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~r ~ ~: U.S. COURT OF APPEALS ' ,I,,

NORTHERN 

Seventh Circuit

Loose Pleadings ~S, EASTERN DIVISION

UNITED STATES OF AMERICA Of VOI

V.

..,~:.anINAL COMPLAINT

JAMES VALENCIA aka "Jota" and "Father, " CASE NUMEER:

KELLY JONES aka "sone~ anfl ~~Miguel, ~ MAGISTRATE :~~+~ ~: CARLOS JIRON aka Lucho and Luis," ~;~OWN

JESUS ABEL ROLDAN aka "Tomatico"

DAVID ACEVEDO, ~ ~ ~ 1

WILLIAM ANTHONY MORCIGLIO aka "Wo~~dy," ~i

MARCUS JONES aka "Titty' and "T," i .

DANIEL C. MALDONADO, ~

ANGEL GEORGE MELENDEZ, JR.,

NATHAN THOMAS aka "Edwin Garcia," O

DIANA MUNOZ, _

YOLANDA RIVERA, ~Q~

IRIS D. TORRES,

RUBEN CHAPARRO-RAMOS, -

MARTHA LLANOS aka "Martica", "La Mona", and "Pie Malo,"

VIBENCIO CONSUEGRA,

SHANTELL HILL,

RICARDO ARNOLD aka "Ricky" and "Crino,"

MIGUEL SAI3CHEZ aka "Mikey,"

MILENA P. PUPO aka "Paisa" and "Paisita,"

LUIS E. RIVERA aka "Tito,"

JUAN LOZADA aka "Mono", "Monito" and "Pablito,"

SANDRA P. VELAZQUEZ aka "La Negra" and "Negrita,"

COSME CHACON aka "Meno" and "Nano,"

VIVIANA HERNANDEZ,

~~ i tr. ~ y

^' r

(' T ~ ~ 2002

MlCWA~L W. D0881N5

CLERF;, U. S. DISTRICT COURT

I, the undersigned complainant being duly sworn state the following is true and correct

to the best of my knowledge and belief. On or about November 1999 to the present, in Cook

county, in the Northern District of Illinois defendants) did, Track SGatu[ory Language of Offense)

See Attachment A.

in violation of Title See Attachment A United States Code, Sections) See Attachment A .

I further state that I am a(n) Special Agent, U.S. Customs and that this complaint is based

on the following facts:

See Attached Affidavit.

Continued on the attached sheet and made a part hereof: X Yes No

Colberd lmeida, U.S. us~rorris ~Z~~,~~

Signature of Complainant 

06-2562-L01 F 1 I.. E D

Sworn to before me and subscribed in my presence, ~~JN p $ ~p~6 ~P

~: . LINO J, AGNELL~

October 29, 2002'",` ~ at Chicago, Illinois CLERK

Date City and State D~C~

~'

Geraldine Soat Brown, _U._S_. _Ma4istrate _Judcre -~~~~ ~"'t—

Name &Title of Jud cial Officer Signature of Judicial Off er
~-- ~~ r-~ ~----~ --- r- r --- r---- ~- ~-• r- - r

ATTACHI~lENT A

A. Defendants JAMES VALENCIA aka "Jota" and "Father," KELLY

JONES aka "Bone" and "Miguel," CARLOS JIRON aka "Lucho" and

"Luis," JESUS ABEL ROLDAN aka "Tomatico" DAVID ACEVEDO, WILLIAM

ANTHONY MORCIGLIO aka "Woody," MARCUS JONES aka "Titty" and "T,"

DANIEL C. MALDONADO, ANGEL GEORGE MELENDEZ, JR., NATHAN THOMAS

aka "Edwin Garcia," DIANA MUNOZ, YOLANDA RIVER.A, IRIS D. TORRES,

RUBEN CHAPARRO-RAMOS, MARTHA LLANOS aka "Martica", "La Mona", and

"Pie Malo," VIBENCIO CONSUEGRA, SHANTELL HILL, RICARDO ARNOLD aka

"Ricky" and "Chino," MIGUEL SANCHEZ aka "Mikey," MILENA P. PUPO

aka "Paisa" and "Paisita," LUIS E. RIVERA aka "Tito," JUAN LOZADA

aka "Mono", "Monito" and "Pablito," SANDRA P. VELAZQUEZ aka "La

Negra" and "Negrita,"

between in or about late 1999 to the present, conspired and

agreed with each other and with others known and unknown to

possess with intent to distribute and distribute a controlled

substance, namely, in excess of one kilogram of heroin, in

violation of Title 21, United States Code, Section 846 and with

aiding and abetting said conspiracy, in violation of Title 18,

United States Code, Section 2.

B. Defendants, JAMES VALENCIA aka "Jota" and "Father," KELLY

JONES aka "Bone",and "Miguel," CARLOS JIRON aka "Lucho" and

"Luis MARTHA LLANOS aka "Martica" "La Mona" and "Pie Malo "

COSME CHACON aka "Meno" and "Nano," and VIVIANA HERNANDEZ,

between in or about June of 2002 to the present, did

conspire and agree with each other and with others known and

unknown to conduct and attempt to conduct financial transactions

involving proceeds of a specified unlawful activity, namely the

distribution of controlled substances, knowing that the property

involved in the activity and that the transactions were designed,

in whole or in part to conceal and disguise the nature, the

location, the source, the ownership, and the control of the

proceeds of the specified unlawful activity, in vialation of

Title 18, United States Code, Section 1956(h).
~~,

STATE OF ILLINOIS )

COUNTY OF COOK )

AFFIDAVIT

I, Colberd Almeida, being first duly sworn on oath, depose and

state as follows:

I. PRELIMINARY MATTERS

1. I am a Special Agent of the United States Customs Service

(Customs) and have been so employed for approximately one year and

five months. I have been involved in various types of electronic

surveillance and in the debriefing of defendants, witnesses,

informants, and others who have knowledge of the illegal

distribution and transportation of controlled substances.

2. This affidavit is made in support of a criminal complaint

charging (a) that between in or about late 1999 to the present, the

following individuals conspired and agreed with each other and with

others known and unknown to possess with intent to distribute and

distribute a controlled substance, namely, in excess of one

kilogram of heroin, in violation of Title 21, United States Code,

Section 846 and with aiding and abetting said conspiracy, in

violation of Title 18, United States Code, Section 2:

JAMES VALENCIA also known as "Jota" and "Father,"

KELLY JONES aka 'Bone" and ~~Miguel,"

CARLOS JIRON aka "Lucho" and "Luis,"

JESUS ABEL ROLDAN aka "Tomatico"

DAVID ACEVEDO,

WILLIAM ANTHONY MORCIGLIO aka "Woody,"

MARCUS JONES aka "Titty" and "T,"

DANIEL C. MALDONADO,

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ANGEL GEORGE MELENDEZ, JR.,

NATHAN THOMAS aka "Edwin Garcia,"

DIANA MUNOZ,

YOLANDA RIVERA,

IRIS D. TORRES,

' RUBEN CHAPARRO-R~MOS,

MARTHA LLANOS aka "Martica", "La Mona", and "Pie Malo,"

VIBENCIO CONSUEGRA,

SHANTELL HILL,

RICARDO ARNOLD aka "Ricky" and "Chino,"

MIGUEL SANCHEZ aka "Mikey,"

MILENA P. PUPO aka "Paisa" and "Paisita,"

LUIS E. RIVER.A aka °Tito,"

JUAN LOZADA aka "Mono", ~~Monito" and "Pablito,"

SANDRA P. VELAZQUEZ aka "La Negra" and "Negrita,"

and (b) that between in'or about June 2002 to the present,

the following individuals conspired and agreed with each other and

with others known and unknown to commit money laundering, in

violation of Title 18, United States Code, Section 1956(h):

JAMES VALENCIA also known as "Jota" and "Father,"

KELLY JONES aka "Bone" and "Miguel,"

CARLOS JIRON aka "Lucho" and "Luis,"

MARTHA LLANOS aka "Martica", "La Mona", and ~~Pie Malo,"

COSME CHACON aka "Meno" and "Nano"

VIVIANA HERNANDEZ

3. This affidavit is also made in support of a warrant to

search the residence of KELLY JONES located at 1433 W. Warner, Unit

#2, Chicago, Illinois and seize certain evidence relating to the

commission of violations of the above-stated criminal offenses.

4. I have received special training in all aspects of the

enforcement of laws concerning controlled substances as found in

Title 21 of the United States Code ("U.S.C."), including but not

limited to, the authorized interception of wire communications, the

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use of pen registers, undercover operations, various types of

surveillance, debriefing of defendants, witnesses, and informants

having knowledge of the distribution and transportation of

controlled substances, and the laundering and concealing of

proceeds from drug trafficking.

5. As a Customs Special Agent, I have participated in

numerous drug trafficking investigations, and have participated in

investigations relating to the illegal distribution of controlled

substances. Based on my training and experience, I am familiar

with the ways in which drug traffickers and their associates

conduct their drug-related business, including, but not limited to,

their methods of distributing narcotics, their use of telephones,

and their use of codes and code words to identify themselves, and

the nature of the communications.

6. As a result of my participation in this investigation, my

interviews with and review of reports prepared by agents in Customs

as well as other federal agencies and other law enforcement agents

and officers, I am familiar with all aspects of this investigation

as described in this affidavit. The information contained in this

affidavit includes the results of physical surveillances; agents'

interviews of witnesses; agents' review of recordings of

consensually-recorded conversations and conversations intercepted

pursuant to Court orders; and review of statements of witnesses.

Since this affidavit is being submitted for the limited purposes of

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establishing probable cause to arrest the individuals identified

above and to search the premises identified above, I have not

included each and every fact known to me concerning this

investigation.

7. Based on the information contained in this affidavit, I

submit that there is probable cause to believe (a) that between in

or about late 1999 to the present, the following individuals

conspired and agreed with each other and with others known and

unknown to possess with intent to distribute and distribute a

controlled substance, namely, in excess of one kilogram of heroin,

in violation of Title 21, United States Code, Section 846 and with

aiding and abetting said conspiracy, in violation of Title 18,

United States Code, Section 2:

JAMES VALENCIA also known as "Jota" and "Father,"

KELLY JONES aka "Bone" and "Miguel,"

CARLOS JIRON aka "Lucho" and "Luis,"

JESUS ABEL ROLDAN aka "Tomatico"

DAVID ACEVEDO,

WILLIAM ANTHONY MORCIGLIO aka ~~Woody,"

MARCUS JONES aka "Titty" and "T,"

DANIEL C. MALDONADO,

ANGEL GEORGE MELENDEZ, JR.,

NATHAN THOMAS aka "Edwin Garcia,"

DIANA MUNOZ,

YOLANDA RIVERA,

IRIS D. TORRES,

RUBEN CHAPARRO-RAMOS,

MARTHA LLANOS aka "Martica", "La Mona", and "Pie Malo,"

VIBENCIO CONSUEGRA,

SHANTELL HILL,

RICARDO ARNOLD aka "Ricky" and "Chino,"

MIGUEL SANCHEZ aka "Mikey,"

MILENA P. PUPO aka "Paisa" and "Paisita,"

LUIS E. RIVERA aka "Tito,"

