AO 91 (Rev. 11/11) Criminal Complaint
AUSA Peter M. Flanagan (312) 469-6235
AUSA Ryan P. Fayhee (312) 353-1998
SAUSA Minnie Yuen (312) 353-5361
UNITED STATES DISTRICT COURT.
NORTHERN DISTRICT OF ILLINOIS.
EASTERN DIVISION
UNITED STATES OF AMERICA
DIEGO PINEDA SANCHEZ,
allda “Botas,” “Boots,”
CARLOS PARRA-PEDROZA,
alla “Walter,” “Walt Disney,
Walt,” “Ary,
JOSE ABEL MENDOZA-PARRA,
afkla “Robin,”
MARIA LOERA ALVARADO,
a/kia “Samys@m"
ERNESTO RUIZ-RAMIREZ,
MARIO HERRERA,
ANTHONY LEIVA,
TEODOCIO CARO,
LUIS REYNA-TELLEZ,
HECTOR CHAVEZ CUEVAS,
JUAN CARLOS NUNEZ GALVEZ,
JOSE SANANTONIO,
PEDRO SAUCEDO-PALOMINOS,
OMAR LOPEZ-CABRERA,
VIRGIL DURBIN,
VALENTIN RODRIGUEZ,
ALMA LORENA ORTIZ DE ROSAS VERA,
CASMIRO ISAIAS-PADILLA,
EFREN MOTA,
FELIX LEMUS.GUEVARA,
PEDRO URQUIZA-OSORIO,
LUIS ARMANDO ACOSTA VIZCARRA,
OSCAR MONTES-LAMAS,
JOEL ESTRADA,
HARRANAH SAMORI,
GABRIEL SALCEDO,
TOMAS SALGADO REYNA,
OSCAR ACOSTA,
FEDERICO BARRERA-PEREZ,
EMMANUEL DIAZ,
JOSE HERNANDEZ OCHOA, and
ALFONSO NEVAREZ
Willy,” “Don
CASE NUMBER:
UNDER SEAL
15k 0s «6A
MAGISTE.ATE JUDGE MARTIN
RECEIVED
FEB ~ 9 2015
ue Bera (court
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and
belief.Beginning in or about August 2011, and continuing until at least in or about September 2014, in the
Northern District of Hlinois, and elsewhere, the defendants, together with others known and unknown,
violated:
Code Section Offense Description
Title 18, United conspiring to knowingly conduct and attempt to conduct financial
States Code, transactions affecting interstate and foreign commerce, namely, the
Section 1956(h) delivery of quantities of United States currency to third parties, which
transactions involved the proceeds of specified unlawful activity, namely
the felonious buying and selling and otherwise dealing in a controlled
substance, knowing that the transactions were designed in whole or in
part to conceal and disguise the nature, location, source, ownership, and
control of the proceeds of said specified unlawful activity, and that while
conducting and attempting to conduct such financial transactions,
Kmowing that the property involved in the financial transactions
represented the proceeds of some form of unlawful activity, in violation of
Title 18, United States Code, Section 1956(a)(1)(B)().
‘This criminal complaint is based upon these facts:
-X_ Continued on the attached sheet.
Jill N. Dennewitz
Special Agent,
Homeland Security Investigations (HSI)
Sworn to before me and signed in my presence.
22 ALM ta!
Date: February 9, 2015 }
Judge's signature
City and state: Chicago, Illinois Daniel G. Martin, U.S. Magistrate Ju
Printed name and TitleUNITED STATES DISTRICT COURT
8s
NORTHERN DISTRICT OF ILLINOIS.
AFFIDAVIT
I, dill N. Dennewitz, being duly sworn, state as follows:
1. Lam a Special Agent of the United States Department of Homeland
Security, Immigration and Customs Enforcement (“ICE”), Homeland Security
Investigations (‘HST’), and have been so employed since approximately May 2005. T
am currently assigned to the Homeland Security Investigations Office of the Special
Agent in Charge, Chicago, Illinois, and my responsibilities include the investigation
of money laundering and narcotics trafficking offenses. I am currently assigned to a
Public Safety Unit in which investigative efforts are focused on violent street gang
members committing various crimes including narcotics and firearms trafficking
and money laundering. I have worked on investigations targeting drug traflickers
and money launderers whose organizations are based in Mexico and who operate
throughout the United States. Prior to working in the Public Safety Unit, I was
assigned to a Narcotics Smuggling Group for six years. I have worked on numerous
investigations targeting drug traffickers and money launderers whose organizations
are based in Mexico, Central America, and South America, who operate throughout,
the United States. I have received training related to smuggling contraband,
including drugs, into the United States. This training included methods of
investigation related to international and domestic drug trafficking and money
laundering2. Tam the co-case agent on a joint HSI and Internal Revenue Service
investigation involving DIEGO PINEDA SANCHEZ, CARLOS PARRA-PEDROZA,
and others. As co-case agent, among other things, I have sworn out affidavits
supporting applications to intercept wire and electronic communications in this
investigation, have monitored wire and electronic communications pursuant to
court orders, have conducted surveillance as part of the investigation, and have
interviewed subjects.
3. This affidavit is submitted in support of a criminal complaint alleging
that DIEGO PIENDA SANCHEZ, CARLOS PARRA-PEDROZA, JOSE ABEL
MENDOZA-PARRA, MARIA LOERA ALVARADO, ERNESTO RUIZ-RAMIREZ,
MARIO HERRERA, ANTHONY LEIVA, TEODOCIO CARO, LUIS REYNA-
TELLEZ, HECTOR CHAVEZ CUEVAS, JUAN CARLOS NUNEZ GALVEZ, JOSE
SANANTONIO, PEDRO SAUCEDO-PALOMINOS, OMAR LOPEZ-CABRERA,
VIRGIL DURBIN, VALENTIN RODRIGUEZ, ALMA LORENA ORTIZ DE ROSAS
VERA, CASMIRO ISAIAS-PADILLA, EFREN MOTA, FELIX LEMUS-GUEVARA,
PEDRO URQUIZA-OSORIO, LUIS ARMANDO ACOSTA VIZCARRA, OSCAR
MONTES-LAMAS, JOEL ESTRADA, HARRANAH SAMORI, GABRIEL
SALCEDO, TOMAS SALGADO REYNA, OSCAR ACOSTA, FEDERICO
BARRERA-PEREZ, EMMANUEL DIAZ, JOSE HERNANDEZ OCHOA, and
ALFONSO NEVAREZ, have violated Title 18, United States Code, Section 1956(h)
(conspiring to commit concealment money laundering). Because this affidavit is
being submitted for the limited purpose of establishing probable cause in support ofa criminal complaint charging these individuals with money laundering, I have not
included each and every fact known to me concerning this investigation. I have set
forth only the facts that I believe are necessary to establish probable cause to
believe that the defendant committed the offense alleged in the complaint.
4, This affidavit is based on: (a) my personal participation in this
investigation; (b) information provided by other federal, state, and local law
enforcement officers; (c) surveillance conducted by HSI agents and other law
enforcement officers; (d) analyses of toll records, pen register and trap and trace
data, and subscriber information; (e) information derived from consensually-
recorded telephone conversations and Blackberry Messenger Messages (“BBMs”);
( review of conversations intercepted pursuant to court orders; (g) emails obtained
through the execution of court-authorized search warrants; (h) Federal Express
records; (i) my training and experience and the training and experience of other law
enforcement agents with whom I have spoken; (j) laboratory analysis reports;
(&) commercial database records; (1) criminal history records maintained by the
Illinois State Police (“ISP”) and the National Crime Information Center (“NCIC”);
(m) records of the Illinois Secretary of State (“SOS”); and (n) information provided
by cooperating sources and other individuals.
BACKGROUND OF THE INVESTIGATION
5. This complaint is based on an investigation conducted by HSI and IRS
into money laundering and related criminal activities involving DIEGO PINEDA
SANCHEZ, CARLOS PARRA-PEDROZA, and others.6. The information supporting probable cause set forth below includes:
a. Information derived from consensually-recorded telephone
conversations between a confidential source (‘CI-2”) and DIEGO PINEDA
SANCHEZ, CARLOS PARRA-PEDROZA, and their co-conspirators;
b. Information derived from consensually captured! BBM
exchanges between CI-2 and CARLOS PARRA-PEDROZA, JOSE ABEL
MENDOZA-PARRA (“ABEL”) and other co-conspirators;
c. Information derived from court-authorized interceptions of BBM
exchanges over Blackberry devices, including (i) the Blackberry model RIM8520
mobile device used by PINEDA SANCHEZ and permanently assigned Blackberry
PIN 233D184B (“Target Device 6”); (ii) the Blackberry model RIM8520 mobile
device used by PINEDA-SANCHEZ and permanently assigned Blackberry PIN
26F13A1B (“Target Device 7”); and (iii) the Blackberry model STL100-3/Z10 mobile
device used by MARIA LOERA ALVARADO (a/k/a “Samys@m”) and permanently
assigned Blackberry PIN 2AC18671 (“Target Device 9”);?
e. Law enforcement’s controlled collection and seizure of over $4.5
million in narcotics proceeds from multiple individuals, as directed by PINEDA
SANCHEZ, PARRA-PEDROZA, ABEL, and others;
1 Agents furnished CI-2 with a Blackberry device and Blackberry PIN for exclusive
use in this investigation. Agents consensually captured BBM messages that Cl-2 sent and
received over that device by video recording the messages after they were exchanged.
2 ‘The BBM summaries in this Affidavit that include a “Session” number refer to
BBMs that were intercepted pursuant to one of the above-referenced court orders.a. Narcotics seizures by law enforcement, including, among others,
the seizure of (i) approximately 33 kilograms of cocaine on or about September 30,
2011; (i) approximately 325 pounds of marijuana on September 12, 2013; and
(ii) approximately 8.3 kilograms of cocaine on February 24, 2014.
ROLES OF THE DEFENDANTS
IL The Parra-Pedroza MLO
7. HSI is conducting an investigation of DIEGO PINEDA SANCHEZ,
CARLOS PARRA-PEDROZA,} and others involved in laundering over $100 million
in narcotics proceeds since at least August 2011. The investigation has revealed
that DIEGO PINEDA SANCHEZ and PARRA-PEDROZA are high-ranking and
Mexican-based members of this money laundering organization (“Parra-Pedroza
MLO”). Through this investigation, agents have learned that PINEDA SANCHEZ
is responsible for directing PARRA-PEDROZA to arrange for U.S.-based members of
the Parra-Pedroza MLO — including CI-2 — to collect narcotics proceeds from
multiple money couriers and drug traffickers; to use those proceeds to purchase
scrap and fine gold at jewelry stores and businesses located in the Chicagoland
area; and to ship the gold via FedEx to cash for gold companies, including a Florida-
based refinery (“Refinery A”) and a Los Angeles based jewelry store (“Refinery B”).
‘The investigation has further revealed that, after Refinery A received the gold from
7 On December 11, 2014, DIEGO PINEDA SANCHEZ and CARLOS PARRA-
PEDROZA were charged by indictment in the Northern District of [linois with multiple
counts of concealment money laundering, in violation of Title 18, United States Code,
Section 1956(a)(1)(B)(i), in Case No. 14 CR 533, ‘Those charges are related to the conduct
discussed herein,
athe U.S.-based members of the Parra-Pedroza MLO, the company sent payments for
that gold to PARRA-PEDROZA in Mexico.
8. PINEDA SANCHEZ negotiated agreements to launder narcotics
proceeds with numerous Mexican based drug traffickers and money launderers,
including Individual N, Individual I, Individual O, and Individual L.
9. PINEDA SANCHEZ, PARRA-PEDROZA, JOSE ABEL MENDOZA-
PARRA, MARIA LOERA ALVARADO, and others directed a confidential informant
(‘CI-2”), two undercover agents (“UCA-1” and “UCA-2”), Individual CC, Individual
DD, and others to collect narcotics proceeds for the purposes of laundering the
money from numerous individuals, including ERNESTO RUIZ-RAMIREZ, MARIO
HERRERA, ANTHONY LEIVA, TEODOCIO CARO, LUIS REYNA-TELLEZ,
HECTOR CHAVEZ CUEVAS, JUAN CARLOS NUNEZ GALVEZ, JOSE
SANANTONIO, PEDRO SAUCEDO-PALOMINOS, OMAR LOPEZ-CABRERA,
VIRGIL DURBIN, VALENTIN RODRIGUEZ, ALMA LORENA ORTIZ DE ROSAS
VERA, CASMIRO ISAIAS-PADILLA, EFREN MOTA, FELIX LEMUS.GUEVARA,
PEDRO URQUIZA-OSORIO, LUIS ARMANDO ACOSTA VIZCARRA, OSCAR
MONTES-LAMAS, JOEL ESTRADA, HARRANAH SAMORI, GABRIEL
SALCEDO, TOMAS SALGADO REYNA, OSCAR ACOSTA, FEDERICO
BARRERA-PEREZ, EMMANUEL DIAZ, JOSE HERNANDEZ OCHOA, and
ALFONSO NEVAREZ.
10. Between on or about August 2011 and September 2014, the Parra-
Pedroza MLO laundered, or attempted to launder, over $100 million in narcoticsproceeds through the purchase of gold and transmission of money from the United
States to Mexico.
Il. The Defendants
11. The following is a brief summary of the roles played by the defendants:
a. DIEGO PINEDA SANCHEZ (a/k/a “Botas’; “Boots”). PINEDA
SANCHEZ is a Mexican-based money launderer and a leader of the Parra-Pedroza
MLO, Among other things, PINEDA SANCHEZ negotiated agreements with
Mexican cartel members and drug traffickers to launder narcotics proceeds from
various locations in the United States to Mexico (see {¥ 76(q)-(), 90-105, 205-33,
352-405, 458-526); arranged for co-conspirators to collect and deliver proceeds from
the sale of narcotics to CI-2 (see {§ 37-49, 90-105, 205-33, 244-54, 278-89, 322-33,
353-405, 458-526); directed CI-2 to collect narcotics proceeds from money couriers,
to use that money to purchase gold, and to mail that gold to Refinery A, which in
turn would transmit payment for the gold to MLO members in Mexico (see {4 17,
106-16); and directed CI-2 to obtain a new cellular telephone because Mexican drug
traffickers were concerned about CI-2’s connection to a recent seizure of narcotics
proceeds by law enforcement (see J] 353-60).
b. CARLOS PARRA-PEDROZA (a/k/a “Willy,” “Walt Disney,”
“Walter,” “Don Walt,” “Ary”). PARRA-PEDROZA is a Mexican-based money
launderer and another leader of the Parra-Pedroza MLO. Among other things, after
PINEDA SANCHEZ and others negotiated money laundering contracts with
Mexican cartel members and drug traffickers, PARRA-PEDROZA arranged forU.S.-based members of the Parra-Pedroza MLO to deliver narcotics proceeds to CI-
2, UCA-1, and other U.S.-based members of the Parra-Pedroza MLO (see passim);
directed CI-2 and other U.S.-based members of the Parra-Pedroza MLO to collect
narcotics proceeds, to use that money to purchase gold, and to mail that gold to
Refinery A (see passim); negotiated with Refinery A and CI-2 to set prices for gold
purchased with narcotics proceeds (see passim); directed Refinery A to transmit
payment for the gold to himself and other MLO members in Mexico (see {{ 41,
75(c)-(), 104, 352); provided CI-2 and other U.S.-based members of the Parra-
Pedroza MLO code names in order to communicate with each other (see passim);
provided prepaid and preaddressed shipping labels to CI-2 and UCA-1 for purposes
of shipping gold (see {¥ 18, 33-34, 101-02, 115, 129); directed CI-2 and UCA-1 to
wire transfer narcotics proceeds to designated bank accounts (see {{{ 406-25, 436-48,
458-85, 517-26, 550-62); and recruited CI-2 and others to join the Parra-Pedroza
MLO (see {fj 13, 15-16).
ce. JOSE ABEL MENDOZA-PARRA (‘ABEL’). ABEL is a Mexican-
based money launderer. Among other things, after PINEDA SANCHEZ and others
negotiated money laundering contracts with Mexican cartel members and drug
traffickers, ABEL arranged for U.S.-based members of the Parra-Pedroza MLO to
deliver narcotics proceeds to Cl-2 and UCA-1 (see {4 183-310); directed CI-2 to
collect narcotics proceeds, to use that money to purchase gold, and to mail that gold
to Refinery A (see 4 133-310); negotiated with Refinery A and CI-2 to set prices for
gold purchased with narcotics proceeds (see ¥ 167, 180, 192, 203-02, 254, 264);provided prepaid and preaddressed shipping labels to CI-2 and UCA-1 for purposes
of shipping gold (see {4 139-40, 274-75); and provided CI-2 and other U.S.-based
members of the Parra-Pedroza MLO code names in order to communicate with each
other (see {If] 168, 194, 206, 220, 234, 244, 255, 267, 278).
d. MARIA LOERA ALVARADO (a/k/a “Samys@m"). LOERA
ALVARADO is a Mexico-based supervisor of the Parra-Pedroza MLO. LOERA
ALVARADO, among other things, worked with PINEDA SANCHEZ, and directed
others, to coordinate the collection and laundering of $132,000 in narcotics proceeds
from EFREN MOTA on August 5, 2014. See 486-516. In addition, LOERA
ALVARADO arranged for three separate deliveries of a total of approximately
$170,000 to three different individuals in Los Angeles — namely, approximately
$90,000 and $30,000 on May 2, 2014, and approximately $53,700 on August 18,
2014 ~ all of which was subsequently seized by law enforcement.
e. ERNESTO RUIZ-RAMIREZ. RUIZ delivered narcotics proceeds
to Cl-2 on two occasions for purposes of concealing the nature, location, source,
ownership, and control of the money, namely approximately $50,020 on December
10, 2013 (see 244-54), and $107,280 on January 17, 2014 (see 4] 290-310). In
addition, RUIZ arranged for JOSE SANANTONIO to deliver approximately
$100,000 to UCA-1 on August 26, 2014, and to store approximately $122,000 on thesame day, all for purposes of concealing the nature, location, source, ownership, and
control of the money. See {{ 538-49.4
f. MARIO HERRERA. HERRERA delivered approximately
$100,220 in narcotics proceeds to CI-2 on September 13, 2018 (see 157-67), and
attempted with PEDRO SAUCEDO-PALOMINOS to deliver approximately
$173,133 in narcotics proceeds to CI-2 on November 7, 2013 (see {{f 234-43), all for
purposes of concealing the nature, location, source, ownership, and control of the
money.
g. ANTHONY LEIVA. LEIVA attempted to deliver approximately
$290,704 in narcotics proceeds to CI-2 on September 11, 2013, for purposes of
concealing the nature, location, source, ownership, and control of the money. See
41 133-56.
h. TEODOCIO CARO. CARO arranged for Individual Q to deliver
approximately $98,999 in narcotics proceeds to CI-2 on June 11, 2013 (see 1 60-74),
and personally delivered approximately $283,740 in narcotics proceeds to CI-2 on
June 25, 2013 (see {{ 78-89), all for purposes of concealing the nature, location,
source, ownership, and control of the money.
i, LUIS REYNA-TELLEZ. REYNA-TELLEZ — delivered
approximately $143,980 in narcotics proceeds to UCA-1 on July 25, 2014 (see
+ Contemporaneous with the filing of this affidavit, the government has also filed an
affidavit in support of a criminal complaint alleging that ERNESTO RUIZ and SAMUEL
MATA conspired with each other and others to possess with the intent to distribute and
distribute approximately 8.3 kilograms of cocaine. Law enforcement seized this cocaine on
or about February 24, 2014, from an individual who was transporting the cocaine on behalf
of RUIZ and MATA.
10‘I 458-85), and attempted to deliver to UCA-1 approximately $210,960 in narcotics
proceeds on August 14, 2014 (see 4] 527-37), all for purposes of concealing the
nature, location, source, ownership, and control of the money.
j. HECTOR CHAVEZ CUEVAS. CUEVAS delivered
approximately $200,780 in narcotics proceeds to CI-2 on July 24, 2013, for purposes
of concealing the nature, location, source, ownership, and control of the money. See
49 117-32.
k. JUAN CARLOS NUNEZ GALVEZ. NUNEZ GALVEZ delivered
narcoties proceeds to CI-2 and UCA-1 on two occasions for purposes of concealing
the nature, location, source, ownership, and control of the money, namely
approximately $20,000 on December 12, 2013 (see fj 255-66), and approximately
$62,350 on July 16, 2014 (see {1 436-48). In addition, NUNEZ GALVEZ attempted
to deliver at least $100,000 in narcoties proceeds to UCA-1 on July 23, 2014. See
¥4 449-57.
1, JOSE SANANTONIO. SANANTONIO attempted to deliver
approximately $100,000 to UCA-1 on August 26, 2014, and intended to deliver
approximately $122,000 to another individual, as directed by RUIZ, all for purposes
of concealing the nature, location, source, ownership, and control of the money. See
49 538-51.
m. PEDRO SAUCEDO-PALOMINOS. SAUCEDO arranged for
FELIX LEMUS-GUEVARA to deliver approximately $120,000 in narcotics proceeds
to CI-2 on September 27, 2013 (see {{ 181-92), and attempted with MARIO
aiHERRERA to deliver approximately $173,133 in narcotics proceeds to CI-2 on
November 7, 2018, for purposes of concealing the nature, location, source,
ownership, and control of the money. See {{f 234-43.
n, OMAR LOPEZ-CABRERA. LOPEZ-CABRERA delivered
approximately $150,000 in narcotics proceeds to CI-2 on January 22, 2014, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See 311-21.
o. VIRGIL DURBIN. DURBIN delivered approximately $140,000
in narcotics proceeds to UCA-1 on August 28, 2014, for purposes of concealing the
nature, location, source, ownership, and control of the money. See {| 551-63.
p. VALENTIN RODRIGUEZ. RODRIGUEZ delivered narcotics
proceeds to CI-2 on two occasions for purposes of concealing the nature, location,
source, ownership, and control of the money, namely approximately $110,000 on
June 5, 2018 (see {| 37-49), and $30,010 on June 10, 2013 (see 'f 50-59).
4. ALMA LORENA ORTIZ DE ROSAS VERA. ORTIZ delivered
approximately $80,000 in narcotics proceeds to UCA-1 on June 25, 2014 (see ff 412-
25), and attempted to deliver another approximately $59,452 in narcotics proceeds
to UCA-1 later the same day (see {| 426-35), all for purposes of concealing the
nature, location, source, ownership, and control of the money.
r. CASMIRO ISAIAS-PADILLA. ISAIAS delivered approximately
$139,470 in narcotics proceeds to CI-2 on July 10, 2013, for purposes of concealing
the nature, location, source, ownership, and control of the money. See {{ 90-105.
12EFREN MOTA. MOTA delivered approximately $132,000 in
narcotics proceeds to an undercover agent (“UCA-2”) on August 5, 2014, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See {| 486-516.
t. FELIX LEMUS-GUEVARA. GUEVARA delivered
approximately $120,000 in narcotics proceeds to CI-2 on September 27, 2013, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See {{] 181-92.
u. PEDRO URQUIZA-OSORIO. URQUIZA-OSORIO delivered
approximately $50,000 in narcotics proceeds to CI-2 on September 20, 2013, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See {{ 168-80.
vy. LUIS ARMANDO ACOSTA VIZCARRA. VIZCARRA delivered
approximately $89,980 in narcotics proceeds to CI-2 on October 11, 2013, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See {| 193-204.
w. OSCAR MONTES-LAMAS. MONTES-LAMAS delivered
approximately $66,990 in narcotics proceeds to CI-2 on January 14, 2014, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See {|{| 278-89.
13x. JOEL ESTRADA. ESTRADA delivered approximately $62,000
in narcotics proceeds to Cl-2 on January 13, 2013, for purposes of concealing the
nature, location, source, ownership, and control of the money. See §{] 267-77.
y. HARRANAH SAMORI. SAMORI delivered approximately
$59,960 in narcoties proceeds to CI-2 on February 27, 2014, for purposes of
concealing the nature, location, source, ownership, and control of the money. See
14 334-49.
z GABRIEL SALCEDO. SALCEDO attempted to deliver
approximately $110,000 in nareotics proceeds to CI-2 on January 22, 2018, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See §{ 311-14, 322-33.
aa. TOMAS SALGADO REYNA. SALGADO attempted to deliver
approximately $100,075 in narcotics proceeds to CI-2 on October 24, 2013, for
purposes of concealing the nature, location, source, ownership, and control of the
money. See { 205-33.
bb. OSCAR ACOSTA. ACOSTA delivered approximately $100,020
in narcotics proceeds to CI-2 on March 31, 2013, for purposes of concealing the
nature, location, source, ownership, and control of the money. See {{/ 353-60, 387-
405.
cc, FEDERICO BARRERA-PEREZ. BARRERA-PEREZ delivered
approximately $100,000 in narcotics proceeds to UCA-1 on August 8, 2014, for
14purposes of concealing the nature, location, source, ownership, and control of the
money. See $4 517-26.
dd. EMMANUEL DIAZ. DIAZ delivered approximately $37,220 in
narcotics proceeds to CI-2 on March 27, 2013, for purposes of concealing the nature,
location, source, ownership, and control of the money. See {{ 353-75, 381-86.
ee. JOSE HERNANDEZ OCHOA. OCHOA delivered approximately
$29,990 in narcotics proceeds to CI-2 on July 16, 2013, for purposes of concealing
the nature, location, source, ownership, and control of the money. See 106-16.
ff. ALFONSO NEVAREZ. NEVAREZ delivered approximately
$10,280 in narcoties proceeds to CI-2 on March 26, 2014, for purposes of concealing
the nature, location, source, ownership, and control of the money. See {| 353-86.
