IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO UNITED STATES or AMERICA, INDICTMENT I, u: - t? ?3 CRMAL NO. re; 3 L33 JOSUE VAZQUEZ-CARRASQUILLO, VIOLATIONS: a/k/a ?Mayito/Mayo/El Father?, . qt (Counts 1?3, 6?7, 8-9) COUNT ONE 5 E5 PEDRO VIGIO-APONTE, Racketeer In?uenced and Cerrupt .- a/k/a ?Pedrito/ Pedrito He Man/Pelle/Redrito Trauma?, (Counts 1-3, 6?7) FRANKIE ROSA-CALDERON, a/k/a ?Anky/EI Negro/Frank?, (Counts 1-3) LUIS F. ALICEA-COLON, a/k/a ?Trenza/Enano/Luis Trenza?, (Counts 1?2, 4-5, 8-9) MIGUEL a/k/ a ?MigueIo/RadioMicIo/BJ?, (Counts 1-3) RUBEN a/k/ a ?Rulien E1 Negro"; (Counts I - ERNESTO MORALES-CASTRO, a/k/a ?Nestor/L03 Gordit?'s'?; (Counts 1-3) CHRISTIAN MORALES-CASTRO, a/k/a ?Bimbo/Les Gorditos?, (Counts 1-3) . REYFRANK elk/a ?Peloter'o?, (Counts 1-3, 6?7) [10] KELVIN D. MORALES-CINTRON, (Counts 1?3) [11] ISMAEL DIENDEZ-ARROYO, a/k/a ?Bol?lo?, (Counts 1?3) - [12] MICHAEL MUNIZ-SANCHEZ, (Counts 1-2) [13] JONATHAN PEREZ-RODRIGUEZ, a/k/a ?Perra/Perreke?, (Counts 1-2) Organiiations Act, 18 U.S.C. 1962(d) COUNT TWO Conspiracy to Possess with Intent to Distribute a Controlled Substance Within a Protected Location, 21 U.S.C. 846 and 860 COUNT THREE Using and Carrying Firearms During and in Relation to a Drug Traf?cking Crime, 18 U.S.C. 924(c)(1)(A) COUNTS FOUR, SIX, and EIGHT Drive By Shooting, 18 U.S.C. COUNTS FIVE, SEVEN, and NINE Use and Carry of a Firearm During and in Relation to a Crime of Violence, 18 U.S.C. 924(c)(1)(A) and RICO Forfeiture 18 U.S.C. 1963 Narcotics Forfeiture Allegation 21 U.S.C. 853 Firearms Forfeiture Allegation 28 U.S.C. 2461(c) [14] JOSE L. ORTIZ-AGUIRRE, a/k/a ?Chea/ Cheo Cede?o?, (Counts 1-3) [15] REINALDO RODRIGUEZ- MARTINEZ, a/k/a ?Pitbuli?, (Counts 1?3) [16] WILLIAM ORTIZ-AGUIRRE, a/k/a ?Maya/Play?, (Counts 1-3) [17] FIGUEROA-OSORIO, a/k/a ?Sony/Sonata?, (Counts 1-3) [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/ Scary?, (Counts 1-3, 6-7) [19] JOSE E. a/k/a ?Papito Mojica?, (Counts 1?2) [20] VICTOR M. RODRIGUEZ-TORRES, alkla ?Cuca/Cucaracha/Papotin?, (Counts 1-3, 67) [21] RAFAEL ANDINO-OJEDA, a/k/a ?Rafa! Rafa Colgate/Boca Chula?, (Counts 1-3) [22] MYLES J. ROMAN-ADORNO, (Counts 1-2) [23] GUILLERMO SAN a/k/a ?Guillo?, . (Counts 1?2) [24] ENIANUEL a/k/a ?Punky/Dalmata?, (Counts 1-3, 6-7) [25] ALEXANDER a/k/a ?Lechon?, (Counts 1-3) [26] DAVID E. RODRIGUEZ-CASTRO, (Counts 1-2) [27] RAFAEL a/k/a ?Bolillo?, (Counts 1-2) [28] ALEXIS a/k/a - (Counts 1-3) [29] ANGEL L. SOT a/k/a ?Huesito?, (Counts 1-2) [30] OSCAR A. allda ?Alex?, (COunts 1?3, 4?9) [31] JESUS a/k/ a ?Romulo?, (Counts 1?3) [32] JOSE L. MENDEZ-DE-JESUS, afk/a (COunts 1?3) [33] WILLIAM a/k/a ?W/Willito?, (Counts 1-3, 4-5) [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy?, (Counts 1-3) [35] ARNALDO ALICEA-COLON, a/k/a ?Naldito?, (Counts 1-2) [36] XAVLER a/k/a ?Raton?, I (Counts 1?3, 4?7) [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos E1 NegroMarcel?, (Counts 1?3, 8-9) [38] ANALDI AN a/k/a ?ijbito?, (Counts 1?3, - [39] ORLANDO J. SANTAN a/k/a ?Fina?, (Counts 1-3) [40] LUIS RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, (Counts. 1-3) [41] JESUS E. a/k/a ?Luis Garcia-Diaz/Willy Wonka?, (Counts 1-3) [42] AMAURY . a/k/a ?Boty?, (Counts 1?3) [43] LUIS afk/a ?Kimbe/Bauncer/Jose Boria-NIillan?, (Counts 1?3, 4-7) [44] FNU LNU, a/k/a ?Eziel?, (Counts 1-3) [45] LUIS MARTINEZ-NIEVES, a/k/a ?Raya/Trenza?, (Counts 1-3) [46] MCHAEL RIVERA-RODRIGUEZ, (Counts 1-3) [47] ALVIN A. CABEZAS-CWTRON, a/k/a ?Ardilla?, (Counts 1-3) [48] M. (Counts 1?3) [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin?; (Counts 1-3) [50] ROBERTO FUENTES-PACHECO, a/k/a ?Junth Parcha?, (Counts 1-3) [51] (ROGER a/k/a (Counts 1?3) [52] FELIX A. a/k/a ?Cholon?, (Counts 1?3) . [53] EDGARBO LUNA-LOPEZ, a/k/a ?Piri/ Enano?, (Counts 1-3) [54] JESSY J. MLENDEZ-HERNANDEZ, a/k/a ?Koby/El Negro/Lely?, (Counts L3) [55] DENZEL RODRIGUEZ- CARABALLO, (Counts 1-3) [56] ABMAEL a/k/a ?Lindo/FeoMetra?, (Counts 1-3) ANGEL L. COTTO-NEGRON, a/k/a ?Quij a/Kija?, (Counts 1-2) [58] JOSE E. a/k/a ?Camon?, (Counts 1-2, 8?9) '1 [59] FNU LNU, ?abt? 2, (Counts 1-3, 8-9) [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, (Counts 1-3, 8-9) [61] ORLANDO a/k/a ?Oreo/Willito/Angel M. Santiago- Ayala?, (Counts 1-3, 8-9) [62] a/k/a ?Sosa?, (Counts 1-3) [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, (Counts 1?3) [64] WILFREDO RUIZ, a/k/a ?Freddy?, (Counts 1-3) [65] CARLOS E. a/k/a ?El Barber/Wiso El Barber?, (Counts 1-3) [66] CARLOS (Counts 1-3, 4-5) [67] JONATHAN FIGUEROA-CATINCHI, a/k/a ?Katinchi?, (Counts 1?3) [68] IRAM I. a/k/a ?Cubano? (Counts 1?2) . [69] CHARLIE J. a/k/a ?Chiry?, (Counts 1-3) [70] EDGARDO R. a/k/a ?Masacre/Masa?, (Counts 1-2) [71] FRANCISCO J. GONZALEZ- a/k/a ?Lento?, (Counts 1-2) [72] NESTOR R. a/k/a ?Nesti/Kilate?, . (Counts 1-3) [73] IVETTE VAZQUEZDROZ, a/k/a ?Ive/ Precious Moments?, (Counts 1?2) [74] BILLY CARRASQUILLO, a/k/a ?Meca/Billy Meca?, (Counts 1-2) JAYFRANK QUINONES-CARRION, (Counts 1?2) [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/Baloncelista/El Indie?, (Counts 1-3) [77] DANIEL 0. MARTINEZ-VELEZ, afk/a ?Berta?, (Counts 1:3) [78] LUIS F. DIAZ-TINEO, a/k/a ?Pipen/ Pipe?, (Counts 1?2) [79] OSUE O. a/k/a ?Gordo Puta?, (Counts 1?2) [80] RAMON a/k/a ?Poke?, (Counts 1?2) [81] LUIS E. GUADALUPE-CAMACHO, a/k/a (Counts 1-2) [82] JULIO N. MATOS-SANCHEZ, a/k/a ?Julio Mara?a?, (Counts 1?2) [83] REYNALDO GONZALEZ-ZAYAS, afk/a ?Cuto?, (Counts 1-2) [84] BRYAN MARTINEZ, a/k/a ?Fat Edy?, (Counts 1?3) [85] FERNANDEZ-JORGE, (Counts 1?2) [86] JOSE A. a/k/a ?Semilla?, (Counts 1?3) 7 [87] KEVIN (Counts 1-3) [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, (Counts 1?3) [89] DAVID GARCIA-FRANCO, a/k/a ?David Nata?, (Counts 1?3) [90] GIOVANI a/k/a ?Zegueta?, (Counts 1-3) [91] CHRISTIAN HERNANDEZ, a/k/a ?Chapa?, (Counts 1?3) [92] JAMES STEELE-TORRES, 7 W3 ?Negro Steele?, (Counts 1-2) [93] NILDA SANTIAGO-ESPJNOSA, a/k/a ?Katy/Kathy?, . (Counts [94] ALEX a/k/a ?Papo Swing/Ale?, (Counts 1-2) [95] FRANCISCO VARGAS-SANCHEZ, a/k/a ?Ma'ra?a?, (Counts 1-2) [96] CARLOS MIRANDA, a/k/a ?Eon, (Counts 1-2) [97] RAMON ANDINO-PEGUERO, . a/k/a ?Mono?, (Counts 1?2) [98] VICTOR ALFONSO-JORGE, a/k/a ?Nano?, (Counts 1-3) [99] HECTOR J. CRULVARGAS, a/k/a ?Funky?, (Counts 1?3) [100] YAMIL ARRIZMENDI-SANT ANA, a/k/a ?El Mono?, (Counts 1?2) [101] ROBERT D. PEREZ-NUNEZ, a/k/a ?Minino?, (Counts 1?2) [102] ANTHONY ESPADA-COLON, a/k/a ?Oreo/Apu?, (Counts 1?2) I [103] DANIEL a/k/a ?Paleta?, (Counts 1-3) [104] LUIS E. a/k/a ?Zena? (Counts 1?3) [105] ASTRID J. MARTINEZ-VALEN TIN, afk/a ?La efa?, (Counts 1-2) Defendants. THE GRAND JURY CHARGES: COUNT ONE (Racketeer In?uenced and Corrupt Organizations .Act) The Enterprise At mans times relevant to this Indictment, JOSUE VAZQUEZ-CARRAS QUILLO, a/k/a ?MayitoMayo/EI Father?; PEDRO a/k/a ?Pedrito/Pedrito He- ManJPello/Ped?to Trauma?, FRANKIE a/k/a ?Anky/EI Negro/Frank?, LUIS F. a/k/a ?Trenza/Enano/Luis Trenza?, MIGUEL MARTINEZ, a/k/a ?Mguelo/Radio/Mielo/BJ?, RUBEN a/k/a ?Ruben E1 Negro?, ERNESTO MORALES-CASTRO, a/k/a ?Nestor/Los Gorditos?, CHRISTIAN a/k/a ?Bimbo/L03 Gorditos?, REYFRANK QUINONES-CARRION, a/k/a ?Pelotero?, [10] KELVIN D. [11] ISMAEL a/k/a ?Bolillo?, [12] MICHAEL [13] JONATHAN a/k/a ?Perra/Perreke?, [14] JOSE L. a/k/a ?fCheo/Cheo Cede?o?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/a ?Pitbull?, [16] WILLIAM a/k/a ?Maya/Play?, [17] KJDANNY a/k/a ?Sony/Sonata?, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?, [19] JOSE- E. MOJICA-ROBLES, a/k/a ?Papito Mojica?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin?, [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Bow Chula?, [22] MYLES J. ROMAN-I ADORNO, [23] GUILLERMO SANCHEZ-MORA, a/k/a ?Guillo?, [24] EMANUEL PEREZ, a/k/a ?Punky/Dahnata?, [25] ALEXANDER a/k/a ?Lechon?, [26] DAVID E. [27] RAFAEL HIRALDO-ALEJANDRO, a/k/a ?Bol?lo?, [28] ALEEGS a/k/a [29] ANGEL L. SOTO-RAMOS, a/k/a ?Hussite?, [30] OSCAR A. a/k/a ?Alex?, [31] JESUS DE-JESUS- COLON, a/k/a ?Romulo?, [32] JOSE L. a/k/a ?Sonso/Nariz?, [33] WILLIAM a/k/a ?W/Willito?, [34] EDGAR afk/a ?Eggy?, [35] ARNALDOALICEACOLON, a/k/a ?Naldito?, [36] XAVIER CASTRO- VEGA, a/k/a ?Raton?, [37] CARLOS M. a/k/a ?CarIitos E1 N?gro/Marcel?, [38] ANALDI a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fine?, [40] LUIS F. a/Ida ?CheykiE?, [41] JESUS a/k/a ?Luis Garcia-DiaZ/Willy Wonka?, [42] AMAURY a/k/a ?Boty?, [43] A, LUIS a/k/a ?ijbofBauncer/Jose Boria-L?jlan?, [44] ENU LNU, afk/a ?Eziel?, [45] LUIS NIEVES, a/k/a ?Ram/Irena": [46] MICHAEL RIVERA-RODRIGUEZ, [47] ALVIN A. CABEZAS-CINTRON, a/k/a ?Ard?la?, [48] JAIME M. [49] KENNY 0. PACI-IECO, a/k/a ?Keny/Bolin?, [50] ROBERTO a/k/a ?Jum'to Parcha?, [51] ROGER a/k/a ?Gua?, [52] FELIX A. a/k/a ?0101011?, [53] EDGARDO a/k/a ?Phi/Enano?, [54] JESSY J. HERNANDEZ, a/k/a?KobY/E1Negro/L61y?, [55] DENZEL RODRIGUEZ-CARABALLO, [56] ABIMAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/Feo/Metra?, [57] ANGEL L. NEGRON, a/k/a ?Quija/Kija?, [58] JOSE E. a/k/a ?Camon?, [59] ENU LNU, a/k/a ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, afk/a ?Tego?, [61] ORLANDO PADILLA-AYALA, a/k/a ?OreoWiUito/Angel M. Santiago-Ayala?, [62] KERNIS RODRIGUEZ-RIVERA, a/k/a ?Sosa?, [63] WALTER D. a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, [65] CARLOS E. COLLANTES, a/k/a Barber/W130 E1 Barber?, [66] CARLOS a/k/a ?Pirjn?, [67] JONATHAN a/k/a ?Katinehi?, [68] IRAM I. a/k/a ?Cubano?, [69] CHARLIE J. a/k/a ?Chiry?, [70] EDGARDO R. a/k/a ?Masacre/Masa?, [71] FRANCISCO J. a/k/a ?Lento?, [72] NESTOR R. a/k/a ?Nesti/K?ate?, [73] a/k/a ?Ive/Precious Moments?, [74] BILLY a/k/a ?Mesa/Billy Mesa?, [75] JAYFRANK QUINONES- CARRION, [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/BaloncelistafEl Indie?, [77] DANIEL O. MEEZ-VELEZ, a7k/a ?Berto?, [78] LUIS F. a/k/a ?Pipen/Pipe?, [79] JOSUE O. a/k/a ?Gordo Puta?, [80] RAMON a/k/a ?Poke?, [81] LUIS E. a/k/a [82] JULIO N. a/k/a ?Julio Mara?a?, [83] REYNALDO GONZALEZ-ZAYAS, a/k/a ?Cute?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [85] DAMIAN FERNANDEZ-JORGE, [86] JOSE A. FOURNIER-COLLAZO, afk/a ?Semi?a?, [87] KEV1N CASTRO-VEGA, [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID GARCIA-FRANCO, a/k/a ?David Nata?, [90] GIOVANI IUSTINIANO-DIAZ, a/k/a ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, [92] JAMES STEELE-TORRES, a/k/a ?Negro Steele?, [93] NILDA SANTIAGO-ESPINOSA, elk/a ?Katy/Kathy?, [94] ALEX a/k/a ?Papo Swing/Ale?, [95] FRANCISCO a/k/ei ?Mara?a?, [96] CARLOS MIRANDA, a/k/a [97] RAMON afk/a ?Mono?, [98] VICTOR a/k/a ?Nam?, [99] 10 HECTOR I. CRUZ-VARGAS, a/k/a ?Funky?, [100] YAMIL a/k/a ?El Mono?, [101] ROBERT D. PEREZ-NUNEZ, a/k/a ?Minino?, [102] ANTHONY ESPADA- a/k/a ?Oreo/Apu?, [103] DANIEL a/k/a ?Paletai?, [104] LUIS E. a/k/a ?Zena?, and, [105] ASTRID I. a/k/a ?La Jefa?, the defendants herein, and others known and unknown, were members and associates of a criminal organization whose members and associates engaged in drug distribution, robbery and acts of violence, including murder. The criminal organization, referred to as La Rompe ONU or La Rompe, including its members and associates, constituted an ?enterprise,? as de?ned by 18 U.S.C. 1961(4) (?the enterprise?), that is, a group of individuals associated in fact. The enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise. The enterprise was engaged in, and its activities affected, interstate, and foreign commerce. Background of the Enterprise (La Rompe Most street level drug sales in the San Juan, Puerto Rico, metropolitan area are controlled by- gangs operate in public housing projects. Generally, each housing project has its own gang which is organized in a similar fashion, leaders, drug point owners, enforcers, runners, sellers, drug processors, facilitators and look-outs. For decades these drug gangs fought over control of the drug points within the various housing projects. The violence associated with these battles regularly brought the attention of local and federal authorities, which negativer affected drug sales and resulted in large scale conspiracy indictments. in or-around 2004, the leaders from nearly all of the drug gangs in the San Juan, Puerto Rico, metropolitan area gathered for the purpose of conducting a meeting. At said meeting, the leaders agreed to form an alliance. The purpose of this alliance was to resolve con?ict between 11 the previously rival drug gangs in a way that would not bring about the attention of local and federal authorities, thus ensuring increased pro?ts from drug sales for all and reducing the risk of federal charges. They agreed that if con?ict arose between members of the alliance, the leaders from the different housing projects would discuss the issue with each other to resolve it. At this meeting, the leaders named the alliance La ONU (GNU stands for: Organizacion de Narcotra?cantes Unidos). For a time, the alliance remained intact; members of drug gangs aligned with La ONU could visit and sell narcotics in other La ONU aligned housing projects, as long as they had the permission of the leader of each speci?c housing project. Additionally, the leaders of the different housing projects met regularly to discuss drug related issues and to resolve con?icts. The alliance, however, weakened over time. Certain housing project gangs became disgruntled with La GNU-and sought to break off. After several or about the year 2007, La ONU broke into two separate rival factions, La ONU and La Rompe ONU. Soon thereafter, the housing project gangs in the metropolitan area were essentially split evenly between those belonging to La ONU and La Rompe ONU. From that point on, the goal of La Rompe ONU was to maintain control over the drug points in their housing projects by force and to kill La GNU members and leaders in order to expand. The leaders of La Rompe continued to meet together to resolve internal con?icts 7 and discuss strategies to take over housing projects under La control. La Rompe ONU leaders Would regularly pool their resources to purchase weapons, vehicles, and other items to engage in violent acts. Also, the members from the various La Rompe ONU housing projects would jointly attack and commit murders of the La ONU members. Each housing project would provide some of their enforcers, or hit men, for these joint operations. 12 Members of La Rompe ONU that committed murders and other violent acts were given bene?ts, including weapons, money, and the ability to advance within the criminal enterprise. Though unwritten, the general rules members of La Rompe GNU had to follow, included, but were not limited to: no associating with La ONU members; 2) kill La ONU members on sight; 3) no killing of other members of La Rompe ONU without leadership authorization; 4) no overtaking housing projects/drug points owned by another member of La Rompe and 5) no I cooperating with law enforcement. Any violation of these rules resulted in punishment by death to the Violator and their family. Purposes of the Enterprise I i The purposes of the enterprise included the following: 1. Enriching the members and associates of the enterprise through the distribution of narcotics. 2. Preserving. and protecting the power, territory, and pro?ts of the enterprise through the use of intimidation, violence, threats of violence, assault, and murder. Concealing its activities by obstructing justice. U.) 4.. Promoting and enhancing the enterprise and its members? and associates? activities. 5. Keeping people in fear of the enterprise and in fear of its members and associates through threats of violence and murder. . 'Means and Methods of the Enterprise Among the manner and means by which the defendants and co-conspirators conducted and participated in the conduct of the a?airs of the enterprise were the following: 13 . 