JUAN LOZADA aka "Mono", "Monito" and "Pablito,"
L ~ Z I t_ _ ~ i ~ l ~ l- ~ ~_ I L

~~~,

SANDRA P. VELAZQUEZ aka "La Negra" and "Negrita,"

and (b) that between in or about June 2002 to the present,

the following individuals conspired and agreed with each other and

with others known and unknown to commit money laundering, in

violation of Title 18, United States Code, Section 1956(h):

JAMES VALENCIA also known as "Jota" and "Father,"

KELLY JONES aka "Bone" and "Miguel,"

CARLOS JIRON aka "Lucho" and "Luis,"

MARTHA LLANOS aka "Martica", "La Mona", and "Pie Malo,"

COSME CHACON aka "Meno" and "Nano"

VIVIANA HERNANDEZ

8. Based on my training and experience and discussions with

other experienced law enforcement officers, I know that wholesale

drug traffickers regularly keep the following items at places

within their control, including their residences, for extended

periods of time:

a. Controlled substances;

b. Drug paraphernalia, including scales, cutting

supplies, and packaging;

c. Weapons and ammunition;

d. Cash, jewelry, and precious metals;

e. Records of drug sales, including ledgers and

tally sheets;

f. Financial information and statements, books,

records, receipts, cash disbursement journals,

computers, discs, software, safe deposit box

keys, bank statements, tax returns and other

records related to the receipt, expenditure

and concealment or other disposition of

income.

II. OVERVIEW OF THE CONSPIRACY

9. Since in or about December 2001, Customs has conducted an

investigation concerning the drug trafficking and related

activities of JAMES VALENCIA and other individuals working with and

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on behalf of VALENICA, including drug suppliers, distributors,

customers, and couriers.

10. This investigation has revealed that VALENICA heads a

large-scale drug organization that distributes multi-kilogram

quantities of heroin in various cities in the United States,

including Chicago, Illinois, New York City and Miami, Florida (the

'VALENCIA organization") At the direction of VALENCIA, high-level

members of the VALENCIA organization coordinate the interstate

delivery of large quantities of heroin to Chicago and elsewhere, as

well as the delivery of drug proceeds to various wire remitter

businesses in Chicago and to members of the organization located

outside of Chicago. These high-level members, including VALENCIA,

KELLY JONES, CARLOS JIRON, and JESUS A. ROLDAN, communicate with

each other by telephone to coordinate these deliveries of heroin

and drug proceeds. The high-level members typically send drug

couriers from Chicago to these other cities to meet with and

receive heroin shipments from members of the organization who are

stationed in these cities. The drug couriers, who often deliver

drug proceeds to their co-conspirators in these other cities, pick

up the heroin shipment and transport the shipments of heroin back

to Chicago, usually by car or bus. After the heroin arrives in

Chicago, the drugs are typically brought to a "lab," which is a

location where members of the organization process and prepare the

heroin for further distribution to members of the conspiracy,

'~
including MARTHA LLANOS, VIBENCIO CONSUEGR.A, SHANTELL HILL, RICARDO

ARNOLD, MIGUEL SANCHEZ, MILENA PUPO, LUIS RIVERA, JUAN LOZADA,

SANDRA P. VELAZQUEZ, and others, who in turn distribute the heroin

to customers.

11. This investigation has revealed the following about the

roles of the defendants in the VALENCIA organization:

A. Organizers/Leaders

a. JAMES VALENCIA aka "Father" and "Jota," heads the

VALENCIA heroin organization and operates the organization from

South America.l

b. KELLY JONES aka "Bone" and "Miguel" is an organizer

and leader of the Chicago-area cell of the VALENCIA heroin

organization who distributed large quantities of heroin to members

of the conspiracy and others.2 Since June of 2002, various

telephones used by KELLY JONES, including Target Phones I, II, III,

lAs described in this affidavit, beginning on June 14, 2002,

Customs began intercepting wire communications over telephones

used by KELLY JONES, and later over telephones used by CARLOS

JIRON aka "Lucho." Prior to the initiation of this wire tap, two

members of the organization, NATHAN THOMAS and Source of

Information 1 ("SOI 1"), had provided information to Customs that

VALENCIA was the leader of this heroin organization and that they

believed he was living in South America. NATHAN THOMAS provided

Customs agents with a photograph of JAMES VALENCIA, which Customs

compared with photographs contained in JAMES VALENCIA'S

Immigration & Naturalization Service (INS) records. Based on

Customs' comparison of these photographs, they were of the same

person, JAMES VALENCIA.

ZDuring the wire interception investigation, Customs

identified KELLY JONES through surveillance, among other means.

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and V2I2, were the subjects of court-authorized wire interceptions.

c. CARLOS JIRON aka "Lucho" and "Luis" is an organizer

and leader of the Chicago-area cell of the VALENCIA heroin

organization who distributed large quantities of heroin to members

of the conspiracy and others.3 Since August of 2002, various

telephones used by CARLOS JIRON, including Target PHones IV, V, VI,

VII, IX and X, were the subjects of court-authorized wire

interceptions.

d. JESUS ABEL ROLDAN aka "Tomatico" is an organizer and

leader of the Miami, Florida area cell of the VALENCIA heroin

organization who distributed large quantities of heroin to members

of the conspiracy and others.4

B. Couriers

e. DAVID ACEVEDO assisted in the VALENCIA heroin

organization by, among other things, transporting wholesale

quantities of heroin from other cities to Chicago, Illinois for

distribution to others.5

3During the wire interception investigation, law enforcement

conducted a car stop on this individual and identified him as

CARLOS JIRON. Moreover, he was observed during surveillance.

4During the wire interception investigation, law enforcement

conducted surveillance of this individual in Florida and Chicago.

On or about October 28, 2002, agents conducted surveillance on

this individual, and based on Florida driver's license records,

identified this individual as JESUS ABEL ROLDAN.

SDuring the wire interception investigation, this individual

was identified as DAVID ACEVEDO during a traffic stop by Chicago

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f. WILLIAM ANTHONY MORCIGLIO aka "Woody," assisted in

the VALENCIA heroin organization by, among other things,

transporting wholesale quantities of heroin from other cities to

Chicago, Illinois for distribution to others.6

g. MARCUS JONES aka "Titty" and "T," assisted in the

VALENCIA heroin organization by, among other things, transporting

wholesale quantities of heroin from other cities to Chicago,

Illinois for distribution to others.'

h. DANIEL C. MALDONADO, assisted in the VALENCIA heroin

organization by, among other things, transporting wholesale

quantities of heroin from other cities to Chicago, Illinois for

distribution to others.$

i. ANGEL GEORGE MELENDEZ, JR., assisted in the VALENCIA

heroin organization by, among other things, transporting wholesale

quantities of heroin from other cities to Chicago, Illinois for

Police Department and on surveillance.

6During the wire interception investigation, this individual

was identified through a photograph contained in his California

criminal records and on surveillance.

'During the wire interception investigation, this individual

was identified through telephone records, driver's license

records, and on surveillance.

$During the wire interception investigation, this individual

was identified on surveillance and when law enforcement officers

conducted a car stop on a vehicle and identified this person as

"Daniel C. Maldonado".

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distribution to others.9

j. NATHAN THOMAS aka "Edwin Garcia," assisted in the

VALENCIA heroin organization by, among other things, transporting

heroin from other cities to Chicago, Illinois for distribution to

others .10

k. DIANA MUNOZ, assisted in the VALENCIA heroin

organization by, among other things, transporting wholesale

quantities of heroin from other cities to Chicago, Illinois for

distribution to others,ll

1. YOLANDA RIVERA, assisted in the VALENCIA heroin

organization by, among other things, transporting wholesale heroin

from other cities to Chicago, Illinois for distribution to others.lz

m. IRIS D. TORRES, assisted in the VALENCIA heroin

organization by, among other things, meeting with couriers of the

9During the wire interception investigation, this individual

was identified on surveillance and when an officer conducted a

traffic stop of a vehicle driven by this individual and

identified him as Angel George Melendez, Jr.

10As described in this affidavit, this individual was, at

one point, cooperating with law enforcement. However, soon after

the wire interception investigation began, THOMAS stopped

cooperating with law enforcement and later on participated in the

conspiracy by transporting a heroin shipment from Florida to

Chicago for KELLY JONES.

11As described in this affidavit, MUNOZ was identified by

law enforcement while waiting at Midway Airport in Chicago,

Illinois. She was also identified on surveillance.

1ZDuring the wire interception investigation, this

individual was identified through driver's license records and

surveillance.

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organization who had transported wholesale quantities of heroin to

Chicago, obtaining the heroin from these couriers in Chicago, and

then delivering the heroin to CARLOS JIRON for further

distribution.l3

n. RUBEN CHAPARRO-RAMOS, assisted in the VALENCIA

heroin organization by, among other things, transporting wholesale

quantities of heroin from other cities to Chicago, Illinois for

further distribution.14

C. Chicago-Based Heroin Distributors

o. MARTHA LLANOS aka "Martica", "La Mona", and "Pie

Malo," is a member of the VALENCIA heroin organization who obtained

wholesale quantities of heroin on a regular basis from KELLY JONES

and CARLOS JIRON, for purposes of further distribution of the

heroin to others. LLANOS also received proceeds from the sale of

heroin ("drug proceeds") from members of the VALENCIA heroin

organization and laundered the proceeds through her various wire

remitter businesses.ls

13During the wire interception investigation, this

individual was identified through driver's license records and

surveillance.

14During the wire interception investigation, this

individual was identified through driver's license records and

surveillance, as well as hotel records.

1sDuring the wire interception investigation, this

individual was identified by surveillance, telephone records, and

Secretary of State records.

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p. VIBENCIO CONSUEGRA, is a member of the VALENCIA

heroin organization who obtained wholesale quantities of heroin on

a regular basis from KELLY JONES and CARLOS JIRON, for purposes of

further distribution of the heroin to others,16

q. SHP,NTELL HILL, is a member of the VALENCIA heroin

organization who obtained wholesale quantities of heroin on a

regular basis from KELLY JONES, for purposes of further

distribution of the heroin to others.'i

r. RICARDO ARNOLD aka "Ricky" and "Chino," is a member

of the VALENCIA heroin organization who obtained wholesale

quantities of heroin on a regular basis from KELLY JONES,~for

purposes of further distribution of the heroin to others.18

s. MIGUEL SANCHEZ aka "Mikey," is a member of the

VALENCIA heroin organization who obtained wholesale quantities of

heroin on a regular basis from KELLY JONES, for purposes of further

distribution of the heroin to others.19

16During the wire interception investigation, this

individual was identified through his arrest record and

surveillance.

17During the wire interception investigation, this

individual was identified through surveillance, a traffic stop,

and arrest records.

18During the wire interception investigation, this

individual was identified through surveillance and Secretary of

State records.

19During the wire interception investigation, this

individual was identified through a traffic stop by Chicago

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t. MILENA P. PUPO 20 aka "Paisa" and "Paisita" and LUIS

E. RIVERAzl aka "Tito," are members of the VALENCIA heroin

organization who obtained wholesale quantities of heroin on a

regular basis from KELLY JONES and CARLOS JIRON, for purposes of

further distribution of the heroin to others. The investigation

indicates that PUPO is the wife of LUIS E. RIVERA, and that they

both work together in the distribution of drugs.

v. JUAN LOZADA aka "Mono", "Monito" and "Pablito,"is a

member of the VALENCIA heroin organization who obtained wholesale

quantities of heroin on a regular basis from CARLOS JIRON, for

purposes of further distribution of the heroin to others.22

w. SANDRA P. VELAZQUEZ aka "La Negra" and "Negrita, " is

a member of the VALENCIA heroin organization who obtained wholesale

quantities of heroin on a regular basis from KELLY JONE5 and CARLOS

JIRON, for purposes of further distribution of the heroin to

Police Department.

20During the wire interception investigation, this person

was identified through surveillance and a driver's license

photograph.

21During the wire interception investigation, this

individual was identified through surveillance and Secretary of

State records.

Z2During the wire interception investigation, this

individual was identified through surveillance and a traffic

stop, as well as Secretary of State records.

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others . 23

D. Launderers of Drug Proceeds

x. COSME CHACON24 aka "Meno" and "Nano" and VIVIANA

HERNANDEZZS are members of the VALENCIA heroin organization who

received drug proceeds from members of the organization and

laundered those proceeds through a wire remitter business, which

CHACON and HERNANDEZ, believed to be his wife, operate.

II2. PROBABLE CAUSE

A. Historical Information

12. Before the wiretap phase of this investigation began on

June 14, 2002, NATHAN THOMAS was cooperating with law enforcement.

During this period of cooperation, THOMAS provided credible

historical information about the VALENCIA organization.26 THOMAS

had personally participated in numerous interstate shipments of

heroin for the organization, and had consensually recorded

telephone conversations with KELLY JONES concerning heroin

z3During the wire interception investigation, this

individual was identified through a traffic stop and

surveillance.

24During the wire interception investigation, this

individual was identified through telephone records and [FBI CW.]

ZSDuring the wire interception investigation, this

individual was identified through surveillance and SOS records,

[AND FBI CW)

26However, soon after the initiation of the wire tap, THOMAS

stopped cooperating and afterwards assisted the organization as a

drug courier.

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trafficking over Target Phone I, and overheard JONES' end of

conversations relating to narcotics trafficking over Target Phone

II. THOMAS has identified, among other individuals, JAMES VALENCIA

as the head of the VALENCIA organization who resides in Colombia,

South America; KELLY JONES as the head of the Chicago-based cell of

the organization; MARCUS JONES as an individual who packages the

heroin for distribution for the organization; DAVID ACEVEDO as an

individual who packages the heroin for the organization; SHANTELL

HILL as a customer of the organization; "CONSUEGRA" (VIBENCIO

CONSUEGRA) as a customer of the organization; "PAISA" (MILENA PUPO)

as someone believed to be a customer of the organization; as well

as members of the organization in New York, Florida, California,

and Michigan.

13. THOMAS has been arrested in Illinois at least twenty-six

times, and has four convictions. THOMAS has one arrest in the

state of Florida for the charge of Unlawfully Engaging in the

Business of Money Transmissions, which charge is still pending in

Florida.

14. THOMAS began cooperating after he was arrested in

Mississippi on January 25, 2002 following a traffic stop and

consent search of his vehicle that resulted in the seizure of

approximately fourteen grams of marijuana and $5,000.00 cash.

When he was arrested, THOMAS said that he was traveling to New

Orleans, Louisiana, to pick up heroin for the VALENCIA organization

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and bring the heroin to KELLY JONES in Chicago. The State of

Mississippi had agreed not to prosecute THOMAS based on his arrest

on January 25, 2002, so long as he cooperated with Mississippi

state authorities and federal authorities in their investigation.

15. From at least February 7, 2002 until May 2002, THOMAS

had provided multiple post-arrest statements to Customs about the

VALENCIA organization and his personal involvement in the

organization. During this time period, THOMAS made and received

several consensually-recorded telephone calls to and from KELLY

JONES on Target Phone I. No promises were made to THOMAS

concerning the statements he made to Customs about the VALENCIA

organization. THOMAS was told that his statements to Customs about

his role in the VALENCIA organization exposed him to substantial

criminal liability. At the time of his cooperation, THOMAS was

cooperating in the hope that his cooperation would result in lesser

charges and/or a reduced sentence. THOMAS had also received

$4,000.00 in payment for information furnished to Customs.

16. Before THOMAS's period of cooperation with Customs,

THOMAS had purchased a false social security card and birth

certificate, and obtained a driver's license using the false

documents to obtain a new name. THOMAS' stated purpose for using

the new name was to attempt to get out of the drug business.

17. During THOMAS's period of cooperation with Customs,

Customs agents instructed THOMAS to report any contact or

communications he had with either KELLY JONES or JAMES VALENCIA.

-16-
.. _ 1... _ ~.. 1 i . - ~. _ 1.

~,\

During this period, it was discovered that THOMAS had contacts with

KELLY JONES which were not reported to Customs. When confronted by

agents with these unreported contacts, THOMAS admitted to these

contacts . 27

18. After the wiretap investigation began, THOMAS stopped

cooperating with law enforcement. In particular, THOMAS failed to

accurately disclose to Customs his communications with KELLY JONES

and he refused to follow the instructions of Customs. Moreover, as

described later in this affidavit, THOMAS and YOLANDA RIVERA drove

to Florida to pick up heroin and brought it back to KELLY JONES,

even though THOMAS was specifically instructed by Customs on

several occasions that he was not to participate in any drugrelated activity.

19. Your Affiant believes that the information provided by

27According to THOMAS, one of the contacts he had with KELLY

JONES (which he did not report to Customs) was on April 30, 2002,

when he was with KELLY JONES when JONES met with SHANTELL HILL.

JONES asked THOMAS to approach the vehicle of HILL and obtain

money from him. THOMAS received a quantity of currency from

HILL, that HILL reported to be $2,705.00. THOMAS gave the

currency to JONES. THOMAS stated that he believed this money was

payment for heroin, since HILL at one time used to be a heroin

customer of THOMAS. In addition, THOMAS stated that earlier that

same day, THOMAS and KELLY JONES went in JONES' Navigator to a

house that according to THOMAS, a male who THOMAS knows only as

"Consuegro" [VIBENCIO CONSUEGRA] resides. While at that house,

JONES exited the vehicle and went into the house. After some

time elapsed, JONES came back out of the house and entered the

vehicle, and later that day drove to meet the male on the

motorcycle. According to THOMAS, in his past trips to New York

on behalf of the organization, THOMAS has seen "Consuegro"

(VIBENCIO CONSUEGRA) in New York. According to THOMAS, KELLY

JONES told THOMAS that "Consuegro" (CONSUEGRA) is one of his

heroin customers.

-17-
>..t ~ 1. -- _ .. 1.

~~

THOMAS is reliable. THOMAS's post-arrest statements implicated him

in criminal conduct and were made against his penal interest. A

substantial portion of the information provided by THOMAS

concerning the organization has been corroborated by consensual

tape recordings, physical surveillance, travel records, and

telephone records, and intercepted conversations during the wire

interception investigation described below. The information

provided by THOMAS about the VALENCIA heroin organization is based

on both first-hand knowledge and/or from individuals with first

hand knowledge of the events referred to.

20. THOMAS advised law enforcement agents that he had been

involved with the VALENCIA drug organization since November 1999.

THOMAS stated that he had transported between 50 and 100 kilograms

of heroin into the Chicago, Illinois area and transported more than

one million dollars in currency. Based on his personal involvement

with the organization, he has learned that JAMES VALENCIA is the

head of the organization and has heroin distribution organizations

in various United States cities, including Chicago, Illinois.

According to THOMAS, he has traveled to New York, Fort Lauderdale,

Detroit, Los Angeles, and New Orleans to traffic narcotics on

behalf of the organization. According to THOMAS, KELLY JONES

oversees the Chicago cell of the organization and has done so since

January 2001. THOMAS provided Customs with photographs of JAMES

VALENCIA, which depicted the same individual in photographs

contained in VALENCIA'S INS alien file.
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21. According to THOMAS, the VALENCIA organization smuggles

multi-kilogram quantities of heroin from various United States

cities, to include New York, New Orleans and Ft. Lauderdale, into

the Chicago area. Once the heroin is in Chicago, it is broken down

and packaged into street level distribution quantities and

distributed by members of the VALENCIA organization. THOMAS acted

as a drug courier for the organization, traveling to distant cities

to transport narcotics and deliver money. THOMAS explained that

the heroin was processed and packaged at a "lab" in Chicago.

B. Wiretap Investigation

22. Beginning on June 14, 2002, several federally courtauthorized wiretaps involving several cellular telephones used by

KELLY JONES and CARLOS JIRON, were obtained. These wire taps

involved Target Phones I through X. KELLY JONES was the principal

user of Target Phones I, II, III, and VIII, and LUCHO (JIRON) was

the principal user of Target Phones IV, V, VI, VII, IX, and X. The

