Full text of "La Familia Indictment"

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2013 JUL {8 PH 2-kk 







UNITED STATES DISTRICT COURT 







FOR THE CENTRAL DISTRICT OF CALIFORNIA 







UNITED STATES OF AMERICA, 

Plaintiff, 







February 2013 Grand Jury 



cr no. 13 1 ;-; 



INDICTMENT 







V. 







JOSE RODRIGUEZ -LANDA, 



aka "Fox," 



aka "Fox~Tapia, ". 



aka "Jose Rodriguez-Tapia, " 



aka "Alejandro Tapia," 

MICHAEL MORENO, 



aka "Boo," 

FRED ANTHONY MONTOYA, 



aka "Fast Freddy," 

FREDDIE MONTES, 



aka "Fredrico Monte s," 

LUIS GERARDO VEGA, 



aka "Little," 



aka "Little One," 

MANUEL LARRY JACKSON, 



aka "Cricket," 

JIMMY RUBEN SOTO, 



aka "Rube," 



aka "Old Man," 

RAYMOND LOZANO, 

EFRAIN ISAK ROSALES, 



aka "Tucan, " 



aka "Toucan, " 

SONIA APODACA, 



aka "Shorty," 

CLAUDIA GARCIA,. 



aka "Giggles," 







[21 U.S.C. § 846: Conspiracy 

to Possess with Intent to 

Distribute and to Distribute 

Controlled Substances; 21 U.S.C. 

§§ 841 (a) (1) , (b) (1) (A) (viii) : 

Possession with Intent to 

Distribute and Distribution of 

Methamphetamine ; 21 U.S.C. 

§§ 841(a) (1) , (b) (1) (B) (vii) : 

Possession with Intent to 

Distribute Marijuana; 18 U.S.C. 

§ 2(a): Aiding and Abetting; 21 

U.S.C. § 853: Criminal 

Forfeiture] 







ADAM RIOS, 



aka "Blanco," 

aka "Little Blanco," and- 

OMAR HUGO ROBLES, 



Defendants . 







The Grand Jury charges: 



GENERAL ALLEGATIONS 

At all times relevant to r this Indictment, the following 

applies : 



1. JOSE RODRIGUEZ -LANDA, also known as ("aka") "Fox," aka 

"Fox-Tapia," aka "Jose Rodriguez -Tapia, " aka "Alejandro Tapia" 

( "RODRIGUEZ -LANDA" ) , MICHAEL MORENO, aka "Boo" ("MORENO"), FRED 

ANTHONY MONTOYA, aka "Fast Freddy" ("MONTOYA"), LUIS GERARDO 

VEGA, aka "Little," aka "Little One" ("VEGA"), MANUEL LARRY' 

JACKSON, aka "Cricket" ("JACKSON"), JIMMY RUBEN SOTO, aka 

"Rube," aka "Old Man" ("SOTO"), RAYMOND LOZANO ("LOZANO"), SONIA 

APODACA, aka "Shorty" ("APODACA"), CLAUDIA GARCIA, aka "Giggles" 

("GARCIA"), and others known and unknown to the Grand Jury, were 

members and/or associates of the "Mexican Mafia" or. "EME, " which 

is Spanish for the letter "M." The Mexican Mafia is an 

organized group of individuals that controls much of the 

distribution of drugs and other criminal activities within 

California state prisons, California county jails, and some 

federal prisons. In addition, outside of prison, the Mexican 

Mafia exercises control over the criminal activities, including 

drug trafficking, of Hispanic street gangs throughout Southern 

California and elsewhere. 







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2. Members of the Mexican Mafia generally are more senior 

members of local street gangs in the Southern California area 

and elsewhere. The majority of Mexican Mafia members and 

associates are incarcerated in California prisons and jails or 

in federal prison. Most incarcerated Mexican Mafia members and 

associates are housed in high- security prisons, including 

Pelican Bay State Prison (referred to in Spanish coded language 

as "La Playa Azul" or "La Playa" ) , the United States 

Penitentiary in Lewisburg, Pennsylvania, and the Administrative 

Maximum Facility at the United States Penitentiary in Florence, 

Colorado. 



3. Mexican Mafia members and associates are generally 

able to organize and direct the activities of other Hispanic 

prison inmates, including members and associates of Southern 

California based Hispanic street gangs, who comprise a 

significant percentage of the inmates within the California 

penal system. Indeed, Mexican Mafia members and associates 

wield such power among the prison population that they are able 

to order that acts of violence be carried out against other 

prison inmates and against street gang members outside of 

prison. Because of the substantial power they wield both inside 

and outside of prison, Mexican Mafia members and associates are 

able to provide protection and status to other inmates, 

including inmates who are not members of Hispanic street gangs. 

Generally, Mexican Mafia members and associates require that 

inmates who are not members of. Hispanic street gangs provide 

services and/or payments in exchange for protection within 

prison or jail . 



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4. Street gangs controlled by and/or affiliated with the 

Mexican Mafia generally include the number "13" in their gang, ■ 

name, with the number "13" representing the thirteenth letter of 

the alphabet, the letter "M." Members and associates of street 

gangs controlled by and/or affiliated with the Mexican Mafia 

must pay "taxes" to members and associates of the Mexican Mafia 

in order to be permitted to maintain control over their 

territories in order to distribute drugs and engage in other 

criminal activity, and in order to ensure their protection once 

gang members enter California prisons or local jails. Due to 

their control over Hispanic street gangs, Mexican Mafia members 

and associates are able to direct the drug trafficking 

activities of Hispanic street gangs, including what territories 

or areas they are permitted to distribute drugs. Mexican Mafia 

members and associates also provide permission to distribute 

drugs and protection inside and outside prison to other criminal 

groups who provide them with services' and/or payments, including 

Mexico-based drug cartels . 



5. Since the majority of Mexican Mafia members are 

incarcerated, Mexican Mafia members and associates in prisons or 

jails send instructions to local street gangs and other Mexican 

Mafia members and associates, both inside and outside prison and 

jail, via telephone calls, prison- system e-mails, letters, 

including letters mailed to fictitious individuals, and 

"kites," which are notes smuggled by prisoners. Mexican Mafia 

members and associates generally use coded language in order to 

conceal the true nature of their discussions with and 

instructions to criminal associates. In order to pass on 



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instructions and information from prison and jail, Mexican Mafia 

members and associates often rely on trusted female associates 

(known as "secretaries") who communicate with the incarcerated 

Mexican Mafia members and associates and relay their 

instructions to others. These secretaries are often treated as 

respected criminal figures by members of street gangs controlled 

by and/or affiliated with the Mexican Mafia. 



6. Defendants FREDDIE MONTES, aka "Freddie Montes" ("F. 

MONTES"), EFRAIN ISAK ROSALES , aka "Tucan," aka "Toucan" 



( "ROSALES" ) , ADAM RIOS, aka "Blanco," aka "Little Blanco" 

("RIOS"), OMAR HUGO ROBLES ("ROBLES"), co- conspirator Hugo 

Montes ("H. Montes"), and others known and unknown to the Grand 

Jury, were members and associates of "La Familia Michocana" drug 

cartel and its successor, the "Knights Templar" drug cartel (in 

Spanish, "Los Caballeros Templarios") (hereinafter, both 

referred to as "La Familia"). La Familia is a large-scale drug 

cartel and organized crime syndicate based in the Mexican state 

of Michoacan, Mexico. La Familia is responsible for the 

trafficking of hundreds of thousands of pounds of controlled 

substances, including me thamphet amine, from. Mexico into the 

United States, and it controls drug trafficking routes 

throughout Mexico for the purpose of smuggling drugs into the 

United States.. La Familia has been previously allied with other 

major drug cartels in Mexico to augment its power and influence 

in the drug trade. 



7. The above -stated, paragraphs are hereby incorporated by 



reference in every count of this Indictment. 







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COUNT ONE 

[21 U.S.C. § 846] 

A. OBJECTS OF THE CONSPIRACY 



Beginning on a date unknown, but no later than in or around 

January 2 011, and continuing to on or about July 18, 2013, in 

Los Angeles and Orange Counties, within the Central District of 

California, and elsewhere, defendants RODRIGUEZ - LANDA, MORENO, 

MONTOYA, F. MONTES, VEGA, JACKSON, SOTO, LOZANO, ROSALES, 

APODACA, GARCIA, RIOS, and ROBLES, co- conspirator H. Montes, and 

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

with each other to knowingly and' intentionally commit, aid and 

abet the commission of, and willfully cause the commission of, 

the following offenses : 



1. To possess with intent to distribute at least 50 grams 

of methamphetamine , or at least 500 grams of a mixture or 

substance containing a detectable amount of methamphetamine , a 

Schedule II controlled substance, in violation of Title 21, 

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



2. To distribute at least 50 grams of methamphetamine , . or 

at least 500 grams of a mixture or substance containing a 

detectable amount of methamphetamine, a Schedule II controlled 

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

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



3. To possess with intent to distribute at least 100 

kilograms of a mixture or substance containing a detectable 

amount of marijuana, a Schedule I controlled substance, in 

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

and 841(b) (1) (B) (vii) ; and . 