BACKGROUND OF MONEY LAUNDERING AND DRUG TRAFFICKING
ORGANIZATIONS:
12. Through training, experience, law enforcement training publications
about money laundering methods, and from my conversations with confidential
sources and other law enforcement officers who have expertise in such matters, I
am familiar with the methods by which drug traffickers utilize the purchase of gold
to launder drug proceeds. For example, I know that:
a. There are numerous money laundering and drug trafficking
organizations operating in the country of Mexico. Examples of some of these
organizations include the Sinaloa Cartel, La Familia Cartel, Knights Templar
Cartel, Juarez Cartel, the Gulf Cartel, and New Generations. As a general rule,
these Mexico-based organizations purchase South American processed cocainewhich is transshipped through Mexico and smuggled into the United States. These
organizations also grow, cultivate, cook and process heroin, methamphetamine, and
marijuana in Mexico and subsequently smuggle the controlled substances into the
United States for resale. The sale of these controlled substances generates
substantial cash proceeds for these drug and money laundering organizations,
which cash represents the cost of goods sold and illegal profits.
b. After the sale of controlled substances, the proceeds from the
sales must be collected, counted, packaged and delivered in some fashion to the
Mexican-based drug trafficking organizations (‘DTOs"). At times, these funds are
transported or transferred in one way or another to Mexico. This can occur through
a variety of techniques.
c. Typically, DTOs smuggle drug proceeds in bulk from the United
States to Mexico. However, because bulk smuggling is often considered more risky
due in part to seizures of drug proceeds at border areas, more sophisticated DTOs
rely on more complex money laundering schemes. Those schemes include trade
based money laundering mechanisms as well as trading in precious metals, such as
gold.
4. DTOs use different money laundering cells in the United States
to facilitate laundering their drug proceeds. These cells perform different
functions, including money pickup operations, bulk cash smuggling operations, and
operations involving the purchase of goods, such as gold.
16e. The basic money laundering process has three steps. The first
step occurs when the DTO arranges to deposit or drop off the drug proceeds in the
United States. At this stage, launderers sometimes insert the drug proceeds, or
“dirty money,” into a legitimate financial institution in the form of cash bank
deposits, This method, however, risks detection because depositing large amounts
of cash requires banks to report transactions to law enforcement. Therefore, some
money laundering schemes avoid using financial institutions.
£ One of the most common money laundering practices for DTOs
that wish to avoid depositing into a financial institution is to direct drug traffickers
and money couriers to deliver drug proceeds to money launderers in what is
referred to as a “money pickup.” In a typical money pickup, the DTO-associated
broker arranges for a U.S.-based co-conspirator to meet an individual in possession
of a large quantity of narcotics proceeds. To arrange the meeting, the money
broker typically provides the U.S.-based conspirator a telephone number to call,
and a code phrase to say to the individual who answers the telephone call. The
code phrase is a means for those who are exchanging the narcotics proceeds to
confirm that both parties are executing a previously agreed upon money contract
between the money broker and the DTO.
g. The second step in the process is referred to as layering. For
those DTOs who use the formal banking system, they send the drug proceeds
through various financial transactions to change the form of the money in order to
make it difficult to trace its origin. Layering may consist of several bank-to-bank
17transfers, wire transfers between different accounts in different names in different
countries, and making deposits and withdrawals to continually vary the amount of
money in the accounts. For those DTOs that avoid the formal banking system,
layering involves changing the form of the currency of the drug proceeds by using
the currency to purchase high-value items, such as gold and diamonds.
h. The final step is the integration stage, when the now-laundered
money re-enters the mainstream economy and appears as though it originated
from a legal transaction, such as the purchase or importation of gold. This step
may involve a final bank transfer into the account of a business in which the
launderer “invests” the profits from the sale of gold bought during the layering
stage or the purchase of an overvalued item from a company owned by the
Jaunderer.
i, Further, I know that the use of trade-based money laundering
has become increasingly popular with DTOs due in part to the new restrictions
introduced in 2010 by the Mexican government to limit the use of U.S. dollars in
the country.
i Finally, I also know that members of DTOs employ various
trade-based laundering techniques to transport drug proceeds gained in the United
States across the border to Mexico. For example, DTOs have executed wire
transfers to Mexico-based companies that are disguised as payment for importing
commodities, such as gold, but that are actually drug proceeds. Some DTOs prefer
to purchase commodities, such as textiles, toys, or scrap gold in the United States
18with U.S. dollars derived from drug sales, and then either export the commodities
into Mexico to resell them for Mexican pesos, or, sell scrap gold in the United
States to companies that import gold from Mexico. This form of trade-based money
laundering explains the inconsistency between the amount of imported gold and
the money wired from the United States to the Mexico-based gold export
companies.
FACTS SUPPORTING PROBABLE CAUSE
1 CI-2’s Cooperation with Law Enforcement and Information about the
Parra-Pedroza MLO
13. On April 26, 2013, agents approached a member of the Parra-Pedroza
MLO (who subsequently became a cooperating informant, hereinafter “CI-2”) and
informed this individual that he/she was the target of a money laundering
investigation. CI-2 thereafter provided agents with detailed information admitting
his/her involvement in the Parra-Pedroza MLO.‘ According to CI-2:
a. CL-2 had laundered narcotics proceeds for a man named
“DIEGO” (who, as discussed below, was subsequently identified as PINEDA
SANCHEZ), PARRA-PEDROZA, and other members of the Parra-Pedroza MLO
between approximately August 2011 and October 2012. PARRA-PEDROZA owns
5 CI-2 has agreed to cooperate with law enforcement in an effort to receive
consideration in charging and sentencing decisions that will be made in connection with CI-
2s case. CI-2 has been advised that he/she will be charged for his/her criminal conduct in
this case. To date, HSI has paid CI-2 approximately $50,000 to cover living expenses while
he/she is working at the direction of law enforcement. The information provided by CI-2
has been independently corroborated by physical surveillance, wire communications
intercepted pursuant to court order, and consensual recordings made by CI-2 after he/she
began cooperating.
19the Mexico based jewelry store De Mexico British Metal, and is a member of the
Sinaloa Cartel.
b. At PARRA-PEDROZA’s direction, CI-2 received narcotics
proceeds ranging from $20,000 to $1.2 million from various narcotics traffickers and
money couriers, used the proceeds to purchase scrap gold, and then shipped the
scrap gold via FedEx to Refinery A. On several occasions, individuals from whom
CI-2 collected large cash proceeds advised Cl-2 that the money was proceeds of
narcotics transactions. CI-2 was typically paid one to two percent of the amount
laundered or delivered in exchange for assisting drug traffickers with laundering
drug proceeds.
c. Beginning in August 2011 and continuing to October 2012, CI-2
obtained millions of dollars of drug proceeds from drug traffickers and money
couriers in Illinois, Indiana, Ohio, Kentucky, Georgia, and North Carolina at
PARRA-PEDROZaA’s direction.
d. Prior to obtaining drug proceeds from drug traffickers and
money couriers, CI-2 typically received a BBM from PARRA-PEDROZA, advising
CI-2 how much money he/she was to collect. CI-2 would then receive phone calls
from various unidentified drug traffickers and money couriers who used different
cellular telephone numbers. The unidentified drug traffickers and money couriers
would then arrange to meet CI-2 at a specific time and location so that CI-2 could
obtain the drug proceeds to launder. Once CI-2 picked up and counted the drug
proceeds, CI-2 contacted PARRA-PEDROZA with a final count of the money. CI-2
20and others then used the narcotics proceeds to purchase scrap gold, and CI-2
shipped the gold to Refinery A using pre-addressed shipping labels that PARRA-
PEDROZA provided via e-mail. PARRA-PEDROZA directed CI-2 and others to ship
that gold to Refinery A under fictitious company names, including “Shopping Silver”
and “Shopping S,” and many of the pre-addressed shipping labels that PARRA-
PEDROZA provided listed Shopping Silver as the shipper.§
e. In 2012, PINEDA SANCHEZ and PARRA-PEDROZA traveled
from Mexico to Chicago, by way of Los Angeles, California to meet with CI-2.
PARRA-PEDROZA introduced PINEDA SANCHEZ to CI-2 as “Diego” and said that
PINEDA SANCHEZ was his “partner.” During this meeting PINEDA SANCHEZ
and PARRA-PEDROZA inspected the store front where CI-2 met with money
couriers and collected narcotics proceeds prior to purchasing gold. During this,
visit, PINEDA SANCHEZ and PARRA-PEDROZA (a) complained that CI-2 was
always losing money; (2) asked CI-2 to use the narcotics proceeds to buy fine gold
instead of scrap (CI-2 advised them he could not); (3) asked CI-2 to refine the gold
himself (CI-2 advised them it was too difficult); and (4) instructed CI-2 to keep a
sample of the gold that CI-2 sent to Refinery A and to get someone independent to
test it to see if Refinery A was cheating them in its valuation of the gold.
® Prior to his/her cooperation, agents observed CI-2 drop off numerous packages at
Fed Ex stores, addressed to Refinery A from, among other names, Shopping Silver.
According to Fed Ex records, an individual named “Rodolfo Lopez” (which CI-2 advised was
an alias used by CI-2 and his/her associates) shipped approximately 707 boxes to Refinery
A between August 2011 and October 2012 (prior to his/her cooperation), almost always
identifying the shipping company as “Shopping S.”
21f. During their visit in Spring 2012, PINEDA SANCHEZ told
PARRA-PEDROZA that they had $1 million in drug proceeds in Atlanta that were
ready to be laundered. PINEDA SANCHEZ and PARRA-PEDROZA also discussed
giving CI-2 $500,000 to launder in Chicago through the purchase of scrap gold, and
another $500,000 for an individual in Los Angeles to launder in the same manner.
PINEDA SANCHEZ and PARRA-PEDROZA made and took several calls during
their visit in which they discussed moving money from one place to another.
g. Sometime during the summer of 2012, at PARRA-PEDROZA’s
direction, CT-2 collected a bag filled with drug proceeds from an unknown narcotics
trafficker. As CI-2 began counting the money in the bag, he/she observed that the
bag also contained one plastic bag filled with a white powdery substance that
appeared to be cocaine. CI-2 refused to transport the substance that he/she believed
to be cocaine, and gave the plastic bag back to the unknown drug trafficker. CI-2
also identified Herasmo Herrera as a man who had previously delivered narcotics
proceeds to CI-2, and stated that Herasmo Herrera met with CI-2 only when
Individual Y had narcotics proceeds to deliver.”
7 Onor about September 29, 2011 — prior to CI-2's cooperation with law enforcement —
surveillance observed CI-2 meet with Herasmo Herrera at the location where Cl-2 used to
meet with couriers to collect narcotics proceeds. Following this meeting, law enforcement
performed a traffic stop of Herasmo Herrera, and in the course of this stop, discovered
approximately four kilograms of cocaine in the vehicle. Law enforcement subsequently
obtained a state search warrant to search Herasmo Herrera’s residence, and in the course
of that search, found approximately 24 kilograms of cocaine. Law enforcement also found a
ledger documenting an inventory of approximately 51 kilograms of cocaine, of which
approximately 20 kilograms had previously been sold. Herasmo Herrera was subsequently
charged and convicted in the Circuit Court of DuPage County, Ilinois, of the
manufacture/delivery of cocaine, and sentenced to 16 years’ imprisonment.
22h. Between approximately August 2011 and October 2012, CI-2
laundered approximately $28 million in narcotics proceeds through the purchase
and shipment of scrap gold, all at the direction of PARRA-PEDROZA and his
associates. CI-2 stopped working for PINEDA SANCHEZ and PARRA-PEDROZA
in October 2012.
14. Soon after he began cooperating with law enforcement, Cl-2 resumed
working for PINEDA SANCHEZ and PARRA-PEDROZA at the direction of agents.
Since the beginning of CI-2's cooperation in April 2013, and at HSI’s direction, CI-2
has obtained, or arranged to obtain, drug proceeds from thirty-eight different money
couriers on forty-eight separate occasions for the purpose of laundering the proceeds
in an undercover operation. Prior to receiving drug proceeds from the drug
traffickers and money couriers, PARRA-PEDROZA or one of his associates
contacted CI-2 using a combination of voice calls, BBMs, and e-mail messages to
arrange for CI-2 to pick up the proceeds, purchase gold, and ship the gold via FedEx
to Refinery A. Intercepted electronic communications show that PINEDA
SANCHEZ instructed PARRA-PEDROZA to arrange for several of those money-
pick-ups conducted by CI-2. Unless otherwise indicated, the BBMs between CI-2
and others were viewed by agents with CI-2’s consent.
23Il. PARRA-PEDROZA Asks CI-2 to Resume Laundering Narcotics
Proceeds (May 2013).
15. On or about May 16, 2013, CI-2 had a consensually recorded telephone
call with PARRA-PEDROZA,* who was using telephone number (508) 545-3027
(‘Parra-Pedroza Phone 1”).9 According to CI-2, PARRA-PEDROZA and CI-2 had not
* __ Agents identified PARRA-PEDROZA and PARRA-PEDROZA's voice, and identified
PARRA-PEDROZA as the user of a Blackberry device assigned BBM PIN: 26249D82 (‘MLO
Device 1") and Parra-Pedroza Phones 1 through 12, as follows: On or about June 3, 2013,
CL-2 had a consensually recorded call with a man whose voice he identified as PARRA-
PEDROZA based on numerous prior interactions. During this call, CI-2 gave PARRA-
PEDROZA his/her Blackberry PIN so that PARRA-PEDROZA could contact CI-2 on CI-2's
Blackberry device. CI-2's Blackberry device and PIN were furnished by agents for exclusive
use in this investigation. According to CI-2, PARRA-PEDROZA is the only person to whom
CI-2 has given his Blackberry PIN. PARRA-PEDROZA told CI-2 during this June 3 call
that he had sent an invitation to CI-2’s Blackberry device that would allow the two
individuals to communicate with each other over BBMs. After this call, CI-2 received a
BBM invitation from MLO Device 1 and CI-2 began communicating with PARRA-
PEDROZA over that device until September 6, 2013. In addition, between June 14, 2013,
and June 19, 2018, CI-2 exchanged numerous BBMs with the user of MLO Device 1
During these conversations, the individual using MLO Device 1, whom agents and CI-2
believed to be PARRA-PEDROZA, arranged to meet CI-2 in person in Las Vegas, Nevada,
on Thursday, June 20, 2013, for the purpose of discussing CI-2's efforts in furtherance of
the Parra-Pedroza MLO. On or about June 20, 2013, CI-2 exchanged a series of messages
with PARRA-PEDROZA, who was using MLO Device 1. This exchange was not recorded,
but it was made in the presence of law enforcement. During this exchange, CI-2 and the
individual using MLO Device 1 arranged to meet later that day at the Las Vegas Premium
Outlets mall located at 875 South Grand Central Parkway in Las Vegas, Nevada. Agents
conducting surveillance subsequently observed Cl-2 meet with a man and a woman at that
outlet mall at the designated time. Agents who observed this meeting reviewed a
photograph of “Carlos Parra-Pedroza” obtained from a from a Law Enforcement Database,
and positively identified PARRA-PEDROZA as the man CI-2 met with at the Las Vegas
Premium Outlets and as the user of MLO Device 1. In addition, based on prior in-person
meetings that occurred prior to CI-2's cooperation with law enforcement, CI-2 identified the
man whom he met on June 20 as PARRA-PEDROZA. Prior to the June 20 meeting, agents
outfitted Cl-2 with a concealed audio recording device. Agents have compared the audio
recording of PARRA-PEDROZA’s voice from this June 20, 2013, meeting (and from a
subsequent meeting on March 13, 2014) to the recording of the voice of the man using
Parra-Pedroza Phones 1 through 12 and, based on that comparison, concluded that PARRA.
PEDROZA is the user of Parra-Pedroza Phones 1 through 12.
e Some of the consensually recorded conversations (hereinafter "recorded
conversations") have been summarized in this Affidavit. The language that is quoted from
the recorded conversations throughout this Affidavit is based upon a preliminary review of
24spoken since October 2012, when CI-2 had stopped working for PARRA-PEDROZA.
During this call:
a. PARRA-PEDROZA stated, “What a miracle!” CI-2 stated, “Well,
you get lost.” PARRA-PEDROZA teplied, “No way, well, you turned both phones off
{CI-2 disconnected two phones that PARRA-PEDROZA had previously used to
contact CI-2].” CI-2 stated, “Well, yeah, when I went to go get them connected.
They didn't want to connect them, man. I mean the same number. . .. I don’t know
how to call you anymore.”
b. PARRA-PEDROZA stated, “Yeah, no, man, we [PINEDA
SANCHEZ and PARRA-PEDROZA] are already here. What’s up? What is there to
do?” CI-2 responded, “No, well, we are ready [to collect and launder narcotics
proceeds for the Parra-Pedroza MLO}. Is there something to do or not?” PARRA-
PEDROZA stated, “Fuck! They are working my ass off... . They [PINEDA-
SANCHEZ, money laundering associates, and narcotics traffickers] call me daily to
see if it's [money laundering] going to happen, if it’s going to happen, if it's going to
happen.”
the recorded conversations, and not on final transcripts of the recorded conversations. The
times listed for the recorded conversations are approximate. The summaries do not include
all statements or topies covered during the course of the recorded conversations. At various
points in the Affidavit I have included in brackets my interpretation of words and phrases
used in the recorded conversations. My interpretations are based on information received
from CI-2, the contents and context of the recorded conversations, events occurring before
and after the conversations, my knowledge of the investigation as a whole, my experience
and training, and the experience and training of other law enforcement agents in this
investigation. Some of the recorded conversations contained herein are in the Spanish
language. For these conversations, I have relied on draft not final ~ English translations
of conversations in Spanish done by HSI agents and/or interpreters contracted by HSI.
25c. Cl-2 stated, “How are you going to do it? Ihave a guy that, that
just has the fine one [gold].” PARRA-PEDROZA responded, “Oh! Those are good.”
CE-2 stated, “Okay, but he also wants his cut.” PARRA-PEDROZA asked, “How
much?” CI-2 responded, “Well, he also wants two [percent].” PARRA-PEDROZA
asked, “Two?... Wow.” CI-2 stated, “But he guarantees that he will get me the
fine stuff [fine gold, 24 karat], the fine stuff.” PARRA-PEDROZA stated, “Well, um,
but it’s [a two percent fee is] a lot, man... The thing is that it is a lot.”
4. CE-2 asked, “What is the most that you would give me for the
fine stuff [fine gold]?... Getting you just fine stuff. The thing is, look, with the
thing with the pieces [scrap gold], it won't come out if it’s dirty [scrap gold has
impurities that diminish the value to refiners, like Refinery A]. It's the truth, it’s
the truth, it's the truth.” PARRA-PEDROZA responded, “Yeah, no, it's, it’s fucked
up that way. But, well.... How much, how much you are going to buy the fine on?
At what price?” CI-2 responded, “At spot [current market value of gold].”
PARRA-PEDROZA stated, “Spot. The thing is there, we are putting one percent
there [Refinery A takes a one percent fee]. ... In other words, you are selling it to
me at three percent over [the current market value] because the refinery [Refinery
A] buys it from me at one under [under the current market value].” CI-2 stated,
“{HJow much would be the most? So I can talk to him [CI-2's putative gold supplier]
tomorrow.” PARRA-PEDROZA responded, “Well, offer him one [percent].”
e. Cl-2 stated, “Okay and what about me [CI-2's payment for
laundering money for the Parra-Pedroza MLO]?” PARRA-PEDROZA asked, “Well,
26what about another one [percent]?” . .. It's [gold purchased with narcotics proceeds
is] going to be all fine stuff?” CI-2 responded, “It’s not going to be enough. It’s not
going to be enough. One and one is not enough.” PARRA-PEDROZA asked, “How
much do you want? One and one is two [percent]. How much, how much does it
come out to?... How much, how much, how much or, or just two [percent], and just
offer him one [percent]. You are going to come out clean, You are not going to, you
are not going to do anything [CI-2 will no longer have to go store-to-store to
purchase scrap gold.” CI-2 stated, “Well, no, but I also have to make some moves
[CI-2 will have to collect narcotics proceeds from drug traffickers and money
couriers].” PARRA-PEDROZA said, “So then put two [percent for CI-2] and one for
him [CI-2's putative gold supplier]. My total is going to be four [percent in fees]
because the refinery [Refinery A] takes one from me.”
f£ CI-2 stated, “Okay, okay, and then there’s something else. How
should we do it with the cousins (drug traffickers and money couriers who deliver
narcotics proceeds to CI-2]?... Uh, the problem is the cousins. How should we do
it?” PARRA-PEDROZA asked, “Why? You can't receive them [eollect narcotics
proceeds from them]? ... I think that we are going to have to find a way. In other
words, for you to see them today in, I don't know, at a place.” CI-2 stated, “Well, the
problem, I could pick them [narcotics proceeds] up on the street. The problem is
that they won't turn out exact [drug traffickers and money couriers may deliver less
money than promised if CI-2 collects the narcotics proceeds in public spaces because
C1-2 would not have any way to count the money before the drug traffickers and
27money couriers leave]. That is the problem.” PARRA-PEDROZA stated, “No, but
they are just going to be, they are just going to be, they are just going to be small
ones [small amounts of narcotics proceeds}. Alright, they are going to be all fifty
[deliveries of $50,000] more or less. I think we are going to start with fifty, fifty,
fifty, and fifty. Then, um, I will try to find a way to, to, to take care of that thing
somehow.”
g. CL-2 stated, “So, that’s the problem. Then, just, they can give it
[narcotics proceeds] to me later and they say they will give me fifty pesos [$50,000]
and they only end up giving me forty-nine [$49,000].”. PARRA-PEDROZA stated,
“Yeah, uh, um, what are we going to do? What are we going to do? Alright, .. .
well, let me, let me see how I, I organize that so that it’s also one day you see them
here, one day you see them over there, and another day you will see them
somewhere else.”
h CI-2 stated, “The other thing, the other thing is uh, well, I need
an advance to, to open up the office [money to set up a place where CI-2 can collect
the narcotics proceeds}. About ten [$10,000], fifteen pesos [$15,000]. Well, I would
need to get the place first, a week or two weeks, while I look for the place. I'll look
for the place in a week or two weeks. And then I would need to provide the deposit
for the house, the deposit a month’s rent, a month for the deposit, and buy stuff to
measure [money counter], and buy all the shit. Otherwise, how am I going to work
right now?” PARRA-PEDROZA stated,
‘eah, well, not even that, you know,
because it’s [the narcotics proceeds delivered] almost going to be for fifty [850,000].”
28i. Cl-2 stated, “
No, it’s not going to be enough [CI-2 wants to
receive more than $50,000 in narcotics proceeds at a time].”. PARRA-PEDROZA
laughed and stated, “No, but they [narcotics traffickers in Mexico] don’t want to give
any more [than $50,000 in narcotics proceeds at a time]. The thing is, they will give
me whatever I want. But I have to pay them here right, right before they arrive
here with you [PARRA-PEDROZA will have to give Mexican drug traffickers their
narcotics proceeds before CI-2 even receives the money]... . So fifty [$50,000] daily,
daily, daily. . They are going to open up [increase the amounts of narcotics
proceeds delivered] on their own. They will begin to trust [PARRA-PEDROZA and
CI-2] on their own. Later they are going to tell me, ‘Look, I'm going to bring you a
hundred [$100,000], man.’ On their own, I already know that.”
j. CL-2 stated, “ll go and get you the phone number for these guys
[drug traffickers] and to see if, if, if you send me that, ten [$10,000] or fifteen pesos
[$15,000] to get everything.” PARRA-PEDROZA stated, “Alright, that’s fine.” C1-2
stated, “And I won't start moving [picking up narcotics proceeds and buying gold]
until I get that [$10,000 to $15,000] because I don’t have anything to start moving
with.” PARRA-PEDROZA stated, “Alright.” CI-2 stated, “Call me on Saturday
either way, so I can tell you about this guy [CI-2's gold supplier]. We'll see what we
agree on with this, with this guy.... So then three [percent], three right? ... Two
and one [a two percent fee for CI-2 and a one percent fee for CI-2's gold supplier]?”
PARRA-PEDROZA stated, “Yeah, yeah. ... Two and one.” PARRA-PEDROZA and
CI-2 then agreed to talk again later.