relevant orders were obtained on the following phones and dates:

June 14, 2002 (Target Phones I and II); July 12, 2002 (Target

Phones I, II and III); August 9, 2002 (Target Phones I, III, IV and

V); September 6, 2002 (Target Phones I, III, VI, and VII); October

10, 2002 (Target Phones I, VI, and VIII); and October 25, 2002

(Target Phones IX and X).

~Z
IV. INTERCEPTED CONVERSATIONS AND SURVEILLANCE

23. Pursuant to the above-listed court orders, wire

communications to and from Target Phones I through X were

intercepted at various times from June 14, 2002 to the present.

Moreover, agents conducted surveillance before and during the time

periods of the wire interceptions. The intercepted conversations

and related investigation establish the involvement of members of

the VALENCIA organization in the drug trafficking conspiracies

charged in the attached complaint.

24. For some of the calls summarized below, I have placed in

brackets my and other agents' understanding of what is being said

during the call, based on the contents and context of the

conversations, my experience as a law enforcement officer and the

experience of other law enforcement officers in this investigation,

including our experience listening to the intercepted conversations

as a whole. The times listed for these calls are approximate. In

most cases, voice identifications are based on names used during

the intercepted conversations, voice recognition that has been

accomplished to date by agents or translators, historical

information developed during this investigation, telephone

subscriber information, and/or surveillance by agents. Many of the

conversations were in Spanish and have been translated, which

translations are preliminary. Finally, the summaries below do not

include all potentially criminal calls intercepted during the

-20-
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period of interception, or all statements or topics covered during

the course of the intercepted conversations.

Druq Shipment From New York to Chicano

June 15 - 17, 2002

25. On June 15, 2002, at approximately 3:51 p.m., KELLY JONES

used Target Phone I to contact telephone number (773) 895-4323, a

cellular phone subscribed to DAVID ACEVEDO. During this call,

JONES spoke on the phone with Individual N and asked for "Diana's"

telephone number. Individual N provided the telephone number

"547-0370."

26. On June 15, 2002, at approximately 5:16 p.m., KELLY JONES

received an incoming call on Target Phone I from (773) 547-0370,

the number previously provided by Individual N for "Diana" (later

identified as DIANA MUNOZ). During this telephone conversation,

KELLY JONES and MUNOZ agreed to meet in order for JONES to give

MUNOZ a "ticket." MUNOZ informed JONES that she needed to "shower"

and "pack."

27. On June 15, 2002, at approximately 5:18 p.m., KELLY JONES

using Target Phone II called telephone number (646) 246-3855, a New

York telephone number, and spoke to a person in New York who

supplies heroin to the VALENCIA organization (the "New York

Supplier"). JONES told the New York Supplier that he (JONES) was

sending his girlfriend on this same date and her flight arrived at

11:00 p.m. JONES asked if he would like her to travel to New York

Supplier's "crib" by taxi [take a taxi cab to New York Supplier's

-21-
- ~ _ ~ i ,_ ~ ~ ~ ~ L _ ~ ( -

~_

,\

home to pick up heroin]. New York Supplier instructed JONES to

have her (MUNOZ) call New York Supplier when she arrives. JONES

informed New York Supplier that he (JONES) will give her New York

Supplier's telephone number and she will call. JONES informed New

York Supplier that her name is "Diana.i28

28. On June 15, 2002, at approximately 8:02 p.m., KELLY JONES

received a call on Target Phone II from MUNOZ, and MUNOZ told JONES

that she was at the airport and that she missed her flight. MUNOZ

advised JONES that a flight was leaving the following morning and

that she would take that flight. MUNOZ stated that she would call

JONES after she made the flight arrangements.

29. On June 15, 2002, at approximately 8:28 p.m., while

surveillance agents observed a Hispanic female standing near the

ATA Airlines ticket counter at Midway Airport. A Chicago Police

Department (CPD) officer approached MUNOZ and asked for

identification. MUNOZ produced identification documents showing

that she was "Diana Munoz," and indicated to the officer that her

address was 2456 North Kilpatrick, Chicago, Illinois.

30. -0n June 15, 2002, at approximately 8:29 p.m., KELLY JONES

received a call on Target Phone II from MUNOZ. MUNOZ informed

28After this telephone conversation, a Customs agent

contacted ATA airlines and determined that ATA had two flights

leaving Chicago Midway Airport and arriving in New York at

LaGuardia Airport on June 15, 2002. The first flight was

scheduled to depart Midway at 7:09 p.m. and arrive at LaGuardia

at 10:29 p.m. The second flight was scheduled to depart Midway

at 8:10 p.m. and arrive at LaGuardia at 11:30 p.m.

-22-
JONES that she arranged a 6:20 a.m. flight for the following

morning (June 16, 2002). MUNOZ asked JONES if he would pick her up

from the airport and JONES agreed.

31. On June 15, 2002, at approximately 8:56 p.m., a Customs

agent observed MUNOZ standing near the curb of the ATA departure

area at Midway. The agent observed a black Lincoln Navigator with

at least two male occupants, with Illinois license plate 1353413,

drive to the ATA arrival area.29 MUNOZ entered the Navigator, and

the vehicle departed the area.

32. The next day (June 16, 2002) at approximately 7:08 a.m.,

MiJNOZ called Target Phone I and left a voice message. She stated

in her voice message that she missed her flight and that she made

reservations on the next available flight, which was departing

later that same day at 7:00 p.m. MUNOZ stated that JONES should

call "his friend" [New York Supplier from whom she was going to

pick up the heroin] and let him know that she would contact him

(New York Supplier) when she arrived.

33. On June 16, 2002, at approximately 7:00 p.m., KELLY JONES

received a call on Target Phone II from New York Supplier. During

this telephone conversation, New York Supplier infor-med JONES that

he was waiting for JONES' girlfriend (MUNOZ) and asked what time

she would arrive. JONES informed New York Supplier that she would

29Based on Illinois Secretary of State ("SOS") records, this

vehicle is registered to KELLY JONES. Moreover, on prior

occasions, surveillance agents and officers have seen KELLY JONES

driving this vehicle.

-23-
--~ ~_,

arrive at 10:00 p.m. New York Supplier instructed JONES to have

her (MUNOZ) call New York Supplier when she arrived.

34. On June 16, 2002, at approximately 9:22 p.m., KELLY JONES

using Target Phone 22 made an outgoing call to New York Supplier.

During this call, JONES asked New York Supplier if MUNOZ should

travel to New York Supplier's apartment. New York Supplier stated

that he had instructed MUNOZ where to go. JONES asked New York

Supplier to call him (JONES) when it [the drug transaction] was

done.

35. On June 16, 2002, at approximately 9:55 p.m., KELLY JONES

received a call on Target Phone II from MUNOZ. JONES instructed

ML]NOZ to travel to the Greyhound bus station at the Port Authority

on 42nd Street and 5th Street [in New York].

36. On June 16, 2002, at approximately 10:04 p.m., KELLY

JONES received a call on Target Phone 2I from MUNOZ. During this

call, JONES asked MUNOZ if she had a bag or if "it's showing" [boom

box used to conceal the heroin] and if she was going to attempt to

put "it" [the boom box] in her bag.

37. On June 17, 2002, at approximately 2:59 p.m., MUNOZ

called Target Phone I and left a voice message. MUNOZ stated that

she was in Chicago and would be downtown at 3:30 p.m. MUNOZ

further stated that a person [believed to be a friend of MUNOZ]

would pick her up and requested JONES to call her in order to make

arrangements for MUNOZ to see him [to give JONES the heroin].

-24-
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38. On June 17, 2002, at approximately 4:10 p.m.,

surveillance agents and officers (collectively "surveillance

agents") observed a Dodge Neon arrive at the Greyhound bus station

in Chicago, Illinois, and further observed MUNOZ enter that

vehicle.

39. On June 17, 2002, at approximately 4:48 p.m, KELLY JONES

received a call on Target Phone II from MUNOZ. During the call,

MUNOZ informed JONES that she was currently at her residence.

JONES informed MUNOZ that he would arrive at her residence in

thirty minutes.

40. On June 17, 2002, at approximately 5:25 p.m.,

surveillance agents went to MUNOZ's residence at 2456 North

Kilpatrick, Chicago, Illinois. Agents/officers observed the Dodge

Neon parked in front of that residence. Shortly thereafter, agents

and officers observed three individuals, later determined to be

KELLY JONES, WILLIAM MORCIGLIO, and DANNY MALDONAD0,30 enter the

2456 North Kilpatrick residence without anything visible in their

possession, and afterwards observed those same three individuals

along with DAVID ACEVEDO exit the residence. MALDONADO was in

possession of a "boom box" style portable stereo [commonly used by

members of the VALENCIA organization to transport heroin], which he

3oThese identifications are based on Customs agents'

familiarity of the physical appearance of these members of the

organization and the agents' review of the surveillance video

tape.

-25-
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handed to KELLY JONES.31 Afterwards, JONES and other unidentified

individuals entered JONES' Lincoln Navigator - and left the area.

41. On June 17, 2002, at approximately 10:52 p.m., KELLY

JONES called an unknown male (hereinafter UM 1) using Target Phone

II. During this conversation, UM 1 complained to JONES that the

"CDs" [heroin] that JONES had provided to him were "stepped-on."32

In response, JONES asked whether UM 1 was referring to the new ones

that JONES had just given UM 1, and further stated that he (JONES)

had not touched them [that JONES had not stepped on or cut the

heroin] .

KELLY JONES Delivers Drug Proceeds to COSME CHACON

June 20 - 21, 2002

42. On June 20, 2002, at approximately 12:45p.m., KELLY JONES

received a call on Target Phone II from "MEND" (COSME CHACON).

This call was from (312) 733-2470, which is registered to COSME

CHACON, 1842 S. Blue Island, Chicago, Illinois. During this

conversation, "MEND" asked JONES if they have to talk today, and

JONES replied it would be good to talk. JONES asked "MENO" how he

31Both NATHAN THOMAS and SOI 1 have indicated to law

enforcement agents/officers that members of the VALENCIA

organization use boom box style stereos to transport drugs and

drug proceeds. Also, as set forth below, DIANA MUNOZ used a boom

box style portable stereo to transport approximately 1.5

kilograms of heroin from New York to Chicago on behalf of the

organization.

32Based on Affiant's training and experience, drugs that are

"stepped-on" or "cut" means drugs that are mixed with a substance

to increase the quantity of drugs, and as a result, generally

reducing the quality of the drugs.

-2 6-
~ "'•

wanted to do it, and "MEND" told JONES to tell me when you are

ready.

43. During the investigation, NATHAN THOMAS accompanied

agents to the above subscriber address (1842 S. Blue Island,

Chicago, Illinois), which is a wire remitter business, and stated

that members of the VALENCIA organization delivered currency to

this business location.

44. On June 20, 2002, at approximately 6:23 p.m., KELLY JONES

received a call on Target Phone II from JAMES VALENCIA. During

this conversation, JONES informed VALENCIA that he did not have

MENO's (CHACON) phone number. JONES further stated that MEND was

going to call him at 4:00 p.m., in order to set something up [to

arrange a meeting likely for the purpose of delivering drug money].

JONES then stated that MEND never called him. VALENCIA then

provided JONES with the telephone number 851-3051. Subsequent

interceptions of MENO's telephone calls indicate that the correct

telephone number is (773) 851-3021.

45. On June 21, 2002 at approximately 12:29 p.m., KELLY JONES

received a call on Target Phone II from MEND (CHACON) During this

conversation MENO asked JONES "how many", and JONES replied twentynine, that he had thirty but dropped one [it is believed that 29

refers to $29,000 of drug money]. MEND asks JONES if he was going

to have any more today or tomorrow. JONES replied that he might

have more later. JONES then asked MEND if he knew LUCHO, and MEND

-27-
j ~

~~

replied that he did.

46. On June 21, 2002, at approximately 6:05 p.m., KELLY JONES

received a call on Target Phone II from MEND (CHACON) from (773)

851-3021. MENO told JONES that JONES was supposed to give him

(MENO) "twenty-nine," but that the bank counted out only 27,781.

JONES stated that he had counted it himself and put it [the money]

in order. JONES stated that it was supposed to be thirty, but he

dropped one [so that it was supposed to be $29,000]. JONES stated

that he put everything in two's and one's, and all the five's in

five hundreds. JONES stated that is how he always brings it.

JONES stated that it is not his money, and that he just organizes

it and gives it away.

47. On June 23, 2002, at approximately 1:47 p.m., KELLY JONES

received a call on Target Phone II from JAMES VALENCIA. During

this conversation, VALENCIA instructed JONES to contact LUCHO

(CARLOS JIRON) JONES then asked VALENCIA about problems with MEND

(CHACON). JONES stated that "I go bring him thirty" and "I put

everything in a bag and I drop." JONES told VALENCIA that he found

a thousand at his house. JONES stated that he counted everything,

and separated it into 20's, 10's, and 5's [denominations that

represent drug money]. JONES told VALENCIA that he has never had

a problem before. JONES said that MEND told him that the bank said

it was twenty-seven. JONES stated that he counted the money using

Individual N's machine.
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Drug Shipment From New York to Chicago

June 26 - 28, 2002 and

Seizure of 1.5 Kilograms of Heroin From DIANA MUNOZ

48. On June 26, 2002, at approximately 6:43 p.m., KELLY JONES

received a telephone call on Target Phone I from JAMES VALENCIA.

During this conversation, VALENICA told JONES that he needed a

"favor." VALENICA asked JONES if he (JONES) would send someone to

his (VALENCIA's) "daughter's house" ["daughter's house" refers to

New York, since VALENICA at one time lived and worked there, and

the investigation has indicated that VALENICA has a young daughter

who is believed to live in New York]. JONES stated that he would

send someone to New York. VALENICA instructed JONES to see "LUCHO"

(CARLOS JIRON) before the trip was made, in order to send money for

his (VALENCIA'S) "bills" [VALENCIA'S drug debts, likely owed to an

unidentified person in New York]. VALENICA told JONES that he

(VALENICA) would call LUCHO and then call JONES when LUCHO is

"ready." VALENICA instructed JONES to send someone on the night of

the conversation (June 26, 2002).

49. On June 26, 2002, at approximately 6:48 p.m., KELLY JONES

made a call on Target Phone I to DANIEL MALDONADO at (773) 895-

1206. During this conversation, JONES spoke with MALDONADO and

~~ANGEL" (later identified as ANGEL MELENDEZ, JR.), and JONES

informed MALDONADO that he had a "store mission," [drug-related

trip to New York] that needed to be done in the "next couple of

hours." JONES further stated that he had a "beach mission" [drug-

-29-
related trip to Florida] during the upcoming weekend. JONES

informed MALDONADO that he was trying to "work everything up right

now" and that if he (MALDONADO) could not make the trip, JONES

could "send the girls" [send one of the organization's female

couriers]. MALDONADO informed JONES that he would be unable to

make the trip, but stated that "ANGEL" (MELENDEZ) was with him.

JONES and MELENDEZ then talked on the phone. During their

conversation, JONES informed MELENDEZ that there was a "mission"

[drug-related trip]. MELENDEZ asked JONES if the mission was to

the "beach" [Florida]. JONES stated that the "mission" was not to

the "beach", but rather to the "store" [New York]. MELENDEZ

informed JONES that his (MELENDEZ's) sister could drive him to New

York. JONES instructed MELENDEZ to call later.

50. On June 27, 2002, at approximately 12:37 p.m., KELLY

JONES used Target Phone 22 and called JAMES VALENICA. During this

conversation, JONES informed VALENICA that "everything is fine."

VALENCIA asked JONES if he had sent his "boys" [couriers to pick up

heroin] and JONES acknowledged that he did and that they left "last

night". JONES further stated that he had talked with "CONSUEGRA"

(VIBENCIO CONSUEGRA) and that CONSUEGR.A's "big man" was ready and

wanted "1000" [a quantity of heroin]. VALENICA asked JONES how

many people he sent on the trip. JONES stated that he had sent two

people that were traveling in a car. JONES asked VALENICA if he

needed anything further. JONES informed VALENCIA that the two

individuals would arrive sometime around 2:00 a.m. or 3:00 a.m.,

-30-
'I ~

because it was a thirteen hour drive. VALENCIA instructed JONES to

have one of the individuals return via bus.

51. On June 27, 2002, at approximately 12:43 p.m., KELLY

JONES received a call on Target Phone II from New York Supplier

from (646) 263-6228. During this conversation, New York Supplier

wanted to know what time JONES' "girlfriend" [MUNOZ] would be

arriving. JONES informed New York Supplier that he had sent his

"friends" and they would arrive sometime in the early morning

hours. JONES informed New York Supplier that he was also

considering sending his "girlfriend".

52. On June 27, 2002, at approximately 12:45 p.m., KELLY

JONES called MUNOZ on Target Phone II at (773) 882-1212. During

the conversation, JONES asked MUNOZ if she would travel to the

"store" [New York to pick up heroin] again, and MUNOZ agreed.

JONES stated that MUNOZ would need to leave on the day of the call

(June 27). JONES informed MUNOZ that he would get the ticket [an

airplane ticket] and she would be leaving around the same time as

the last trip [her prior trip to New York on June 16, 2002],33

33

At approximately 1:37 p.m. on June 27, 2002, JONES called

telephone directory assistance using Target Phone I, and

requested the telephone number for ISLA TRAVEL on Foster

(Chicago). JONES was then forwarded to (773) 334-2118. During

this call, JONES spoke with a travel representative. JONES

inquired about flights to New York/LaGuardia airport, leaving on

that evening, June 27, 2002. The representative told JONES that

there was a flight scheduled to leave at 7:00 p.m. (Central Time)

and would arrive in New York at 10:30 p.m. (Eastern Time). The

representative further stated that the cost of the ticket was

$225.00. JONES told the representative that he would purchase

the ticket and gave the name of the traveler as "Diana MUNOZ".

-31-
JONES asked MUNOZ if she had a bag, so that she would not have to

carry "that" out [boom box stereo used to conceal the heroin].

JONES further stated that she (MUNOZ) now knows how big "they are"

[boom box stereo], so she should get a duffel bag the same size.

JONES stated he would get the ticket and meet her later.

53. On June 27, 2002, at approximately 12:48 p.m., KELLY

JONES called VIBENCIO CONSUEGR.A using Target Phone 2I at (773) 562-

0537 and informed him (CONSUEGR.A) that he has "two people for

tomorrow night" [two individuals returning with the heroin].

54. On June 27, 2002, at approximately 2:28 p.m., KELLY JONES

called MARCUS JONES using Target Phone I at (773) 592-0398. During

this conversation, KELLY JONES informed MARCUS JONES that he (KELLY

JONES) was picking up a plane ticket and he would be over later.

MARCUS JONES informed KELLY JONES that he (MARCUS JONES) had his

clothes ready "just in case."

55. On June 27, 2002, at approximately 2:59 p.m., KELLY JONES

using Target Phone II called (646) 263-6228 and again spoke with

New York Supplier. During this conversation, JONES informed New

York Supplier that he (New York Supplier) would see JONES'

girlfriend later that night (June 27). JONES informed New York

Supplier that she would be there at 10:30 p.m. JONES asked New

York Supplier if he wanted to "do the same thing like last time."

JONES further stated that she (MUNOZ) would be flying in and she

-32-
'.` ~ _ i _ i

/ ~

would have a bag "to put it in" [put the boom box stereo in]. New

York Supplier asked JONES if she (MUNOZ) would need any new "CD's"

[heroin]. JONES stated she would. KELLY JONES further stated that

the money would be coming out with his "friend" and that MUNOZ was

only going to pick up and return. JONES instructed New York

Supplier not to send it with "cologne" [to mask the scent of the

heroin with cologne], because "a couple of people did not like it."

At the conclusion of the conversation, JONES and New York Supplier

agreed to place coffee with the "CD" {to mask the scent of the

heroin].

56. On June 27, 2002, at approximately 8:09 p.m., KELLY JONES

received a call on Target Phone II from New York Supplier. During

the conversation, New York Supplier asked JONES if he wanted

"1500". New York Supplier informed JONES that the "car" [boom box

stereo] with the "1.5 engine" [1.5 kilograms of heroin] would be

ready the following morning and that the other "car" [another boom

box stereo with heroin] would be ready the following night, around

8:00 p.m. or 9:00 p.m.

57. On June 27, 2002, JONES spoke with MUNOZ and advised her

that she may have visitors later. MUNOZ told JONES that "he" [New

York Supplier] was not going to call her until tomorrow. JONES

then stated that MUNOZ already knows the visitors, "your neighbors"

[ACEVEDO and MELENDEZ]. JONES told MUNOZ that they should be there

in about two hours. MUNOZ then told JONES to give them her

cellular phone number, so she could give them her hotel

-33-
information.

58. On June 28, 2002, at approximately 11:18 a.m., KELLY

JONES using Target Phone II called MUNOZ at (773) 710-5616. During

this conversation, MUNOZ informed JONES that she was waiting to

"meet this guy" and then return to Chicago. MUNOZ informed JONES

that she would call him (JONES) after meeting with the person and

what bus she would be traveling on.

59. On June 28, 2002, surveillance agents in New York

conducting surveillance observed MUNOZ meeting with a male in New

York (New York Courier). During this meeting, New York Courier was

seen in possession of a boom box style portable stereo, and MUNOZ

was seen in possession of a dark-colored duffle bag. New York

Courier was observed putting the boom box stereo inside the duffle

bag, which was then taken by MUNOZ.

60. On June 28, 2002, at approximately 3:10 p.m., KELLY JONES

received a call on Target Phone II from MUNOZ at (773) 710-5616.

During the conversation, MUNOZ asked JONES if he had talked with