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4. To distribute at least 100 kilograms of a mixture or 

substance containing a detectable amount of marijuana, a 

Schedule I controlled substance, in violation of Title 21, 

United States Code, Sections 841(a) (1) and 841(b) (1) (B) <vii) . 

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



ACCOMPLISHED 



The objects of the conspiracy were to be accomplished, in 

substance, as follows: 



1. Defendants F. MONTES, ROSALES, RIOS, and ROBLES, co- 

conspirator H. Montes, and other members and associates of La 

Familia, would distribute and coordinate the distribution of 

methamphet amine and marijuana to others in the Southern 

California area, including Los Angeles County, and elsewhere. 



2. Defendants RODRIGUEZ -LANDA, MORENO, MONTOYA, VEGA, 

JACKSON, SOTO, LOZANO, and APODACA, and other members and 

associates of the Mexican Mafia, would assist, facilitate, and 

aid. the possession with intent to distribute and distribution of 

drugs by members and associates of La Familia by ordering, 

instructing, and informing Hispanic gang members to protect La 

Familia drug shipments and sales, to- prevent criminal taxation 

of La Familia drug shipments and sales, and to collect drug 

debts. 



3. Defendants RODRIGUEZ -LANDA, MORENO, MONTOYA, VEGA, 

JACKSON, SOTO, LOZANO, and APODACA, and other members and 

associates of the Mexican Mafia, would assist, facilitate, and 

aid the possession with intent to distribute and distribution of 

drugs by members and associates of La Familia drug cartel by 

protecting and arranging for the protection of incarcerated 



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members and associates of La Familia from violence and criminal 

taxation. , . 



4. In exchange for the Mexican Mafia's services and 

protection, members and associates of La Familia, including 

defendant F. MONTES and co- conspirator H. Montes, would provide 

thousands of dollars in drug proceeds and pound -quantities of 

methamphetamine and marijuana at a discounted price to members 

and associates of the Mexican Mafia. 



5. Defendants RODRIGUEZ -LANDA, MORENO, SOTO, MONTOYA, 

VEGA, JACKSON, LOZANO, APODACA, and GARCIA, and other members 

and associates of the Mexican Mafia, would communicate, 

including via telephone and in-person meetings, with members and 

associates of La Familia, in order to discuss how the Mexican 

Mafia could facilitate the possession with intent to distribute 

and distribution of drugs by members and associates of La 

Familia within the United States. 



6. Defendants MORENO, MONTOYA, VEGA, JACKSON, SOTO, 

LOZANO, and APODACA, and other members and associates of the 

Mexican Mafia, would distribute, send, and arrange the delivery 

of drug proceeds provided by members and associates of La 

Familia to incarcerated members of the Mexican Mafia. 



7. Defendants F. MONTES, LOZANO, and APODACA, co- 

conspirator H. Montes, and others known and unknown to the Grand 

Jury, would facilitate communications between members and 

associates of La Familia to incarcerated Mexican Mafia members 

and associates. 



8. Defendants' MORENO, MONTOYA, SOTO, LOZANO, and APODACA 

would facilitate communications about the drug trafficking 



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alliance of La Familia and the Mexican Mafia between 

incarcerated Mexican mafia members and- out -of -custody Mexican 

Mafia members and associates. 



9. Defendant SOTO would pick up and deliver proceeds 

derived from the sale of drugs supplied by defendant F. MONTES. 



10. Defendant C. GARCIA would, at the direction of 

defendant VEGA, transport controlled substances and drug 

proceeds, and would communicate messages about drug transactions 

between VEGA and others. 



11. Defendants RIOS and ROBLES would, at the direction of 

defendant F. MONTES, transport to others, including to defendant 

VEGA, raethamphetamine sold by La Familia members and associates 



at a discounted price. 



12. Defendant RIOS, would, at the direction of defendant 



F. MONTES, transport drug proceeds. 

C. OVERT ACTS 



In furtherance of the conspiracy and to accomplish the 

objects of the conspiracy, defendants RODRIGUEZ -LANDA, MORENO, 

MONTOYA, F. MONTES, VEGA, JACKSON, SOTO, LOZANO, ROSALES , 

APODACA, GARCIA, RIOS, and ROBLES, co- conspirator H. Montes, and 

others known and unknown to the Grand Jury, committed various 

overt acts within the Central District of California,, and 

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



1. On or about January 25, 2011, in a telephone 

conversation using coded language, defendants RODRIGUEZ -LANDA 

and APODACA discussed helping three brothers, defendant F. 

MONTES, unindicted co- conspirator CM., and co- conspirator H. 

Montes, with issues related to the brothers' drug trafficking, 



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and RODRIGUEZ -LANDA said he would ask defendant MORENO to assist - 

the brothers. 



2. On or about January 25, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 

defendant APODACA to not use his name over the telephone, but 

instead to refer to him in coded language, and that RODRIGUEZ - 

LANDA was calling on another inmate's prison telephone account. 



3. On or about January 27, 2011, defendants APODACA and 

LOZANO facilitated telephone calls between defendant RODRI.GUEZ- 

LANDA and co- conspirator H. Montes to discuss an alliance 

between the Mexican Mafia and La Familia, referred to as the 

"Project." 



4. On or about January 27, 2011, co- conspirator H. 

Montes, in a telephone conversation using coded language, 

discussed with defendant RODRIGUEZ -LANDA the Project, and H. 

Montes said that he .wanted RODRIGUEZ -LANDA to be the leader of 

the Pro j ect . 



5. On or about January 27, 20ll, co- conspirator H. 

Montes, in a telephone conversation using coded language, told 

defendant RODRIGUEZ -LANDA that "the Project is very large" and 

that it was for the benefit of RODRIGUEZ -LANDA and all Mexican 



Mafia members. 



6. On or about January 27, 2011, co-conspirator H, 

Montes, in a telephone conversation using coded language, told 

defendant RODRIGUEZ -LANDA that the Project involved the head of 

La Familia in Michoacan, Mexico, who H. Montes wanted RODRIGUEZ - 

LANDA to go to Mexico to meet, and RODRIGUEZ -LANDA said that 







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upon being released from prison and deported he would remain in 

Mexico. 



7. On or about • January 27, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, agreed 

to assist in the Project and told co-conspirator H. Montes that 

he would assist in any way he could from prison, including 

through use of the telephone, and that RODRIGUEZ -LANDA had the 

support of n la Bay," referring to incarcerated Mexican Mafia 

members at Pelican Bay State Prison. 



8. On or about January 27, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 

co -conspirator H. Montes that RODRIGUEZ -LANDA hoped to be 

released from prison soon, but that he trusted defendant MORENO, 

who was not incarcerated at the time, to assist in the Project 

while RODRIGUEZ -LANDA was incarcerated. 



9. On or about January 27, 2011, in a telephone 

conversation using coded language, defendant RODRIGUEZ - LANDA and 

co-conspirator H. Montes discussed sending money to RODRIGUEZ - 

LANDA and putting money in his prison account, and H. Montes 

agreed to send RODRIGUEZ -LANDA $1,500 and said that the head of 

La Pamilia wanted to send $100,000 to RODRIGUEZ - LANDA . 



10. On or about January 27, 2011, co- conspirator H. 

Montes, in a telephone conversation using- coded language, agreed 

to provide monetary support to defendant APODACA in return for 

her assistance in facilitating communication between defendant 

RODRIGUEZ -LANDA and co- conspirator H. Montes. 



11. On or about January 28, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 



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defendant APODACA to tell defendant F. MONTES and co- conspirator 

H. Montes that they had the support of RODRIGUEZ -LANDA and 

incarcerated Mexican Mafia Members at Pelican Bay State Prison, 

and that RODRIGUEZ -LANDA was going to protect them and their 

incarcerated brother, unindicted co-conspirator CM. 



12. On or about February 8, 2011, defendant LOZANO, in a 

telephone conversation using coded language, told an unindicted 

co-conspirator that he was calling on behalf of defendant 

RODRIGUEZ -LANDA, the "boss," about the status of a drug deal 

involving $19,000 worth of drugs that also involved defendant 

MORENO, and the unindicted co- conspirator said he was ready to 

conduct the drug deal. 



13. On or about February 21, 2011, defendants F. MONTES 

and ROSALES and co- conspirator H. Montes met with a Mexican 

Mafia member who, unbeknownst to defendants and their co- 

conspirators, was acting as a confidential informant ("CI-1")/ 

to discuss an alliance between the Mexican Mafia and La Familia. 



