS to Pick Up Narcotics Proceeds from Various Individuals On April 16 2014 FIGUEROA and BETANCOURT Delivered Narcotics Proceeds to and Picked Up a Vehicle with Hidden Compartments from Individual A 72 On April 15 2014 at approximately 10 54 a m Session #4165891 MARTINEZ using Target Device 1 had a BBM conversation with FIGUEROA who was using BBM PIN 334E508A “Figueroa Device 2” 31 In that conversation MARTINEZ asked “Did you go and bring the truck yet because my friend Individual A needs the space in his garage ” FIGUEROA replied “Yo but tomorrow Today is a day off ” MARTINEZ stated “7 7 3 7 9 1 3 5 9 4 That is my friend’s Individual A’s number Tell him you are going on behalf of the cousin and 200 dollars are owed ” FIGUEROA replied “Okay ” MARTINEZ further stated “He Individual A is only owed 200 $200 okay ” The identification of FIGUEROA as the user of Figueroa Device 2 is based on the following a pen register data and consensually recorded BBM conversations between CS1 and MARTINEZ which led LEOs to determine that FIGUEROA’s previous BBM PIN was 334B7A49 “Figueroa Device 1” b Figueroa Device 1 which had the BBM screen name “Maddog ” was intercepted over Target Device 1 used by MARTINEZ and c Figueroa Device 2 had the same screen name “Maddog ” 31 35 73 Continuing on April 16 2014 at approximately 10 39 a m Session #4172148 MARTINEZ using Target Device 1 had a BBM conversation with FIGUEROA who was using BBM PIN 334E508A MARTINEZ asked “What’s happening ” In that conversation FIGUEROA replied “Your friend Individual A is asking if you can call him ” MARTINEZ stated “Okay are you with him right now FIGUEROA responded “No ” MARTINEZ further stated “Are you going to go get the truck ” FIGUEROA replied “I want to go but they won’t tell where it is Do you know ” Individual A right now ” MARTINEZ stated “Okay I’ll call him MARTINEZ later stated “Don’t forget to give him Individual 200 dollars okay my friend ” FIGUEROA replied “Okay sure ” MARTINEZ stated “I already called Okay it’s on fulerton Fullerton and minitor Monitor ” 74 Pole camera surveillance footage of 2337 N Monitor Avenue Chicago Illinois showed that on April 16 2014 at approximately 4 48 p m an Acura sports utility vehicle bearing Illinois license V331444 the “Acura SUV” arrived by the garage associated with 2337 N Monitor Avenue 32 FIGUEROA exited the driver’s side of the Acura SUV and walked inside the garage At approximately 5 03 p m FIGUEROA exited the garage entered the Acura SUV and departed the location At approximately 5 18 p m a red Chrysler Pacifica the “Chrysler Pacifica” came According to Illinois Secretary of State records in April 2014 the Acura SUV was registered to ELISEO BETANCOURT 1010 Trask Street Aurora Illinois The Acura SUV currently has Illinois license E246944 and is registered to Individual H 641 Grand Avenue Aurora Illinois Other than BETANCOURT and Individual H the Acura SUV had two prior registered owners – FIGUEROA at 641 Grand Avenue Aurora Illinois and Individual K at 803 Magnolia Drive North Aurora Illinois 32 36 out of the garage at 2337 N Monitor Avenue 33 Individual A exited the Chrysler Pacifica and re-entered the garage At approximately 5 40 p m FIGUEROA walked toward the garage carrying a white plastic bag in his hand FIGUEROA was with BETANCOURT 34 Both FIGUEROA and BETANCOURT then entered the garage A few minutes later Individual A put a license plate on the rear of the Chrysler Pacifica At approximately 5 48 p m BETANCOURT and FIGUEROA entered the Chrysler Pacifica and traveled away from the location 75 Based on the above-described intercepted BBM communications and physical surveillance I believe that FIGUEROA at MARTINEZ’s direction delivered $200 of narcotics proceeds to Individual A FIGUEROA and BETANCOURT also picked up the Chrysler Pacifica which LEOs later determined was outfitted with hidden compartments On April 26 2014 VEGA Directed FIGUEROA to Pick Up $323 000 in Narcotic Proceeds from FNU LNU a k a “Alan ” 76 On April 26 2014 at approximately 3 22 p m Session #4233673 VEGA using Target Device 2 had a BBM conversation with BBM PIN 334B22ED believed to be used by FIGUEROA “Figueroa Device 3” 35 During that As detailed further below in paragraph 164 LEOs observed a hidden compartment within this Chrysler Pacifica In addition as further described below in paragraph 225 LEOs approached Individual C on June 10 2014 and found approximately 31 kilograms of heroin in the Chrysler Pacifica that Individual C was driving 33 On September 26 2014 LEOs identified BETANCOURT pursuant to a traffic stop of BETANCOURT who was identified by his Wisconsin driver’s license 34 The identification of FIGUEROA as the user of Figueroa Device 3 is based on the following a FIGUEROA was identified as the user of Figueroa Device 2 based on pen register data consensually recorded BBM conversations between CS-1 and MARTINEZ and a common call analysis between Figueroa Device 2 and Figueroa Device 1 and b Figueroa Device 2 had the same screen name “MADDOG ” as Figueroa Device 1 Pen 35 37 conversation VEGA asked “Did you go pick up narcotics proceeds with Paisa SANCHEZ yet ”36 FIGUEROA replied “No ” VEGA stated “Okay Go pick up M’s Individual F’s narcotics proceeds so they the money can be turned in ” FIGUEROA replied “Okay Can you give me the number for M’s ” VEGA responded “Okay ” 77 On April 26 2014 at approximately 3 59 p m Session #4233944 VEGA using Target Device 2 had a BBM conversation with Blackberry PIN 2A75C94C believed to be used by Individual F 37 In that conversation Individual F stated “7 0 8 5 0 1 2 1 4 9 He FIGUEROA should ask for Alan this one narcotics proceeds is ready ” VEGA replied “Okay ” 78 On April 26 2014 at approximately 4 01 p m Session #4233945 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 In that conversation VEGA stated “7 0 8 5 0 1 2 1 4 9 Ask for Alan He is ready ” FIGUEROA replied “Okay ” register data for Figueroa Device 2 showed no activity on Figueroa Device 2 after April 26 2014 However on that same day Figueroa Device 3 with the screen name of “MADDOG” was intercepted over Target Device 2 According to CS-1 “Paisa” is one of the Blackberry screen names for SANCHEZ Furthermore in intercepted BBM conversations over Target Device 1 and Target Device 2 MARTINEZ and VEGA refer to SANCHEZ as “Paisa ” 36 Based on information from Mexican law enforcement the DEA in Mexico City Mexico and court-authorized interceptions of Blackberry PINs used by VEGA and Individual F LEOs determined that Individual F was the leader of the GUDTO in Mexico On or about April 29 2014 Individual F was arrested in Mexico by Mexican law enforcement and military authorities Based on the intercepted communication described in paragraph 76 above where VEGA refers to “M’s” narcotics proceeds I believe that VEGA was referring to Individual F whose first name begins with the letter “M ” 37 38 79 Continuing on April 26 2014 at approximately 6 06 p m Session #4234570 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 During that conversation FIGUEROA stated “Okay finished with Alan It’s 323 $323 000 I’m heading over to Paisa SANCHEZ now ” VEGA replied “Let me know when you guys are at the warehouse ” 80 Pole camera surveillance footage showed that on April 27 2014 at approximately 6 55 a m FIGUEROA left his residence at 641 Grand Avenue Aurora Illinois in a silver Acura the “silver Acura” Based on intercepted conversations over Target Device 2 and location information for a telephone used by FIGUEROA 38 LEOs subsequently established surveillance at 850 Ridgeway Avenue Aurora Illinois at approximately 7 30 a m where they observed FIGUEROA and WILFREDO FLORES-SANTOS at a warehouse at that location 39 81 Based on the above-described intercepted BBM communications and surveillance I believe that FIGUEROA and FLORES-SANTOS took the $323 000 of narcotics proceeds that FIGUEROA previously picked up from FNU LNU a k a This telephone number was 331 454-4728 which was the telephone number associated with Figueroa Device 2 38 The identification of FLORES-SANTOS is based on the following On February 18 2014 LEOs conducted a traffic stop of FIGUEROA and another male individual Pursuant to a consent search of the vehicle LEOs found what appeared to be used vacuum-sealed bags in the shape of rectangular bricks that contained a white powdery residue LEOs determined that there was an odor of cocaine emitting from the bags The male individual in the vehicle with FIGUEROA identified himself during the traffic stop as WILFREDO FLORES-SANTOS Based on a surveillance photograph of this male individual from the traffic stop LEOs determined that the male individual observed with FIGUEROA at the warehouse at 850 Ridgeway Avenue Aurora Illinois on April 27 2014 was the same person who was with FIGUEROA during the traffic stop conducted on February 18 2014 39 39 “Alan ” to the warehouse at 850 Ridgeway Avenue Aurora Illinois “Warehouse 1” As described further below based on physical surveillance prior interceptions of BBM communications over Target Device 4 used by VEGA and telephone location information for Target Device 7 used by FIGUEROA LEOs determined that commercial passenger buses containing narcotics arrive at Warehouse 1 and another warehouse located at 496 S River Street Batavia Illinois “Warehouse 2” where FIGUEROA FLORES-SANTOS BETANCOURT and others unload narcotics off the buses and load them into vehicles some of which have concealed compartments as well as store narcotics and narcotics proceeds On April 27 2014 VEGA Directed FIGUEROA to Pick Up $47 700 in Narcotics Proceeds from SANCHEZ 82 On April 26 2014 at approximately 7 10 p m Session #4235937 VEGA using Target Device 2 had a BBM conversation with SANCHEZ who was using Target Device 3 In that conversation VEGA stated “Cousin the guy FIGUEROA got busy but he can go pick up narcotics proceeds from you tomorrow ” SANCHEZ replied “Okay it’s set I may have the other paper for him by Tuesday ” 83 On April 27 2014 at approximately 11 19 p m Session #4239760 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 In that conversation VEGA stated “Alex when you’re finished go to Paisa SANCHEZ ” FIGUEROA replied “Okay ” 84 On April 27 2014 at approximately 1 24 p m Session #4240251 SANCHEZ using Target Device 3 had a BBM conversation with FIGUEROA who 40 was using Figueroa Device 3 SANCHEZ asked “You coming ” FIGUEROA replied “Yeah like in 30 30 minutes I’ll be there ” SANCHEZ stated “Okay ” 85 Pole camera surveillance footage of Individual E’s residence at 4221 N Sawyer Avenue Chicago Illinois on April 27 2014 at approximately 1 46 p m showed SANCHEZ by the rear garage of the residence typing on a Blackberry device At approximately 1 58 p m Individual E opened the door to the garage SANCHEZ and Individual E entered the garage and both came out shortly thereafter At approximately 2 06 p m FIGUEROA driving the Acura SUV parked the vehicle in front of the door of the main garage of the residence FIGUEROA walked in the direction of the side door of the garage Approximately six minutes later FIGUEROA and SANCHEZ exited the garage and engaged in conversation 86 On April 27 2014 at approximately 2 13 p m Session #4240493 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 During that conversation VEGA stated “8 7 2 2 1 4 5 4 7 7 Ask for superman … give him all of them a quantity of narcotics ” FIGUEROA replied “Okay ” VEGA then asked “Did you already with Paisa SANCHEZ ” FIGUEROA replied “I’m right here ” 87 Continuing on April 27 2014 at approximately 2 23 p m Session #4240500 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 FIGUEROA stated “I already picked up from Paisa SANCHEZ there are 47700 $47 700 in narcotics proceeds ” 41 VEGA replied “Okay Look send me the list of whatever you sent me last week list of narcotics proceeds that FIGUEROA previously picked up and sent to VEGA ” FIGUEROA stated “Okay I’ll send it the list of proceeds to you when I get home ” 88 Based on the above-described intercepted BBM communications and physical surveillance I believe that VEGA directed FIGUEROA to pick up narcotics proceeds from SANCHEZ as payment for narcotics that SANCHEZ previously received from the VEGA DTO FIGUEROA met SANCHEZ who was with Individual E and picked up $47 700 from SANCHEZ VEGA also passed the telephone number of an individual named “superman” and directed FIGUEROA to contact this individual to deliver narcotics C On April 26 2014 SANCHEZ Received One Kilogram of Heroin from the VEGA DTO which SANCHEZ Intended to Sell to His Customer MANDUJANO 89 On April 25 2014 at approximately 3 33 p m Session #4225993 SANCHEZ using Target Device 3 had a BBM conversation with VEGA who was using Target Device 2 SANCHEZ stated “I have the tickets money for heroin Can you send the guy a courier ” VEGA replied “It’s set ” 90 On April 25 2014 at approximately 3 38 p m Session #4225994 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 2 In that conversation VEGA asked “Can you go to Paisa SANCHEZ and pick something narcotics proceeds up ” 91 Continuing on April 25 2014 at approximately 3 40 p m Session #4226133 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 2 In that conversation FIGUEROA 42 stated “Yes ” VEGA stated “Okay Don’t put them on load narcotics proceeds onto the bus until we gather more additional proceeds from VEGA’s narcotics customers ” FIGUEROA replied “But the guys other narcotics customers are going to come for the work narcotics already right now ” VEGA stated “Call maddonals FNU LNU a k a “MCDONAL” ” FIGUEROA responded “And I have to go and fix the alternator ” VEGA stated “First go and fix the alternator and then you go pick up narcotics proceeds from SANCHEZ ” FIGUEROA replied “Okay ” 92 On April 25 2014 at approximately 3 41 p m Session #4226135 SANCHEZ using Target Device 3 had a BBM conversation with VEGA who was using Target Device 2 In that conversation SANCHEZ stated “Let me know what time they’ll VEGA’s narcotics couriers take care of me provide heroin ” VEGA replied “I already told macdog FIGUEROA to go and pick up the narcotics proceeds from SANCHEZ SANCHEZ then asked “He’s FIGUEROA’s going to take care of provide heroin to me too ” VEGA replied “Yes buddy Like always ” SANCHEZ responded “Okay it’s set ” 93 On April 25 2014 at approximately 3 43 p m Session #4226136 VEGA using Target Device 2 had a BBM conversation with FNU LNU a k a “MCDONAL ” VEGA’s narcotics courier who was using BBM PIN 334B3370 40 VEGA asked “Buddy can you please give one one kilogram of heroin to paisa SANCHEZ ” MCDONAL replied “Okay Of the 9 nine kilograms of heroin from the ones heroin that just arrived From the ones heroin that arrived 2 of them 40 “MCDONAL” is the Blackberry screen name for the user of BBM PIN 334B3370 43 two kilograms of heroin are a little better ” VEGA stated “Yes first those one kilogram of heroin to SANCHEZ and then the rest So we don’t get the accounts mixed up ” MCDONAL replied “Okay ” 94 On April 25 2014 at approximately 9 10 p m Session #4230270 SANCHEZ using Target Device 3 had a BBM conversation with VEGA who was using Target Device 2 In that conversation SANCHEZ stated “They VEGA’s narcotics couriers didn’t take care provide heroin of me They said until tomorrow ” SANCHEZ further stated “I’ll let you know when they take care of me ” VEGA replied “Okay alright then ” 95 On April 25 2014 at approximately 9 28 p m Session #4230375 SANCHEZ using Target Device 3 had a BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 SANCHEZ stated “If it can be done earlier that would be better ” MCDONAL replied “That’s what I’m going to try to do ” SANCHEZ stated “Please do that for me ” MCDONAL responded “We’ll be in contact ” 96 Continuing on April 25 2014 at approximately 10 00 p m Session #4230530 SANCHEZ using Target Device 3 had another BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 MCDONAL stated “Buddy he MCDONAL’s narcotics courier answered me already He gets off work at 12 30 He says he will try to be there at 1 00 or a little after What do you think ” SANCHEZ replied “Earlier if he can Please ” MCDONAL stated 44 “Yes I told him that they will pick up the paper narcotics proceeds at 1 00 but he says he doesn’t want to lie He will try for the earliest as possible ” 97 Continuing on April 25 2014 at approximately 10 04 p m Session #4230645 SANCHEZ using Target Device 3 had another BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 SANCHEZ stated “I don’t want them to take the paper narcotics proceeds ” MCDONAL replied “Call your guy SANCHEZ’s narcotics customer Have him wait until 2 00 so he can give us a chance ” SANCHEZ asked “Why don’t you send the individual MCDONAL’s narcotics courier who took care of me last time ” MCDONAL responded “He is not here ” SANCHEZ asked “It’s the one who is coming for the paper narcotics proceeds ” MCDONAL stated “Oh it’s because he MCDONAL’s narcotics courier dedicates himself completely to the paper narcotics proceeds that’s why ” SANCHEZ requested “Try early I don’t want to lose it referring to losing SANCHEZ’s narcotics customer It’s not a good time right now to let go of people who bring paper narcotics customers who pay in advance for narcotics as you know ” MCDONAL responded “Yes I’m going to hurry him ” SANCHEZ replied “Okay do that for me Thank you ” 98 On April 26 2014 at approximately 11 05 a m Session #4232440 SANCHEZ who was using Target Device 3 had a BBM conversation with ISAIAS MANDUJANO SANCHEZ’s wholesale narcotics customer who was using BBM 45 PIN 334DE74C 41 In that conversation MANDUJANO asked “What’s going on Paisa Were you going to take a trip this way ” 99 Continuing on April 26 2014 at approximately 11 39 a m Session #4232535 SANCHEZ using Target Device 3 had a BBM conversation with MANDUJANO who was using BBM PIN 334DE74C SANCHEZ replied “Yes later on ” 100 On April 26 2014 at approximately 12 41 p m Session #4232825 SANCHEZ using Target Device 3 had a BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 SANCHEZ asked “What happened is he MCDONAL’s narcotics courier coming before 1 00 My buddy MANDUJANO is calling me What do I tell him to pick up the money or is the guy MCDONAL’s narcotics courier going to arrive ” MCDONAL replied “I am checking on it ” SANCHEZ stated “Let me know if not so that he MANDUJANO can leave please ” 101 Continuing on April 26 2014 at approximately 2 30 p m Session #4233400 SANCHEZ using Target Device 3 had another BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 SANCHEZ stated “They MCDONAL’s narcotics couriers arrived already to deliver narcotics to SANCHEZ ” MCDONAL replied “Alright and I apologize ” SANCHEZ stated The identification of MANDUJANO as the user of BBM PIN 334DE74C is based on the following a as described further below in paragraphs 106-108 the user of BBM PIN 334DE74C arranged a meeting with SANCHEZ on April 27 2014 and LEOs conducting surveillance of the meeting subsequently saw a male individual with SANCHEZ and b LEOs compared an Illinois driver’s license photograph of MANDUJANO to the male individual observed during the surveillance and determined it was the same person 41 46 “Don’t think I like bothering you I did not want to let my buddy MANDUJANO down ” 102 Based on the above-described intercepted BBM communications I believe that VEGA arranged for FIGUEROA to pick up narcotics proceeds from SANCHEZ which was payment for narcotics SANCHEZ previously received from the VEGA DTO VEGA also instructed FNU LNU a k a “MCDONAL ” to deliver one kilogram of heroin to SANCHEZ so that SANCHEZ could sell the heroin to his customer MANDUJANO 42 On April 27 2014 MANDUJANO Received One Kilogram of Heroin from SANCHEZ that SANCHEZ Received from the VEGA DTO 103 On April 26 2014 at approximately 5 46 p m Session #4234469 SANCHEZ using Target Device 3 had a BBM conversation with MANDUJANO who was using BBM PIN 334DE74C SANCHEZ asked “Can you come get it heroin yourself ” MANDUJANO replied “What time Where do I go ” 104 Continuing on April 26 2014 at approximately 5 59 p m Session #4234469 SANCHEZ using Target Device 3 had another BBM conversation with MANDUJANO who was using BBM PIN 334DE74C SANCHEZ stated “By Motros Montrose and Kedzie early in the morning ” MANDUJANO asked “Do you want me to go today or tomorrow ” SANCHEZ responded “I am going out with the lady in a little bit early tomorrow and I have it heroin over there where I told you ” As described further below in paragraph 106 SANCHEZ informed MANDUJANO that he had one kilogram of heroin available 42 47 105 On April 26 2014 at approximately 7 13 p m Session #4235934 SANCHEZ using Target Device 3 had a BBM conversation with MARTINEZ who was using BBM PIN 2A7D79FC 43 In that conversation SANCHEZ stated “I was already taken care of provided with narcotics today ” MARTINEZ replied “Okay cousin we will be in touch ” 106 On April 26 2014 at approximately 7 37 p m Session #4236087 SANCHEZ using Target Device 3 had a BBM conversation with MANDUJANO who was using BBM PIN 334DE74C In that conversation MANDUJANO stated “III requesting three kilograms of heroin ” kilogram of heroin ” SANCHEZ replied “Only 1 one MANDUJANO then asked “What time do I stop by you tomorrow ” SANCHEZ replied “Early let me know an hour b4 before u get so I can b ready ” 107 Continuing on April 27 2014 at approximately 2 19 p m Session #4240489 SANCHEZ using Target Device 3 had a BBM conversation ith MANDUJANO who was using BBM PIN 334DE74C MANDUJANO stated “I am by Kedzie ” SANCHEZ replied “Kedzie and what other one Ketzie Kedzie and Cullon at the auto parts ” 108 On April 27 2014 at approximately 2 23 p m LEOs observed SANCHEZ exit the side door of the garage at 4221 N Sawyer Avenue Chicago The identification of MARTINEZ as the user of BBM PIN 2A7D79FC is based on the following a a common contact analysis between Target Device 1 used by MARTINEZ and BBM PIN 2A7D79FC and b use of the Blackberry screen name “Apaxtla ” which is the same screen name MARTINEZ used while using Target Device 1 43 48 Illinois 44 SANCHEZ was holding a cellular telephone to his ear Approximately two minutes later SANCHEZ entered the rear gate of the residence with MANDUJANO Both individuals then entered the side door of the garage of the residence and exited the garage shortly thereafter At approximately 2 46 p m LEOs observed Individual E walk out of the main garage door and into the alley carrying a white plastic bag Shortly thereafter LEOs observed Individual E return inside the garage empty-handed 109 Continuing on April 27 2014 at approximately 5 23 p m Session #4241380 SANCHEZ using Target Device 3 had a BBM conversation ith MANDUJANO who was using BBM PIN 334DE74C MANDUJANO stated “I arrived already In the conversation I am just waiting for him MANDUJANO’s narcotics customer to come and I will let you know either yes or no whether the customer likes the heroin that MANDUJANO received from SANCHEZ ” 110 Based on the above-described intercepted BBM communications and physical surveillance I believe that after SANCHEZ obtained the heroin from the VEGA DTO SANCHEZ went to Individual E’s residence where Individual E at SANCHEZ’s direction met MANDUJANO and provided MANDUJANO with one kilogram of heroin 4221 N Sawyer Avenue is located approximately one-half block south of W Cullom Avenue Chicago Illinois and near an Auto Zone store 44 49 D On April 28 2014 SANCHEZ Arranged for Individual E to Receive One Kilogram of Heroin from the VEGA DTO which SANCHEZ Provided to His Customer MANDUJANO On April 28 2014 VEGA Arranged for His Courier FNU LNU a k a “MCDONAL ” to Deliver One Kilogram of Heroin to SANCHEZ 111 On April 27 2014 at approximately 9 45 p m Session #4244031 SANCHEZ using Target Device 3 had a BBM conversation ith MANDUJANO who was using BBM PIN 334DE74C In that conversation MANDUJANO stated “The buddy MANDUJANO’s narcotics customer says yes but he will not give me the check money for narcotics until tomorrow Let’s see if I get a chance to go pick up additional narcotics from SANCHEZ tomorrow if not I will go Tuesday ” 112 On April 28 2014 at approximately 9 41 a m Session #4245915 SANCHEZ using Target Device 3 had a BBM conversation with VEGA who was using Target Device 2 In that conversation SANCHEZ stated “Do you remember the guy MANDUJANO that was asking for the photo heroin … He is offering 20 bucks $20 000 now and the rest in 15 days What do you think ” VEGA replied “If he likes it the heroin give it to him ” SANCHEZ stated “Okay once he MANDUJANO calls me to tell me that he is coming I will let you know so I can be taken care of provided with heroin ” VEGA responded “Okay alright it’s set ” 113 On April 28 2014 at approximately 11 55 a m Session #4246545 SANCHEZ using Target Device 3 had a BBM conversation ith MANDUJANO who was using BBM PIN 334DE74C In that conversation MANDUJANO asked “Hey ” SANCHEZ replied “Are you coming today or tomorrow ” MANDUJANO stated “I think you will not work until tomorrow ” SANCHEZ responded “I don’t think so 50 it’s going to rain Let me know once you have the paper money for narcotics so I can put the order in order narcotics from the VEGA DTO ” MANDUJANO replied “Alright I might as well bring the car with me ” 114 On April 28 2014 at approximately 5 23 p m Session #4248878 SANCHEZ using Target Device 3 had a BBM conversation with VEGA who was using Target Device 2 In that conversation SANCHEZ stated “Send the guy so he VEGA’s courier can take care of me provide SANCHEZ with heroin My friend MANDUJANO the one for the 20 $20 000 called me already ” VEGA replied “Okay ” 115 On April 28 2014 at approximately 5 24 p m Session #4249110 SANCHEZ using Target Device 3 had a BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 In that conversation SANCHEZ asked “What time can you take care of me provide heroin today ” MCDONAL replied “Let me check I have to take care of another 2 provide heroin to two other customers more Hold on ” SANCHEZ stated “But today please because I’m going to meet with my friend MANDUJANO early tomorrow morning The same that you had given me the same amount of heroin previously given to SANCHEZ by MCDONAL ” MCDONAL responded “Let me finish up with those deliveries of narcotics to other customers and then more or less around 7 00 or 8 00 ” 116 On April 28 2014 at approximately 5 30 p m Session #4249235 VEGA using Target Device 2 had a BBM conversation with FNU LNU a k a 51 MCDONAL ” who using BBM PIN 334B3370 In that conversation MCDONAL stated “Paisa SANCHEZ called me ” VEGA replied “Okay but today you’re going to give primo Buddy attend the 1 of 5 deliver one out of the five kilograms of heroin ” MCDONAL stated “We’re on that already I’m waiting on the 1 of 5 What should I do with paisa SANCHEZ yes or no ” VEGA responded “First the 1 of 5 deliver the one out of the five kilograms of heroin to primo first and then paisa SANCHEZ ” MCDONAL stated “Yes that’s set The 1 of 5 is coming it’s just that he SANCHEZ lives a little far ” 117 Pole camera surveillance of 4221 N Sawyer Avenue Chicago Illinois showed that on April 28 2014 at approximately 7 08 p m Individual E exited the side door of the garage empty-handed and walked out of the rear gate of the residence At approximately 7 23 p m a silver vehicle parked behind the gate of the residence Approximately ten minutes later the silver vehicle departed the location and Individual E entered the side door of the garage carrying a darkcolored object in his hand Based on this surveillance and the intercepted BBM communications described above between MCDONAL and SANCHEZ and between VEGA and MCDONAL I believe that the dark-colored object that Individual E was carrying was the heroin provided by MCDONAL who arrived at 4221 N Sawyer Avenue in the silver vehicle 118 On April 28 2014 at approximately 7 34 p m Session #4250966 SANCHEZ using Target Device 3 had a BBM conversation with FNU LNU a k a “MCDONAL ” who was using BBM PIN 334B3370 52 In that conversation MCDONAL asked “Are you already there ” SANCHEZ replied “Yes ” MCDONAL then stated “Alright then we’ll be right there ” 119 On April 28 2014 at approximately 7 36 p m Session #4250977 VEGA using Target Device 2 had a BBM conversation with FNU LNU a k a MCDONAL ” who was using BBM PIN 334B3370 MCDONAL stated “It’s a done deal with Paisa heroin was delivered to SANCHEZ ” VEGA asked “Did you give another one one kilogram of heroin to paisa SANCHEZ ” At approximately 7 45 p m in another intercepted BBM communication with VEGA Session #4250983 MCDONAL replied “Yeah ” 120 On April 28 2014 at approximately 7 51 p m Session #4251106 SANCHEZ using Target Device 3 had a BBM conversation with MARTINEZ who was using BBM PIN 2A7D79FC SANCHEZ stated “I was taken care of again provided with heroin today ” 121 Based on the above-described intercepted BBM communications and physical surveillance I believe that SANCHEZ requested heroin from VEGA who directed MCDONAL to deliver one kilogram of heroin to SANCHEZ The heroin was then delivered to Individual E at 4221 N Sawyer Avenue Chicago Illinois SANCHEZ also informed MARTINEZ that the VEGA DTO had provided him with heroin On April 29 2014 MANDUJANO Received One Kilogram of Heroin from SANCHEZ 122 On April 28 2014 at approximately 7 51 p m Session #4251105 SANCHEZ using Target Device 3 had a BBM conversation with MANDUJANO 53 who was using BBM PIN 334DE74C In that conversation MANDUJANO stated “It’s set ” SANCHEZ asked “What time are you coming ” MANDUJANO replied “Around 9 10 is that okay ” SANCHEZ stated “If you can arrive at 10 it would be better ” MANDUJANO responded “Alright I will let you know when I am on my way ” 123 Continuing on April 29 2014 at approximately 9 41 a m Session #4254383 SANCHEZ using Target Device 3 had a BBM conversation with MANDUJANO who was using BBM PIN 334DE74C MANDUJANO stated “I got off already ” SANCHEZ replied “Okay I am here ” 124 Pole camera surveillance footage at 4221 N Sawyer Avenue Chicago Illinois showed that on April 29 2014 at approximately 9 41 a m LEOs observed SANCHEZ driving a Nissan sedan bearing Illinois license 78389FF park in the parking lot of an Auto Zone store located a block from 4221 N Sawyer 45 SANCHEZ then entered the backyard of 4221 N Sawyer and entered the garage on the premises Approximately four minutes later LEOs observed MANDUJANO driving a silver Lexus bearing Illinois license R66521 park near the garage at 4221 N Sawyer 46 MANDUJANO exited the Lexus and entered the garage with SANCHEZ At approximately 9 51 a m LEOs observed SANCHEZ return to the Nissan parked at the Auto Zone MANDUJANO entered the Lexus and drove the vehicle to the parking lot of the Auto Zone According to Illinois Secretary of State records the Nissan is registered to ROBERTO SANCHEZ 1301 Auburn Court Rockford Illinois 45 According to Illinois Secretary of State records this vehicle is registered to ISAIAS MANDUJANO 2406 New Haven Ct Rockford Illinois 46 54 125 LEOs then observed the Nissan and Lexus travel to a Chase Bank at 3204 W Irving Park Road Chicago Illinois At the parking lot of the bank LEOs observed SANCHEZ hand paperwork to MANDUJANO MANDUJANO and a female individual “Individual G” who was a passenger in the Lexus went to a Western Union across the street At approximately 10 22 a m LEOs observed SANCHEZ enter the Nissan and MANDUJANO and the female individual enter the Lexus Both vehicles then traveled to a residence at 3516 W Irving Park Road Chicago Illinois At that location LEOs observed MANDUJANO drive a white Lincoln bearing Illinois license V321456 out of the backyard of the residence 47 126 LEOs further observed the Lexus and the Nissan travel back to the Auto Zone parking lot MANDUJANO drove the Lincoln to the alley next to the garage of 4221 N Sawyer LEOs observed MANDUJANO exit the Lincoln and meet SANCHEZ by the vehicle SANCHEZ then returned to the garage Shortly thereafter MANDUJANO drove the Lincoln to the parking lot of the Auto Zone The Lincoln and the Lexus driven by Individual G then departed the area traveling in the same direction At approximately 10 54 the Chicago Police Department conducted a traffic stop on the Lexus LEOs observed the Lincoln driven by MANDUJANO continue to travel to a parking lot of the Des Plaines Oasis off the 90 94 interstate highway LEOs further observed that this parking lot was closed due to construction MANDUJANO then entered a 7-11 store at the Oasis while talking on a cellular telephone At approximately 11 18 a m the According to Illinois Secretary of State records the Lincoln is registered to MANDUJANO’s wife Individual G at 809 Corbin Street Rockford Illinois 47 55 Lexus driven by Individual G arrived at the Des Plaines Oasis and MANDUJANO entered the front passenger seat of the vehicle LEOs observed the Lexus travel to 809 Corbin Street Rockford Illinois 48 Meanwhile at the Des Plaines Oasis a narcotics canine alerted several times on the exterior front passenger side area of the Lincoln LEOs subsequently searched the Lincoln and did not find any contraband inside the vehicle According to information obtained from the Illinois State Police on April 30 2014 the Lincoln was towed for being parked in an area with a two-hour parking limit On or about November 20 2014 LEOs learned that the Lincoln was never claimed from the tow yard and was salvaged 127 Based on the above-described intercepted BBM communications and physical surveillance I believe that MANDUJANO picked up one kilogram of heroin from SANCHEZ who received the heroin from the VEGA DTO MANDUJANO received the heroin at the garage at 4221 N Sawyer Avenue Chicago Illinois MANDUJANO then put the heroin in the Lincoln which he drove and later abandoned at the Des Plaines Oasis because he suspected law enforcement detection of his activities when the Lexus driven by Individual G was stopped by LEOs Although LEOs did not recover any contraband from within the Lincoln I believe that MANDUJANO either took the heroin with him when he left the Lincoln at the Des Plaines Oasis or left the heroin in a hidden compartment within the Lincoln which LEOs were unable to find during the search of the vehicle According to law enforcement databases MANDUJANO is associated with 809 Corbin Street Rockford Illinois 48 56 E April 28 2014 Intercepted Communications Between VEGA and Individual F Regarding Heroin that the VEGA DTO was to Deliver to Various Narcotics Customers 128 On April 28 2014 at approximately 11 36 a m Session #4246469 VEGA using Target Device 2 had a BBM conversation with Individual F believed to be the leader of the GUDTO who was using BBM PIN 2A75C94C In that conversation Individual F asked “What’s going on buddy Have they narcotics couriers made that delivery yet ” VEGA replied “No the meeting was scheduled for 1 1 00 Call me on the other number ” 129 Continuing on April 28 2014 at approximately 11 59 a m Session #4246572 VEGA using Target Device 2 had a BBM conversation with Individual F who was using BBM PIN 2A75C94C During that conversation Individual F stated “For the 2 two kilograms of heroin orange 630-215-5581 ” VEGA asked “Who should they ask for ” 130 On April 28 2014 at approximately 12 00 p m Session #4246574 VEGA using Target Device 2 had BBM conversation with FIGUEROA who was using Figueroa Device 3 During this conversation FIGUEROA asked “Are they the heroin all for superman a narcotics customer ” 131 Continuing on April 28 2014 at approximately 12 01 p m Session #4246694 VEGA using Target Device 2 had another BBM conversation with FIGUEROA who was using Figueroa Device 3 During this conversation VEGA stated “Yes except the two 2 kilograms of heroin that have orange tape Those are for someone else ” FIGUEROA replied “Yes but there are more orange ones ” VEGA stated “How many Put Wili WILFREDO FLORES-SANTOS on ” 57 132 On April 28 2014 at approximately 12 03 p m Session #4246697 VEGA using Target Device 2 had a BBM conversation with Individual F who was using BBM PIN 2A75C94C In that conversation VEGA stated “Buddy apparently there are more of the orange ones heroin wrapped with orange tape ” Individual F responded “There are only 2 two kilograms of heroin wrapped with orange tape ” Individual F further stated “If there are more orange ones check for 2 two kilograms of heroin that have an iguana that sticks out it stands out as a bulge on the square ” VEGA asked “Okay there are 7 seven kilograms of heroin Let me check ” Individual F replied “It’s 2 two kilograms of heroin that have a bulge like an iguana There are only 2 two kilograms of heroin like that ” Individual F further stated “And they should ask for Tio ” 133 Based on the above-described intercepted BBM communications I believe that VEGA received multiple kilograms of heroin from Individual F Individual F then gave VEGA the telephone number of a narcotics courier named “Tio ” who was