"DAVE" [ACEVEDO, who Affiant believes based on intercepted

conversations was in New York to pick up heroin for the

organization], because ACEVEDO called MUNOZ and informed her they

were currently in Queens (New York). MUNOZ further stated that she

was scheduled to arrive at 6:30 a.m. and that "everything is fine".

MUNOZ further stated that she received money from New York Supplier

in New York.

-34-
/ ~^

61. On June 28, 2002, at approximately 10:48 p.m., KELLY

JONES using Target Phone I called DANNY MALDONADO at (773) 895-

1206. During the conversation, JONES asked MALDONADO what "DAVE'S"

last name was, and MALDONADO stated "ACEVEDO". JONES then asked

what "ANGEL'S" last name was, and MALDONADO stated "MELENDEZ".

62. On June 29, 2002, at approximately 12:20 a.m., a

Greyhound bus traveling from New York to Chicago stopped in

Cleveland, Ohio's Greyhound bus terminal. MUNOZ was a passenger on

this bus. Agents requested and received consent from the bus

driver to board the bus. Agents identified themselves as police

officers and told the passengers that they were conducting a

routine luggage check. MUNOZ was observed standing in front of the

last seat of the bus, and after the announcement was made, she was

heard saying "Oh shit." Later, drug canines boarded the bus, and

alerted to the duffle bag that MUNOZ claimed belonged to her.

MUNOZ granted the agents consent to search the bag. Agents found

the boom box stereo, and could see hidden inside the stereo clear

plastic bags containing tan pellets. The bags were later removed

from the stereo, and a field test of one of the pellets tested

positive for the presence of heroin. The total gross weight of the

heroin was approximately 1.5 kilograms. MUNOZ was not arrested at

that time, nor was she questioned about the contents of the stereo.

63. On June 29, 2002, at approximately 5:55 a.m., KELLY JONES

received a call on Target Phone II from MUNOZ at (773) 547-0370.

'lc~'~
~' ~ .

'~

During this conversation, MUNOZ informed JONES that she would be at

the bus station at 7:00 a.m. MUNOZ further stated that she had

"bad news" and that the police "took my luggage". JONES and MUNOZ

agreed to talk when she arrived in Chicago.

64. On June 29, 2002, at approximately 5:56 a.m., KELLY JONES

using Target Phone II called DAVID ACEVEDO at (773) 610-2209.

During this conversation, JONES asked ACEVEDO if everything was

"o.k." ACEVEDO stated everything was "fine" and wanted to know why

JONES was asking. JONES stated that he had "problems". JONES

instructed ACEVEDO not to go to his "crib" [home].

65. On June 29, 2002, at approximately 6:16 a.m., KELLY JONES

using Target Phone II called New York Supplier at (646) 263-6228.

During this conversation, JONES asked if everything was all right

when his "girlfriend" was there. New York Supplier stated that

"everything was fine". JONES informed New York Supplier that "they

took her stuff" [the police took the heroin from MUNOZ]. New York

Supplier explained that everything "was perfect, like the last

time" [the prior narcotics trip MUNOZ took to New York]. New York

Supplier further stated that he put coffee "there" like JONES had

instructed.34 JONES stated that he thought MUNOZ may have lied to

him and New York Supplier stated that "something is fishy" and that

if a person goes to the "hospital, they take the phone away"

34After the agents seized the boom box from MUNOZ at the

Cleveland bus station, they found, in addition to the heroin,

bags with coffee grinds inside the stereo.

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~ 

r r-- ~. r--~ ~ r--. r-~

i ~ i t ~ ! 1

[referring to getting arrested by law enforcement]. JONES stated,

"yeah, I'm not stupid, I've been doing this for a few years".

66. On June 29, 2002, at approximately 6:29 a.m., KELLY JONES

using Target Phone I called DANNY MALDONADO at (773) 895-1206.

During this conversation, JONES told MALDONADO that he had

"problems". JONES further stated that "they took her bag"

[officers took the heroin from MUNOZ]. JONES stated that he told

MELENDEZ and ACEVEDO not to go to the house "dirty". JONES further

stated that "all it takes is two people to get him" . JONES further

stated that he (MALDONADO) should be careful with what he says,

because they could get everyone on a "conspiracy." On that date,

surveillance agents and officers observed DAVID ACEVEDO and ANGEL

MELENDEZ arrive at KELLY JONES' residence and enter the residence

carrying a boom box stereo.

67. On June 29, 2002, at approximately 12:46 p.m., KELLY

JONES using Target Phone II called JAMES VALENCIA at a number in

Columbia. During this conversation, VALENCIA asked JONES ~~what

happened," and JONES stated that he "don't know." JONES further

stated that while MUNOZ was on the bus, police officers utilized a

dog on her luggage and then seized her luggage. VALENCIA

instructed JONES to get a new phone and to give him (VALENCIA) the

new phone number,3s

68. On July 5, 2002, at approximately 2:44 p.m., KELLY JONES

3sAccording to telephone records, on June 29, 2002, service

was activated on Target Phone III.

-37-
'.

using Target Phone I called Individual A. During that call, JONES

told Individual A that he had to make up half of the money [that

was lost due the police seizing the heroin from MUNOZ]. JONES also

discussed his suspicions about MUNOZ's story about how the drugs

were seized. During this call, JONES said that "my guy" [VALENCIA]

would be coming in [to the United States] at the beginning of next

month , 

36

69. On July 5, 2002, at approximately 1:49 p.m., KELLY JONES

using Target Phone II called VIBENCIO CONSUEGRA. During that call,

JONES told CONSUEGRA about MUNOZ and her trip to New York, and his

suspicions about MUNOZ's story.

Drug Shipment July 6 - 8, 2002

70. On July 6, 2002, at approximately 12:18 p.m., KELLY JONES

using Target Phone I contacted DANIEL MALDONADO. During this call,

JONES and MALDONADO discuss making a trip to New York [to pick up

heroin]. MALDONADO indicated that he would go with DAVID ACEVEDO

and that they would use KELLY JONES' white car to drive to the

location. On that same date, surveillance agents observed

MALDONADO and DAVID ACEVEDO standing in front of KELLY JONES'

residence, along with KELLY JONES and MARCUS JONES. Later,

360n June 25, 2002, at approximately 3:43 p.m., KELLY JONES

received a call on Target Phone II from JAMES VALENCIA, in which

VALENCIA provided JONES with his most recent phone number (011-

573-539-7420), and indicated that he (VALENCIA) would be coming

back to America in the near future to see two members of the

organization who Affiant believes reside in the Detroit, Michigan

area.
L ~ ~-- ~ L ~ ~ _ ~ ~ I. _ L L 1. r ~ I _ i

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MALDONADO and ACEVEDO were seen getting into KELLY JONES' white

Nissan Altima and driving away.

71. On July 8, 2002, surveillance agents and officers

observed MALDONADO and DAVID ACEVEDO arrive at the residence of

KELLY JONES and enter that residence carrying a boom box style

stereo.

72. On July 8, 2002, at approximately 12:42 p.m., KELLY JONES

used Target Phone II to contact JAMES VALENCIA and informed

VALENCIA that JONES had provided "9" [a quantity of heroin] to

CONSUEGR.A and that JONES would give the rest to LUCHO (JIRON).

JONES also informed VALENCIA that he (JONES) had made a $5,000

deposit in the bank.

73. On July 10, 2002, at 11:50 a.m., WILLIAM MORCIGLIO called

KELLY JONES on Target Phone I. During this conversation, JONES

asked MORCIGLIO if he had picked up two stacks [$2,000] from LUCHO

and MORCIGLIO said he did. JONES told MORCIGLIO that VALENCIA has

LUCHO doing everything that he (JONES) used to do and that now he

(JONES) was only making "3 a month" [$3,000 a month]. JONES told

MORCIGLIO that VALENCIA has LUCHO doing everything that VALENCIA

had told JONES he was not allowed to do. JONES told MORCIGLIO that

LUCHO is sitting on two of them that they had to get rid of and

that he (LUCHO) was working and complained that he (JONES) had

nothing to do.

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i _ ~ _ 1. t L 1. 1 ~ i. 1

_ ~~

Drug Shipment From New York to Chicago

July 14 - 17, 2002

74. On July 14, 2002, at approximately 3:38 a.m., KELLY JONES

using Target Phone I made a call to DAVID ACEVEDO at (773) 206-

0694. During this conversation, JONES asked ACEVEDO what he was

doing the following day. ACEVEDO responded that he had a family

party to attend. JONES then asked ACEVEDO "what about that mish

[mission or courier trip to pick up heroin]". ACEVEDO stated that

he was "down with whatever", and asked JONES if he was going to get

the oil changed on the car [vehicle used by the couriers to

transport heroin]. During this conversation, JONES further stated

that he (JONES) would receive money in order to give to ACEVEDO, so

that he (ACEVEDO) would be able to leave on Monday, July 15, 2002.

75. On July 14, 2002, at approximately 1:32 p.m., KELLY JONES

received a call on Target Phone I from DANIEL MALDONADO at (773)

895-1206. During this conversation, JONES told MALDONADO that

there might be another "mission" [courier trip to pick up heroin].

MALDONADO asked JONES if he (JONES) knew "how much". JONES further

stated that he needed to get the oil changed on the "white car"

[JONES' white Nissan Altima used by couriers to pick up heroin].

76. On July 14, 2002, at approximately 3:03 p.m., KELLY JONES

using Target Phone III called LUCHO on Target Phone IV. JONES

asked LUCHO if he had any "platita" [money] .37 LUCHO informed JONES

37Affiant believes that JONES was attempting to collect

money from LUCHO to take to New York on a heroin-related trip.
that nothing had arrived. LUCHO added that CONSUEGRA was supposed

to give him (LUCHO) some "platita" [money] but he (CONSUEGRA) left

for "Las Torres" [New York] without giving him anything. LUCHO

also advised that LA NEGRA (SANDR.A P. VELAZQUEZ) could not be

located anywhere. JONES asked LUCHO if he (LUCHO) had any "work"

[drug-related activity]. LUCHO responded that he had people

working [engaged in drug-related activity). JONES responded "me

too". JONES told LUCHO to give him 1,500 [money] when he (LUCHO)

had it and that it was for his (JONES') friends. LUCHO stated that

upon arrival of the "platita" [money] he would contact JONES.

77. On July 14, 2002, at approximately 8:23 p.m., KELLY JONES

received a call on Target Phone III from JAMES VALENCIA. During

this conversation, VALENCIA advised JONES to "send the guys over"

[send the couriers to pick up heroin].

78. On July 15, 2002, at approximately 1:14 p.m., KELLY JONES

received a call on Target Phone III from an individual believed to

be New York Supplier at (347) 724-6296. During this conversation,

New York Supplier asked if the "kids" [drug couriers] were coming

over [driving to New York]. JONES responded by telling New York

Supplier "yeah, I was trying to get some receipts [money] together

for you first [to give to New York Supplier]". New York Supplier

then asked JONES when "they" [drug couriers] were going to arrive.

JONES stated that "they" [drug couriers] were going to leave that

afternoon and get "there" [to New York] in the morning. JONES then

-41-
~~

stated that he would call New York Supplier before "they" [drug

couriers] left.

79. On July 15, 2002, at approximately 1:42 p.m., JONES made

a call on Target Phone I to DANIEL MALDONADO at (773) 895-1206.

JONES advised MALDONADO that he (JONES) needed to know who was

going on the trip [trip to New York to pick up heroin]. MALDONADO

stated that DAVE (ACEVEDO) and ANGEL (MELENDEZ, JR.) were going.

MALDONADO further stated that ACEVEDO and MELENDEZ went to get the

oil changed, and that they were ready to leave. JONES told

MALDONADO that he (JONES) was going to LUCHO's "crib" [residence]

to see if he (LUCHO) had any money, because they would need money

to "drive over there" [to New York]. MALDONADO then asked JONES if

he wanted "them" [drug couriers] to leave before or after rush

hour. JONES advised that he wanted them to leave before.

80. On July 15, 2002, at approximately 1:50 p.m., KELLY JONES

received a call on Target Phone I from MARCUS JONES at (773)592-

0398. During this call, KELLY JONES asked MARCUS JONES if he had

the oil changed. KELLY JONES further stated that "these niggers

got to ride", and instructed MARCUS JONES to change the oil before

"they" [drug couriers] go.

81. On July 15, 2002, at approximately 3:10 p.m., KELLY JONES

made a call on Target Phone III to JAMES VALENCIA at 011-573-539-

7420. During this conversation, VALENCIA asked JONES if he (JONES)

had sent the "guys" [drug couriers]. JONES stated that he did not

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l ~ l - l _ L I I L _ L L J t L l ~

r ~~ ~ ~

have any money [for the couriers to take to New York]. VALENCIA

told JONES to call LUCHO; "maybe he has something." JONES asked

VALENCIA if LUCHO had the same number or a new number. VALENCIA

provided the number "931-2177" (TargetPhone V) for LUCHO.

82. On July 15, 2002, at approximately 3:23 p.m., VALENCIA

called KELLY JONES on Target Phone III. VALENCIA stated that he

called LUCHO and that he (LUCHO) had something for JONES. JONES

asked "what number?", to which VALENCIA responded "818-2812"

(Target Phone IV) Affiant believes VALENCIA was telling JONES

that LUCHO had drug money for JONES, which was to be transported to

New York by the couriers.

83. On July 15, 2002, at approximately 3:25 p.m., LUCHO using

Target Phone IV called KELLY JONES on Target Phone III. LUCHO

stated that he talked to "Jotita" [VALENCIA] and that JONES should

come and pick up ten "pesitos" [drug money] to give to the "son".

JONES asked if LUCHO had twelve [an amount of money] and LUCHO

responded that he had twelve [an amount of money] but that he's

going to take two (an amount of money] because he's broke. JONES

stated that he would stop by LUCHO's apartment at 3:30 p.m.

84. On July 15, 2002, at approximately 3:47 p.m., KELLY JONES

made a call on Target Phone I to DANIEL MALDONADO at (773) 895-

1206. During this conversation, JONES asked MALDONADO what time

"they" [drug couriers] were leaving. MALDONADO asked JONES if he

(JONES) had the "loot" [money]. JONES advised MALDONADO to come to

-43-
his house and "grab everything". MALDONADO advised that "they"

[drug couriers] could leave at 7:00 p.m.

85. On July 15, 2002, at approximately 4:20 p.m., LUCHO using

Target Phone IV called KELLY JONES on Target Phone III. LUCHO

stated that he passed [gave] him (JONES) eleven "pesitos", eleven

thousand [amount of money]. JONES confirmed this.38

86. On July 15, 2002, at approximately 6:15 p.m.,

surveillance agents observed KELLY JONES, MARCUS JONES, DAVID

ACEVEDO, ANGEL MELENDEZ, JR. and DANIEL MALDONADO arrive at and

enter the residence of KELLY JONES, at 1433 W. Warner, Chicago,

Illinois. At approximately 6:55 p.m., agents/officers observed

MELENDEZ and MARCUS JONES exit 1433 W. Warner and walk to the white

Nissan Altima registered to KELLY JONES. MALDONADO then exited

1433 W. Warner and entered the Altima, while carrying a radio.

ACEVEDO then exited the residence and entered the Altima. The

Altima departed that area.

87. On July 15, 2002, at approximately 7:15 p.m., KELLY JONES

using Target Phone III called "LUCHO" on Target Phone IV. JONES

asked LUCHO if he (LUCHO) spoke with LA NEGRA (SANDR.A P.

VELAZQUEZ) LUCHO responded that he just did. JONES asked LUCHO

how much he (LUCHO) "passed" [distributed] to her (LA NEGRA) and

whether she wanted more. LUCHO stated that he was going to "pass"

38on July 18, 2002, KELLY JONES called JAMES VALENCIA and

told VALENCIA that he (JONES) had given LUCHO three hundred

[quantity of heroin] and that LUCHO had given JONES "eleven"

[amount of money] the other day [to bring to New York].
~ r ~ r r r r ~~ r

L ~ ~i_ l_ - ~ t. L 1 l 1 __~v ._ _ 'I i. _ r i C

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[distribute] to LA NEGRA "8" [quantity of heroin] and see if she

needed more. LUCHO stated that he would call JONES or give LA

NEGRA JONES' number so that she could call him. During this

intercepted conversation, LUCHO could be heard in the background

talking over the telephone with a person believed to be LA NEGRA.

88. On July 16, 2002, at approximately 4:06 a.m., KELLY JONES

made a call on Target Phone I to ACEVEDO at (773) 610-2209. During

this conversation, ACEVEDO advised JONES that they were in

Pennsylvania. ACEVEDO stated that they should arrive in New York

at 8:00 a.m. or 9:00 a.m., Chicago time.

89. On July 16, 2002, at approximately 11:51 a.m., KELLY

JONES received a call on Target Phone III from New York Supplier at

(347) 724-6296. During this conversation, New York Supplier

advised JONES that everything was okay, but his (New York

Supplier's) "guy" [drug courier assisting New York Supplier] worked

overnight, and did not finish until 6:00 a.m., so New York Supplier

thought that.he was sleeping. New York Supplier further stated

that he was going to send JONES a "check" for fifteen hundred

dollars.

90. On July 16, 2002, at approximately 11:53 a.m., KELLY

JONES received a call on Target Phone I from ACEVEDO at (773) 610-

2209. During this conversation, ACEVEDO advised JONES that the

"guy" [drug courier assisting New York Supplier] needed more time,

that he was sleeping, and that they were going to give him another

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l ''. l ~

1

hour.

91. On July 16, 2002, at approximately 12:00 p.m., based on

intercepted conversations between KELLY JONES and the drug

couriers, Customs in Chicago related in substance to agents in New

York that the heroin transfer would take place in the vicinity of

35th Street and Steinway in New York, and that the couriers were

currently at a Kentucky Fried Chicken (KFC) at an undisclosed

location. Based on this information, agents and officers checked

the KFC located at Northern Blvd. and 88th Street, the closest KFC

to the 30-33 93rd Street location, and discovered JONES' 1995 Nissan

Altima with Illinois license number 3104374 parked in front.

92. On July 16, 2002, at approximately 1:15 p.. m., ACEVEDO and

MELENDEZ drove to the vicinity of 88th Street between Northern

Blvd. and 32nd Ave. At approximately 1:30 p.m., agents observed

ACEVEDO and MELENDEZ park their vehicle just before the KFC parking

lot, exit the vehicle, and meet with an Hispanic male, believed to

be New York Courier.39 ACEVEDO, MELENDEZ and New York Courier

entered the Nissan Altima and proceeded on 88th Street across

Northern Blvd. At approximately 1:35 p.m., the vehicle stopped on

88th Street between Northern Blvd. and 34th Avenue. At

approximately 1:41 p.m., New York Courier exited the Nissan with a

39This individual (New York Courier) appeared to be the same

person who on June 28, 2002 delivered a "boombox" style radio

(which contained approximately 1.5 kilograms of heroin) to DIANA

MUNOZ.
C_ ~ ~ ~. t.. l ~ i

/~

knapsack over his shoulder and entered the front entrance of an

apartment building located at 88-11 34th Avenue. The Nissan Altima

with ACEVEDO and MELENDEZ then left the area. Affiant believes

that ACEVEDO and MELENDEZ met New York Courier, a courier for New

York Supplier, for the purpose transferring drug money to New York

Courier which was contained in the knapsack.

93. On July 16, 2002, at approximately 1:48 p.m., DAVID

ACEVEDO called KELLY JONES on Target Phone I from (773) 206-0694.

ACEVEDO advised JONES that they were "riding out now" [leaving New

York]. ACEVEDO further stated that they would arrive in Chicago,

Illinois between 2:00 a.m. and 3:00 a.m.

94. On July 16, 2002 at approximately 5:34 p.m., KELLY JONES

received a call on Target Phone I from DAVID ACEVEDO at (773) 206-

0694. During this conversation, ACEVEDO advised JONES that they

were returning from New York and that they were currently in

Pennsylvania. JONES asked ACEVEDO if "Angel" (MELENDEZ) was

driving, to which ACEVEDO advised that he (MELENDEZ) was driving.

95. On July 16, 2002, at approximately 7:43 p.m., KELLY JONES

made a call on Target Phone III to JAMES VALENCIA at 011-573-539-

7420. During this conversation, VALENCIA asked JONES about his

"friends" [drug couriers). JONES advised VALENCIA that they would

return between 3:00 a.m. and 4:00 a.m.

96. On July 16, 2002, at approximately 10:03 p.m., KELLY

JONES received a call on Target Phone I from MELENDEZ, JR. at (773)

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f_

~ ~

206-0694. During this conversation, MELENDEZ first spoke with

MARCUS JONES, who answered the phone. MARCUS JONES asked MELENDEZ

if they were almost home. MELENDEZ advised that they were about

four hours away from Chicago. KELLY JONES then came to the phone

and MELENDEZ advised KELLY JONES that they were four or five hours

away from Chicago. MELENDEZ then stated that he would call KELLY

JONES in two hours. KELLY JONES asked MELENDEZ what their "ETA"

[estimated time of arrival] was, to which MELENDEZ replied about

"three" [hours].

97. On July 17, 2002, at approximately 2:03 a.m., KELLY JONES

received a call on Target Phone I from DAVID ACEVEDO at (773) 206-

0694. During this conversation, ACEVEDO advised JONES that they

would be at JONES' "crib" [home] at about 3:30 a.m.

98. On July 17, 2002, at approximately 3:32 a.m., agents

observed the white Nissan Altima, registered to KELLY JONES, travel

west on Warner street from Southport Avenue in Chicago, Illinois.

The vehicle circled the area and parked in front of a fire hydrant

in front of 1433 W. Warner., the residence of KELLY JONES. Agents

observed DAVID ACEVEDO walk to the residence carrying a bag over

his shoulder and observed ANGEL MELENDEZ, JR. follow ACEVEDO into

the residence. At approximately 3:40 a.m, agents/officers observed

MARCUS JONES exit the residence and walk to the north side of

Warner. MARCUS JONES carried a bag back into the residence. At

approximately 3:58 a.m., agents/officers observed MARCUS JONES,

DAVID ACEVEDO, and ANGEL MELENDEZ, JR. exit the residence, enter
~- ~~ l ..._ ~ - __a.~ \ l l ~ _ ~ 1,

l ~

the white Nissan Altima, and leave the area. Affiant believes that

MELENDEZ and ACEVEDO returned from their trip to New York with

heroin stored in the bag and brought the heroin to KELLY JONES at

JONES' residence.

99. On July 17, 2002, at approximately 9:47 a.m., KELLY JONES

received a call on Target Phone 222 from New York Supplier at (347)

724-6296. During this call, New York Supplier asked JONES why he

(JONES) had not called him (New York Supplier) when the couriers

returned. JONES stated that he (JONES) did not know that New York

Supplier wanted a phone call at 4:00 a.m. New York Supplier told

JONES to call him anytime. During this same conversation, New York

Supplier asked JONES if everything was fine with the "check".

JONES stated, "yeah, well let me check, yeah its okay". New York

Supplier asked JONES if "these guys" were going to "send someone