14. On or about February 21, 2011, defendant F. MONTES, in 

a conversation using coded language, told CI-1 that he, 

defendant' ROSALES, and co-conspirator H. Montes represent a "big 

Project" on behalf of "La Familia de Michoacan" drug cartel, and 

that they wanted to make a formal agreement with members of the 

Mexican Mafia. 



15. On or about February 21, 2011, defendant F. MONTES , in 

a conversation using coded language, told CI-1 that he had known 

defendant RODRIGUEZ -LANDA since 1991, and that RODRIGUEZ -LANDA 

would lead the Project because he is from Michoacan, Mexico. 







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16. On or about February 21, 2011, defendant F. MONTHS, in 

a conversation using coded language, told CI-1 that La Familia 

wanted to provide the Mexican Mafia with money for all of the 

Mexican Mafia's members so that the cartel's- members would be 

protected when they sell pounds of methamphetamine on the street 

and when they enter prison. 



17. On or about February 21, 2011, in a conversation using 

coded language, defendants F. MONTES and ROSALES and CI-1 

discussed having representatives of the Mexican Mafia travel 

into Mexico to meet .with "leaders of the cartel" to discuss what 

La Familia expected from the Mexican Mafia and what the' Mexican 

Mafia wanted from the cartel. 



18. On or about February 21, 2011, defendant ROSALES, in a 

conversation using coded language, told CI-1 that he would 

return to Mexico, .but that defendant F. MONTES and co- 

conspirator H. Montes would stay in the United States to 

represent La Familia' s interests. 



19. On or about February 21, 2011, defendant F. MONTES, in 

a conversation using coded language, told CI-1 that La Familia 

did not want any publicity for the "Project," and that if F. 

MONTES, defendant ROSALES, co- conspirator H. Montes, CI-1, and 

others got caught carrying out the Project, they were "f**king 

with the RICO Act." . 



20. On or about February 21, 2011, defendant ROSALES, in a 

conversation using coded language, told CI-1 that La Familia < 

wanted a "union" with the Mexican Mafia in which the Mexican "■ 

Mafia would support the cartel with whatever problems the cartel 

had in the United States distributing drugs. 



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21. On or about February 21, 2011, in a conversation using 

coded language, defendants- F. MONTES and ROSALES , co- conspirator 

H. Montes, and CI-1 discussed how, through the Project, the 

Mexican Mafia would provide La Familia members with "free rein" 

to sell methamphetamine in areas controlled by the Mexican Mafia 

and prevent' gang members from robbing cartel members, and how 

Mexican Mafia members could also obtain pounds of 

methamphetamine for further distribution as well. 



22. On or about February 21, 2011, defendant ROSALES, in a 

conversation using coded language, told CI-1 that La Familia was 

at a level a little higher than the drug trafficking 

organization of "Chapo Guzman" (referring to Joaquin Guzman 

Loera, the head of the Sinaloa drug cartel), and ROSALES and co- 

conspirator H. Montes discussed the fact that La Familia' s 

former leader, Nazario Moreno, had recently been shot and 

killed. 



23. On or about February 21, 2011, defendant F. MONTES , in 

a conversation using coded language, told CI-1 that he went to 

Mexico in November 2 010 to meet with leaders of La Familia and 

was asked by those leaders to arrange the Project, .and, as a 

result, F. MONTES came back and reached out to defendant 

RODRIGUEZ -LANDA, who put him in contact with defendant MORENO as 

a person RODRIGUEZ -LANDA trusted. 



24. On or about February 22, 2011, defendant APODACA, in a 

telephone conversation using coded language, told defendant 

RODRIGUEZ -LANDA that she was present with defendant F. MONTES 

and co-conspirator H; Montes, and APODACA facilitated a 







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telephone call between RODRIGUEZ-LANDA and H. Montes to discuss 



the Project. . " ■ ■ 



25. On or about February 22, 2011, co-conspirator H. 

Montes, in a telephone conversation using coded language, told 

defendant RODRIGUEZ - LANDA that "the Project is big" and would be 



appreciated by RODRIGUEZ -LANDA, and that H. Montes and his 



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people were "1000%" with RODRIGUEZ -LANDA. 



26. On or about February 22, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 

co-conspirator H. Montes that RODRIGUEZ - LANDA is calm and 

handles things well, while CI-1 did not handle things well, and 

that H. Montes and defendant F. MONTES should confide in 

RODRIGUEZ -LANDA as he would take care of all of them, including 

their brother, unind.icted co- conspirator CM,, who was 

incarcerated. 



27. On or about February 22, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 

co- conspirator H. Montes that RODRIGUEZ-LANDA was in 

communication and good standing with "La Playa," referring to 

incarcerated Mexican Mafia members at Pelican Bay State Prison. 



28. On or about February 22, 2011, co- conspirator H. 

Montes, in a telephone conversation using coded language, told 

defendant RODRIGUEZ-LANDA to instruct defendant F. MONTES and H. 

Montes on what to do and they would do it, and that F. MONTES 

and H. Montes wanted RODRIGUEZ-LANDA in charge of the Project. 



29. On or about February. 22, 2011, defendant RODRIGUEZ- 

LANDA, in a telephone conversation using coded language, told 

co- conspirator H. Montes that RODRIGUEZ - LANDA trusted defendant 



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MORENO to carry out the Project, but did not want CI-1 involved, 

and H. Montes said that MORENO had sent, defendant F. MONTES and 



H. Montes to CI-1. • 



30. On or about February 22, 2011, defendant RODRIGUEZ - 

LANDA, in a telephone conversation using coded language, told 

co-conspirator H. Montes that RODRIGUEZ - LANDA' s prison telephone 

privileges were limited and that RODRIGUEZ -LANDA would have his 

cellmate communicate directives regarding the Project to 

defendant APODACA, who would relay those directives to defendant 

F. MONTES and H. Montes. 



31. On or about February 22, 2011, defendant LOZANO, in a 

telephone conversation using coded Language, told defendant 

APODACA that defendant RODRIGUEZ -LANDA trusted defendant MORENO 

to be involved in the Project, but did not want CI-1 involved, 

and LOZANO said he and RODRIGUEZ -LANDA would be providing 

further instruction .about the Project. 



32. On or about February 25, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, discussed with CI-1 

obtaining drug proceeds from defendant F. MONTES and co- 

conspirator H, Montes, and MONTOYA said he had names of 

incarcerated Mexican Mafia members to whom they could distribute 

the money. 



33. On or about February 25, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, discussed with CI-1 

obtaining from MONTOYA, defendant MORENO, and others the names 

of 40 incarcerated Mexican Mafia members to whom they could send 

drug proceeds provided to the Mexican Mafia by La Familia, and 







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MONTOYA. discussed travelling to Mexico to meet with leaders of 

La Familia. 



34. On or about February 25, 2011, defendant APODACA, in a 

telephone conversation using coded language, told defendant 

LOZANO that she had spoken with co- conspirator H. Montes and 

that H. Montes was asking for direction from defendant 

RODRIGUEZ - LANDA with regard to the Project, and LOZANO agreed to 

speak with RODRIGUEZ -LANDA about the Project. 



35. On or about February 25, 2011, in a telephone 

conversation using coded language, defendant MORENO and CI-1 

discussed sending drug proceeds to "carnales" (referring to 

other' Mexican. Mafia members) as part of the Project, and MORENO 

said he was in communication with defendant RODRIGUEZ -LANDA. 



36. On or about February 26, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that 

MONTOYA would travel to Michoacan, Mexico to- further the 

Project. 



37. On or about March 2, 2011, in a telephone conversation 

using coded language, defendant MORENO and CI-1 discussed 

sending drug proceeds obtained from La Familia to a list of 

incarcerated Mexican Mafia members as part of the Project to 

show the incarcerated Mexican Mafia members how serious the 

Project was. 



38. On or about March 8, 2011, defendant APODACA, in a 

telephone conversation using coded language, told defendant 

LOZANO that defendant F. MONTES, co- conspirator H. Montes, and 

their group were currently moving forward with the Project, but 

that it was understood that defendant RODRIGUEZ -LANDA would be 



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"on top" of the Project upon his release, and LOZANO said that 

was "perfect." 



39. On or about March 9, 2011, in a telephone conversation 

using coded language, defendant MORENO and CI-1 discussed 

meeting later that, day to discuss the Project and divide 

approximately $30,000 in drug proceeds that La Pamilia was going 

to give them, and MORENO said that there should be no complaints 

so long as they ensured that there was money for "everybody," 

referring to all Mexican Mafia members. 



40. On or about March 9, 2011, defendant F. MONTES 

delivered approximately $24,400 in drug proceeds to CI-1 in 

furtherance of the Project. 