'Members of the enterprise and their associates would act in different roles in order to further the goals of the enterprise, to wit: leaders, who directed and supervised, drug point owners, enforcers, suppliers, runners, sellers, and drug processors. Members of_ the enterprise and their associates would purchase wholesale quantities of heroin, cocaine, and marijuana in order to distribute the same in street quantity amounts at their drug distribution points. i . Members of the enterprise and their associates would purchase Wholesale quantities of cocaine and would convert it' into crack cocaine, ?cooked?, for subsequent sale and distribution at their drug distribution points. . Members of the enterprise and their? associates would use residences and apartments within the controlled areas in order to store and conceal heroin, cocaine base ?crac cocaine, marijuana, drug paraphernalia, ?rearms, and ammunition. Members of the enterprise and their associates would routinely possess, carry, brandish, and use ?rearms to protect themselves and their drug traf?cking organization. At different points during the conspiracy, the leaders would provide to some members of the organization different types of ?rearms, including but not limited to ?high power? ri?es, in order to protect themselves, the narcotics and the profits from rival drug traf?cking gangs. I Members of the enterprise and their associates promoted a climate of fear through violence and threats of violence. They would commonly use and threaten to use physical violence against their rivals. Members of the enterprise and their associates committed, attempted, and threatened to commit acts of violence, including murder, to protect and expand the enterprise?s l4 10. ll. 12. 13. criminal operations. They were instructed to shoot and kill suspected rival drug traf?dking members. Members of the enterprise and their associates would use force, violence, and intimidationin order to intimidate rival drug traf?cking organizations, and in order to discipline members of their own drug traf?cking organization. Members of the enterprise and their associates Used violence against law enforcement o?icers to escape detection and apprehension. They would also pay bribes to law enforcement of?cers for information on informants or cooperators and for information as to law enforcement initiatives to disrupt the drug points. Members of the enterprise and their associates would often alter their firearms (pistols and high power ri?es) in order to make them fire in a fully automatic mode. Members of the enterprise and their associates would pool resources with other housing projects aligned with La Rompe ONU in order to accomplish criminal acts. Members of the enterprise and their associates provided shelter and protection to known fugitive members of La Rompe GNU in order to aid against their apprehension by law enforcement. Often, they would pay attorney?s fees and hail money for lower level members to prevent cooperation with law enforcement. Members of the enterprise and their associates would use two-way radios (?wande? talkies?. referred to as scanners) in order to communicate and alert the presence of law enforcement agents or members of rival gangs inside their controlled areas. 14. Members of the enterprise and their associates would rob persons and businesses at gun point. 15 15. Members of the enterprise and their associates would use the money obtained from the robberies to purchase drugs, ?rearms, and ammunition to be used in furtherance of La Rompe ONU. I i 16. Members of the enterprise andtheir associates conducted and participated in gun point robberies of motor vehicles (commonly referred to as ?caij ackings?). 17. Members of the enterprise and their associates would in turn use the stolen motor vehicles during subsequent robberies and drive-by shootings. 18. The vehicles that Were robbed were ?cloned? that is members of the enterprise and their associates would locate an identical ?legal? vehicle and would copy the license plate and VEN number to use the same in the ?cloned? vehicle. Roles of the Defendants A. Leaders/Drug Point Owners/ Drug Point Administrators Leaders directly controlled and supervised the drug traf?cking activities at the drug points located at the Public Housing Projects controlled by La Rompe ONU, Which include: Jardines del Paraiso Public Housing Project, Villa Andalucia Public Housing Project,.Alturas de Cupey Public Housing Project, Iardines de Cupey Public Housing Project, Brisas de Cupey Public Housing Project, Los Claveles Public Housing Project, Nuestra Se?ora de Covadonga Public Housing Project, Los Lirios Public Housing Project, Jardines de Monte Hatillo Public Housing Project, Jardines de Campo Rico Public Housing Project, Jardines de Berwind Public Housing Project, San Martin Public Housing Project, Monte Park Public Housing Project, El Polvorin Ward, Villa Lomas ,Verdes. Public Housing Project, Mango Sector and other areas nearby, Within the Municipalities of San Juan, Trujillo Alto and Carolina, Puerto Rico. 16 Drug point owners purchased multi?kilogram quantities of narcotics and oversaw the transportation and sale of such narcotics at the drug points located at the Iardines del Paraiso Public Housing Project, Villa Andalucia Public Housing Project, Alturas de Cupey Public Housing Project, Iardines dc Cupey Public Housing Project, Brisas de Cupey Public Housing Project, Los Claveles Public Housing Project, Nuestra Senora de Covadonga Public Housing Project, Los Lirios Public Housing Project, Jardines dc Monte Hatillo Public Housing Project, Jardines dc Campo Rico Public Housing Project, Iardines de Berwind Public Housing Project, El Polvoring Ward, Villa Lomas Verdes Public Housing Project, Mango Sector and other areas nearby, within the Municipalities of San Juan, Trujillo Alto and Carolina, Puerto Rico. At various times during the course of the conspiracy, leaders purchased ?rearms and allowed members to use and carry such ?rearms and ammunition in order to protect the leaders and members of La Rompe ONU, the narcotics, the proceeds derived from their sales, and to further accomplish the goals of the conspiracy. The following co?conspirators acted as leaders and drug point owners: OSUE VAZQUEZ-CARRASQUELO, Father? was the main leader of La Rompe ONU. In or about the year 2007, upon the arrest of an unindicted co?conspirator, JOSUE a/k/a ?Mayito/Mayo/El Father?,became the main leader of La Rompe ONH, wherefore he controlled, through co?defendants also acting as leaders, the drug distribution points located in the areas controlled by the enterprise. As the main leader, he directly supervised the operations of the drug points, received the proceeds from the distribution iof narcotics sold during the span of his leadership in the conspiracy and was in charge of maintaining control of all the drug distribution activities. He had the ?nal approving authority as 17 to the discipline to be imposed upon members of the conspiracy, as well as its enemies and rivals. At some point in the conspiracy, OSUE a/k/a ?Mayito/Mayo/El Father? was the ?owner? of the crack cocaine and heroin sold at the Jardines del Paraiso Public Housing Project drug points. As the main leader, he would also receive payment or ?rent? from other drug points, including-but not limited to drug points located in Los Claveles, Villa Andalucia, and Nuestra Se?ora de Covado?nga Public Housing Projects. He would also often act as an enforcer and as a supplier within the conspiracy. As an enforcer, he would useand carry ?rearms during and in relation to the drug trafficking activities and would allow other members of the conspiracy, to carry and use ?rearms during and in relation to the drug trafficking activities. As a supplier, he would supply narcotics and firearms, including but not limited to ?high power? ri?es, to other members of La Rompe ONU in order to further the goals of the conspiracy. I PEDRO a/kfa ?Pedrito/Pedrito HeiMan/Pello/Pedrito Trauma? also a leader in La Rompe ONU. He was the second in charge of La Rompe ONU. He was in charge of the drug points during the absence of the main leader. He would be in charge of the administration of the drug points and its daily operations. He would also act as a drug point owner and as an enforcer within the conspiracy. As a drug point owner, he was the ?owner? of the: crack cocaine, powder cocaine, and heroin sold at the Jardines del Paraiso, Villa Andalucia, Monte Hatillo, and Nuestra Se?ora de Covadonga Public Housing Projects. As an enforcer, he would carry and use ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to carry and use firearms during and in relation to the traf?cking activities. 18 FRANKIE a/k/a ?Anky/El aggro/Frank? was also a leader in La Rompe ONU. Speci?cally, he was the leader at Alturas de Cupey Public Housing Project. He would also act as a drug point owner and as an enforcer within the conspiracy. He was the ?owner? of the powder cocaine sold at the drug points in Los Claveles and Alturas de Cupey Public Housing Project. He was also known as the ?owner? of the crack cocaine sold at the Jardines del Paraiso Public Housing Project drug pointAs an enforcer, he would carry and use ?rearms during and-in relation to the drug traf?cking activities and would allow other members of the conspiracy to. carry and use ?rearms dining and in relation to the drug trafficking activities. - i LUIS F. ALICEA-COLON, a/lc/a ?Trenza/Enano/Lliis Trenza? was also a leader in La Rompe ONU. He would also act as a drug point owner and as an enforcer within the conspiracy. He was the ?owner? of the crack cocaine and marijuana sold at the drug points in Los Laureles and Los Claveles Public Housing Projects and at E1 Mango sector. As an enforcer, he would carry and use ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to carry and use ?rearmsduring and in relation to the drug traf?cking activities. MIGUEL VAZQUEZLBKARTINEZ, alk/a ?Miguelo/RadioMclo/BJ? was also a leader in La Rpmpe ONU. Speci?cally, he was the leader at lardines- de Monte Hatillo, San Martin, El Polvorin, .Tardines de Berwind, Jardines de Campo Rico and Monte Park Public Housing Projects. He would also act as a drug point owner and as an enforcer within the conspiracy. He was the ?owner? of the crack cocaine, powder cocaine, and marijuana that was sold at drug points in Jardines de Monte Hatillo and Nuestra Se?ora de Covadonga Public - Housing Projects. At some point in the conspiracy, he was appointed by the main leader to 19 supervise the operations of the drug points at Jardines de Monte Hatillo, San Martin, El olvorin,? Jardines de Berwind, Jardines de Campo Rico, and Monte Park Public Housing Projects and maintaining the control of all the drug distribution activities in those areas. As an enforcer, he would carry and use ?rearms during and in relation to the drug traf?cking activities and would allow other members of the con3piracy to carry and use ?rearms during and in relation to the traf?cking activities. RUBEN COTTO-ANDINO, a/k/a ?Ruben El Negro? was also a leader in La Rompe ONU. Speci?cally, he was the leader at Jardines de Cupey and Brisas de Cupey Public Housing Projects. He would alsoreceive payment or ?rent? from the ?owner? of the narcotics sold at the drug'points in lardines de Cupey Public Housing Project and Brisas de Cupey Public Housing Project. ERNESTO a/kla ?Nestor/Les Gorditos? was also a leader in La Rompe ONU. He was the leader at Iardines de Cupey Public Housing Project jointly with his brother CHRISTIAN a/k/a ?Bimbo/Les Gorditos?. He would also act as a drug point owner within the conspiracy. He was?the ?owner? of the crack cocaine sold at the drug point in Jardines .de Cupey Public Housing Project. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. I CHRISTIAN MORALES-CASTRO, a/k/a ?Bimbo/Les Gorditos? was also a leader in La Rompe ONU. He was the leader at Jardines de Cupey Public Housing Project jointly with his brother ERNESTO MORALES-CASTRO, a/k/a ?Nestor/Les Gorditos?. He would also act as a drug point owner within the conspiracy. He was the ?owner? of the crack cocaine sold at the drug point in Jardines de Cupey Public Housing Project. He would also use and carry ?rearms during and in relation to the drug trafficking activities. 20 REYFRANK afk/a ?Pelotero? was also a leader in La Rompe ONU. He was the leader at Nuestra Se?ora do Covadonga Public Housing. Project. He would also act as a drug point owner and as an enforcer within the conspiracy. He was the ?owner? of crack cocaine, powder cocaine, heroin, and marijuana sold atthe drug points in Nuestra Se?ora de Covadonga Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug trafficking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. [10] KELVIN 1). acted as a drug point owner and a supplier for La Rompe ONU. He was the ?owner? of the powder cocaine and marijuana sold at the drug point in Los Terrenos Ward,'in Cupey. As a supplier, he would supply narcotics and ?rearms to other members of La Rompe ONU in order to further the goals of the conspiracy. He would also use and carry ?rearms during and in relation to the drug tra??icking activities. [11] ISMAEL DIENDEZ-ARROYO, a/k/a ?Bolillo? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the crack cocaine and marijuana sold at the drug points in Los Cleveles Public Housing Project and Nuestra Se?ora de Covadonga Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?reamis during and in relation to the drug traf?cking activities. [12] MICHAEL acted as a drug point owner and as an enforcer for La Rompe He was the ?owner? of the marijuana sold at the drug point in Jardines de Monte Hatillo Public Housing Project. As an enforcer, he would use and carry ?rearms during 21 and in relation to the drug traf?cking activities and would allow other members of the conspiracy . to use and carry ?rearms during and in relation to the drug traf?cking activities. [13] JONATHAN PEREZ-RODRIGUEZ, a/k/a ?Perra/Perreke? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the marijuana sold at the drug point in Jardines de Berwind Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during. and in relation to the drug traf?cking activities. [14] JOSE L. a/k/a ?Cheo/Cheo Cede?o? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the powder cocaine and marijuana sold at the drug pointin lardines del Paraiso Public Housing Project. He was also the ?owner? of the powder cocaine sold at the drug point in lardines de Monte Hatillo Public Housing Project. He would'also use and carry ?rearms during and in relation to the drug traf?cking activities. {15] RODRIGUEZ-MARTMZ, a/k/a ?Pitbull? acted as a drug point owner for La Rompe ONU. He was the L?owner? of the powder cocaine sold at the drug point in lardines del Paraiso Public Housing Project. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [16] WHLIAM a/k/a ?Playa/Play? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the powder cocaine and the prescription pills sold at the drug point in lardines del Paraiso Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. 22 i [17] KIDANNY FIGUEROA-OISORIQ, a/k/a ?Sony/Sonata? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the powder cocaine sold at the drug points in Nuestra Se?ora de Covadonga and Jardines del Paraiso Public Housing Projects. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. . [18] JOSE L. a/k/a ?Luisito/Scary? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the powder cocaine, crack cocaine, and marijuana sold at the drug points in lardines dc Monte Hatillo, Nuestra .Se?ora de Covadonga, and Jardines del Paraiso Public Housing Projects. As an enforcer, he would use and . carry ?rearms during and in relation to the trafficking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. [19] JOSE E. a/k/a ?Papito Mojica? acted as a drug point owner, as an enforcer, and as a drug processor for La Rompe ONU. He was the ?owner? of the crack cocaine, powder cocaine, and marijuana sold at the drug points in Jardines de Monte Hatillo, Nuestra Senora de Covadonga, Jardines del Paraiso, and Loleaureles Public Housing Projects. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking I activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. As a drug processor, he would ?cook? or convert wholesale quantities of cocaine into crack cocaine. [20] M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the marijuana sold at the drug 23 points in ardines dc Monte Hatillo and Nuestra Senora dc Covadonga Public Housing Projects. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Boca Chula? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the heroin and the powder cocaine sold at the drug point Jardines del Paraiso Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug tra?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. I [22] MYLES J. ROMAN-ADORNO acted as a drug point owner for La Rompe ONU. He was the ?owner? of the powder cocaine sold at the drug point in Nuestra Senora de Covadonga Public Housing Project. [23] GUILLERMO SANCHEZ-MORA, afk/a ?Guillo? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the heroin sold at the drug points in Nuestra Senora de Covadonga and Jardines del Paraiso Public Housing Projects. I [24] EMANUEL a/k/a. acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the heroin and the marijuana sold at the drug points in Iardines del Paraiso and Nuestra Senora de Covadonga Public Housing Projects. As an enforcer, he would use and carry firearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities.? [25] ALEXANDER RIVERA-CARRION, a/kia ?Lechon? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the powder cocaine and the marijuana sold at the 24 drug point inAlturas de Cupey Public Housing Project. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. A [26] DAVID E. acted as a drug point owner for La Rompe GNU. He was the f?owner? of the heroin sold at the drug point in Jardines de Cupey Public Housing Project. [27] RAFAEL a/k/a ?Bolillo? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the crack cocaine sold at the drug point in lardines de Cupey Public Housing Project. [28] ALEXIS a/k/a acted as a drug point owner and a supplier for La Rompe ONU. He was the ?owner? of the marijuana sold at the drug point in Alturas de Cupey Public Housing Project. As a supplier, he would supply narcotics and ?rearms, to other members of La Rompe ONU in order to ?irther the goals of the conspiracy. He would also use and carry ?rearms during and inrelation to the drug traf?cking activities. [29] ANGEL L. SOTO-RAMOS, a/k/a ?Huesito? acted as a drug point owner for La Rompe ONU. He was the ?owner? of the crack cocaine, powder cocaine, and marijuana sold at the drug point in Iardines de Monte Hatillo Public Housing Project. [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the marijuana sold at the drug points in Los Laureles and Los Claveles Public Housing Projects. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking ?activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. 25 [31] a/k/a ?Romulo? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the marijuana and powder cocaine sold at the drug point in Los Laureles Public Housing Project. As an enforcer, he would use and carry ?rearms during and. in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug activities. - i [32] JOSE L. a/k/a ?Schso/Nariz? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the marijuana sold at the drug point in Los Laureles Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. [33] WILLIAM a/k/a ?W/Willito? acted as a drug point owner and as an enforcer for La Rompe ONU. He was the ?owner? of the powder cocaine and marijuana sold at the drug point in Villa Lomas Verdes Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy? acted as a drug point owner and as an enforcer for La Roinpe ONU. He was the ?owner? of the marijuana sold at the drug point in Los Claveles Public Housing Project. As an enforcer, he would use and carry ?rearms during and in relation to the drug traf?cking activities and would allow other members of the conspiracy to use and carry ?rearms during and in relation to the drug traf?cking activities. 26 [35] ARNALDO ALICEA-COLON, a/k/a ?Naldito? acted as a drug point owner for La Rompe GNU. He was the ?owner? of the powder cocaine sold at the drug point in Villa Lomas Verdes Puhlic Housing Project. 13. Enforcers Enforcers possessed, carried, brandished, used and discharged ?rearms to protect the leaders and members of La Rompe ONU, the narcotics,??1e proceeds derived from their sales, and to further accomplish the goals of the conspiracy. Enforcers often acted upon instructions given by the leaders ?of this organization. Enforcers would often provide protection to La Rompe drug distribution points. In addition to those previously mentioned leaders and drug point owners who also acted as enforcers, the following individuals and others known and unknown, acted as enforcers for La Rompe ONU: [36] XAVIER CASTRO-VEGA, a/k/a ?Raton? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a drug point owner within the conspiracy. [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos El Negro/Marcel? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a drug point owner and an amied seller within the conspiracy. [38] ANALDI a/k/a ?Kimbito? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a runner and a seller the conspiracy. [39] ORLANDO J. SANTANA, a/k/a ?Fine? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a seller within the conspiracy. [40] LUIS F. RODRIGUEZ-MARQUEZ, elk/a ?Cheykin? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a drug point owner within the conspiracy. 27' [41] JESUS E. a/k/a ?Luis Garcia-Diaz/Willy Wonka? acted as an enforcer for La Rompe ONU. Additionally, he would often act as an armed seller the conspiracy. [42] AMAURY a/k/ a ?B?oty? acted as an enforcer for La Rompe Additionally, he would often act as an armed seller within the conspiracy. [43] LUIS a/k/al?Kimbo/Bauncer/Jose Boria-lVIillan? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a runner within the conspiracy. [44] FNU LNU, a/k/a ?Eziel? acted as an enforcer for La Rompe ONU. Additionally, he would often act as an armed seller within the conspiracy. LUIS MARTINEZ-NEWS, a/k/a acted as an enforcer for La Rompe ONU. Additionally, he would often act as an armed seller within the conspiracy. [46] MICHAEL RIVERA-RODRIGUEZ acted as an enforcer for La Rompe Additionally, he would often act as a drug point owner within the conspiracy. [47] ALVIN A. CABEZAS-CWTRON, a/k/a ?Ardilla? acted as an enforcer for La Rompe ONU. Additionally, he would often act as an armed seller within the conspiracy. [48] JAIME M. acted as an enforcer for La Rompe ONU. [49] O. PACHECO, a/k/a ?Keny/Bolin? acted as an enforcer for La Rompe ONU. Additionally, he would often act as an armed seller within the conspiracy. [50] ROBERT FUENTES-PACEECO, a/k/a ?Junito Parcha? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a drug point owner within the conspiracy. I [51] ROGER ALU-DIAZ, a/k/a ?Gua? acted as an enforcer for La Rompe ONU. 28 [52] FELIX A. a/k/a ?Cholon? acted as an enforcer for La Rompe ONU. - [53] EDGARDO a/k/a ?Piri/Enano? acted as an enforcer for La Ronipe ONU. Additionally, he would often act as an. armed seller Within the conspiracy. [54] JESSY J. a/k/a ?Koby/El Negro/Lely? acted as an enforcer for La Rompe ONU. Additionally, he would often act as a drug point owner Within the conspiracy. [55] DENZEL RODRIGUEZ-CARABALLO acted as an enforcer for La Romp?e ONU. [56] ABIMAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/Feo/Metra? acted as anenforcer for La Rompe ONU. Additionally, he would often act as a seller Within the conspiracy. ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kija? acted as an enforcer for La - Rompe GNU. Additionally, he would often act as a runner Within the conspiracy. [58] JOSE E. RIVERA-MALBONADO, a/k/a ?Camon? acted as an enforcer for La Rompe GNU: Additionally, he would often act as a seller Within the conspiracy. [59] FNU LNU, a/k/a ?Gaby? acted as an enforcer for he Rompe ONU. Additionally, he would often act as a seller Within the conspiracy. [60] JOSE D. a/k/a ?Tego? acted as an enforcer for La Rompe GNU. C. Suppliers The suppliers were the defendants and their co-conspirators that would perform or carry out several acts within the conspiracy including but not limited to, supplying narcotics, ?rearms, and ammunition to La Rompe ONU in order to further the goals of the conspiracy by 29 maintaining the control and dominion over the drug distribution points located in the Municipality of San Juan, Carolina, and Trujillo Alto, Puerto Rico. A A . In addition to those previously mentioned, the following individuals and others known and unknown, acted as suppliers for LaRompe GNU: [61] ORLANDO a/k/a ?Oreo/?NillitolAngel M. Santiago-Ayala? acted as a supplier for La. Rompe ONU. As a supplier, he would supply narcotics, ?rearms, and ammunition to other members of La Rompe ONU in order to further the goals of the conspiracy. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [62] KERNIS a/k/a ?Sosa? acted as a supplier for La Rompe ONU. As a supplier, he would supply narcotics, ?rearms, and ammunition to other members of La Rompe ONU in order to further the goals of the conspiracy. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. I [63] WALTER D. a/k/a ?Vampy/Bolo? acted as a supplier for La Rompe ONU. As a supplier, he would supply ?rearms and ammunition to other members of La Rompe ONU in order to further the goals of the conspiracy. He w0uld also use and carry ?rearms during and in relation to the drug traf?cking activities. [64] RUIZ, a?da ?Freddy? acted a supplier for the La Rompe ONU. As a supplier, he would supply ammunition to other members of La Rompe in order to further the goals of the conspiracy. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [65] CARLOS E. BRIOSO-COLLANTES, a/k/a ?El Barber/Wise El Barber? acted as a supplier for La Rompe ONU. As a supplier, he would supply ?rearms and ammunition to 30 other members of La Rompe ONU in order to further the goals of the conspiracy. He would also use and carry ?rearms during and in relation to the drug trafficking activities. [66] CARLOS acted as a supplier for La Rompe ONU. As a supplier, he supply ?rearms and ammunition to other members of La Rompe ONU in order to further the goals of the conspiracy. Additionally, he would often act as runner for La Rompe ONU. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [67] ONATHAN acted as a supplier for La Rompe ONU. As a supplier, he would supply ?rearms and ammunition to other members of La Rompe GNU in order to further the goals of the conspiracy. Additionally, he would often act as facilitator for the drug traf?cking organization. As a facilitator, he would clean, and alter ?rearms, such as? pistols and high power ri?es, in order to make them ?re in a fully automatic mode. He would also use and carry ?rearms during and in relation to the drug traf?cking activities. [68] IRANI II. a/k/a ?Cubans? acted as a supplier for La Rompe ONU. As a supplier, he would supply marijuana to the organization. D. Runners The runners worked under the direct supervision of the leaders of La Rompe GNU. They were responsible for providing suf?cient narcotics to the sellers for further distribution at the drug point. .They were also responsible for collecting the proceeds of drug sales and paying the street sellers. They would also supervise and make sure that there were street sellers for every shift of the drug point. They would make schedules and prepare ledgers to maintain accountability of the sales of the narcotics sold at the drug point. At various times, they would be 31 responsible for recruiting street sellers and additional runners. The runners had a supervisory role within the conspiracy, as they would directly supervise on a daily basis, the activities of multiple sellers, and the daily activities of the drug points. i In addition to the enforcers and suppliers who also acted as runners, the following individuals and others known and unknown, acted as runners for La Rompe ONU: [69] CHARLIE J. a/k/a ?lChiry? acted as a runner for La Rompe ONU. Additionally, he would often act as an armed. seller within the conSpiracy and would also use and carry ?rearms during and in relation to the drug traf?cking activities. [70] EDGARDO RUANO-CHEVERE, a/k/a ?Masacre/Masa? acted as a runner for La Rompe ONU. Additionally, he would often act as a seller for the drug traf?cking organization. - [71] FRANCISCO J. GONZALEZ-CAMACHO, a/k/a ?Lento? acted as a runner for La Rompe ONU. Additionally, he would often act as a seller for the drug traf?cking organization. [72] NESTOR R. CONCEPCION-RIVERA, a/k/a ?Nesti/Kilate? acted as a runner for La Rompe ONU. Additionally, he would often act as a drug point ownerwithin the conspiracy and would also use and carry ?rearms during and in relation to the drug traf?cking activities. [73] a/k/a ?Ive/Precious Moments? acted as a runner for La Rompe . [74] BILLY a/k/a ?Meca/Billy Meca? acted as a runner for La Rompe ONU. JAYFRANK QUINONES-CARRION acted as a runner for La Rompe ONU. 32 [76] FELIX a/k/a ?Correa/Baloncelista/El Indie? acted as a runner for La Rompe ONU. Additionally, he would often act as a seller within the conspiracy and would also use and carry ?rearms during and in relation to the drug traf?cking activities. [77] DANIEL O. MARTINEZ-VELEZ, a/k/a ?Berta? acted as a runner for La Rompe ONU. Additionally, he would often act as a seller within the conspiracy and would also use and carry ?rearms during and in relation to the drug traf?cking activities. [78] LUIS F. DIAZ-TJNEO, a/k/a ?Pipen/Pipe? acted as a runner for La Rompe Ol\lU. [79] OSUE 0. a/k/a ?Gordo Puta? acted as a runner for La Rompe GNU. I E. Sellers The sellers would distribute street quantity amounts of heroin, crack cocaine, cocaine, marijuana, oxycodone (commonly lmown as Percocet), and alprazolam (commonly known as Xanax). As sellers, they were accountable for the drug proceeds and the. narcotics sold at the drug distribution points. At tinies, sellers would use twO-way radios (?walkie?talkies?, ?scanners?) in order to communicate with other members of the conspiracy. In addition to the above-mentioned enforcers, suppliers, and runners, who also acted as sellers, the following individuals and others known and unknown, acted as sellers for La Rompe I [80] RAMON 'a/k/a ?Poke?, who would also use and carry ?rearms during and in relation to the drug trafficking- activities, [81] E. a/k/a ?Yaya/Yayi/Ardilla?, [32] JULIO N. a/k/a ?Julio Mara?a?, 33 [83] REYNALDO GONZALEZ-ZAYAS, a/k/a E?Cuto?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, who would also use and carry ?rearms dining and in relation to the drug traf?cking activities, [85] DWN FERNANDEZJORGE, [86] JOSE A. a/k/a ?Semilla?, who would also use and carry ?rearms during and in relation to the drug trafficking activities, [87] KEVIN who would also use and carry ?rearms during and in relation to the drug traf?cking activities, [88] JUAN a/k/a ?Bocao?, who would also use and carry - ?rearms during and in relation to. the drug traf?cking activities, [89] DAVID a/k/a ?David Nata?, who would also use and carry ?rearms during and in relation to the drug traf?cking activities, [90] GIOVANI a/k/a ?Zegueta?, who would also use and Carry ?rearms during and in relation to the drug traf?cking activities, [91} CHRISTIAN VAZQUEZ-HERNANDEZ, alk/a ?Chapa?, who would also use A and carry ?rearms during and in relation to the drug traf?cking activities, [92] JAMES a/k/a ?Negro Steele?, [93] SANTIAGO-ESPINOSA, a/k/a ?Katy/Kathy?, [94] a/k/a ?Papo Swing/Ale?; [95] FRANCISCO VARGAS-SANCHEZ, a/k/a ?Mara?a?, [96] CARLOS NIERANDA, a/k/a who would also use and carry ?rearms during and in relation to the drug traf?cking activities, 34 [97] RAMON a/k/a ?Mono?, who would also use and carry- ?rearms during and in relation to the drug trafficking activities, [98] VICTOR ALFONSO-JORGE, a/k/a ?Nana?, who would also use and carry ?rearms during andin relation to the drug trafficking activities, [99] HECTOR J. CRUZ-VARGAS, a/k/a ?Funky?, who would also use and carry firearms during and in relation to the drug traf?cking activities, [100] YAMTIL a/k/a ?El Mono?, [101[ ROBERT D. PEREZ-NUNEZ, afk/a ?Mjnino?, [102] ANTHONY a/k/a ?Oreo/Apu?, [103i] a/k/a ?Paleta?, who would also use and carry ?rearms during and in relation to the drug traf?cking activities, . [104] LUIS E. a/k/a ?Zona?, who would also use and carry ?rearms during and in relation to the drug traf?cking activities. F. Drug Processors Drug processors would meet under the direction of the leaders'of La Rompe ONU and. would weigh, cut, mix, and prepare the controlled substances for street distribution. They' would also package the heroin, crack, 'cocaine, and marihuana in single dosage amounts and in distinctive ?baggies?, ?decks?, and ?vials?. - In addition to the above-mentioned leaders, drug point owners, enforcers, suppliers, runners, and sellers, who also acted as drug processors, the tollowing individuals and others known and unknown, acted as drug processors for the above described drug organization: 35 [105] ASTRID J. MARTINEZ-VALENTIN, a/k/a ?La efa? acted as a drug processor for La Rompe ONU. Racketeering Conspirag: Beginning on a date unknown, but no later than in or about the year 2007, and continuing up to and until the return of the instant Indictment, in the District of Puerto Rico and within the jurisdiction oic this Court, I OSUE a/k/a ?fMayitoMayo/El Father?, PEDRO VIGIO-APONTE a/k/a ?Pedrito/Pedrito He?Man/Pello/Pedrito Trauma?, FRANKIE ROSA-CALDERON a/k/a ?Anky/EI egro/F rank?, LUIS afk/a ?Trenza/Enano/Luis Trenza?, MIGUEL a/k/a ?Miguelo/Radio/Miclo/BJ?, RUBEN COTTO-ANDINO, a/k/a ?Ruben E1 Negro?, ERNESTO a/k/a ?Nestor/Les Gorditos?, CHRISTIAN a/k/a ?Bimbo/Les Gorditos?, REYFRANK a/k/a ?Pelotero?, [10] KELVIN D. MORALES-CINT RON, [11] ISMAEL a/k/a ?Bolillo?, [12] MCHAEL [13] JONATHAN PEREZ-RODRIGUEZ, a/k/a ?Perra/Perreke?, [14] JOSE L. a/k/a ?Chen/Ghee Cede?o?, [15] REINALDO a/k/a ?Pitbull?, [16] WILLIAM ORTIZ-AGUIRRE, a/k/a ?Maya/Play?, I [17] KIDANNY a/k/a ?Sony/Sonata?; [18] JOSE L. a/k/a ?Luisito/Scary?, [19] JOSE E. .a/k/a ?Papito Mojica?