this week, or not yet". JONES advised New York Supplier that he

did not know, but he would find out and call New York Supplier

back. New York Supplier stated "alright, give me a call and I'll

be ready".

100. On July 17, 2002, at approximately 10:10 p.m., LUCHO

using Target Phone V called KELLY JONES on Target Phone III. LUCHO

asked JONES if he (JONES) could give him 300 "pesitos" [quantity of

heroin] and JONES stated "yeah" and that he would be by the

apartment [LUCHO's residence] at 10:00 a.m.
~ - r ~~ ~-~ r ~

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101. On July 18, 2002, at approximately 11:01 a.m., LUCHO

using Target Phone V called KELLY JONES on Target Phone III. JONES

asked LUCHO where he (LUCHO) was at, and LUCHO replied at the

"apartment" [LUCHO's residence]. LUCHO and JONES agreed to meet at

LUCHO's residence at 11:30 a.m.

102. On July 18, 2002, at approximately 12:01 p.m., KELLY

JONES using Target Phone III called JAMES VALENCIA at telephone

number 011-573-539-7420. JONES told VALENCIA that he had given

LUCHO three hundred [quantity of heroin]. JONES also advised

VALENCIA that LUCHO had given JONES ~~eleven" [an amount of money]

the other day. It is believed LUCHO was next to JONES at the time

of this conversation because LUCHO's voice is heard in the

background telling JONES CONSUEGRA's phone number when JONES is

repeating it to VALENCIA. Moreover, on July 18, 2002, surveillance

observed JONES enter what is believed to be LUCHO's apartment

(located at 3005 Gunnison, Chicago, IL} at approximately 12:00 p.m.

and did not see JONES exit the residence until approximately 1:09

p.m. that same day.

103. On July 18, 2002, at approximately 2:14 p.m., KELLY JONES

using Target Phone III called LUCHO on Target Phone V. LUCHO asked

JONES where to meet and JONES stated that he (JONES) would park his

car at Irving Park and Damen, past a Firestone.

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~~~

104. On July 18, 2002, at approximately 2:30 p.m., KELLY JONES

using Target Phone III called LUCHO on Target Phone V. LUCHO told

JONES that he (LUCHO) was on Lawrence and Elston and would meet

JONES in eight minutes.

105. On July 18, 2002, at approximately 2:42 p.m., LUCHO using

Target Phone IV called KELLY JONES on Target Phone III. JONES

asked LUCHO where he was at and LUCHO replied that he was at Irving

Park and Damen. LUCHO stated that he did not see his (JONES')

truck, and JONES replied he was on Irving Park.

106. On July 18, 2002, at approximately 2:45 p.m.,

surveillance agents observed KELLY JONES and an individual

(believed to be LUCHO) meet in front of a Firestone tire and auto

repair store located at 1910 West Irving Park Road, Chicago,

Illinois. At approximately 2:50 p.m., a CPD officer conducted a

traffic stop on the vehicle driven by the individual (LUCHO) who

had earlier met with JONES at the Firestone. LUCHO was driving a

tan, Chrysler Sebring, bearing Illinois license plate number

2512007. The officer received verbal consent from LUCHO to search

the vehicle, and in doing so, the officer observed two stacks of

United States currency inside the glove compartment. The cash was

not disturbed nor was any contraband discovered in the vehicle.

LUCHO provided the officer with a Florida driver's license

identifying him as ~~CARLOS JIRON" with a date of birth of November

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_~ c

~ ~ — 

~~,,

'~ . 

,.

2, 1967.4° JIRON provided other documents indicating his residence

was located at 3005 Gunnison, Apartment 1E, Chicago, Illinois,

60625.41

107. On July 18, 2002, at approximately 4:53 p.m., LUCHO using

Target Phone IV called KELLY JONES on Target Phone III. LUCHO told

JONES that he (LUCHO) spoke to "Consu" (CONSUEGR.A) and that

CONSUEGRA wanted to know if JONES could give him (CONSUEGRA) the

remainder of what [heroin] JONES had there, "the small check for

five hundred [quantity of heroin]". LUCHO told JONES that

CONSUEGRA wanted to speak to him (JONES) about it.

Drug Shipment From New York to Chicac~ro

July 19 - 21, 2002

108. On July 18, 2002, at approximately 10:34 p.m., KELLY

JONES received a call on Target Phone I from ANGEL MELENDEZ, JR.,

during which MELENDEZ told JONES that a trooper had conducted a car

stop on a vehicle occupied by MELENDEZ and DAVID ACEVEDO and seized

the money that they MELENDEZ and ACEVEDO were transporting to New

York. Later, MELENDEZ spoke with KELLY JONES on Target Phone I,

and it appeared that they allegedly were stopped in either Ohio or

4oRecords from the Florida Department of Highway Safety and

Motor Vehicles confirms this information.

410n July 22, 2002, a surveillance officer observed the same

Chrysler Sebring, bearing Illinois license plate 2512007, parked

on Sacramento Avenue just south of Gunnison Street.

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~' ~ i

__. /\

Indiana.42 As a result of this incident, KELLY JONES decided to

complete the trip to New YORK himself with ACEVEDO.

109. On July 19, 2002, at approximately 11:22 a.m., KELLY

JONES received a telephone call on Target Phone III from New York

Supplier at (347) 742-6296. During the conversation, JONES and New

York Supplier discussed the loss or seizure of money by law

enforcement from David ACEVEDO and Angel MELENDEZ. During this

conversation, JONES informed New York Supplier that he (JONES)

would travel to New York and would depart on July 19, 2002. New

York Supplier informed JONES that he (New York Supplier) wanted to

talk with JONES.

110. On July 19, 2002, at approximately 11:24 a.m., KELLY

JONES using Target Phone III called James VALENCIA at 011-573-539-

7420. During this conversation, JONES informed VALENCIA that his

friends were traveling and were stopped by law enforcement.

VALENCIA asked JONES if there was anyone else to "send it back

[travel to New York]?" JONES informed VALENCIA that he (JONES)

would travel to New York.

111. On July 19, 2002, at approximately 11:28 a.m., KELLY

JONES using Target Phone I called Individual B at (773) 935-2902.

During the conversation, JONES informed Individual B that "I got

fucking problems I need to take care of". JONES then informed

42The investigation thus far has shown that there is no

record of the claimed traffic stop or seizure by the Ohio State

Police or Indiana State Police.

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~'

'\

Individual B that he was going to travel to New York and leave

within an hour. During this same conversation, Individual Basked

JONES why he was going to travel to New York. JONES stated, "cause

I got problems and it seems that nobody can handle shit right. I

have to do shit myself". JONES informed Individual B that DAVID

ACEVEDO and ANGEL MELENDEZ were stopped by law enforcement and that

"shit gets confiscated" [referring to money] and they returned to

Chicago with no "paperwork" to show that money was seized by law

enforcement.

112. On July 19, 2002, at approximately 11:41 a.m., KELLY

JONES received a call on Target Phone III from LUCHO. During this

conversation, LUCHO told JONES that he has "some receipts here so

you can take over there" [referring to picking up money for JONES

to take with him to New York].

113. On July 19, 2002, at approximately 12:00 p.m., agents

established surveillance in the area of 1433 W. Warner, Chicago,

Illinois, the residence of KELLY JONES, in an attempt to locate

JONES. At approximately 12:55 p.m., agents/officers observed KELLY

JONES driving his Lincoln Navigator east on Warner and park near

his residence. Agents/officers observed KELLY JONES and a Hispanic

male, believed to be DAVID ACEVEDO, enter 1433 W. Warner.

Agents/officers observed KELLY JONES walk into the residence

carrying a manilla envelope.

114. On July 19, 2002, at approximately 1:30 p.m., KELLY JONES

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r-- ~ ~-~ - , F- -- C- -~_ -- ~ .~.__. --. i ~----~ r --~ .-~-~ ~- -- r- - ~ -..- -, ---- ~ -

_ ~^ ~ i

using Target Phone III called JAMES VALENCIA at 011-573-539-7420.

During this conversation, JONES informed VALENCIA, "I got that

[drug money] from LUCHO" and that he (JONES) would be leaving

immediately [for New York]. JONES and VALENCIA further discussed

how much drug money JONES would transport to New York. JONES asked

VALENCIA "How much for over there, 21?" [$21,000 that JONES was

taking to New York]. VALENCIA replied, "yea, 21, thank you so

much."

115. On July 19, 2002, at approximately 1:52 p.m.,

agents/officers observed KELLY JONES and an individual believed to

be DAVID ACEVEDO at the Navigator with the trunk of the vehicle

open. At approximately 1:58 p.m., agents/officers observed the

individual believed to be DAVID ACEVEDO exit the vehicle and enter

a currency exchange business, located at 4000 N. Broadway, Chicago,

Illinois. The individual believed to be ACEVEDO was observed

exiting the currency exchange, returning to the Lincoln Navigator,

and then returning to the currency exchange. At approximately 2:04

p.m., agents/officers observed the individual believed to be

ACEVEDO exit the currency exchange, re-enter the Lincoln Navigator,

and leave the area.

116. On July 19, 2002, at approximately 2:01 p.m., KELLY

JONES using Target Phone III called New York Supplier at (347) 724-

6296. During this conversation, JONES informed New York Supplier

that he (JONES) would be arriving in New York at approximately 3:00

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a.m. (on July 20, 2002), and that he was currently leaving Chicago.

117. On July 19, 2002, at approximately 7:19 p.m., KELLY JONES

received a call on Target Phone 2 from WILLIAM MORCIGLIO at (626)

221-4725. During this conversation, JONES informed MORCIGLIO that,

"I'm fucking going to the store [New York] to handle something".

JONES further stated, "sometimes you got to do shit yourself".

JONES also stated, "and then I'll be in D-town [Detroit] on

Sunday".

118. On July 20, 2002, at approximately 4:00 a.m. (EST), KELLY

JONES's black Lincoln Navigator with license number 1353413, was

observed traveling west on Northern Blvd. in the area of 78th

Street in New York. At approximately 4:15 a.m., the Navigator

proceeded to Manhattan and was lost in the vicinity of 42nd Street

and 6th Avenue. At approximately 5:00 a.m. (EST), surveillance

units returned to the vicinity of Northern Blvd. between 94th

Street and 69th Street. At approximately 1:00 p.m. (EST), agents

located the Navigator traveling eastbound on Northern Blvd. in the

vicinity of 88th Street. The Navigator turned onto 90th Street and

parked between Northern and 34t'' Avenue, closer to Northern Blvd.

During a drive-by of the Navigator, another male later identified

as New York Supplier was observed in the rear seat of the

Navigator.

119. Shortly thereafter, the Navigator circled the block

and returned to 90t'' Street and parked on the eastside of the

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r---, r r-

~ \ ~ /~

~.

street. At approximately 1:10 p.m. (eastern time), New York

Supplier exited the rear passenger door of the Navigator with a

"boombox" style radio in hand and proceeded midway down the block.

A drive-by revealed that New York Supplier was sitting in a dark

colored Infinity with New York license number BKJ5755, parked midblock on the eastside of the street. At approximately 1:24 p.m.

(eastern time), New York Supplier emerged onto the street empty

handed. JONES and New York Supplier appeared to be engaged in

conversation while sitting on steps located in front of a building,

mid-block on 90th Street between Northern and 34th Ave. At

approximately 1:38 p.m. (eastern time), New York Supplier departed

from JONES and was later seen sitting in the Infinity. At

approximately 1:40 p.m. (eastern time), a Hispanic male believed to

be New York Courier carrying a "boombox" style radio emerged from

the front entrance of an apartment building located at 88-11 34th

Avenue. New York Courier was using a cellular telephone, walked up

90th Street and delivered the "boombox" to JONES. Affiant believes

that KELLY JONES provided New York Supplier with a boom box

containing drug proceeds, and received from New York Courier a boom

box containing heroin.

120. On July 20, 2002, at approximately 1:56 p.m., KELLY

JONES received a call on Target Phone I from Individual B at (773)

255-4307. During this conversation, JONES informed Individual B

that he was currently in Manhattan.

-57-
' `-z

121. On July 21, 2002, at approximately 10:32 a.m., KELLY

JONES talked with New York Supplier on Target Phone III. During

this conversation, New York Supplier asked JONES if he wa.s "okay".

JONES stated that everything was "okay".

122. On July 21, 2002, at 11:51 a.m., KELLY JONES received a

call on Target Phone III from JAMES VALENCIA. During this

conversation, VALENCIA asked JONES, "How's everything?" and "You

home?" JONES informed VALENCIA that he was at home and "everything

went fine, man". Affiant believes that VALENCIA was inquiring

whether JONES was able to complete the drug transaction without

incident.

Delivery of Drug Proceeds

Ju11r 22 - 23, 2002

123. On July 22, 2002, at approximately 4:47 p.m., LUCHO

(CARLOS JIRON) using Target Phone V called KELLY JONES ~~n Target

Phone III. JONES received the telephone call and gave the phone to

WILLIAM MORCIGLIO. LUCHO told MORCIGLIO that he (LUCHO) spoke with

JAMES VALENCIA to see if JONES could give him (LUCHO) 15 "Pesitos"

(an amount of money) and to tell JONES to "hold the rest for the

girl ~~ , 

43

430n July 22, 2002, at approximately 5:03 p.m., VALENCIA

called KELLY JONES on Target Phone III. VALENCIA asked JONES if

LUCHO had called him and JONES replied that he had. VALENCIA

then told JONES "15 [amount of money] for LUCHO" and JONES

replied "Okay, no problem, everything else ok?" VALENCIA asked

JONES if "LA MONA" called him and JONES stated that "some lady,

Spanish lady" had called him on his other phone. VALENCIA asked

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i ~ ' ~

_ 

~ ` ~'~ ~ i

124. On July 22, 2002, at approximately 6:17 p.m., LUCHO

using Target Phone IV called KELLY JONES on Target Phone III.

LUCHO told JONES that he was on Damen Avenue at "Las Tapas", and

JONES told LUCHO to wait there. At approximately 6:20 p.m., a

surveillance agent arrived in that area and observed the Chrysler

Sebring, with Illinois license plate number 2512007 and driven by

a Hispanic male, traveling west on Irving Park Road from Damen

Avenue. The insurance for this vehicle comes back to CARLOS JIRON

(LUCHO). Surveillance team members established a fixed surveillance

throughout the immediate area of Damen and Irving Park, but were

unable to locate JONES or the Chrysler Sebring vehicle.

125. On.July 23, 2002, at approximately 1:36 p.m., VALENCIA

called KELLY JONES on Target Phone I. VALENCIA instructeCl JONES to

go to "MARTICA" [MARTHA LLANOS] and JONES asked "where, which one?"

VALENCIA told JONES to go to ~~her house" and JONES stated that he

had not been there in a long time and then said "ok, no problem"

VALENCIA told JONES to go to "MARTICA's" [MARTH LLANOS'] house at

6:00 p.m. JONES asked VALENCIA if he should take care of

everything and VALENCIA replied yes, everything thirty-five [amount

of money]. JONES then told VALENCIA that he (JONES) had given

LUCHO ten [amount of money] and had fifty left over. VALENCIA

asked JONES "and what about you?", and JONES replied "I'll take a

"when, today?" and JONES replied "yeah, like maybe a half hour

ago". VALENCIA then instructed JONES to give only ten [amount of

money] to LUCHO and thirty-five for "the girl".

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little for me and then take the rest to her [MARTHA LLANOS]".

VALENCIA then stated "ok, forty-five" [amount of money]. Affiant

believes that VALENCIA instructed KELLY JONES to bring LLANOS the

drug proceeds, and JONES later explained to VALENCIA how he

distributed a portion of the proceeds.

126. On July 23, 2002, at approximately 7:00 p.m., KELLY JONES

using Target Phone III called LUCHO on Target Phone IV. LUCHO told

JONES that "Martica" [MARTHA LLANOS] needed him (JONES), and JONES

replied that he was on his way to her (LLANOS') house. LUCHO

stated "alright, I'm here with her now".44 JONES stated that he

would get there in thirty minutes.

127. On July 23, 2002, surveillance was established in the

area of 4522 N. St. Louis, Chicago, Illinois, the residence of

MARTHA LLANOS.45 Based on the above intercepted telephone

conversation, it was determined that KELLY JONES was going to meet

with MARTHA LLANOS at her residence in order to drop off currency,

believed to be about $43,000 in drug proceeds].46 At approximately

44The investigation has shown that MARTHA LLANOS owns or

operates wire remitter businesses in the Chicago area.

Subpoenaed telephone records for LaKayana Express, at 2952 W.

Montrose, Chicago, Illinois, a wire remitter business, is listed

in the name of "Martha L. Llanos". Moreover, Multi Service,

another wire remitter business located at 3640 West Montrose,

Chicago, Illinois, is listed in the name of "Martha L. Llanos."

4sThis is based on surveillance and subpoenaed phone

records.

460n July 25, 2002, at approximately 4:38 p.m., KELLY JONES

was' called by VALENCIA on Target Phone III. During this call,
"- ~~l

6:20 p.m., surveillance agents observed LUCHO's Chrysler Sebring

parked in front of 4522 N. St. Louis. LUCHO exited the driver's

side door, carrying a black leather purse or bag and a notebook,

and walked directly into the residence.

128. On July 23, 2002, at approximately 7:44 p.m.,

surveillance agents observed a Lincoln Navigator, bearing Illinois

license plate 1353415 (previously identified as belonging to KELLY

JONES) parked in front of 4522 N. St. Louis. Upon arriving an

unidentified passenger was sitting in the front seat of the

Navigator. KELLY JONES was observed exiting the driver's side door

carrying a white plastic grocery bag with a box inside of the bag.

JONES was observed entering the residence. Shortly thereafter,

LUCHO was observed leaving the residence and walking to his vehicle

while utilizing a cellular telephone.

129. On July 23, 2002, at approximately 7:49 p.m., a

surveillance agent observed KELLY JONES exit the front door of

MARTHA LLANOS' residence and approach the tan Chrysler Sebring.

LUCHO opened the driver's side door and the two (JONES and LUCHO)

appeared to shake hands and engage in a brief conversation. JONES

and LUCHO then departed the area in their respective vehicles.

Affiant believes that LUCHO delivered drug proceeds to LLANOS at

her house, and later JONES arrived at that house to deliver drug

JONES informed VALENCIA that he had given 10 [amount of money] to

LUCHO, 43 [amount of money] to Martica [MARTHA LLANOS], and he

kept 7 [amount of money] for himself.

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proceeds as well.

Drug Shipment From Florida to Chicago

August 20 - 23, 2002

130. As set forth below, from on or about August 20 through

August 23, 2002, KELLY JONES was instructed by JAMES VALENCIA to

send drug couriers (later identified as MARCUS JONES and ANGEL

MELENDEZ, JR.) to Florida to pick up heroin. MELENDEZ and MARCUS

JONES drove to Florida to drop off drug money and obtain heroin

from "TOMATICO" (later identified as JESUS ABEL ROLDAN) MELENDEZ

and JONES then brought the heroin back to Chicago on behalf of the

organization.

131. On August 20, 2002, at approximately 1:03 p.m., KELLY

JONES received a call from James VALENCIA on Target Phone 2.

During this conversation, VALENCIA told JONES to send someone to

the "beach" [send a drug courier to Florida].

132. On August 20, 2002, at approximately 6:17 p.m., KELLY

JONES using Target Phone 2 called ANGEL MELENDEZ, JR. at 773-430-

8168. During this conversation, JONES stated to MELENDEZ ~~later on

just count this [count money that was to be delivered to Miami,

Florida to an unknown subjectj, just in case I might of

miscounted". JONES further stated "T's [MARCUS JONES] ready, the

car's ready, everything's ready bro" [ready for MELENDEZ and MARCUS

JONES to drive to Miami, Florida to deliver money and pick up

heroin for the organization]. MELENDEZ stated to JONES that he

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(MELENDEZ) wanted to leave "ASAP".

133. On August 20, 2002, at approximately 7:49 p.m., KELLY

JONES received a call on Target Phone I from MARCUS JONES. During

this call, MARCUS JONES asked KELLY JONES if "there suppose to be

fifteen (15) stacks here [stacks of money]"? MARCUS JONES

continued to state that he counted fifteen-nine (15-9). KELLY

JONES then told MARCUS JONES to leave as soon as MELENDEZ arrived.

KELLY JONES also advised MARCUS JONES that the contact number for

the person in Florida (ROLDAN) was stored on the cellular telephone

that was stolen [Target Phone II]. KELLY JONES stated that he

(Kelly) would call Marcus JONES later and give him the information

[the telephone number for ROLDAN in Florida].

134. On August 20, 2002, at approximately 8:56 p.m., KELLY

JONES received a call on Target Phone I from MELENDEZ, JR. During

this call, MELENDEZ advised JONES that they were "on the road" [on

their way to Florida].

135. On August 21, 2002, at approximately 12:13 p.m., KELLY

JONES received a call from MELENDEZ, JR. on Target Phone I.

MELENDEZ advised JONES that they [MELENDEZ and MARCUS JONES] had

just crossed from Georgia and entered the "State of the beach"

[Florida]. MELENDEZ further advised that the estimated time of

arrival to their destination was 5:00 - 5:30. JONES then advised

MELENDEZ that he (JONES) would give MELENDEZ "the numbers and

everything" [the contact telephone number for ROLDAN in Florida].

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- - - - -- r ~- --, i_ ! t ~ 

~ ' ~

~~ , ~`,,

~\

136. On August 21, 2002, at approximately 2:02 p.m., KELLY

JONES made a call to LUCHO using Target Phone II2. During this

conversation, KELLY JONES asked LUCHO, "who is going to the beach

[Florida]? TOMATICO"? LUCHO replied "yes, TOMATICO" (ROLDAN).

JONES then asked LUCHO for "TOMATICO's" number. LUCHO then told

JONES that he (LUCHO) had to find the number and told JONES to call

him (LUCHO) back.

137. On August 21, 2002, at approximately 2:19 p.m., KELLY

JONES again called LUCHO using Target Phone II2. LUCHO told JONES

to write the number down, and proceeded to give JONES the number,

786-543-9342 [for ROLDAN].

138. On August 21, 2002, at approximately 2:20 p.m., KELLY

TONES made a call to "TOMATICO" (ROLDAN) using Target Phone III.

JONES advised "TOMATICO" (ROLDAN) that his (JONES') ~~friends"

[couriers MELENDEZ and MARCUS JONES] would arrive between 5:30-

6:00.

139. On August 21, 2002, at approximately 3:03 p.m., KELLY

JONES made a call to JAMES VALENCIA using Target Phone III. During

this conversation, VALENCIA asked JONES if he (JONES) had sent his

'brother" [MARCUS JONES]. JONES replied that he did. JONES