41. On or about March 9, 2011, defendant MORENO and CI-1 

met in Fresno, California, and CI-1 showed MORENO the 

approximately $24,400 in drug proceeds CI-1 had received from 

defendant F. MONTES earlier that day and gave MORENO 

approximately $17,400 of the drug proceeds. 



42. On or about March 9, 2011, in a conversation using 

coded language,. CI-1 explained to defendant MORENO that CI-1 had 

instructed defendant F. MONTES to .take out defendant RODRIGUEZ- 

LANDA's portion of the $30,000 in drug proceeds before giving 

the drug proceeds to CI-1. 



43. On or about March 9, 2011, in a conversation using 

coded language, defendant MORENO and CI-i discussed assisting La 

Familia by providing protection for associates of the cartel 

engaged in drug sales in the United States and collecting drug 

proceeds for the cartel, and MORENO discussed obtaining drugs 

from the cartel. 



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44. On or about March 9, 2011, in a conversation using 

coded language, defendant MORENO told CT-1 that the, Project was 

designed to benefit "everybody" in the Mexican Mafia. 



45. On or about March 9, 2 011, in a conversation using 

coded language, defendant MORENO and CT-1 discussed traveling to 

Michoacan, Mexico to meet with leaders of La Familia. 



46. On or about March 15, 2011, defendant APODACA 

facilitated a telephone conversation between co- conspirator H. 

Montes and defendants RODRIGUEZ -LANDA and LOZANO to discuss the 

Project. 



47. On or about March 15, 2011, defendant LOZANO, in a 

telephone conversation using coded language, told co- conspirator 

H . Montes that defendant RODRIGUEZ -LANDA' s word carries great 

weight, and that H. Montes and his group had the support of 

RODRIGUEZ -LANDA and LOZANO. 



48. On or about March 15, 2011, in a telephone 

conversation using coded language, defendant LOZANO and co- 

conspirator H. Montes discussed making sure that defendant 

RODRIGUEZ -LANDA get's out of prison as soon as possible so that 

RODRIGUEZ -LANDA could lead the Project. 



49. On or about March 15, 2011, co- conspirator H; Montes, 

in a telephone conversation using coded language, told defendant 

LOZANO that H. Montes and his group would be proceeding with the 

Project while defendant RODRIGUEZ -LANDA was in prison, but that 

RODRIGUEZ -LANDA would lead the Project on. behalf of the Mexican 

"lafia when he was released from prison. 



50. On or about March 15, 2011, in a telephone 

conversation using coded language, defendant LOZANO and co- 



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conspirator H. Montes discussed having H, Montes and his group 

provide money to defendants RODRIGUEZ - LANDA , LOZANO, and 

APODACA; and LOZANO said he would be calling periodically, on 

behalf of RODRIGUEZ -LANDA, to check in with H. Montes about the 

Project. 



51. On or about March 15, 2011, defendant MORENO, in a 

telephone conversation using coded language, told defendant 

LOZANO that MORENO was. proceeding with the Project and would do 

whatever defendant RODRIGUEZ -LANDA wanted MORENO to do; and 

LOZANO, in the presence of RODRIGUEZ -LANDA, said that RODRIGUEZ - 

LANDA approved of MORENO'S work on the Project. 



52. On or about March 15, 2011, defendant MORENO, in a 

telephone conversation using coded language, told defendant. 

LOZANO that MORENO would take care of issues that certain 

incarcerated gang members had with unindicted co- conspirator 

CM., and LOZANO said CM. was a good friend of defendant 

RODRIGUEZ - LANDA . 



53. ' On or about April 1, 2011, defendants MONTOYA and VEGA 

and CT-1 met with defendant F. MONTES and co- conspirator H. 

Montes to discuss the benefits of the Project and MONTOYA and 

VEGA travelling to Michoacan, Mexico, to represent . the Mexican 

Mafia in a meeting with the leaders of La Familia; and 

defendants MONTOYA. and VEGA agreed to make the trip. 



54. On or about April 1, 2011, in a conversation using 

coded language, defendant F. MONTES told defendants MONTOYA and 

VEGA that F. MONTES could supply a "hundred kilos" of 

tnethamphe t amine . 







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55. On or about April 3, 2011, defendants MONTOYA and 

VEGA, along with defendant F. MONTES and co- conspirator H. 

Montes, left the United States and travelled to Michoacan, 

Mexico, to meet with leaders of La Familia and discuss the 

alliance between the Mexican Mafia and La Familia. MONTOYA was 

on parole at the time of this trip and removed his electronic 

monitoring ankle device in order to travel to Mexico. 



56. On or about April 3, 2 011, defendant MONTOYA, in a 

telephone conversation using coded language, discussed with CI-1 

his. trip to Michoacan, Mexico, to meet with the leaders of La 

Familia. 



57. From on- or about April 3, 2011 to on or about April 6, 

2011, in Michoacan, Mexico, defendants MONTOYA, VEGA, and F. 

MONTES met with leaders of La Familia, including defendant 

ROSALES, and discussed the alliance between the Mexican Mafia 

and La Familia which would further the trafficking of drugs into 

and within the United States. 



58. On or about April 5, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that 

MONTOYA was in Mexico meeting with leaders of La Familia and 

that the cartel had been wanting to work with the Mexican Mafia 



for a long time. 



■ 59. On or about April 5, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that 

MONTOYA believed that La Familia would offer the Mexican Mafia 

unlimited amounts of drug proceeds as part of the Project. 







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60. On or about April 6, 2011, defendants F. MONTES and 

MONTOYA, in a telephone conversations using coded language, 

informed CI-1 that they would return 1 from Mexico the next day. 



61. On or about April 11, 2011, defendant VEGA, in a 

conversation using coded language, informed CI-1 that, during 

meetings in Michoacan, Mexico, the leadership of La Familia told 

VEGA that the cartel needed the help of the Mexican Mafia to 

collect debts in the United States, needed protection in D.S. 

prisons for members or associates of the cartel, and wanted a 

member of La Familia to become a member of the Mexican Mafia^ 

and, in exchange, the cartel would provide money and drugs, 

namely, "a lot of keys." 



62. On or about April 11, 2011, in a conversation using 

coded language, defendant VEGA told CI-1 that VEGA had "people 

all over" to help with the Project. 



63. On or about April 16, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that 

MONTOYA was in Mexico trying to return to the United States, but 

that La Familia was taking care of him, along with defendant F. 

MONTES, at a resort. 



64. On or about April 18, 2011, defendant MONTOYA, in a 

conversation using coded language, informed CI-1 that, during 

meetings in Michoacan, Mexico, the leadership of La Familia had 

told MONTOYA that the cartel wanted to do the Project, which 

would involve hundreds of kilograms and pounds of drugs, that 

defendant F. MONTES and co-cpnspirator H. Montes would act as 

the representatives of the cartel in the United States, that 

drugs of poor quality from the cartel could be returned to the 



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cartel, and that the cartel would provide "financial start-up" 

for the Project. 



65. On or about April 18, 2011, defendant MONTOYA, in a 

conversation using coded language, told CI-1 that, during 

meetings in Michoacan, Mexico, MONTOYA informed the leadership 

of La Familia that the Mexican Mafia would not just focus on the 

"illegal aspects" of the Project but also on the "bank[ing]" of 



illegal proceeds. 



66. On or about April 18, 2011, defendant MONTOYA, in a 

conversation using coded language, told CI-1 that MONTOYA' s 

efforts in regards to the Project were being done in order to 

benefit the Mexican Mafia. 



67. On or about April 19, 2011, defendant APODACA, in a 

telephone conversation using coded language, told defendant 

LOZANO that defendant F. MONTES and co - conspirator H. Montes 

were continuing to work on the Project with defendant MORENO and 

CI-1, and LOZANO said he did not like the idea of CI-1 being 

involved and would contact MORENO to discuss CI-l's involvement 

in the Project. 



68. On or about April 19, 2011, co- conspirator H. Montes, 

in a telephone conversation using coded language, told defendant 

LOZANO that H. Montes had gone with defendant MONTOYA to 

Michoacan, Mexico, to meet with leaders of La Familia, but that 

they had not taken CI-1, and LOZANO said MONTOYA was a 

trustworthy person, but that H. Montes should be careful with 

CI-1. 



69. On or about April 19, 2011, co-conspirator H. Montes, 

in a telephone conversation using coded language, told defendant 



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I , a Hlvuc proceeds to- defendant 

TAMO that H. Montes would send drug P r 

in a. telephone 

, . on or about ^ «■ „ and j^poDACA 



„ rim usl rig coded language, defendants 

I It that defendant KWMOB--** ^ 

.cussed the fact that ^ ^ ^ 



xlca n Mafia members ^ ^ ■ Mexican Ma£ia 



. „„ that they were looking out for all » 

oject and that aad „ inquired with APODACA 



fflb ers through the Project, an ^ ^ ^ 



>ou t drug proceeds co-conspirator H. 

waOOB-IM^- 21 2011 , ma conversation using 



■71 On or about April 21, 2011, 

defendant VEGA told defendants MONTOYA and F ■ 

, d ed language, defendant ^ 

pt 1 that VEGA had gang members acr 

ONTES and Cl-1 ^ M0HIES 



iel p distribute drugs as par ^ ^ . 