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin?, . [21] RAFAEL ANDEIO-OJEDA, a/k/a ?Rafa/Rafa Colgate/Boca Chula?, [22] MYLES J. . SANCHEZ-MOM, a/k/a ?Guillo?, . [24] EMANUEL a/k/a ?Punky/Dalmata?, [25] ALEXANDER RIVERA-CARRION, a/k/a ?Lechon?, [26] DAVID E. RODRIGUEZ-CASTRO, [27] RAFAEL a/k/a ?Bolillo?, [28] ALEXIS a/k/a [29] ANGEL L. SOTO-RAMOS, a/k/a ?Huesito?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS a/k/a ?Romulo?, [32] JOSE L. a/k/a ?Sonso/Nariz?, [33] WILLIAM a/k/a ?W/Willito?, [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy?, 36 [35] ARNALDO ALICEA-COLON, a/k/a ?Naldito?, [36] XAVIER a/k/a ?Raton?, [37] CARLOS M. GUERRERO-CASTRO, a/kfa ?Carlitos E1 Negro/Marcel?, [38] ANALDI TAN CO-MORENO, a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fine?, [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. MONTALVAN-DIAZ, a/k/a ?Luis Garcia-Diaz/Willy Wonka?, [42] a/k/a ?Boty?, [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jose Boria?Millan?, [44] FNU LNU, a/k/a ?Eziel?, [45] LUIS MARTINEZ-NIEVES, a/k/a ?Raya/Trenza?, [46] MICHAEL RIVERA-RODRIGUEZ, I [47] ALVIN A. CABEZAS-CINTRON, a/k/a ?Ard?la?, [48] JAIME M. [49] KENNY O. PACHECO, a/k'la ?Kelly/B01111?, FUENTES-PACHECO, a/k/a unite Parcha?, [51] ROGER a/k/a ?Gua?, [52] FELIX A. a/k/a ?Cholon?, [53] EDGARDO a/k/a ?Piri/Enano?, [54] JESSY J. NIELENDEZ-HERNANDEZ, a/k/a ?Koby/El Negro/Lely?, [55] DEN ZEL RODRIGUEZ-CARABALLO, I [56] ABIMAEL a/k/a ?LindofFeo/Metra?, [57] ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kij [58] JOSE E. a/k/a ?Camon?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. REST a/k/a ?Tego?, [61] ORLANDO a/k/a ?Oreo/?Willito/Angel M. Santiago-Ayala?, [62] KERNIS RODRIGUEZ-RIVERA, a/k/a ?Sosa?, - [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, afk/a ?Freddy?, [65] CARLOS E. BRIOSO-COLLANTES, a/k/a ?El Barber/Wiso El Barber?, [66] CARLOS VELAZQUEZ-FONTANEZ, a/k/a ?Pirin?, [67] JONATHAN a/k/a ?Katinchj?, [68] I. a/k/a ?Cabana?, [69] CHARLIE J. a/k/a ?Chiry?, [70] EDGARDO R. a/k/a ?Masacre/Nfasa?, [71] FRANCISCO J. GONZALEZ-CAMACHO, a/k/a ?Lento?, [72] NESTOR R. a/k/a es?/Kjlate?, [73] IVETTE a/k/a ?Ive/Precious Moments?, [74] BILLY VELANUEVA-CARRASQUILLO, a/k/a ?Meca/Billy Meta?, [75] JAYFRANK QUINONES-CARRION, [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/Baloncelista/El Indio?, [77] DANIEL O. a/k/a f?Berto?, [78] LUIS F. DIAZ-TINEO, a/k/a ?Pipen/Pipe?, [79] JOSUE O. alk/a ?Gordo Puta?, [80] RAMON a/k/a ?Poke?, 37 [81] LUIS E. a/k/a ?Yaya/Yayi/Ardilla?, [82] JULIO N. MATOS-SANCEEZ, a/k/a ?Julio Mara?a?, [83] REYNALDO GONZALELZAYAS, a/k/a ?Cute?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [85] DAMIAN FERNANDEZ-JORGE, [86] JOSE A. a/k/a ?Semilla?, [87] KEVIN CASTRO-VEGA, [88] JUAN a/lda ?Bocao?, [89] DAVID GARCIA-FRANCO, a/k/a ?David eta?, [90] GIOVANI JUSTINIANO-DIAZ, a/k/a ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, STEELE-TORRES, a/k/a ?Negro Steele?, [93] NILDA a/k/a ?Katy/Kathy?, [94] ALEX SANTIAGO-CRESPO, a/k/a ?Papo Swing/Ale?, [95] FRANCISCO a/k/a ?Mara?a?, [96] CARLOS MIRANDA, a/k/a . [97] RAMON ANDINO-PEGUERO, a/k/a ?Mono?, [98] VICTOR a/k/a [99] HECTOR J. a/k/a ?Funky?, [100] ARRIZMZENDI-SANT ANA, a/k/a ?El Mono?, [101] ROBERT D. PEREZ-NUNEZ, a/k/a ?Minino?, [102] ANTHONY a/k/a ?Oreo/Apu?, [103] DANIEL DE-JESUS-DIAZ, a/k/a ?Paleta?, [104] LUIS E. a/k/a ?Zena?, [105] ASTRID J. a/k/a ?La Jefa?, the defendants and others known and unknown, being persons employed by and associated with the La Rompe ONU enterprise, which engaged in, and the actiyities of Which affected, interstate, and foreign commerce, knowingly and intentionally conspired to violate 18 U.S.C. 1962(0), that is, to conduct and participate, directly, and indirectly, in the conduct of the affairs of that enterprise through a pattern of racketeering activity consisting of multiple acts involving: 1. Drug traf?cking, including cocaine base (commonly referred to as ?crac cocaine, heroin, marijuana, oxycodone (commonly known as Percocet), and alprazolam (commonly known as Xanax), in violation of the laWs of the United States, that being, 21 U.S.C. 841 and 846; 38 2. Robbery, chargeable under Articles 35 (attempt), 198 (general robbery statute) and 249 I (conspiracy) of the 2004 Puerto Rico Penal Code and Articles 35 (attempt), 189 (general robbery statute) and 244 (conspiracy) of the 2012 Puerto Rico Penal Code; 3. Murder, chargeable under Articles 35 (attempt), 105 (general murder statute), 106 (?rst degree and second degree murder), and 249 (conspiracy) of the 2004 Puerto Rico Penal Code and Articles 35 (attempt), 92 (general murder statute), 93 (?rst degree and second degree murder) and 244 (conspiracy) of the 2012 Puerto Rico Penal Code; and 4. Acts indictable under 18 U.S.C. 1951 and 2 (interference with commerce by robbery). It was a part of the conspiracy that the defendants agreed that a conspirator would commit at (2) acts of racketeering activity in the conduct of the affairs of the enterprise. Overt Acts In furtherance of the racketeerihg conspiracy, and to effect the object thereof, the defendants and their co?conspirators committed and caused to be committed the following overt acts, among others, on or about the following dates, in the District of Puerto Rico and Within the jurisdiction of this Court: 1. On or about February 26, 2007, [32] JOSE L. a/k/a ?Sonso/Nariz? possessed marijuana. 2. On or about October 31, 2007, [31] JESUS DE-JESUS-COLON, a/k/a ?Remulo? possessed one (1) Type: Pistol, Make: Taurus, Caliber; 9mm, Serial Number: TOD72701. 3. On or about December 5, 2007, [47] ALVIN A. CABEZAS-CINTRON, a/k/a ?Ardilla? possessed one (1) Type: Pistol, Make: Smith Wesson, Model: SW9VE, Caliber: 9mm, Serial Number: PBF6590. 39 On or about January 11, 2008, [31] JESUS a/k/a ?Romulo? possessed one (1) Ri?e, Caliber: .22, Make: Rugger, Model: 1022, Serial Number: 114- 98271. On or about February 3, 2.008, [63] WALTER D. MULLER-COLON, a/k/a ?fVampy/Bolo? and [86] JOSE a/k/a ?Semilla? possessed one (1) Type: Pistol, Make: Glock, Model: 32, Caliber: .357, Serial Number: obliterated. On or about February '21, 2008, CELRISTIAN MORALES-CASTRO, a/k/a ?Bimbo/Les Gorditos? possessed one (1) Type: Pistol, Make: Glock, Model: 21, Caliber: .45, Serial Number: one (1) Type: Pistol, Make: FNH, Model: Five - Seven Semie, Caliber: 5.7 28, Serial Number: 38Gl24564, and one (1) Ri?e, Caliber: 10. 11. 39, Serial Number: AD0283 82. On or about February 29, 2008, [11] ISMAEL a/k/a ?Bolillo? possessed marijuana. On or about March 05, 2008, PEDRO VIGIO-APONTE, ?a/k/a ?PedritolPedr-ito He-Man/P ello/Pedrito Trauma? possessed cocaine. L. a/k/a JOSE Onor about October 9, 2008, [32] ?Sonso[Nariz? possessed cocaine and marijuana. On or about November 6, 2008, [11] ISMAEL a/k/a ?Bolillo?i possessed marijuana, cocaine, and heroin. On or about January 21, 2009, [74] BILLY a/k/a ?Meca/Billy Meca? possessed marijuana, cocaine, and heroin. 40 12. On or about June 13,2009, [39] ORLANDO J. SANTANA, a/k/a ?Fine? possessed one 13. 14. 15. 16. 17. 18. 19. (1) Type: Pistol, Make: Taurus, Model: PT9ZAP, Caliber: 9mm, Serial Number: TYF95 5 00 and marijuana. On or about July 8, 2009, [76] FELIX a/k/a ?Correa/Baloncelista/El India? possessed marijuana, cocaine, and heroin. On or about August 29, 2009, [16] WILLIAM a/k/a ?Player/Play? . and [53] EDGARDO LUNA-LOPEZ, a/k/a ?Piri/Enano? possessed marijuana, cocaine, and heroin. On or about September 2, 2009, [81] LUIS E. a/k/a ?Yaya/Yayi/Ardi?a? possessed marijuana. On or about September 11, 2-009, [12] MICHAEL possessed one (1) Type: Pistol, Make: Glock, Model: 20, Caliber: .357, Serial Number: On or about September 13, 2009, [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin? possessed one (1) Type: Pistol, Make: Glock, Model: 23, Caliber: .40, Serial Number: On or about October 31, 2009, [50] ROBERTO FUENTES-PACHECO, a/k/a unite Par-aha? possessed one (1) Type: Pistol, Make: Smith Wesson, Model: 5906, Caliber: 9mm, Serial Number: TCL5650. On or about December 4, 2009, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary? possessed one (1) Type: Revolver, Make: Magnum, Caliber: .357, Model: 65-3, Serial Number: AEY0037. 41 20. 21. 22. On or about May 6, 2010, [31] JESUS afk/a ?Romain? possessed one Type: Revolver, Make: Colt, Model: Magnum, Caliber: .357, Serial Number: L- 73556. On or about June 2, 2010, [31] JESUS DE-JESUS-COLON, a/k/a ?Romulo? possessed marijuana. On or about September 14, 2010, [47] ALVIN A. CABEZAS-CINTRON, afk/a ?Ardi?a? possessed one (1) Type: Pistol, Make: Smith Wesson, Model: 5906, Caliber: 23. 24. 25. 9mm, Serial Number: On or about December 23, 2010, [95] FRANCISCO a/k/a ?Mara?a? possessed marijuana, cocaine, and heroin. On or about February 8, 2011, JOSUE a/k/a ?Mayito/lVIayo/El Father? contacted LUIS F. a/k/a ?Trenza/ Enano/Luis Trenza? and ordered him to DAVID GONZALEZ-REYES a/k/a ?Chispa?, a fellow member of La Rompe. ONU, because DAVID a/k/a ?Cbispa? wanted to kill JOSUE a/k/a ?FMayitoMayo/El Father?. On or about February 8, 2011, LUIS F. a/k/a ?Trenza/ Emma/Luis Trenza?, JOSE E. a/k/a ?Papito Mojiea?, i LUIS YANYORE-PIZARRO, a/k/a ?KJ'mbo/Bauncer/Jose Boria-Millan?, and [57] ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kija? shot and killed DAVID a/k/a ?Chispa?. 26. On or about March 9, 2011, [57] ANGEL L. COTTO-NEGRQN, a/k/a ?Quija/Kija? possessed ammunition. 42 27. on or April 8, 2011, [17] KIDANNY FIGUEROA-OSORIO, a/k/a ?Sony/Sonata? 28. 29. 31. 32. possessed one (1) Type: Pistol, Make: Model: 6906, Caliber: 9mm, Serial Number: VAN0235. I On ot about April 29, 2011, [39] ORLANDO J. SANTANA, a/k/a ?Fine? possessed cocaine and marijuana. On or about May 10, 2011, [32] JOSE L. alk/a ?Sonso/Nariz? possessed one (1) Type: Pistol, Make: Glock, Model: 23; Caliber: .40, Serial Number: AUS 819. 1 . On or about May 10, 2011, [19] JOSE E. a/k/a ?Papito Mojica? ordered that RICCO LUIS DAVILA-DIAZ be killed because he had betrayed La Rompe ONU. LUIS F. a/k/a ?Trenza/ Enano/Luis Trenza? also authorized the murder. On or about May 10, 2011, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [33] WILLIAM 'a/k/a ?W/W?lito?, and [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jose Boria?Millan? shot and killed LUIS On or about June 25, 2011, LUIS F. ALICEA-COLCN, a/k/a ?Trenza/ Enano/Luis Trenza? ordered that HERVIN VALCARCEL-MARTINEZ, a/k/a ?Prieto?, a member of a rival drug traf?cking organization be killed. On that date, [66] CARLOS AVELAZQUEZ-FONTANEZ informed members of La Rompe ONU that HERVIN a/k/a ?Prieto? was at a business washing cats 'with his associates. With that information, [301 OSCAR A. a/k/a ?Alex?, [33] WILLIAM a/k/a ?W/Willito?, [36] XAVIER 43 33. 34. a/k/a ?Eaton?, and [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jose Boria?IMillan? drove to the business and shot and killed DIAZ-CRUZ, HERVIN VALCARCEL-MARTINEZ, a/k/ a ?Prieto?, JAVIER CATALA- BERMUDBZ, and ORLANDO On or about July 20, 2011, OSUE a/k/a ?Mayito/Mayo/El Father? ordered the murder of SANTOS DIAZ-CAMACHO, a/k/a ?Joel Bazooka?, a member of La Rompe ONU, because he had allied himself with a rival drug traf?cking organization. On or about July 20, .2011, QUINONES-CARRION, a/k/a ?Pelotero? informed members of La Rompe ONU that SANTOS a/k/a ?Joel Bazooka? was ina vehicle and that another vehicle was escorting him. With that information, JOSUE VAZQUELCARRASQUILLO, a/k/a ?Mayito/Mayo/El Father?, PEDRO a/k/a ?Pedrito/Pedrito He~ Man/Pello/Pedrito Trauma?, REYFRANK . QUJNONES-CARRION, a/k/a - - ?Pelotero?, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?, [20] VICTOR M. a/k/a ?Cuca/CucarachajPapotin?, EMANUEL RODRIGUEZ-TORRES, [24] OSCAR A. CALvui'ro- ,a/k/a ?Punky/Dalmata?, [30] ACEVEDO, a/k/a ?Alex?, [36] XAVIER CASTRO-VEGA, a/k/a ?Raton?, [43] LUIS a/k/a ?Kimbo/Bauncer/Jose Boria-Millan?, and others known and unknown shot and killed SANTOS a/k/a ?Joel Bazooka?, JUAN ROSARIO-WRCADO, a/k/a ?To?ito?, and KEVIN SOTO-ROMAN, a/k/a ?Bl Gordo?. ?44 35. On' or about July 21, 2011, [91] CHRISTIAN a/k/a 36. 37. ?Chapa? possessed one (1) Type: Pistol, Make: Smith Wesson, Model: MP, Caliber: .40, Serial Number: DTK375 7. On or about August 3, 2011, [97] RAMON ANDINO-PEGUERO, afk/a ?Mono? possessed one (1) Type: Pistol, Make: Glock, Model: 23, Caliber: .40, Serial Number: EAW185 and one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: RFDO72. On or about October 27, 2011, [33] WILLIAM ZAMBRANA-SIERRA, a/k/a ?W/Willito?, [36] XAVIER CASTRO-VEGA, a/k/a ?Raton?, and [58] ANGEL L. COT a/k/a ?Quija/Kij a? possessed one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: ERZ359, one (1) Type: Pistol, Make: Model: MP, Caliber: .40, Serial-Number: MPB2756, one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: EHC046, one (1) Ri?e, Caliber: 7.62 39, Model: Serial Number: 1-70605-4, one (1) Ri?e, Caliber: -.223, Serial - Number: 052220, marijuana, heroin, and cocaine. .On or about August 28, 2012, [61] ORLANDO PADELA-AYALA, a/kla ?Oreo/Willito/Angel M. Santiago?Ayala? went to JOSUE CARRASQUILLO, a/k/a ?Mayito/Mayo/El Father? and requested that LUIS ENRIQTJE a/k/a ?Pollo?, who was a member of 'La Rompe, be handed over because he had killed his brother, a fellow member of La Rompe ONU. JOSUE a/k/a ?Mayito/Mayo/El Father? agreed With the and allowed ORLANDO PADILLA-AYALA, a/k/a request [61] ?Oreo/\Villito/Angel M. Santiago-Ayala? to kill LUIS ENRIQUE 45 39. a/k/a ?Polio?. Then, a/k/a M. Santiago?Ayala? provided money, 7131633313, a Trail Blazer, and an Explorer to the members of La Rompe ONU that were going kill LUIS ENRIQUE a/k/a ?Pollo?: On or about August 28, 2012, LUIS F. afkla ?Trenza/Enano/Luis Trenza?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a 40. ?Alex?, a/k/a ?Carlitos I E1 [37] CARLOS M. GUERRERO-CASTRO, Negro/Marcel?, [38] ANALDI TANGO-MORENO, a/k/a ?Kimbito?, E. RIVERA-MALDONADO, a/k/a ?Camon?, [59] FNU- LNU, a/k/a ?Gaby?, and [60] JOSE D. a/k/a ?Tego?, and others known and unknown shot and killed LUIS elk/a ?Pollo,? LUIS - a/k/a? ?Urraea?, and JOSE AYALA-GARCIA. On or about Mach 22, 2012, [90] GIOVANI JUSTINIANO-DIAZ, a/k/a ?Zegueta? possessed one (1) Type: Pistol, Make: Gloek, Model: 27, Caliber: .40, Serial Nunaber: RUC484. 41. 42. On or about March 22,2012, REYFRANK a/k/a ?Pelotero? possessed one (1) Type: Pistol, Make: Glock, Model: 32a, Caliber: .357, Serial Number: LKPSOS. On or about January 2, 2013, [34] EDGAR GONZALEZRIVERA, a/k/a ?Eggy? possessed one (1) Ri?e, Caliber: 5.56, Make: Colt, Serial Number: obliterated, marijuana, and cocaine. 46 43about April 30, 2013, [14] JOSE L. ORTIZ-AGUIRRE, a/k/a ?Cheo/Cheo Cede?o?3 possessed one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: ACY-867. On or about May 9, 2013, [77] DANIEL O. a/k/a. ?Berta? possessed cocaine, marijuana, and heroin. 