2916. Based on subsequent consensually-recorded conversations between
PARRA-PEDROZA and CI-2, subsequent controlled collections of proceeds from
various individuals by CI-2 at the direction of PINEDA SANCHEZ and PARRA-
PEDROZA, my knowledge of this investigation as a whole, and my training and
experience as a Special Agent, I believe that, during the aforementioned
conversation, PARRA-PEDROZA (a) expressed surprise at hearing from CI-2
because it had been several months since the two had last spoken to each other;
(b) stated that he and PINEDA SANCHEZ continued to launder narcotics proceeds
for Mexican drug traffickers on a regular basis; (c) asked CI-2 to resume buying gold
for the Parra-Pedroza MLO with narcotics proceeds; (d) accepted CI-2’s proposal to
use the narcotics proceeds to purchase fine gold, rather than scrap; (e) advised that
Refinery A kept one percent of the current market value of the gold that members of
the Parra-Pedroza MLO shipped to the company on the PARRA-PEDROZaA’s behalf;
(® agreed to pay CI-2 and CI-2’s putative fine gold supplier two percent and one
percent, respectively, of the current market value of the fine gold for their work on
behalf of the Parra-Pedroza MLO; (g) discussed concerns about drug traffickers and
money couriers shorting CI-2 on their money deliveries if CI-2 was forced to collect
the money in a public place where CI-2 could not immediately count the money; and
(h) explained that CI-2 would begin with daily collections of $50,000 in narcotics
proceeds and that the amount of the collections would increase over time as the
drug traffickers began to trust CI-2.
30III. PINEDA SANCHEZ Calls CI-2 to Discuss the Money Laundering
Operation (May 23, 2013).
17. On or about May 23, 2013, at approximately 10:40 a.m., CI-2 received
a call from PINEDA SANCHEZ," who was using telephone number (508) 545-3022
(‘Pineda Sanchez Phone 1"), This call was not recorded, but it was verified by toll
records for CI-2's phone. According to CI-2, during this call:
© Agents identified PINEDA SANCHEZ and PINEDA SANCHEZ's voice, and
identified PINEDA SANCHEZ as the user of Target Devices 6 and 7 and Pineda Sanchez
Phone 1, as follows: According to CI-2, prior to his/her cooperation with law enforcement,
CI-2 met with an individual known to CI-2 as “Diego” in 2012, when PARRA-PEDROZA
and Diego traveled to Chicago, by way of Los Angeles, to discuss the PARRA-PEDROZA
MLO with Cl-2. According to Customs and Border Patrol records, on August 7, 2012,
PINEDA SANCHEZ and PARRA-PEDROZA entered the United States at Los Angeles on
the same flight from Guadalajara, Mexico, and on August 11, 2012, departed the United
States from Chicago Midway airport on the same flight to Mexico. CI-2 recognized the voice
of the user of Pineda Sanchez Phone 1 as the same “Diego” that he met in 2012. On March
26, 2014, agents showed CI-2 a photograph of PINEDA SANCHEZ that was taken when
PINEDA entered the United States in August of 2012. Cl-2 identified PINEDA as the
individual who accompanied PARRA-PEDROZA to Chicago. On July 12, 2013, CI-2 had a
consensually recorded telephone call with telephone number 52 (333) 902-9794. During
that conversation, CI-2 recognized the voice to be same as “Diego,” with who he/she met in
Chicago. According to Blackberry Subscriber Records, telephone number 52 (333) 902-
9794, is assigned Blackberry PIN 233D184B (Target Device 6). During an in-person meet
in March 2014 in Las Vegas, Nevada between CI-2 and PARRA-PEDROZA, PARRA-
PEDROZA told CI-2 that they also refer to PINEDA as “BOTAS,” which in Spanish means
“boots.” On March 25, 2014, agents intercepted incoming Blackberry Messages over PIN:
233D184B (Target Device 6) bearing the screen name: “Boot.s” from MARIA LOERA
ALVARADO, who was using Target Device 9, during which LOERA ALVARADO referred
to Boot.s as “Diego.” Based on the above information agents believe PINEDA SANCHEZ to
be the user of Blackberry Pin: 233D184B (Target Device 6). On March 27, 2014 [TD6
Session ##33874- 910], PINEDA SANCHEZ, who was using Target Device 6, exchanged a
series of Blackberry messages with LOERA-ALVARDO, who was using Target Device 9.
During the exchange, PINEDA SANCHEZ stated, “It’s because I'm [PINEDA] going to
delete [stop using] this one [Target Device 6]... . Once you accept [BBM invitation from
‘Target Device 7], I can delete you [delete Target Device 9 from Target Device 6].... My
new [Blackberry] pin is 26F13A1B [Target Device 7].” Target Device 7 bears the screen
name “Botas” and “Boots,” and the user of Target Device 7 was referred and responded to
the name “Diego” in numerous messages.
31a. PINEDA SANCHEZ referred to himself as “Carlos’ partner.”
During this call, PINEDA SANCHEZ stated that PARRA-PEDROZA was out of
town and asked if CI-2 was ready to start working, meaning resume purchasing
gold with narcotics proceeds. PINEDA SANCHEZ and CI-2 discussed the risks
involved when CI-2 picked up money from couriers on the street and how couriers in
the past often brought less money than what PINEDA SANCHEZ and PARRA-
PEDROZA expected. PINEDA SANCHEZ assured CI-2 that CI-2 would not be held
responsible for these shortfalls if CI-2 picked money up off the street, but suggested
that Cl-2 find a place where the couriers could deliver the money so that CI-2 could
count it in their presence,
b. PINEDA SANCHEZ also asked CI-2 about the gold stores that
CIL-2 used to buy scrap gold from. Cl-2 told PINEDA SANCHEZ that he/she never
had a problem with the gold stores, and that CI-2's problems were always with the
money couriers. CI-2 told PINEDA SANCHEZ that CI-2 would not be buying scrap
gold anymore and that CI-2 had a friend who could get fine gold bars. PINEDA
SANCHEZ stated that he liked the idea of dealing with fine gold. PINEDA
SANCHEZ said that he and PARRA-PEDROZA were waiting for money and that
they would soon be sending CI-2 to pick up $50,000 a day for a few days. PINEDA
SANCHEZ told CI-2 that he or PARRA-PEROZA would call CI-2 again soon.
IV. PARRA-PEDROZA Directs CI-2 to Collect and Launder
Approximately $53,475 in Narcotics Proceeds (June 2, 2013).
18. On or about May 21, 2013, CI-2 had a consensually recorded call with
PARRA-PEDROZA, who was using telephone number (608) 545-3026 (“Parra-
32Pedroza Phone 2"). During the call, CI-2 stated, “I need to make an email. I need to
make an email and everything, man. And grab the computer and everything to
send you [an email address] where you are going to send mine [prepaid Fed Ex
labels that CI-2 can use to ship gold purchased with narcoties proceeds to Refinery
Al” PARRA-PEDROZA stated, “Listen, make an email that has to do with gold.
So, Ican send it directly to the refinery [Refinery A]. ... I mean, just make one that.
says, I don't know, ‘Gold Ilinois’ And I will send it [CI-2's email address] directly
to the refinery, so they can see mine (PARRA-PEDROZA’s email address, which
would serve to vouch for CI-2] directly.” CI-2 stated, “Okay, well, that's what I tell
you. Let me start working on the email. I'll start working on everything. I'll grab a
computer. I'll get everything, so I can be ready.” PARRA-PEDROZA stated, “Yeah,
look for a name, a name similar to, to gold [create an email name with the word
“gold” in it].”
19. On or about May 31, 2013, at approximately 6:05 p.m., Cl-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 1. During this call:
a. PARRA-PEDROZA asked, “Listen, tomorrow we have to go
[collect narcotics proceeds]. . .. It’s going to be, where the, Indiana.” CI-2 asked, I
can't do it Monday [June 3, 2013]?” PARRA-PEDROZA responded, “Oh, no, no. It’s
only fifty pesos [$50,000]. ... What about Sunday [June 2, 2013]?... Uh, is
Indiana far? ... Let me, let me tell them [Mexican drug traffickers] that on
Monday [CI-2 will receive the narcotic proceeds].”
33b. CI-2 stated, “On Monday, he [UM 5285, the money courier]
should tell me, or he should tell you where he is at.... He’s not that far... . Early
on Monday. ... I hope I have enough time to move [to meet with the money courier
to receive the narcotics proceeds].” PARRA-PEDROZA stated, “Yeah, this way we'll
see if that same [day], we'll send off a package [of gold to Refinery AJ, don't you
think?” PARRA-PEDROZA and CI-2 agreed to speak again later.
20. On or about May 31, 2013, at approximately 6:10 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using telephone
number (508) 545-3029 (“Parra-Pedroza Phone 3”). During this call, CI-2 asked,
“Well, hey, where to [pickup narcotics proceeds]?” PARRA-PEDROZA responded,
“Listen, uh, well, uh, it is Indianapolis.”
21. On or about May 31, 2013, at approximately 6:19 p.m., CL-2 had a
consensually recorded call with PARRA-PEDROZA, who was using telephone
number (508) 545-3023 (“Parra-Pedroza Phone 4"). During this call, PARRA-
PEDROZA stated, “I told them [money courier] to call you after eight [p.m.] today,
so you guys can come to an agreement. But that yeah, Sunday [June 2, 2013] is fine
[to receive the narcotics proceeds].”
22. On or about May 31, 2013, at approximately
22 p.m, CL-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 4. During this call, PARRA-PEDROZA stated, “[T]hey [UM 5285, the money
courier] are going to ask you for Daniel [code name that money courier will use to
ensure C]-2’s trustworthiness]. You are Daniel now.” CI-2 responded, “Okay.”
3428. On or about June 1, 2013, at approximately 9:50 a.m, Cl-2 had a
consensually recorded call with an unidentified man (“UM 5285”), who was using
UM 5285 Phone 1. This call was not recorded, but it was verified by toll records
from CI-2’s phone. According to CI-2, during this call, UM 5285 asked for “Daniel”
and CI-2 stated that he/she could not talk at the moment but would call UM 5285
back shortly.
24. On or about June 1, 2013, at approximately 9:51 am., Cl-2 had a
consensually recorded call with UM 5285, who was using UM 5285 Phone 1.
During this call:
a. UM 5285 stated, “They [UM 5286's associate in Mexico] told me
the cable... . Did they [PARRA-PEDROZA], did they tell you that I was going to
deliver some postcards [narcotics proceeds] to you?" CI-2 replied, “Uh, yeah, but,
they [PARRA-PEDROZA] told me for tomorrow.” UM 5285 stated, “Oh, okay. Just
0 were on the same page.”
b. CL-2 asked, “[W]here is it going to be [the delivery of the
narcotics proceeds]” UM 5285 responded, “[W]ell, I'm over here towards, over here
towards the chicken [Kentucky]. Towards Kentucky.” CI-2 stated, “Oh, they
[PARRA-PEDROZA] had told me that it [the meeting] was over here by, the cousin
said that it was over here by Indianapolis.” UM 5285 stated,
you want, let me
ask my dad [UM 5285's boss in Mexico] what the deal is and then I will call you.
And if you want to ask him [PARRA-PEDROZa] too, go ahead and ask him.” UM
5285 and CI-2 agreed to talk again later.25. On or about June 1, 2013, at approximately 1:06 p.m., CI-2 had a
consensually recorded call with UM 5285, who was using UM 5285 Phone 1.
During this call, UM 5285 stated, “It is going to be like you think. We are going to
have to meet with the, with the Indian girl [Indianapolis]... In the, in the big city
(Indianapolis), halfway [between Chicago and Kentucky].” UM 5285 and CI-2 then
agreed to meet the next day and to talk again later.
26. On or about June 2, 2013, between approximately 11:10 a.m. and 1:57
p.m., CI-2 had a series of consensually recorded calls with UM 285, who was using
‘UM 5285 Phone. During these calls, UM 5285 and CI-2 agreed to meet each other
at an exit immediately off Interstate 65 in Indianapolis. During an unrecorded call
made after CS-1 arrived in Indianapolis, according to CI-2, UM 5285 and CI-2
arranged to meet at approximately 3:30 p.m. in the parking lot of a Wal-Mart
Supercenter located at 4545 Lafayette Road in Indianapolis.
27. On or about June 2, 2013, at approximately 3:27 p.m., CI-2 met with
UM 5285 at the Wal-Mart Supercenter parking lot located at 4545 Lafayette Road
in Indianapolis, Prior to this meeting, agents outfitted Cl-2 with a concealed audio
recording device and searched CI-2 and his/her vehicle for large amounts money
and contraband, and found none. CI-2 traveled under constant surveillance from a
staging location to the meeting. During this meeting, surveillance observed an
unidentified male carrying a white FedEx shipping package in his hand meet and
talk with CI-2, The unidentified male entered the backseat of CI-2's vehicle with
the white Fediix shipping package and then exited CI-2's vehicle empty handed.
36The unidentified male then walked to his vehicle retrieved a small, black
pocketbook and returned to the backseat of CI-2's vehicle. According to CI-2, the
unidentified man placed additional money onto the white shipping package that he
had earlier placed on the floor of the vehicle.
28, Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved a white shipping package and
cash totaling approximately $53,475 from Cl-2's vehicle. Agents thon transported
the money to the HSI Chicago Field Office, where a canine trained to detect the
odor of narcotics sniffed the money and alerted positive for the presence of narcotics.
29. On or about June 2, 2013, at approximately 8:14 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using telephone
number (508) 545-3025 (“Parra-Pedroza Phone 5”). During this call, PARRA-
PEDROZA asked, “Oh, you haven't verified it [counted the narcotics proceeds
delivered by UM 5285] yet?” CI-2 responded, “No, I rushed over here and I arrived,
it's secured over there. Everything [narcotics proceeds] is at the house. I'm already,
I'm already here.”
30. At approximately 10:30 p.m., CI-2 had a consensually recorded call
with PARRA-PEDROZA, who was using telephone number (333) 146-1711 (“Parra-
Pedroza Phone 6”). During the call, PARRA-PEDROZA asked, “How much [money]
was it?” CI-2 responded, “Five, three, four, seventy-five [$53,475]." PARRA-
PEDROZA confirmed, “Hold on. Five, three, four, seven, five [$53,475].”
3731. On June 3, 2013, at approximately 11:22 a.m., CI-2 had a consensually
recorded call with PARRA-PEDROZA, who was using telephone number (508) 545-
3021 ("Parra-Pedroza Phone 7”). During this call:
a. PARRA-PEDROZA asked, “I was just going to ask you to send
that [gold]. Let's see if we can try to send it today, don't you think?” CI-2
responded, “I think so. As long as, as long as I get everything. I already called this
guy [CY2's putative gold supplier] and he said he would let me know later if he
could deliver (the gold] to me today.” PARRA-PEDROZA responded, “Alright.”
b. CL-2 stated, “The other cousin [VALENTIN RODRIGUEZ, a
different drug trafficker/money courier with whom PARRA-PEDROZA had put CI-2
in contact, see below] already called me. The other cousin already called me, too.
Okay, and I already agreed to meet the one from around here later. Well, I told him
I would call him later to see, so we could agree on something and see what
happens.” PARRA-PEDROZA responded, “I'm saying, we should, we should get
yesterday's [gold purchased with narcotics proceeds from UM 5285] out first
(shipped to Refinery A], so it [narcotics proceeds] doesn't pile up on us.” CI-2 stated,
“Okay, so that it doesn't pile up. Okay, so then call me later so, better yet, I also
have to create an email so I can send it to you and you can send me the guides
[prepaid FedEx labels].” PARRA-PEDROZA stated, “Alright, that's fine.”
32. On June 3, 2013, at approximately 1:09 p.m., CI-2 had a consensually
recorded call with PARRA-PEDROZA, who was using telephone number (508) 545-
3020 (“Parra-Pedroza Phone 8”). During this call, PARRA-PEDROZA asked, “Will
38you be able to send the package [FedEx Box containing the gold]?” Cl-2 responded,
“Let me see if I am able to pay, uh, that guy [CI-2’s gold supplicr] hasn’t let me
know if he will bring me that [gold] today or not.” PARRA-PEDROZA stated,
“Alright, help me out, help me out so we can start {laundering money] well.”
33. On or about June 4, 2013, agents gave CI-2 an undercover email
address that was created and controlled by agents and included the name “Chicago
Gold” (‘UC Email Address”). The UC Email Address is monitored by agents. CI-2
does not have access to the UC Email Address. Agents directed CI-2 to give UC
Email Address to PARRA-PEDROZA. Later that day, Cl-2 sent the UC Email
Address to PARRA-PEDROZA in a BBM message. This message was not recorded,
but the CI sent it in the presence of law enforcement.
34, On or about June 4, 2013, at approximately 1:25 p.m., the UC Email
Account received an email from email account
[email protected] (“Abel
Email Account 1”), which is subscribed to JOSE ABEL MENDOZA-PARRA
(ABEL). This email was entitled, “Fwd: RV: [Refinery A] — FedEx Labels &
1 Agents identified JOSE ABEL MENDOZA-PARRA as follows: According to
subscriber records, Abel Email Account 1 is registered to “Jose Abel Mendoza” in Jalisco,
Mexico. As discussed below, this June 4, 2013, email forwarded an email from Refinery A
that had previously been sent to
[email protected] (‘Abel Email Account 2”)
which is registered to “Jose Abel” and includes in its address the name “joseabel” and the
name of Parra-Pedroza's business ("“britishmetal”). On or about September 6, 2013,
PARRA-PEDROZA sent CI-2 a BBM message over MLO Device 1, advising CI-2 that he
planned to give MLO Device 1 to his nephew, ABEL. PARRA-PEDROZA stated, “I'm not
going to have my cell [MLO Device 1], it’s going to be with my nephew. . .. But he knows
how to close [coordinate money laundering shipments] and everything.” According to CI-2,
prior to his/her cooperation with law enforcement, CI-2 had worked with PARRA-
PEDROZA’s nephew named “Abel” to conduct the money laundering conduct scheme when
PARRA-PEDROZA was unavailable. On or about September 9, 2013, CI-2 sent a BBM
message to MLO Device 1, asking, “Is this Willy [PARRA-PEDROZA]?” When the user of
39Packing List.” Prior to reaching the UC Email Account, this email had been
forwarded to two other email accounts, including
[email protected]
(Parra-Pedroza Email Account 1’) and
[email protected] (‘Abel
Email Account 2"), The email included two attachments, including ten prepaid
FedEx labels addressed to Refinery A and a Refinery A shipping form called a
packing list. The body of the email stated, “We were requested by phone for a
FedEx labels. We have it attached in this e mail along with a (Refinery A] packing
list .... Thank you for choosing [Refinery AJ!"
35. On or about June 4, 2013, CI-2 had a consensually recorded call with
PARRA-PEDROZA, who was using Parra-Pedroza Phone 1. During this call, CI-2
stated, “Whatever [gold] arrives {in Chicago from CI-2's gold supplier] is what will
arrive over there [Refinery A]. And J already told this guy [CI.
’s gold supplier], as
soon I close [agree upon the market value of the gold with the gold supplier], I will
call over there [Mexico] and close [agree upon the current market value of the gold
with PARRA-PEDROZA]. I don't want to take a chance [on losing any money
MLO Device 1 responded, “No,” Cl-2 stated, “Abel.” In response, the user of MLO Device 1
responded, “Call me Robin hahaha. Better.” In a U.S. Visa application for a trip to the
United States in December 2004, ABEL listed Individual R as his cousin. In March 2014,
surveillance observed PARRA-PEDORZA and Individual R meet with Cl-2 in Las Vegas.
During this meeting, PARRA-PEDORZA introduced Individual R to CI-2 as his niece.
Accordingly, agents determined that ABEL is PARRA-PEDROZa’s nephew. In addition,
during a September 2014 interview with agents, PARRA-PEDROZA identified a
photograph from ABEL’s Facebook page as his nephew “Abel” and stated that ABEL
worked with him to launder narcotics proceeds. Agents compared that Facebook page
photo to the photograph of ABEL in his December 2004 Visa application, and determined
that the photos depicted the same man.
Parra-Pedroza Email Account 1 is registered to “Carlos Alberto Parra-Pedroza” in
Jalisco, Mexico
40due to a decline in the value of gold]. ... I already closed [agreed upon the market
value of the gold] with him [CI-2’s gold supplier] right now. But yesterday, I
couldn't close [agree upon the current market value of the gold with PARRA-
PEDROZA]. When I closed, I said, ‘I already closed with him (CI-2’s gold supplier]
at four, thirteen right now. At a thousand four hundred thirteen [set the current
fair market value of the gold at $1,413 per ounce of 24 Karat gold]... . I lost
[money] over there [in purchasing gold at a higher price than what Refinery A
would buy it]. But I said, ‘Well, it's the first day [purchasing gold].’ But then for
next time, I'l tell you, as soon as I close with him [CI-2’s gold supplier], I have to, I
mean, as soon as I receive [purchase the gold with narcotics proceeds], I'l close with
him [CI-2’s gold supplier] and I'll close with you"? PARRA-PEDROZA asked, “
e
won't be able to deliver {the gold to Refinery A] until the day after [the gold was
purchased]? ... Let me see if it [market value of gold] will go up a little tomorrow.
T'm keeping an eye on it [market value on gold] either way.”
36. Onor about June 5, 2013, using one of the shipping labels forwarded in
the June 4 email, agents sent to Refinery A approximately 808.6 grams of 24-Karat,
gold, which agents had purchased with approximately $37,642 of the proceeds
obtained from UM 5285, Agents also enclosed in this shipment the Refinery A
18 According to CI-2, soon after CI-2 began working for PARRA-PEDROZA ~ and prior
to Cl-2's cooperation with law enforcement — PARRA-PEDROZA instructed Cl-2 that each
time he/she purchased gold, CI-2 was to contact PARRA-PEDROZA or one of his associates
and let that person know the amount and price of the gold that CI-2 purchased, so that
PARRA-PEDROZA or one of his associates could record it. This was called “closing.”
According to CI-2, PARRA-PEDROZA told CI-2 that he/she needed to close with him by
providing a specific value for the gold based on current market prices, and that once Cl-2
gave him that closing value, he would contact Refinery A to lock in to that same market
rate.
41packing list that had been attached to the June 4 email. ‘The packing list identified
the shipping company as “Chicago Gold” and described the contents of the box as
808.6 grams of 24-karat gold. According to FedEx records, this shipment arrived at
Refinery A on June 6, 2018
V. PINEDA SANCHEZ and PARRA-PEDROZA Direct CI-2 to Collect and
Launder Approximately $110,000 in Narcotics Proceeds from
RODRIGUEZ (June 5, 2013).
37. On or about June 2, 2013, at approximately 10:30 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 6. During the call, PARRA-PEDROZA stated, “Yeah, I'll call. you early
tomorrow. They [another money courier] want to take you some [deliver narcotics
proceeds] tomorrow from that same place where you are at [Chicago]... They are
going to call you and tell you that it’s on behalf of Botas [PINEDA SANCHEZ].” Cl-
2 replied, “Okay.”
38. On or about June 3, 2013, at approximately 7:58 a.m., CI-2 had a call
with VALENTIN RODRIGUEZ, who was using telephone number (630) 697-5298
(Rodriguez Phone 1”).!4 This call was not recorded, but it was verified by toll
Agents identified RODRIGUEZ and RODRIGUEZ’s voice as follows: As discussed
below, between June 3 and 6, 2013, CI-2 had numerous consensually recorded calls with the
user of Rodriguez Phone 1. During these calls, the user of Rodriguez Phone 1 arranged to
meet Cl-2 in person at the Home Depot located at a Home Depot located at 12000 S. Cicero
Avenue in Alsip, Illinois, at approximately 11:34 a.m. on June 5, 2013, for the purpose of
delivering narcotics cash proceeds. Similarly, the user of telephone number (630) 865-7710
Rodriguez Phone 2”) arranged in a series of unrecorded calls to meet CI-2 for the same
reason at the same Home Depot at approximately 5:19 p.m. on June 10, 2013. CI-2
recognized the voice of the user of Rodriguez Phone 2 to be the same man with whom he
met on June 5 and 10, 2013. Following these phone calls, surveillance observed CI-2 meet
with, and obtain proceeds from, a man at the designated time and place. Agents conducting
surveillance of both meetings subsequently viewed a February 18, 2010, CPD arrest
42records. According to CI-2, during the call, RODRIGUEZ told CI-2 that he had “100
tickets [$100,000]” for CI-2 and that the “tickets” belonged to “Botas [PINEDA
SANCHEZ].”. RODRIGUEZ stated that he was told to give CI-2 “50 tickets
[$50,000] today” and “another 50 tickets [50,000] on Tuesday [June 4, 2013].”
RODRIGUEZ and Cl-2 agreed that it made more sense to only meet once.
RODRIGUEZ told CI-2 that he was located near the intersection of 167th Street
and Interstate 57 and preferred to meet around that area. CI-2 and RODRIGUEZ
agreed to speak again later.