to receive 2 kilograms of that heroin that was wrapped with orange tape and an iguana stamp VEGA then confirmed with FIGUEROA that the rest of the heroin was to be delivered to “superman ” another narcotics customer Based on my training and experience and the experience of other LEOs I know that narcotics suppliers frequently mark their narcotics with a particular label or stamp to identify which narcotics are to be delivered to which of the supplier’s customers 58 F On April 28 2014 at VEGA’s direction FIGUEROA and FLORES-SANTOS Sorted Through the Heroin Received from Individual F and Delivered 26 Kilograms of Heroin to Narcotics Customers 134 As described above in paragraphs 128-129 and 132 after VEGA discussed with Individual F which narcotics were marked for the narcotics courier “Tio” and for another customer called “superman ” VEGA instructed his courier FLORES-SANTOS to determine which kilograms had the iguana stamp because these kilograms needed to be delivered to the narcotics courier “Tio ” On April 28 2014 at approximately 12 05 p m Session #4246698 VEGA using Target Device 2 had BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F 49 During this conversation VEGA asked “Hey how many of the orange ones are there ” FLORES-SANTOS replied “There are seven seven kilograms of heroin wrapped with orange tape ” VEGA stated “The ones with orange tape are there two different ones Send me a picture ” FLORES-SANTOS responded “There are seven with orange tape ” VEGA asked “Are there two different ones Send me a picture of the seven If there are seven of them then look for two 2 kilograms of heroin that have an iguana stamp that sticks out The iguana sticks out ” The identification of FLORES-SANTOS as the user of BBM PIN 334DF84F is based on the following On February 18 2014 LEOs conducted a traffic stop on a vehicle and subsequently identified FLORES-SANTOS as a passenger in that vehicle On May 9 2014 LEOs observed FLORES-SANTOS at two locations in Aurora Illinois and one location in North Aurora Illinois Court-authorized location information obtained for a telephone number assigned to Blackberry PIN 334DF84F showed that the telephone was in the same locations as FLORES-SANTOS 49 59 135 Continuing on April 28 2014 at approximately 12 11 p m Session #4246702 VEGA using Target Device 2 received a BBM message from FLORESSANTOS who was using BBM PIN 334DF84F That message was a photograph of seven rectangular-shaped black objects further wrapped in green cellophane wrapping Each object had an orange area on top of the object Based on my training and experience the shape and packaging of these objects are consistent with the appearance of kilogram quantities of narcotics 136 Continuing on April 28 2014 at approximately 12 14 p m Session #4246773 VEGA using Target Device 2 had BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “Yeah 2 two kilograms of heroin are different their stamp sticks out I can’t see the photo ” FLORES-SANTOS replied “Hold on I’m checking ” “What happened ” VEGA asked FLORES-SANTOS responded “Look there are 8 eight kilograms of heroin with green sticker 12 orange-colored ones 1 that says Nacho and 5 that don’t have a name The iguana is indistinguishable on the orange ones I’m going to have to open them Or tell me what should I do ” VEGA replied “Only the orange ones Check them M Individual F says that the iguana sticks out Hey check the rest to see which ones have the iguana that sticks out ” 137 On April 28 2014 at approximately 12 24 p m Session #4246774 VEGA using Target Device 2 had BBM conversation with FIGUEROA who was using Figueroa Device 3 In that conversation VEGA stated “The 2 orange ones are for 6 3 0 2 1 5 5 5 8 1 Ask for Tio ” FIGUEROA replied “Okay ” 60 138 On April 28 2014 at approximately 1 23 p m Session #4247148 VEGA using Target Device 2 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation FLORES-SANTOS stated “There is only 1 one kilogram of heroin that has the iguana stamp ” 139 Continuing on April 28 2014 at approximately 1 24 p m Session #4247275 VEGA using Target Device 2 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “There should be 2 two kilograms of heroin with the iguana stamp FLORES-SANTOS replied “There is only 1 ” VEGA stated “Check so the hour doesn’t pass The other one one kilogram of heroin with the iguana stamp is probably less noticeable ” FLORES-SANTOS replied “I already checked You are going to get mad but I opened all of them And the guy narcotics customer is already waiting ” VEGA stated “It doesn’t matter just put tape on them so you can deliver the rest ” FLORES-SANTOS stated “Only 1 one kilogram of heroin has it the iguana stamp I’m here with Alex FIGUEROA I already checked all of them ” VEGA responded “Check it’s 2 two kilograms of heroin have the iguana stamp ” VEGA later asked “Is the other guy narcotics customer there yet the one who is picking up at 1 1 00 ” FLORES-SANTOS replied “Yes the guy is waiting for us We already have his truck here with us ” VEGA stated “Okay go ahead Perhaps it doesn’t look much like the other one Okay put Alex FIGUEROA in charge of it the narcotics delivery FLORES-SANTOS responded “Man I opened all of them heroin to see them ” FLORES-SANTOS later asked “Should I get another of the 61 orange ones heroin wrapped with orange tape ” VEGA replied “Yes one that looks similar ” FLORES-SANTOS asked “But weren’t we looking for the iguana but there is only 1 one kilogram of heroin with the iguana stamp ” FLORESSANTOS further stated “Okay but I have the guy narcotics customer from 1 1 00 waiting ” VEGA then stated “Give him the narcotics customer that one one kilogram of heroin with the iguana stamp and another one another kilogram of heroin and deliver the rest Let me know once you have delivered ” FLORESSANTOS replied “Okay ” 140 Based on the intercepted BBM communications described above in paragraphs 134-139 I believe that FIGUEROA and FLORES-SANTOS at VEGA’s direction sorted through the heroin the VEGA DTO received from Individual F VEGA then instructed FLORES-SANTOS to give “Tio ” a narcotics courier a total of two kilograms of heroin - one kilogram wrapped with the orange tape and iguana stamp and another kilogram of heroin VEGA also gave FIGUEROA the telephone number for “Tio” so FIGUEROA and FLORES-SANTOS could deliver the two kilograms to this individual 141 On April 28 2014 at approximately 1 34 p m Session #4247277 VEGA using Target Device 2 had a BBM conversation with Individual F who was using BBM PIN 2A75C94C In that conversation VEGA stated “Buddy of the orange ones kilograms of heroin with orange tape only 1 one kilogram of heroin has the iguana and the other guy the narcotics customer is waiting They FIGUEROA and FLORES-SANTOS already checked the orange ones and only 1 62 has the stamp ” Individual F replied “Give him the narcotics customer that one one kilogram of heroin with the iguana stamp and another one another kilogram of heroin ” Individual F further stated “And deliver the rest of the remaining heroin 142 On April 28 2014 at approximately 1 58 p m Session #4247337 VEGA using Target Device 2 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “Let me know once you have delivered ” FLORES-SANTOS replied “Yeah we still haven’t ” VEGA stated “Okay alright ” FLORES-SANTOS later stated “The trip is completed It’s done FLORES-SANTOS and FIGUEROA delivered the heroin ” 143 On April 28 2014 at approximately 2 04 p m Session #4247338 VEGA using Target Device 2 had a BBM conversation with FIGUEROA who was using Figueroa Device 3 FIGUEROA stated “Okay finished with the 24 delivered 24 kilograms of heroin ” VEGA replied “Okay good ” 144 Based on the intercepted BBM communications described above I believe that Individual F instructed VEGA to deliver two kilograms of heroin to “Tio” - one kilogram wrapped with the orange tape and another kilogram of heroin VEGA then gave these instructions to FIGUEROA who delivered with FLORESSANTOS the two kilograms of heroin as well as the remaining twenty-four kilograms of heroin to “superman ” another narcotics customer 63 G On June 1 2014 the VEGA DTO Received 26 Kilograms of Heroin at Warehouse 2 145 Based on intercepted BBM communications of VEGA FLORES- SANTOS and FIGUEROA on May 30 2014 at approximately 11 02 a m LEOs established surveillance at a warehouse at 850 Ridgeway Avenue Aurora Illinois “Warehouse 1” and observed a passenger bus bearing the name “Monarca” “Bus 1” arrive at the warehouse Approximately ten minutes later LEOs observed a second passenger bus “Bus 2” bearing the name “Monarca” exit Warehouse 1 LEOs further observed FLORES-SANTOS drive Bus 2 to Warehouse 1’s parking lot FLORES-SANTOS then exited Bus 2 and entered Bus 1 Shortly thereafter LEOs observed BETANCOURT at Warehouse 1 LEOs observed BETANCOURT and FLORES-SANTOS engaged in brief conversation BETANCOURT then left Warehouse 1 driving the Acura SUV 146 Later that day at approximately 7 24 p m Session #4433041 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F 50 In that conversation VEGA stated “Take out the things heroin the stickers heroin Put them heroin in the trunk of the white one a white vehicle ” FLORES-SANTOS replied “We put everything all the heroin in the red one a red vehicle and we loaded the Acura with stuff heroin The identification of VEGA as the user of Target Device 4 is based on the following Pen register data showed that on May 2 2014 VEGA ceased using Target Device 2 Information obtained from the U S Customs and Border Patrol showed that VEGA crossed the border from Mexico into the United States on May 2 2014 On May 3 2014 Target Device 3 used by SANCHEZ received a BBM invitation from Target Device 4 to add Target Device 3 to Target Device 4’s contact list The BBM invitation read “Cobra would like to add you to his or her Blackberry Messenger Contact List ” “Cobra” was a Blackberry screen name previously used by VEGA 50 64 It’s outside already the vehicles with the heroin are outside of a warehouse ” VEGA responded “Okay all right Look not in the red one It’s better if you put everything all the heroin in the trunk of the white one It’s outside VEGA stating that the white vehicle is outside of Warehouse 1 Put everything in the white one and we’ll move it early tomorrow ” FLORES-SANTOS stated “We’re not there anymore not at Warehouse 1 We’re going to put them in Cowboy’s car I’ll take care of that right now ” 147 On May 30 2014 at approximately 9 16 p m Session #4436801 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “FRANKLIN ” who was using BBM PIN 7A6E50D1 51 In that conversation FRANKLIN stated “Your aunt the passenger bus gets here from 8 and 9 in the morning with the kids heroin The other lady the other passenger bus arrives at 7 7 00 a m to 8 8 00 a m ” VEGA replied “Okay alright Is Adan going to give me the # telephone number of individual picking up the heroin ” FRANKLIN replied “Yeah ” 148 On May 30 2014 at approximately 9 35 p m Session #4436802 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E 52 VEGA asked “Buddy can you get the number telephone number of the individual picking up the heroin so we can deliver ” 51 “FRANKLIN” is the Blackberry screen name for the user of BBM PIN 7A6E50D1 “STAR” is the Blackberry screen name for the user of BBM PIN 2824C71E Based on intercepted BBM communications described below in paragraphs 175-176 179 187 191192 and 194 I believe that STAR is one of VEGA’s narcotics suppliers 52 65 149 On May 30 2014 at approximately 9 35 p m Session #4436845 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “The aunt bus arrives between 7 7 00 a m and 8 8 00 a m at the 1 Warehouse 1 The aunt another bus at the 2 Warehouse 2 is bringing her nephews heroin ” FLORES-SANTOS asked “What do you know about the 2 bus arriving at Warehouse 2 Did they check it or something like that ” VEGA replied “No it’s doing good ” 150 Continuing on May 30 2014 at approximately 9 37 p m Session #4436895 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F FLORES-SANTOS asked “What time is the 2 one bus at Warehouse 2 arriving ” VEGA replied “Between 8 8 00 a m and 9 9 00 a m You open up the one open up Warehouse 1 and they BETANCOURT and FIGUEROA should go to the 2 Warehouse 2 ” FLORESSANTOS replied “Do you want me to unload and load at the same time or what do you want me to do Or should 2 bus at Warehouse 2 leave without the documentation narcotics proceeds ” VEGA responded “We’ll see about that early tomorrow if the one bus that brings the check narcotics proceeds arrives ” VEGA later instructed “Go to 1 Warehouse 1 and open up ” VEGA further stated “If it’s possible we’ll take it down unload the heroin from the bus at Warehouse 1 and we’ll put them the heroin in the other one Warehouse 2 ” 66 151 Continuing on May 30 2014 at approximately 9 37 p m Session #4436896 VEGA using Target Device 4 had a BBM conversation with courier BETANCOURT who was using BBM PIN 334DDF1A 53 In that conversation VEGA stated “Make arrangements with Alex FIGUEROA tomorrow at 7 7 00 a m okay 152 On June 1 2014 based on location information for telephone number 630 962-8364 which is the telephone number associated with BBM PIN 334DF84F used by FLORES-SANTOS at approximately 10 05 a m LEOs observed a passenger bus bearing the name “Volcano” pull into the bay of Warehouse 2 153 Continuing on June 1 2014 at approximately 11 20 a m Session #4437820 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F In that conversation FLORESSANTOS stated “I’m on my way to two Warehouse 2 already ” VEGA replied “Okay cool ” FLORES-SANTOS asked “Hey the one the bus at two Warehouse 2 is bringing nephews heroin Is that what you told me ” The identification of BETANCOURT as the user of BBM PIN 334DDF1A is based on the following On May 9 2014 at approximately 2 53 p m LEOs observed BETANCOURT holding what appeared to be a cellular device in his hands and typing on the device Pen register data for Target Device 4 used by VEGA showed that on that same date and time Target Device 4 received an incoming BBM message from BBM PIN 334DDF1A On September 26 2014 LEOs conducted a traffic stop of BETANCOURT who was identified by his Wisconsin driver’s license Location information for telephone number 331 9994486 which is associated with BBM PIN 334DDF1A showed that the telephone was in the area of the vehicle that BETANCOURT was driving during the traffic stop 53 67 154 Continuing on June 1 2014 at approximately 12 00 p m Session #4437850 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “Yes it the bus at Warehouse 2 does have have heroin Unload them the heroin ” FLORES-SANTOS replied “Okay ” 155 Continuing on June 1 2014 at approximately 12 43 p m Session #4437900 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F In that conversation FLORESSANTOS stated “Look at how they sent it open like that and white packages containing heroin were open Say something to them ” VEGA responded “That’s how it came out fuck let me check ” 156 Continuing on June 1 2014 at approximately 12 43 p m Session #4437905 VEGA using Target Device 4 received a BBM message from FLORESSANTOS who was using BBM PIN 334DF84F The message was a photograph of a long rectangular brick-shaped object wrapped in black plastic with half of the wrapping peeled off Underneath the peeled off portion of the plastic was a hardpacked white-colored substance in a clear vacuum-sealed bag Based on my training and experience the shape and packaging of this object is consistent with narcotics packaging In addition as described further below in paragraph 203 the object in this BBM message was consistent with the bricks of heroin seized by LEOs on June 7 2014 68 157 On June 1 2014 at approximately 12 55 p m Session #4437944 VEGA using Target Device 4 had a BBM conversation with one of his narcotics suppliers FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA stated “Buddy tell whoever arranges them the individuals who packed the heroin to pay attention to the work because some came out almost nude some of the heroin came out of the packages ” STAR replied “Alright I’ll tell them ” 158 On June 1 2014 at approximately 1 50 p m LEOs observed a white Dodge truck bearing Illinois license 78205X drive through the parking lot of Warehouse 2 54 159 At approximately 2 01 p m Session #4438050 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “I passed over there Warehouse 2 and I didn’t see anyone outside the warehouse ” Based on the intercepted BBM communications described above in paragraph 154-158 and the surveillance of the Dodge truck at Warehouse 2 I believe that VEGA was conducting counter surveillance for FLORES-SANTOS as FLORES-SANTOS unloaded the heroin from the passenger bus at Warehouse 2 160 Continuing on June 1 2014 at approximately 3 49 p m Session #4438300 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation VEGA asked “Where are you going ” FLORES-SANTOS replied “To eat and then According to Illinois Secretary of State records the Dodge truck is registered to Individual J 1201 Superior Street Aurora Illinois 54 69 to the house There were 26 twenty-six kilograms of heroin that was unloaded from the bus at Warehouse 2 VEGA asked “Did you bring Alex FIGUEROA ” FLORES-SANTOS replied “I came to drop Alex off ” VEGA stated “Okay ” 161 Based on the above-described BBM communications and physical surveillance of the buses at Warehouse 1 and Warehouse 2 I believe that VEGA instructed FLORES-SANTOS and FIGUEROA to unload the heroin from a commercial passenger bus that arrived at Warehouse 2 on June 1 2014 VEGA also asked FNU LNU a k a “STAR ” for the telephone number of the individual who was supposed to pick up the heroin Furthermore while unloading the heroin FLORES-SANTOS complained to VEGA that the heroin concealed on the bus at Warehouse 2 was packaged poorly FLORES-SANTOS also confirmed that there were twenty-six kilograms of heroin that he and FIGUEROA unloaded from the bus at Warehouse 2 H On June 3 2014 VEGA Directed FIGUEROA and BETANCOURT To Pick Up $600 000 in Narcotics Proceeds From Courier RODRIGUEZ 162 On June 2 2014 at approximately 5 10 p m Session #4441885 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E In that conversation STAR stated “Buddy I’m going to give you a number so you can pick up some money ” VEGA replied “Okay ” STAR stated “It’s going to be 600 $600 000 of narcotics proceeds Do you want the whole thing