7 On or about August .20, 2013, [37] CARLOS M. a/k/a ?Carlitos El egro/Mai'cel? possessed marijuana, cocaine, and heroin. - On or about September 13, 2013, [52] FELIX A. elk/a ?Cholon? possessed one (1) Type: Revolver, Make: Ruger, Model: Speed?Six, Caliber: .357, Serial Number: 158-14081. On or about November 5, 2013, [64] WEFREDO RUIZ, a/k/a ?Freddy? possessed one (1) Ri?e, Caliber: 7.62 39, Make: Draco Romalm/Cugir, Serial Number: 11 R0. On or about November 19, 2013, [90] GIOVANI a/k/a ?Zegueta?lpossessed marijuana and cocaine: 1 On or?about November 25, 2013, [52] FELIX A. a/k/a ?Cholon? possessed one (1) Ri?e, Caliber: 7.62 39, Model: GP Make: ROMARM, Serial Number: 1973 ET 0988 and one (1) Type: Revolver, Make: Colt, Model: Detective, Special, Caliber: .38, Serial Number: 44539. On or about February 20, 2014, [93] NILDA SANTIAGO-ESPINOSA, W21 ?Katy/Kathy? possessed heroin, cocaine, and marijuana. On or about April 11, 2014, [97] RAMON ANDINO-PEGUERO, a/k/a ?Mono? possessed marijuana, heroin, and cocaine. 47 All inviolation of 18 U.S.C. 1962((1). Notice of Special Findings for Count One (Conspiracy to Possess With Intent to Distribute a Controlled Substance) Beginning on a date unknown, but no later than in or about the year 2007, and continuing up to and until the retum of the instant Indictment, in the District of Puerto Rico and Within the jurisdiction of this Court, OSUE a/k/a ?Mayito/Mayo/El Father?, PEDRO VIGIO-APONTE a/k/a ?Pedrito/Pedrito He-Maanello/Pedrito Trauma?, FRANICIE ROSA-CALDERON a/k/a ?Anky/El Negro/F rank?, LUIS F. a/k/?a MIGUEL ajk/a ?Miguelo/RadioMiclo/BJ?, RUBEN COTTO-ANDINO, a/k/a ?Ruben El Negro?, ERNESTO MORALES-CASTRO, a/k/a ?Nestor/Los Gorditos?, CHRISTIAN a/k/a ?Bimbo/Les Gorditos?, REYFRANK QUINONES-CARRION, a/k/a ?Pelotero?, [10] KELVIN D. I [11] ISMAEL a/k/a. ?Bolillo?, [12] MICHAEL [13] JONATHAN a/k/ a ?Perra/Perreke?, [14] JOSE L. a/k/a ?Cheo/Cheo Cede?o?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/ a ?Pitbull?, [16] WILLIAM a/k/a ?Playa/Play?, [17] KIDANNY a/k/a ?Sony/Sonata?; [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?l?, [19] JOSE E. MOJICA-ROBLES, a/k/a ?Papito-Mojica?, 7 - [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin?, [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Bow Chula?, [22] MYLES ROMAN-ADORNO, [23] GUILLERMO SAN CEEZ-MORA, a/k/a ?Guillo?, [24] EMANUEL a/k/a ?Punky/Dahnata?, [25] ALEXANDER a/k/a ?Lechon?, - [26] DAVID E. [27] RAFAEL HIRALDO-ALEJANDRO, a/k/a ?Bolillo?, [28] ALEXIS CARTAGENA-GERENA, a/k/a ?Polio?, [29] ANGEL L. a/k/a ?Hue-site?, 7 [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS a/k/a ?Ronnie?; [32] JOSE L. a/k/a ?Sonso/Nariz?, [33] WILLIAM a/k/a ?W/W?lito?, - [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy?, 48 [35] ARNALDO a/k/a aldito?, [36] XAVIER CASTRO-VEGA, a/k/a ?Raton?, [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos E1 Negro/Marcel?, [38] ANALDI TAN CO-MORENO, a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fine?, [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. a/k/a ?Luis Garcia-Diaz/Willy Wonka?, [42] AMAURY a/k/a ?Boty?, [43] LUIS a/k/a ?Kimbo/Bauncer/Jose Boria?M?an?, [44] FNU LNU, a/k/a ?Eziel?, [45] LUIS MARTINEZ-NIEVES, a/k/a ?Raya/Trenza?, [46] MCHAEL [47] ALVIN A. a/k/a ?Ardilla?, [48] JAIME M. SEMIDAYQPEREZ, [49] KENNY O. a/k[a ?Keny/Bolin?, [50] ROBERTO FUENTES-PACHECO, a?da ?lunito Parcha?, [51] ROGER a/k/a ?Gua?, [52] FELIX A. a/k/a ?Cholon?, [53] ED GARDO LUNA-LOPEZ, a/k/a ?Piri/Enano?, [54] JESSY J. a/k/a ?Koby/El Negro/Lely?, [55] DENZEL [56] ABINIAEL a/k/a ?Lindo/Feo/Metra?, [57] ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kija?, [58] JOSE E. RIVERA-MALDONADO, a/k/a ?Camon?, [59] FNU LNU, a/kfa ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Togo?, [61] ORLANDO PADILLA-AYALA, a/k/a ?Oreo/\VillitolAngel M. Santiago-Ayala?, [62] KERNIS a/k/a ?Sosa?, - [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, I [65] CARLOS E. a/_k/a ?El Barber/Wiso El Barber?, [66] CARLOS a/k/a ?Pirin?, [67] JONATHAN a/k/a ?Katinchi?, [68] IRAM I. a/k/a ?Cubano?, [69] CHARLIE J. FOURNIER-COLLAZO, a/k/a ?Chiry?, [70] EDGARDO R. a/k/a ?Masacre/Masa?, [71] FRANCISCO J. GONZALEZ-CAMACHO, alk/a ?Lento?, [72] NESTOR R. a/k/a ?Nesti/Kilate?, IVETTE VAZQUEZ-DROZ, a/k/a ?Ive/Precious Moments?, [74] BILLY a/k/a ?Mew/Billy Meca?, [75] JAYFRANK QUINONES-CARRION, [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/Baloncelista/El Indio?, [77] DANIEL O. a/k/a ?Berto?, - [78] LUIS F. a/k/a ?Pipen/Pipe?, [79] JOSUE O. a/k/a ?Gordo Puta?, [80] RAMON VICENTY-RIVERA, a/k/a ?Poke?, 49 [81] LUIS E. GUADALUPE-CAMACHO, a/k/a ?YayafYayi/Ardilla?, [82] JULIO N. a/k/a ?Julio Mara?a?, [83] REYNALDO a/k/a ?Cute?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, . [85] DAMIAN [86] JOSE A. alk/a ?Semilla?, [87] KEVIN [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID GARCIA-FRAN CO, a/k/a ?David Nata?, [90] GIOVANI a/k/a ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, [92] JAMES STEELE-TORRES, afk/a ?Negro Steele?, [93] NILDA SANTIAGO-ESPNOSA, a/k/a ?Katy/Kath [94] ALEX SANTIAGO-CRESPO, a/k/a ?Papa Swing/Ale?, [95] FRANCISCO VARGAS-SANCIIEZ, a/k/a ?Mara?a?, [96] CARLOS DIERANDA, a/k/a [97] RAMON ANDINO-PEGUERO, a/k/a ?Mono?, [98] VICTOR a/k/a ?Nana?, [99] HECTOR J. CRUZ-VARGAS, a/k/a ?Funky?, [100] YAMIL ARRIZMENDLSANTANA, a/k/a ?El Mono?, [101] ROBERT D. PEREZ-NUNEZ, afk/a ?Minino?, [102] ANTHONY a/k/a ?Oreo/Apu?, [103] DANIEL a/k/a ?Paleta?, - [104] LUIS E. ESPADA-COLON, a/k/a ?Zena?, [105] ASTRD) J. MARTINEZ-VALENTIN, a/k/a ?La efa?, the defendants herein, did knowingly and intentionally, combine, conspire, and agree with each other and With diverse other persons knotm and. unknown to the Grand Jury, to commit an offense against the United States, that is, to knowingly and intentionally possess with intent to distribute and to distribute controlled substances, to Wit: in excess of two hundred and eighty (280) grams of a mixture or substance containing a detectable amount of cocaine base (crack), a Schedule II Narcotic Drug Controlled Substance; in excess of one (1) kilogram of a mixture or substance containing a detectable amount of heroin, a Schedule I, Narcotic Drug Controlled Substance; and in excess of ?ve (5) kilograms of a mixture or substance containing a detectable amount of cocaine, a Schedule II, Narcotic Dru-g Controlled Substance; in violation of 21 U.S.C. 841(a)(1) and All in Violation of21 U.s.c. 846. 50 COUNT TWO (Conspiracy to Possess with Intent to Distribute a Controlled Substance) Beginning on a date unknown, but no later than in or about the year 2007, and continuing up to and until the return of the instant Indictment, in the District of Puerto Rico and Within the jurisdiction of this Court, OSUE a/k/a ?Mayito/Mayo/El Father?, PEDRO a/k/a ?Pedrito/Ped'rito He?Man/Pello/Pedrito Trauma?, FRANKJE ROSA-CALDERON a/k/a ?Anky/El Negro/Frank?, LUIS F. a/k/a ?Trenza/Enano/Lujs? Trenza?, MIGUEL VAZQUEZ-MARTINEZ, a/k/a ?lVIiguelo/Radio/lVIiclo/BJ?, RUBEN COTTO-ANDINO, a/k/ a ?Ruben El Negro?, ERNEST MORALES-CASTRO, a/k/a ?Nestor/L03 Gorditos?, CHRISTIAN a/k/a ?Bimbo/Les Gorditos?, REYFRANK QUWONES-CARRION, a/k/a ?Pelotero?, [10] KELVIN D. MORALES-CINTRON, [11] ISMAEL MNDEZ-ARROYO, a/k/a ?Bol?lo?, [12] MICHAEL [13] JONATHAN a/k/a ?Perra/Perreke?, [14] JOSE L. ORTIZ-AGUIRRE, a/k/a ?Cheo/Cheo Cede?o?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/a ?Pitbull?, [16] WILLIAM ORTIZ-AGUIRRE, a/k/a??PIaya/Play?, [17] KIDANNY FIGUEROA-OSORIO, a/k/a ?Sony/Sonata?, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?, [19] JOSE E. MOJICA-ROBLES, a/k/a ?Papito Mojica?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin?, [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Boca Chula?, [22] MYLES J. ROMAN-ADORNO, I [23] GUILLERMO SAN CHEZ-MORA, a/k/a ?Guillo?, [24] EMANUEL ZABALA-PEREZ, a/k/a ?Punky/Dalmata?, [25] ALEXANDER RIVERA-CARRION, a/k/a ?Lechon?, [26] DAVID E. . [27] RAFAEL HERALDO-ALEJANDRO, aJk/a ?Bol?lo?, CARTAGENA-GERENA, a/k/a ?Polio?, [29] ANGEL L. a/k/a ?Huesito?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS a/k/a?Ron1ulo?, [32] JOSE L. a/k/a ?Sonso/Na?z?, [33] WILLIANI ZALIIBRANA-SIERRA, a/k/a ?W/W?lito?, [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy?, [35] ARNALDO ALICEA-COLON, a/k/a ?Naldito?, [36] XAV1ER CASTRO-VEGA, a/k/a ?Raton?, [37] CARLOS M. a/k/a ?Carlitos El Negro/Marcel?, 51 [38] ANALDI TAN CO-MORENO, a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Film?, [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. a/k/a ?Luis Garcia?Diaz/VViIIy Wonka?, [42] AMAURY a/k/a ?Boty?, [43] LUIS YANYORE-PIZARRO, a/k/a ?ijbo/Bauncer/Jose Boria-Millan?, [44] FNU LNU, a/k/a ?Eziel?,, [45] LUIS a/k/ a ?RayafTrenza?, [46] MICHAEL RIVERA-RODRIGUEZ, [47] ALVIN A. RON, a/k/a ?Ard?la?, [48] JAIME M. SEMIDAY-PEREZ, [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin?, [50] ROBERTO UENTES-PACHECO, a/k/a unite Parcha?, [51] ROGER a/k/a ?Gua?, [52] FELIX A. a/k/a [53] EDGARDO a/k/a ?Piri/Enano?, [54] JESSY J. DIELENDEZ-HERNANDEZ, a/k/a ?Koby/El Negro/Lely?, [55] DENZEL RODRIGUEZ-CARABALLO, [56] ABIMAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/Feo/Metra?, [57] ANGEL L.-COTTO-NEGRON, a/k/a ?Quija/Kija?, [58] JOSE E. a/k/a ?Camon?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, [61] ORLANDO a/k/a ?Oreo/Willito/Angel M. Santiago-Ayala?, [62] KERNIS RODRIGUEZ-RIVERA, a/k/a ?Sosa?, [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy[65] CARLOS E. a/k/a ?El Barber/W150 El Barber?, [66] CARLOS a/k/a ?Pirin?, [67] JONATHAN FIGUEROA-CATINCIEII, a/k/a ?Ka?nchi?, [68] I. a/k/a ?Cubano?,_ [69] CHARLIE J. FOURNIER-COLLAZO, a/k/a ?Chiry?, [70] EDGARDO R. RUANO-CHEVERE, a/k/a ?Masacre/lVIasa?, [71] FRANCISCO J. GONZALEZ-CAMACHO, a/k/a ?Lento?; [72] NESTOR R. a/k/a ?Nesti/Kilate?, [73] VAZQUEZ-DROZ, a/k/a ?Ive/Precious Moments?, [74] BILLY a/k/ a ?Mew/Billy Meca?, [75] JAYFRANK [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/Baloncelista/El Indie?, [7 7] DANIEL O. a/k/a ?Berta?, 7 [78] LUIS F. a/k/a ?Pipen/Pipe?, [79] OSUE O. a/k/a ?Gordo Puta?, [80] RANION a/k/a ?Poke?, [81] LUIS E. GUADALUPE-CAMACHO, a/k/a ?YayafYayi/Ard?la?, [82] JULIO N. MATOS-SANCHEZ, a/k/a 11110 Mara?a?, [83] REYNALDO GONZALEZ-ZAYAS, a/k/a ?Cute?, 52 [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [85] DAMIAN FERNANDEZ-JORGE, - [86] JOSE A. a/k/a ?Semilla?, [87] KEVIN CASTRO-VEGA, [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID GARCIA-FRANCO, a/k/a ?David Nata?, [90] GIOVANI JUSTINIANO-DIAZ, a/k/a ?Zegueta?, [91] CHRISTIAN VAZQUEZ-HERNANDEZ, a/k/a ?Chapa?, [92] JAMES a/k/a ?Negro Steele?, [93] NILDA a/k/ a ?Katy/Kathy?, [94] ALEX SANTIAGO-CRESPO, a/k/a ?Papo? Swing/Ale?, [95] FRANCISCO VARGAS-SANCHEZ, a/k/a ?Marafia?, [96] CARLOS NERANDA, a/k/a [97] RAMON a/k/a ?Mono?, [98] VICTOR ALFONSO-JORGE, a/k/a ?Nana?, [99] HECTOR J. CRUZ-VARGAS, a/k/a ?Funky?, l? [100] YAMIL ARRIZMENDI-SANTANA, a/k/a ?El Mono?, [101] ROBERT D. PEREZ-NUNEZ, a/k/a ?Miniuo?, [102] ANTHONY a/k/a ?Oreo/Apu?, [103] DANIEL DE-JESUS-DIAZ, a/k/a ?Paleta?, [104] LUIS E. a/k/a ?Zena?, [105] ASTRD) J. a/k/a ?La Jefa?, the defendants herein, did knowingly and intentionally, combine, conspire, and agree with each other and With diverse other persons known and unknown to the Grand Jury, to commit an offense against the United States, that is, toknowingly and intentionally possess with intent to distribute and to distribute controlled substances, to Wit: in excess of two hundred and eighty (280) grams of a mixture or substance containing a detectable amount of cocaine base (crack), a Schedule 11 Narcotic Drug Controlled Substance; in excess of one (1) kilogram of a mixture or substance containing a detectable amount of heroin, a Schedule I, Narcotic Drug Controlled Substance; in excess of ?ve (5) kilograms ot-a mixture or substance containing a detectable amount of cocaine, a Schedule II, Narcotic Drug Controlled Substance; in excess of one hundred (100) kilograms of a mixture or substance containing a detectable amount of marijuana, a Schedule I, Controlled Substance; within one thousand (1,000) feet of a real property comprising housing facilities owned by a public housing authority, to Wit: Iardines del Paraiso Public 53 Housing Project, Villa Andalucia Public Housing Project, de Cupey Public Housing Project, Iardines de Cupey Public Housing Project, Brisas de Cupey Public Housing Project, Los Claveles Public Housing Project, Nuestra Se?ora de Covadonga Public Housing Project, Los Lirios Public Housing Project, Iardines dc Monte Hatillo Public Housing Project, Iardines de Campo Rico Public Housing Project, Iardines de BerWind Public Housing Project, San Martin Public Housing Project, Monte Park Public Housing Project, El Polvorin Ward, Villa Lomas Verdes Public Housing Project, Mango Sector and other areas nearby, Within the Municipalities of San Juan, Trujillo Alto and Carolina inviolation of 21 All in Violation of 21 U.S.C. 846 and 860. COUNT THREE (Using and Carrying Firearms During and in Relation to a Drug Crime) Beginning on a date unknown, but no later than in or about the year 2007, and continuing up to and until the return of the instant Indictment, in the Municipalities of San Juan, Carolina and Trujillo Alto, District of Puerto Rico and Within the jurisdiction of this Court, OSUE VAZQUEZ-CARRASQUILLO, a/k/a ?Mayito/Mayo?ill Father?, PEDRO a/k/a ?Pedrito/Pedn'to He?Man/Pello/Pedrito Trauma?, FRANKIE a/k/a ?Anky/El Negro/Frank?, a/k/a ?lVIigueIc/Radio/Miclo/BJ?, ERNESTO a/k/a ?Nestor/Los Gorditos?, CHRISTIAN MORALES-CASTRO, a/k/a ?Bimbo/Los Gorditos?, QUHSIONES-CARRION, a/k/a ?Peloterc?, [10] KELVIN D. [11] ISMAEL a/k/a ?B'olillo?, [14] JOSE L. ?Chen/Ghee Cede?o?, [15] REINALDO afk/a ?Pitbull?, [16] WILLIAIVI a/lda ?Playa/Play?, [17] KEANNY a/k/a ?Sony/Sonata?, [18] JOSE L. a/k/a ?Luisitc/Scary?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/CucarachaJPapotin?, [21] RAFAEL ANDINO-OJEDA, a/k/a ?Rafa/Rafa Colgate/Boca Chula?, [24] EMANUEL a/k/a ?Punky/Dalmata?, [25] ALEXANDER RIVERA-CARRION, a/k/a ?Lechon?, 54 [28] ALEXIS a/k/a [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS DE-JESUS-COLON, a/k/a ?Romulo?, [32] JOSE L. a/k/a ?Sonso/Nariz?, [34] EDGAR GONZALEZ-RIVERA, a/k/a ?Eggy?, [36] XAVIER a/k/a ?Raton?, - [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos El Negro/Marcel?, [38] ANALDI TAN CO-MORENO, a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fina?, [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. a/k/a ?Luis Wonka?, [42] AMAURY a/k/a ?Boty?, [43] LUIS a?da ?Kimbo/B auncer/Jose Boria?Millan?, [44] FNU LNU, a/k/a ?Eziel?, [45] LUIS NIARTINEZ-NIEVES, a/k/a ?Raya/?I?renza?, [46] MICHAEL RIVERA-RODRIGUEZ, [47] ALVIN A. CABEZAS-CINTRON, a/k/a ?Ardilla?, [48] JAUVIE M. [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin?, [50] ROBERTO a/k/a ?Jum'to Parcha?, [51] ROGER FALU-DIAZ, a/k/a ?Gua?, [52] FELIX A. a/k/a ?Cholon?, - [53] EDGARDO a/k/a ?Piri/Enano?, [54] JESSY . a/k/a ?Koby/El Negro/Lely?, [55] DENZEL RODRIGUEZ-CARABALLO, [56] ABINIAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/Feo/Metra?, [59] FNU LNU, a/k/a ?Gaby?, . [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, [61] ORLANDO PADILLA-AYALA, a/k/a ?Oreo/Willito/Angel M. Santiaga?Ayala?, [62] KERNIS RODRIGUEZ-RIVERA, a/k/a ?Sosa?, [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, [65] CARLOS E. a/k/a Barber/Wise El Barber?, [66] CARLOS VELAZQUEZ-FONTANEZ, JONATHAN FIGUEROA-CATINCEI, a/k/a ?Katinchi?, [69] CHARLIE J. a/k/a [72] NESTOR R. a/k/a ?NeS?JKilate?, [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/a ?Correa/Baloncelista/El India?, [77] DANIEL O. MARTINEZ-VELEZ, a/k/a ?Berto?, [80] RAMON a/k/a ?Poke?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [86] JOSE A. FOURNIER-COLLAZO, a/k/a ?Semilla?, [87] KEVIN CASTRO-VEGA, - [88] JUAN ?Bocao?, [89] DAVID GARCIA-FRAN CO, a/k/a ?David Nata?, [90] GIOVANI JUSTINIANO-DIAZ, a/kla ?Zegueta?, 55 [91] CHRISTIAN a/k/a ?Chapa?, [98] VICTOR a/k/a ?Nana?, [99] HECTOR J. CRUZ-VARGAS, a/k/ a F?Punky?, [103] DANIEL DE-JESUS-DIAZ, a/k/a ?Paleta?, [104] LUIS E. ESPADA-COLON, a/k/a ?Zena?, the defendants herein, aiding and abetting each other, did knowingly and unlawfully use and carry ?rearms as that term is defnied in 18 U.S.C. 921(a)(3), during and in relation to a drug traf?cking crime as charged in Count Two of the instant Indictinent. All in Violation of 18 U.S.C. COUNT FOUR (Drive By Shooting) On or about June 25, 2011, in the District of Puerto Rico, and within the jurisdiction of this Court, LUIS F. a/k/a ?Trenza/ Enano/Luis Trenza?