,, . v, ou nd of methamphetamme 

,tated he could sell a pound 

»r, nnn a below market rate. 

re(m for 59 ,000, a b ^ a COOTer sation using 



to On or about ApriJ- 

„ fendant F • MORTES agreed to make available to 

coded language, defendant ^ ^ ^ 



.. urarmvA and VEGA and CI-1 sju",« 

defendants MOHTOYA and ^ ^ arugs as 



„ pot , f money that would be used for P 

part of the Preset ^ ^ oonvers ation using 



n-x on or about Aprxi ax, ^„„^ ar1 t-s 

I defendant F. MONTES agreed to provide defendants 



coded language, defendant marijua na and other drugs 







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VEGA agreed to take, "five to ten" pounds of methamphetamine from 

F. MONTES. 



74. on or about April 22, 2011, defendant MONTOYA, in a 

telephone conversation using coded language ,. told CT-1 that 

defendant F. MONTES and. co- conspirator H. Montes had sent a 

half-pound of methamphetamine to defendant VEGA, but the quality 

of the drugs was not as high as a prior drug delivery.. 



75. On or about April 24, 2011, co- conspirator H. Montes, 

in a telephone conversation using coded language, told defendant 

LOZANO that La Familia had given H. Montes $300,000 in.drug- 

proceeds to deliver to defendant RODRIGUEZ - LANDA as part of the 

Proj ect, and LOZANO told H. Montes that RODRIGUEZ - LANDA "trusts" 

H. Montes and that H. Montes should hold onto the money for 



RODRIGUEZ -LANDA. 



76. On or about April 24, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, discussed with CI-1 

obtaining drugs from La Familia, and MONTOYA said that Mexican 

Mafia members were not drug dealers but rather drug 

distributors . 



77. On or about April ;24, 2011, defendant .LOZANO, in a 

telephone conversation using coded language, told co- conspirator 

H. Montes to send drug proceeds to LOZANO and another inmate on 

behalf of defendant RODRIGUEZ - LANDA . 



78. On or about April 30, 2011, defendant MONTOYA , in a 

telephone conversation using coded language, told CI-1 that 

defendant F. MONTES and co-conspirator H. Montes had given 

MONTOYA a car and would be giving him a residence in Mexico. 







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' 79. On or about May 2, 2011, in a conversation using coded 

language, defendant VEGA told defendant F. MONTE S and co- 

conspirator H. Montes that VEGA wanted to purchase drugs from 

them and that VEGA sells pound quantities of methamphetamine . 



80. On or about May 2, 2011, in a meeting using coded 

language, defendant F. MONTES told defendant VEGA and CI-1 that 

he had the money for the Project and proposed another trip to 

Michoacan, Mexico, to meet with leaders of La Familia in order 

to discuss the Project. 



81. On or about May 16, 2011, defendants MONTOYA and VEGA 

and CI-1 met with defendant F. MONTES and co- conspirator H. 

Montes and discussed the. progress of the Project. 



82. On or about June 6, 2011, CI-1, in a telephone 

conversation using coded language, told defendant MORENO that 

CI-1 and others were going to meet with defendant F. MONTES and 

co- conspirator H. Montes in the near future to obtain drug 

proceeds, and CI-1 and others would then travel to MORENO'S 

location with the money in order to get it distributed to 

incarcerated Mexican Mafia members. 



83. On or about June 7, 2011, in a telephone conversation 

using coded language, defendant MONTOYA and CI-1 discussed 

picking up drug proceeds from defendant F. MONTES and co- . 

conspirator H. Montes and then traveling to defendant MORENO'S 

location to divide the money among defendants MORENO, MONTOYA, 

and VEGA, and CI-1, ■ for distribution to incarcerated Mexican. 

Mafia members, and MONTOYA said he would travel to Mexico to 

further the Project. ' 







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84. On or about June 8, 2011, defendants MONTOYA and VEGA 

and CI-1 met with defendants F. MONTES 'and RIOS and co- 

conspirator H. Montes to discuss the Project, and P. MONTES gave 

MONTOYA, VEGA, and CI-1 approximately $59 , 000 in drug proceeds 

as payment for the alliance between the Mexican Mafia and La 

Familia. 



85. On or about June 8, 2011, in a telephone conversation 

using coded language, defendant MORENO and CI-1 discussed 

meeting at MORENO'S location later that day to deliver the drug 

proceeds obtained from defendant F. MONTES and co- conspirator H. 

Montes on behalf of La Familia. . 



86. On or about June 8, 2011, defendant MORENO met with 

defendants MONTOYA and VEGA and CI-1 at MORENO'S residence in 

Fresno, California, to discuss the Project, and the four divided 

the approximately $59,000 in drug proceeds delivered earlier, 

that day by defendant F. MONTES on behalf of La Familia and 

agreed to distribute portions of the money to incarcerated 

Mexican Mafia members . 



87. On or about June 8, 2011, defendants MORENO and 

MONTOYA and CI-1, in the presence of defendant VEGA, voted and 

agreed to make VEGA a member of the Mexican Mafia. 



88. On or about June 10, 2011, defendant MORENO, in a 

telephone conversation using coded language, told CI-1 that 

MORENO had sent drug proceeds provided on behalf of La Familia 

to incarcerated Mexican Mafia members, and MORENO said that he 

had contacted inmates to spread the word about the Project and 

about the money being distributed to incarcerated Mexican Mafia 

members . 



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89. On or about June 24, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that 

MONTOYA had already- taken care of sending drug proceeds provided 

on behalf of La. Familia to all the incarcerated Mexican Mafia 

members for whom MONTOYA was responsible. 



90. On or about June 28, 2011, defendant MORENO, in a 

telephone conversation using coded language, told CI-1 that 

MORENO had already sent drug proceeds provided on behalf of La 

Familia to six incarcerated Mexican Mafia members and that 

MORENO was continuing to send money to incarcerated Mexican 

Mafia members. 



91. On or about July 5, 2011, .defendant VEGA and CI-1 met 

with defendant P. MONTES and co- conspirator H. Montes, and VEGA 

agreed to assist with the drug distribution portion of the 

alliance between the Mexican Mafia and La Familia. 



92-. On or about July 5, 2011, defendant MONTOYA, in a 

telephone conversation using coded language, told CI-1 that he 

had obtained a pound of methamphetamine from defendant F. MONTES 

and co-conspirator H. Montes, that the price was $9,500 per 

pound, and that the methamphetamine was of high quality.- 



93. On or about July 14, 2011, defendants MONTOYA, VEGA, 

F. MONTES, and RIOS, co- conspirator H. Montes, and CI-1, met 

with numerous other members of street gangs from across Southern 

California to inform the gang members about the alliance between 

the Mexican Mafia and La Familia. 



94. On or about July 2.7, 2011, defendant RODRIGUEZ -LANDA, 

in a letter using coded language, told an unindicted co- 

conspirator that the "Project" does not pertain to CI-1, but 



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rather was to be controlled by RODRIGUEZ -LAND A and others, 

including "Las Playas," referring to incarcerated Mexican Mafia 

members at Pelican Bay State Prison. 



95. On or about July 27, 2 011, defendant RODRIGUEZ -LANDA, 

in a letter using coded language, told an unindicted co- 

conspirator to instruct co- conspirator H. Montes to deal only 

with RODRIGUEZ -LANDA and his associates, and told the unindicted 

co- conspirator to destroy the letter after reading it. 



96. On or about August 11, 2011, defendant VEGA and CI-1 

met with co- conspirator H. Montes, and H. Montes delivered 

approximately $24,02 in drug proceeds to VEGA and CI-1 in 

furtherance of the Project, and H. Montes agreed that an 

additional $100,000 in drug proceeds would be paid to the 

Mexican Mafia on behalf of La Familia at a later time. 



97. On or about August 19, 2011, defendant VEGA and CI-1 

met with co-conspirator H. Montes, and H. Montes delivered 

approximately $22,340 in drug proceeds to VEGA and CI-1 in 

furtherance of the Project. 



98. On or about August 22, 2011, defendant MORENO met with 

CI-1 and obtained from CI-1 approximately $14,720 in drug 

proceeds and 15 money orders worth $500 that MORENO understood 

had been funded with drug proceeds from the Project; and, in a 

conversation using coded language, MORENO agreed to distribute 

the money and money orders to other incarcerated Mexican Mafia 

members in furtherance of the Project. 