or half They can give it in two parts ” VEGA responded “In two parts two deliveries of $300 000 each will be fine ” In another intercepted BBM communication with VEGA Session #4441909 at approximately 70 5 16 p m STAR stated “Okay here is the number 3 1 2 9 3 1 7 7 2 9 ask for the saint ” VEGA replied “Okay ” 163 On June 3 2014 at approximately 10 40 a m Session #4444077 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using BBM PIN 333E56DF “Target Device 7” 55 In that conversation VEGA stated “3 1 2 9 3 1 7 7 2 9 for the saint individual who was to deliver the narcotics proceeds ” The First June 4 2014 Pickup of $300 000 in Narcotics Proceeds 164 Pole camera surveillance footage of 641 Grand Avenue Aurora Illinois showed that on June 4 2014 at approximately 9 21 a m FIGUEROA left his residence at 641 Grand Avenue driving a black Ford Edge bearing Illinois license V333147 the “Ford Edge” 56 Approximately one hour later LEOs observed the Ford Edge parked in front Salude Bienstar at 1691 Town Center Suite 105 Aurora Illinois At approximately 10 37 a m at Warehouse 1 LEOs observed the Chrysler Pacifica parked outside the warehouse LEOs further observed BETANCOURT and FIGUEROA enter the Chrysler Pacifica and drive to an alley between N Harding Ave and N Springfield Ave in Chicago Illinois At that location LEOs observed The identification of FIGUEROA as the user of Target Device 7 is based on the following a the use of the same Blackberry screen name of “Maddog” for Target Device 7 and other Blackberry devices previously identified as being used by FIGUEROA through courtauthorized interceptions of Target Device 1 Target Device 2 Target Device 3 and b location information for Target Device 7 showed that the telephone was at Warehouse 1 on June 4 2014 where LEOs observed FIGUEROA pick up the Chrysler Pacifica 55 According to Illinois Secretary of State records this vehicle is registered to Individual H 641 Grand Avenue Aurora Illinois 56 71 RODRIGUEZ 57 carrying a large bag exit a black Volkswagen sports utility vehicle “the Volkswagen SUV” and approach the rear of the Chrysler Pacifica LEOs further observed FIGUEROA open the rear hatchback door of the Chrysler Pacifica and the rear floorboard of the vehicle rise up RODRIGUEZ then placed a bag inside the floorboard area and returned to the Volkswagen SUV LEOs subsequently observed RODRIGUEZ drive the Volkswagen SUV at a high rate of speed away from the alley and change lanes in an erratic manner 165 On June 4 2014 at approximately 12 21 p m Session #4448220 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 In that conversation VEGA asked “How is it going ” FIGUEROA replied “Fine They RODRIGUEZ are on their way back now ” VEGA asked “How much did they give you ” FIGUEROA replied “300 $300 000 ” VEGA stated “Let me know when you arrive ” FIGUEROA responded “Okay ” 166 Based on the intercepted BBM communications described above I believe that STAR instructed VEGA to pick up $600 000 of narcotics proceeds on STAR’s behalf VEGA indicated that he wanted to pick up the money in two separate deliveries VEGA then instructed FIGUEROA to contact an individual called “the saint ” to arrange for the money pickup Based on the intercepted BBM communications and surveillance I believe that FIGUEROA and BETANCOURT picked up the Chrysler Pacifica at Warehouse 1 and traveled to another location to meet RODRIGUEZ RODRIGUEZ then placed a bag in a hidden compartment of As described further below in paragraph 203 JUAN RODRIGUEZ was identified during a traffic stop of RODRIGUEZ’s vehicle on June 7 2014 57 72 the Chrysler Pacifica FIGUEROA later confirmed with VEGA that he and BETANCOURT picked up $300 000 in narcotics proceeds As described below in paragraphs 202-203 the Volkswagen SUV that Rodriguez used to deliver the narcotics proceeds was the same vehicle RODRIGUEZ picked up from FIGUEROA on June 7 2014 and in which LEOs found approximately 25 kilograms of heroin The Second June 4 2014 Pick Up of $300 000 in Narcotics Proceeds 167 On June 4 2014 at approximately 12 21 p m Session #4448221 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E During that conversation VEGA asked “Around what time will you be ready so I can send my brother FIGUEROA over there My guys are already coming They FIGUEROA and BETANCOURT already picked up 300 $300 000 ” STAR later replied “Okay they are going to give 300 $300 000 more VEGA asked “Okay should they FIGUEROA and BETANCOURT go right away ” STAR responded “Yes ” 168 On June 4 2014 at approximately 12 25 p m Session #4448222 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “Look those guys are coming now Go so the tickets narcotics proceeds can be counted ” 169 Continuing on June 4 2014 at approximately 1 30 p m Session 4448534 VEGA who was using Target Device 4 had a BBM conversation with BETANCOURT who was using BBM PIN 334DDF1A In that conversation BETANCOURT stated “Ready We’ll be at the warehouse in 20 minutes ” 73 170 On June 4 2014 at approximately 2 04 p m LEOs observed the Chrysler Pacifica arrive at Warehouse 1 Shortly thereafter LEOs observed BETANCOURT driving the Chrysler Pacifica with FIGUEROA as the passenger leave Warehouse 1 and travel again to the alley between N Harding Ave and N Springfield Ave in Chicago Illinois At that location at approximately 4 16 p m LEOs observed the Volkswagen SUV arrive LEOs further observed RODRIGUEZ exit the Volkswagen SUV and remove a large bag from the vehicle FIGUEROA then exited the Chrysler Pacifica and opened the vehicle’s rear hatchback door RODRIGUEZ then placed a bag in the rear floor area of the Chrysler Pacifica 171 On June 4 2014 at approximately 5 32 p m Session #4449383 VEGA using Target Device 4 had a BBM conversation with BETANCOURT who was using BBM PIN 334DDF1A In that conversation BETANCOURT asked “Aye where should we take these tickets narcotics proceeds to the warehouse or somewhere else ” VEGA responded “To the warehouse so they narcotics proceeds can be made ready tomorrow ” 172 On June 4 2014 at approximately 8 38 p m Session #4450574 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E In that conversation VEGA stated “We already picked up the 600 $600 000 of narcotics proceeds We’ll get them ready tomorrow cousin and intend to deliver so that they the 26 kilograms of heroin that arrived on a bus at Warehouse 1 on June 1 2014 don’t accumulate on us ” STAR responded “Okay thank you ” 74 173 Based on the above-described intercepted BBM communications and physical surveillance of FIGUEROA BETANCOURT and RODRIGUEZ on June 4 2014 I believe that FIGUEROA and BETANCOURT picked up another $300 000 in narcotics proceeds from RODRIGUEZ on the afternoon of June 4 2014 After the pickup VEGA indicated to STAR that he intended to deliver the twenty-six kilograms of heroin he received on June 1 2014 I June 5 2014 and June 6 2014 Intercepted Communications Between the VEGA DTO’s Members Regarding the Delivery of 26 Kilograms of Heroin that the VEGA DTO Received on June 1 2014 at Warehouse 2 174 On June 5 2014 at approximately 9 33 a m Session #4451407 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation FLORES-SANTOS asked “Hey are we going to deliver the work heroin The one bus carrying the heroin for tomorrow is coming and it will be put it away ” VEGA replied “Let me see I’m checking I’m going there now ” 175 On June 5 2014 at approximately 10 14 a m Session #4451512 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E During that conversation VEGA asked “Cousin can you call the guys so we can deliver the flower vases twenty-six kilograms of heroin received on June 1 2014 so they the heroin won’t accumulate on us ” 176 Continuing on June 5 2014 at approximately 11 57 a m Session #4451782 VEGA using Target Device 4 had a BBM conversation with FNU LNU 75 a k a “STAR ” who was using BBM PIN 2824C71E During this conversation STAR asked “How many flower vases heroin ” VEGA responded “There are 26 twentysix kilograms of heroin from June 1 2014 ” 177 On June 5 2014 at approximately 5 39 p m Session #4453077 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “FRANKLIN ” who was using BBM PIN 7A6E50D1 Based on the intercepted BBM communications described below I believe that FRANKLIN on behalf of VEGA’s narcotics sources in Mexico alerted members of the VEGA DTO in the Chicago area as to when the passenger buses containing narcotics would arrive at Warehouse 1 or Warehouse 2 In that conversation FRANKLIN stated “The lady the passenger bus is arriving tomorrow from 9 00 to 10 00 in the morning ” 178 Continuing on June 5 2014 at approximately 5 40 p m Session #4453141 VEGA using Target Device 4 had another BBM conversation with FNU LNU a k a “FRANKLIN ” who was using BBM PIN 7A6E50D1 VEGA stated “Okay Is she the passenger bus bringing the kids heroin ” FRANKLIN replied “Yes ” VEGA asked “Okay and what time does the other other bus arrive ” FRANKLIN responded “From 7 00 to 8 00 in the morning ” VEGA stated “Okay alright ” 179 On June 5 2014 at approximately 8 40 p m Session #4454283 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA stated “Cousin the aunt the passenger bus containing heroin will arrive tomorrow 76 Give me the number telephone number of individual who is to receive the heroin so we can make the delivery so they the heroin won’t accumulate on us ” 180 Based on the above-described intercepted BBM communications I believe that the VEGA DTO still had twenty-six kilograms of heroin that arrived at Warehouse 2 on June 1 2014 FRANKLIN informed VEGA that additional heroin would be arriving in a passenger bus on June 6 2014 VEGA was concerned about the heroin accumulating on him so he asked STAR for the contact information for the individuals to whom VEGA’s couriers should deliver the twenty-six kilograms of heroin that the DTO received on June 1 2014 J On June 6 2014 VEGA Instructed His Couriers FIGUEROA FLORES-SANTOS and BETANCOURT to Unload Narcotics From the Passenger Bus at Warehouse 2 181 On June 6 2014 at approximately 6 21 a m Session #4455124 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “From 7 00 to 8 00 okay to the 1 Warehouse 1 ” I forgot ” 182 On June 6 2014 at approximately 6 22 a m Session #4455125 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 VEGA stated “Between 9 00 and 10 00 the 2 Warehouse 2 okay ” FIGUEROA replied “Okay ” 183 Continuing on June 6 2014 at approximately 6 24 a m Session #4455139 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 77 VEGA stated “Alex go to 1 Warehouse 1 Willi FLORES-SANTOS is not answering It the bus arrives between 7 00 and 8 00 ” FIGUEROA replied “Okay ” VEGA asked “Did you already talk to Diego BETANCOURT ”58 FIGUEROA replied “In a little bit ” VEGA later stated “Go to 1 Warehouse 1 ” FIGUEROA replied “Okay ” 184 On June 6 2014 at approximately 8 23 a m Session #4455210 VEGA using Target Device 4 had a BBM conversation with BETANCOURT who was using BBM PIN 334DDF1A In that conversation VEGA stated “What the fuck what time are you guys arriving ” BETANCOURT replied “We’re already here Warehouse 2 ” VEGA stated “Alex already went to the other one Warehouse 1 BETANCOURT replied “Okay ” 185 On June 6 2014 at approximately 8 38 a m Session #4455227 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “FRANKLIN ” who was using BBM PIN 7A6E50D1 VEGA stated “Hey tell the cousin to give me the # so I can deliver deliver the heroin We still have last week’s the heroin that arrived on June 1 2014 they’re going to pile up ” FRANKLIN replied “Okay ” 186 On June 6 2014 at approximately 9 08 a m Session #4455280 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA asked “Did you already leave ” FLORES-SANTOS replied “I’m storing away the other gifts heroin because if they come to wash wash the bus at Warehouse 2 they are going to want to put in water The Blackberry screen name that BETANCOURT used for BBM PIN 334DDF1A was “Diego Verdaguer ” 58 78 there because I told them that is where you throw it But its set already I’m leaving This thing the bus needs a tire ” Later in the conversation VEGA stated “Stop by the tire shop to see if they open tomorrow ” VEGA further stated “Do a good job of putting the gifts heroin away ” FLORES-SANTOS replied “We put them in the white car just in the meantime while they wash the car the bus at Warehouse 2 Later on we’ll put them the heroin inside Tomorrow we’ll take them out again ” 187 On June 6 2014 at 9 20 a m Session #4455281 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA stated “Buddy send me the number to deliver the ones for today heroin that arrived at Warehouse 2 on June 6 2014 ” 188 On June 6 2014 at approximately 9 41 a m LEOs observed a passenger bus bearing the name “Volcano” enter the parking area of Warehouse 2 189 Continuing on June 6 2014 at approximately 10 57 a m Session #4455499 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F In that conversation FLORESSANTOS stated ‘Hey there are several people in the warehouse next door I’m going to wait a while okay Because everything one says can be heard ” VEGA replied “Okay have them start cleaning it the bus at Warehouse 2 ” 190 Based on the above-described intercepted BBM communications and physical surveillance of a passenger bus arriving at Warehouse 2 I believe that FNU LNU a k a “FRANKLIN ” informed VEGA that on June 6 2014 a bus was 79 going to arrive at Warehouse 1 and another bus containing heroin was going to arrive at Warehouse 2 VEGA was concerned that there would be too much heroin stored at the warehouses so VEGA contacted FNU LNU a k a “STAR ” and asked for the telephone number of the individual who was to receive the twenty-six kilograms of heroin that the VEGA DTO received on June 1 2014 VEGA then instructed FIGUEROA to go to Warehouse 1 FLORES-SANTOS and BETANCOURT went to Warehouse 2 where they started to unload the heroin off the bus FLORES-SANTOS then informed VEGA that he was going to wait before unloading the heroin because he was concerned that the people in the next warehouse may hear what he was doing K Between June 6 2014 and June 7 2014 VEGA Directed FIGUEROA and FLORES-SANTOS to Deliver the Heroin Received by the VEGA DTO on June 1 2014 and June 6 2014 to Various Narcotics Customers VEGA Arranged the Delivery of the 26 Kilograms of Heroin Received by the VEGA DTO on June 1 2014 to the Couriers “Diego” and “Botas ” 191 On June 6 2014 at approximately 11 21 a m Session #4455588 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E In that conversation STAR stated “Here goes the number it is 8 7 2 2 2 3 2 2 8 6 Ask for Diego Give them the 20 flower vases 20 kilograms of heroin that the VEGA DTO received on June 1 2014 ” VEGA asked “The ones from today heroin that arrived at Warehouse 2 on June 6 2014 ” 80 192 Continuing on June 6 2014 at approximately 11 41 a m Session #4455627 VEGA using Target Device 4 had another BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E In that conversation STAR stated “Oh give them Diego 20 twenty kilograms of heroin received by the VEGA DTO on June 1 2014 and 6 to another number the remaining six kilograms of heroin received that day to another individual ” VEGA replied “Okay ” STAR stated “You want me to give it the telephone number to you while I’m at it ” VEGA replied “Should I deliver the 20 twenty kilograms of heroin to Diego first Yes ” STAR responded “Yes ” VEGA asked “But call the other one ” STAR replied “Okay for the guy for the 6 six kilograms of heroin it’s 6 3 0 9 1 5 0 3 2 2 Ask for botas the individual who was to receive the heroin ” VEGA responded “Okay sounds good ” 193 On June 6 2014 at approximately 11 48 a m Session #4455628 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 In that conversation VEGA stated “8 7 2 2 2 3 2 2 8 6 Ask for Diego give him 20 twenty out of the twenty-six kilograms of heroin that the VEGA DTO received on June 1 2014 ” VEGA Arranged the Delivery of the 20 Kilograms of Heroin Received by the VEGA DTO on June 6 2014 to Courier “Primo ” 194 On June 6 2014 at approximately 4 23 p m Session #4456569 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E STAR stated “Give 20 twenty kilograms of heroin to the first number to Diego of what you have stored away of 81 the heroin that the VEGA DTO received on June 1 2014 and give 6 six kilograms of heroin to the other to botas of the stored ones from the remaining heroin that the VEGA DTO received on June 1 2014 ” VEGA replied “We haven’t unloaded todays the heroin that arrived on the bus at Warehouse 2 on June 6 2014 The other guy called me on behalf of primo the individual who was to receive the heroin that the VEGA DTO received on June 1 2014 The guy primo we were going to give the ones I have stored away to the heroin received on June 1 2014 ” STAR responded “The other one the heroin that the VEGA DTO received on June 6 2014 tomorrow needs to be delivered tomorrow ” VEGA stated “The 26 twentysix kilograms of heroin from last week received by the VEGA DTO on June 1 2014 They the individuals who were to receive that heroin are saying they can come now The one that arrived today heroin received on June 6 2014 I am going to unload in the morning Oh okay that’s fine So then the one heroin we are going to unload I’ll store these away ” STAR replied “I will give you another # telephone number of the individual who is to receive the heroin that the VEGA DTO received on June 6 2014 and you can arrange it with him ” VEGA stated “Okay ” STAR responded “2 1 7 8 4 8 4 3 6 5 on behalf of primo for the 20 twenty kilograms that arrived at Warehouse 2 on June 6 2014 ” 195 Based on the above-described intercepted BBM communications I believe that STAR instructed VEGA to deliver twenty of the twenty-six kilograms of heroin that the VEGA DTO received on June 1 2014 to an individual called “Diego ” and the remaining six kilograms of heroin to an individual called “botas ” VEGA 82 then instructed FIGUEROA to deliver the narcotics to “Diego ” STAR further instructed VEGA to deliver the twenty kilograms that the VEGA DTO received on June 6 2014 to “primo ” June 7 2014 Intercepted Communications Between VEGA FIGUEROA and FLORES-SANTOS Regarding the Delivery of 20 Kilograms of Heroin to “Diego ” 196 On June 6 2014 at approximately 4 33 p m Session #4456803 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “The one I just gave to Alex FIGUEROA is for 20 twenty kilograms of heroin to be