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [33] WILLIAM a/k/a ?W/Willito?, [36] XAVLER a/k/a ?Baton?, [43] LUIS a/k/a ?KinibofBauncer/Jose Boria?N?llan?, [66] CARLOS - - . - the defendants herein, aiding and abetting each other, in furtherance of a major drug offense, as charged in Count Two, which count is incorporated by reference herein, and with intent to intimidate, harass, injure, and maim, ?red a weapon into a group of two (2) or more persons and, in the course! of such conduct, killed ED WIN HERVIN VALCARCEL- a/k/a ?Prieto?, JAVIER CATALA-BERNIUDEZ, and ORLANDO MELENDE-Z- VILLEGAS, which killings are murder within the meaning of 18 U.S.C. All in Violation of 18 U.S.C. and 2. 56 COUNT FIVE - (Use and Carry of a Firearm During and in Relation to a Crime of Violence) On or about June 25, 2011, in the District of Puerto Rico, and within the jurisdiction of this Court, LUIS F. a/k/a ?Trenza/ Enano/Luis Trenza?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [33] WILLIAM a/k/a ?W/Willito?, [36] XAVTER a/k/a ?Raton?, [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jo [66] CARLOS VELAZQUEZ-FONTANEZ, se Boria-Millan?, the defendants herein, aiding and abetting each other, did knowingly use and carry a ?rearm, that is, a ?rearm with an unknown serial number, during and in relation to a crinm of violence for which they may be prosecuted in a Court of the United States, namely, a Violation of 18 U.S.C. as charged in Count Four of the Indictment, and in'the course of that crime did cause the death of EDWIN HERVIN a/k/a ?Prieto?, JAVIER and ORLANDO through the use ofa ?rearm, which killing is a murder as de?ned 1:118 USIC. 1111. All in Violation of 13 use. 924(c)(1xA), 924mm, and 2. COUNT SIX (Drive By Shooting) On or about July 20,2011, in the District of Puerto Rico, and within the jurisdiction of this Court, OSUE VAZQUEZ-CARRASQUILLO, a/k/a ?Mayito/Mayo/El Father?, PEDRO VIGIO-APONTE, a/k/ a ?Pedrito/Pedrito He?Man/Pello/Pedrito Trauma? REYFRANK QUINONES-CARRION, a/k/a ?Pelotero?, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?, [20] VICTOR M. RODRIGUEZTORRES, a/k/a Cuca/Cucaracha/Papotin?, [24] EMANUEL a/k/a ?Punky/Dalmata?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, 57 5 [36] XAVUER CASTRO-VEGA, a/k/a ?Raton?, [43] LUIS a/k/a ?Kimbc/Bauncer/Jose Boria?Millan?, the defendants herein, aiding and abetting each other and others known and unknown, in furtherance of a major drug offense, as charged in Count Two, which count is incorporated by reference herein, and With intent to intimidate, harass, injure, and maim, ?red a weapon into a group of two (2) or more persons and, in the course of such conduct, killed SANTOS CAMACHO, a/k/a ?Joel Bazooka?, JUAN a/k/a ?To?ito?, and afk/a Gordo?, which killings are murder Within the meaning of 18 U.S.C. 111.1 All in Violation of 18 use. and 2. COUNT SEVEN (Use and Carry of a Firearm During and in Relation to a Crime of Violence) On or about July 20, 2011, in the District of Puerto Rico, and within the jurisdiction of this Court, OSUE VAZQUEZCARRASQUELO, a/k/a ?Mayito/Mayo/El Father?;, PEDRO a/k/a ?Pedrito/Pedrito He?Man/Pello/Pedrito Trauma?, REYFRANK QUINONES-CARRION, a/k/a ?Pelotero?, [18] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a Cuca/Cucaracha/Papotin?, [24] EMANUEL a/k/a ?Punky/Dalmata?, [30] OSCAR A. CALVINOFACEVEDO, a/k/a ?Alex?, [36] XAVIER CAST a/k/a ?Raton?, [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jose Boria?N?llan?, the defendants herein, aiding and abetting each other and others known and unknown, did knowingly use and carry a ?rearm, that is, a ?rearm with an unknown serial number, during and in relation to a crime of Violence for which they may be prosecuted in a Court of the United States, namely, a Violation of 18 U.S.C. as charged in Count Six of the Indictment, and in the course of that crime did cause the death of SANTOS 58 a/k/a ?Joel Bazooka?, JUAN ROSARIO-MERCADO, a/k/a ?To?ito?, and KEVIN soro- ROMAN, a/k/a ?El Gordo?, through the use of a ?rearm, which killing is a murder as de?ned in 18 U.S.C. 1111. A11 in violation of 18 U.S.C. 924mm and 2. COUNT EIGHT (Drive By Shooting) On or about August 28, 2012, in the District of Puerto Rico, and within the jurisdiction of ?ns-Court, JOSUE VAZQUEZCARRASQUELQ a/k/a ?Mayito/Mayo/El Father?, LUIS F. ALICEA-COLON, a/k/a ?Trenza/Enano/Luis Trenza?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, . [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos El Negro/Mined?, [38] ANALDI TAN a/k/a ?Kimbito?, I [58] JOSE E. a/k/a ?Camon?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, [61] ORLANDO PADILLAHAYALA, a/k/a ?Oreo/Willito/Angel M. Santiago?Ayala?, - the defendants herein, aiding and abetting each other and others known and unknown, in furtherance of a major drug offense, as charged in Count Two, which count is incorporated by reference herein, and with intent to intimidate, harass, injure, and maim, ?red a Weapon into a group of two (2) or more persons and, in the course of such conduct, killed LUIS ANDINO, a/k/a ?Polio,? LUIS VELAZQUEZ-AQUDJO, a/k/a ?Urraca?, and JOSE AYALA- GARCIA, which killings are murder Within the meaning of 18 U.S.C. 1111(a). Allin Violation of 18 U.S.C. and 2. 59 COUNT NINE (Use and Carry of a Firearm During and in Relation to a Crime of Violence) On or about August 28, 2012, in the District of Puerto Rico, and within the jurisdiction of this Court, OSUE a/k/a ?Mayito/Mayo/El Father?, LUIS F. a/k/a ?Trenza/Enano/Luis Trenza?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [37] CARLOS M. GUERRERO-CASTRO, afk/?a ?Carlitos El Negro/Marcel?, [38] ANALDI TAN CO-MORENO, a/k/a ?Kimbito?, [58] JOSE E. NRA-MALDONADO, a/kfa ?Camon?, [59] FNU LNU, a/k/a ?Gaby?, - [60] JOSE D. a/k/a ?Tego?, . [61] ORLANDO PADILLA-AYALA, a/k/a ?Oreo/Willito/Angel M. Santiago-Ayala?, the defendants herein, aiding and abetting each other and others known and unknown, did knoviringly use and carry a ?rearm, that is, a ?rearm with an unknown serial number, during and in relation to a crime of Violence for which they may be prosecuted in a Court of the United States, namely, a Violation of 18 U.S.C. as charged in Count Eight of the Indictment, and in the course of that crime did cause the death of LUIS a/k/a ?Polio,? LUIS VELAZQUEZ-AQUINO, a/k/a ?Unaca?, and JOSE through I the use of a firearm, which killing is amurder as defmedlin 18 U.S.C. 1111. Allin Violation of 18 U.S.C. 924mm) and 2. NOTICE OF SPECIAL FINDINGS OSUE a/k/a ?MayitoMayo/Father? I. Counts Six and Seven: Murder of JUAN ROSARIO-LIERCADO, a/k/a ?To?ito?, KEVIN a/k/a ?El Gordo?, and SANTOS a/k/a ?Joel Bazooka? on July 20, 2011 I l. Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. 60' 2. It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. 18 U.S.C. 3591(a). The defendant intentionally killed the Victim. 18 U.S.C. 359l(a)(2)(A). The defendant intentionally in?icted serious bodily injury that resulted in the death of the victim. 53:; 18 U.S.C. 3591(a)(2)(B). The defendant?intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the paiticipants in the offenses, and the victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(C). The defendant- intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the Victim, died as a direct result of the act. si 18 - The defendant, the commission ofthe offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. 18 U.S.C. 35 The defendant committed the offenses after substantial planning and premeditation to cause the death of aperson. 18 U.S.C. 3592(c)(9). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). 61 I1. Counts Eight and Nine: Murder of LUIS a/k/ a ?Polio,? LUIS a/k/a ?Urraca?, and JOSE on August 28, 2012 l. Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. 2. It is ?thher alleged that: a. The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the. offenses, and the Victim, died as a direct reent'etthe act. Sie 18 Use. 3591(a)(2)(C). b. The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. _S_c;e 18 U.S.C. 3592(c)(5). PEDRO VIGIO-APONTE, a{k/a ?Pedrito/Pedrito He?Man/Pello/Pedrito Trauma? I. Counts Six and Seven: Murder of JUAN ROSARIO-MERCADQ a/k/a ?To?ito?, SOTO-ROMAN, a/k/a ?El Gordo?, and SANTOS a/k/a ?Joel Bazooka? on July 20, 2011 l. Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. 2. It is further alleged that: a. The defendant was eighteen (l 8) years of age or older at the time of the offenses. SE 18 U.S.C. 3591(a). I b. The defendant intentionally killed the victim. 18 U.S.C. 3591(a)(2)(A). e. The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe victim. see 18 use. 3591(a)(2)(B). 62 d. The defendant intentionally participated in an act, contemplating that the life 'of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result ofthe act. ?ee l8 U.S.C. 3591(a)(2)(C). e. The defendant intentionally and speci?cally engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the Victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(D). f. The defendant, in the commission of the offense, or in escaping apprehension for the Violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. l8 3592(c)(5). g. The defendant committed the offenses after substantial planning and premeditation to cause the death of aperson. 18 U.S.C. 3592(c)(9)7. h. The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. See 18 U.S.C. 3592(c)(l6). LUIS F. a/k/a ?Trenza/Eriano/Luis Trenza? I. Counts Four and Five: Murder of EDWIN DMZ-CRUZ, HBRVIN VALCARCEL- MARTINEZ, a/k/a ?Prieto?, JAVIER and ORLANDO on June 25, 2011 . Counts Four and Five of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. $33 18 U.S.C. 3591(a). The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. See 18 U.S.C. 3591(a)(2)(C). The defendant has previously been convicted of a Federal or State offense punishable by a term of imprisonment of more than one year, involving the use or attempted or threatened use of a ?rearm (as de?ned in section 921) against another person. See 18 U.S.C. 3592(c)(2). Counts Eight and Nine: Murder of LUIS OJEDA-ANDINO, a/k/a ?Pollo,? LUIS a/k/a ?Urraca?, and JOSE AYALA-GARCIA on August 28, 20 1-2 . Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. $18 U.S.C. 3591(a). The defendant intentionally killed the victim. S_eg 18 U.S.C. 35 The defendant intentionally in?icted serious bodily injury that resulted in the death of the victim. ?g 18 359l(a)(2)(B). The defendant intentidnally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection 64 with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. gee 18 U.S.C. 3591(a)(2)(C). . The defendant intentionally and speci?cally engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(D). The defendant has previously been convicted of a Federal or State offense punishable by a term of imprisonment of more than one year, involving the use or attempted or threatened use of a firearm (as defined in section 921) against another person. 18 U.S.C. 3592(c)(2). . The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in'addition to the victim of the offense. 18 U.S.C. 3592(c)(5). . The defendant procured the commission of the offense by payment, or promise of payment, of anything of pecuniary value. ?ee 18 U.S.C. 3592(c)(7). The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. ?g 18 U.S.C. 3592(c)(9). The defendant intentionally killed or attempted: to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). 65 REYFRANK a/k/a ?Pelotero? I. Counts Six and seven: Murder of JUAN ROSARIO-MERCADO, a/k/a ?To?ito?, KEVIN SOTO-ROMAN, a/lC/a ?El Gordo?, and SANTOS a/k/a ?Joel Bazooka? on July 20, 2011 a. . Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: The defendant was eighteen (18) years of age or older at the time of the offenses. gap 18 U.S.C. 3591(a). The defendant intentionally killed the victim. ,S_e_e 18 U.S.C. 3591 The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe victim. 18 U.S.C. 359l(a)(2)(B). The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(C). 'The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act- sag 18 U.S.C. 3591(a)(2)(n). The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. See 18 U.S.C. 3592(c)(5). 66 The defendant committed the offenses . after substantial planning and premeditation to cause the death of a person. ?g 18 U.S.C. 3592(c)(9). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). [13] JOSE L. SOTO-RIVERA, a/k/a ?Luisito/Scary? I. Counts Six and Seven: Murder of JUAN ROSARIO-MERCADO, a/k/a ?To?ito?, KEVIN SOTO-ROMAN, a/k/a ?fEl Gordo?, and SANTOS a/k/a a. ?Joel Bazooka? on July 20, 2011 - . Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: The defendant was eighteen (18) years of age or older at the time of the offenses. 18 U.S.C. 3591(a). The defendant intentionally killed the Victim. 18 U.S.C. 3591 The defendant intentionally in?icted serious bodily injury that resulted in the death of the Victim. 18 U.S.C. 3591(a)(2)(B). . The defendant intentionally participated in an act, contemplating that the life of a persOn would be taken and intending that lethal force would be used in connection yvith a person, other than one of the participants in the o?enses, and the Victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(C). The defendant intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a 67 reckless disregard for human life and the victim, died as a direct result of the act. as 18 use. 3591(a)(2)(D). f. The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. 5g: 18 U.S.C. 3592(c)(5). g. The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. 18 U.S.C. 3592(c)(9). h. The defendant intentionally killed or attempted to kill more one person in a single criminal episode. See 18 U.S.C. 35 92(c)(16). [20] M. a/k/a ?Cuca/Cucaracha/Papo?n? I. counts Six and Seven: Murder of JUAN a/k/a ?To?ito?, KEVIN SOTO-ROMAN, aJk/a ?El Gordo?, and SANTOS DIAZ-CAMACHO, a/k/a ?Joel Bazooka? on July 20, 2011 l. Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. 2-. It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. 18 U.S.C. 3591(a). b. The defendant intentionally killed the victim. 18 U.S.C. 3591(a)(2)(A). c. The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe Victim. ?e_e l8 U.S.C. 359l(a)(2)(B). d. The defendant intentionally participated in an act", contemplating that the life of a person would be taken and intending that lethal force would be used in connection 68 with a person, other than one of the participants in the offenses, and the Victim, died as a. direct result of the act. 53; 18 U.S.C. 3591(a)(2)(C). I e. The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. SE 18 U.S.C. 359l(a)(2)(D). f. The defendant, in the commission of the offense, or in escaping apprehension for the Violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. 18 U.S.C. 3592(c)(5). g. The defendant committed the offenses after substantial planning and_ premeditation to cause the death of a person. SE 18 U.S.C. 35 h. The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. See 18 U.S.C. 3592(c)(16). [24] EMANUEL afk/a ?Funky/Damage I. Counts Six and Seven: Murder of IUAN a/k/a ?To?ito?,' KEVIN SOTO-ROMAN, a/k/a Gordo?, and SANTOS DIAZ-CAMACHO, a/k/a ?Joel BaZooka? on July 20, 2011 . Counts Six and Seven of this Indictment are hereby realleged and adopted by reference. . It-is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. _Se_e 18 U.S.C.. 3591(a). b. ?The defendant intentionally?k?led the Victim. _Se_e l8 U.S.C. 35 69 c. The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe Victirn. 18 U.S.C. 3591(a)(2)(B). d. The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. 18 U.S.C. 35 e. The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death toa person, other than one of the participants inthe offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. 18 U.S.C. f. The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. Egg 18 U.S.C. 3592(c)(5). g. The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. ?g 18 U.S.C. 3592(c)(9). h. The defendant intentionally killed or attempted to kill more than one person in a Isingle criminal episode. 18 U.S.C. 3592(c)(16). [33] WILLIAM a/k/a ?W/Willite? I. 1. Counts Four and Five: Murder of EDWIN HERVTN VALCARCEL- MARTMZ, a/k/a ?Prieto?_?, JAVIER and ORLANDO on June 25, 2011 Counts Four and Five of this Indictment are hereby realleged and adopted by reference. 70 2. It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. See 18 U.S.C. 3591(a). The defendant intentionally killed the Victim. si? 18 U.S.C. 35 The defendant intentionally in?icted serious bodily injury that resulted in the death of the Victim. 