39. On or about June 3, 2013, at approximately 2:47 p.m., Cl-2 had a
consensually recorded call with RODRIGUEZ, who was using Rodriguez Phone 1
During the call, CI-2 stated,
'm going to go over by [meet] you on Wednesday. You
are going to give me the hundred tickets [$100,000] or how many?” RODRIGUEZ
responded, “Well, yeah, that’s what Iwas...” CI-2 stated, “Yeah, so we can avoid
the bag, the bag for fifty, fifty [an initial delivery for $50,000 and then a second
delivery for $50,000]. Then you just report that, and you report the hundred [tell
associates in Mexico that CI-2 collected $100,000].” RODRIGUEZ responded,
“Okay.” RODRIGUEZ and CI-2 then agreed to talk again later.
photograph of “Valentin Rodriguez,” and positively identified RODRIGUEZ as the
individual who delivered narcotics proceeds to CI-2 on June 5, and again on June 10, 2013.
In addition, prior to the June 5 and June 10 meetings, agents outfitted Cl-2 with a
concealed audio recording device, which captured RODRIGUEZ's voice. After reviewing the
recordings of the June 5 and 10 meetings, agents compared the voice of the man with whom
CI-2 met to the voice of the man who was Rodriguez Phone 1, in numerous, consensually
recorded calls with CI-2, and determined that RODRIGUEZ was the user of Rodriguez
Phone 1,
4340. On or about June 4, 2013, at approximately 2:42 p.m., CI-2 had a
consensually recorded call with RODRIGUEZ, who was using Rodriguez Phone 1.
During the call, CI-2 stated, “Hey, Primo. I'll give you a call tomorrow when I'm on
my way to go pick up the tickets [narcotics proceeds].” RODRIGUEZ responded,
“All right. That's fine.” CI-2 stated, “Around eleven [11:00 a.m, twelve [12:00
p.m], we will meet close to your ranch [RODRIGUEZ's home]. Okay?”
RODRIGUEZ responded, “Alright.”
41. On or about June 4, 2013, at approximately 6:15 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 1. During the call, PARRA-PEDROZA asked, “Well, they [Refinery A] are
going to pay me on Friday [June 7, 2013]. But then tomorrow [collection of
narcoties proceeds from RODRIGUEZ] is a sure thing, right?” CI-2 replied, “Yeah,
tomorrow is a sure thing. [ll go and meet with the other primo [RODRIGUEZ]
tomorrow. And then on, what is it? Tomorrow is Wednesday. I'll set you up again
on Friday [send more gold to Refinery A on Friday June 7, 2013).” PARRA-
PEDROZA stated, “Right now they [RODRIGUEZ and associates] are going to bring
usa hundred, a hundred and fifty [between $100,000 and $150,000], I think.”
42, On or about June 5, 2013, at approximately 10:02 a.m., CI-2 had a
consensually recorded call with RODRIGUEZ, who was using Rodriguez Phone 1
During this calls, CI-2 stated, “Tl be there in about an hour. ... When I'm close, Tl
give you a call from where I'm at, when I am close.” RODRIGUEZ said, “Sounds
good, sounds good.”
4443. On or about June 5, 2013, between approximately 11:10 a.m. and 11:34
am., CI-2 had a series of calls with RODRIGUEZ, who was using Rodriguez Phone
1. CL-2’s half of the conversations were monitored by agents and recorded. During
these calls, CI-2 and RODRIGUEZ agreed to meet at approximately 11:34 a.m. in
the parking lot of a Home Depot located at 12000 S. Cicero Avenue in Alsip.
44. On or about June 5, 2013, at approximately 11:34 a.m., CI-2 and
RODRIGUEZ met in the parking lot of the Home Depot located at 12000 S. Cicero
Avenue in Alsip. Prior to this meeting, agents outfitted CI-2 with a concealed audio
recording device and searched CI-2 and his/her vehicle for large amounts money
and contraband, finding only $98. CI-2 traveled under constant surveillance from a
staging location to the meeting. Surveillance agents also video recorded the
meeting. Surveillance observed RODRIGUEZ arrive in Rodriguez Vehicle 1, park
next to CI-2's vehicle, exit his car, retrieve a Modelo beer box from his car, and hand
the box to CI-2, who placed the box into the back of his/her vehicle. During this
meeting:
a, RODRIGUEZ stated, “What a miracle! You do remember me
[from a prior delivery of narcotics proceeds, prior to CI-2's cooperation}, right?” CI-2
responded, “Yeah. If I would have known [it was someone with whom CI-2 had
previously met], I would have told you to go over there (CI-2's former office]. But
you don’t want me to go to the office.” RODRIGUEZ asked, “Are you still at the
same place [office]?” CI-2 stated, “No, somewhere else.”b. RODRIGUEZ stated, “Well, they told me that something had
happened there (at Cl-2’s office]. Is it true?” CI-2 responded, “That's why we moved
over there.” RODRIGUEZ stated, “Yeah, you need to be calm discrete, to avoid the
attention of law enforcement]. Do you want us to go into the store [Home Depot] for
a bit [to avoid the detection of law enforcement]?” CI-2 responded, “No, this is fine
here. People keep taking stuff up. That’s why I parked here.” RODRIGUEZ stated,
“That's good, that’s good.”
c. CE-2 asked, “They didn't tell you who's it was [the owner of the
narcotics proceeds}? They had told me it was from Botas [PINEDA SANCHEZ].”
RODRIGUEZ responded, “Botas? He [RODRIGUEZ's associate] didn’t tell me.
You're Daniel [CI-2's codename, provided by PARRA-PEDROZAl, right?” CI-2
responded, “Yeah.” RODRIGUEZ stated, “Yeah, no, no, the thing is, they just told
me to call you Daniel. The good thing is that we already know each other.” CI-2
responded, “Yeah. That’s the good thing. Then when you see each other there's
more trust.”
d. RODRIGUEZ stated, “Look, you know what we are going to do?
Let's go to the Seven-Bleven [a nearby convenience store, to hand over the narcotics
proceeds].” CI-2 responded, “Just give it [narcotics proceeds] to me here right away.
Thave to leave already.” RODRIGUEZ stated, “There's an asshole [law enforcement
agent] there.” CI-2 asked, “Where?” RODRIGUEZ replied, “The one in the black
car. He’s just looking over here. Look, let’s go there. We'll buy the beers there
46[deliver the narcotics proceeds}. Or let’s at least go to the gym [a nearby LA.
Fitness]. So they don't see us.” CI-2 stated, “Just give it to me here. Don't worry.”
e. CE-2 asked, “There are a hundred pesos [$100,000] in here,
right?” RODRIGUEZ responded, “Yeah. Yeah, a hundred and ten [$110,000].” CI-
2 stated, “A hundred and ten [$110,000]?” RODRIGUEZ responded, “Yeah.” CI-2
stated, “Okay. You set it up well [the money is well hidden inside the beer box).
You can’t see it in that thing.” RODRIGUEZ responded, “Yeah, no, it's a twenty-
four pack [24-pack Modelo beer bos].”
45. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved a Modelo beer box containing
approximately $110,000 in cash from CI-2’s vehicle. Agents then transported the
money to the HSI Chicago Field Office, where a canine trained to detect the odor of
narcotics sniffed the money and alerted positive for the presence of narcotics.
46. On or about June 5, 2013, between approximately 11:58 a.m. and 12:00
p.m., Cl-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
BBM PIN: 26249D82 (“MLO Device 1”). Following this exchange, agents reviewed
the exchange and documented several of the messages. During this exchange, CI-2
stated, “I just fixed the primo [CI-2 received narcotics proceeds from
RODRIGUEZ].” PARRA-PEDROZA asked, “How much [money was delivered]?”
CL-2 replied, “Its 110 pesos [$110,000], not yet verified [not yet counted by CI-2].”
47. On or about June 5, 2013, between approximately 1:05 p.m. and 2:12
p-m., Cl-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
aTMLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, PARRA-PEDROZA.
asked, “And the verification [money count of narcotics proceeds delivered by
RODRIGUEZ]?” CI-2 responded, “I will go [count] in a while, send the metal first
[mail to Refinery A gold purchased with the narcotics proceeds that CI-2 collected
from UM 5285 on June 2, 2013] and then verify.” PARRA-PEDROZA responded,
“OK.” CE-2 stated, “I sent the mail [gold to Refinery A] and will verify. Will call you
when I'm done,”
48. On or about June 5, 2013, between approximately 2:48 p.m. and 3:47
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, CL-2 stated, “Put me
down for 110 [the final money count of the proceeds delivered by RODRIGUEZ is
$110,000}.” PARRA-PEDROZA responded, “OK.” CI-2 stated, “Close 2,340 of the
fine at 1404 [CI-2 purchased 2,340 grams of 24 Karat gold at the current fair
market value of $1,404 per ounce, using narcotics proceeds collected from
RODRIGUEZ].” PARRA-PEDROZA responded, “OK.” Cl-2 stated, “I will send
todays [gold purchased from RODRIGUEZ’s proceeds] to you on Friday [June 7,
2013).” PARRA-PEDROZA responded, “OK.”
49. On or about June 7, 2013, using two of the shipping labels provided by
PARRA-PEDROZA, agents sent to Refinery A approximately 2,342 grams of 24-
Karat gold, which agents had purchased with approximately $107,826.49 of the
48proceeds obtained from RODRIGUEZ. Agents also enclosed in this shipment a
Refinery A packing list that identified the shipping company as “Chicago Gold” and
described the contents of the boxes as containing a total of 2,842 grams of 24-Karat
gold. According to FedEx records, this shipment arrived at Refinery A on or about
June 10, 2013.
VI. PARRA-PEDROZA Directs CI-2 to Collect and Launder
Approximately $30,010 in Narcotics Proceeds from RODRIGUEZ
(June 10, 2013).
50. On or about June 5, 2013, at approximately 8:11 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 1. During the call, PARRA-PEDROZA asked, “Can you do me a favor
tomorrow and pick up fifty [$50,000 in narcotics proceeds]? They [RODRIGUEZ
and associates] were already committed [made arrangements to deliver more
money] and, then we told them that Monday [June 10, 2013] would be better.” CL-2
responded, “Okay, let me see what I will be able to do tomorrow because, you know,
T have to go pick that [$110,000 collected from RODRIGUEZ] up and deliver that to
him [CI-2's putative gold supplier], otherwise I am not going to be able to finish
[purchase the gold with the $110,000]. And I just don’t want to fall behind.”
PARRA-PEDROZA stated, “I mean, even if you don't move them [ship the gold to
Refinery A] tomorrow. I mean, maybe you can wait to move them [ship the gold]
until Friday.”
On or about June 5, 2013, at approximately 1
:22 p.m. CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
49Phone 4. During the call, PARRA-PEDROZA asked, “So then what [can you receive
the delivery of narcotics proceeds]?” CI-2 stated, “The thing is T am in a rush and I
have to do some things tomorrow. And the thing is that I don't have a place [secure
location] to put the tickets [narcotics proceeds].” PARRA-PEDROZA responded,
“It’s just fifty pesos [$50,000]. The thing is that since he [RODRIGUEZ] committed,
I mean, since we said, ‘We're already working [laundering proceeds], the guy
[RODRIGUEZ] moved them [$50,000] from somewhere else... . Then we told him
that it [the pick-up] was going to be on Monday [June 10, 2013] and he said, ‘No, I
already moved, man. I'm already here.” Cl-2 stated, “I don't know if I'll be able to
make it [collect RODRIGUEZ’s $50,000] tomorrow.”
52. On or about June 9, 2013, between approximately 1:13 p.m. and 1:21
p.m., Cl-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, PARRA-PEDROZA
stated, “The primos [RODRIGUEZ and associates] stayed in Chicas [Chicago] in
order to deliver to you tomorrow.” CI-2 responded, “OK.”
53. On or about June 9, 2013, at approximately 9:45 p.m., CI-2 had a call
with RODRIGUEZ, who was using Rodriguez Phone 2. This call was not recorded,
but it was verified by toll records. According to CI-2, during the call, RODRIGUEZ
asked to meet with CI-2 at the “tool place [Home Depot where they had previously
met on June 5, 2013].” CI-2 and RODRIGUEZ agreed to meet each other onMonday, June 10, 2013, because RODRIGUEZ had $30,000 in narcotics proceeds to
deliver to CI-2 and was leaving town on Tuesday, June 11, 2013.
54, On or about June 10, 2013, betwoon approximately 12:40 p.m. and 4:51
p.m., CI-2 had a series of calls with RODRIGUEZ, who was using Rodriguez Phone
2. Those calls were not recorded, but they were verified by toll records. According
to CI-2, during these calls, RODRIGUEZ and CI-2 agreed to meet at the same Home
Depot at approximately 5:19 p.m. that day.
55. On or about June 10, 2013, at approximately 5:19 p.m., CI-2 and
RODRIGUEZ met in the parking lot of the Home Depot located at 12000 S. Cicero
Avenue in Alsip. Prior to this meeting, agents outfitted CI-2 with a concealed audio
recording device and searched CI-2 and his/her vehicle for large amounts money
and contraband, with negative results. CI-2 traveled under constant surveillance
from a staging location to the meeting. Surveillance agents video recorded the
meeting. Surveillance observed RODRIGUEZ arrive in Rodriguez Vehicle 1, park
next to CI-2's vehicle, exit his car, retrieve a gift bag with a “Bat Man’ logo from his
car, and hand the bag to CI-2, who placed the bag into the back of his/her vehicle.
During this meeting:
a. CE-2 stated, “I wanted to ask you, since you work on cars, do you
have any compartments (hidden compartments, or “traps,” installed inside vehicles
used to store narcotics and narcotics proceeds]?” RODRIGUEZ responded, “No,
man. I used to have a guy before, but he left. Yeah, no, there used to be a guy
before who used to hook it up [install the trap] for us, but he left to Mexico and that
51was it.” CI-2 stated, “I also had a guy who used to do them for me, but I lost track
of him.” RODRIGUEZ stated, “Yeah, it’s hard. No one wants to do that [install
traps]. No one wants to. It’s not easy. But damn, they're so necessary.”
b. CL-2 asked, “Thirty bucks [$30,000], right?” RODRIGUEZ
responded, “Thirty [$30,000].”
56. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved from CI-2’s vehicle a gift bag
with a “Bat Man” logo containing approximately $30,010 in cash. Agents then
transported the money to the HSI Chicago Field Office, where a canine trained to
detect the odor of narcotics sniffed the money and alerted positive for the presence
of narcotics.
57. On or about June 10, 2013, between approximately 5:37 p.m. and 7:00
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, PARRA-PEDROZA
asked, “And the 30 [the delivery of $30,000 from RODRIGUEZ]?” CI-2 stated, “Im
verifying [counting the money]. Put me down for 30,010.” PARRA-PEDROZA
responded, “OK.”
58. Onor about June 11, 2013, between approximately 1:10 p.m. and 1:11
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, Cl-2 stated, “Close 622
52of the fine at 1378 [CI-2 purchased 622 grams of 24 Karat gold at the current fair
market value of $1,378 per ounce, using narcotics proceeds collected from
RODRIGUEZ on June 10, 2013].” PARRA-PEDROZA replied, “OK.”
59. On or about June 13, 2013, using a shipping label provided by PARRA-
PEDROZA, agents sent to Refinery A approximately 622.07 grams of 24-Karat gold,
which agents had purchased with approximately $28,159.80 of the proceeds
obtained from RODRIGUEZ. Agents also enclosed in this shipment a Refinery A
packing list that identified the shipping company as “Chicago Gold” and described
the contents of the box as containing a total of 622.07 grams of 24-Karat gold.
According to FedEx records, this shipment arrived at Refinery A on or about June
14, 2013.
VII. PARRA-PEDROZA Directs CI-2 to Collect and Launder
Approximately $98,999 in Narcotics Proceeds from CARO and
Individual Q (June 11, 2013).
60. On or about June 6, 2013, at approximately 2:55 p.m., Cl-2 had a
consensually recorded call with TEODOCIO CARO," who was using telephone
18 Agents identified TEODOCIO CARO and CARO's voice as follows: As discussed
below, between June 6 and 25, 2013, Cl-2 had several consensually recorded call with the
man who was using Caro Phone 1. During several of these calls, the man using Caro Phone
1 arranged to meet CI-2 in person at Home Depot located at 12000 S. Cicero Avenue in
Alsip, Ilinois, at approximately 1:30 p.m. on June 25, 2013, for the purpose of delivering
narcotics cash proceeds. Following those phone calls, surveillance observed Cl-2 meet with,
and obtain proceeds from, a man at the designated time and place. Agents conducting
surveillance subsequently viewed an Illinois State Driver's License photograph of “Teodocio
Caro,” and positively identified CARO as the individual who delivered narcotics proceeds to
CI-2 on June 25, 2013. CARO arrived at the June 25 meeting in a car that was, according
to SOS records, registered to “Teodocio Caro.” In addition, prior to this June 25 meeting,
agents outfitted CI-2 with a concealed audio recording device, which captured CARO's
voice. After reviewing the recording of the June 25 meeting, agents compared the voice of
the man with whom CI-2 met to the voice of the man who was using Caro Phone 1 in
53number (773) 715-2419 (“Caro Phone 1”), During this call, CARO stated, “They told
me to pick up a title for the truck, the dark one [deliver narcotics proceeds].” CI-2
asked, “Where are you, primo?” CARO responded, “Here in West Chicago... By
the eighty-eight [Interstate 88], towards Aurora.” CI-2 stated, “Can you wait until
Monday [June 10, 2013]?” CARO stated, “No, well, that’s what they [CARO's
associates in Mexico] told me. I can wait two, three days, you know?” CI-2 asked,
“Did they tell you how many tickets [amount of narcotics proceeds that will be
dolivered]?” CARO replied, “Yeah, it's a little more than a hundred [over
$100,000).”
61. On or about June 10, 2013, at approximately 1:02 p.m., CI-2 had an
unrecorded call with CARO, who was using Caro Phone 1. This call was verified by
toll records, According to CI-2, during this call, CI-2 agreed to meet an associate of
CARO (Individual Q) in the area of 59th and Main Street in West Chicago on June
11, 2018 at around 4:00 p.m.
62. On or about June 10, 2013, between approximately 5:38 p.m. and 5:39
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed the exchange and
documented several of the messages. During this exchange, PARRA-PEDROZA
asked, “And the 107 [the delivery of $107,000 arranged by CARO]? CI-2
responded, “Tomorrow evening.”
numerous, consensually recorded calls with CI-2, and determined that CARO was the user
of Caro Phone 1.63. On or about June 11, 2013, at approximately 12:08 p.m., CI-2 had a
consensually recorded call with PARRA-PEDROZA, who was using Parra-Pedroza
Phone 4. During this call, PARRA-PEDROZA asked, “Hey, can you call him
[CARO] and set up a meeting {to receive narcotics proceeds}? It’s because he has
things to do even if you do it [meet] at five [5:00 p.m.], but that way he [CARO] can
move and do his stuff.” CI-2 replied, “Okay, lot me call him right now in about ten,
fifteen minutes.”
64. On or about June 11, 2013, at approximately 12:37 p.m., CI-2 had a
consensually recorded call with CARO, who was using Caro Phone 1. During this
call, CI-2 stated, “I'll be there around four [4:00 p.m.], right where you told me [area
of 59th and Main Street in West Chicago].” CARO replied, “Look, primo, so I won't
make you wait there too long, come at about, it would have to be around six [6:00
p.m.].... The guy [Individual Q] is going to be there at that time. The thing is he
[Individual Q] works and gets out at that time.” CI-2 asked, “
Jamn, he can't make
it at five [5:00 p.m J?... Call him [Individual Q] and tell him because I won't make
it at six. It’s because I have to take my relative the invitation [take the money to
the putative gold supplier] so he can go to the dance [sell gold] and I won't be able to
take it [purchase gold] at six.” CARO stated, “Hold on, let me check.”
65. On or about June 11, 2013, at approximately 12:42 p.m., Cl-2 had a
consensually recorded call with CARO, who was using Caro Phone 1. During this
call, CI-2 stated, “I'll see him [Individual Q] around five-thirty [5:30 p.m.] or six
[6:00 p.m.], okay?” CARO stated, “All right, primo. We'll leave it like that.” CI-2
&stated, “When I'm around there, around where you said [location of the meeting], Tl
give you a call. Okay? And he [Individual Q] can come by me.” CARO responded,
“Alright.”
66. On or about June 11, 2013, between approximately 5:50 p.m. and 6:15
p.m., CL-2 had a series of unrecorded calls with CARO, who was using Caro Phone
1. These calls were verified by toll records. According to CI-2, during these calls,
CI-2 advised CARO that he/she was waiting in the parking lot of the Menard’s
located at 220 W. North Avenue in We
st Chicago and explained where Individual Q
could find CL-2.
67. Moments after the last call, CI-2 and Individual Q met in the parking
lot of the Menard’s located at 220 W. North Avenue inn West Chicago. Prior to this
meeting, agents outfitted CI-2 with a concealed audio recording device, but due to a
technical malfunction, the audio recording device did not record the meeting.
Agents also searched CI-2 and his/her vehicle for large amounts money and
contraband, finding only $29. CI-2 traveled under constant surveillance from a
staging location to the meeting. Surveillance agents also video recorded the
meeting. Surveillance observed Individual Q arrive in a vehicle, park next to CI-2’s
vehicle, exit his car, retrieve a detergent box wrapped inside a clear plastic Wal-
‘Mart shopping bag from his vehicle, and hand the bag to CI-2, who placed the bag
into the back of his/her vehicle. According to CI-2, during this meeting, Individual
Q stated, “Here is the soap to wash the dishes,” and confirmed that he was
delivering $107,520.
5668. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved from CI-2’s vehicle a detergent
box wrapped inside a clear plastic Wal-Mart shopping bag containing approximately
$98,999 in cash. The money consisted of a large number of one and five dollar bills.
Agents then transported the money to the HSI Chicago Field Office, where a canine
trained to detect the odor of narcotics sniffed the money and alerted positive for the
presence of narcotics.
69. On or about June 11, 2013, after agents had counted the money
delivered by Individual Q, CI-2 exchanged a series of BBMs with PARRA-
PEDROZA, who was using MLO Device 1. According to CI-2, CI-2 advised PARRA-
PEDROZA that the amount of narcotics proceeds delivered by Individual Q was
$98,999 not $107,520.
70. On or about June 12, 2013, CI-2 exchanged a series of BBMs with
PARRA-PEDROZA, who was using MLO Device 1. According to CI-2, during this
exchange, CI-2 advised PARRA-PEDROZA that he/she had purchased 54.15 ounces
of gold with a portion of the money that CI-2 collected from Individual Q, and
PARRA-PEDROZA agreed to a purchase price of $1,392 per ounce.
71. On or about June 13, 2013, CI-2 exchanged a series of BBMs with
PARRA-PEDROZA, who was using MLO Device 1. According to CI-2, during this
exchange, CI-2 advised PARRA-PEDROZA that he/she had purchased 14 ounces of
gold with the balance of the money that CI-2 collected from Individual Q, and
PARRA-PEDROZA agreed to a purchase price of $1,384 per ounce.
5772. On or about June 17, 2013, using two shipping labels provided by
PARRA-PEDROZA, agents sent to Refinery A approximately 54.15 ounces of 24-
Karat gold, which agents had purchased with approximately $76,942.21 of the
proceeds obtained from Individual Q. Agents also enclosed in this shipment a
Refinery A packing list that identified the shipping company as “Chicago Gold” and
described the contents of the boxes as containing a total of 1,684.28 grams of 24-
Karat gold. According to FedEx records, this shipment arrived at Refinery A on or
about June 18, 2013.
73. On or about June 18, 2013, using a shipping label provided by PARRA-
PEDROZA, agents sent to Refinery A approximately 14 ounces of 24-Karat gold,
which agents had purchased with approximately $19,826.41 of the proceeds
obtained from Individual Q. Agents also enclosed in this shipment a Refinery A
packing list that identified the shipping company as “Chicago Gold” and described
the contents of the boxes as containing a total of 435.45 grams of 24-Karat gold.
According to FedEx records, this shipment arrived at Refinery A on or about June
19, 2013.
74. Onor about June 18, 2013, between approximately 4:12 p.m. and 7:08
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1, During this exchange, CI-2 stated, “I just sent you the rest
[remaining 14 ounces of gold].”. PARRA-PEDROZA asked, “How much?” CI-2
replied, “The 20 [the value of the gold shipment was approximately $20,000] that I
was going to deposit [into the bank account].” PARRA-PEDROZA responded, “OK.”
58VIII, PARRA-PEDROZA and CI-2 Meet to Discuss PARRA-PEDROZA’s
Money Laundering Operation (June 20, 2013).