delivered to Diego ” FLORES-SANTOS replied “Yes he FIGUEROA arranged for tomorrow arranged the delivery of heroin for tomorrow ” VEGA stated “It’s 3 deliveries we’ll deliver everything tomorrow ” VEGA further stated “They’re new numbers telephone numbers nothing from last week I have 3 numbers so I can turn in all of them ” FLORES-SANTOS replied “Okay ” VEGA stated “The one telephone number I gave Alex FIGUEROA which is from Diego and 2 two other telephone numbers that I have Okay ” FLORES-SANTOS replied “Okay ” VEGA stated “I’ll give you the numbers here at the game for early tomorrow ” 197 On June 7 2014 at approximately 11 02 a m Session #4459356 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 FIGUEROA asked “What are they going to do with the 6 six out of the twenty-six kilograms that the VEGA DTO received on June 1 2014 ” VEGA replied “Store them the heroin First hand over deliver the 20 twenty 83 out of the twenty kilograms that the VEGA DTO received on June 1 2014 and 20 twenty kilograms of heroin that the VEGA DTO received on June 6 2014 ” 198 Continuing on June 7 2014 at approximately 11 44 a m Session #4459455 FIGUEROA using Target Device 7 had another BBM conversation with VEGA who was using Target Device 4 VEGA asked “Who went for you Did you hand over the truck ” FIGUEROA replied “No Yeah I have some ” VEGA later stated “Don’t give it to him Diego in the same spot okay ” FIGUEROA asked “Don’t what ” VEGA responded “Give it the twenty kilograms of heroin to him Diego somewhere else Not the same spot okay ” 199 Continuing on June 7 2014 at approximately 12 28 p m FIGUEROA using Target Device 7 had another BBM conversation with VEGA who was using Target Device 4 FIGUEROA stated “Okay finished with the first one delivery of twenty kilograms of heroin to Diego ” VEGA asked “Where are you I’ll come by for you ” FIGUEROA replied “I am with Diego BETANCOURT ” VEGA stated “Oh okay fine ” 200 Based on the above-described intercepted BBM communications I believe that VEGA instructed FIGUEROA to deliver twenty kilograms of heroin that the VEGA DTO received on June 1 2014 to “Diego ” VEGA also indicated to FLORES-SANTOS that he would give FLORES-SANTOS the telephone numbers of the other individuals who were to receive additional amounts of heroin FIGUEROA later confirmed with VEGA that he delivered the twenty kilograms of heroin to “Diego ” 84 L On June 7 2014 LEOs Seize Approximately 25 Kilograms of Heroin from RODRIGUEZ Who Received the Heroin from FIGUEROA and BETANCOURT 201 On June 7 2014 at approximately 6 33 a m LEOs observed FIGUEROA leave his residence at 641 Grand Avenue Aurora Illinois driving the Ford Edge Approximately half an hour later LEOs observed FIGUEROA and BETANCOURT exit a silver Acura at Warehouse 2 At approximately 9 48 a m FIGUEROA drove a silver Acura to Warehouse 1 A few minutes later BETANCOURT driving the Chrysler Pacifica left Warehouse 1 202 At approximately 11 33 a m LEOs observed BETANCOURT arrive at Warehouse 1 Approximately ten minutes later FIGUEROA who was driving the same Volkswagen SUV that RODRIGUEZ drove to deliver narcotics proceeds to FIGUEROA on June 4 2014 see paragraphs 164 and 170 above entered Warehouse 1 At that same time LEOs also observed VEGA who was driving a white van drive slowly past Warehouse 1 VEGA continued to circle the area in the van Based on my training and experience the experience of other LEOs and the physical surveillance of VEGA I believe that VEGA was looking out for law enforcement’s presence At approximately 12 08 p m LEOs observed the Volkswagen SUV leave Warehouse 1 and travel to a parking lot of the Westgate shopping center in Aurora Illinois At approximately 12 22 p m RODRIGUEZ exited a store at the shopping center and met FIGUEROA by the Volkswagen SUV in the parking lot RODRIGUEZ then entered the driver’s seat of the Volkswagen SUV FIGUEROA entered the front passenger seat and the vehicle traveled to a nearby Walmart in Aurora Illinois At approximately 12 24 p m FIGUEROA 85 exited the Volkswagen SUV and entered the Walmart RODRIGUEZ then drove the Volkswagen SUV park in the parking lot of the Walmart At approximately 12 32 p m LEOs observed FIGUEROA and BETANCOURT exit the Walmart enter the silver Acura and leave the area Shortly thereafter the Volkswagen SUV driven by RODRIGUEZ also left the area 203 At approximately 1 03 p m LEOs conducted a traffic stop on the Volkswagen SUV because RODRIGUEZ was using a cellular telephone while driving After RODRIGUEZ consented to a search of the vehicle LEOs recovered approximately twenty brick-shaped packages weighing approximately twenty-five kilograms and containing a tan powdery substance wrapped in black tape and green plastic wrap 59 The substance field-tested positive for heroin These packages were found in a hidden compartment underneath the driver and front passenger seats of the vehicle The shape and packaging of the heroin was consistent with the objects depicted in a BBM message sent by FLORES-SANTOS to VEGA on June 1 2014 see paragraph 156 above LEOs also recovered approximately sixty-three grams of a white powdery substance that was concealed in a vitamin bottle which was located in a hidden compartment underneath the front passenger seat of the vehicle The substance field-tested positive for cocaine RODRIGUEZ told LEOs that he had “a little K-2 inside the door ”60 59 Inside the front driver’s side door Twenty-five kilograms is the gross weight including the packaging RODRIGUEZ made no other statements about the heroin and cocaine found in his vehicle 60 86 compartment LEOs recovered two separate baggies containing synthetic cannabis that weighed a total of approximately 36 5 grams M On June 7 2014 at VEGA’s Direction FIGUEROA and BETANCOURT Delivered Eleven of the Twenty Kilograms of Heroin that the VEGA DTO Received on June 6 2014 to “Primo” and Six Kilograms of Heroin that the VEGA DTO Received on June 1 2014 to “Botas ” 204 On June 7 2014 at approximately 1 12 p m Session #4459705 VEGA using Target Device 4 had a BBM conversation with BETANCOURT who was using BBM PIN 334DDF1A BETANCOURT asked “Aye are the 20 twenty kilograms of heroin for this primo VEGA replied “Yes ” VEGA further stated “In the red truck to the number telephone number that I gave Alex FIGUEROA ” BETANCOURT replied “Okay I’ll let him know ” VEGA asked “Aren’t you with him FIGUEROA ” BETANCOURT responded “Yes ” 205 On June 7 2014 at approximately 1 22 p m Session #4459786 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 FIGUEROA stated “Okay They the twenty kilograms of heroin don’t all fit in the trap ” VEGA responded “Just the ones that fit deliver the heroin that fits in the hidden compartment ” VEGA asked “How many fit ” FIGUEROA replied “Okay ” FIGUEROA replied “11 eleven kilograms of heroin ” VEGA stated “Okay ” 206 Continuing on June 7 2014 at approximately 1 45 p m Session #4459883 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 In that conversation FIGUEROA stated “Okay finished with the second delivery of heroin to primo ” VEGA asked 87 “Only 11 eleven kilograms of heroin ” FIGUEROA replied “Yes ” VEGA asked “Okay when will he primo be back ” FIGUEROA stated “Where We are eating ” VEGA stated “No the guy you gave 11 eleven kilograms of heroin to when will he primo come back for the rest ” FIGUEROA responded “I don’t know Let me check with Diego BETANCOURT ” VEGA stated “Okay I am on my way there so the tires tires to the bus can be put on ” FIGUEROA replied “Okay ” VEGA then stated “6 3 0 9 1 5 0 3 2 2 Ask for votas 61 see if he can come There are 6 six kilograms of heroin for him ” 207 Continuing on June 7 2014 at approximately 2 04 p m Session #4459937 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 FIGUEROA stated “They primo said tomorrow at 11 00 ” VEGA replied “Okay Good I’ll wait for you here at the warehouse ” 208 On June 7 2014 at approximately 4 23 p m Session #4460497 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA stated “Diego BETANCOURT could only fit 11 eleven kilograms of heroin he’ll primo come tomorrow for the rest and for votas has to be handed over early the additional six kilograms of heroin will be delivered to the individual called “boots” ” VEGA wrote “votas” in Spanish but based on the communication described above in paragraph 192 above VEGA most likely meant to write “botas ” which in English means “boots ” 61 88 209 Based on the above-described intercepted BBM communications I believe that VEGA initially arranged for FIGUEROA and BETANCOURT to deliver twenty kilograms of heroin that the VEGA DTO received on June 6 2014 to “primo” however FIGUEROA informed VEGA that only eleven kilograms of heroin fit in a hidden compartment of a vehicle that was being used by “primo” to transport the heroin Therefore FIGUEROA and BETANCOURT delivered only eleven kilograms of heroin to “primo ” VEGA later informed FNU LNU a k a “STAR ” that the next day “primo” would pick up the remaining kilograms of heroin and the six kilograms of heroin that the VEGA DTO received on June 1 2014 would be delivered to “botas ” 210 On June 8 2014 at approximately 10 49 a m Session #4463642 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 FIGUEROA stated “The guy is coming for the 6 six kilograms of heroin that I told the guy What are you waiting for ” VEGA asked “Where is the truck at ” FIGUEROA replied “In the warehouse ” VEGA stated “Ok give it to them the individual picking up the six kilograms of heroin ” 211 On June 8 2014 at approximately 6 53 p m Session #4464696 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA stated “Hey man I delivered to Votas and he has not answered to return the truck check if everything is ok ” 212 Continuing on June 9 2014 at approximately 11 31 a m Session #4465872 VEGA using Target Device 4 had a BBM conversation with FNU LNU 89 a k a “STAR ” who was using BBM PIN 2824C71E STAR stated “Botas finally responded they called him and he said everything is fine ” 213 Based on the above-described intercepted BBM communications I believe that FIGUEROA delivered six out of the twenty-six kilograms that the VEGA DTO received on June 1 2014 to “botas ” who FIGUEROA contacted by calling telephone number 630 915-0322 N On June 8 2014 the VEGA DTO Received Twenty-Six Kilograms of Heroin at Warehouse 2 and on June 10 2014 at VEGA’s Direction FIGUEROA and FLORES-SANTOS Delivered the Heroin to a Courier for a Narcotics Customer 214 On June 7 2014 at approximately 8 55 p m Session #4462612 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “FRANKLIN ” who was using BBM PIN 7A6E50D1 In that conversation FRANKLIN stated “Between 6 and 7 6 00 a m and 7 00 a m the aunt bus arrives with the kids heroin ” 215 On June 8 2014 at approximately 10 47 a m Session #4463641 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F FLORES-SANTOS stated “I am here at Warehouse 2 ” VEGA stated “Oh okay that’s fine Has the aunt bus arrived or not yet ” FLORES-SANTOS responded “Yes she just arrived Cowboy left with the drivers ” FLORES-SANTOS later asked “What do you want me to take out of here the bus just the welding machine ” VEGA replied “I will tell you shortly ” FLORES-SANTOS stated “Okay So then I can’t go with you ” VEGA replied “No not the tools ” FLORES-SANTOS asked “Then what do I take out if the gifts 90 the heroin are in the aunt’s wallet the bus’ hidden compartments You said tomorrow morning ” VEGA responded “No the ones then heroin that were left at the 2 Warehouse 2 ” FLORES-SANTOS stated “There is nothing here there are no narcotics at Warehouse 2 They the heroin are at 1 Warehouse 1 but let me ask so that if not then I’ll do it ” VEGA asked “Where is the red truck ” FLORESSANTOS replied “At 1 Warehouse 1 That’s where the gifts the heroin are ” VEGA asked “You moved them the heroin ” FLORES-SANTOS replied “Yes They the heroin are in the red one the red truck ” 216 On June 9 2014 at approximately 1 19 p m Session #4466119 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E In that conversation VEGA stated “Yes got it the heroin ” STAR asked “How many flower vases kilograms of heroin do you have total ” 217 Continuing on June 9 2014 at approximately 2 02 p m Session #4466215 VEGA using Target Device 4 had another BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E VEGA responded “9 from the 1162 and 26 twenty-six kilograms of heroin arrived today ” 218 Continuing on June 9 2014 at approximately 2 33 p m Session #4466300 VEGA using Target Device 4 had a BBM conversation with FNU LNU Based on the prior BBM conversations of VEGA and STAR it is believed that in this BBM communication VEGA meant to say that he had nine out of the twenty kilograms that the VEGA DTO received on June 1 2014 not eleven since eleven kilograms were already delivered to “primo” VEGA also seemed to miscount the amount of heroin he had remaining because as of the time of this BBM conversation FIGUEROA had already delivered six kilograms to “botas ” 62 91 a k a “STAR ” who was using BBM PIN 2824C71E STAR stated “Give the 26 twenty-six kilograms of heroin that the VEGA DTO received on June 8 2014 to Manuel’s helper ” 219 On June 9 2014 at approximately 4 01 p m Session #4466746 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a LOBO al MILLON who was using BBM PIN 2A10655C 63 VEGA stated “Send me the # telephone number for delivering the flower vases twenty-six kilograms of heroin ” 220 Continuing on June 9 2014 at approximately 4 33 p m Session #4466852 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a LOBO al MILLON who was using BBM PIN 2A10655C LOBO al MILLON stated “8 7 2 3 0 3 4 8 3 9 El guero ” 221 On June 9 2014 at approximately 7 03 p m Session #4467324 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 VEGA asked “Did you find a tel telephone 8 7 2 3 0 3 4 8 3 9 Ask for El guero ” 222 On June 10 2014 at approximately 11 05 a m Session #4468768 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation FLORES-SANTOS stated “The gifts twenty-six kilograms of heroin have been delivered Everything is fine ” “LOBO al MILLON” is the Blackberry screen name used by the user of BBM PIN 2A10655C 63 92 223 Continuing on June 10 2014 at approximately 11 06 a m Session #4468769 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 FIGUEROA stated “It’s already done ” VEGA asked “Did you hand in deliver the heroin in the red truck ” FIGUEROA replied “Yes ” 224 Based on the above-described intercepted BBM communications I believe that FLORES-SANTOS informed VEGA that a bus containing heroin arrived at one of the warehouses VEGA then confirmed with FNU LNU a k a “STAR ” that the bus contained twenty-six kilograms of heroin VEGA then reached out to FNU LNU a k a “LOBO AL MILLON ” who instructed VEGA to deliver the heroin to “El guero ” FIGUEROA received the telephone number for “El guero” from VEGA and FLORES-SANTOS later confirmed with VEGA that the delivery had been completed O On June 10 2014 LEOs Seized Approximately 31 Kilograms of Heroin from Individual C Who Received the Heroin from FIGUEROA 225 On June 10 2014 at approximately 8 30 a m LEOs observed FIGUEROA leave the residence at 641 Grand Avenue Aurora Illinois FIGUEROA entered a white Acura bearing Illinois license V46403364 and traveled to a business located at 1691 Town Center #105 Aurora Illinois the “Salude Bienstar” 65 LEOs According to Illinois Secretary of State records the white Acura is registered to ALEXANDER FIGUEROA 641 Grand Avenue Aurora Illinois 64 According to lease documents for Salude Bienstar Individual I VEGA’s wife see paragraph 270 below is one of the tenants of the business which is described on the lease agreement as an “Herbal Life Office ” 65 93 then observed FLORES-SANTOS and BETANCOURT standing outside Salude Bienstar Shortly thereafter LEOs observed FLORES-SANTOS BETANCOURT enter a silver Acura and leave the area and LEOs also observed FIGUEROA who was driving a maroon Acura depart the area At Warehouse 2 at approximately 10 33 a m LEOs observed the bay door of Warehouse 2 open and the Chrysler Pacifica leave the warehouse Shortly thereafter LEOs observed the Chrysler Pacifica in a Walmart parking lot at 2900 Kirk Road Aurora Illinois LEOs then observed FIGUEROA exit the Walmart and leave the area in a maroon Acura which LEOs observed earlier that day at Salude Bienstar Shortly after FIGUEROA left Walmart LEOs observed a male individual enter the Chrysler Pacifica and drive the vehicle to a garage at 5340 S Kedzie Chicago Illinois LEOs approached the driver of the Chrysler Pacifica Individual C and pursuant to a consent search recovered approximately twenty-six brick-shaped packages containing a tan powdery substance which were wrapped in black tape and green plastic wrap The substance field-tested positive for heroin and weighed approximately 31 kilograms 66 The packages were found in a hidden compartment in the rear floor area of the Chrysler Pacifica Based on the intercepted BBM communications described above in paragraphs 214-223 and physical surveillance I believe that FIGUEROA at VEGA’s direction loaded the Chrysler Pacifica with heroin that the VEGA DTO received at Warehouse 2 on June 9 2014 then delivered the vehicle to Individual C 66 This is gross weight which included the packaging 94 P VEGA’s Intercepted Communications between June 10 2014 and June 12 2014 Regarding the Delivery of the Remaining Kilograms of Heroin that the VEGA DTO Received on June 6 2014 226 As described above in paragraphs 205-208 out of the twenty kilograms of heroin that the VEGA DTO received on June 6 2014 only eleven kilograms were delivered by FIGUEROA and BETANCOURT to “primo ” As described below VEGA instructed FIGUEROA to deliver the seven kilograms of heroin to an individual called “El Veterano ” VEGA then kept the remaining two kilograms of heroin 227 On June 10 2014 at approximately 12 01 p m Session #4468808 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E During the conversation STAR stated “Look I’m going to give you the number for the flower vases remaining heroin once and for all ” STAR then stated “7 7 3 4 9 4 7 3 0 1 with El Veterano ” VEGA replied “Okay alright ” 228 On June 11 2014 at approximately 10 38 a m Session #4471042 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 VEGA stated “Listen I’m going to send you the number for the ones heroin that are left ” VEGA later stated “7 7 3 4 9 4 7 