99. On or about August 22, 2011, in a conversation using 

coded language, defendant MORENO and CI-1 discussed maintaining 

"receipts" of the money that they were sending to other Mexican 



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Mafia members so that they would have records that they had in 

fact distributed drug proceeds to Mexican Mafia members in 

furtherance of the Project. 



100. On or about August 22, 2011, in a conversation using 

coded language, defendant MORENO and CI-1 discussed obtaining 

pounds of methamphetamine from La Pamilia at discount rates, and 

MORENO said that Mexican Mafia members should be getting pounds 

of methamphetamine at cheaper rates than what others were paying 

for pounds of methamphetamine. 



101. On or about August 22, 2 011, in a conversation using 

coded language, defendant MORENO and CI-1 discussed whether 

defendant F. MONTES, co- conspirator H. Montes, and other 

representatives of La Familia were providing drug proceeds to 

defendant RODRIGUEZ -LANDA for his role in the Project, and 

MORENO and the' CI discussed having RODRIGUEZ -LANDA and defendant 

SOTO assist with the Project from Mexico. 



102. On or about September 7, 2011, defendant APODACA, in a 

telephone conversation using coded language, spoke with an 

unindicted co- conspirator and agreed to arrange a 

methamphetamine transaction on behalf of defendant RODRIGUEZ - 

LANDA. 



103. On or about September 7, 2 Oil, defendant APODACA, in a 

telephone conversation using coded language, told an unindicted 

co- conspirator that CI-1 had received a large amount of drug 

proceeds from defendant F. MONTES, co- conspirator H. Montes, and 

La Familia as part of the Project, and that other Mexican Mafia 

members and associates did not want CI-1 to lead the Project. 







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104. On or about September 22, 2011, defendant VEGA and CI- 

1 met with numerous other Hispanic street gang members to 

discuss the alliance between the Mexican Mafia and La Familia. 



105. On or about September 23, 2011, defendant VEGA and CI- 

1 met with numerous other Hispanic street gang members to 

discuss the alliance between the Mexican Mafia and La Familia, 

including the drugs that La Familia would make available to the 

gang members. 



106. On or about September 27, 2011, defendant APODACA gave 

unindicted co- conspirator M.M., who was a member of the Mexican 

Mafia, the telephone number for co- conspirator H. Montes, and 

APODACA said that La Familia had given Mexican Mafia members a 

large amount of money and everything was going well with the 

Proj ect . 



107. On or about September 27, 2011, unindicted co- 

conspirator M.M., in a telephone conversation using coded 

language, told co- conspirator H. Montes to send defendant 

RODRIGUEZ - LANDA. $1, 000 in drug proceeds, and H. Montes agreed to 

do so. 



108. On or about September 30, 2011, defendant APODACA, in 

a telephone conversation using coded language, told unindicted 

co-conspirator M.M. that she had. sent defendant RODRIGUEZ - LANDA 

$1,000 in drug proceeds. 



109. On or about October 10, 2011, in telephone 

conversations using coded language, defendant VEGA asked co- 

conspirator H. Montes if H. Montes had 100 pounds (approximately 

45 kilograms) of marijuana for sale that VEGA intended to sell 







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to a third party; and H. Montes responded that he did have 

marijuana for sale and provided the prices for the marijuana. 



110. On or about October 10, 2011, in telephone 

conversations using coded language, defendant C. GARCIA agreed 

to bring drugs to defendant VEGA in order for VEGA to show the 

drugs to a potential customer. 



111. On or about October 10, 2011, in telephone 

conversations using coded language, defendant C. GARCIA informed 

defendant VEGA that an unindicted co- conspirator had a problem 

with drugs that were provided by VEGA, and VEGA told C. GARCIA 

to inform the unindicted co-conspirator to do the drug deal 

anyways, and C. GARCIA agreed to do so. 



112. On or about October 10, 2011, in telephone 

conversations using coded language, defendant VEGA instructed 

defendant C. GARCIA to ask an unindicted co- conspirator if the 

unindicted co- conspirator had sold the drugs that were provided 

by VEGA, and C. GARCIA agreed to do so. 



113. On or about October 11, 2011, in telephone 

conversations using coded language, defendant C. GARCIA informed 

defendant VEGA that an- unindicted co-conspirator, who had 

received drugs from VEGA, would have drug proceeds .available for 

VEGA later that evening, and VEGA told C> GARCIA to inform the 

unindicted co-conspirator to have the money ready to be picked 

up. 



114. On or about October 11, 2011, in telephone 

conversations using coded language, defendant VEGA asked 

defendant F. MONTES if he had 100 pounds (approximately 45 







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kilograms) of marijuana ready for pick up, and F. MONTES told 

VEGA the prices for the marijuana. 



115. On or about October 11, 2011, in telephone 

conversations using coded language, defendant VEGA informed 

defendant C. GARCIA that VEGA was negotiating the price for the 

purchase of 200 pounds (approximately 90 kilograms) of marijuana 

from defendant F. MONTES. In response, C. GARCIA agreed to 

update a drug customer of VEGA about VEGA' s pending drug deal 

with F. MONTE S . 



116. On or about October 11, 2011, in telephone 

conversations using coded language, defendant VEGA informed 

defendant C. GARCIA that defendant VEGA would acquire 300 pounds 

(approximately 136 kilograms) of marijuana the next day; and C. 

GARCIA informed VEGA of her communications with various drug 

customers who wanted to purchase marijuana from VEGA and C. 

GARCIA. 



117. On or about October 12, 2011, in telephone 

conversations using coded language, defendant F. MONTES informed 

defendant VEGA that F. MONTES had a large quantity of marijuana 

available for sale, and VEGA stated that he would make 

arrangements to pick up the marijuana. 



118. On or about October 12, 2011, in telephone 

conversations using coded language, defendant VEGA asked 

unindicted co-conspirators to pick up marijuana being provided 

by defendant F. MONTES and to deliver the drugs to a stash 

house. 



119. On or about October 12, 2011, in telephone 

conversations using coded language, defendant C. GARCIA agreed, 



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at the request of defendant VEGA, to pick up and store a large 

quantity of marijuana, and to inform unindicted co- conspirators 

to have their money- ready to purchase the marijuana. 



120. On or about October 12, 2011, in telephone 

conversations using coded language, defendant C. GARCIA informed 

defendant VEGA that she had picked up and made arrangements to 

store the marijuana and that she would deliver one unit of 

marijuana to an unindicted co -conspirator. 



121. On or about October 12, 2011, in telephone 

conversations using coded language, defendant VEGA told 

defendant C. GARCIA to inform an unindicted co- conspirator that 

VEGA had such a large quantity of drugs that VEGA could front 

the unindicted co- conspirator one or two units of drugs. 



122. On or about October 13, 2011, defendant VEGA met with 

CI-1, and, in coded language, agreed to send drug proceeds to 

incarcerated Mexican Mafia members and to travel to Michoacan, 

Mexico, to meet with members of La Familia. 



123. On or about October 13, 2011, defendant VEGA and CI-1 

met with defendants. F. MONTES and RIOS, and F. MONTES and RIOS 

delivered approximately . $20, 000 in drug proceeds to VEGA and CI- 

1 in furtherance of the Project. 



124. On or about October 13, 2011, in telephone 

conversations using coded language, defendants F. MONTES. and 

VEGA discussed evading law enforcement surveillance. 



125. On or about October 15, 2011, in telephone 

conversations using coded language,, defendants VEGA and F. 

MONTES discussed the condition of the marijuana provided to VEGA 

by F. MONTES . 



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126. On or about October 18, 2011, in telephone 

conversations using coded language, defendant C. GARCIA, informed 

defendant VEGA that an unindicted co- conspirator had delivered 

money and taken one unit of marijuana. 



127. On or about October 18, 2011, unindicted co- 

conspirator M.M., in a telephone conversation using coded 

language, thanked defendant F. MONTES for money that F. MONTES 

and his brothers had sent, and F. MONTES said he was eager for 

defendant RODRIGUEZ -LANDA to be released from prison so that 

RODRIGUEZ -LANDA could lead the Project. 



128. On or about October 20, 2011, in telephone 

conversations using coded language, defendant VEGA instructed 

defendant C. GARCIA to provide a sample of drugs to an 

unindicted co- conspirator at or around a muffler shop in Los 

Angeles, California. 



129. On or about October 20, 2011, in telephone 

conversations using coded language, defendant C. GARCIA informed 

defendant VEGA that an unindicted co- conspirator had asked 

whether VEGA would. lower the price of drugs for sale if the 

unindicted co- conspirator purchased 100 units of drugs, and VEGA 

responded that he would lower the price and C. GARCIA stated 

that she would inform the unindicted co- conspirator of VEGA's 

response. 



130. On or about October 22 and 27, 2011, in telephone 

conversations using coded language, defendant VEGA updated 

defendant F. MONTES about the sale of marijuana. 