18 U.S.C. 3591 The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in cennection with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(C). The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the Victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(cj. The defendant has previously 'been convicted of a Federal or State o?ense ptmishable by a term of imprisonment of more than one year, involving the use or attempted or threatened use of a firearm (as defined in section 921) against another person. S_ee 18 U.S.C. 3592(c)(2). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. See 18 U.S.C. 3592(c)(16). [36] XAVIER CASTRO-VEGA, a/k/a ?Raton? I. Counts Four and Five: Murder of EDWIN HERVIN VALCARCED MARTINEZ, a/k/a ?Prieto?, JAVIER and ORLANDO on June 25, 2011 a. . Counts Four and Five of this Indictment are hereby realleged and adopted by reference. . It is further alleged that The defendant was eighteen (l 8) years of age or older at the time of the offenses. 18U.S.C. 3591(a). The defendant intentionally killed the Victim. gee 18 U.S.C. 3591(a)(2)(A). The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe Victim. _S_e_e 18 U.S.C. 3591(a)(2)(B). The defendant intentionally participated in an act, contemplating that the life- of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result ofthe act. 18 U.S.C. 3591(a)(2)(C). The defendant intentionally and speci?cally engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the Victim, died as a direct result of the act. gee 18 U.S.C. 3591(a)(2)(D). The defendant has preyiously been convicted of a Federal or State offense punishable by a term of nnprisontnent of more than one year, involving the use or 72 attempted or threatened .use of a ?rearm (as de?ned in section 921) against another person. See 18 U.S.C. 3592(c)(2). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). Counts Six and'Seven: Murder of JUAN a/k/a ?To?ito?, KEVIN a/k/a ?El Gordo?, and SANTOS DIAZ-CAMACHO, a/k/a ?Joel Bazooka? on July 20, 2011 . Counts Six and Seven of this lndictrnent are hereby realleged and adopted by reference. . It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. ?e_e 18 U.S.C. 3591(a). I The defendant intentionally killed the Victim-See 18 USC. 3591 The defendant intentionally inflicted serious bodily injury that resulted in the death ofthe victim. 18 use. 3591(e)(2)(s). The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result of the act: See 18 U.S.C. 3591(a)(2)(C). The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. see 18 U.S.C. 3591(e)(2)(n). 73 f. The defendant, in the commission of the offense, or in escaping apprehension for the?violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. l8 U.S.C. 3592(c)(5). The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. 18 U.S.C. 3592(c)(9). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). [37] CARLOS M. a/k/a ?Carlitos El NegroMarcel? I. Counts Eight and Nine; Murder of LUIS a/k/a LUIS a/k/a ?Urraca?, and JOSE on August 28, 2012 a. b. C. . Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: The defendant was eighteen (18) years of ageior older at the time of the offenses. gee 18 U.S.C. 3591(a). The defendant intentionally killed the victim. i3; 18 U.S.C. 3591(a)(2)(A). The. defendant intentionally in?icted serious bodily injury that resulted in the death of the Victim. gee 18 U.S.C. 359l(a)(2)(B). The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. SE 18 U.S.C. 3591(a)(2)(C). 74 The defendant intentionally and speci?cally engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the Victim, died as a direct result of the act. . 18 U.S.C. 3591(a)(2)(D). The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. 18 U.S.C. 3592(c)(5). The defendant procured the commission of the offense by payment, or promise of payment, of anything of pecuniary value. 18 U.S.C. 3592(c)(7). The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. ?g 18 U.8.C. 3592(c)(9). The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. _S_e_e l8 U.S.C. 3592(c)(16). [38] ANALDI TANGO-MORENO, alk]a?Kin1bito? I.. Counts Eight and Nine: Murder of LUIS a/k/a ?Polio,? LUIS a/k/a ?Urraca?, and JOSE on August 28, 2012 3.. . Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: The defendant was eighteen (18) years of age or older at the t'me of the offenses. 18 U.S.C. 3591(a). The defendant intentionally killed the victim. 13 U.S.C. 3591(a)(2)(A). 75 . The defendant intentionally in?icted serious bodily injury that resulted in the death ofthe victim. s_ea 18 use. 3591(a)(2)(B). . The defendant intentionally participated inan act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. 853 18 U.S.C. 359l(a)(2)(C). . The defendant intentionally and speci?cally engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants inthe offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. ?ee 18 U.S.C. 3591(a)(2)(D). The defendant has previously been convicted of a Federal or State offense punishable by a term of imprisonment of more than one year, involving the use or attempted or threatened use of a ?rearm - (as de?ned in section 921) against another person. ?g 18 U.S.C. 3592(c)(2). . The defendant, in the commission of the offense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. 18 U.S.C. 3592(c)(5). . The defendant procured the commission of'the offense by payment, or promise of payment, of anything of pecuniary value. 18 U.S.C. 3592(c)(7). The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. sag 18 use. 35 9203(9). 76 j. The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). {53] JOSE E. a/k/a ?Camon? I. Counts Eight and Nine: Murder of LUIS OJEDA-ANDINO, a/k/a LUIS a/k/a ?Urraca?, and JOSE on August 28, 2012 a. . Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: The defendant waseighteen (18) years of age or older at the time of the offenses. 18 U.S.C. 3591(a). The defendant intentionally killed the victim. S_ee_ l8 U.S.C. 35 The defendant intentionally inflicted serious bodily injury that .resulted in the death ofthe victim. 18 use. 3591(a)(2)(B). I The defendant intentionally participated in an act, contemplating that. the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result of the act. See 18 U.S.C. 3591(a)(2)(C). The defendant intentionally and Speci?cally engaged in an act of violence, linong that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. - sag 18 U.S.C. 3591(a)(2)(D). 77 f. The defendant has previously been convicted of a Federal or State offense punishable by a term of imprisonment of more than one year, involving the use or attempted or threatened use of a ?rearm (as de?ned in section 921) against another person. ?g 18 U.S.C. 3592(c)(2). g. The defendant, in the commission of the o?ense, or in escaping apprehension for the violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. 18 U.S.C. 3592(c)(5). h. The defendant procured the commission of the offense by payment, or promise of payment, of anything of pecuniary value. gee 18 U.S.C. 3592(c)(7). i. The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. gee, 18 U.S.C. j. The defendant intentionally killed or attempted to kill more than One person in a single criminal episode. gee, 18 U.S.C. 3592(c)(16). [59] FNU LNU, a/k/a ?Gaby? I. Counts Eight and Nine: Murder of LUIS a/k/a LUIS a/k/a ?Urraca?, and JOSE on August 28, 2012 . Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. . It is further alleged that: a. The defendant was eighteen (18) years Of age or older at the time of the offenses. 18 U.S.C. 3591(a). b. The defendant intentionally killed the victim. 18 U.S.C. 3591(a)(2)(A). 78 . The defendant intentionally in?icted serious bodily injury that resulted in the death of the Victim. 18 U.S.C. 3591(a)(2)(B). . The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with 'a person, other than one of the participants in the offenses, and the victim, died as a direct result of the act. ?gs; 18 U.S.C. 3591(a)(2)(C). . The defendant intentionally and specifically engaged in an act of Violence, knowing that the act created a grave risk of death to a person, other than one of the participants inthe offenses, such that participation in the act constituted a reckless disregard for human life and theivictim, died as a direct result of the act. is; 18 U.S.C. 3591(a)(2)(D). The defendant, in the commission of the offense, or in escaping apprehension for the Violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the Victim of the offense. 18 U.S.C. 3592(c)(5). . The defendant procured the commission of the o?ense by payment, or promise of payment, of anything of pecuniary value. See 18 U.S.C. 3592(c)(7). . The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. 18 U.S.C. 3592(c)(9). The defendant intentionally killed or attempted to more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). 79 [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego? I. Counts Eight and Nine: Murder of LUIS a/k/a ?130110,? LUIS a/k/a ?Urraca?, and JOSE AYALA-GARCIA on August 28, 2012 . Counts Eight and Nine of this Indictment are hereby rea?eged and adopted by reference. . It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. See 18 U.S.C. 3591(a). - b. The defendant intentionally killed the Victim. ?g 18 U.S.C. 3591(a)(2)(A). c. The defendant intentionally in?icted serious bodily injury that?resulted in the death of the Victim. S_ee_ 18 U.S.C. 3591(a)(2)(B). d. The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the victim, I died as a direct result of the. act. 18 U.S.C. 3591(a)(2)(C). e. The defendant intentionally and specifically engaged in an act of Violence, knowing that the act created a grave risk. of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(D). f. The defendant, in the commission of the offense, or in escaping apprehension for the Violation of the offense, blowineg created a grave risk of death to one or more persons in addition to the Victim of the offense. See 18 U.S.C. 3592(c)(5). 80 g. The defendant procured the commission of the offense by payment, or promise of payment, of anything of pecuniary value. See 3592(c)(7). h. I The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. 18 U.S.C. 3592(c)(9). i. The defendant intentionally killed or attempted to kill more than one person in a single criminal episode. 18 U.S.C. 3592(c)(16). [61] ORLANDO a/k/a ?Oreo/Willito/Angel M. Santiago-Ayala? I. . Counts Eight and Nine: Murder of LUIS OIEDA-ANDINO, a/k/a ?Pollo,? LUIS .a/k/a ?Urraca?, and JOSE on August 28, 2012 1. Counts Eight and Nine of this Indictment are hereby realleged and adopted by reference. 2. It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the offenses. 18 U.S.C. 3591(a). b. The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection with a person, other than one of the participants in the offenses, and the Victim, died as a direct result of the act. See 13 U.S.C. 3591(a)(2)(C). c. The defendant, in the commission of the o?ense, or in escaping apprehension for the Violation of the offense, knowingly created a grave risk of death to one or more persons in addition to the victim of the offense. 18.U.S.C. 3592(c)(5). cl. The defendant committed the offenses after substantial planning and premeditation to cause the death of a person. get; 18 U.S.C. 3592(c)(9). 81 [66] CARLOS I. Counts Four and Five: Murder Of EDWIN DIAZ-CRUZ, HERVIN a/k/a ?Prieto?, IAVIER and ORLANDO on June 25, 2011 1. Counts Four and Five of this Indictment are hereby realleged and adepted by reference. 2. It is further alleged that: a. The defendant was eighteen (18) years of age or older at the time of the o?enses. 18 U.S.C. 3591(3). 13. The defendant intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in connection With a person, other than one of the participants in the offenses, and the Victim, died as a direct result of the act. 18 U.S.C. 3591(a)(2)(C). RICO FORFEITURE The allegations contained in Count One of this Indictment are hereby repeated, realleged, and incomorated by reference herein as though fully set forth at length for-the purpose of alleging forfeiture pursuant to the provisions of 18 U.S.C. 1963 and 28 U.S.C. 21161 Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is hereby given to the defendants that the United States will seek forfeiture as part of any sentence inaccordance with 18 U.S.C. 1963 in the event of any defendant?s conviction under Count One of this Indictment. The defendants, OSUE a/k/a ?Mayito/Mayo/El Father?, PEDRO VIGIO-APONTE a/k/a ?Pedrito/Pedrito He-Man/Pello/Pedrito Trauma?, FRANKIE a/k/a ?Ankyf? Negro/Frank?, LUIS F. a/k/a ?Trenza/Enano/Luis Trenza?, 82 MIGUEL VAZQUEZ-MARTJNEZ, a/k/a ?Miguelo/Radio/NIiclo/BJ?, RUBEN COTTO-ANDINO, a/k/a ?Ruben El Negro?, ERNESTO MORALES-CASTRO, a/k/a ?Nestor/L05 Gorditos?, CHRISTIAN MORALES-CASTRO, a/k/a ?Bimbo/L03 Gorditos?, REYFRANK QUINONES-CARRION, a/k/a ?Pelotero?, [10] KELVIN D. [11] ISMAEL MENDEZ-ARROYO, a/k/a ?Bolillo?, MICHAEL MUNIZ-SANCHEZ, - [13] JONATHAN PEREZ-RODRIGUEZ, a/k/a ?Perra/Perreke?, [14] JOSE L. ORTIZ-AGUIRRE, a/k/a ?Cheo/Cheo Cede?u?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/a ?Pithull?, [16] WILLIAM a/k/a ?PlayaJPlay?, [17] KIDANNY a/k/a ?Sony/Sonata?, [18] JOSE L. a/k/a ?Luisito/Scary?, [19] JOSE E. MOJICA-ROBLES, a/k/a ?Papito Mojica??, VICTOR M. RODRIGUEZ-TORRES, a/k/ a ?Cuca/Cucaracha/Papotin?, [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Bow Chula?, [22] MYLES J. ROMAN-ADORNO, [23] GUILLERMO SANCHEZMORA, a/k/a ?Guillo?, [24] EMANUEL a/k/a ?Punky/Dalmata?, [25] ALEXANDER a/k/a ?Lechon?, [26] DAVID E. RODRIGUEZ-CASTRO, [27] RAFAEL HIRALDO-ALEJANDRO, a/k/a ?Boliilo?, [28] ALEXIS CART AGENA-GERENA, a/k/a [29] ANGEL L. a/kfa ?Huesito?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS a/k/a ?Romulo?, [32] JOSE L. a/k/a ?Sonso/Nariz?, [33] WILLIAM ZAMBRANA-SIERRA, a/k/a [34] EDGAR a/k/a ?Eggy?; [35] ARNALDO ALICEA-COLON, a/k/a ?Naldito?, XAVIER a/k/a ?Raton?, [37] CARLOS M. a/k/a ?Carlitos El egro/IVIarcel?, [38] ANALDI TAN CO-MORENO, a/k/a ?ijbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fine?, . [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a f?Cheykin?, [41] JESUS E. MONTALVAN-DIAZ, a/k/a ?Luis Garcia?Diaz/Willy Wonka?, a/k/a ?Boty?, [43] LUIS YANYORE-PIZARRO, a/k/a ?KimbO/Bauncer/Jose Boria-N?llan?, [44] FNU LNU, a/k/a ?Eziel?, [45] LUIS a/k/a ?RayafI'renza?, [46] MICHAEL RIVERA-RODRIGUEZ, ALVIN A. a/k/a ?Ardilla?, [48] M. [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin?, [50] ROBERTO FUENTES-PACHECO, a/k/a unite Parcha?, 83 1 [51] ROGER a/k/a ?Gua?, [52] FELIX A. a/k/a ?Cholon?, [53] EDGARDO LUNA-LOPEZ, a/k/a ?Piri/Enano?, [54] JESSY J. MELENDEZ-HERNANDEZ, a/kla ?Koby/El NegrofLely?, [55] DENZEL [56] ABIMAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/FeofMetra?, [57] ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kija?, [58] JOSE E. RIVERA-BIALDONADO, a/k/a ?Cannon?