further advised VALENCIA that he (JONES) spoke with "TOMATICO"

(ROLDAN) and advised him of what time MELENDEZ and MARCUS JONES

would arrive.

140. On August 21, 2002, at approximately 3:39 p.m., KELLY

~'Z~
1

JONES received a call from "TOMATICO" (ROLDAN) on Target Phone III.

During this conversation, ROLDAN asked JONES what time his "cousin"

was arriving. JONES stated "at 6:00 p.m."

141. On August 21, 2002, at approximately 5:49 p.m., KELLY

JONES received a call from MARCUS JONES on Target Phone I. During

this call, Marcus JONES asked Kelly JONES for the "number". Kelly

JONES then relayed "786-543-9342" [number for ROLDAN] Kelly JONES

further instructed Marcus JONES to "tell Angel [MELENDEZ, JR.] to

talk to that TOMATICO" (ROLDAN) Kelly JONES continued to advise

Marcus JONES to "put it [heroin] in the thing [hidden compartment

inside the vehicle used by Marcus JONES], because he (ROLDAN)

doesn't have the radio [boom-box style portable stereo used to

transport heroin]".

142. On August 21, 2002, at approximately 7:12 p.m., KELLY

JONES made a call to "TOMATICO" (ROLDAN) using Target Phone III.

During this conversation, JONES asked "TOMATICO" if everything was

okay. "TOMATICO" advised JONES that everything was fine.

143. On August 22, 2002, at approximately 1:50 p.m., KELLY

JONES made a call to Marcus JONES and MELENDEZ using Target Phone

I. During this conversation, MELENDEZ advised KELLY JONES that

they were "chillin in Miami". MELENDEZ then advised KELLY JONES

that he (MELENDEZ) was kidding, and that they [MELENDEZ and MARCUS

JONES] were in Indiana, about two hours from Chicago, Illinois.

JONES instructed MELENDEZ to return to JONES' house upon their

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_, ~ 1

~~.

\ `I

arrival in Chicago.

144. On August 22, 2002, at approximately 4:38 p.m., KELLY

JONES made a call to JAMES VALENCIA using Target Phone III.

VALENCIA asked JONES about his brother [MARCUS JONES]. JONES

advised VALENCIA that they [MELENDEZ and MARCUS JONES] would arrive

later that day.

145. On August 22, 2002, at approximately 5:01 p.m., KELLY

JONES made a call to MELENDEZ using Target Phone I. During this

call, MELENDEZ advised KELLY JONES that everything went smooth, and

that they did not have to stop in Miami. JONES then stated that he

was not home. MELENDEZ then asked JONES where he wanted him

(MELENDEZ) to "put the stuff" [heroin picked up in Florida]. JONES

instructed MELENDEZ to put it [heroin] "in the book bag that's in

the back room". JONES continued to advise MELENDEZ to then "put

the book bag like behind the entertainment center".

146. On August 22, 2002, at approximately 5:06 p.m., KELLY

JONES made a call to 347-724-6296 using Target Phone III. This

number is believed to be used by New York Supplier. JONES left a

message that "everything is fine".

147. On August 22, 2002, at approximately 5:08 p.m., KELLY

JONES received a call from New York Supplier on Target Phone III.

JONES advised New York Supplier that he was trying to call the

person (ROLDAN) from the "beach" [Florida] and confused the

numbers.

~•
- .. 1. i. ~ ~ .. i ~ ~ I

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t

148. On August 22, 2002, at approximately 5:09 p.m., KELLY

JONES made a call to "TOMATICO" (ROLDAN) using Target Phone III.

During this conversation, JONES advised "TOMATICO" that "everything

is fine". JONES continued to state that "my friends" [MELENDEZ and

MARCUS JONES) are back in Chicago, Illinois.

149. On August 23, 2002, at approximately 3:00 p.m., KELLY

JONES made a call to JAMES VALENCIA using Target Phone II2. During

that conversation, JONES advised VALENCIA that his brother, Marcus

JONES, returned and that everything was okay.

Drug Shipment from Florida to Chicago

August 30 - September 5, 2002

150. On August 30, 2002, at approximately 3:07 p.m., KELLY

JONES received a call from VALENCIA on Target Phone III. During

this conversation, VALENCIA advised JONES to send couriers to "La

Playa" [Miami]. JONES confirmed with VALENCIA that he was to send

his couriers to "La Playa" [Miami], and told VALENCIA that he

(JONES) would "take care of it".

151. On August 30, 2002, at approximately 3:10 p.m., KELLY

JONES made a call to Marcus JONES on Target Phone I. During this

conversation, KELLY JONES advised Marcus JONES that he (Kelly)

needed "to get the car ready `cause then somebody's gotta go today

or tomorrow" [JONES wanted to prepare the Nissan Altima for travel

to Florida].

152. On August 31, 2002, at approximately 11:34 a.m., KELLY

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~ -,

JONES received a call on Target Phone I from Yolanda RIVERA.

During that conversation, RIVER.A advised JONES that she could be

ready at around 3:00 p.m. JONES asked RIVERA if that was "the

earliest you can get out here"? RIVER.A responded, "yeah, cause I

gotta pack, then I'm gonna have to get to the city". JONES

continued to advise RIVERA, "I'll have the car whatever, you know,

and if anything Angel [MELENDEZ] can just pick you up and ya' can

ride out"

153. On August 31, 2002, at approximately 4:13 p.m., KELLY

JONES made a call to NATHAN THOMAS over Target Phone I. JONES

asked THOMAS what he was doing. THOMAS advised JONES that he had

to pick his girlfriend up from work later. JONES stated "why don't

you give her some money to take a cab home, you can go on this

mission with "Cuzo" [YOLANDA RIVERA) THOMAS replied "all right".

154. On August 31, 2002, at approximately 7:46 p.m., KELLY

JONES received a call on Target Phone III from JAMES VALENCIA.

JONES advised VALENCIA that "my brother [couriers] be there

tomorrow, see my car broke down, so I had to get it fixed today,

this morning, so they left this morning".

155. On August 31, 2002, at 8:48 P.M., JONES received a call

on Target Phone I from NATAN THOMAS. During that conversation

JONES and THOMAS discuss the best route to Florida, and JONES

complains to THOMAS that THOMAS is not taking the best route.

156. On August 31, 2002, at approximately 9:22 p.m., KELLY

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JONES made a call on Target Phone I to William Anthony MORCIGLIO.

During that conversation, JONES complained to MORCIGLIO about

THOMAS. JONES stated "why do I keep giving him chances"? JONES

then explained to MORCIGLIO that "CUZO" [RIVERA] and MELENDEZ were

supposed to travel to Florida, but then MELENDEZ backed out, so

JONES contacted THOMAS.

157. On September 1, 2002, at approximately 4:53 p.m., KELLY

JONES received a call on Target Phone I from THOMAS. During this

call, THOMAS advised JONES that they were "about a half an hour"

from their destination. THOMAS then asked JONES "where do I gotta

go"? At that time JONES is overheard telling David ACEVEDO to

~~tell Nate [NATHAN THOMAS] where to, where to ." ACEVEDO then

relayed the directions to THOMAS. ACEVEDO later stated, "you're

gonna pass like a dealership and all that shit and then just go by

there's a McDonald's, you bust a right as soon as you get off of

the E-way, you are gonna see a McDonald's. And just hit him up

when you get there".

158. On September 1, 2002, at approximately 6:45 p.m. (EST),

agents initiated surveillance at the Palm Plaza shopping center

located on the corner of 167t'' Street and 67t'' Avenue in Miami Lakes,

Florida. At approximately 7:15 p.m. (EST), agents observed a white

Nissan Altima bearing Illinois license plate number 310 4374

(registered to Kelly M. JONES) park in front of the McDonalds

restaurant. Agents observed NATHAN THOMAS and YOLANDA RIVERA exit

~'
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the Altima, walk into the McDonalds, and then reenter the Altima.

Agents also observed THOMAS and RIVERA speaking on cellular

telephones as they walked between the McDonalds and the adjacent

Citgo gas station.

159. On September 1, 2002, at approximately 6:27 p.m. (CST),

KELLY JONES received a call on Target Phone I from THOMAS. During

this call, as JONES and THOMAS begin to talk, JONES received a call

on another phone. JONES is overheard stating, "hey Papo, what's

up? Yes, my friend is there. Yes, yes, he has a seven (7) zero (0)

eight (8) number". JONES then returned to THOMAS, stating "call

him, call the motherfucker".

160. On September 1, 2002, at approximately 6:34 p.m. (CST),

JONES spoke with RIVERA on Target Phone I. During that

conversation, RIVERA advised JONES that they tried to contact the

subject (JESUS ROLDAN) in Florida, but "he hung up". RIVERA

further stated to JONES, "dude hung up on us. So why don't you call

him and tell him we're at Palm Plaza on sixty-seventh (67t''), the

McDonald's". JONES then stated, "all right, I'm going to call you

right back".

161. On September 1, 2002, at approximately 8:11 p.m. (CST),

JONES received a call on Target Phone III from "TOMATICO" [Jesus

Abel ROLDAN] ROLDAN asked JONES, "what happened, talk to this

guy, that he doesn't call or nobody showing up"? JONES then

stated, "huh, so this hasn't happened"? ROLDAN advised JONES that

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"she called me, and we said we'd meet at McDonald's, and I went to

wait at McDonald's and no one has arrived". At that time, JONES

handed the phone to WILLIAM MORCIGLIO, who then spoke with ROLDAN.

MORCIGLIO asked ROLDAN what happened. ROLDAN advised MORCIGLIO

that "I went over there, waiting and nothing". MORCIGLIO then

asked, "you see them? Mi cousin, did you see him"? ROLDAN again

advised that he was at the location but did not see anyone.

MORCIGLIO then advised ROLDAN that he (MORCIGLIO) would "call him

right now, to see what's up". ROLDAN stated, "okay, have him call

me from a public phone".

162. On September 1, 2002, at approximately 8:46 p.m. (CST),

William MORCIGLIO made a call on Target Phone III to ROLDAN.

MORCIGLIO asked ROLDAN if he had "heard from my cousin or what"?

ROLDAN advised MORCIGLIO that "oh, mi'jo, he called me and said to,

said to meet with him at McDonald's, and I told him to meet in half

an hour, and I went to wait there, and he did not get there".

ROLDAN told MORCIGLIO that "I already passed by, I passed by about

four (4) times, I don't want to pass by too much".

163. On September 1, 2002, at approximately 9:12 P.M. (CST),

KELLY JONES received a call on Target Phone I from THOMAS. THOMAS

advised JONES that "this shit is ridiculous folks, I cannot talk to

the fuckin guy [ROLDAN], bro". MORCIGLIO then took the phone from

KELLY JONES and spoke with THOMAS. MORCIGLIO asked THOMAS "what

the fuck! What's up man"? THOMAS stated, "how the fuck do you

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expect me to fuckin talk to this guy [ROLDAN] if he can't speak a

fuckin lick of English"? MORCIGLIO then told THOMAS that he

(MORCIGLIO) would call "TOMATICO" [ROLDAN] and tell him where

THOMAS was. MORCIGLIO then confirmed that THOMAS was at the

McDonald' s on 67t'' Street .

164. On September 1, 2002, at approximately 9:13 P.M. (CST),

JONES received a call from ROLDAN. ROLDAN advised JONES to

"listen, tell (U/I) to call me, because we are here waiting for

those assholes, you understand what I'm telling you"? JONES then

put WILLIAM MORCIGLIO back on the phone to speak with ROLDAN.

MORCIGLIO advised ROLDAN that "he's [THOMAS] eating at the

McDonald's". ROLDAN told MORCIGLIO to tell THOMAS to "come

outside". MORCIGLIO described THOMAS's physical appearance to

ROLDAN. ROLDAN then asked MORCIGLIO what kind of car THOMAS was

driving, and what color it was. MORCIGLIO advised that it was a

"white one".

165. On September 1, 2002, at approximately 10:15 p.m. (EST),

SAIC/Miami Agents again initiated surveillance of the McDonalds

restaurant located on the corner of 167t'' Street and 67t'' Avenue in

Miami Lakes, Florida. At approximately 10:30 p.m. (EST), agents

observed THOMAS and RIVERA in the same Nissan Altima parked in the

parking lot of the Citgo gas station adjacent to the McDonalds

restaurant. Shortly thereafter, Agents observed a white Honda

Accord bearing Florida temporary license plate number F232477 park

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perpendicular to the Altima at the gas pump. Agents then observed

THOMAS exit the Altima, walk to the Accord, and speak with the male

inside the Accord. At that point, agents observed both the Altima

and the Accord depart the Citgo gas station and drive toward the

Dry Cleaners USA store inside the Palm Plaza shopping center. Both

vehicles drove the wrong way on a one-way road behind the Dry

Cleaners USA. Shortly thereafter, agents observed the Altima drive

toward the front of the Dry Cleaners USA to exit the Palm Plaza

shopping center while the Accord drove out a back alley of the Dry

Cleaners USA. Agents observed the Altima depart the area. Agents

also observed the Accord depart the area after making a U-turn on

67t'' Avenue.

166. On September 1, 2002, at approximately 10:05 p.m. (CST),

KELLY JONES made a call on Target Phone I to RIVERA. RIVER.A

advised JONES that "everything is all good" [RIVERA and THOMAS

successfully picked up the heroin].

167. On September 2, 2002, at approximately 8:18 p.m., KELLY

JONES made a call on Target Phone I22 to JAMES VALENCIA. JONES

advised VALENCIA that "my friend, you know, my friends [THOMAS and

RIVER.A] not coming back til, ah, maybe Wednesday, okay, their car

broke down".

168. On September 3, 2002, at approximately 1:18 p.m., KELLY

JONES placed a call on Target Phone III to JAMES VALENCIA. JONES

stated that he was on his way to do "that" [narcotics-related work]

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at that time. VALENCIA responded "Okay, and `Martica' [Martha

LLANOS], too, nine hundred (900)[heroin quantity]". JONES stated

that he would give "everything" [heroin quantity] and that he would

go by "her" [LLANOS] house.

169. On September 3, 2002, at approximately 4:10 p.m., KELLY

JONES placed a call on Target Phone III to LUCHO. LUCHO stated

that "Piecito Malo" [LLANOS] had been calling and she needed JONES.

JONES asked "who, `Martica' [LLANOS]", which LUCHO confirmed.

LUCHO provided LLANOS' number as 562-7316. JONES stated that he

was three (3) minutes from her house. LUCHO stated that LLANOS was

at her business on Montrose and that JONES should call her because

"she's desperate".

170. On September 3, 2002, at approximately 4:18 p.m., KELLY

JONES placed a call on Target Phone I to LLANOS at (773) 562-7316.

LLANOS stated that she was at the store. JONES stated that he was

near St. Louis [LLANOS' residence street address]. JONES and

LLANOS agreed to meet at LLANOS' residence.

171. On September 3, 2002, at approximately 4:37 p.m.,

surveillance agents in the area of 4522 N. St. Louis Avenue

(residence of LLANOS) observed JONES driving a black Chevy Malibu

bearing Illinois license plate number J290301 southbound on St.

Louis Avenue from Sunnyside Avenue. At approximately 4:38 p.m.,

agents observed JONES park the black Malibu in the front of 4522 N.

St. Louis and exit the vehicle. JONES was observed walking to the

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door of the residence carrying a white plastic bag in his right

hand. JONES entered the residence. At approximately 4:43 p.m.,

surveillance units observed JONES exiting the residence carrying an

unknown object in his hand and entering the drivers seat of the

black Malibu. The black Malibu driven by JONES then proceeded

southbound on St. Louis away from the location.

172. On September 3, 2002, at approximately 5:01 p.m., KELLY

JONES called JAMES VALENCIA. During this call, JONES stated "I see

Martica, you know, I pass, I pass her, I pass her everything

[delivered heroin quantity to LLANOS]". VALENCIA later asked JONES

"when is the guy [couriers RIVERA and THOMAS] coming, tomorrow,

yes"? JONES responded "yeah, afternoon, tomorrow afternoon".

173. On September 4, 2002, at approximately 4:25 p.m., KELLY

JONES received a call on Target Phone I from JAMES VALENCIA.

VALENCIA asked JONES if everything was "okay". JONES advised

VALENCIA that everything was fine, "I just got a call, they are eh,

in Tennessee". VALENCIA stated "oh, oh okay, but they got the

stuff [heroin quantity] right now"? JONES replied that they did.

VALENCIA told JONES to call him when "it`s [heroin quantity] there,

okay".

174. On September 5, 2002, at approximately 2:26 a.m.,

surveillance units observed a white Nissan Altima bearing Illinois

license plate 3104374 arrive at 1433 Warner Street in Chicago,

Illinois (residence of KELLY JONES). Agents observed a Hispanic

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male, matching the description of THOMAS, exit the vehicle with a

large white (pillowcase) size package. Agents videotaped the male

exiting the vehicle. Agents observed JONES and an unidentified

individual exit the residence. JONES, the unknown individual, and

the male matching the description of THOMAS met in front of the

residence. At approximately 2:38 a.m., the individual matching the

description of THOMAS entered the passenger side of the Altima and

retrieved an unknown object inside of the car. At approximately

3:00 a.m., JONES, the unknown individual, and the Hispanic male

matching the description of THOMAS, entered 1433 Warner Street,

Chicago, Illinois.

175. On September 5, 2002, at 8:09 a.m., KELLY JONES made a

call on Target Phone I to DAVID ACEVEDO. KELLY JONES advised

ACEVEDO that he, Marcus JONES and WILLIAM MORCIGLIO were going to

do "lab work" [processing heroin delivered by THOMAS and RIVER.A].

176. On September 5, 2002, at approximately 9:41 a.m., KELLY

JONES received a call from YOLANDA RIVERA. RIVERA asked JONES if

THOMAS made it to his house. JONES advised RIVER.A that "yeah, like

at 3:00 a.m."

177. On September 6, 2002, at approximately 2:56 p.m., KELLY

JONES received a call on Target Phone III from Ricardo ARNOLD.

ARNOLD asked JONES if he (JONES) could "slide five (5) [heroin

quantity] on me". JONES responded "yeah" and asked if ARNOLD

needed it right away. ARNOLD stated that he was coming to JONES'

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residence and would call on the way.

178. On September 6, 2002, at approximately 4:55 p.m.,

surveillance units in the area of 1433 W. Warner observed ARNOLD

parked across from 1433 Warner Street in a 1995 Chevy Lumina,

Illinois license plate number 2267903. The vehicle was parked on

the North side of the street facing West. At approximately 5:10

p.m., agents observed KELLY JONES park his black Lincoln Navigator

on Greenview Street. Agents observed JONES, Individual B, and two

small children walk towards the residence in the alley. At

approximately 5:35 p.m., agents observed KELLY JONES exit 1433

Warner Street and walk across the street towards ARNOLD. Agents

observed ARNOLD and JONES entering 1433 Warner Street residence.

At approximately 5:46 p.m., agents observed ARNOLD exit 1433 Warner

Street. ARNOLD was observed with his right hand in his front

pocket. ARNOLD entered his vehicle and left the area.

Drug Shipment From Florida to Chicago

September 15-16, 2002

179. On September 12, 2002, at approximately 10:05 a.m., LUCHO

placed a call from Target Phone VI to JAMES VALENCIA. During this

conversation, VALENCIA told LUCHO (JIRON) to remember that the two

"guys" [drug couriers] are coming in this weekend. LUCHO stated

that he would call VALENCIA in a little while so that they

(VALENCIA and LUCHO) could make arrangements about that.

180. On September 14, 2002, at approximately 10:00 P.M., LUCHO

received a call on Target Phone VI from (773) 833-5899 and spoke

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with Iris D. TORRES. LUCHO asked TORRES if she had already spoken

with Individual F [unidentified courier]. TORRES stated that she

had and that "everything's okay". LUCHO stated that he (Individual

F) would be going to TORRES' house. TORRES stated "he already got

here". LUCHO (JIRON) stated that he would call her the following

morning so she can pick up another "cousin of mine" [courier].

LUCHO continued "he's not the one who came the other time" [not the

same courier]. LUCHO also stated that he would call TORRES because

"they'll give me his telephone number to call him in the morning,

so you can see him". TORRES asked when LUCHO was going to stop by.

LUCHO stated that he would be coming the following day "because

I've got to pick up all the CD's at once because the party is

tomorrow" [JIRON will pick up the entire shipment of heroin at once

for distribution]. In addition, LUCHO stated that some of the CD's

[heroin quantity] are "scratched" [not ready for distribution] and

"have to go to be cleaned with your friend" [some of the heroin

needs to be processed for distribution].

181. On September 15, 2002, at approximately 9:26 a.m., LUCHO

placed a call on Target Phone vI to an unidentified number, and

spoke with Individual C. Individual C stated that he was going to

give LUCHO "the information" [information related to the drug

courier]. Individual C provided the telephone number (847) 635-

1300 and the room number 155. Individual C told LUCHO that the

"man's" [courier] name is "Ruben" [RUBEN CHAPARRO-RAMOS] and that
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he was at the Comfort Inn. Individual C further provided the

address of 2175 E. Touhy Avenue. Individual C told LUCHO to call

RUBEN and "tell him you're on your way".

182. On September 15, 2002, at approximately 9:29 a.m., LUCHO

placed a call from Target Phone VI to '~RUBEN" [CHAPARRO-R.AMOS] at

(847) 635-1300. LUCHO then dialed room number 155. LUCHO told

"RUBEN" that "IRIS" [IRIS D. TORRES] was going to stop by to pickup

some "CD's" [heroin quantity] and that she was going to call him

(CHAPARRO-RAMOS) so they (CHAPARRO-RAMOS and TORRES) could meet in

half an hour to an hour.

183. On September 15, 2002, at approximately 9:37 a.m., LUCHO

received a call on Target Phone VI from (773) 317-9233. During

this conversation, LUCHO spoke with "NEGRITA" (SANDRA P.

VELAZQUEZ). LUCHO stated that he already talked with "the guys"

[couriers] and stated that he could see "NEGRITA" in the afternoon

or for breakfast. "NEGRITA" told LUCHO to call when he was ready

so that she could get ready. LUCHO agreed and added that he

thought that two (2) "CD's" [heroin quantity] are "ready"

[available for distribution] and that two (2) "CD's" [heroin

quantity] are "scatched" [not yet available for distribution].

184. On September 15, 2002, at approximately 11:05 a.m.,

surveillance agents in and around the Comfort Inn observed

CHAPARRO-RAMOS exit room 155. CHAPARRO-R.AMOS returned to his room

after walking to the Mobil gas station across the street. At

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approximately 11:14 a.m., surveillance agents observed CHAPARROR.AMOS exit his room and walk to the front of the Comfort Inn.

CHAPARRO-R.AMOS was also observed utilizing his cellular telephone.