3 0 1 to give him whatever is left ” 229 Continuing on June 12 2014 at approximately 11 49 a m Session #4474167 FIGUEROA using Target Device 7 had a BBM conversation with 95 VEGA who was using Target Device 4 FIGUEROA stated “Okay finish They already left with the job heroin ” 230 Continuing on June 12 2014 at approximately 12 19 p m Session #4474232 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 VEGA asked “Okay how many were they ” FIGUEROA replied “7 seven kilograms of heroin ” 231 On June 12 2014 at approximately 8 56 p m Session #4475764 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E During the conversation STAR stated “Alright buddy they only delivered seven flower vases seven kilograms of heroin out of the nine nine kilograms of heroin remaining from the heroin received by the VEGA DTO on June 6 2014 that were there ” 232 Continuing on June 12 2014 at approximately 9 09 p m Session #4475768 VEGA using Target Device 4 had a BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E STAR asked “Did you keep 2 two kilograms of heroin ” VEGA replied “I grabbed 2 two kilograms of heroin I’ll deposit pay for them I have 70 $70 000 I’ll send them the money STAR stated “Alright We’ll settle up later ” VEGA stated “Yes I’ll deposit them the money for the two kilograms of heroin in the one that’s supposed to be deposited into the bus transporting narcotics proceeds back to Mexico ” 233 Based on the above-described intercepted BBM communications I believe that VEGA received telephone number 773 494-7301 from STAR who 96 instructed VEGA to deliver to the individual using that telephone number seven out of the twenty kilograms of heroin that the VEGA DTO received on June 6 2014 VEGA provided telephone number 773 494-7301 to FIGUEROA who later confirmed with VEGA that he had delivered the seven kilograms of heroin to that individual VEGA later indicated to FNU LNU a k a “STAR” that he kept the remaining two kilograms of heroin and would pay STAR $70 000 for the heroin at a later time 67 Q Between June 16 2014 and June 18 2014 at VEGA’s Direction FIGUEROA Picked Up Narcotics Proceeds from Couriers of Narcotics Customers “La Torre” and “Veterano ” 234 On June 16 2014 at approximately 1 07 p m Session #4482422 VEGA using Target Device 4 had the following BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E STAR stated “Cousin I am going to give you a # telephone number so you can pick up 125 $125 000 in narcotics proceeds and add them to what you got ” VEGA replied “But would it be for the one the bus arriving Friday Today’s the bus is leaving already we already filled filled the bus with narcotics proceeds Send it the telephone number to me ” STAR stated “For Friday I am going to send you another 200 more an additional $200 000 in narcotics proceeds of 100 and 100 two separate pick-ups of $100 000 each ” STAR later stated “It’s 7 7 3 6 4 1 1 2 3 7 to la torre It’s 125 $125 000 in narcotics proceeds with him ” Out of the twenty kilograms of heroin that the VEGA DTO received on June 6 2014 eleven kilograms were delivered to “primo ” seven kilograms were delivered to “Veterano ” and two kilograms were kept by VEGA 67 97 235 On June 16 2014 at approximately 4 19 p m Session #4482796 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 VEGA stated “7 7 3 6 4 1 1 2 3 7 La torre ” Based on the intercepted BBM communication between VEGA and STAR described above I believe that VEGA provided FIGUEROA with this telephone number so that FIGUEROA could pick up the narcotics proceeds from the user of that telephone number 236 On June 16 2014 at approximately 4 58 p m Session #4482897 VEGA using Target Device 4 had the following BBM conversation with FNU LNU a k a “STAR ” who was using BBM PIN 2824C71E STAR stated “Buddy this is the other one 7 7 3 4 9 4 7 3 0 1 with Veterano he is going to give 100 $100 000 in narcotics proceeds ” 237 Continuing on June 17 2014 at approximately 7 23 p m Session #4484626 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 FIGUEROA asked “Can you guys give me the guy’s number so that I can go pick up tomorrow ” VEGA replied “7 7 3 4 9 4 7 3 0 1 for el Veterano He’s going to give you 100 $100 000 in narcotics proceeds ” FIGUEROA stated “Okay ” 238 Continuing on June 18 2014 at approximately 2 31 p m Session #4484807 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 During that conversation VEGA stated “Did they only give you 100 $100 000 ” FIGUEROA replied “105 98 $105 000 ” VEGA stated “Okay then and how about yesterday ” FIGUEROA replied “125 $125 000 ” 239 Continuing on June 18 2014 at approximately 2 57 p m Session #4484810 VEGA using Target Device 4 had a BBM conversation with STAR who was using BBM PIN 2824C71E VEGA stated “We already picked up they gave 105 $105 000 and yesterday 125 $125 000 ” 240 Based on the above-described intercepted BBM communications I believe that STAR instructed VEGA to pick up narcotics proceeds from two couriers for narcotics customers - “La torre ” who was using telephone number 773 6411237 and “Veterano ” who was using telephone number 773 494-7301 VEGA provided these telephone numbers to FIGUEROA who then picked up $125 000 from “La torre” and $105 000 from “Veterano ” R July 3 2014 Traffic Stop of VEGA and FIGUEROA in Texas and VEGA’s Subsequent Conversations with Members of the VEGA DTO Regarding Concealing Their Narcotics-Related Activities 241 Based on location information for Target Device 4 used by VEGA LEOs determined that VEGA left Illinois on or about July 2 2014 and headed toward the U S-Mexico border On July 3 2014 LEOs learned that on that same day VEGA and FIGUEROA were stopped by law enforcement officers in Webb County Texas “Webb County LEOs” for traffic-related offenses 68 Webb County LEOs subsequently found a total of approximately $21 000 in cash on VEGA and FIGUEROA Some of the money was concealed in the waist area of the pants worn 68 VEGA and FIGUEROA were identified by their Illinois driver’s licenses 99 by VEGA and FIGUEROA VEGA and FIGUEROA were released and no charges were filed against them 242 On July 3 2014 at approximately 8 17 p m Session #4540342 VEGA using Target Device 4 had a BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation FLORES-SANTOS asked “Hey where are you ” VEGA responded “You know what Move the truck truck used to transport narcotics and narcotics proceeds to Fredi’s Put it away We got fucked over here ” FLORES-SANTOS replied “Right now There is nowhere to park it there The garage is full of things Where are you Aye ” 243 Continuing on July 3 2014 at approximately 8 26 p m Session #4540399 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “On the street In that conversation Can you or should I send someone ” FLORES- SANTOS replied “But if I take it the truck right now they law enforcement are going to see where I take it ” VEGA responded “No There is no problem yet Take it out ” FLORES-SANTOS stated “Let me ask Fre to help me but the paper narcotics proceeds has to be taken out out of the truck So then should we not go there the warehouse anymore or what am I going to do ” VEGA replied “Okay Just cleaning clean the vehicles at the warehouse ” FLORES-SANTOS stated “Okay The aunts buses carrying narcotics are only going to be cleaned because if I go by they law enforcement are going to arrive you can count on that ” 100 244 Continuing on July 3 2014 at approximately 9 59 p m Session #4540700 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “Here at the border the U S -Mexico border without money They law enforcement took it all from me ” FLORES-SANTOS replied “So then you were the one they law enforcement fucked over I thought it was the aunt bus carrying narcotics I already took out the … brown truck I have it put away already ” VEGA stated “That’s right me and Alex ” 245 Continuing on July 3 2014 at approximately 10 16 p m Session #4540806 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F FLORES-SANTOS asked “How much did they take from you ” VEGA replied “All of it 21000 $21 000 ” FLORES-SANTOS replied “Fudge man but you knew ” VEGA stated “But the problem is coming from over there LEOs investigating his activities in Chicago not because of the money Be careful ” FLORES-SANTOS replied “Okay what did they law enforcement say to you But you already know they are investigating you ” VEGA stated “The problem is that the DEA has them Yes That’s exactly it ” FLORES-SANTOS asked “So then nothing can be done anymore ” VEGA responded “You guys can ” FLORES-SANTOS further asked “Did they law enforcement say anything to you about us But the good thing is they let you go ” VEGA replied “Nothing ” FLORES-SANTOS stated “Okay And what did they say to Alex FIGUEROA Is he alright ” VEGA replied “No ” FLORES-SANTOS 101 further stated “So then not you or Alex can work engage in narcotics trafficking activities anymore ” 246 Continuing on July 3 2014 at approximately 10 40 p m Session #4540808 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F In that conversation VEGA stated “No VEGA and FIGUEROA will discontinue their narcotics trafficking activities for the time being ” FLORES-SANTOS replied “Then it’s going to be tough ” VEGA stated “Yes honestly yes Where are you ” FLORESSANTOS responded “At the house ” VEGA stated “Oh okay ” 247 Continuing on July 3 2014 at approximately 10 52 p m Session #4540916 VEGA using Target Device 4 had another BBM conversation with FLORES-SANTOS who was using BBM PIN 334DF84F VEGA stated “Send me Alex’s ping FIGUEROA’s BBM PIN ” FLORES-SANTOS stated “Okay Isn’t he FIGUEROA with you Or did he FIGUEROA already come back to Chicago ” VEGA replied “Yeah but Individual H has the ping ”69 FLORES-SANTOS stated “Okay 333E56DF Target Device 7 ” FLORES-SANTOS then asked “Okay so then what am I going to do because they law enforcement are going to be checking on me too ” VEGA replied “Nothing Just clean unload narcotics from the bus bus carrying narcotics that’s all ” Location information for Target Device 7 showed that on July 3 2014 the same day FIGUEROA was in Texas Target Device 7 was in the vicinity of 641 Grand Avenue Aurora Illinois which is the registered residence for FIGUEROA and his wife Individual H Based on this telephone location information and the conversations described below in paragraphs 249-252 LEOs believe that the user of Target Device 7 in these conversations was Individual H not FIGUEROA 69 102 248 Based on the above-described intercepted BBM communications and information obtained from LEOs in Webb County Texas regarding the July 3 2014 traffic stop of VEGA and FIGUEROA I believe that VEGA informed FLORESSANTOS about the traffic stop on FIGUEROA’s vehicle in Texas and the seizure of the $21 000 in cash from VEGA and FIGUEROA VEGA suspected that DEA was investigating members of the VEGA DTO and instructed FLORES-SANTOS to move the vehicles the VEGA DTO used to transport narcotics and narcotics proceeds from Warehouse 1 and Warehouse 2 VEGA also instructed FLORESSANTOS to remove any narcotics and narcotics proceeds left on the bus so that law enforcement will not find them VEGA indicated to FLORES-SANTOS that he and FIGUEROA were going to cease their narcotics trafficking activities for the time being VEGA also asked FLORES-SANTOS for FIGUEROA’s BBM PIN and indicated that FIGUEROA’s wife Individual H had FIGUEROA’s BBM PIN S Between July 3 2014 and July 4 2014 VEGA Instructed Individual H to Move Narcotics Proceeds Out of VEGA’s House 249 On July 3 2014 at approximately 11 21 p m Session #4541026 VEGA using Target Device 4 had a BBM conversation with Individual H who was using Target Device 7 70 In that conversation VEGA stated “Look go to the house VEGA’s residence at 1744 Shari Lane Aurora Illinois but park far away Take a safe to the tea Salude Bienstar and the white truck to Yeni They can put it away there ” Individual H asked “Should we do it now or in the morning ” VEGA replied “Today check 1 one safe to the tea the Business ” Individual H stated 70 See footnote 69 above 103 “But won’t they law enforcement be there ” VEGA stated “And the truck even if it’s empty to Yeni so it won’t be over there Vega’s residence at 1744 Shari Lane ” 250 Continuing on July 3 2014 at approximately 11 25 p m Session #4541080 VEGA using Target Device 4 had a BBM conversation with Individual H who was using Target Device 7 Individual H asked “Will they law enforcement be checking out the tea Salude Bienstar ” VEGA replied “They law enforcement are not there I don’t think so It’s a business Check it out Go talk to Individual I VEGA’s wife 71 and give her the lawyer’s number just in case ” Individual H responded “Yeah but Brenda says a detective has been parked there outside the tea Salude Bienstar for 2 days ” Individual H later asked “Well what did they law enforcement say to you Hey well it’s scary to go over there now ” VEGA replied “Nothing just in case Do it carefully Where ” Individual H stated “So then are they law enforcement following us or does the car have something narcotics or narcotics proceeds Well over there at Individual I ’s house 1744 Shari Lane Aurora Illinois ”72 VEGA replied “Park it far away ” Individual H asked “Would they law enforcement come over here to the house 641 Grand Avenue Aurora Illinois ” VEGA stated “Do it in case they go They took the money we had $21 000 seized by Webb County LEOs on July 3 2014 In case they law enforcement go tell them I do live there but we’re legalizing some cars Have the lawyer’s number just in case ” Individual H later stated “Oh okay On November 16 2010 LEOs interviewed Individual I in an unrelated investigation and Individual I identified herself as VEGA’s wife 71 72 According to utility records cable service for 1744 Shari Lane is in Individual I’s name 104 Then I’ll go to Individual I right now and see if they law enforcement don’t follow me ” VEGA stated “Don’t take the 2 of them two safes out together 1 by 1 remove the safes one at a time ” Individual H replied “Oh okay But I am going to bring it the safe with me walking And is there a camera at the house I think they law enforcement already put on there as well Don’t you think ” VEGA asked “There is a camera at which house ” Individual H replied “At the house 1744 Shari Lane Aurora Illinois with Individual I ” VEGA stated “No not at mine ” VEGA further stated “There are none Check before you do it ” Individual H asked “Are you sure because yesterday I saw a ball on the street light Or is that the way it was ” VEGA replied “Take the white truck ” Individual H stated “Okay I am going now We’ll see if I’m not followed and send me the lawyer’s number ” Later in the conversation VEGA stated “Alright the one the safe on the basement first but bring someone to help you ” 251 Continuing on July 4 2014 at approximately 12 09 a m Session #4541228 VEGA using Target Device 4 had a BBM conversation with Individual H who was using Target Device 7 Individual H stated “I am here VEGA’s residence at 1744 Shari Lane now ” VEGA stated “Take a look around Would you be able to take 1 one safe out through the garage ” Individual H replied “Okay ” VEGA further stated “Take a good look if not don’t But don’t go alone ” Individual H replied “ Individual I says tomorrow that right now we’ll put it the safe in the new car and she say early in the morning we’ll take it the safe to Jenny That way they law enforcement won’t see that we moved anything ” 105 Individual H later stated “And Individual I says 1 one safe is going to be taken by Individual I’s father Individual J ” Individual H further confirmed “Yes 1 one safe with Jeny and the other other safe with Individual J she Individual I says ” Individual H later asked “Hey did they give you guys VEGA and FIGUEROA a court date ” VEGA replied “No they are just going to send the paper for us to see if we can say where the money came from That’s all ” VEGA further stated “But they law enforcement are going to think there is more at the house Don’t you think ” Individual H replied “That’s true but there isn’t ” VEGA responded “That’s why I want to move them the safes ” Individual H stated “There is nothing at the house FIGUEROA’s residence at 641 Grand Avenue Aurora Illinois ” 252 Continuing on July 4 2014 at approximately 12 21 a m Session #4541264 VEGA using Target Device 4 had another BBM conversation with Individual H who was using Target Device 7 VEGA stated “Alright Do that move the safes and early in the morning have the safe moved in the car Give her Individual I the lawyer’s number ” Individual H responded “ Individual J is going to take the truck to his house ” VEGA asked “But is he Individual J going to stay there today ” Individual H later replied “Yes Individual J is going to stay there ” VEGA stated “That’s fine ” 253 Based on the above-described intercepted BBM communications I believe that after VEGA and FIGUEROA were stopped by Webb County LEOs on July 3 2014 VEGA contacted his sister and FIGUEROA’s wife Individual H and 106 instructed her to go to VEGA’s residence and remove two safes containing narcotics proceeds so LEOs would not find them Individual H informed VEGA that one safe would be taken to an individual named “Jeny” and the other safe to VEGA’s fatherin-law Individual J T On June 6 2014 VEGA Instructed FIGUEROA and FLORESSANTOS to Move Narcotics Proceeds to Individual J’s Residence to Conceal VEGA’s Narcotics Trafficking Activities 254 On June 6 2014 at approximately 12 13 p m Session #4455730 VEGA using Target Device 4 had a BBM conversation with FIGUEROA who was using Target Device 7 VEGA stated “Alex FIGUEROA come to warehouse 1 and take everything out in the Acura ” FIGUEROA asked “Take what out What happened ” VEGA replied “Nothing The city to going to go check Take the tickets narcotics proceeds out and work material narcotics ” FIGUEROA replied “Okay The material narcotics is outside in the white car Only the tickets narcotics proceeds ” VEGA responded “Yes That thing with the heater is fine in case they check so they can’t see what it does ” VEGA further stated “I’ll see you at Individual J’s We’ll store them narcotics proceeds there ” FIGUEROA replied “Okay ” VEGA stated “Alright then Just the money with Individual J okay Hide the material narcotics FIGUEROA replied “Okay okay ” 255 Continuing on June 6 2014 at approximately 12 15 p m Session #4455731 VEGA using Target Device 4 had a BBM conversation with FLORESSANTOS