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, [61] ORLANDO a/k/a ?Or'eo/Willito/Angel M. Santiago-Ayala?, [62] KERNIS RODRIGUEZRIVERA, a/k/a ?Sosa?, [63] WALTER D. MULLER-COLON, a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, [65] CARLOS E. ES, a/k/a ?El Barber/Wiso E1 Barber?, [66] CARLOS a/k/a ?Pirin?, [67] JONATHAN a/k/a ?Katinehi?, [68] IRAM I. a/k/a ?Cubano?, [69] CHARLIE J. a/k/a ?Chiry?, [70] EDGARDO R. a/k/a ?MasacreMasa?, [71] FRANCISCO J. GONZALEZ-CAMACHO, a/k/a ?Lento?, [72] NESTOR R. CONCEPCION-RIVERA, a/k/a ?Nesti/K?ate?, [73] IVETTE a/k/a ?Ive/Precious Moments?, [74] BILLY a/k/a ?Mew/Billy Meca?, [75] AYFRANK QUINONES-CARRION, . [76] FELIX RODRIGUEZ-RODRIGUEZ, a/k/ a ?Correa/Baloncelista/El Indie?, [77] DANIEL O. MARTINEZVELEZ, a/k/a ?Berto?, [78] LUIS F. DIAZ-TINEO, a/k/a ?Pipen/Pipe?, [79] OSUE O. a/k/a ?Gordo Puta?, [80] RAMON VICENTY-RIVERA, a/k/ a ?Poke?, [81] LUIS E. GUADALUPE-CAMACHO, a/k/a ?YayafYayi/Ardi?a?, [82] JULIO N. MATOS-SANCHEZ, afk/a ulio Mara?a?, [83] REYNALDO GONZALEZ-ZAYAS, a/k/a ?Cato?, MARTINEZ, a/k/a ?Faj: Boy?, [85] DAMIAN FERNANDEZ-JORGE, [86] JOSE A. a/k/a ?Semilla?, [87] KEVIN CASTRO-VEGA, [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID CO, a/k/a ?David Nota?, [90] GIOVANI ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, [92] JAMES STEELE-TORRES, a/k/a ?Negro Steele?, [93] NILDA a/k/a ?Katy/Kathy?, [94] ALEX SANTIAGO-CRESPO, a/k/a ?Papo Swing/Ale?, [95] FRANCISCO a/k/a ?Mara?a?, [96] CARLOS MIRANDA, a/k/a 84 [97] RAMON ANDINO-PEGUERO, a/k/a ?Mono?, [98] VICTOR ALFONSO-JORGE, a/k/a ?Nana?, [991 HECTOR J. CRUZ-VARGAS, a/k/a ?Funky?, [100] YAMIL a/k/a ?El Mono?, [101] ROBERT D. a/k/a ?Minim?, [102] ANTHONY a/k/a ?Oreo/Apu?, [103] DANIEL a/k/a ?Paleta?, [104] LUIS a/k/a ?Zena?, [105] ASTRID J. a/k/a ?La Jefa?, 1. have acquired and maintained interests in Violation of 18 U.S.C. 1962, which interests are subject to forfeiture to the United States pursuant to 18 U.S.C. 1963(a)(1); 2. have an interest in, security of, claims against, and property and contractual rights which afford a source of in?uence over, the enterprise named and described herein which the defendants established, operated, controlled, conducted, and participated in the conduct of, in Violation of 18 U.S.C. 1962, which interests, securities, claims, and rights are subject to forfeiture to the United States pursuant to 18 US .C. 1963(a)(2); 3. have property constituting and derived from proceeds obtained, directly and indirectly, U.S.C. from racketeering activity, in Violation of 18 U.S.C. 1962, which property is subject to forfeiture to the United States pursuant to 18 U.S.C. I The interests of the defendants subject to forfeiture to the United States pursuant to 18 1963 and (3), include but are not limited to: at least $82,000,000; one (1)-Type: Pistol, Make: Taurus, Caliber: 9mm, Serial Number: TOD72701, one (1) Type: Pistol, Make: Smith Wesson, Model: SW9VE, Caliber: 9mm, Serial Number: PBP6590, one (1) Ri?e, Caliber: .22, Make: Rugger, Model: 1022, Serial Number: 114- 98271, one (1) Type: Pistol, Make: Glock, Model: 32, Caliber: .357, Serial Number: obliterated, one (1) Type: Pistol, Make: Glock, Model: 21, Caliber: .45, Serial Number: I 85 one (1) Type: Pistol, Make: FNH, Model: Five Seven Semie, Caliber: 5.7 28, Serial Number: 386124564, and one (1) Rifle, Caliber: 7.62 39, Serial Number: AD028382, one (1) Type: Pistol, Make: Taurus, Model: PT9ZAF, Caliber: 9mm, Serial Number: TYP95500, one (1) Type: Pistol, Make: Glock, Model: 20, Caliber: .357, Serial Number: GEN-411, one (1) Type: Pistol, Make: Glock, Model: 23, Caliber: .40, Serial Number: one (1) Type: Pistol, Make: Smith Wesson, Model: 5906, Caliber: 9mm, Serial Number: TCL5650, one (1) Type: Revolver, Make: Magnum, Caliber: .357, Model: 65?3, Serial Number: AEY0037, one (1) Type: Revolver, Make: Colt, Model: Magnum, Caliber: .3357, Serial Number: one (1) Type: Pistol, Make: Smith 85 Wesson, Model?: 5906, Caliber: 9mm, Serial Number: TYN3286, one (1) Type: Pistol, Make: saw, Modelz6906, Caliber: 9mm, Serial Number: VAN0235, one (1) Type: Pistol, Make: Glock, Model: 23, Caliber: .40, Serial Number: one (1) Type: Pistol, Make: Smith Wesson, Model: MP, Caliber: .40, one (1) Type: Pistol, Make: Glock, Model: 23, Caliber: .40, Serial Number: EAWISS, one (1) Type: Pistol,? Make: Glook, Model: 22, Caliber: .40, Serial Number: RFD072, one'(1) Type: Pistol, Make: Gloek, Model: 22, Caliber: .40, Serial Number: ERZ359, one (1) Type: Pistol, Make: Model: NIP, Caliber: .40, Serial Number: MPB2756, one (1) Type: Pistol, Make: Glook, Model: 22, Caliber: .40, Serial Number: EHC046, one (1) Ri?e, Caliber: 7.62 39, Model: Serial Number: 1-70605?4, one (1) Ri?e, Caliber: .223, Serial vNurnber: 052220, one (1) Type: Pistol, Make: Glock, Model: 27, Caliber: .40, Serial Number: RUC484, one (1) Type: Pistol, Make: Glock, Model: 9323, Caliber: .357, Serial Number: LKPSOS, one (1) Ri?e, Caliber: 5.56, Make: Colt, Serial Number: obliterated,? one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: 86 one (1) Type: Revolver, Make: Ruger, Model: Speed?Six, Caliber: .357, Serial Number: 158-14081, one (1) Ri?e, Caliber: 7.62 39, Make: Draco Romarm/Cugir, Serial Number: DC?7805?ll R0, one (1) Ri?e, Caliber: 7.62 39, Model: GP Make: ROMARM, Serial Number: 1973 ET 0988, one (1)'Type: Revolver, Make: Colt, Model: Detective Special, Caliber: .38, Serial Number: 44539 and ammunition. If any of the property described above, as a result of any act or omission of a defendant, 1. cannot be located upon the exercise of due diligence; . 2. has been transferred or sold to, or deposited with, a third party; 3. has been placed beyond the jurisdiction of the court; 4. has been substantially diminished in value; or 5. has been commingled with other property which cannot be divided Without dif?culty; the court shall order the forfeiture of any other property of the defendants up to the value of any property set forth above. The above-named defendants, and each of thorn, are jointly and severally liable for the forfeiture obligations as'alleged above. All pursuant to 18 U.S.C. 1963. NARCOTICS FORFEITURE ALLEGATION The allegations contained in Count Two of this Indictment are hereby re?alleged and incorporated by reference for the purpose of alleging forfeitures pursuant to 21 U.S.C. 853. Upon conviction of the offense in violation of 21 U.S.C. 846, set forth in Count Two of this Indictment, the defendants, OSUE a/k/a ?Mayito/Mayo/El Father?, a/k/a ?Pedrito/Pedrito Trauma? PEDRO VIGIO 87? a/k/a ?Anky/El Negro/F rank?, LUIS F. a/k/a ?Trenza/Enano/Luis Trenza?, IVIIGUEL a/k/a ?Miguelo/Radio/N?clo/BJ?, RUBEN a/k/a ?Ruben E1 Negro?, ERNESTO a/k/a ?Nestor/L03 Gorditos?, CHRISTIAN a/k/a ?Bimbo/Les Gorditos?, REYFRANK a/k/a ?Pelotero?, [10] KELVIN D. MORALES-CINTRON, [11] ISMAEL a/k/a ?Bolillo?, [12] MICHAEL [13] JONATHAN PEREZ-RODRIGUEZ, a/k/a' ?Perm/P erreke?, [14] JOSE L. alkla ?Cheo/Cheo Cede?o?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/a ?Pitbull?, [16] WILLIANI a/k/a ?Playa/Play?, [17] KIDANNY afk/a ?Sony/Sonata?, JOSE a/k/a ?Luisito/Scary?, I [19] JOSE E. a/k/a ?Papito Mojica?, [20] VICTOR M. RODRIGUEZ-TORRES, a/k/a ?Cuca/Cucaracha/Papotin?, [21] RAFAEL a/k/a ?Rafa/Rafa Colgate/Becca Chula?, [22] MYLES J. [23] GUILLERMO SANCHEZ-MORA, a/k/a ?Guillo?, [24] EMANUEL a/k/a ?Punky/Dalmata?, [25] ALEXANDER RIVERA-CARRION, a/k/a ?Lechon?, [26] DAVID E. RODRIGUEZ-CASTRO, - [27] RAFAEL HERALDO-ALEJANDRO, a/k/a ?Bolillo?, [28] ALEXIS a/k/a ?Pollo?, [29] ANGEL L. a/k/a ?Huesito?, [30] OSCAR A. CALVINO-ACEVEDO, a/k/a ?Alex?, [31] JESUS DE-JESUS-COLON, a/k/a ?Romulo?, [32] JOSE L. a/k/a ?Sonso/N?riz?, [33] WILLIAM a/k/a ?W/Willito?, GONZALEZ-RIVERA, a/k/a ?.Eggy?, [35] ARNALDO a/k/a ?Nalditb?, [36] XAVIER CASTRO-VEGA, a/k/a ?Raton?, [37] CARLOS M. GUERRERO-CASTRO, a/k/a ?Carlitos E1Negro/Marce1?, [38] ANALDI TAN a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fina?, - [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. a/k/a ?Luis Garcia-Diaz/Willy Wonka?, [42] AMAURY a/k/a ?Duty?, [43] LUIS YANYORE-PIZARRO, a/k/a ?Kimbo/Bauncer/Jose Boria-Mj?an?, [44] FNU LNU, afk/a ?Eziel?, [45] LUIS MARTINEZ-NEWS, a/k/a ?Raya/Trenza?, [46] NEICHAEL RIVERA-RODRIGUEZ, [47] ALVIN A. a/k/a ?Ard?la?, [48] JAINIE M. 88 [49] KENNY 0. PACHECO, a/k/a ?Keny/Bolin?, [50] ROBERTO FUENTES-PACIIECO, a/k/a ?Junito Parcha?, [51] ROGER FALU-DIAZ, a/k/a ?Gua?, [52] FELIX A. MALAVE-TORRES, a/k/a ?Cholon?, [53] EDGARDO LUNA-LOPEZ, a/k/a ?Piri/Enano?, [54] JESSY J. MELENDEZ-HERNANDEZ, a/k/a ?Kaby/El Negro/Lely?, [55] DENZEL RODRIGUEZ-CARABALLO, [56] ABIIVIAEL CRULRODRIGUEZ, a/k/a ?Lindo/FeoMe?tra?, [57] ANGEL L. COTTO-NEGRON, a/k/a ?Quija/Kija?, [58] JOSE E. RIVERA-MALDONADO, a/k/a ?Camon?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. afk/a ?Tego?, [61] ORLANDO PADILLA-AYALA, a/k/a ?Oreo/Willito/Angel M. Santiago-Ayala?, [62] KERNIS a/k/a ?Sosa?, . [63] WALTER D. a/k/a ?Vampy{Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, [65] CARLOS E. BRIOSO-COLLANTES, a/k/a Barber/Wise E1 Barber?, [66] CARLOS a/k/a ?Pirin?, [67] JONATHAN FIGUEROA-CATINCHI, a/Ida ?Katinchi?, [68] I. SAN a/k/a ?Cabana?, [69] CHARLIE J. a/k/a ?Chiry?, [70] EDGARDO R. RUANO-CHEVERE, a/k/a ?MasacrefMasa?, [71] FRANCISCO J. GONZALEZ-CAMACHO, a/k/a ?Lento?, [7 2] NESTOR R. CONCEPCION-RIVERA, a/k/a ?NestifKilate?, [73] IVETTE VAZQUEZ-DROZ, a/k/a ?Ive/Preciqus Moments?, [74] BILLY QUILLO, a/k/a ?Mew/Billy Meca?, [75] JAYFRANK [7 6] FELIX a/k/a [7 7] DANIEL O. MARTINEZVELEZ, a/k/a ?Berta?, [78] LUIS F. a/k/a ?Pipen/Pipe?, [79] OSUE O. FIGUEROA-RODRIGUEZ, a/k/a ?Gerda Puta?, [80] RAMON VICENTY-RIVERA, a/k/a ?Poke?, [81] LUIS E. GUADALUPE-CANIACHO, a/k/a ?Yaya/Yayi/Ardilla?, [82] JULIO N. a/k/a ?Julio Mara?a?, [83] REYNALDO GONZALEZ-ZAYAS, a/k/a ?Cuto?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [85] DAMIAN FERNANDEZ-JORGE, [86] JOSE A. a/k/a ?Sem?la?, [87] KEVIN CASTRO-VEGA, [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID a/k/a ?David Nata?, [90] GIOVANI a/k/a ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, [92] JAMES a/k/a ?Negro Steele?, [93] NILDA SANTIAGO-ESPINOSA, a/k/a ?Katy/Kathy?, [94] ALEX a/k/a ?Papa Swing/Ale?, 89 [95] FRANCISCO VARGAS-SANCHEZ, a/k/a ?Mara?a?, [96] CARLOS MIRANDA, a/k/a [97] RAMON a/k/a ?Mono?, [98] VICTOR ALFONSO-JORGE, a/k/a ?Nana?, [99] HECTOR J. CRUZ-VARGAS, a/k/a ?Punky?, [100] YAMIL a/k/a ?El Mono?, [101] ROBERT D. PEREZ-W2, a/k/a ?Minino?, [102] ANTHONY ESPADA-COLON, a/k/a ?Oreo/Apu?, [103] DANIEL a/k/a ?Paleta?, [104] LUIS E. a/k/a ?Zena?, [105] ASTRB) J. MARTINEZ-VALENTIN, a/k/a ?La Jefa?, shall forfeit ?to. the United States pursuant to 21 U.S.C. 853, any property constituting, or derived ?cm, proceeds obtained, directly or indirectly, as a result of said Violation and any property used, or intended to be?used, in any manner or part, to commit, or to facilitate the commission of said violation, including but not limited to- the following: $82,000,000. If any of the property described above, as a result of any act or omission of a defendant, 1. 2. 3. 4. 5. cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or A I has been commingled with other property which cannot be divided Without dif?culty; the-United States of America shall be entitled to forfeiture of substitute property pursuant to 21 U.S.C. 853(p), as incorporated by 28 U.S.C. 2461(0). Allpursuant to 21 U.S.C. 853. 90 FIREARMS FORFEI-TURE ALLEGATION The allegations in this Indictment are hereby rea?eged and [incorporated by reference for . the purpose of alleging forfeiture pursuant to 18 U.S.C. 1963 and 924(d)(1) and 28 U.S.C. 2461(c). A Upon copyic?on of the offenses in Violation of 18 USC. 1962(d), 924(0), and 9246), as set forth 1'11 this Irldietment, I OSUE VAZQUEZ-CARRASQUILLO, a/k/a ?Mayito/Mayo/EI Father?, PEDRO a/k/a ?Pedrito/Pedrito Trauma?, FRANKEE ROSA-CALDERON, a/k/a ?Anky/El Negro/F rank?, MIGUEL a/k/a ?IVIiguelo/Radio/Miclo/BJ?, ERNESTO MORALES-CASTRO, a/k/a ?Nestor/L05 Gorditos?, CHRISTIAN a/k/a REYFRANK a/k/a ?Pelotero?, [10] KELVIN D. [11] ISMAEL a/k/a ?Bolillo?, [14] JOSE L. a/k/a ?Cheo/CheoCede?o?, [15] REINALDO RODRIGUEZ-MARTINEZ, a/k/a ?Pitbull?, [16] WILLIAM ORTIZ-AGUTRRE, a/k/a f?Playa/Play?, [17] KIDANNY a/k/a ?Sony/Sonata?, [18] JOSE L. a/k/a ?Luisito/Scary?, [20] VICTOR M. RODRIGUELTORRES, a/k/a ?Cuca/Cucarac?a/Papotin?, [21] RAFAEL ANDINO-OJEDA, a/k/a ?Rafa/Rafa Colgate/Boca Chula?, [24] EMANUEL ZABALA-PEREZ, a/k/a ?Punky/Dalmata?, [25] ALEXANDER RIVERA-CARRION, a/k/a ?LeChon?, [28] ALEXIS CARTAGENA-GERENA, a/k/a [301 OSCAR A. a/k/a ?Alex?, [31] JESUS a/k/a ?Romain?, [32] JOSE L. a/k/a ?Sonso/Nariz?, [34] EDGAR GONZALEZ-RIVERA, a/k/ a ?Eggy?, [36] XAVTER CASTRO-VEGA, a/k/a ?Raton?, [37] CARLOS M. a/k/a ?Carlitos E1 Negro/Marcel?, [38] ANALDI TAN a/k/a ?Kimbito?, [39] ORLANDO J. SANTANA, a/k/a ?Fine?, - [40] LUIS F. RODRIGUEZ-MARQUEZ, a/k/a ?Cheykin?, [41] JESUS E. a/k/a ?Luis Wonka?, [42] AMAURY MIENDELROSADO, a/k/a ?Boty?, [43] LUIS, a/k/a ?Kimbo/Bauncer/Jose Boria-N?llan?, [44] FNU LNU, a/k/a ?Eziel?, [45] LUIS a/k/a ?Raya/Trenza?, [46] MICHAEL RIVERA-RODRIGUEZ, 91 [47] ALVIN A. a/k/a ?Ardilia?, [48] M. SEMJDAY-PEREZ, - [49] KENNY O. PACHECO, a/k/a ?Keny/Bolin?, [56] ROBERTO UENTES-PACHECO, a/k/a ?Junito Pareha?, [51] ROGER a/k/a ?Gila?, [52] FELIX A. MALAVE-TORRES, a/k/a ?Cholon?, [53] EDGARDO LUNA-LOPEZ, a/k/a ?Piri/Enano?, [54] a/k/a ?Koby/El egro/Lely?, [55] DENZEL RODRIGUEZ-CARABALLO, [56] ABHVIAEL CRUZ-RODRIGUEZ, a/k/a ?Lindo/Feo/Metra?, [59] FNU LNU, a/k/a ?Gaby?, [60] JOSE D. RESTO-FIGUEROA, a/k/a ?Tego?, [61] ORLANDO a/k/a ?Oreo/Willito/Angel M. Santiago-Ayala?, [62] KERNIS RODRIGUEZ-RIVERA, afk/a ?Sosa?, [63] WALTER D. a/k/a ?Vampy/Bolo?, [64] WILFREDO RUIZ, a/k/a ?Freddy?, [65] CARLOS E. Barber/Wise El Barber?, [66] CARLOS VELAZQUEZ-FONTANEZ, [67] JONATHAN FIGUEROA-CATINCHI, a/k/a ?Katinchi?, [69] CHARLIE J. a/k/a ?Chiry?, [72] NESTOR R. CONCEPCION-RIVERA, a/k/a - [76] FELIX a/k/a ?Correa/Baloncelista/El India?, [77] DANIEL O. MARTINEZ-VELEZ, a/k/a ?Berto?, [80] RAMON a/k/a ?Poke?, [84] BRYAN MARTINEZ, a/k/a ?Fat Boy?, [86] JOSE A. FOURNIER-COLLAZO, a/k/a ?Semilla?, [87] IGEZVIN CASTRO-VEGA, [88] JUAN GUADALUPE-DELGADO, a/k/a ?Bocao?, [89] DAVID a/k/a ?Dairid ota?, [90] GIOVANI JUSTINIANO-DIAZ, a/k/a ?Zegueta?, [91] CHRISTIAN a/k/a ?Chapa?, - [98] VICTOR ALF ON SO-J ORGE, a/k/a ?Nana?, [99] HECTOR J. a/k/a ?Funky?, [103] DANIEL a/lda ?Paleta?, [104] LUIS E. afk/a ?Zena?, the defendants herein, shall forfeit to the United States, pursuant to 18 U.S.C. 924(d)(1) and 28 U.S.C. 2461(c), any ?rearm and ammunition involved or used in the knowing commission of the offense, including? but not limited to: one Type: Pistol, Make: Taurus, Caliber: 9mm, Serial Number: TOD72701, one (1) Type: Pistol, Make: Smith Wesson, Model: SW9VE, Caliber: 9min, Serial Number: PBF6590, one (1) Ri?e, Caliber: .22, Make: Rugger, Model: 92 1022, Serial Number: 114-98271, one (1) Type: Pistol, Make: Glock, Model: 32, Caliber: .357, Serial Number: obliterated, one (1) Type: Pistol, Make: Glook, Model: 21, Caliber: .45, Serial Number: FEB-741, one (1) Type: Pistol, Make: FNH, Model: Five Seven Semie, Caliber: 5.7 28, Serial Number: 38G124564, and one (1) Ri?e, Caliber: 7.62 39, Serial Number: AD0283 82, one (1) Type: Pistol, Make: Taurus, Model: PT9ZAF, Caliber: 9mm, Serial Number: TYF95500, one (1) Type: Pistol, Make: Glock, Model: 20, Caliber: .357, Serial Number: 411, one (1) Type: Pistol, Make: Gloek, Model: 23, Caliber: .40, Serial Number: one (1) Type: Pistol, Make: Smith Wesson, Model: 5906, Caliber: 9mm, Serial Number: TCL5650, one (1) Type: Revolver, Make: Magnum, Caliber: .357, Model: 65-3, Serial Number: AEY003 7, one (1) Type: Revolver, Make: Colt, Model: Magnum, Caliber: .357, Serial Number: one (1) Type: Pistol, Make: Smith Wesson, Model: 5906, Caliber: 9mm, Serial Number: TYN3286, one (1) Type: Pistol, Make: Model: 6906, Caliber: 9mm, Serial Number: VAN 0235, one (1) Type: Pistol, Make: Glock,?Model: 23, Caliber: .40, Serial Number: one (1) Type: Pistol, Make: Smith Wesson, Model: MP, Caliber: .40, one (1) Type: Pistol, Make: Glook, Model: 23, Caliber: .40, Serial Number: SAWISS, one (1) Type: Pistol, Make: Gloek, Model: 22, Caliber: .40, Serial Number: IRFD072, one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: .40, Serial Number: ER2359, one (1) Type: Pistol, Make: 886W, Model: MP, Caliber: .40, Serial Number: MPB2756, one (1) Type: Pistol, Make: Glook, Model: I 22, Caliber: .40, Serial Number: EHC046, one (1) Ri?e, Caliber: 7.62 39, Model: Serial Number: 1?70605-4, one (1) Ri?e, Caliber: .223, Serial Number: 052220, one (1) Type: Pistol, Make: Glook, Model: 27, Caliber: .40, Serial Number: RUC484, one (1) Type: Pistol, Make: Glock, Model: 32a, Caliber: .357, Serial Number: LKP505, one (1) Ri?e, Caliber: 5.56, Make: Colt, Serial Number: obliterated, one (1) Type: Pistol, Make: Glock, Model: 22, Caliber: 93 .40, Serial Number: one (1) Type: Revolver, Make: Roger, Model: Speed?Six, Caliber: .357, Serial Number: 158?14081, one (1) Ri?e, Caliber: 7.62 39, Make: Drao'o Romarm/Cugir, Serial Number: DC-7805?ll R0, one (1) Ri?e, Caliber: 7.62 39, Model: GP Make: ROMARM, Serial Number: 1973 ET 0988, one (1) Type: Revolver, Make: Colt, Model: Deteotive Special, Caliber: .3 8, Serial Number: 44539 and ammunition. All pursuant to 18 924(d)(1) and 28 Use. - TRUE BILL, - Date: RosA EMILIA United States Attorney r? . - 4/4 {gee/xf?/ Jose . Ruiz-Sa tiago Alberto R. Lopez?Rocafort United tates Attorney Assistant United States Attorney Chief, Criminal Division Victor 0. Acevedo?Hernandez Assistant United States Attorney Jenifel Y. andez Vegd Assist tUnited States orney Chief, Violent Crimes Unit 94