Shortly thereafter, surveillance units observed a white Toyota in

the parking lot of the hotel. This vehicle is registered to the an

individual with an address of 4715 W. McLean, Chicago, Illinois.

This vehicle was driven by a Hispanic female and another female was

observed in the passenger seat. At approximately 11:15 A.M.,

surveillance agents observed CHAPARRO-R.AMOS return to his room and

retrieve a red box. An agent observed CHAPARRO-R.AMOS return to the

Toyota and place the box in the trunk of the Toyota. The Toyota

then departed the parking lot of the Comfort Inn, followed by

surveillance units.

185. On September 15, 2002, at approximately 11:21 a.m., LUCHO

placed a call from Target Phone VI to (847) 635-1300. During this

conversation, LUCHO told "RUBEN" (CHAPARRO-RAMOS) that "the lady"

(IRIS TORRES) is close by and that she (IRIS TORRES) is almost

there.

186. On September 15, 2002, at approximately 11:25 a.m., LUCHO

placed a call from Target Phone VI to (773) 317-9233. During this

conversation, LUCHO spoke with "NEGRITA" (SANDR.A P. VELAZQUEZ).

LUCHO asked "NEGRITA" if they could meet the following morning

because some of the "clothes" [heroin] came in "unironed" [not

available for distribution]. LUCHO and "NEGRITA" agreed to meet

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the following morning at approximately 7:00 a.m.

187. On September 15, 2002, at approximately 11:50 a.m., LUCHO

placed a call from Target Phone VII to (773) 851-8640. During this

conversation, LUCHO spoke with "IRIS" [IRIS D. TORRES] LUCHO

asked if she had spoken with "him" [drug courier] already or not.

TORRES stated that they were talking at that time.

188. On September 15, 2002, at approximately 11:51 a.m., LUCHO

placed a call from Target Phone V22 to (646) 262-4421. During this

conversation, LUCHO told Individual C that "she" (IRIS TORRES) was

at the hotel. LUCHO confirmed it was "IRIS."

189. During this time period, surveillance units in the area

of the Comfort Inn located at 2175 E. Touhy observed an individual

later identified as RUBEN CHAPARRO-RAMOS carrying a box out of room

155. CHAPARRO-RAMOS then exited the hotel with the box and

approached a vehicle occupied by two (2) females. Surveillance

then followed the vehicle to the area of 4715 W. McLean Street in

Chicago, which is believed to be the residence of IRIS D. TORRES.

190. On September 15, 2002, at approximately 12:28 p.m.,

LUCHO received a call on Target Phone VII from VALENCIA at an

unidentified telephone number. During this conversation, LUCHO

stated that "Natacha" [believed to be CHAPARRO-RAMOS] and another

person also believed to be a drug courier arrived. LUCHO also

stated that he spoke with "NEGRITA" (VELAZQUEZ) and that they

(LUCHO and VELAZQUEZ) agreed to meet tomorrow.
191. On September 15, 2002, at approximately 9:08 p.m., LUCHO

received a call on Target Phone vI from (773) 833-5899. During

this conversation, LUCHO spoke with "IRIS" [IRIS D. TORRES] LUCHO

asked if they could meet at 6:00 a.m. the following morning.

TORRES stated that she could not because she had a lot of things to

do the following day.

192. On September 15, 2002, at approximately 9:10 p.m., LUCHO

placed a call on Target Phone VI to (773) 317-9233. LUCHO told

"NEGRITA" (VELAZQUEZ) that the lady [TORRES] ~~is telling me that I

can't to eat with you at seven (7:00) o'clock tomorrow morning

[TORRES cannot meet to deliver the heroin to LUCHO and therefore

LUCHO cannot deliver the heroin to VELAZQUEZ]. LUCHO stated that

'`the clothes [heroin quantity] I have for you, you know, the ones

that are ironed [ready for distribution] are ready but I just

called the lady [TORRES] that is supposed to give me that [heroin

quantity] tomorrow morning and she said she can't do it at six (6)

o'clock in the morning".

193. On September 16, 2002, at approximately 8:27 a.m., LUCHO

received a call on Target Phone vI from (773) 317-9233. LUCHO and

"NEGRA" (VELAZQUEZ) agreed to meet at approximately 10:00 a.m.

LUCHO•added "I'll give you the oven [container for heroin quantity]

and then you' 11 give me the little oven [container] so the guys

[couriers] can So we can put receipts [currency] in there too
i ~~

194. On September 16, 2002, at approximately 8:46 a.m., LUCHO

placed a call on Target Phone VI to (773} 637-8271. LUCHO told

IRIS D. TORRES that he was on his way over "there" (to TORRES'

residence).

195. On September 16, 2002, at approximately 9:30 a.m.,

surveillance units in the area of 4715 W. McLean Street (near the

residence of IRIS TORRES) in Chicago, observed a vehicle previously

identified during the investigation as a vehicle driven by LUCHO

parked on the east side of the residence. At approximately 9:40

a.m., surveillance units observed LUCHO's vehicle departing the

area northbound on Cicero Avenue.

196. On September 16, 2002, at approximately 9:58 a.m., LUCHO

placed a call from Target Phone VI to (773) 317-9233. LUCHO told

"NEGRITA" (VELAZQUEZ) that he (LUCHO) would arrive in five (5) to

six (6) minutes.

197. On September 16, 2002, at approximately 10:05 a.m.,

surveillance units observed LUCHO's vehicle parked in the west

alley of the 5700 block of North St. Louis Avenue [believed to be

VELAZQUEZ' residence]. The hatchback of the vehicle was open and

surveillance observed LUCHO carrying a box east through the alley.

198. On September 16, 2002, at approximately 11:19 a.m., LUCHO

placed a call from Target Phone VI and spoke with JAMES VALENCIA.

LUCHO states "I already spoke to `NEGRITA' [VELAZQUEZ] and I gave

her what I had ironed out [heroin prepared for distribution], which
was 2260 [heroin quantity]"

Drug Shipment From Florida to Chicago

September 16 - 20, 2002

199. On September 16, 2002, at approximately 2:52 p.m., KELLY

JONES made a telephone call on Target Phone I to ANGEL MELENDEZ,

JR. During this conversation, JONES asked MELENDEZ if he "feel

like doin' something?" JONES further asked MELENDEZ if he wanted

to go "somewhere and getting a tan?" [travel to the Miami, Florida

area to pick up heroin for the organization and transport the drugs

back to Chicago]. MELENDEZ stated that "you got the number, bro.

Whenever you get word, just hit me up JONES asked MELENDEZ

who would accompany him on the trip and Melendez replied, "most

likely Dave" [DAVID ACEVEDO, who during the investigation has been

observed making drug-related trips between Chicago and New York on

behalf of the organization].

200. On September 17, 2002, at approximately 2:48 p.m., KELLY

JONES using Target Phone I called MELENDEZ. During this

conversation, JONES told MELENDEZ that he would find out about the

"mission" [narcotics-related trip] as soon as he talked with his

"guy". JONES asked MELENDEZ if he was still interested in taking

the trip, and MELENDEZ stated that he was.

201. On September 18, 2002, at approximately 8:07 a.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, MELENDEZ told JONES that his "girl" would be
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traveling with him. JONES and MELENDEZ also discussed traveling in

the "white car" [white Nissan Altima registered to JONES which has

been used by the organization's drug couriers on prior drug-related

trips].

202. On September 18, 2002, at approximately 6:46 p.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, JONES asked MELENDEZ where he was. MELENDEZ stated

that he was near Atlanta. JONES asked if everything is "running

smoothly". JONES instructed MELENDEZ to "check in every couple

hours, bro".

203. On September 18, 2002, at approximately 10:30 p.m., KELLY

JONES called LUCHO using Target Phone I. During this conversation,

LUCHO provided JONES with two telephone numbers, each having a

Florida area code.

204. On September 19, 2002, at approximately 7:27 a.m., KELLY

JONES called MELENDEZ using Target Phone I. During this

conversation, MELENDEZ told JONES that he (MELENDEZ) had been doing

a majority of the driving. MELENDEZ informed JONES that they were

near Ft. Lauderdale, Florida. JONES asked MELENDEZ to call him

(JONES) when he "get over there", so JONES could give him

(MELENDEZ) the Florida contact phone number.

205. On September 19, 2002, at approximately 9:38 a.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, MELENDEZ told JONES he was at the McDonald's
i_ .- -_. ~ .. ~ t - \~ f J~ t 1 4 _ ~ 1.

`~

restaurant and wants "o' boys" phone number. JONES provided

MELENDEZ with the number (786) 543-9360.

205. On September 19, 2002, at approximately 9:42 a.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, MELENDEZ told JONES that the phone he was trying to

call is turned off. JONES told MELENDEZ, "give me a minute let me

call him. Let me see what I can do".

206. On September 19, 2002, at approximately 9:49 a.m., KELLY

JONES called MELENDEZ on Target Phone I. During this conversation,

JONES provided MELENDEZ with the phone number (786) 546-6891.

MELENDEZ stated that he would, "hit him up right now". JONES

instructed MELENDEZ to call him (JONES) back.

207. On September 19, 2002, at approximately 10:06 a.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, MELENDEZ told JONES that they were going to "have

lunch" with an individual. MELENDEZ further told JONES that he

(MELENDEZ) would call JONES in one and a half hours.

208. On September 19, 2002, at approximately 12:35 p.m., KELLY

JONES received a voice mail message on Target Phone I from

MELENDEZ. During the message, MELENDEZ informed JONES, "I just did

that, everything's cool. Got up all our gear and what not"

[informing JONES that he (MELENDEZ) met with the Florida member of

the organization and received heroin to return to Chicago,

Illinois].

:~
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~ .. ~_ ' -

i

209. On September 20, 2002, at approximately 3:06 p.m., KELLY

JONES made a call on Target Phone I to DANIEL MALDONADO. During

this conversation, MALDONADO informed JONES that MELENDEZ was

currently delayed in Indiana due to weather conditions. JONES then

told MALDONADO that they would need to do "lab" work the next day

[preparing the heroin for distribution].

210. On September 20, 2002, at approximately 5:01 p.m., KELLY

JONES received a call on Target Phone I from RICARDO ARNOLD.

During this conversation, JONES informed ARNOLD that he (JONES) was

still "waiting" and that his couriers were behind schedule, due to

a tornado.

211. On September 20, 2002, at approximately 7:52 p.m., KELLY

JONES received a call on Target Phone I from MELENDEZ. During this

conversation, MELENDEZ informed JONES that he was twenty minutes

from JONES' residence.

212. On September 20, 2002, at approximately 8:25 p.m.,

surveillance observed a white Nissan Altima arrive at 1433 West

Warner [residence of KELLY JONES]. Surveillance observed ANGEL

MELENDEZ exit the vehicle and carry a black bag into the residence.

JAMES VALENCIA Travels to Chicago to Meet

With Members of the Organization

213. On October 16, 2002, at 1:07 p.m., JONES made a call to

VALENCIA using Target Phone VIII. VALENCIA told JONES that "I'll

be there in a couple days". Also during that conversation, JONES

-87-
and VALENCIA discuss getting an "apartment" for VALENCIA. JONES

advised VALENCIA that he (JONES) had an apartment because he and

his family had just moved to another one, but he maintained the old

apartment (1433 Warner, Chicago). VALENCIA also asked JONES for a

phone number for others to be able to reach VALENCIA while he was

here. JONES told VALENCIA to give out the number for Target Phone

VIII, (773) 968-3149. VALENCIA advised JONES that phone would be

getting calls from Spanish speaking people, and asked if he should

give MORCIGLIO'S phone number. JONES stated "no that, cause that's

him Mom's phone". JONES continued to state that "cause any

problems I could throw it away", referring to Target Phone VIII.

214. On October 19, 2002, at 11:26 a.m., JONES again made a

call to VALENCIA using Target Phone VIII. During that call,

VALENCIA advised JONES "maybe I gonna see you this weekend". JONES

replied "okay, no problem", and told VALENCIA to call him (JONES)

and "let me know".

215. On October 22, 2002, at 4:21 p.m., JONES called VALENCIA

using Target Phone VIII. VALENCIA instructed JONES to give two

thousand dollars to "MONO" [JUAN LOZADA], so he (LOZADA) could

"bring my tickets". JONES stated that he would comply.

216. At 4:22 p.m., on October 22, 2002, JONES called

LOZADA from Target Phone VIII. JONES advised LOZADA that he had

spoken with "JOTA" (VALENCIA) and was instructed to give him

(LOZADA) two thousand for the "tickets". LOZADA then advised JONES

~:~:~
that they could meet later.

217. On October 23, 2002, at 12:54 p.m., JONES called

VALENCIA using Target Phone VIII. In the course of this

conversation, VALENCIA again told JONES, "maybe see you this

weekend, okay".

218. On October 24, 2002, at 8:55 p.m., JONES received a call

from VALENCIA on Target Phone VIII. During that conversation,

VALENCIA again stated to JONES, "maybe I'll see you Sunday". JONES

then asked VALENCIA, "you want me to have anything ready for you"?

VALENCIA then stated, "apartment, maybe". JONES replied, "let me

know, yeah, I put apartment, I put a bed, everything". During that

same conversation, VALENCIA advised JONES that he (JONES) would be

going to "see, eh, [Individual G] for [Individual G] it's...but wait

for me, okay, don't do it nothing".

219. On October 25, 2002, at 2:29 p.m., JONES put a call into

VALENCIA using Target Phone VIII. An unknown male subject answered

the phone, and JONES asked for "JAMES". The subject then stated,

"no little cousin, no, no, no, he's already traveling". Later in

the conversation the subject told JONES that if he (JONES) needed

anything to call him at a specified number. This subject continued

to tell JONES, "listen, is, is, Dallas if go over there okay". He

then stated "I thinking tomorrow is over there, buddy".

220. On October 25, 2002, at 3:29 p.m., JONES received a

call from VALENCIA on Target Phone VIII. VALENCIA advised JONES,

.'
_. i. 1. I

"Monday, don't forget Monday, maybe I see you Monday".

221. On October 25, 2002, at 6:00 p.m., LUCHO received a call

from LLANOS at (773) 454-5155 on Target Phone X. LLANOS advised

LUCHO that VALENCIA had been trying to call him (LUCHO), but had

been unable to get through. LLANOS then gave LUCHO the following

telephone number and told LUCHO to call VALENCIA, at 011-52-55-11-

73-79-22. A check of that number revealed that it was a Mexico

City, Mexico telephone number.

222. On October 28, 2002, in the late evening, surveillance

agents in Chicago observed VALENCIA, KELLY JONES, LUCHO (JIRON),

ROLDAN, WILLIAM MORCIGLIO, and other individuals at a local

restaurant in Chicago. Later that same night, these individuals

were observed leaving the restaurant.

223. On October 28, 2002, at approximately 8:41 p.m., LUCHO

spoke with IRIS TORRES over Target Phone IX and told her to bring

the machine that irons [heroin press] to the old apartment [3005

Gunnison, apartment 1E] in the morning.

V. ADDITIONAL INTERCEPTED CALLS/SURVEILLANCE

JAMES VALENCIA aka "Jota" and "Father"

224. On August 20, 2002, at approximately 12:55 p.m., LUCHO

received a call on Target Phone IV from an unidentified number.

LUCHO spoke with VALENCIA. VALENCIA stated that he had been away

and had just returned. VALENCIA asked if LUCHO had sent any of

"that" [wire transfer of money]. LUCHO stated that he did.
- ... - ,. , i_ _. 

~.. - t _ ~.. ~ ..

~ \

VALENCIA stated that he missed the wire and asked where LUCHO had

sent them [wire transfer]. LUCHO stated "over there, the same

place you told me, Cancun". VALENCIA asked LUCHO to see if they

[wire remitter] can change it to Caracus, Venezuela. LUCHO asked

if he should use the same names. VALENCIA stated that he should.

LUCHO stated that he would do that.

225. On August 20, 2002, at approximately 1:58 p.m., LUCHO

placed a call from Target Phone IV to VALENCIA. LUCHO told

VALENCIA to write down a number [money transfer control number] for

the money wire [of drug proceeds]. LUCHO then gave a name

[sender's name on wire transfer]. LUCHO continued "he's sending it

to ." and gave a different name [receiver's name on wire

transfer]. LUCHO then provided what is believed to be a money

transfer control number. VALENCIA asked where "that one" [wire

transfer] was going. LUCHO stated that initially to Cancun but

that they were going to change it to "D.F." [Mexico City]. LUCHO

stated that he sent "one thousand eight-hundred (1,800)" [quantity

of drug money]. VALENCIA stated that he was ready for the other

one, "one thousand eight-hundred (1,800)" [quantity of drug money].

LUCHO stated that "Individual H [sender's name on wire transfer] is

sending the other one to Individual I [receiver's name on wire

transfer]". LUCHO then provided a money transfer control number

and stated "the same amount, one thousand eight-hundred (1,800)

dollars...to Cancun, but...if you can't claim over there, then I'll

-91-
— ..

- 1. ' 

.. _ ~ _. _ 1.

~~

see if, if I can change it to D.F. [Mexico City]".

226. On September 24, 2002, at approximately 9:24 p.m., LUCHO

received a call on Target Phone VI from VALENCIA at an unknown

telephone number. VALENCIA asks LUCHO "did you `cook' [wire

transfer money] five thousand (5,000) [quantity of money] to that

guy...". LUCHO states that he did "cook" five thousand, two

hundred (5,200) [quantity of money]. LUCHO states that "Paisita"

(MILENA PUPO) gave him "seven (7) pesitos" [quantity of money].

LUCHO says that he paid "Iris" (TORRES) and "Kelly" (JONES), and

that three thousand four hundred [quantity of money] was left.

VALENCIA tells LUCHO to give him three thousand (3,000) "pesitos"

[quantity of money] that he needs in his account "number 310" [bank

account].

CARLOS JIRON aka "Lucho" and "Luis"

227. On August 18, 2002, at approximately 1:25 p.m., LUCHO

(JIRON) received a call on Target Phone V from KELLY JONES using

Target Phone III. LUCHO told Kelly JONES that he (LUCHO) has a

"check for five hundred dollars" for JONES. LUCHO said he would

pass by and deliver it to JONES at 5:00 p.m. or 6:00 p.m.

228. On August 18, 2002, at approximately 1:32 p.m., LUCHO

placed a call from Target Phone V to JONES at Target Phone III.

LUCHO stated that he was going to the apartment and that he would

call JONES when he arrived. JONES asked how long until LUCHO

arrived at the apartment. LUCHO stated approximately twenty (20)

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~ 

~~

minutes.

229. On August 18, 2002, at approximately 2:05 p.m., LUCHO

placed a call from Target Phone V to JONES at Target Phone III.

LUCHO asked JONES if he (JONES) was coming. JONES stated that he

was almost at the apartment. JONES asked LUCHO to "pass" [deliver]

him "five fifteen (515)" [amount of money]. LUCHO agreed to this

amount.

230. On August 18, 2002, at approximately 2:28 p.m., LUCHO

placed a call from Target Phone V to JONES at Target Phone III.

LUCHO asked if JONES was coming. JONES stated that he was and

asked if they were going to meet outside or at the corner. LUCHO

stated that he was already outside. JONES stated he would arrive

in five (5) minutes.

231. On August 18, 2002, at approximately 2:30 p.m.,

surveillance units in the area of 1433 W. Warner (residence of

JONES) observed JONES enter his vehicle and depart the area. At

approximately 2:38 p.m., surveillance units observed a Chrysler

Sebring (previously identified as being registered to LUCHO) parked

on Sacramento just south of Gunnison Ave. JONES in his Navigator

parked immediately behind the Sebring. At approximately 2:40 p.m.,

JONES drove away in the Navigator and proceeded westbound on

Gunnison. LUCHO proceeded westbound on Gunnison.

232. October 2, 2002, at approximately 6:06 P.M., LUCHO placed

a call from Target Phone VI to VALENCIA. LUCHO stated that he

-93-
talked to "the Singer" [New York Supplier] and that New York

Supplier would be calling LUCHO to let him know if Individual J

[drug courier] was coming to Chicago.

233. On October 3, 2002, at approximately 9:58 A.M., LUCHO

placed a call from Target Phone VI to VALENCIA. LUCHO stated that

there is "fourteen five hundred (14500)" [quantity of money] to

give to Individual J.

234. On October 3, 2002, at approximately 1:19 P.M., LUCHO

placed a call from Target Phone v2 to Individual J at (347) 256-

4642. Individual J stated that he would arrive in approximately

one hour. During the same time period, surveillance units in the

area of the Greyhound Bus terminal observed LUCHO exit his vehicle

and walk to the bus terminal where he waited for some time. While

waiting, LUCHO was observed utilizing his cellular phone. At

approximately 3:50 P.M., Greyhound Bus #6347 arrived at the bus

terminal on Harrison Avenue. DEA Transportation agents approached

the off-loading area for bus. The first passenger to exit the bus

was carrying a small black overnight-size bag. This individual was

believed to be Individual J. After departing the arrival area,

Individual J was approached by LUCHO. They both exited the bus

terminal together and walked to LUCHO's car on Des Plaines Avenue.

Surveillance units subsequently followed LUCHO and Individual J to

3005 W. Gunnison.

235. On October 17, 2002, at approximately 10:30 p.m., KELLY

-94-
JONES received a call from JAMES VALENCIA on Target Phone VIII.

During that conversation, VALENCIA instructed JONES to "pass to"

LUCHO (JIRON) later that night. JONES advised VALENCIA that he

(JONES) had been calling LUCHO, but LUCHO was not answering.

VALENCIA then gave JONES the following telephone number: 501-1695

(Target Phone X). JONES then stated that he would call LUCHO

"right now".

236. On October 17, 2002, at approximately 10:31 p.m., KELLY

JONES using Target Phone VIII called Target Phone X and spoke with

LUCHO. During that conversation, LUCHO asked JONES if he (JONES)

had "four hundred" [quantity of heroin]. JONES advised LUCHO that

he had "three twenty or three twenty-five" [quantity of heroin].

LUCHO then told JONES that he (LUCHO) was at "MARTICA's" (LLANOS).

JONES stated that he (JONES) would meet LUCHO there. Affiant

believes that based on this conversation, JONES and LUCHO were

planning to meet in order for JONES to deliver a quantity of heroin

to LUCHO.

237. However, rather than meeting at LLANOS' place, based on

subsequent intercepted conversations Affiant believes that JONES

and WILLIAM MORCIGLIO agreed to meet with LUCHO at a different

location to deliver LUCHO the heroin. Specifically, on October 17,

2002, at approximately 11:09 p.m., Target Phone VIII contacted

Target Phone X. During that call, WILLIAM MORCIGLIO spoke with

LUCHO, and KELLY JONES is heard in the background next to

-95-
MORCIGLIO. MORCIGLIO and LUCHO discussed meeting each other in the

area of the streets of Wilson and California, by the "train".

238. On October 17, 2002, at approximately 11:20 p.m., WILLIAM

MORCIGLIO using Target Phone VIII called LUCHO on Target Phone X.