131. On or about October 27, 2011, defendant VEGA and CI-1 

met with defendant JACKSON to discuss the alliance between the 



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Mexican Mafia and La Familia, and JACKSON said he wanted to 

assist in the Project. 



132. On or about December 15, 2011, defendant F. MONTES, in 

a telephone conversation using coded language, agreed to provide 

methamphetamine to. CI-1. 



133. On or about January 6., 2012, defendant MORENO, in a 

telephone conversation using coded language, told CI-1 that he 

had recently been released from prison, and MORENO, inquired with 

CI-1 about whether defendant F. MONTES and co- conspirator H. 

Montes had provided any additional drug proceeds as part of the 

Project because MONTES needed money. 



134. On or about January 6, 2012, defendant MORENO, in a 

telephone conversation using coded language, told CI-1 that, 

while MORENO was in prison, he had met with other incarcerated 

Mexican Mafia members and they were aware of the Project and 

were "on board with it," and MORENO said that it was just up to 

defendant F. MONTES and co-conspirator H. Montes to do their 

part by providing drug proceeds. 



135. On or about January 17, 2012, defendant APODACA met. 

with CI-1, and APODACA stated that she was working for defendant 

RODRIGUEZ -LANDA. CI-1 showed APODACA copies of money orders . 

that CI-1 had sent to incarcerated Mexican Mafia members as part 

of the alliance between the Mexican Mafia and La Familia, and 

APODACA agreed to pass this information to RODRIGUEZ -LANDA. 



136. On or about January 21, 2012, in a telephone 

conversation using coded language, defendant F. MONTES discussed 

with CI-1 the prices and quantities of methamphetamine that F. 

MONTES proposed to sell to CI-1. 



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.137. On or about January- 23, 2012, in a telephone 

conversation using coded language, defendant F. MONTES suggested 

to Cl-1 that they flee immediately because federal law 

enforcement was investigating F. MONTES. 



138. On or about January 23, 2012, in a telephone 

conversation using coded language, defendant F. MONTES informed 

CT-1 that F. MONTES would make arrangements for CI-l to receive 

methamphetamine . 



139. On or about January 24 and 25, 2012, in telephone 

conversations using coded language, defendant F. MONTES 

confirmed that he could provide CT-1 with methamphetamine. on 

Friday, January 27, 2012. 



140. On or about January 26, 2012, in a telephone 

conversation using coded language, defendant F. MONTES confirmed 

with CT-1 that the. price of methamphetamine that F. MONTES had 

for sale to CT-1 was $8,500 per pound. 



141. On or about January 27, 2012, in a telephone 

conversation using coded language, defendant F. MONTES confirmed 

with CI-1 that F. MONTES would arrange for a courier to deliver 

to CI-1 three pounds of methamphetamine that day and two pounds 

of methamphetamine at a later time. 



142. On or about January 27, 2012, during an in-person 

meeting, defendant RIOS provided CI-1 with approximately 1,303 

grams of methamphetamine and, in exchange, CI-1 provided RIOS 

with approximately $25,500. 



143. On or about January 27, 2012, defendant RIOS delivered 

drug proceeds to defendant F. MONTES and co- conspirator H. ' 







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Montes at an auto body shop located on First Street, San 

Fernando, California. . 



144. On or about January 27, 2012, during an in-person 

meeting, CI-1 informed defendant JACKSON that CI-1 had received 

three pounds of methamphetamine and would receive two pounds of 

methamphetamine at a later time. 



145. On or about January 27, 2012, during an in-person 

meeting, defendant JACKSON accepted $4,000 in drug proceeds from 

CI-1 in furtherance of the Project, and JACKSON offered to have 

one of his associates meet with members of La Familia in 

Michoacan, Mexico, in March 2012. 



146. On or about January 27, 2012, in a telephone 

conversation using coded language, defendant JACKSON told CI-1 

to order two pounds of methamphetamine from defendant F. MONTES. 



147. On or about January 27, 2012, in telephone 

conversations using coded language,, defendant F. MONTES told CI- 

1 that he would provide defendant JACKSON and CI-1 with 

methamphetamine the next day, namely, Saturday, January 28, 

2012. 



148. On or about January 28, 2012, in a telephone 

conversation using coded language, CI-1 informed defendant 

JACKSON that defendant F. MONTES had failed to contact CI-1, and 

JACKSON said that he had a courier waiting to pick up 

methamphetamine from F. MONTES. 



149. On or about January 28, 2012, unindicted co- 

conspirator A. P. A., in a telephone conversation using coded 

language, told CI-1 that he was calling on behalf of defendant 

RODRIGUEZ -LANDA to inquire about the status of the Project, and, 



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after receiving information that the Project was moving forward, 

A. P. A. said he would relay the information about the status of 

the Project to RODRIGUEZ -LANDA. 



150. On or about January 31, 2012, defendant JACKSON, in a 

telephone conversation using coded language, told CT-1 that 

defendant F. MONTES had told him that F. MONTES was unable to 

deliver methamphetamine on Saturday, January 28, 2012, because 

F. MONTES had been followed by law enforcement and threw away 

his telephone and, consequently, did not have the telephone 

numbers for JACKSON or CI-1. 



151. On or about January 31,. 2012, defendant JACKSON, in a 

telephone conversation using coded language, told CI-1 that a 

courier of defendant F. MONTES had delivered two pounds of 

methamphetamine to JACKSON'S courier and that F. MONTES had 

additional methamphetamine ready to deliver to CI-1. 



152. On or about February 1, 2012, defendant JACKSON , in a 

telephone conversation using coded- language, confirmed with CI-1 

that JACKSON would use the proceeds from the sale of 

methamphetamine to purchase money orders that would be sent to 

incarcerated Mexican Mafia members in furtherance of the 

Project. 



153. On or about February 2 and 3, 2012, in telephone 

conversations using coded language, defendant F. MONTES informed 

CI-1 that F. MONTES would have a courier deliver two pounds of 

methamphetamine to CI-1 the morning of February 3, 2 012, and 

that F. MONTES had previously delivered methamphetamine to 

defendant JACKSON. 







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154. On or about February 2, 2012, defendant F. MONTES , in 

a telephone conversation using coded language, informed 

defendant RIOS that methamphetamine would be delivered to RIOS's 

residence the next day and that RIOS would deliver that 

methamphetamine to a drug customer; and RIOS requested that F. 

MONTES provide him with money for gas. 



155. On or about February 3, 2012, defendant F. MONTES, in 

a telephone conversation using coded language, told defendant 

ROBLES to give money to defendant RIOS for gas. 



156. On or about February 3, 2012, defendant ROBLES, in a 

telephone conversation using coded language, confirmed with 

defendant F. MONTES • that ROBLES would meet with defendant RIOS 

at 9:00 a.m. that morning. 



157. On or about February 3, 2012, defendant ROBLES, in a 

telephone conversation using coded language, told defendant F. 

MONTES that ROBLES informed defendant RIOS that ROBLES was 

outside of RIOS's residence. 



158. On or about February 3, 201 c 2, defendant F. MONTES, in 

a telephone conversation using coded language, informed 

defendant RIOS that defendant ROBLES was outside of RIOS's 

residence . 



159. On or about February 3, 2012, defendant ROBLES 

delivered methamphetamine to defendant RIOS at his residence on 

Foothill Boulevard in Sylmar, California. 



160. On or about February 3, 2012, defendant F. MONTES, in 

telephone conversations using coded language, informed CT-1 that 

his courier was on. his way to meet CT-1. 







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161. On or about February 3, 2 012, defendant JACKSON, in 

telephone conversations using coded language, acknowledged that 

CI-1 was about to receive two pounds of methamphetamine from the 

courier of defendant F. MONTES. 



162. On or about February 3, 2012, defendant RIOS, in a 

telephone conversation using coded language, informed defendant 

F. MONTES that RIOS had arrived at CI-l's location. 



163. On or about February 3, 2012, defendant RIOS provided 

CI-1 with approximately 872 grams of methamphetamine and, in 

exchange, CI-1 provided RIOS with approximately $17,000. 



164. On or about February 3, 2012, defendant RIOS, in a 

telephone conversation using coded language, informed defendant 

F. MONTES that RIOS believed that law enforcement had followed 

him after his meeting with CI-1. 



165. On or about February 3, 2012, defendant RIOS, in a 

telephone conversation using coded language, informed defendant 

F. MONTES that -RIOS had not yet delivered the proceeds from the 

recent methamphetamine deal with CI-1. 



166. On or about February 14, 2012, during an in-person 

meeting, defendant MONTOYA accepted approximately $2,000 in cash 

that CI-1 told MONTOYA was from the sale of methamphetamine 

provided by defendant F. MONTES. 



167. On or about March 13, 2012, in a telephone 

conversation using coded language, defendant MONTOYA and CI-1 

complained about defendant F. MONTES and co- conspirator H. 