75. On dune 14, 2013, between approximately 7:02 p.m., and 7:30 p.m., CI-
2 exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO Device
1. During this exchange:
a. PARRA-PEDROZA stated, “That’s not how we're going to do it
[the extended amount of time that CI-2 took to purchase gold with narcotics
proceeds from various individuals to date and send it to Refinery A was
unacceptable]. They're [PINEDA SANCHEZ and the drug traffickers] going to send
us to hell [stop using PARRA-PEDROZA for laundering money]... Don't you have
another option? To buy [gold]? ... It’s that now they're [drug traffickers and MLO
members] telling us to tell the truth if it [PARRA-PEDROZA’s money laundering
services] was worth a damn again. ... And if] tell them [drug traffickers and MLO
members] we always pay them on Tuesday that it’s not going to be until Wednesday
they'll truly kill me [PARRA-PEDROZA must provide the drug traffickers with the
laundered money on the day PARRA-PEDROZA promises].”
b. CI-2 responded, “This one [CI-2’s gold supplier] is fine. I only
need a little time to learn all of the movement [process of purchasing the gold], it's
that with a single year of elementary [purchasing fine gold is complicated for a man
of CI-2's educational background] it's not easy.” PARRA-PEDROZA stated, “The
bad thing is that these guys [drug traffickers and MLO members] don’t even know
the word school, only know how to shoot.”
59c. PARRA-PEDROZA and CI-2 made arrangements to meet each
other in Las Vegas, Nevada on June 20, 2013.
76. On or about June 20, 2013, PARRA-PEDROZA and Cl-2 met at a
shopping mall in Las Vegas, Nevada. Prior to this meeting, agents outfitted CI-2
with a concealed audio recording device. CI-2 traveled under constant surveillance
from a staging location to the meeting. Surveillance observed CI-2 meet with
PARRA-PEDROZA in the food court of the mall. During this meeting:
a. CL-2 stated. “Look, this {method of buying fine gold] is better
{unintelligible (‘U/P)]. The longer the better. I just need . . . for you to have them
[money couriers] well organized so we can work well. That’s what you need to do. . .
. The thing is, they [money couriers] don't trust and I don’t trust either, so, uh, I
don’t want to pick up [narcotics proceeds] from them every day .... I don’t want to
have anything [narcotics proceeds] on me. The way I receive it [narcotics proceeds],
Thave to take it over there and get rid of it [CI-2 takes the narcotics proceeds to the
gold vendor to buy gold immediately after he receives the money, so he/she does not,
have to store narcotics proceeds].” PARRA-PEDROZA asked, “So you take it
{narcotics proceeds] and right there and then you get rid of it [purchase gold]?” CI-2
responded, “Right there and then, I verify [count] it and let’s go because I don't
want to have anything [narcotics proceeds] stored there [at Cl-2's residence] just in
case flaw enforcement raids CI-2's residence].”
b. PARRA-PEDROZA stated, “The problem is they [drug
traffickers and MLO members] are very alert... . I was talking to him [PINEDA
60SANCHEZ] right now. He [PINEDA SANCHEZ] told me, ‘We need [CI-2] to tell us
exactly, exactly the date and time [that CI-2 will meet with and collect narcotics
proceeds from money couriers]... Okay, how many days do we need [to coordinate
the delivery of narcotics proceeds and purchase of gold.].” CI-2 responded, “I need,
let’s say two days [notice], for them [drug traffickers/money couriers] to deliver
[narcotics proceeds] to me in two days, two days, for example, they can deliver to me
Monday and Wednesday, that way you get it [laundered money] on time over there
[in Mexico] ....”
c. PARRA-PEDROZA stated, “Yes, Wednesday, Thursday, it [gold
purchased with narcotics proceeds] would arrive [at Refinery A] on Friday and I
don't get paid [by Refinery A] on Saturday. They [Refinery A] don't pay me until
Monday. ... Can it be Monday and Tuesday [to receive narcotics proceeds from
money couriers}?... [We got a few days... Two, three days to, um, to pay them
[Mexico-based drug traffickers]. Uh, they gave it {money laundering contract] to us
and we're barely, um, we're still making payments [sending money that should have
been completely laundered already]. They [Mexico-based drug traffickers] almost
killed us [PARRA-PEDROZA and PINEDA SANCHEZ]. The thing is we didn't,
yesterday, they were about to [U/I] fucking beating [for the delay in delivering
laundered money to cartel drug traffickers]. [Mexico-based drug traffickers said]
‘Tell me, did you drop it [allow law enforcement to seize narcotics proceeds] again?
You'll see what we'll [cartel drug traffickers] do but don’t be telling me [the
laundered money will arrive] tomorrow, tomorrow, tomorrow. If you dropped it [lost
61narcoties proceeds to law enforcement] again, tell me.” CI-2 stated, “No, we're fine.
We're working [collecting narcotic proceeds], and everything is fine.”
d. Later in the conversation, PARRA-PEDROZA stated, “But they
[drug traffickers] don’t want to give more than fifty [$50,000 money laundering
contracts]. It’s because, at the beginning, they didn’t want to give anything and
then they wanted us [Parra-Pedroza MLO] to pay them [once the drug traffickers
were willing to give PARRA-PEDROZA money laundering contracts, they wanted
PARRA-PEDROZA to pay them the money before the narcotics proceeds were even
delivered to CI-2 in the United States]... We [PINEDA SANCHEZ and PARRA-
PEDROZA] asked them to give us two, three days [to launder the money]. They
[drug traffickers} take them [deliver the narcotics proceeds to Cl-2] and we go all
these days [took too long to launder the money through Refinery AJ. No, I couldn't
take it anymore.”
e. CL-2 stated, “So I prefer to do the fine one [purchase fine gold
with narcotics proceeds] or send you, I have a friend [CI-2’s gold supplier] who says
Tecan send you the money via cable [bank wire transfers) over there [Mexico] but I
don’t know how that works. That's something I don't understand. I don't
understand that.” PARRA-PEDROZA stated, “Because the law [banking law in
Mexico] is going to get really hard over here in Mexico. ‘There’s going to pass a
really tough law in July [2013] regarding that [making it easier for law enforcement
to detect bank wire transfers from the United States to Mexico]... . It’s because if
he [CI-2's gold supplier], he might be able to send [wire] it to me but if don’t have a
62way of sending [the laundered money to] the uncle [Mexican based drug
traffickers} ....”
f PARRA-PEDROZA stated, “{I]f they bring me the money and I'l
[UM] it fell [gets seized by law enforcement]. The thing is, they [Refinery A] have an
office in Mexico [as well as Florida]. ... They [Refinery A] say I sold them [gold] in
Mexico and since the payment comes from over there [Refinery A Mexican-based
office].... They [Refinery A] sold it [the gold] to me in Mexico, but the money is
sent from here [Refinery A falsifies paperwork to make it look like PARRA-
PEDROZA sold gold to the company’s Mexico-based office to justify the payments
the company sends PARRA-PEDROZA in Mexico for the gold shipments that
Refinery A receives from U.S.-based members of the MLO, such as CI-2].”
g. CL-2 asked, “[HJow do they [PINEDA SANCHEZ and Mexican
drug traffickers] take them [get narcotics proceeds to Mexico] right now? They have
to send a car over there [to Mexico] right?” PARRA-PEDROZA responded, “Yeah. . .
. Yeah, that's why they [drug traffickers/money couriers] only take the twenties
[deliver $20 dollar bills to CI-2] sometimes, because they take the big ones [larger
denomination bills] in the car, in the compartment [drug traffickers use hidden
compartments in cars to smuggle narcotics proceeds into Mexico].” CI-2 asked, “So
that’s what he [PINEDA SANCHEZ or Mexican drug trafficker] does right now,
sends the car over there [smuggles narcotics proceeds into Mexico in cars}?”
PARRA-PEDROZA responded, “Yes, yes, yes.”
63h, — CI-2 asked, “So what do they [Mexican drug traffickers] do with
all the paper [laundered narcotics proceeds]?” PARRA-PEDROZA responded,
“Down there [in Mexico]? . .. Look, we've (PINEDA SANCHEZ and PARRA-
PEDROZA] had pesos, Mexican pesos, we couldn't find dollars (U.S. dollars} and the
thing is, [PARRA-PEDROZA asks drug traffickers to] ‘Take pesos.’ [Drug
traffickers respond] ‘No, I gave you dollars. I want dollars [drug traffickers did
want to be paid in U.S. dollars, not Mexican pesos]. ... We give them [U.S. dollars]
to them [Mexican drug traffickers] and they go sell them [U.S. dollars] a lot cheaper
than we [PINEDA SANCHEZ and PARRA-PEDROZA] bought them... At the end
they [Mexican drug traffickers] have to receive pesos [for their laundered narcotics
proceeds].”
i. CL-2 stated, “We're talking about big things. What are they
[Mexican drug traffickers] going to do with all that [laundered narcotics proceeds]
over there [in Mexico]? It’s not like put it away [save the money]?” PARRA-
PEDROZA stated, “Mexico is just a stop [for the narcotics proceeds.” CI-2 asked,
“All the way over there [Mexico]?” PARRA-PEDROZA responded, “More south
{Colombia}. They've asked me if I'll take it south [launder the narcotics proceeds
from Mexico to Colombia]
. It’s just that if I start to operate the companies south
of Mexico [in Colombia], they're going to fail [the money laundering scheme would
not succeed between Mexico and Colombia]. ... There's a lot of operations [business
transactions] between United States and Mexico .. . .”
64i CI-2 stated, “[TJhe reason why I'm scared is because [if the
narcotics proceeds get seized by law enforcement], then they're [Mexican drug
traffickers] going to cut our balls off without it being our fault.” PARRA-PEDROZA
stated, “Yeah that's true.... And they're good at beating everyone up.... And
they're good at saying, ‘It was you.” Cl-2 stated, “If it wasn’t you, oh well. And
that's why we have to be careful with that fucking shit [narcotics proceeds]. We
have to be careful because of that, because they think bad about you and whether
it's our fault or not, they're going to get us. That way, they [Mexican drug
traffickers] get one of them [a money courier who becomes familiar with CI-2], that
guy already knows me, I already know him. ‘Okay, we'll meet [to collect narcotics
proceeds] at so and so place.” PARRA-PEDROZA stated, “Alright.” CI-2 stated, “I
don’t want to store anything [narcotics proceeds] right now. I don't want to store
anything just in case anything happens [law enforcement raids CI-2's residence].
There's nothing [no narcotics proceeds at CI-2's residence}.”
k. PARRA-PEDROZA asked, “They [law enforcement] didn’t get
you the second time [referring to a prior arrest of Individual B, one of CI-2’s
associates, prior to CI-2's cooperation with law enforcement]?”!5 CI-2 responded,
“No, just them [Individual B and Individual C, who was also working for the Parra-
Pedroza MLO].” PARRA-PEDROZA asked, “Then why did they [Individual B] get
caught [by law enforcement] so fast?... One week [Individual B had been working
1 On or about October 19, 2012, law enforcement confronted Individual B about his
involvement in a money laundering organization. At the direction of agents, CI-2 made up
a story about how Individual B had been caught by law enforcement so that PARRA-
PEDROZA would not suspect CI-2 of working with law enforcement.
65for PARRA-PEDROZA for only one week before he was confronted by law
enforcement]?” CI-2 responded, “That's the problem, they [law enforcement] were
already on the one from this one [gold] store, from a store that would buy, that
would buy dirty [accept narcotics proceeds in the sale of gold] and that’s why they
(law enforcement] followed the idiot [Individual B]. That's why they [law
enforcement] were on him [Individual B], because of the guy from the store. That's
why they [law enforcement] haven't found out [about PARRA-PEDROZA or the
MLO] over here on this side [United States], because he [Individual B] didn’t have
anything [that would tie him to PARRA-PEDROZA or the Mexican-based drug
traffickers] from over here and the one from the store is the one they [law
enforcement] were on [investigating] and the thing is they [Individual B and
Individual C] would go and buy scrap [gold] from him [the gold store that law
enforcement was investigating] every day and that’s why they [law enforcement]
followed him [Individual B].”
1 Cl-2 stated, “I was going to call you a while ago, but I thought,
‘How am I going to call him? How can I fucking locate him”... And I thought
about coming down here, over here [CI-2 considered going to Mexico to reconnect
with PARRA-PEDROZA], but then I said, I'll get there and he's going to say, ‘What
the fuck is he bringing? You know, I’'m not just going to show up like that.”
PARRA-PEDROZA stated, “Yeah, yeah, no. And since, and since everyone [Mexican
drug traffickers and MLO members], um, found out about everything [law
enforcement’s encounter with Cl-2, Individual B, and Individual C in September
66and October 20121]. ‘What happened with the guy [Individual BJ? You know,
‘What happened up there [Individual B's arrest in Chicago}? They [Mexican drug
traffickers} found out [about Individual B’s encounter with law enforcement).
They're [Mexican drug traffickers] going to see you [in Mexico] and say, ‘No
[Mexican drug traffickers would refuse to work with CI-2 because of CI-2’s and
Individual B’s prior encounters with law enforcement].”
m. PARRA-PEDROZA stated, “They [PINEDA SANCHEZ and
Mexican drug traffickers] asked me to look for you.” CI-2 stated, “Yeah, I said, ‘I
feel like trying him {calling PARRA-PEDROZA\.’ But then I said, ‘No, I'm going to
wait until more time passes by because then he’s going to say, ‘Well, what does this
guy want to know about me [CI-2 was concerned that PARRA-PEDROZA would be
suspicious of CI-2 if CI-2 tried to reconnect with him out of the blue]?” PARRA-
PEDROZA stated, “No, no.” CI-2 stated, “Everything was fine, the thing is we [CI-
2, Individual B, Individual C, and PARRA-PEDROZal were all paranoid [because of
recent encounters with law enforcement]. Well, we get scared.” PARRA-PEDROZA
responded, “Well, yeah.” CI-2 stated, “We were just scared.”
n. — CL-2 stated, “I said, ‘I should call him [PARRA-PEDROZAI, it’s
been a while [since CI-2 was encountered by law enforcement], seven, eight months
already passed.” PARRA-PEDROZA stated, “No, well, I was calling you [to resume
their money laundering operation].” CI-2 stated, “I should call this guy [PARRA-
a Prior to Cl-2's cooperation with law enforcement, in September 2012, law
enforcement seized approximately $176,000 from CI-2 during a traffic stop, as CI-2
returned to Chicago after collecting the money from an individual in Kentucky. According
to CI-2, CI-2 had told PARRA-PEDROZA about the seizure at the time it happened.
67PEDROZA], I should go look for him down there {in Mexico]. I said, ‘If I go over
there and he's upset at me, he's not going to let me come back [CI-2 was afraid that
PARRA-PEDROZA would have Cl-2 kidnapped or killed if CI-2 went to Mexico and
found that PARRA-PEDROZA was upset with CI-2 for falling out of touch].”
PARRA-PEDROZA stated, “No.” CI-2 stated, “What if I get there [Mexico], [and
PARRA-PEDROZA says], ‘He's already here, don't let him go.” PARRA-PEDROZA
stated, “He's here.” Cl-2 laughed and stated, “I get scared.”
o. PARRA-PEDROZA stated, “The thing is we [PINEDA
SANCHEZ and PARRA-PEDROZA] had to get a lot of stuff situated down there
arrangements had to be made in Mexico once Cl-2 resumed laundering money for
PARRA-PEDROZA]. Yeah, we had to get a lot of things situated down there
because it wasn’t going to, I mean, (U/I]. And it’s worse now because they got pissed
off again [Mexican drug traffickers were unhappy with CI-2's delay in getting
money down to Mexico]... Right now, right now, right now, I have to go make
them happy again, tell them, ‘Look, I already saw them [CI-2], everything is fine.
There were some problems [law enforcement’s prior encounters with CI-2,
Individual B, and Individual C]. We already took care of that [confirmed that law
enforcement is not investigating CI-2].’ We'll see if they [Mexican drug traffickers]
don't send me to hell {stop using PARRA-PEDROZA to launder narcotics proceeds].”
CL-2 responded, “No, they have to work [drug traffickers need to have their narcotic
proceeds laundered].”. PARRA-PEDROZA stated, “No, they need it [money
laundering service].”
68Pp. Later in the conversation, PARRA-PEDROZA stated, “Yeah,
that’s why I haven’t wanted to go over there [Chicago]. You know how it got really
hot flaw enforcement began investigating members of the Parra-Pedroza MLO].
‘They've [law enforcement] got [Individual D, a member of the Parra-Pedroza MLO]
on a short leash... She came about three or four times and all four times they've
[law enforcement] held her up (when she entered the United States] for an hour or
two and question, after question, after question. That last time she arrived [in the
United States] and when she was about to leave [the United States], they [law
enforcement] pulled her out of the plane. ... And they [law enforcement] started to
ask her, this and that. The officer started to get comfortable . . . [and asked] ‘What
did you come [to the United States] for? ... They got her and they’re on to her [law
enforcement is investigating Individual D]. The last three times she came [into the
United States], they stopped her.... She’s paranoid. She's scared to come. I had
to invite her last time just so, they [law enforcement] wouldn't suspect.”
q. PARRA-PEDROZA stated, “There’s two, there’s two
representatives [PARRA-PEDROZA launders narcotics proceeds for two individuals,
PINEDA SANCHEZ and Individual K]. I don’t know them. There’s one before me,
they're [PINEDA-SANCHEZ and Individual K] the ones that talk to [the Mexican
drug traffickers] . . . one of them [PINEDA-SANCHEZ or Individual K] does talk to
the owner and other one with [Individual GJ.” CI-2 asked, “The one [member] that
used to be before [Individual KJ, is he still with you [provide you with money
laundering contracts}]?” PARRA-PEDROZA answered, “[Individual K] and Botas
69[PINEDA-SANCHEZ], the one that went [traveled to Chicago with PARRA-
PEDROZA to meet with CI-2 in Spring 2012], the skinny one. That's Botas
(PINEDA-SANCHEZ] and you don’t know [Individual Kj.”
r. PARRA-PEDROZA stated, “They're [PINEDA- SANCHEZ and
Individual K] the same ones from before, I mean, they're the same contacts
(PINEDA-SANCHEZ and Individual K receive money laundering contracts from the
same Mexican drug traffickers] but I don’t know them [the drug traffickers]. I
mean there's some ahead of me and one of them [PINEDA-SANCHEZ], [Individual
K] is the one that does know him [Individual G] and Botas [PINEDA-SANCHEZ]
has a middle man, so, um, I will have to talk to them [PINEDA-SANCHEZ and
Individual K] so they can push him forward and I think I would have to get with
one, one day and the other one the other day [PARRA-PEDROZA will arrange for
money couriers working with PINEDA-SANCHEZ to deliver to CI-2 on one day, and
couriers working with Individual K to deliver to CI-2 on another day]. Botas
{PINEDA SANCHEZ] needs to deliver on Monday and [Individual K] on Tuesday.
Like I told you, they
see how they'll do it.”
8. PARRA-PEDROZA stated, “That's why we [PARRA-PEDROZA
and CI-2] were working on the down low [secretly, to avoid detection by law
enforcement], because if another one thousand pesos [$1 million in narcotics
proceeds] come and something bad happens [money seized by law enforcement after
the Parra-Pedroza MLO agrees to launder it]. No, no I don't even think they're
[Mexican drug traffickers] going to ask us [to launder narcotics proceeds] anymore.
70They're probably just going to arrive and, you hand everything back. Houses, cars
[when law enforcement seizes narcotics proceeds, Mexican drug traffickers take the
personal possessions of the person responsible for losing their money].” CI-2 asked,
“They took everything [PARRA-PEDROZA’s possessions, after one of his people lost
over $1 million in June 2012]?” PARRA-PEDROZA responded, “Yeah, even while
business [money laundering operations] was going on... . I haven't been able to
pay them off... . [I]t was a year exactly [June 2012] when it fell [law enforcement
seized $1 million from a member of the Parra-Pedroza MLO]... . It fell.... [A]
woman came and brought them [the narcotics proceeds] down [to Mexico]. They
caught it here [law enforcement seized the narcotics proceeds in the United States].
She said they [law enforcement] stopped her and she was on her way [to
Mexico] when the officer came back and said,
’m going to send you back [deport her
to Mexico].’ I think she must have been so scared she was pale.”
t. CL-2 stated, “Tell them [Mexican drug traffickers] we don't want
them,
don’t want you to be bullshitting if they trip [law enforcement seizes
narcotics proceeds from U.S.-based money couriers]. This is how it is.... If they're
doing bad [being investigated by law enforcement], they're the ones doing bad, not
anyone else [CI-2].”. PARRA-PEDROZA responded, “There’s one [money courier]
that supposedly they had taken away what he had [law enforcement seized
narcotics or narcotics proceeds] and at the end he [money courier] did agree [that he
was responsible for losing the Mexican drug traffickers’ drugs or money]. I think
they even cut his fingers off [to get the courier to confess}. Even I would've agreed.”
ae77. Based on previous and subsequent _consensually-recorded
conversations between PARRA-PEDROZA and Cl-2, controlled collections of
proceeds from various individuals by CI-2 at the direction of PARRA-PEDROZA, my
knowledge of this investigation as a whole, and my training and experience as a
Special Agent, I believe that, during the aforementioned conversation, PARRA-
PEDROZA:
(@) expressed his and PINEDA SANCHEZ's concerns over the time it
was taking CI-2 to ship the gold that Cl-2 purchased with narcotics proceeds to
Refinery A;
(b) explained that the Mexican drug traffickers threaten and
administer physical violence against, and take the personal possessions of,
individuals whom they deem responsible for losing their drug money;
© rejected Cl-2's offer to wire narcotics proceeds to him in Mexico
because he was concerned about pending changes in Mexican law that would make
it easier for law enforcement to detect the true nature of the wired funds;
(d) explained that, after Refinery A received the gold shipments from
CI-2, the company sends payments for that gold to PARRA-PEDROZA in Mexico;
(©) explained that Refinery A falsifies paperwork to make it appear
that PARRA-PEDROZA sold gold to the company’s Mexico-based office to justify the
payments the company sends to PARRA-PEDROZA in Mexico for gold shipments it
receives from CI-2 or other U.S.-based members of the Parra-Pedroza MLO;
72( explained that the PINEDA SANCHEZ and Mexican drug
traffickers use hidden compartments in cars to smuggle narcotics proceeds into
Mexico;
(g) advised that Mexican drug traffickers ask PINEDA SANCHEZ and
PARRA-PEDROZA to give them their laundered narcotics proceeds in U.S. dollars,
rather than Mexican pesos, so that the traffickers can earn even more money when
converting the U.S. dollars to pesos themselves;
(h) stated that Mexican drug traffickers have asked PARRA-PEDROZA
to assist them in laundering narcotics proceeds from Mexico to Columbia;
() discussed his and CI-2's mutual concern about reconnecting with
each other and resuming their money laundering operation following law
enforcement’s known encounters with CI-2, Individual B, and Individual C in Fall
2012; and
@) explained that he launders narcotics proceeds for two different
individuals, PINEDA SANCHEZ and Individual K, and that, going forward, he
would arrange for money couriers working with PINEDA-SANCHEZ to deliver to
CE-2 on one day, and couriers working with Individual K to deliver to CI-2 on
another day.
IX. PARRA-PEDROZA Directs CI-2 to Collect and Launder
Approximately $283,740 in Narcotics Proceeds from CARO (June 25,
2013).
78. On or about June 12, 2018, at approximately 8:57 p.m. — and prior to
CI-2's June 20, 2018, meeting with PARRA-PEDROZA ~ CI-2 exchanged a series of
73BBMs with PARRA-PEDROZA, who was using MLO Device 1. Following this
exchange, agents reviewed the exchange and documented several of the messages.
During this exchange, PARRA-PEDROZA stated, “7737152419. Primo [call Caro
Phone 1 to coordinate collection of narcotics proceeds}.” CI-2 responded, “That was
the one that gave me all the change [referring to the unusually large number of $1
and $5 bills that Individual Q delivered on June 11, 2013]. Tell him no more
change. Tell him.” PARRA-PEDROZA responded, “OK.”
79. On or about June 12, 2013, at approximately 9:43 p.m., CL-2 had a
consensually recorded call with CARO, who was using Caro Phone 1. During this
call, CARO stated, “What's up, primo? They told me to call you so I can see you
(deliver more narcotics proceeds] around nine [9:00 a.m.” CARO and CI-2 agreed
to speak again later.
80. On or about June 16, 2013, at approximately 8:47 p.m., CI-2 had a
consensually recorded call with CARO, who was using Caro Phone 1. During this
call, CI-2 asked, “What time will you be ready [to meet] tomorrow? Is it going to be
at the same place [the location of the June 11 pick-up] or somewhere else?” CARO
responded, “I'll let you know. ... Yeah, let me call over there [to Mexico].” CI-2
stated, “Okay, then give them [CARO’s associates in Mexico] a call and call me and
tell me where to go, and I'll give you a call when I'm around there.”
81. On or about June 17, 2013, at approximately 2:03 p.m., CI-2 had a
consensually recorded call with CARO, who was using Caro Phone 1. During this
call, CI-2 asked, “Are you ready or not?” CARO replied, “They [CARO’s associatesin Mexico] haven't said anything over there.” CI-2 stated, “Oh, okay. Call the man
[CARO's associate] and see what he says, okay?” CARO responded, “Alright.”