who was using BBM PIN 334DF84F FLORES-SANTOS asked “Hey what’s happening at the 1 Warehouse 1 They are working there washing the bus because Alex FIGUEROA says he is going to stop by over there to take everything 107 narcotics proceeds out ” VEGA replied “Nothing the ones from the Siry City of Aurora are going over He FIGUEROA should take out the cash the machine and the material narcotics Make sure nothing can be seen The gifts narcotics are fine in the car ” FLORES-SANTOS replied “Ok so he FIGUEROA should put everything in a box ” VEGA stated “Yes that’s fine Just make sure that they are not in sight and he FIGUEROA should take the cash over with Individual J ” 256 Continuing on June 6 2014 at 12 47 p m Session #4455853 FIGUEROA using Target Device 7 had a BBM conversation with VEGA who was using Target Device 4 FIGUEROA asked “Are you guys coming to the city Wait here and I’ll go by Individual J’s house ” 257 Continuing on June 6 2014 at approximately 1 04 p m Session #4455918 FIGUEROA using Target Device 7 had another BBM conversation with VEGA who was using Target Device 4 VEGA stated “Yes ” FIGUEROA replied “They’ll be here Individual J’s residence in 10 minutes ” VEGA responded “Okay Put everything narcotics proceeds in the trunk of the car Individual J is there I came by to drop off the batteries ”73 FIGERUOA replied “Okay ” 258 Based on location information for Target Device 4 used by VEGA and the above-described intercepted BBM communications I believe that VEGA instructed FIGUEROA and FLORES-SANTOS to remove narcotics and narcotics proceeds from Warehouse 1 while city officials inspect Warehouse 1 FIGUEROA Location information for Target Device 4 showed that at approximately 1 32 p m the device was in the vicinity of Individual J’s residence at 1210 Superior Street Aurora Illinois 73 108 informed VEGA that the narcotics are already outside of Warehouse 1 in a white vehicle VEGA then instructed FIGUEROA and FLORES-SANTOS to take the narcotics proceeds to Individual J’s residence for storage and safe-keeping during the city’s inspection of Warehouse 1 Location information for Target Device 7 used by FIGUEROA showed that on June 6 2014 at approximately 1 37 p m Target Device 7 was in the vicinity of Individual J’s residence at 1210 Superior Street Aurora Illinois U On October 29 2014 VEGA Resumed His Narcotics Trafficking Activities and Arranged with MARTINEZ for the Delivery of Heroin to SANCHEZ 259 On October 29 2014 at approximately 4 13 p m Session #4787726 VEGA using Target Device 9 had a conversation with MARTINEZ who was using Target Device 1 74 During that conversation MARTINEZ asked “What’s up Cousin How is everything going over there Chicago Illinois ” VEGA responded “Fine let me see if they’re VEGA’s narcotics couriers going to unload them heroin already ” MARTINEZ responded “Okay ” VEGA responded “Look get a hold of a number telephone number for Paisa SANCHEZ for me so the guy VEGA’s narcotics courier can give it heroin to him SANCHEZ ” The identification of VEGA as the user of Target Device 9 is based on the following a VEGA’s use of the name “Paisa” in Session #4787726 which VEGA previously used on numerous occasions to refer to SANCHEZ a wholesale narcotics customer of the VEGA DTO and b location information for Target Device 9 showed that on October 27 2014 at approximately 5 10 p m Target Device 9 was in the vicinity of W North and N Kedzie Avenues in Chicago Illinois LEOs subsequently observed a white Dodge truck in that area At approximately 5 27 p m LEOs observed VEGA driving the white Dodge truck and VEGA was the sole occupant in the vehicle 74 109 260 Continuing on October 29 2014 at approximately 4 39 p m Session #4787727 VEGA using Target Device 9 had a conversation with MARTINEZ who was using Target Device 1 During that conversation MARTINEZ asked “Cousin or could the guy VEGA’s narcotics courier not send them heroin to my buddy the Mechanic Individual A And my buddy Individual A would receive them heroin over there It would be useful for them VEGA’s narcotics courier to give him an oil change or something like check out the truck for him What do you think about that and then that’s that I will give my buddy Individual A a little something money for expenses ” VEGA responded “No I have the mechanic SANCHEZ pick them heroin up ” Just have Paisa MARTINEZ responded “Yeah I know Cousin What I’m asking is if he VEGA’s narcotics courier could bring them heroin to the mechanic Individual A mine the heroin due to MARTINEZ and Paisa SANCHEZ could pick them heroin up there ” VEGA replied “No have him SANCHEZ pick them heroin up directly It’s a new guy VEGA’s new narcotics courier ” MARTINEZ responded “Okay ” VEGA stated “Have him SANCHEZ go all the way to his VEGA’s narcotics courier’s house He’s VEGA’s narcotics courier trustworthy ” MARTINEZ responded “Okay ” VEGA stated “The thing is I’m not going to go right there The guy is going to do everything ” MARTINEZ responded “Yeah that’s fine ” VEGA stated “Have a number SANCHEZ’s telephone number ready so I can give it to my cousin VEGA’s narcotics courier ” 110 261 In the same BBM conversation MARTINEZ later asked “Cousin how much are you going to leave sell them heroin at for me At 44 $44 000 per kilogram of heroin as we had agreed ” kilogram of heroin VEGA responded “At 45 $45 000 per Dude it comes out to be more expensive bringing them smuggling the heroin to the Chicago area this way ” MARTINEZ responded “Get the fuck out of here Nothing will come out of it profit from the sale of heroin for you then ” VEGA stated “At 45 $45 000 per kilogram of heroin like always ” MARTINEZ responded “Alright ” 262 Based on the above-described intercepted BBM communications I believe that VEGA along with MARTINEZ agreed to distribute additional amounts of heroin in the Chicago area to SANCHEZ VEGA requested SANCHEZ’s telephone number from MARTINEZ in order to coordinate the delivery of the heroin from VEGA’s narcotics courier to SANCHEZ MARTINEZ requested that VEGA deliver the heroin to Individual A’s garage but VEGA disagreed and insisted that SANCHEZ pick up the heroin directly from his new narcotics courier IV PROBABLE CAUSE FOR THE REQUESTED SEARCH WARRANTS 263 The facts in this Affidavit also establish probable cause in support of a warrant to search the Subject Premises identified below as further described below and in Attachments A-1 through A-4 corresponding to the premises which also contain pictures of the premises and to seize the records documents and other items in the Attachment B corresponding to the Subject Premises For each computer that the government searches the government will follow the Computer Search Protocol outlined in the Addendum to the corresponding Attachment B 111 a 1691 Town Center #105 Aurora Illinois the business Salude b 1201 Superior Street Aurora Illinois Individual J’s residence c 2241 Bienstar N Monitor Avenue Chicago Illinois ROBERTO SANCHEZ’s residence d 2404-2406 New Haven Court Rockford Illinois ISAIAS MANDUJANO’s residence 264 The facts set forth in this Affidavit establish probable cause to believe that records documents and items as further described in the Attachment B corresponding to each of the premises constitute fruits instrumentalities and or evidence of a conspiracy to distribute and possess with intent to distribute narcotics and the distribution of and possession of with intent to distribute narcotics in violation of 21 U S C §§ 841 and 846 and further that a search of the premises will result in the discovery of such records documents and items 265 As a result of my law enforcement experience and this investigation I am familiar with the ways in which the members of the narcotics organization conduct their business including but not limited to their methods of importing and distributing narcotics their use of numerical codes and code words to conduct their transactions in secret and their methods of laundering the proceeds of their narcotics trafficking Through my experience and my discussions with other experienced LEOs I am familiar with the methods schemes and operations used by major narcotics traffickers and know 112 a Narcotics traffickers commonly place assets in names other than their own to avoid detection of these assets by law enforcement b Even though assets may be in other persons’ names narcotics traffickers continue to use those assets and exercise dominion and control over the assets c Narcotics traffickers keep books records receipts notes ledgers and other papers relating to the transportation ordering sale and distribution of illegal drugs and these documents may be in code Because narcotics traffickers commonly “front” drugs meaning they will provide illegal drugs to their customers on consignment and the customers will pay for it at a later date narcotics traffickers’ books records receipts notes ledgers etc are commonly maintained where the illegal drug traffickers have ready access to them i e homes offices and automobiles d Narcotics traffickers do not frequently and or routinely dispose of or discard their ledgers documents and records related to the distribution of narcotics for the following reasons i such records could be obtained by LEOs during a search of a trafficker’s trash a practice known as a “trash pull” which narcotics traffickers are often aware of ii such records contain information about narcotics transactions and arrangements for credit transactions known as “fronting” and transactions on consignments all of which require future payment by customers for narcotics obtained from the narcotics trafficker and for which the narcotics trafficker will need to keep ongoing records of payment activity much the 113 same way a normal business operator will keep track of credit transactions and iii narcotics traffickers will frequently keep names and contact information for their associates suppliers and customers written down for at least as long the narcotics trafficking relationship exists and possibly into the future in the event that the narcotics trafficker has reason to obtain narcotics from the supplier in the future or has reason to contact the customer in the future should additional narcotics become available e Narcotics traffickers commonly maintain records of illegal drug transactions sources and customers in secure locations within their residences offices vehicles garages storage buildings safety deposit boxes and other locations including stash houses for ready access and also to conceal such items from law enforcement f Narcotics traffickers commonly conceal large amounts of currency financial instruments precious metals jewelry and other items of value and or proceeds of drug transactions and evidence of financial transactions relating to obtaining transferring secreting or spending large sums of money made from engaging in illegal drug trafficking activities in their residences offices vehicles garages storage buildings automobiles and safety deposit boxes g Narcotics traffickers commonly keep addresses or telephone numbers in books papers pagers computers tablets or cellular phones and often have multiple cellular phones and pagers corresponding to names addresses 114 and or telephone numbers for their associates in the trafficking organization even if stated items may be in code h Narcotics traffickers frequently take or cause to be taken photographs of themselves their associates their property and their product and that these traffickers usually maintain these photographs in their residences computers tablets and cellular phones i Narcotics traffickers commonly amass large monetary proceeds from the sale of illegal drugs and they attempt to legitimize these profits by utilizing foreign and domestic banks and their attendant services including securities cashier’s checks money drafts letters of credit brokerage houses real estate shell corporations business fronts and other methods Narcotics traffickers commonly maintain proceeds of narcotics trafficking activity and evidence of financial transactions used to legitimize these profits in their residences vehicles offices garages storage buildings automobiles and safety deposit boxes j Narcotics traffickers sometimes store documents and records relating to their drug supplies customers money and assets on computer hardware and software the contents of which frequently yield evidence of drug trafficking k Courts have found that unexplained wealth is probative evidence of criminal activity in which transactions involving large amounts of cash and high profit margins are common including trafficking in controlled substances l Narcotics traffickers frequently conceal and store items related to their narcotics trafficking and money laundering within safes footlockers boxes 115 containers and other hidden compartments including hidden compartments within vehicles and within places that they own or over which they exercise control and m During the course of residential searches I and LEOs have also found items of personal property that tend to identify the person or persons in residence occupancy control or ownership of the premises including such items as canceled mail deeds leases rental agreements photographs personal telephone books diaries utility telephone and internet bills or other mail statements identification documents and keys A The Business Salude Bienstar Located at 1691 Town Center #105 Aurora Illinois 266 1691 Town Center #105 Aurora Illinois is the lower-level unit on the northeast corner of a commercial two-story structure with multi-colored siding and white trim This commercial structure which is located on the south side of Town Center Street in Aurora Illinois contains business and retail spaces on the lower level and condominium units on the second floor The numbers “1691” are black in color and affixed on the third deck post from the east corner of the commercial structure Suite 105 of the commercial structure has the name “Salude Bienstar ” and has blue siding with white trim There is a white door with a glass window at the northeast corner of the suite This door is the principle entrance to Salude Bienstar The numbers “105” are white in color and are affixed on the glass above the door 267 According to the lease agreement for Salude Bienstar VEGA’s wife Individual J is one of the tenants of the business which is described in the lease 116 agreement as an “Herbal Life Office ” As set forth previously in this Affidavit on July 4 2014 a day after Webb County LEOs seized approximately $21 000 from VEGA and FIGUEROA in Texas VEGA instructed Individual H VEGA’s sister and FIGUEROA’s wife to move narcotics proceeds out of VEGA’s residence at 1744 Shari Lane Aurora Illinois to Salude Bienstar for safe-keeping In addition throughout the investigation LEOs have observed VEGA and FIGUEROA at Salude Bienstar For example on June 3 2014 approximately seven minutes after VEGA provided FIGUEROA the telephone number of the individual who was to deliver $600 000 in narcotics proceeds to FIGUEROA see paragraph 163 above LEOs observed VEGA FIGUEROA and FLORES-SANTOS meet in front of Salude Bienstar The next day FIGUEROA and BETANCOURT picked up $600 000 of narcotics proceeds from RODRIGUEZ B Individual J’s Residence Located at 1210 Superior Street Aurora Illinois 268 1210 Superior Street Aurora Illinois is a one-story single family residence located on the north side of Superior Street and is the fourth structure east of Loucks Street in Aurora Illinois The residence at blue siding white trim a grey-shingled roof and black bars over the front windows On the south side of the structure there are steps which lead to an open porch on the first floor of the residence The numbers “1210” are black in color and are affixed on the white trim above the porch On the west side of the residence there is a concrete driveway which leads to a wooden fence Behind the wooden fence at the rear of the lot is a two-car garage with white siding dark trim and a south-facing white garage door 117 269 According to law enforcement and public records Individual J is the registered owner of 1210 Superior Street Aurora Illinois In addition information obtained from law enforcement databases show that Individual J is a relative of Individual I VEGA’s wife On September 20 2013 LEOs conducted a trash pull at the residence and found various documents and two pill bottles addressed to Individual J at 1210 Superior Street Aurora Illinois As set forth above on June 6 2014 VEGA instructed FIGUEROA to move narcotics proceeds from Warehouse 1 and take them to Individual J’s residence In addition on July 4 2014 Individual H informed VEGA that one safe containing narcotics proceeds would be moved to Individual J’s residence Based on my training experience and participation in this investigation I believe that the VEGA DTO uses 1210 Superior Street Aurora Illinois to store proceeds of drug transactions and other evidence regarding the DTO’s narcotics trafficking activities As such there is probable cause to believe that safes or other containers containing narcotics proceeds and that records relating to the VEGA DTO’s narcotics trafficking activities are maintained at this location C ROBERTO SANCHEZ’s Residence Located at 2241 N Monitor Avenue Chicago Illinois 270 2241 N Monitor Avenue Chicago Illinois is a one-story single family residence with white siding over tan brick white trim and a black shingled roof The residence is located on the east side on Monitor Ave between W Belden Ave and W Grand Ave in Chicago Illinois On the west side of the residence there are concrete stairs which lead to a storm door with dark bars and small windows The 118 storm door leads to a white door with small window which is the principle entrance to the residence The numbers “2241” are black in color and are affixed on white trim above the door to the residence At the rear of the lot there is a detached twocar garage with tan siding white trim and an east-facing white garage door 271 According to public records SANCHEZ is one of the registered owners of 2241 N Monitor Avenue Chicago Illinois The investigation has shown that SANCHEZ purchase from the VEGA DTO multi-kilogram quantities of heroin which he then distributes to his own narcotics customers In addition on March 27 2014 LEOs observed a Jeep parked in front of 2241 N Monitor Avenue As discussed above on March 28 