Monte s delaying the Project, and MONTOYA said "we're gonna make 

this sh*t work somehow, someway." 







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168. On or about March 13, 2012, in a. telephone 

conversation using coded language, defendant MONTOYA and CI-1 

discussed the fact that the Mexican Mafia had already helped 

protect La Familia members in prison as part of the Project. 



169. On or about March 14, 2012, defendant MONTOYA, in a 

telephone conversation using coded language, discussed with CI-1 

using defendant VEGA' s ties to Mexican drug cartels to go around 

defendant F. MONTE S and co- conspirator H. Montes to further the 

alliance between the Mexican Mafia and La Familia. 



170. On or about March 14, 2012, defendant MORENO, in a 

telephone conversation using coded language, discussed with CI-1 

waiting for defendant RODRIGUEZ -LANDA to be released from prison 

to lead the Project, and MORENO said that RODRIGUEZ - LANDA had 

originally brought MORENO into the Project and that MORENO then 

got everyone else involved. 



171. On or about March 19, 2012, defendant MORENO, in a 

telephone conversation using coded language, discussed with CI-1 

violence in Mexico involving La Familia and a "break-away 

faction" of the. cartel. 



172. On or about March 22, 2012, an unindicted co- 

conspirator possessed "kites," or concealed prison notes, 

written by an unindicted incarcerated Mexican Mafia member to 

other incarcerated Mexican Mafia members on death row at San 

Quentin State Prison. In the kites, the Mexican Mafia member 

wrote that defendants RODRIGUEZ -LANDA, MORENO, MONTOYA, and VEGA 

were working on the alliance between the Mexican Mafia and La 

Familia, and that the alliance is called "the Project." 







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173. On or about March 22, 2012, defendant MORENO, in a 

telephone conversation using coded language, discussed with CI-1 

traveling to Mexico to meet with the leadership of La Familia in 

order to further the Project and obtain drug- proceeds to 

distribute to. incarcerated Mexican Mafia members. 



174. On or about March 26, 2012, defendant MORENO, in a 

telephone conversation using coded language, discussed with CI-1 

arranging a trip to Michoacan, Mexico, so that MORENO and others 

could meet with leaders of La Familia to obtain more drug 

proceeds, and MORENO and CI-1 discussed the fact that cartel 

members and associates were being protected by the Mexican Mafia 

as part of the Project. 



175. On or about May 2, 2012, defendant SOTO, who had 

recently been released from Pelican Bay State Prison, met with 

CI-1 to discuss the alliance between the Mexican Mafia and La 

Familia. SOTO acknowledged having received money orders while 

he was in custody, accepting $2,000 in furtherance of the 

alliance, and agreed to assist in carrying out the Project. 



176. On or about May 8, 2012, defendant SOTO, in a 

telephone conversation using coded language, told CI-1 that SOTO 

had been instructed by senior Mexican Mafia Members at Pelican 

Bay State Prison to take control of the Project. 



177. On or about May 10, 2012, defendant SOTO, in a 

telephone conversation using coded language, agreed with CI-1 to 

collect drug proceeds from the sale of nine units of drugs 

supplied by defendant F. MONTES and co-conspirator H. Montes and- 

to distribute part of those proceeds to incarcerated Mexican 

Mafia members. 



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178. On or about May 12, 2012, in a. telephone conversation 

using coded language, defendant MONTOYA and CI-1 discussed drug 

proceeds that MONTOYA, CI-1, and others had previously delivered 

to incarcerated Mexican Mafia members, and CI-1 said that 

defendant SOTO would be taking over management of the Project 

per instructions from incarcerated Mexican Mafia members. 



179. On or about May 20, 2012, defendant SOTO met with 

defendant F. MONTES and co- conspirator H. Montes in Santa 

Clarita, California, to discuss the Project and obtain drug 

proceeds . 







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COUNT TWO 



[21 U.S. C. §§ 841(a)(1), (b) (1) (B) (vii) ; 18 U.S.C. § 2(a)] 

On or about October 12, 2011, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES, 

also known as ("aka") "Fredrico Montes," LUIS GERARDO VEGA, aka 

"Little," aka "Little One," and CLAUDIA GARCIA, aka "Giggles," 

aiding and abetting each other, knowingly and intentionally 

possessed with intent to distribute at least 100 kilograms, that 

is, approximately 135 kilograms, of marijuana, a Schedule I 

controlled substance. 







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COUNT THREE 



[21 U.S. C. §§ 841(a)(1), (b) (1) (A) (viii) ; 18 U.S.C. § 2(a)] 

On or about January 27, 2012, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES, 

also known as ("aka") "Fredrico Montes," and ADAM RIOS, aka 

"Blanco," aka "Little Blanco," aiding and abetting each other, 

knowingly and intentionally possessed with intent to distribute 

at least 50 grams, that. is, approximately 1,303 grams, of 

methamphetamine, a Schedule II controlled substance. 







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COUNT FOUR ' 

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

On or about January 27, 2012, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES, 

also known as ("aka") "Fredrico Montes," and ADAM RIOS, aka 

"Blanco," aka "Little Blanco," knowingly and intentionally 

distributed at least 50 grams, that is, approximately 1,303 

grams, of methamphetamine , a Schedule II controlled substance. 







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. COUNT FIVE 



[21 U.S. C. §§ 841(a)(1), (b) (1) (A) (viii) ; 18 U.S.C. § 2(a)] 

On or about January 31, 2012, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES 

also known as ( w aka") "Fredrico Montes," and MANUEL LARRY 

JACKSON, aka "Cricket," aiding and abetting . each other, 

knowingly and intentionally possessed with intent to distribute 

at least 5 00 grams, that is, approximately 906 grams, of a 

mixture or substance containing a detectable amount of 

methamphetamine, a Schedule II controlled substance. 







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COUNT SIX 



[21 U.S.C. §§ 841(a)(1), (b) (1) (A) (viii) ; 18 U.S.C. § 2(a)] 

On or about February 3, 2012, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES, 

also known as ("aka") "Fredrico Montes," MANUEL LARRY JACKSON, 

aka "Cricket," ADAM RIOS, aka "Blanco," aka "Little Blanco," and 

OMAR HUGO ROBLES, aiding and abetting each other, knowingly and 

intentionally possessed with the intent to distribute at- least 

50 grams, that is, approximately 872 grams, of tnethamphetamine, 

a Schedule II controlled substance. 







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COUNT SEVEN 

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

On or about February 3, 2012, in Los Angeles County, within 

the Central District of California, defendants FREDDIE MONTES, 

also known as ( n aka") "Fredrico Montes," and ADAM RIOS, aka 

"Blanco," aka "Little Blanco," knowingly and intentionally 

distributed at least 50 grams, that is, approximately 872 grams, 

of me thamphet amine, a Schedule II controlled substance. 







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FORFEITURE ALLEGATION 

[21 U.S.C. § 853] 



1. The allegations contained in Counts One through Seven 

of this Indictment are hereby repeated, realleged, and 

incorporated by .reference herein as though fully set forth at 

length for the purpose of alleging forfeiture pursuant to the 

provisions of Title 21, United States Code, Section 853. 

Pursuant to Rule 32.2, Fed. R. Crim. P., notice is hereby given 

to the defendants that the United States will seek forfeiture as 

part of any sentence in accordance with Title 21, United States 

Code, Section 853, in the event of any defendant's conviction 

under any of Counts One through Seven of this Indictment. 



2. Each defendant convicted under any of Counts One 

through Seven shall forfeit to the United States any property 

constituting, or derived from, any proceeds the person obtained, 

directly or indirectly, as the result of such violation and any 

of the person's property used, or intended to be used, in any 

manner or part, to commit, or to facilitate the commission of, 

such violation. 



3. Pursuant to Title 21, United States Code, Section 

.853 (p), each defendant shall forfeit substitute property, up to 

the value of the total amount described in paragraph 2, if, as 

the' result of any act or omission of said defendant, the 

property described in paragraph 2, or any portion thereof 



(a) cannot be located upon the exercise of due diligence; 



(b) has been transferred, sold to, or deposited with a third 

party; (c) has been placed beyond the jurisdiction of the court; 

(d) has been substantially diminished in value; or (e) has been 







commingled with other property that cannot.be divided without 

difficulty. 



A TRUE BILL 









ANDRE BIROTTE JR. 

United States Attorney 



ROBERT E. DUGDALE 



Assistant United States Attorney 



Chief, Criminal Division 









ELIZABETH R. YANG 



Assistant United States Attorney 



Chief, Violent and Organized Crime Section 







RODRIGO A. CASTRO -SILVA 

Assistant United States Attorney 

Chief, OCDETF Section 







J. MARK CHILDS 



E. MARTIN ESTRADA 



JENNIFER L. WILLIAMS 



Assistant United States Attorneys 







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