82. On or about June 17, 2013, between approximately 2:05 p.m. and 2:19
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, Cl-2 stated, “The primo [CARO] says they
haven't advised him from over there [Mexico]. Call them [CARO’s associates in
Mexico] and see what they say.” PARRA-PEDROZA replied, “I already told them
but they want payment [PARRA-PEDROZA still owes CARO’s associates the money
from Individual Q's delivery of $98,999 on June 11, 2013).""8
83. On or about June 24, 2013, at approximately 1:49 p.m., CI-2 had a
consensually recorded call with CARO, who was using Caro Phone 1, During this
call, CARO stated, “Take the five-seven [Interstate 57] and get off on a hundred and
fifty-nine (159th Street] east and I'll meet you there [to deliver narcotics proceeds].”
CL-2 stated, “No, the other day I went and met with one [money courier] around,
they fixed my car [delivered narcotics proceeds] by the Home Depot. It’s not the
same one [same drug trafficker/money courier]?” CARO responded, “No, no, ub, at
the Home Depot? No, no. You come this way.” CI-2 stated, ‘I'm going to go close
by, not all the way up there. ... Did they tell you how many miles [total amount of
narcotics proceeds to be delivered]?” CARO responded, “Uh, about two hundred
miles [$200,000].”
1 At the time of this call, agents had yet to ship the gold purchased with the money
delivered by Individual Q on June 11, 2013. See {4 67-72, supra. Soon after this exchange,
PARRA-PEDROZA and CI-2 met in Las Vegas to discuss, among other things, Cl-2’s delay
in shipping gold. See § 75-77, supra.
7584. On or about June 25, 2013, between approximately 12:11 p.m. and 1:24
pam., CI-2 had a series of consensually recorded call with CARO, who was using
Caro Phone 1. During these calls, CARO and CI-2 arranged to meet each other in
the parking lot of a Home Depot located near the intersection of 120th Street and
Cicero Avenue in Alsip, Illinois, at approximately 1:24 p.m. that day. During the
last of these calls at approximately 1:24 p.m., CARO asked, “You're the one in the
red truck?” CI-2 responded, “Yes.” CARO stated, “There's a [suspicious] car in
front.” CI-2 stated, “Just move to the side. It’s [the suspicious car] one of the ones
that work here [a Home Depot employee vehicle]. Just go to the side. Just come to
the side.”
85. On or about June 25, 2013, at approximately 1:24 p.m., CI-2 and
CARO met in the parking lot of the Home Depot located at 12000 S. Cicero Avenue
in Alsip. Prior to this meeting, agents outfitted CI-2 with a concealed audio and
video recording device and searched CI-2 and his/her vehicle for large amounts
money and contraband, with negative results. CI-2 traveled under constant
surveillance from a staging location to the meeting. Surveillance observed CARO
arrive in a car registered in his name, park next to CI-2’s vehicle, exit his car,
retrieve a blue Coleman cooler from his car, and hand the cooler to CI-2, who placed
the cooler into the back of his/her vehicle. During this meeting:
a. CARO asked, “So that one [suspicious person/vehicle] that is in
front are the ones that work here [employees at Home Depot]?” CI-2 responded,
76“Yes, they're the ones that work here. I was going to move later, but no, they're the
ones that work here.”
b. Cl-2 asked, “How much?” CARO responded, “It's two-eighty
{$280,000].” CI-2 asked, “Two-cighty?” CARO responded, “Yes, sir.” CI-2 asked,
“Does it {narcotics proceeds] come well measured [fully counted]?” CARO stated,
“Bill for bill (this delivery is correctly counted] primo.” CI-2 continued, “Because the
other [the June 11, 2014, narcotics proceeds delivery by Individual Q], that same
one that I picked up in. ...” CARO stated, “West Chicago.” CI-2 continued, “. . .
that I picked up in West Chicago [the Individual Q delivery], came up real short.”
CARO stated, “That's fucked up.” CI-2 stated, “He gave me ninety-eight [$98,000],
ninety-nine [$99,000], almost ninety-nine. He was one dollar short to make ninety-
nine [$98,999].” CARO stated, “I already told you [this delivery is correctly
counted].” CI-2 stated, “Yes. He [Individual Q] was short one dollar for ninety-nine
[S98,999].” CARO stated, “Well, okay primo, I counted that [today’s delivery] myself
last night. That’s what I did all fuckin night.” CI-2 responded, “Okay...”
86. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved a blue Coleman cooler
containing approximately $283,740 in cash from CI-2’s vehicle. Agents then
transported the money to the HSI Chicago Field Office, where a canine trained to
detect the odor of narcotics sniffed the money and alerted positive for the presence
of narcotics.
187. Onor about June 25, 2013, at approximately 5:00 p.m., CI-2 exchanged
a series of BBMs with PARRA-PEDROZA, who was using MLO Device 1. According
to CI-2, during this exchange, CI-2 provided PARRA-PEDROZA with the final count
of the money picked up from CARO.
88. On or about June 27, 2013, using six of the shipping labels provided by
PARRA-PEDROZA, agents sent to Refinery A approximately 6,622 grams of 24-
Karat gold, which agents had purchased with approximately $277,892.37 of the
proceeds obtained from CARO. Agents also enclosed in this shipment a Refinery A
packing list that identified the shipping company as “Chicago Gold” and described
the contents of the boxes as containing a total of 6,622 grams of 24-Karat gold.
According to FedEx records, this shipment arrived at Refinery A on or about June
28, 2013.
89. On or about July 1, 2013, between approximately 2:48 p.m. and 5:06
p.m., Cl-2 exchanged a series of consensually captured BBMs with PARRA-
PEDROZA, who was using MLO Device 1. During this exchange, CI-2 stated,
“Close at 1260 [CI-2 purchased gold at the current fair market value of $1,260 per
ounce].” PARRA-PEDROZA replied, “OK.” CI-2 stated, “6622.05 is what I sent you
that day [CI-2 purchased 6,622 grams of 24 Karat gold at the current fair market
value of $1,260 per ounce, using narcotics proceeds collected from CARO on June
25, 2013].” PARRA-PEDROZA asked, “The 280 [confirming that CI-2 is referring to
the $283,740 that CI-2 received from CARO]?” CI-2 responded, “Yes.”
78X. PINEDA SANCHEZ and PARRA-PEDROZA Direct CI-2 to Collect and
Launder Approximately $139,470 in Narcotics Proceeds from ISAIAS
(July 10, 2013).
90. On or about July 9, 2013, at approximately 12:06 p.m., CI-2 placed a
consensually recorded call to CASMIRO ISAIAS-PADILLA, who was using
telephone number (773) 459-4608 (‘Isaias Phone 1’).!9 ‘This call took place
approximately one minute after CI-2 had missed a call from Isaias Phone 1. During
this call, ISAIAS stated, “I wanted to talk to Daniel [CI-2’s codename, provided by
PARRA-PEDROZAl, primo, on behalf of [Individual K, codename to vouch for
ISAIAS's trustworthiness.” CI-2 responded, “Tell me.” ISAIAS asked, “Can I see
you, so I can give you some {narcotics proceeds]?” Cl-2 asked, “Are you the same
one [money courier] I talked to yesterday or are you someone else?” ISAIAS stated,
“No, I, it’s the first time I've called you, primo.” CI-2 and ISAIAS agreed to speak
again later.
91. On or about July 9, 2013, at approximately 12:14 p.m., CI-2 had a
consensually recorded call with ISAIAS, who was using Isaias Phone 1. During the
18 Agents identified ISAIAS as follows: As discussed below, on or about July 9 & 10,
2013, CL-2 had several consensually recorded calls with the user of Isaias Phone 1. During
these calls, the user of this phone arranged to meet Cl-2 in person at the Wal-Mart located
at 7050 S. Cicero Avenue, Chicago, Illinois, for the purpose of delivering narcotics cash
proceeds, on July 10, 2013, at approximately 5:03 p.m. Following these calls, surveillance
observed Cl-2 meet with, and obtain proceeds from, a man at the designated time and
place. As discussed below, agents conducting surveillance subsequently viewed a Wisconsin
driver's license photograph of “Casimiro Isaias-Padilla,” and positively identified ISATAS as
the individual who delivered narcotics proceeds to Cl-2 on July 10, 2013. In addition, prior
to this July 10th meeting, agents outfitted CI-2 with a concealed audio recording device,
which captured ISAIAS's voice. After reviewing the recording of the July 10th meeting,
agents compared the voice of the man with whom CI-2 met to the voice of the man who was
using Isaias Phone 1, in numerous, consensually recorded calls with Cl-2, and determined
that ISAIAS was the user of Isaias Phone 1.
79call, CI-2 asked, “Yeah, how many miles are on the car you want us to fix for you?”
ISAIAS responded, “Oh, I think, I think it was a hundred-fifty [$150,000], primo.”
C12 stated, “Let me report it over there [call PARRA-PEDROZA] first because they
already filled it up [CI-2 is already in possession of a large amount of narcotics
proceeds] over here and I have to check, because I don’t have enough room in the
garage for another car. So let me call over there and I'll call you back.”
92. On or about July 9, 2013, between approximately 1:09 p.m. and 1:13,
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. Following this exchange, agents reviewed this exchange and
documented several of the messages. During this exchange, PARRA-PEDROZA
stated, “Tomorrow they are going to give you 140 [$140,000]. The one [ISAIAS] that
you [CI-2] told that you had a lot on your hands.” CI-2 responded, “OK.”
93. On or about July 9, 2013, at approximately 1:25 p.m., CI-2 had a
consensually recorded call with ISAIAS, who was using Isaias Phone 1. During this
call, CI-2 asked, “Where are you, more or less, so I can come by? They told me not
until tomorrow, or the day after, but I need to call you. Just tell me and I'll come
by.” ISAIAS responded, “Okay, right there by Archer and Kedzie. ... [I]f you want
it can be today, but I can't right now, I'm busy. Let's see, I'll be ready by four, thirty
[4:30 p.m.].” CL-2 stated,
“Okay, then let me give you a call because these guys
[PARRA-PEDROZA] are driving me crazy over there. Okay, I'll give you a call
tomorrow and I'll let you know where we can meet around there.” ISAIAS replied,
“All right, okay, that’s fine.”
8094. On or about July 9, 2013, between approximately 3:40 p.m. and 3:42
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA asked, “What did you
agree to with them [ISAIAS and a second money courier]?” CI-2 responded,
“Tomorrow T'll see them. First the 200 [$200,000] and later the 140 [$140,000 from
ISAIAS].” PARRA-PEDROZA stated, “OK.”
95. On or about July 10, 2013, between approximately 12:47 p.m. and 2:35
p.m,, CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA asked, “What's up?” CI-2
replied, “Nothing, the one of 140 [ISAIAS] has time until 4:30 [ean meet to deliver
narcotics proceeds before 4:30 p.m.” PARRA-PEDROZA asked, “But are they set?”
Cl-2 replied, “Yes.” PARRA-PEDROZA stated, “Hey the 140 one, make his
appointment close, not too far, so you won't risk it [meet ISAIAS in close proximity
to CI-2's office to minimize the risk of being stopped by law enforcement].”
96. On or about July 10, 2013, between approximately 4:23 p.m. and 5:03
p.m,, Cl-2 had a series of consensually recorded calls with ISAIAS, who was using
Isaias Phone 1. During these calls, ISAIAS and CI-2 arranged to meet in the
parking lot of a Walmart located near the intersection of 72nd Street and Cicero
Avenue in Chicago at approximately 5:03 p.m.
97. On or about July 10, 2013, at approximately 5:03 p.m., CI-2 and
ISAIAS met in the parking lot of the Walmart located at 7050 S. Cicero Avenue in
Chicago, Illinois. Prior to this meeting, agents outfitted CI-2 with a concealed audio
81recording device and searched CI-2 and his/her vehicle for large amounts money
and contraband, finding none. CI-2 traveled under constant surveillance from a
staging location to the meeting. Surveillance agents videotaped this meeting and
observed ISAIAS arrive in a car, park next to CI-2's vehicle, exit his car, retrieve a
tan “Justin Boots” cooler bag, and place the cooler into the back of CI-2’s vehicle.
During this meeting:
a, _ ISAIAS asked, “Is everything alright or what [is it safe to hand
off the narcotics proceeds at this location]?” CI-2 responded, “Get out [of the
vehicle] so that they [law enforcement] don't look at us, like we're making an
exchange real quick. Grab the bag slowly and drop it over here, on the back [inside
CL2 vehicle] here. Put it over here. It’s all nicely packed [organized and counted],
right?” ISAIAS responded, “Yes.”
b. CL-2 asked, “Everything, there are a hundred forty [$140,000],
right? Well measured [carefully counted?” ISATAS responded, “A hundred forty
[$140,000].” CI-2 stated, “Yes, because, when you don’t measure it well [deliver the
agreed upon amount] then you have to go to the office [accompany CI-2 to his/her
office] and I have to verify them there [count the money together].” ISAIAS
responded, “Yes.”
98. Following this meoting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved from CI-2's vehicle a tan
“Justin Boots” cooler bag containing approximately $139,470 in cash. Agents then
transported the money to the HSI Chicago Field Office, where a canine trained to
82detect the odor of narcotics sniffed the money and alerted positive for the presence
of narcotics.
99. On or about July 10, 2013, between approximately 5:53 p.m. and 6:28
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, CI-2 stated, “I am on my way back.” PARRA-
PEDROZA asked, “OK. All good?” CI-2 responded, “Yes.” PARRA-PEDROZA
asked, “How much did they sing for [deliver]?” CI-2 responded, “140.0 [$140,000].”
100. On or about July 10, 2013, between approximately 8:19 p.m. and 9:18
p.m, CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA asked, “OK. What's up?”
CE-2 responded, “That's what I am doing. Verifying [counting the money].”
PARRA-PEDROZA stated, “OK.” CL-2 stated, “505 short.” PARRA-PEDROZA
asked, “No. How much are the tickets [how much money was delivered]?” CI-2
responded, “139495 ($139,495, which was the amount that agents had counted prior
to an official money count].” PARRA-PEDROZA asked, “But the size [denomination
of the bills delivered] is ok? There isn’t any garbage [small bills such as $1 and $5
bills]?” CI-2 responded, “Little this one.” PARRA-PEDROZA stated, “If it [gold] all
comes tomorrow, Diego [PINEDA-SANCHEZ] will sell.” CI-2 responded, “Yes.”
101. On July 12, 2013, between approximately 9:49 a.m. and 10:32 a.m., CI-
2 exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO Device
1. During this exchange, Cl-2 stated, “Send me the guides [Fed Ex labels pre-
addressed to Refinery A] so I can get away early.” PARRA PEDROZA responded,
83“OK. I already requested them.” CI-2 stated, “Let me know when you send them.”
PARRA PEDROZA stated, “Yes. What is your mail? Yes. They're gone.”
102. On or about July 12, 2013, at 10:31 am., the UC Email Account
received an email from Parra-Pedroza Email Account 1. This email was entitled,
“Fwd: [Refinery A] FedEx Shipping Label.” The email included two attachments,
including ten prepaid FedEx labels addressed to Refinery A and a Refinery A
packing list.
103. Between about July 12, 2013 and about July 15, 2013, using three of
the shipping labels provided by PARRA-PEDROZA, agents sent to Refinery A
approximately 3,248 grams of 24-Karat gold, which agents had purchased with
approximately $137,033 of the proceeds obtained from ISAIAS. Agents also
enclosed in these shipments a Refinery A packing list that identified the shipping
company as “Chicago Gold” and described the contents of the boxes as containing a
total of approximately 3,248 grams of 24-Karat gold. According to FedEx records,
these shipments arrived at Refinery A between about July 15, 2013 and about July
16, 2013.
104. On or about July 15, 2013, between approximately 11:19 a.m. and
11:42 a.m., Cl-2 exchanged a series of BBMs with PARRA-PEDROZA, who was
using MLO Device 1. During this exchange:
a. PARRA-PEDROZA asked, “How much [gold] did you send? Just
a kilo [1000 grams]. They [narcotics traffickers associated with ISAIAS] are going
to choke me.” CI-2 responded, “More than one [CI-2 purchased more than one
84EE |“
| e @
kilogram of gold with the ISAIAS money], later I will send you the rest.” PARRA-
PEDROZA stated, “Why didn't you tell me? I committed myself. When you talk to
me, you need to tell me the truth. Everything, alright? You lie to me, I relay the
lies and I'm the one who gets it.” Cl-2 responded, “Yes, I brought everything [all of
the gold], but this guy [CI-2’s putative gold supplier] is clueless, I'm telling you
what he's telling me.”
b. PARRA-PEDROZA stated, “Tell him, we are going to get in
trouble.” CI-2 responded, “La refi (CI-2's putative gold supplier], it's easy for him to
say tomorrow because he thinks the metal (gold] goes directly to you [to PARRA-
PEDROZA in Mexico}, doesn’t know it goes all the way over there [to Refinery A in
Florida].”. PARRA-PEDROZA stated,
No problem if it’s late at least a day. It's
when they lie, I would have problems.” CI-2 stated, “OK. I will be careful so it won't
happen again.”
« PARRA-PEDROZA stated, “Later I'm going to face them
everything [all of the gold] is being sent. Arrive tomorrow. How much was sent
exactly?” CI-2 responded, “Let me check my book, will let you know. 1062 [1,062
grams of gold].”
105. On or about July 16, 2013, between approximately 8:24 a.m. and 12:02
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA asked, “Already sent the
|
{narcotics traffickers associated with ISAIAS] and tell them that it was a lie that
rest [balance of the gold purchased with narcotics proceeds from ISAIAS]?” CI-2replied, “I already sent it [a second FedEx shipment containing approximately 2,186
grams of gold sent to Refinery A on or about July 15, 2013]. Close 3,248.76 of fine
for $1,293 [CI-2 purchased 3,248.76 grams of 24 Karat gold at the current fair
market value of $1,293 per ounce, using narcotics proceeds collected from ISAIAS].”
PARRA-PEDROZA responded, “OK.”
XI. PINEDA SANCHEZ and PARRA-PEDROZA Instruct CI-2 to Collect
and Launder Narcotics Proceeds from OCHOA (July 16, 2013).
106. On or about July 10, 2013, at approximately 1:25 p.m., CI-2 had a
consensually recorded call with JOSE HERNANDEZ OCHOA, who was using
Ochoa Phone 1.° During this call, OCHOA stated, “I'm talking to Daniel, right?”
CL-2 responded, “Okay, yes, 'm Daniel [to vouch for Cl-2's trustworthiness].”
OCHOA stated, “Yeah, I'm calling on behalf of Roberto [code name to vouch for
OCHOA’s trustworthiness], sir.”
107. On or about July 10, 2013, at approximately 1:27 p.m. CI-2 had a
consensually recorded call with OCHOA, who was using Ochoa Phone 1. During the
call, OCHOA said, “If you [CI-2] want, I can free up so can see you [meet to deliver
2 Agents identified OCHOA as follows: As discussed below, on or about July 16, 2013,
C12 had a consensually recorded call with the man who was using Ochoa Phone 1. During
this call, the man using Ochoa Phone 1 arranged to meet CI-2 in person at the Portillo's at
the intersection of Roosevelt Road and Des Plaines Avenue on July 16, 2013, at
approximately 1:10 p.m., for the purpose of delivering narcotics cash proceeds. Following
this phone call, surveillance observed CI-2 meet with, and obtain proceeds from, a man at
the designated time and place. Agents conducting surveillance subsequently viewed an
Oregon State Driver's License photograph of “Jose Hernandez Ochoa,” and positively
identified OCHOA as the individual who delivered narcotics proceeds to CI-2 on duly 16,
2013. In addition, prior to this July 16 meeting, agents outfitted CI-2 with a concealed
audio recording device, which captured OCHOA's voice. After reviewing the recording of
the July 16 meeting, agents compared the voice of the man with whom CI-2 met to the voice
of the man who was using Ochoa Phone 1 in numerous, consensually recorded calls with Cl-
2, and determined that OCHOA was the user of Ochoa Phone 1.
86narcotics proceeds).” CI-2 asked, “Okay, uh, are you the one with uh, two tickets
[$2,000]? OCHOA responded, “Yeah, one, one with, with, with thirty pesos
{830,000}.”
108. On or about July 11, 2013, between approximately 10:09 a.m. and
12:24 p.m., Cl-2 exchanged a series of BBMs with PARRA-PEDROZA, who was
using MLO Device 1. During this exchange:
a. CIL-2 stated, “I never answered the one who called me; he is one
of the little ones [a money courier with a small amount of narcotics proceeds].”
PARRA-PEDROZA stated, “It’s 150 [$150,000].” CI-2 stated, “Yesterday [July 10,
2013] he [OCHOA] told me 30 [$30,000].” PARRA-PEDROZA stated, “It’s now 150
[$150,000], it's urgent to me, help me out.” CI-2 stated, “I called, it is 30 [$30,000].”
PARRA-PEDROZA responded, “It is another one [a different money courier who
would deliver $150,000 in narcotics cash proceeds]; let me tell them to redial [call
CI-2 again].” CI-2 stated, “He [OCHOA] is the only one who has called.”
b. PARRA-PEDROZA asked, “How are you going?” CI-2
responded, “Making the metal order [purchasing gold with narcotics proceeds].”
PARRA-PEDROZA asked, “And has the one [a different courier of narcotics cash
proceeds} for the 100 [$100,000] called you?” CI-2 responded, “No he [$100,000
money courier} has not called just the one [OCHOA] for the 30 [$30,000].”
109. On or about July 12, 2013, at approximately 1:28 p.m., CI-2 had a
consensually recorded call with PINEDA SANCHEZ, who was using Target Device
6. During this call
87a. PINEDA SANCHEZ stated, “Listen, this is Carlos’ [PARRA-
PEDROZA's] associate, from this side over here [Mexico]. ... ‘They [OCHOA] have
been calling you . . . to see if you can check their car [collect narcotics proceeds], but
that you haven't been able to meet with them [OCHOA].” CI-2 responded, “It's
because they [OCHOA] have some small ones, a thirty [$30,000 of narcotics
proceeds} and that's the only one [OCHOA] that has call me. The one that had
thirty dollars [$30,000], okay?” PINEDA SANCHEZ stated, “Yes. He [OCHOA]
wanted to refinance a car for thirty dollars [launder $30,000].”
b. Cl-2 stated, “It's best if they [OCHOA] have it [narcotics
proceeds], it's best if he [OCHOA] keeps it and I'll pick it up from him [OCHOA] on
Monday [July 15, 2013].” PINEDA SANCHEZ stated, “Listen, the one that has very
little [OCHOA], the one that wants the refinance for thirty [launder $30,000], what
do I tell him OCHOA?” CI-2 responded, “Well, I don't know what to tell him
{OCHOA}. He [OCHOA] already called me like two, three times. Uh, well, Monday
[collect narcotics proceeds from OCHOA on July 15, 2013].”
c CI-2 stated, “You need to tell Carlos [PARRA-PEDROZA] we
have to put a person [a middle man] to pick up from the ones that have a little
[smaller amounts of narcotics proceeds]. It’s because I'm really fucking paranoid
with the small ones [couriers who deliver small amounts of narcotics proceeds}. One
with fifteen [$15,000] called me, one with forty [$40,000], one with thirty [$30,000],
and that one [OCHOA], that one. So, you gotta’ fear those, I rather not pick up
from those so I won't get into any problems [with law enforcement}.”. PINEDA
88SANCHEZ responded, “Oh, okay but those [OCHOA and other couriers with small
amounts of narcoties proceeds] are very secure. It’s no problem... . Yes, they're,
those are confirmed from over here and all [vetted for connections to law
enforcement by Mexican members of the MLO].”
d. PINEDA SANCHEZ stated, “Oh, I’m telling you the ones that
have very little miles [couriers who deliver small amounts of the narcotics
proceeds]... Have them agree on your time and wherever you want [to deliver
narcotics proceeds]. ... You tell them, ‘At so and so time and here.” CI-2 stated,
“That's what I tell them [money couriers]. ... I always tell them, ‘Do you have time
right now or early tomorrow?’ ‘Oh, no I can until 3:00 in the afternoon.’ And then
they report over there [to their Mexican bosses] and say that I sond them to hell,
that I don’t want to pick up [narcotics proceeds] from them.” PINEDA SANCHEZ
stated, “Yeah, what they're [OCHOA and his bosses] telling us over here is that
you're telling them, ‘Tl call you later, I'll call you later, Tl call you later.’ That's it’s
been like that since yesterday.”
e. PINEDA SANCHEZ stated, “So they [OCHOA and his bosses]
just told me, ‘Listen, just tell me if you're going to pick it up or not, otherwise I'll go
somewhere else [to launder narcotics proceeds}.’ You know.” CI-2 stated, “Yeah
and that’s what they [OCHOA and his bosses] should say, the truth. That's my
word. Why wouldn’t I pick it [narcotics proceeds] up if that’s how we're paying for
lunch [CI-2 receives a percentage of the amount of money he/she launders for
PARRA-PEDROZAJ. . . .. It's not like I'm only going to want one [shipment of
89narcotics proceeds]. For me, the more [narcotics proceeds] there is, the better for
me, But they (drug traffickers and money couriers] won't accommodate my
schedule. Uh, and you sce, like that’s very little [narcotics proceeds], like the one
from here [$30,000 from OCHOA, it’s not worth fucking losing my time with him.”