2014 SANCHEZ driving this same Jeep delivered narcotics proceeds to Individual A on MARTINEZ’s behalf In addition according to Illinois Secretary of State records SANCHEZ is the president and registered agent for R Sanchez Landscaping Inc which has a registered address of 2241 N Monitor Avenue Chicago Illinois Based on my training and experience given that SANCHEZ is a wholesale narcotics customer of the VEGA DTO and operates a business there is probable cause to believe that at SANCHEZ’s main residence he may keep records relating to his narcotics trafficking and money laundering activities either on a computer or in other form D ISAIAS MANDUJANO’s Residence Located at 2404-2406 New Haven Court Rockford Illinois 272 2404-2406 New Haven Court Rockford Illinois is a one-story two- family residence with light-colored brick vinyl siding and a tan-colored roof The residence is located on the northwest section of New Haven Court in the cul-de-sac 119 portion of the street The structure has two white south-facing garage doors The numbers “2406” are black in color and affixed on the white trim above the garage door which is on the southeast side of the structure Next to the garage door marked “2406 ” there are three concrete steps leading to a white door which is the main entrance for the “2406” side of the structure The numbers “2404” are black in color and affixed on the white trim above the garage door which is on the southwest side of the structure Next to the garage door marked “2404 ” there are three concrete steps leading to a white door which is the main entrance for the “2404” side of the structure 273 According to information obtained from law enforcement databases and tax records from the Treasurer’s Office of Winnebago County Illinois 75 24042406 New Haven Court is a two-family residence on one parcel of land The owner of that entire parcel is ISAIAS MANDUJANO with an address of 2404 New Haven Court Rockford Illinois According to law enforcement databases the utilities for 2404-2406 New Haven Court are registered in MANDUJANO’s name MANDUJANO’s address on his Illinois driver’s license is listed as 2404 New Haven Court Rockford Illinois The Lexus which MANDUJANO drove during the April 29 2014 heroin transaction with SANCHEZ is registered to MANDUJANO at 2406 New Haven Court Rockford Illinois On December 2 2014 LEOs observed MANDUJANO enter 2406 New Haven Court Based on my training and experience given that MANDUJANO is a wholesale narcotics customer of 75 Rockford is in Winnebago County Illinois 120 SANCHEZ and has his own set of customers to whom he re-distributes the heroin there is probable cause to believe that at MANDUJANO’s main residence he may keep records relating to his narcotics trafficking activities and money laundering activities either on a computer or in other form SPECIFICS REGARDING SEARCHES OF COMPUTER SYSTEMS 280 Based upon my training and experience and the training and experience of specially trained computer personnel whom I have consulted searches of evidence from computers commonly require agents to download or copy information from the computers and their components or remove most or all computer items computer hardware computer software and computer-related documentation to be processed later by a qualified computer expert in a laboratory or other controlled environment This is almost always true because of the following a Computer storage devices can store the equivalent of thousands of pages of information Especially when the user wants to conceal criminal evidence he or she often stores it with deceptive file names This requires searching authorities to examine all the stored data to determine whether it is included in the warrant This sorting process can take days or weeks depending on the volume of data stored and it would be generally impossible to accomplish this kind of data search on site b Searching computer systems for criminal evidence is a highly technical process requiring expert skill and a properly controlled environment The 121 vast array of computer hardware and software available requires even computer experts to specialize in some systems and applications so it is difficult to know before a search which expert should analyze the system and its data The search of a computer system is an exacting scientific procedure which is designed to protect the integrity of the evidence and to recover even hidden erased compressed password-protected or encrypted files Since computer evidence is extremely vulnerable to tampering or destruction which may be caused by malicious code or normal activities of an operating system the controlled environment of a laboratory is essential to its complete and accurate analysis 281 In order to fully retrieve data from a computer system the analyst needs all storage media as well as the computer The analyst needs all the system software operating systems or interfaces and hardware drivers and any applications software which may have been used to create the data whether stored on hard disk drives or on external media 282 In addition a computer its storage devices peripherals and Internet connection interface may be instrumentalities of the crimes and are subject to seizure as such if they contain contraband or were used to carry out criminal activity PROCEDURES TO BE FOLLOWED IN SEARCHING COMPUTERS 283 The warrant sought by this Application does not authorize the “seizure” of computers and related media within the meaning of Rule 41 c of the Federal Rules of Criminal Procedure Rather the warrant sought by this Application 122 authorizes the removal of computers and related media so that they may be searched in a secure environment 284 With respect to the search of any computers or electronic storage devices seized from the locations identified in Attachments A-1 through A-4 hereto the search procedure of electronic data contained in any such computer may include the following techniques the following is a non-exclusive list and the government may use other procedures that like those listed below minimize the review of information not within the list of items to be seized as set forth herein a examination of all of the data contained in such computer hardware computer software and or memory storage devices to determine whether that data falls within the items to be seized as set forth herein b searching for and attempting to recover any deleted hidden or encrypted data to determine whether that data falls within the list of items to be seized as set forth herein any data that is encrypted and unreadable will not be returned unless law enforcement personnel have determined that the data is not 1 an instrumentality of the offenses 2 a fruit of the criminal activity 3 contraband 4 otherwise unlawfully possessed or 5 evidence of the offenses specified above c surveying various file directories and the individual files they contain to determine whether they include data falling within the list of items to be seized as set forth herein 123 d opening or reading portions of files in order to determine whether their contents fall within the items to be seized as set forth herein e scanning storage areas to discover data falling within the list of items to be seized as set forth herein to possibly recover any such recently deleted data and to search for and recover deliberately hidden files falling within the list of items to be seized and or f performing key word searches through all storage media to determine whether occurrences of language contained in such storage areas exist that are likely to appear in the evidence described in the Attachment B corresponding to the Subject Premises 285 Any computer systems and electronic storage devices removed from the premises during the search will be returned to the premises within a reasonable period of time not to exceed 30 days or unless otherwise ordered by the Court V PROBABLE CAUSE FOR THE REQUESTED VEHICLE SEIZURE WARRANTS 286 Vehicles used by SANCHEZ to facilitate drug transactions As discussed above SANCHEZ used i a Jeep Wrangler bearing Illinois license 80028FF to deliver narcotics proceeds to Individual A on March 28 2014 and April 7 2014 see paragraphs 53 and 62 and ii a Nissan sedan bearing Illinois license 78389FF to deliver one kilogram of heroin to MANDUJANO on April 29 2014 see paragraphs 124-126 As such there is probable cause to believe that upon conviction of SANCHEZ the 2008 silver Jeep Wrangler bearing Illinois license 80028FF with a VIN of 1J8GA69108L586356 and the grey Nissan bearing Illinois license 78389FF with a VIN of 1N4AA51E19C803619 both of which are registered 124 to ROBERTO SANCHEZ 1301 Auburn Court Rockford Illinois will be subject to forfeiture pursuant to Title 21 United States Code Sections 853 a 2 and f 287 Vehicles used by FIGUEROA to facilitate drug transactions As discussed above FIGUEROA used i an Acura bearing Illinois license N773755 to deliver $263 000 in narcotics proceeds to CS-1 on September 5 2013 see paragraphs 33-34 ii an Acura SUV bearing Illinois license E24694476 to pick up $47 700 in narcotics proceeds from SANCHEZ on April 27 2014 see paragraphs 8286 and to pick up from Individual A on April 16 2014 the Chrysler Pacifica which was used to transport approximately 31 kilograms of heroin on June 10 2014 see paragraph 74 iii a Ford Edge bearing Illinois license V333147 prior to picking up the Chrysler Pacifica with BETANCOURT on June 4 2014 to pick up narcotics proceeds from RODRIGUEZ see paragraph 164 and prior to delivering approximately 25 kilograms of heroin to RODRIGUEZ on June 7 2014 see paragraph 201 and iv a white Acura bearing Illinois license V464033 prior to delivering approximately 31 kilograms of heroin to Individual C on June 10 2014 see paragraph 225 As such there is probable cause to believe that upon conviction of FIGUEROA i the Acura bearing Illinois license N773755 with a Vehicle Identification Number of 19UYA42621A027383 and ii the Ford Edge bearing Illinois license V333147 with a Vehicle Identification Number of 2FMDK36C17BB29755 both of which are registered to Individual H 641 Grand Avenue Aurora Illinois as well as iii the Acura SUV bearing Illinois license 76 On April 27 2014 the Acura SUV had Illinois license V331444 125 E246944 with a Vehicle Identification Number of 2HNYD18681H525448 registered to Individual K 803 Magnolia Drive North Aurora Illinois and iv the white Acura bearing Illinois license V464033 with a Vehicle Identification Number of 2HNYD18926H536138 registered to ALEXANDER FIGUEROA 641 Grand Avenue Aurora Illinois will be subject to forfeiture pursuant to Title 21 United States Code Sections 853 a 2 and f 288 Vehicle used by VEGA to facilitate a drug transaction As discussed above VEGA used a white Dodge truck bearing Illinois license 78205X to conduct counter surveillance at Warehouse 2 on June 1 2014 while FLORESSANTOS unloaded heroin from a passenger bus at the warehouse see paragraphs 155-159 As such there is probable cause to believe that upon conviction of VEGA the 2007 white Dodge truck bearing Illinois license 78205X with a Vehicle Identification Number of 1D7HU16P07J574755 registered to Individual J 1210 Superior Street Aurora Illinois will be subject to forfeiture pursuant to Title 21 United States Code Sections 853 a 2 and f 289 Vehicle used by MANDUJANO to facilitate a drug transaction As discussed above on April 29 2014 MANDUJANO used a silver Lexus bearing Illinois license R663521 to meet SANCHEZ who provided MANDUJANO with one kilogram of heroin see paragraphs 124-126 As such there is probable cause to believe that upon conviction of MANDUJANO the silver 2007 Lexus bearing Illinois license R663521 with a Vehicle Identification Number of JTHBJ46G472118969 registered to ISAIAS MANDUJANO 2406 New Haven 126 Court Rockford Illinois will be subject to forfeiture pursuant to Title 21 United States Code Sections 853 a 2 and f 290 Based on the foregoing there is probable cause to believe that the above-described vehicles will be subject to forfeiture upon conviction of SANCHEZ FIGUEROA and VEGA for violations of Title 21 United States Code Section 846 conspiracy to possess with intent to distribute and to distribute heroin and of MANDUJANO for a violation of Title 21 United States Code Section 841 a 1 possession with intent to distribute heroin In order to ensure the availability of the vehicles for forfeiture Title 21 United States Code Section 853 e authorizes the entry of a restraining order or any other action necessary to preserve the property Title 21 United States Code Section 853 e states in the same manner as provided for a search warrant a seizure warrant may issue when the property would in the event of conviction be subject to forfeiture and a restraining order may not be sufficient to assure the availability of the property for forfeiture The government seeks a seizure warrant under Section 853 f because a restraining order or any other action is not sufficient to assure the availability of the abovedescribed vehicles for forfeiture Courts have long recognized the unique circumstances involved in seizing vehicles due to their inherent mobility In Florida v White 526 U S 559 1999 the Supreme Court found that a warrantless seizure did not violate the Fourth Amendment where there was probable cause to believe that the automobile was subject to forfeiture because movable contraband may be “spirited away ” In addition in the instant matter any restraining order 127 would not be issued to an independent third party such as a bank or other lienholder but to the registered owners of the Subject Vehicles who are either the defendants or individuals related to the defendants 291 Furthermore in my experience I know that motor vehicles are easily transferred or hidden thereby making them difficult to locate Moreover I am aware that the appearance of a motor vehicle can be altered or it can be concealed in a garage or storage area making it difficult if not impossible to find for the purpose of forfeiture proceedings In addition motor vehicles can be transported outside the district further increasing the potential unavailability of these motor vehicles for forfeiture in the event of conviction Furthermore I know that unless a motor vehicle is seized it can be difficult to preserve the value of the motor vehicle for forfeiture purposes because financial obligations relating to the vehicle including insurance payments and loan obligations are not satisfied when an owner is notified that it is likely that his property will be subject to forfeiture VI CONCLUSION 292 Based on the foregoing it is Your Affiant’s belief that there is probable cause to believe as follows a Beginning no later than August 2013 and continuing to in or about November 2014 in the Northern District of Illinois and elsewhere defendants PABLO VEGA CUEVAS ARTURO MARTINEZ ALEXANDER FIGUEROA ELISEO BETANCOURT-PEREIRA WILFREDO FLORES-SANTOS ROBERTO SANCHEZ and JOSE RODRIGUEZ did conspire with each other and with others known and unknown to knowingly and intentionally possess with intent 128 to distribute and distribute a controlled substance namely 1 kilogram or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance in violation of 21 U S C § 841 a 1 all in violation of 21 U S C § 846 b On or about April 29 2014 in the Northern District of Illinois ISAIAS MANDUJANO did knowingly and intentionally possess with intent to distribute a controlled substance namely 100 grams or more of a mixture and substance containing a detectable amount of heroin a Schedule I Controlled Substance in violation of 21 U S C § 841 a 1 293 Based on the foregoing I believe that there is probable cause in support of a search warrant for the Subject Premises identified below for evidence of the commission of conspiracy to possess with intent to distribute and to distribute a controlled substance in violation of 21 U S C § 846 and possession with the intent to distribute a controlled substance in violation of 21 U S C § 841 a 1 a 1691 Town Center #105 Aurora Illinois the business Salude b 1201 Superior Street Aurora Illinois Individual J’s residence c 2241 Bienstar N Monitor Avenue Chicago Illinois ROBERTO SANCHEZ’s residence d 2404-2406 New Haven Court Rockford Illinois ISAIAS MANDUJANO’s residence 129 294 Based on the foregoing I believe that there is probable cause in support of the seizure of the Subject Vehicles listed below because the Subject Vehicles represent property used and intended to be used in any manner or part to commit and to facilitate the commission of conspiracy to possess with intent to distribute and to distribute a controlled substance in violation of 21 U S C § 846 and possession with intent to distribute a controlled substance in violation of 21 U S C § 841 a 1 a A 2008 silver Jeep Wrangler bearing Illinois license 80028FF with a Vehicle Identification Number of 1J8GA69108L586356 registered to ROBERTO SANCHEZ 1301 Auburn Court Rockford Illinois b A 2009 grey Nissan bearing Illinois license 78389FF with a Vehicle Identification Number of 1N4AA51E19C803619 registered to ROBERTO SANCHEZ 1301 Auburn Court Rockford Illinois c A 2001 maroon Acura bearing Illinois license N773755 with a Vehicle Identification Number of 19UYA42621A027383 registered to Individual H 641 Grand Avenue Aurora Illinois d A 2007 black Ford Edge bearing Illinois license V333147 with a Vehicle Identification Number of 2FMDK36C17BB29755 registered to Individual H 641 Grand Avenue Aurora Illinois e A 2001 Acura bearing Illinois license E246944 with a Vehicle Identification Number of 2HNYD18681H525448 registered to Individual H 641 Grand Avenue Aurora Illinois 130 f Vehicle A 2006 white Acura bearing Illinois license V464033 with a Identification Number of 2HNYD18926H536138 registered to ALEXANDER FIGUEROA 641 Grand Avenue Aurora Illinois g A 2007 white Dodge truck bearing Illinois license 78205X with a Vehicle Identification Number of 1D7HU16P07J574755 registered to Individual J 1210 Superior Street Aurora Illinois h A 2007 silver Lexus bearing Illinois license R663521 with a Vehicle Identification Number of JTHBJ46G472118969 registered to ISAIAS MANDUJANO 2406 New Haven Court Rockford Illinois FURTHER AFFIANT SAYETH NOT ADAM J STACHECKI Special Agent Drug Enforcement Administration Sworn and subscribed to before me on this 8th day of December 2014 SIDNEY I SCHENKIER United States Magistrate Judge 131