PINEDA SANCHEZ stated, “No, of course, to be waiting there. If they [couriers]
call you and tell you, ‘I have fifteen [$15,000], come over here.’ Wherever you want,
you move them [couriers] wherever you want, at the time you want. If they can't,
well then, ‘No, I [CI-2] can't move’ Right.” CI-2 stated, “Okay, well, then I'll do it,
like that.”
£ PINEDA SANCHEZ stated, “The one that told you right now he
has thirty [OCHOA, who had $30,000 to launder], if you want to call him, tell him,
‘Listen, you [OCHOA] go the receipt [narcotics proceeds] bring it over here.’ If he
doesn't want to [deliver the narcotics proceeds to CI-2], ‘That's fine, call me [CI-2]
when you [OCHOA] get money [narcotics proceeds]. . .. All the small ones [couriers
with small amounts of narcotics proceeds] . . . have to accommodate your schedule
and your place.”
8 CI-2 stated, “Like right now, I’m sending you [PINEDA
SANCHEZ and PARRA-PEDROZA] the mail [gold purchased with narcotics
proceeds], so I can't leave this so I can go meet with someone [a courier] who has
only thirty pesos [$30,000], so I need them [couriers] to accommodate to my
schedule and not to be calling over there [Mexico], telling you [PINEDA SANCHEZ
and PARRA-PEDROZA] I don’t want to take care of them [collect narcotics proceeds
90for laundering." PINEDA SANCHEZ said, “Tell them [money couriers], ‘All the
way over here.’ [If the drug trafficker and money courier says,] ‘No, I can't come,’
[then CI-2 should say], ‘Well, good bye, take care.” CI-2 stated, “Then as soon as
they [money couriers] call me, I'm going to tell them, ‘You know what? Come over
right now at so and so place.” PINEDA SANCHEZ stated, “Yeah, that’s better.”
h. PINEDA SANCHEZ asked, “Hey, and you don't have their
{money couriers] phone number so you can call them?” CI-2 responded, “Okay, I
have their numbers. Let me call them and tell them to come over here. If they say
‘no,’ then TIl be like, ‘You know what? They don't want to come over here.”
PINEDA SANCHEZ stated, “Yeah, if they don’t want to [come to CI-2 as directed],
let us [PINEDA SANCHEZ and PARRA-PEDROZA] know.”
i, PINEDA SANCHEZ stated, “See if you can call the one
[OCHOA] with the miles [$30,000].” CI-2 stated, “I’m going to call him right now.
Okay, as soon as I pull over, I'll call him [OCHOA] and see what he tells me. So we
can set something up [a time and place for OCHOA to deliver narcotics proceeds].”
PINEDA SANCHEZ stated, “Thank you. Talk to you later.”
110. On or about July 16, 2013, between approximately 12:02 p.m. and 1:52
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA wrote, “Pick up the call
from the guy [OCHOA] of the 30 [$30,000]. ... That same guy [OCHOA] going to
bring 200 [$200,000] tomorrow [to be laundered]. We are in trouble.... Are you in
contact with him [OCHOA]?” CTI-2 stated, “I just contacted him [OCHOA] and told
91him T'm en route. These guys are liars, they tell me one thing and tell you
something else, I've been ready [to receive the narcotics proceeds] since the
morning. I'm on my way back, this primo [OCHOA] just arrived.” PARRA-
PEDROZA stated, “Ok. With how much {narcotics proceeds from OCHOA]?” CI-2
responded, “30 [$30,000].”
111. On or about July 16, 2018, at approximately 12:56 p.m., CI-2 had a
consensually recorded call with OCHOA, who was using Ochoa Phone 1, During
this call, OCHOA and CI-2 agreed to meet at approximately 1:10 p.m. in the
parking lot of a restaurant located at 7740 West Roosevelt Road in Forest Park,
Ilinois.
112. At approximately 1:11 p.m, Cl-2 met with OCHOA in a parking lot
located at 7740 West Roosevelt Road in Forest Park. Prior to this meeting, agents
outfitted CI-2 with a concealed audio recording device and searched CI-2 and
his/her vehicle for large amounts money and contraband, and found none. CI-2
traveled under constant surveillance from a staging location to the meeting.
Surveillance observed OCHOA exit his vehicle with a black bag and enter the rear
passenger side door of CI-2's vehicle. During this meeting:
a, CL-2 stated, “Just throw it [the backpack] in the back of my
truck.” OCHOA stated, “Let me, the thing is I have a little backpack. Um, um why
don't we take a little drive and you can leave me over there and I'll walk back.” CI-
2 stated, “
No, just throw it in the back there. You got it [the money] there [in the
backpack]?” OCHOA responded,
‘eah.”
92be OCHOA stated, “Yes. Let’s go [drive to avoid drawing suspicion]
if you want.” CI-2 stated, “Okay, just throw it in the back and close it and you can
stay behind talking [to avoid drawing suspicion].... Then just throw it in the back
of my truck on your own, back there. Yeah, just throw it on the seat and I'll fix it
right now [take the narcotics proceeds out]. Yeah, yeah, just leave it like that so it
doesn't look too bad.” OCHOA asked, “Huh?” Cl-2 stated, “Just leave it on the seat,
on the floor and I'll fix it later. There's thirty [$30,000], right?” OCHOA responded,
“Yes.”
c. CL-2stated, “They had told me you were going to bring another
two [$200,000] more.” OCHOA stated, “I think, they haven't told me.... Yeah,
they haven't told me yet.” CI-2 stated, “Yeah, because I didn’t want to come for that
[$30,000], because it’s very little. It’s very little, so then they told me, ‘Go, go, he'll
be taking another two pesos [$200,000] later.”
a. CI-2 asked, “Do you deal with the money or the other stuff
[narcotics]?” OCHOA asked, “Huh?” CI-2 stated, “I only deal with the money.”
OCHOA stated, “No, well, me too, sometimes I... .” CI-2 stated, “You too. Yeah,
yeah, that’s what...” OCHOA interrupted, “I’m going to open the hood right now
[to make their meeting appear less conspicuous].” CI-2 stated, “Go ahead now.
Just go, take off right now and I'll head out afterwards, yeah.”
113. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents recovered a blue and white plastic bag
containing approximately $29,990 in cash. Agents then transported the money to
93,the HSI Chicago Field Office, where a canine trained to detect the odor of narcotics
sniffed the money and alerted positive for the presence of narcotics.
114. At approximately 4:11 p.m., Cl-2 sent a BBM message to PARRA-
PEDROZA, who was using MLO Device 1. CI-2 stated, “I won't be able to make it to
the refinery [to purchase gold]. Put me down for 29990 [OCHOA delivered $29,990
in narcotics proceeds].”
115. Prior to the July 16, 2013, meeting with OCHOA, on or about July 12,
2013, CI-2 received an email from PARRA-PEDROZA, attaching multiple
preprinted FedEx “Priority Overnight” shipping labels addressed to Refinery A in
Florida and a Refinery A shipping form called a “packing list.” On or about July 18,
2013, using the s
ipping labels previously provided by PARRA-PEDROZA, agents
sent to Refinery A via Fed Ex approximately 22 ounces of gold bars, which agents
had purchased with approximately $28,894.80 of the proceeds obtained from
OCHOA. Agents also enclosed in this shipment the Refinery A packing list that
identified the shipping company as “Chicago Gold” and described the contents of the
box as 684.28 grams of 24 karat gold. According to FedEx records, this shipment
arrived at Refinery A on July 19, 2013.
116. On or about July 19, 2013, between approximately 12:36 p.m. and 2:32
p.m., CI-2 exchanged BBMs with PARRA-PEDROZA, who was using MLO Device 1.
During this exchange, CI-2 wrote, “I just sent you the mail (gold purchased with
OCHOA’s narcotics proceeds}. Close 684.28 [grams] the fine [gold] for $1295 [CI-2
arranged for the gold to be sold at $1,295 per ounce]. Willy [PARRA-PEDROZA],
94where are you at? Why don’t you answer?” PARRA-PEDROZA replied, “Just
arrived.”
XII, PARRA-PEDROZA Directs CI-2 to Collect and Launder
Approximately $200,780 in Narcotics Proceeds from CUEVAS (July
24, 2013).
117. On or about July 17, 2013, between approximately 9:34 p.m. and 9:41
p.m., CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using
MLO Device 1. During this exchange, PARRA-PEDROZA stated, “Primo [HECTOR
CHAVEZ CUEVAS#!] tried to contact you and you didn’t answer. Different
{courier].”22 CI-2 responded, “Yes they [CUEVAS] tried to contact me, I thought it
was the same person [a money courier who had previously arranged to deliver
narcotics proceeds to CI-2].” PARRA-PEDROZA stated, "No someone else. ‘The
other [money courier] was caught with no money [encountered by law enforcement},
everything is good. Call back [CUEVAS] you didn’t answer. . .. For real, contact
them, so I could reason over here [arrange the delivery of narcotics proceeds with
2 Agents identified HECTOR CHAVEZ CUEVAS as follows: As discussed below, on or
about July 24, 2013, CI-2 had a consensually recorded call with the man who was using
(815) 295-7588 (‘Cuevas Phone 1"). During this call, the man using Cuevas Phone 1
arranged to meet CI-2 in person at the parking lot of a Sam’s Club located at 321 South
Larkin in Joliet, Minois on July 16, 2013 at approximately 3:00 p.m., for the purpose of
delivering narcotics cash proceeds. Following this phone call, surveillance observed Cl-2
meet with, and obtain proceeds from, a man at the designated time and place. Agents
conducting surveillance subsequently viewed an Illinois State Driver's License photograph
of “Hector Chavez Cuevas,” and positively identified CUEVAS as the individual who
delivered narcotics proceeds to CI-2 on July 24, 2013. In addition, prior to this July 24
meeting, agents outfitted CI-2 with a concealed audio recording device, which captured
CUEVAS's voice. After reviewing the recording of the July 24 meeting, agents compared
the voice of the man with whom CI-2 met to the voice of the man who was using Cuevas
Phone 1 in numerous, consensually recorded calls with CI-2, and determined that CHAVEZ
CUEVAS was the user of Cuevas Phone 1.
% ‘Toll records show that, on July 17, 2013, at approximately 9:28 p.m., CI-2 received
two telephone calls from Cuevas Phone 1, which Cl-2 did not answer.Individuals E’s Mexican associates)... . They [CUEVAS's associates] told me now.
Please.” CI-2 responded, “Ok. I will contact [CUEVAS].”
118. On or about July 17, 2013, at approximately 9:50 p.m., CI-2 had a
consensually recorded call with HECTOR CHAVEZ CUEVAS, who was using
Cuevas Phone 1. During the call, CUEVAS stated, “Yes, Daniel [codename that
PARRA-PEDROZA provided to vouch for CUEVAS's trustworthiness}, on behalf of
Raul. He [PARRA-PEDROZA] told me to call you.” CI-2 stated, “Okay, uh, do you
know how many miles are on the car he wants me to fix (the amount of narcotics
proceeds that CUEVAS will deliver]” CUEVAS responded, “Yes, he told me it was
something like a hundred and five [$105,000].”
119. Between approximately 9:55 p.m. and 9:58 p.m., CI-2 exchanged a
series of BBMs with PARRA-PEDROZA, who was using MLO Device 1. During this
exchange, CL-2 stated, “Okay. I contacted them [CUEVAS], will be available at 2
afternoon.” PARRA-PEDROZA responded, “Okay. Its 200 [$200,000 that CUEVAS
will deliver to CI-2], I think. Did you make arrangements [to receive the narcotics
proceeds].” CI-2 stated, “They [CUEVAS] said 100 [$100,000}.” PARRA-PEDROZA
responded, “Okay.”
120. On July 22, 2018, at approximately 11:23 am. CI-2 had a
consensually recorded call with CUEVAS, who was using Cuevas Phone 1. During
the call, CUEVAS asked, “When will you have a chance to come for [the narcotics
proceeds].” CI-2 responded, “I'll go but not until Wednesday [July 24, 2013). Tjust
96need for them to call me from over there [receive PARRA-PEDROZA’s permission to
collect the money].”
121. On July 22, 2013, at approximately 1:29 p.m., CI-2 had a consensually
recorded call with CUEVAS, who was using Cuevas Phone 1. During the call,
CUEVAS stated, “Listen, my friend is asking me if Wednesday is for sure?” CI-2
responded, “Yes, Wednesday [July 24, 2013] for sure.” CUEVAS asked, “But you, so
you can come over here and fix the car [collect narcotics proceeds]?” CI-2 responded,
“T'm going to be fixing cars [collecting other narcotics proceeds] now. ... So I'll call
you on Wednesday. You said your car has a hundred and five miles [$105,000],
right?” CUEVAS responded, “Right, exactly.”
122. On July 22, 2013, between approximately 1:33 p.m. and 1:36 p.m., CI-2
exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO Device 1.
During this exchange, CI-2 stated, “Okay. I was contacted by a primo [CUEVAS],
good for Wednesday [CUEVAS to deliver narcoties proceeds on Wednesday, July 24,
2013).” PARRA-PEDROZA responded, “Let me see from who.” CI-2 stated, “Okay.
It’s for 105 [$105,000], told me last week which I didn't receive.” PARRA-
PEDROZA said, “Okay.”
123. On duly 22, 2018, at approximately 4:09 p.m., CI-2 had a consensually
recorded call with CUEVAS, who was using Cuevas Phone 1. During the call, CI-2
asked, “Okay, uh, do you know how many miles you put on the car [the amount of
narcotics proceeds CUEVAS will deliver]?” CUEVAS responded, “Something
around one hundred and forty [$140,000].”
97124. On or about July 24, 2013, CI-2 had a series of consensually recorded
calls with CUEVAS, who was using Cuevas Phone 1. During these calls, CUEVAS
and CI-2 arranged to meet each other at approximately 3:00 p.m. in the parking lot
of a Sam’s Club located at 321 South Larkin in Joliet, Illinois.
125. On duly 24, 2013, at approximately 3:00 p.m., CI-2 and CUEVAS met
in the parking lot of the Sam's Club located at 821 South Larkin in Joliet. Prior to
this meeting, agents outfitted CI-2 with a concealed audio and video recording
device and searched CI-2 and his/her vehicle for large amounts money and
contraband, and finding only $67. CI-2 traveled under constant surveillance from a
staging location to the meeting. Surveillance observed CUEVAS park his car next
to CI-2's vehicle, exit his car, retrieve a green shopping bag, and place the bag into
the back of CI-2’s vehicle. During this meeting:
a. CL-2 stated, “Yeah, just take it {narcotics proceeds] out and put
it [narcotics proceeds] in the back of my truck and close it [the back hatch of CI-2
vehicle]... Yeah, just leave it [narcotics proceeds] there and close it.” CUEVAS
stated, “There you go.”
b. CL2 stated, “You said a hundred and forty [$140,000]?”
CUEVAS responded, “No, two hundred [$200,000].” CI-2 asked, “Two [$200,000]?
‘Two [$200,000]? CUEVAS stated, “It’s because they [drug traffickers] barely gave
me another yesterday [CUEVAS received an additional amount of narcotics
proceeds at the last minute].” CI-2 stated, “
h, uh-huh. They're [narcotics
98proceeds} all sealed [vacuum sealed], well measured, well measured [fully
counted]?” CUEVAS stated, “Well measured [fully counted].”
126. Following this meeting, CI-2 drove under constant surveillance to a
designated meeting location where agents retrieved a green shopping bag
containing approximately $200,780 in cash from Cl-2's vehicle. Agents then
transported the money to the HSI Chicago Field Office, where a canine trained to
detect the odor of narcotics sniffed the money and alerted positive for the presence
of narcotics.
127. On duly 24, 2013, at approximately
:38 p.m., CI-2 exchanged a series
of BBMs with PARRA-PEDROZA, who was using MLO Device 1. During this
exchange, Cl-2 stated, “OK. I'm going to the office [going to count the narcotics
proceeds received from CUEVAS].”. PARRA-PEDROZA asked, “With how much
[money]?” CI-2 responded, “200 [$200,000].”
128. On July 24, 2013, between approximately 8:49 p.m. and 8:59 p.m., CI-2
exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO Device 1.
During this exchange, CI-2 stated, “Put me down for 200 [CUEVAS delivered
$200,000].”. PARRA-PEDROZA asked, “And the other [delivery of narcotics
proceeds] for chikito [code word for a different money courier]? ... Could you see
him in the morning?” Cl-2 responded, “See what time I will be able to see the
refiner [CI-2's gold supplier, from whom CI-2 will purchase gold with the $200,000
that CUEVAS delivered].”. PARRA-PEDROZA responded, “OK. Let me know
later.”
99129. On July 25, 2013, between approximately 10:25 a.m. and 10:33 a.m.,
CI-2 exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO
Device 1. During the exchange, CI-2 stated, “[TJhe guy from the refinery [CI-2’s
gold supplier] left, just left me what [gold] he had.” PARRA-PEDROZA asked, “Will
give you everything [enough gold to cover the $200,000 collected from CUEVAS]
today?” Cl-2 responded, “That's what I'm doing the paperwork on.” PARRA-
PEDROZA asked, “Have guides [enough FedEx labels to ship the $200,000 worth of
gold to Refinery A in Florida]? ... Will send you just in case [PARRA-PEDROZA
will email additional pre-paid FedEx shipping labels addressed to Refinery ].”
130. On July 25, 2013, between approximately 12:25 p.m. and 2:40 p.m., CI-
2 exchanged a series of BBMs with PARRA-PEDROZA, who was using MLO Device
1. During this exchange, PARRA-PEDROZA stated, “I just sent you the guides
[FedEx shipping labels to ship the gold]. ... If everything arrives [enough gold to
cover the $200,000 collected from CUEVAS]?” CI-2 stated, “Till Monday [CI-2 will
not be able to ship the gold to Refinery A until Monday [July 29, 2013].” PARRA-
PEDROZA acknowledged, “OK.”
131. On or about July 80, 2013, using four of the shipping labels provided
by PARRA-PEDROZA, agents sent to Refinery A approximately 4,435.43 grams of
24-Karat gold, which agents had purchased with approximately $192,465. 78 of the
proceeds obtained from CUEVAS. Agents also enclosed in this shipment a Refinery
A packing list that identified the shipping company as “Chicago Gold” and described
the contents of the boxes as containing a total of 4,435.43 grams of 24-Karat gold.
100According to FedEx records, this shipment arrived at Refinery A on or about July
31, 2013.
132. On or about August 12, 2013 CI-2 exchanged a series of BBMs with
PARRA-PEDROZA, who was using MLO Device 1. During this exchange, CI-2
stated, “Last one I send you [four boxes of gold sent to Refinery A on July 30, 2013],
close it [set the price of the gold at the fair market value at the time which it was
sent].”. PARRA-PEDROZA responded, “Okay.” CI-2 stated, “1340 [current fair
market value of the gold at $1,340 per ounce of 24 Karat gold].”, PARRA-PEDROZA
responded, “Okay.”
XII. ABEL Directs CI-2 to Collect and Launder up to $290,704 in Narcotics
Proceeds from LEIVA (September 11, 2013).
133. On or about September 9, 2013, between 4:15 p.m. and 4:19 p.m., CI-2
exchanged a series of consensually captured BBMs with ABEL, who was using MLO
Device 129 During this exchange, ABEL asked, “Listen, can you do it [collect
narcotics proceeds] tomorrow?” CI-2 asked, “How much?” ABEL responded, “150
% As noted above, PARRA-PEDROZA began communicating with CI-2 over MLO
Device 1 on or about June 3, 2013, On or about September 6, 2013, PARRA-PEDROZA sent.
CL-2 a BBM message over MLO Device 1, advising CI-2 that he planned to give MLO
Device 1 to his nephew, ABEL. PARRA-PEDROZA stated, “I'm not going to have my cell
{MLO Device 1], it’s going to be with my nephew. ... But he knows how to close [coordinate
money laundering shipments] and everything.” According to CI-2, prior to his/her
cooperation with law enforcement, CI-2 had worked with PARRA-PEDROZA's nephew
named “Abel” to conduct the money laundering conduet scheme when PARRA-PEDROZA
was unavailable. On or about September 9, 2013, CI-2 sent a BBM message to MLO Device
1, asking, “Is this Willy [PARRA-PEDROZA]?” When the user of MLO Device 1 responded,
“No,” CI-2 stated, “Abel.” In response, the user of MLO Device 1 responded, “Call me Robin
hahaha. Better.’ In another BBM message sent on January 21, 2014, PARRA-PEDROZA,
who was then using Parra-Pedroza Device 1, referred to MLO Device 1 as “the other pin
from Abel.”
101{$150,000}. All right, they [drug trafficker] are going to call you right now.” CL-2
responded, “Okay.”
134. Between 6:05 p.m. and 6:42 pm. CI-2 exchanged a series of
consensually captured BBMs with ABEL, who was using MLO Device 1. During this
exchange, ABEL asked, “Have they [drug trafficker] called you?” CI-2 responded,
“No.” ABEL asked, “What is the number for the cousins [what telephone number
does CI-2 use to coordinate delivery of narcotics proceeds}?” Cl-2 responded, “Tell
Willy [PARRA-PEDROZa] to give it to you.” ABEL stated, “Okay. Does it end in
0423. Or 0015.” CI-2 responded, “0423.” ABEL stated, “Okay. That yeah, they
{drug trafficker] will call you right now.”
135, At approximately 7:59 p.m., CI-2 had a consensually recorded call with
and unidentified man (“UM 2918"), During this call:
a. UM 2918 stated, “Hello, Daniel [CI-2's codename, provided by
PARRA-PEDROZA]?” CI-2 responded, “Yeah.” UM 2918 stated, “I'm calling you on
behalf of Gerardo. ... Listen, I called, right now, to try to pitch in to have enough
for the rent [deliver narcotics proceeds}. We have to deliver a...” Cl-2 asked,
“Well, did they say how much we have to pitch in?” UM 2918 responded, “A
hundred and fifty [$150,000]... The only thing is that, um, that we have to go
certify the, the, the, the authenticity of the, of the, of the amount [count the
narcotics proceeds}. So then um, I think they want to do that. Supposedly that was
already taken care of. That possibly there at your office or I don’t know where. Do
102you know anything about that [UM 2918 wants to count the narcotics with CI-2 so
there is no discrepancy?”
b. CL-2 responded, “No, they didn’t tell me. Because usually wh, I
work on stuff on the street [CI-2 does not normally count the money with the
couriers].”. UM 2918 stated, “Because sometimes, that’s been happening lately.
‘That when, when the deposit is made supposedly some numbers remain in red
[discrepancies in reports of the amounts delivered and collected]. So then they want
to do that right now, um, to look for a place on behalf of the receiver. So this way it
can get certified [counted together] and then you just give a certificate of
authenticity, and everyone is happy. But if you are not aware of that, I would like
for you to look into it and we can make arrangements. And if you want Wednesday,
we can do it on Wednesday. That's fine. Sounds good to me.”
c. CI-2 stated, “Oh, okay, let me call Ingeniero [ABEL] over there
and I'll tell him to see what he tells me. Okay, and then we'll see if, I should work
on it [collect narcotics proceeds] there at the shop [CI-2’ putative office] or if I
should fix it there on the street. Okay. I'll see what he tells me.”
d. UM 2918 stated, “They said that, that I should call you instead.
Because that guy [the money courier, subsequently identified as ANTHONY
LEIVA] is, he doesn’t speak ‘Spanish well. He speaks very little.” CI-2 and UM
2918 agreed to speak again later.
103136. Between 8:11 p.m. and 8:31 p.m. Cl-2 exchanged a series of
consensually captured BBMs with ABEL, who was using MLO Device 1. During this
exchange:
a. ABEL asked, “Ready? Anything? What did you guys [UM 2918]
agree on?” CI-2 responded, “Wednesday [for the collection of narcotics proceeds
from LEIVA].” ABEL asked, “It can’t be done tomorrow? So that everything [gold
purchased with narcotics proceeds from LEIVA and others] will be able to come in
{to Refinery A] on Friday... [W]ill everything come on Frida:
CI-2 responded,
“Yes.”
b. ABEL asked, “And the one that called you today [UM 2918] can’t
be done tomorrow? They just ask me why.” Cl-2 responded, “I need to talk to Refi
[Cl-2's putative gold supplier] so he could put some metal [gold] aside for me for
Wednesday. And as soon as I receive and verify, I'll take it to Refi.” ABEL stated,
“Okay. In other words, have them [UM 2918] tell you how much it is [narcotics
proceeds they will deliver to CI-2]. And you just let them {gold supplier] know that
they have to take it [set aside enough gold to cover the purchase] and that’s it?” ClI-
2 responded, “They [gold supplier] just let me know [when the gold is ready to be
purchased and picked up].”
137. On or about September 10, 2013, at approximately 8:55 p.m., CI-2 had
a consensually recorded call with UM 2918. During this call, UM 2918 stated,
“They were asking me if you had a machine to, to, to review that quickly [a money
counter to count the narcotics proceeds in LEIV.
's presence].” CI-2 responded,
104“Yeah, I do have a secretary [money counter] there, and everything.” UM 2918 said,
“Okay, so then...if you could make an arrangement with the person [LEIVA] to
meet at a place and they can, they can give it {the narcotics proceeds] to you and,
and, and you...” CI-2 stated, “Well, I think P'm going to take him to the office. So
that [count the narcotics proceeds] in front of him.” UM 2918 and CI-2 agreed to
speak again later.
138. On or about September 11, 2013, between 9:37 a.m. and 9:43 a.m., CI-2
exchanged a series of consensually captured BBMs with ABEL, who was using MLO
Device 1. During this exchange, ABEL asked, “What time is the thing [collection of
nareoties proceeds from LEIVA].” CI-2 responded, “Around one [1:00 p.m.” ABEL
asked, “Do you need a guide (pre-paid shipping label addressed to Refinery Al.” CI-
2 responded, “Yes,” ABEL responded, “Okay. Where should I send it to?” CL-2
responded, “Willy, do you have my email [PARRA-PEDROZA should have CI-2's
email].” ABEL stated,
kay. How many guides [shipping labels]? CI-2
responded, “Ten.” ABEL stated, “Okay.”
139. On or about September 11, 2013, at approximately 12:28 p.m., the UC
Email Account received an email from email address
[email protected]
(‘Abel Email Account 3”), entitled, “Guia.” The email included two attachments,
% Agents identified ABEL as the user of Abel Email Account 3 as. follows:
Immediately after this September 11 email attaching the shipping labels, ABEL sent CI-2 a
BBM stating, “I already sent you the guides.” On September 12, 2013, between
approximately 12:66 p.m. and 3:41 p.m., ABEL, who was using MLO Device 1, exchanged a
series of BBMs with CI-2. During this exchange, ABEL asked CI-2 to send him a document
“To Juan C. Ortega’s email.” CI-2 stated, “Give me the complete email.” ABEL responded,
“
[email protected] [Abel Email Account 3).” On January 17, 2014, between 6:08
p.m. and 6:17 p.m., CI-2 exchanged a series of consensually captured BBMs with PARRA-
105including ten prepaid FedEx labels addressed to Refinery A and a Refinery A
shipping form called a packing list. The body of the email stated, “We were
requested by phone for a FedEx labels. We have it attached in this e mail along
with a [Refinery A] packing list... If you have any questions of concerns on how
to use a label, please give us a call.”
140. At approximately 12:28 p.m., CI-2 exchanged a series of consensually
captured BBMs with ABEL, who was using MLO Device 1. During this exchange,
ABEL stated, “I already sent you the guides [Refinery A shipping labels].” CI-2
responded, “Okay.”
141. On or about September 11, 2013, between approximately 12:47 p.m.
and 2:03 p.m., CI-2 had several consensually recorded calls with UM 2918. During
these calls, UM 2918 arranged for LEIVA to meet with CI-2 at a Walgreens located
near the intersection of “Pulaski and Diversey” in Chicago at approximately 2:08
pm, During the first of these calls, Cl-2 asked, “How should we do it to verify
[count the money] for this guy [LEIVA]?... He should just follow me, he can come
in my car so I can take him to the office, or how should we do it?” UM 2918 stated,
“Let me ask him [LEIVA].” CI-2 stated, “Do you want, do you want him to follow
me? He can come right behind me... . I can tell him [LEIVA], ‘Okay, just follow
me and let’s go to the office’ [to count the money together].”
PEDROXA, who was using Parra-Pedroza Device 1. During this exchange, PARRA-
PEDROZA asked, “In the mails that they send you are you [listed as] juan carlos ortega
Ortega. . .. Or is it abel.” CI-2 responded, “Abel or someone from Florida.” PARRA-
PEDROZA stated, “It's abel.”
106142. On September 11, 2013, at approximately 2:08 p.m., CI-2 met with
ANTHONY LEIVA?5 in the Walgreens parking lot located at the intersection of
Pulaski Avenue and Diversey Avenue in Chicago. Prior to this meeting, agents
outfitted CI-2 with a concealed audio recording device and searched CI-2 and
his/her vehicle for large amounts money and contraband, finding found none. CI-2
traveled under constant surveillance from a staging location to the meeting.
Surveillance observed LEIVA park next to CI-2’s vehicle and speak briefly with Cl-
2.
143. During this meeting, LEIVA and CI-2 spoke in English, consistent
with UM 2918's earlier representation that LEIVA did not speak Spanish well.
LEIVA stated, “Hey, um I will follow you [to Cl-2’s office, to count the narcotics
proceeds together] okay.” CI-2 stated, “Okay, uh, they said 150 [$150,000] correct.”
LEIVA responded, “Yeah, yeah, yeah.” CI-2 stated, “Okay, before we go, we have to
count like one time, okay? If you short, we count two times, okay? That's the most I
can count for you.” LEIVA stated, “Yeah no worries, let’s go.” CI-2 stated, “Okay
you follow me.” LEIVA stated, “I'll follow you.” CI-2 and LEIVA then returned to
their respective vehicles and left the Walgreens parking lot together.
144. At approximately 2:18 p.m., police working with agents on this
investigation performed a traffic stop of CI-2 under the guise of issuing CI-2 a
% Agents identified LEIVA as follows: As discussed below, on September 11, 2013, CI-
2 met with, and attempted to obtained narcotics proceeds from, a man who arrived at a
designated meeting location. On September 12, 2013, that same individual was pulled over
by Chicago Police Department and identified himself as Anthony LEIVA and produced an
Dlinois driver's license with that same name and photograph.
107citation for expired registration. Agents arranged for this traffic stop to allow law
enforcement an opportunity to identify and follow LEIVA and to delay his
anticipated delivery of narcotics proceeds. During the traffic stop, surveillance
observed LEIVA drive around in the area of the traffic stop before departing the
area. Agents maintained surveillance of LEIVA.
145, At approximately 2:40 p.m., CI-2 had a consensually recorded call with
‘UM2918. During this call, Cl-2 stated, “They [police] stopped me because, I have to
change cars, Okay, your, your cousin [LEIVA] is fine and everything, so he doesn't
start up with things. ... One of those traffic things. My thing [registration] was
expired, my ticket was expired. ... I was on the phone and they stopped me, but it
was just, it was a routine thing. So that guy [LEIVA] doesn’t go to with things.”
UM 2918 stated, “All right, no... so they don’t think over there [Mexican
associates] that we are acting dumb [drawing law enforcement's attention to the
MLO] here.” UM 2918 and CI-2 agreed to speak again later.
146. On or about September 11, 2013, at approximately 3:28 p.m.,
surveillance observed LEIVA park in front of an auto repair shop located at located
at 4201 W. Schubert in Chicago. Shortly thereafter, LEIVA retrieved a cardboard
box from the rear cargo area of his vehicle, LEIVA then entered the W. Schubert
address with the cardboard box. At approximately 3:55 p.m., surveillance observed
LEIVA exit the address without the cardboard box and drive to a residence located
at 217 E. Medill Ave in Northlake, Illinois (“Leiva Residence 1”).
108147. Between 3:50 p.m. and 5:33 p.m., CI-2 exchanged a series of
consensually captured BBMs with ABEL, who was using MLO Device 1. During
this exchange:
a. CI-2 stated, “We weren't able to do it [collect narcotics proceeds
from LEIVA] today.” ABEL asked, “Why?... Everything okay? They already got
worried over here [in Mexico].” CI-2 responded, “Everything is fine. My sticker
[vehicle registration sticker] was expired that's why they [police] stopped me.”
ABEL asked, “That's why you couldn't meet with them?” CI-2 stated, “The cousin
(LEIVA] was behind me on his way to the office {to count the narcotics proceeds).
And when the law stopped me he [LEIVA] took off.” ABEL stated, “Oh, okay. But
tomorrow you will (collect the narcotics proceeds from LEIVA]?” CI-2 responded,
“Yeah, I already called him [UM2918].”
b. ABEL stated, “Okay. ... But did they [police] check [search] the
car? Or was it just papers [traffic ticket]?” CI-2 responded, “No, nothing. Just a
ticket for an expired sticker.” ABEL stated, “Oh, okay. I'll check in at 830 and see
what's up.... Are you okay with everything else? Little light bulbs or something.
Stop turning signals.” CI-2 responded, “
wverything is fine over here.” ABEL stated,
“I mean, with the car [CI-2 needs to use a car that will give police no excuse to pull
him/her over].” CI-2 stated, “Yes, everything is fine. The thing is the squad car
made a turn behind me and it went behind me and it stopped me.” ABEL stated,
“Oh, okay.”
109148. On September 12, 2013, at approximately 6:42 a.m., surveillance
observed LEIVA exit Leiva Residence 1, drive to the auto repair shop at 4201 W.
Schubert, and pull his vehicle into the bay area. At approximately 7:16 a.m.,
surveillance observed LEIVA departed 4201 W. Schubert in his vehicle. Agents
continued to maintain constant surveillance of LEIVA.,
149. On September 12, 2013, at approximately 7:41 a.m. CI-2 had a
consensually recorded call with UM2918. During this call, UM 2918 stated, “They,
they told me to cancel on you [Mexican associates instructed UM 2918 not to deliver
narcotics proceeds to CI-2].... They told me to cancel on you. Um, if you want, if
you want ask, if you want to ask Sordo [UM 2918's boss}... so he can also agree.
But they told me to cancel.” CI-2 stated, “Okay, all right then.”
150. According to toll records, between 7:36 a.m. and 7:59 a.m., UM 2918
Phone 1 was in contact with telephone number (224) 251-0218 (‘Leiva Phone 1”).
151. On September 12, 2013, between 8:02 am. and 8:07 am, CI-2
exchanged a series of consensually captured BBMs with ABEL, who was using MLO
Device 1. During this exchange, CI-2 stated, “They [UM 2918] cancelled on me.”
ABEL asked, “Why?” CI-2 responded, “I don't know, probably because of yesterday
[encounter with police].” ABEL stated, “Mmm, Let me tell them. ... He's going to
see if he could send them again.”
152. At approximately 8:10 am., while agents maintained their
surveillance of LEIVA from the W. Schubert address, CPD officers conducted a
traffic stop of LEIVA in his vehicle at 10500 S. Indianapolis in Chicago. During the
110traffic stop, LEIVA gave officers verbal consent to search his vehicle. During this
search, officers found two cardboard boxes which contained a total of $290,704. The
number “150 [$150,000]" was written on one box and the number “140,690
($140,690}” was written on the other box. Agents also found Leiva Phone 1 in
LEIVA’s possession.
153. Based on my familiarity with this case, including the aforementioned
calls and communications between CI-2 and ABEL, UM 2918, and LEIVA, I believe
that the $290,704 in cash seized from LEIVA on September 12, 2018, were all or
some of the same narcotics proceeds that LEIVA intended to deliver to Cl-2, at the
direction of ABEL.
154. Following his traffic stop, and after being advised of his Miranda
rights, LEIVA agreed to speak with agents without the assistance of counsel.
During that interview, LEIVA told agents that he worked for a man whom he knew
as “Tio,” who paid LEIVA to collect and deliver large quantities of marijuana and
narcotics proceeds. LEIVA advised that his associates typically stored
approximately 2,000 pounds of marijuana at a time in the garage located at 4201 W.
Schubert in Chicago, and LEIVA would parcel out various quantities of the drug as
directed by Tio. LEIVA stated that he has picked up five or six loads of marijuana,
each load approximately 2000 pounds, over the course of his employment by Tio.
LEIVA stated that Tio also instructed him to collect various amounts of money from
multiple individuals and, once collected, to deliver the consolidated amounts of
money to unknown individuals.
SBE155. LEIVA gave agents verbal consent to search the garage located at 4201
W. Schubert. During this search, agents seized approximately 13 large bundles of a
substance that appeared to be marijuana. CPD submitted this substance to its lab
for testing, which determined that the recovered substance was approximately 325
pounds of marijuana. LEIVA was released without charges so as not to compromise
the ongoing investigation
156. Between 12:51 p.m, and
:22 p.m, CI-2 exchanged a series of
consensually captured BBMs with ABEL, who was using MLO Device 1. During
this exchange:
a. ABEL asked, “What exactly did they [UM2918] tell you in the
morning? Or was it yesterday when they [UM 2918] cancelled?” CI-2 responded,
“This morning when I told him [UM 2918] I was on my way and he said they [UM
2918's boss] cancelled on him.” ABEL asked, “Do you have a picture of the ticket
[traffic ticket]. ... Because these guys [UM 2918's associates] are being assholes.
And they don't believe [that police stopped Cl-2 for only a traffic violation]. Can you
send it [the traffic ticket] to me?” CI-2 responded, “I'll send it [the traffic ticket] to
you right now.” ABEL stated, “Because they think that they stopped you for
something else. ... That's why with the picture [of the traffic ticket].”
b. — CL-2 stated, “They [the police] stopped me for an expired sticker
and it was because the cop made a turn right behind me and he was behind me for a
while. The light turned yellow, I kept going, and that’s when he stopped me.” ABEL
stated, “Yeah, they already told them [UM 2918's associates]. But they say they
112want to see the picture [of the traffic ticket]. You know how they are.” CI-2
responded, “I'm on my way to the office, I'll send it [the traffic ticket] to you as soon
as I get there.” ABEL stated, “All right. Because they (UM 2918's associates] don't
want to take anymore [deliver narcotics proceeds to CI-2].”
XIV. ABEL Directs CI-2 to Collect and Launder $100,220 in Narcotics
Proceeds from HERRERA (September 13, 2013).
157. On or about September 12, 2018, between approximately 3:54 p.m. and
6:02 p.m., CI-2 exchanged a series of consensually captured BBMs with ABEL, who
was using MLO Device 1. During this exchange, CI-2 stated, “I already committed
to the refinery [putative gold supplier], and he’s fucking bothering me down there
about when I'm going.” ABEL stated, “Tomorrow. Can you do [collect] one for 100
[$100,000] and another one for 80 [$80,000].” CI-2 responded, “One I can. Have
them [money couriers] call me so I can meet with him early. I hope I am able to
send it [gold purchased with the narcotics proceeds] to you.” ABEL responded,
“Okay.”
158. At approximately 8:46 p.m., CI-2 had a consensually recorded call with
MARIO HERRERA, who was using telephone (773) 517-4204 (“Herrera Phone 1”).26
% Agents identified MARIO HERRERA and his voice as follows: On or about January
25, 2012 - prior to C! cooperation with law enforcement — surveillance observed CI-2
meet with a man in a dark gray Dodge Durango and then walk together into the location
where Cl-2 used to meet with couriers to collect narcotics proceeds. On January 31, 2012,
in the course of a traffic stop conducted by Chicago Police Department officers on the same
Durango, the driver of the Durango told officers that his name was “Mario Herrera” and
produced a Mexican identification card bearing the same name and the driver's photograph.
Agents compared that photograph to the individual they saw on surveillance and
determined it was the same individual. After CI-2 began cooperating with law enforcement
in April 2013, agents showed CI-2 a photograph of HERRERA and CI-2 identified
HERRERA as one of the individuals who had delivered narcotics precedes to him/her at
113During this call, HERRERA stated, “Yeah, cousin, they told me to call you on behalf
of [Individual K, codename to vouch for trustworthiness}.” HERRERA and CI-2
then discussed possible places to meet the next day.
159. At approximately 8:49 p.m., CI-2 had a consensually recorded call with
HERRERA, who was using telephone Herrera Phone 1. During this call, CI-2
stated, “They [ABEL] said that the car had a hundred miles [$100,000 in narcotics
proceeds], eighty [$80,000], or a hundred miles, they told me it had.” HERRERA
stated, “A little less.” CI-2 stated, “Okay, all right then. I'll call you. I'll call you
when I'm around there. ... Yeah, so we can go get something to eat [HERRERA
can deliver the narcotics proceeds], so we can have-some lunch. Okay?” HERRERA
stated, “Alright.”
160. On or about September 13, 2013, at approximately 9:41 a.m., CI-2 had
a consensually recorded call with HERRERA, who was using telephone Herrera
Phone 1. During this call, CI-2 stated, “Yeah, ub, I'll be there [to collect the money].
I didn’t understand there if it was the car that had eighty miles [$80,000] or a
his/her money laundering location. CI-2 stated that he/she laundered HERRERA's money
through the purchase of gold, and that he/she only met with HERRERA when HERRERA
had narcotics proceeds to deliver. As discussed below, on September 12 and 13, 2013, CI-2
had several consensually recorded calls with the man who was using Herrera Phone 1.
During these calls, the man using Herrera Phone 1 arranged to meet CI-2 at approximately
1:80 p.m. on September 13, 2013, at a Walmart in Chicago, Illinois. Following these calls,
surveillance observed CI-2 meet with, and obtain proceeds from, a man at the designated
time and place. Agents conducting surveillance recognized and positively identified the
man who delivered narcotics proceeds to CI-2 on September 13, 2013, as HERRERA. In
addition, prior to the September 13 meeting, agents outfitted CI-2 with a concealed audio
recording device, which captured HERRERA’s voice. After reviewing the recording of the
September 13 meeting, agents compared the voice of the man with whom CI-2 met to the
voice of the man who was using Herrera Phone 1 in numerous, consensually recorded calls
with CI-2, and determined that HERRERA was the user of Herrera Phone 1.
14hundred miles [$100,000].”. HERRERA stated, “It’s about a hundred [$100,000].”
CE-2 stated, “About a hundred [$100,000]. Okay, um, I'll be there around twelve
[p.m], around there. When I'm in the area I'l, okay. He said there around fifty-
ninth [59th Street] and the, and the polish one [Pulaski Avenue], right?”
HERRERA answered, “Uh-huh.” HERRERA and CI-2 then agreed to meet at “a big
store around there.” CI-2 stated, “Okay, I'll give you a call when I’m close by there.
Around twelve [p.m.], one [p.m.], so you don’t get anxious. Because I'm over here,
okay?” HERRERA responded, “No, no, no, no, nothing like that. That's why I'm
here . . . to serve you.”
161. Between approximately 12:46 p.m. and 1:10 p.m., CI-2 had a series of
consensually recorded calls with HERRERA, who was using telephone Herrera
Phone 1. During these calls, HERRERA and CI-2 arranged to meet at
approximately 1:15 p.m, at a Walmart near the intersection of 71st Street and
Cicero Avenue in Chicago.
162. At approximately 1:30 p.m., CI-2 and HERRERA met in the Walmart
parking lot located at 7050 South Cicero Avenue, Chicago, Illinois. Prior to this
meeting, agents outfitted CI-2 with a concealed audio recording device and searched
Cl-2 and his/her vehicle for large amounts money and contraband, finding none.
CL-2 traveled under constant surveillance from a staging location to the meeting.
Surveillance video taped the meeting and observed HERRERA arrive in a Caravan,
park next to CI-2’s vehicle, hand CI-2 a black plastic bag, which CI-2 in turn placed
in his/her vehicle. During this meeting:
115a. HERRERA asked, “And you're not with the same over there?
You're not in the same [location where HERRERA used to deliver narcotics proceeds
to CI-2].” CI-2 responded, “No, they changed us to another place.” HERRERA
stated, “Yeah?” CI-2 stated, “Yes, they changed us to another place. If] would have
known [that HERRERA was someone for whom CI-2 previously laundered money] I
would have met with you in another place. Yes.” HERRERA replied, “Yes.”
b. CL2 stated, “Yes. Okay, just drop it [narcotics proceeds] in
there. ... How much?” HERRERA responded, “Look, there are forty of two, like
the way you know I count them [the way HERRERA delivered money to CI-2 in the
past]... And four rolls of five [$5,000] each.” CI-2 stated, “So then there are?”
HERRERA responded, “One hundred [$100,000]. One hundred.”
163. Following this meeting, CI-2 drove under constant surveillance to a
predetermined meeting location where agents retrieved from CI-2's vehicle a black
bag containing approximately $100,220 in cash. Agents transported the money to
the HSI Chicago Field Office, where a canine trained to detect the odor of narcotics
sniffed the money and alerted positive for the presence of narcotics.
164. Between approximately 1:48 p.m. and 1:52 p.m., CI-2 exchanged a
series of consensually captured BBMs with ABEL, who was using MLO Device 1.
During this exchange, ABEL asked, “How's it going.” Cl-2 responded, “I'm on my
way to the office [to count HERRERA’s narcotics proceeds].” ABEL asked, “With
the things [narcotics proceeds]?” CI-2 responded, “Yes.” ABEL asked, “Was it the
116one with 100 [$100,000] or 80 [$80,000]... Which one?” CI-2 stated, “A hundred
{$100,000].” ABEL stated, “Okay.”
165. Between approximately 4:13 p.m. and 4:18 p.m., CI-2 exchanged a
series of consensually captured BBMs with ABEL, who was using MLO Device 1.
During this exchange, CI-2 stated, “Put me down for 100 [CI-2 confirmed
HERRERA delivered $100,000 in narcoties proceeds].” ABEL responded, “Done.
Are you going to be able to send [gold purchased with HERRERA’s narcotics
proceeds to Refinery AJ.” CI-2 responded, “No, I just finished verifying [counting],
but I'm going to store at the refinery [CI-2’s putative gold supplier].”. ABEL
responded, “Oh, okay.”
166. On or about September 17, 2013, using shipping labels provided by
ABEL in an email, agents sent to Refinery A approximately 2,199.45 grams of 24-
Karat gold, which agents had purchased with approximately $96,577.08 of the
proceeds obtained from HERRERA on September 13, 2013. Agents also enclosed in
this shipment a Refinery A packing list that identified the shipping company as
“Chicago Gold” and described the contents of the boxes as containing a total of
2,199.45 grams of 24-Karat gold. According to FedEx records, this shipment arrived
at Refinery A on or about September 18, 2013.
167. On or about September 18, 2013, between approximately 1:48 p.m. and
1:52 p.m., CI-2 exchanged a series of consensually captured BBMs with ABEL, who
was using MLO Device 1. During this exchange, CI-2 stated, “Close 2200 of the fine
one at 1345 [CI-2 purchased 2,200 grams of 24 Karat gold at the current fair market
117value of $1,345 per ounce, using narcotics proceeds collected from HERRERA.”
ABEL responded, “At 43 [$1,343 per ounce]. Willy [PARRA-PEDROZA] says.” CI-2
responded, “Okay.” ABEL stated, “It’s at 41 [$1,341 per ounce].” CI-2 stated, “Now
it’s at 43 ($1,343 per ounce].” ABEL responded, “Okay. ... But I already closed it
[reach an agreement with Refinery A on the price of the gold]... . 2200 [grams of
24 karat gold] at 43 [$1,343 per ounce].”
XV. ABEL Directs CI-2 to Collect and Launder $50,000 in Narcotics
Proceeds from URQUIZA-OSORIO (September 20, 2013).
168. On or about September 18, 2013, between approximately 4:25 p.m. and
9:31 p.m., CL-2 exchanged a series of consensually captured BBMs with ABEL, who
was using MLO Device 1. During this exchange, ABEL stated. “512-424-9323
[Urquiza-Osorio Phone 1] with Flaco's father on behalf of [Individual K, codenames
to vouch for trustworthiness]. ‘That if you can call him [to collect narcoties
proceeds}.” Cl-2 responded, “Okay.”
169. On September 19, 2013, at approximately 11:11 am., CI-2 had a
consensually recorded call with PEDRO URQUIZA-OSORIO, who was using
telephone number (512) 424-9323 (“Urquiza-Osorio Phone 1”).27 During this call,
2% Agents identified PEDRO URQUIZA-OSORIO as follows: As discussed below,
between September 19 and 20, 2013, CI-2 had several consensually recorded calls with the
man who was using Urquiza-Osorio Phone 1. During these calls, the man using Urquiza-
Osorio Phone 1 arranged to meet CI-2 in person at the parking lot of a Jewel store located
at 7122 40th Street in Berwyn, Illinois, on September 20, 2013, at approximately 1:20 p.m.,
for the purpose of delivering narcotics cash proceeds. Following these phone calls,
surveillance observed CI-2 meet with, and obtain proceeds from, a man at the designated
time and place. Agents conducting surveillance subsequently viewed a Mexican
identification card of "Pedro Urquiza-Osorio,” and positively identified URQUIZA-OSORIO
as the individual who delivered narcotics proceeds to CI-2 on September 20, 2013. In
addition, as discussed below, following this meeting, agents followed URQUIZA-OSORIO to
118