MORCIGLIO explained to LUCHO how to get to the meeting area. LUCHO

asked MORCIGLIO which car he (MORCIGLIO) was in, and MORCIGLIO

responded that he was in a green Pontiac Bonneville. LUCHO stated

that he was in the "blue one", and he has his lights on.

239. On October 17, 2002, at approximately 11:23 p.m., WILLIAM

MORCIGLIO using Target Phone VIII called LUCHO on Target Phone X.

LUCHO advised that he was at a gas station at Lawrence and

California. MORCIGLIO then gave LUCHO directions from that

location to the meet location, at Wilson and California.

240. On October 22, 2002, at approximately 12:17 P.M.,

JONES placed a call from Target Phone VI22 to LUCHO at (773) 501-

1695. LUCHO asked if he and JONES were going to meet. JONES

agreed to meet. JIRON stated they would meet "in the old

apartment, the one on Lawrence".

241. On October 22, 2002, at approximately 1:18 P.M.,

JONES placed a call from Target Phone VIII to LUCHO at (773) 501-

1695. LUCHO stated that he was on Lincoln and Western and that he

was going over "there" [3005 W. Gunnison]. JONES stated that he

would arrive in five minutes. LUCHO stated that when JONES arrives

he should go upstairs and a "friend" of LUCHO's would give him
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(JONES) the "money".

242. At approximately 12:30 P.M., surveillance units in

the area of 3005 W. Gunnison advised that LUCHO's vehicle was

parked on Sacramento just North of W. Gunnison. At approximately

1:00 P.M., LUCHO accompanied by an unidentified male departed the

vicinity of 3005 W. Gunnison in the LUCHO's vehicle. LUCHO drove

in circles around the streets within one or two blocks going North

then West and then back East to Gunnison. At approximately 1:15

P.M., LUCHO returned to the 3005 W. Gunnison address with the

unidentified male passenger. At approximately 1:30 P.M.,

surveillance units observed JONES' Navigator arrive end park on

Sacramento at Gunnison. Surveillance units observed JONES exit the

Black Navigator and walk to the 3005 W. Gunnison address and enter

the building. At approximately 1:35 P.M., JONES returned to the

Black Navigator and departed the area of W. Gunnison.

DAVID ACEVEDO

243. On August 3, 2002, at approximately 12:06 p.m., KELLY

JONES using Target Phone I called DAVID ACEVEDO at teleplhone number

(773) 206-0694. During this conversation, JONES told ACEVEDO that

he (JONES) had "to finish a little lab work" [drug-related work]

that he had "at the crib" [at his residence]. ACEVEDO asked JONES

if he needed anything [supplies for drug-related work] and JONES

replied that he thought he had everything and that he had the

"gloves from last time" [used to package the heroin]. JONES stated

-97-
- - ~ l ~ _ ~ t

l ~~ 1

that he was going to look for another blender because the one he

had now was jamming on him and ACEVEDO stated "again". JONES then

stated that it [heroin] was not that much, that it [heroin] was

already mixed, "like a couple of hundred just gotta be crushed a

little bit better" and that it will be all ready to go. ACEVEDO

then stated alright and agreed to meet JONES at his residence to

help with the work [drug-related activity].

~nlilliam Anthony Morciglio aka "Woody"

244. On October 21, 2002, JONES received a call from VALENCIA

where VALENCIA stated that he had "work" in Galveston (Texas).

VALENCIA provided a Houston, Texas area cellular phone number to

JONES as a contact number for this "work". VALENCIA told JONES to

"put it in a radio" [boom-box type radio]. JONES stated that he

would take care of it. JONES later contacted Yolanda RIVERA and

stated that "it's about that time" and asked RIVERA if she was

"down". RIVERA agreed to travel for JONES.

245. On or about October 21, 2002, MORCIGLIO and RIVERA

departed Chicago for Galveston, Texas. Several calls were

intercepted between JONES and MORCIGLIO during which MORCIGLIO

reported their (MORCIGLIO and RIVERA) progress. According to

intercepted calls, MORCIGLIO and RIVER.A arrived in Galveston, Texas

on October 23, 2002. MORCIGLIO and RIVERA later traveled to "Htown" (Houston, Texas) in order to meet an unidentified individual

for the purpose of picking up a quantity of heroin. According to

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intercepted calls, MORCIGLIO and RIVERA departed Houston, Texas for

Chicago on October 23, 2002.

246. On October 24, 2002, surveillance units observed

MORCIGLIO and RIVERA arrive in JONES' Nissan Altima at 18215 S.

Kedzie, the residence of RIVERA. At that point, RIVERA exited the

Altima. Shortly thereafter, surveillance units in the area of 1433

W. Warner observed MORCIGLIO arrive in the Altima. MORCIGLIO and

JONES later appeared to meet in the rear alley of 1433 W. Warner.

MARCUS JONES aka "Titty" and "T"

247. On August 3, 2002, at approximately 4:32 p.m., WILLIAM

MORCIGLIO called KELLY JONES on Target Phone I. During this

conversation, MORCIGLIO told JONES that his dad [VALENCIA] had been

trying to contact him (JONES) all day. JONES told MORCIGLIO that

he was working [drug-related activity], and that he would call

VALENCIA when he (JONES) was finished because he (JONES) did not

have "this shit" [heroin] ready and he had to get rid of it

[heroin]. MORCIGLIO also told JONES that VALENCIA wanted JONES to

call LUCHO because he (LUCHO) "needs to go shopping" [purchase

heroin] and wants to know if he needs to send his nephew "out

there" [possibly referring to drug-related trip to New York]

tomorrow. JONES told MORCIGLIO that he would call him (VALENCIA)

in a little bit because he (JONES) was doing the "lab work" [drugrelated activity] with "Dave" [ACEVEDO], "Danny" [MALDONADO] and

"T" [MARCUS JONES].
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IRIS D. TORRES

248. On September 29, 2002, at approximately 7:29 a.m., LUCHO

received a call on Target Phone VI from (954) 554-7647. During

this conversation, LUCHO spoke with Individual K who gave LUCHO the

address and directions to a Holiday Inn Hotel where he (Individual

K) was staying. Individual K asked if the "clothes" [heroin] are

"ironed" [ready for distribution] or if the "lady" [IRIS TORRES]

"irons" them. LUCHO responded that the "lady" [IRIS TORRES] irons

"them" [heroin].

249. On September 29, 2002, at approximately 7:31 A.M., JIRON

(LUCHO) placed a call from Target Phone VI to TORRES at (773) 637-

8271. LUCHO stated that he talked with the "guy" (Individual K).

LUCHO then provided TORRES with Individual K's telephone number,

(954) 554-7647. LUCHO stated that "he" was waiting at a hotel at

5300 Touhy and that he didn't know if it was the same hotel as

"last time". TORRES stated that she was going to call "him"

(Individual K) later.

250. At approximately 10:47 A.M., surveillance agents in the

area of the Holiday Inn located at 5300 W. Touhy, Skokie, Illinois

observed an unidentified Hispanic Male exit the hotel wearing a

blue hooded sweatshirt and utilizing a cellular telephone. This

individual met with a Blue Toyota SW, bearing Illinois license

plate number C11964 (registered to Individual E) Individual K

returned to the hotel and the Blue Toyota pulled away.
Surveillance team members observed IRIS TORRES in the front seat of

the vehicle with an unidentified Hispanic Male.

251. On September 29, 2002, at approximately 10:51 A.M., LUCHO

received a call on Target Phone VI from Individual K at (954) 554-

7647. Individual K stated "it's come, it's here already" [the

delivery had been made]. Individual K asked LUCHO if it was "the

mother and daughter". LUCHO stated that it was. Individual K

continued that he "already gave them ." [delivered the heroin

quantity]. LUCHO then stated "ok, the little clothes" [heroin

quantity].

252. On September 29, 2002, at approximately 11:39 a.m., LUCHO

received a call on Target Phone VII from an unidentified number,

and spoke with JAMES VALENCIA. During this conversation, LUCHO

told VALENCIA that "the guy is here" [a courier arrived in Chicago]

and that LUCHO was talking to him now. LUCHO further told VALENCIA

that he was making arrangements for a "box" [secret compartment] to

be made for his car.

253. On September 30, 2002, at approximately 8:59 a.m., LUCHO

received a call on Target Phone VII from an unidentified number,

and spoke with JAMES VALENCIA. During this conversation, VALENCIA

asked how things went the day before. LUCHO stated that everything

went fine and that he and "IRIS" [TORRES] already delivered it

[delivery of heroin]. VALENCIA told LUCHO to "save" [hold onto the

heroin] for '~NEGRA" [SANDRA VELAZQUEZ] and ~~MONO" [JUAN LOZADA].

-101-
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254. On October 4, 2002, at approximately 1:05 P.M., LUCHO

placed a call from Target Phone VI and spoke with VALENCIA. LUCHO

stated that he spoke with "Iris" [TORRES] and that they (LUCHO and

TORRES) were going to the "shop" [heroin lab] to look at the

"fabrics" [heroin quantity]. LUCHO stated that TORRES was upset

because she spoke with someone who told TORRES that she should be

being paid more than "300 pesos" [quantity of money]. LUCHO

continued that TORRES now wants "us" [VALENCIA and LUCHO] to pay

her "1,000 pesos" [quantity of money]. VALENCIA told LUCHO to tell

TORRES that "the time is different" and "It's not the same as when

she did it with the other guy. When she did it with my friend, it

was more".

255. On October 4, 2002, at approximately 7:02 P.M., LUCHO

placed a call from Target Phone VI and spoke with VALENCIA. LUCHO

told VALENCIA "up until right now, there's one(1) one(1) three(3)

eight(8) and we're picking up the crumbs to see what it comes

to ." [LUCHO and TORRES are processing heroin and LUCHO is

giving the weight to VALENCIA]. LUCHO stated "that threw Iris on

the bed" [TORRES became ill from processing] and that "it's very

good. It's very good." [high quality heroin].

256. On October 4, 2002, at approximately 7:21 P.M., LUCHO

placed a call from Target Phone VI and spoke with VALENCIA. LUCHO

told VALENCIA "one(1) one(1) four(4) five(5)" [heroin quantity].

VALENCIA told LUCHO to "price it at 150, you say it`s great, right"

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i

,~

[price related to the high quality of the heroin]. LUCHO stated

"we're going to iron this now" [LUCHO and TORRES and going to

process heroin quantity]. At that point TORRES began to speak with

VALENCIA. TORRES told VALENCIA that she was "a little out of it"

[ill from processing heroin] and that "we were well covered .

but this shit is an atomic bomb" [LUCHO and TORRES wore protective

attire but the heroin is of very high quality]. TORRES asked

VALENIA how much he (VALENCIA) told "Lucho" to give her (TORRES)

for "the pick-up" [TORRES picking up heroin quantity from a

courier]. VALENCIA stated that he told LUCHO to give her "300"

[quantity of money]. TORRES stated "to go that far for 300, no

way". VALENCIA told TORRES "the job is his [JIRON] so you guys

have to divide it between you". TORRES told VALENCIA to tell LUCHO

because she already told him (LUCHO) "if not I wouldn't go pick up

anymore". [TORRES would not pick up heroin unless she gets more

money].

MARTHA LLANOS aka "Martica", "La Mona", and "Pie Malo'~

257. On August 13, 2002, at approximately 8:54 a.m., LUCHO

placed a call from Target Phone IV to (773) 562-7316 and spoke with

a female LUCHO referred to as "Martica" [Martha LLANOS] LUCHO

stated that he brought back world cup "T-shirts" [heroin] from

Miami and that he had "ten, eight, seven" [heroin quantities].

LUCHO also stated that maybe LLANOS wanted to take the number ten,

"the captain's shirt, the large size" [heroin quantity]. LLANOS

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f

responded that she would need "half" [heroin quantity] for the

following day. LUCHO then stated, "Oh, alright, number five then".

LUCHO added that the T-shirts were "very pretty" [high quality

heroin]. LUCHO and LLANOS agreed to talk later in the day.

258. On August 13, 2002, at approximately 4:31 p.m., LUCHO

received a call on Target Phone IV from (773) 562-7316 and spoke

with LLANOS. LLANOS stated that she needed LUCHO to lend her 100

"pesitos" [heroin or money quantity]. LLANOS asked if LUCHO could

deliver "them" [heroin or money] to the girl that works with her.

LLANOS provided the address of the girl as 2952 "west of the same

street". LUCHO stated that he knew where this address was. LUCHO

stated that he could deliver the heroin or money in approximately

thirty minutes.

259. On August 13, 2002, at approximately 4:09 P.M.,

surveillance units in the area of 3005 W. Gunnison, the residence

of LUCHO. Surveillance units observed the Hispanic male driver (who

matched the known physical description of LUCHO), exit the vehicle

and enter the courtyard area of 3005 W. Gunnison. LUCHO had a

small bag thrown over his shoulder.

260. On August 13, 2002, at approximately 5:00 p.m.,

surveillance units observed LUCHO exit the immediate area of his

residence and enter a vehicle. Surveillance units observed LUCHO

retrieve a small silver plastic bag from the trunk area and place

it in the passenger area of this vehicle. LUCHO departed the area

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followed by surveillance units. At approximately 5:14 p.m.,

surveillance units observed LUCHO pull over in the area of 2952 W.

Montrose. LUCHO exited the vehicle with the same small bag as

observed earlier near his residence. Surveillance units observed

LUCHO enter "La Kayana" located at 2952 W. Montrose, which is the

wire remitter business owned/operated by Martha LLANOS. At

approximately 5:17 P.M., surveillance units observed LUCHO exit La

Kayana. Surveillance units observed LUCHO enter his vehicle and

move the vehicle several feet on Montrose. LUCHO exited the

vehicle and re-entered La Kayana. At approximately 5:22 P.M.,

surveillance units observed LUCHO re-enter the Sebring and depart

the area.

261. On August 14, 2002, at approximately 10:49 a.m., LUCHO

placed a call on Target Phone IV to JAMES VALENCIA. During this

conversation, LUCHO stated that he gave "one hundred (100)" [heroin

or money quantity] to "Pie Malo" (LLANOS).

262. On August 19, 2002, at approximately 8:23 p.m., LUCHO

placed a call from Target Phone IV to "Martica" (Martha LLANOS) at

(773) 562-7316. During this conversation, LUCHO asked if LLANOS

was going to be at her house. LLANOS stated that she would be home

soon. LUCHO stated that he had some "receipts" [amount of money]

for her. LLANOS stated that she would be home at 9:00 p.m.

263. On August 19, 2002, at approximately 9:03 p.m.,

surveillance units observed the Chrysler Sebring registered to

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LUCHO travel south on St. Louis and park in front of 4522 N. St

Louis, the residence of Martha LLANOS.

264. On August 19, 2002, at approximately 9:08 p.m., LUCHO

placed a call from Target Phone Iv to "Martica" (Martha LLANOS) at

(773) 562-7316. LUCHO asked if LLANOS was home yet and stated that

he was outside. LLANOS stated that she would be there in five (5)

minutes. Surveillance units observed LUCHO walk up the front

staircase of the residence at 4522 N. St. Louis while carrying a

small box. LUCHO knocked on the front window and then entered the

front door with the box in hand. At approximately 9:12 p.m.,

surveillance units observed LUCHO exit the residence with two

unidentified Hispanic males. The three individuals entered the

Chrysler and departed the area.

265. On August 20, 2002, at approximately 12:55 p.m., LUCHO

received a call on Target Phone IV from JAMES VALENCIA. During

this telephone call, LUCHO stated that he gave "Pie Malo" (LLANOS)

"twenty (20)" [quantity of money].

266. On September 1, 2002, at approximately 7:02 p.m., LUCHO

using Target Phone VI called KELLY JONES on Target Phone III.

LUCHO stated that "MARTICA" (MARTHA LLANOS) needed "four CD's"

[heroin or money quantity]. LUCHO asked how many CD's [heroin or

money quantity] JONES had, and stated that ~~MARTICA" needed at

least "one big one" [heroin or money quantity) that day, and

further stated that JONES should call "MARTICA" (LLANOS) JONES

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~ ~~

stated that he had "nine hundred" [heroin or money quantity].

267. On September 17, 2002, at approximately 4:36 P.M.,

surveillance units in the area of 2952 West Montrose observed JONES

arrive in the area. Surveillance units observed JONES walk into La

Kayana carrying a white plastic bag., It appeared the bag was a

grocery bag with something inside. At approximately 4:37 P.M.,

JONES left La Kayana store with the same plastic bag. It appeared

the bag contained an object. JONES then left the area and drove

east through an ally.

268. On September 22, 2002, at approximately 10:16 p.m., LUCHO

placed a call from Target Phone VII to Target Phone VIII. LUCHO

told KELLY JONES that "Monito" [JUAN LOZADA] wanted to see him

(JONES) and asked JONES to call "Monito". JONES then asked if

LUCHO wanted anything. LUCHO stated that he needed some "for

`Martica' [MARTHA LLANOS], who needs a whole CD [heroin quantity]".

JONES stated that he has "some" [heroin quantity] and that he could

stop by if LUCHO wants. JONES then stated that he has 1,300

[heroin quantity]. LUCHO stated that he wants "only 1,000 [heroin

quantity] for `Martica' [LLANOS] and 300 [heroin quantity] for

`Mono "' [JUAN LOZADA] JONES agreed to drop off for LUCHO the

following day at approximately 10:30 a.m.

269. On October 16, 2002, at approximately 1:07 p.m., KELLY

JONES using Target Phone VIII made a call to JAMES VALENCIA.

During this conversation, VALENCIA and JONES discussed which

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~—~ ~ ~ r-- -- ~, ~ ---- ~ — _- _ _ --- ~` -, - ~ — -- ~

L l _ _ i i ~ - -- ' ~ ~i l 1 ~ ~ ~ l L

l

cellular telephone number VALENCIA should give oust, in order for

others to contact VALENCIA when he comes to Chicago, Illinois.

JONES advised VALENCIA to give out "this one" (Target Phone VIII).

JONES further stated that "yeah, cause any problems I could throw

it away". VALENCIA also stated to JONES, "maybe we'll, we'll have

apartment over there". JONES advised VALENCIA that he had an

apartment and VALENCIA instructed JONES to "save, save for me".

VALENCIA told JONES to call New York Supplier in New York.

VALENCIA then stated that he (VALENCIA) would "be there in couple

days for the job". VALENCIA then asked JONES about the quality of

the heroin that JONES had taken delivery of recently. JONES stated

that "this one is solid like that but it's changing". JONES

further stated, "it's changing into powder, you know what I'm

saying"? JONES advised VALENCIA that he (JONES) 'gave to, to

MARTICA [LLANOS], yeah five and then I, I have the .rest, the three

seventy at home plus the fifty from before". VALE~TCIA told JONES

to give Individual D the "new one, not the old one."

VIBENCIO CONSUEGRA

270. On June 15, 2002, at approximately 2:42 p.m., VALENCIA

called KELLY JONES on Target Phone I. During this conversation,

JONES advised VALENCIA that he took care of CONSUEGRA with 200

[quantity of heroin] and that LUCHO wanted 300 [quantity of

heroin], one [heroin quantity] for NEGR.A [VELAZQUEZ] and two

[heroin quantity] for PIASA [MILENA PUPO].

1:
271. On June 23, 2002, at approximately 1:47 p.m., VALENCIA

called KELLY JONES on Target Phone II. During this conversation,

VALENICA instructed JONES to ask LUCHO to deliver "600" [heroin

quantity] for CONSUEGRA.

272. On June 23, 2002, at approximately 1:50 p.m., KELLY JONES

called CONSUEGRA on Target Phone II. During this conversation,

JONES informed CONSUEGRA that LUCHO has "600" [heroin quantity] for

him.

273. On June 27, 2002, at approximately 12:36 p.m., CONSUEGRA

called KELLY JONES on Target Phone II. CONSUEGRA asked JONES if he

had a "CD" [heroin quantity] and JONES stated no. CONSUEGR.A then

told JONES to "go to LUCHO, I need, the big man [CONSUEGRA`s

big/primary customer] is ready". CONSUEGRA told JONES to call "J"

[VALENCIA] or LUCHO because he (CONSUEGRA) needed 1,000 [heroin

quantity]. JONES stated that he would call everybody right now and

then he would call CONSUEGR.A back.

274. On July 8, 2002, at approximately 12:42 p.m., KELLY JONES

using Target Phone II called VALENCIA. JONES told VALENCIA that he

gave CONSUEGRA "9" [heroin quantity] and gave LUCHO the rest

[heroin quantity]. VALENCIA stated "yes, give to LUCHO, please".

275. On August 5, 2002, at approximately 1:52 p.m., VALENCIA

called KELLY JONES on Target Phone III. During this conversation,

JONES told VALENCIA that LUCHO had given CONSUEGRA something and

that his (CONSUEGRA's) friend had returned 500 [quantity of heroin]

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~ ~

to him (CONSUEGRA). VALENCIA told JONES that LUCHO was going to

take a vacation for two weeks, and JONES stated that he was ready

for anything, and that he had the stuff [heroin quantity] ready at

home. VALENCIA told JONES that LUCHO was going to take care of LA

NEGRA [VELAZQUEZ] today and that he (LUCHO) was going to "bring

something" [heroin quantity] for JONES to take to Individual G.

JONES also advised VALENCIA that he needed "something to do" [drugrelated activity]. VALENCIA asked JONES if Individual D had

brought him "money" and JONES replied that the store was closed and

the number was disconnected. JONES told VALENCIA that he (JONES)

had spoken with Individual D on Wednesday and that Individual D

told him (JONES) that he would pay him tomorrow but that he (JONES)

went to the store and it was closed. JONES also asked VALENCIA if

he needed someone to go anywhere and VALENCIA stated "no, I need

money" and instructed JONES to go see Individual G to see if he had

money.

276. On August 15, 2002, at approximately 5:16 p.m., LUCHO

received a call on Target Phone V from (773) 510-0537. This

telephone is subscribed to and utilized by Vibencio D. CONSUEGR.A

aka "CONSUEGRO". During this conversation, CONSUEGR.A stated that

he needed "three" [heroin quantity].

277. On August 15, 2002, at approximately 8:36 p.m., LUCHO

placed a call on Target Phone V to CONSUEGRA at (773) 510-0537.

During this conversation, LUCHO and CONSUEGRA agreed to meet at the

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~ ,

,~~

t._...- \

gas station at the intersection of Central Park and Diversey

Avenue. LUCHO stated that he had "four" [heroin quantity].

CONSUGEGRA asked how much and LUCHO answered "four hundred" [heroin

quantity]. CONSUEGRA then asked if LUCHO had a "whole one" [heroin

quantity]. LUCHO replied that he did have a "whole one" [heroin

quantity]. LUCHO and CONSUEGR.A agreed to meet approximately thirty

minutes later.

278. On August 15, 2002, at approximately 8:55 p.m.,

surveillance units observed LUCHO arrive by vehicle at the gas

station located at the intersection of Central Park Avenue and

Diversey Avenue. At approximately 9:01 p.m., LUCHO left the gas

station and traveled east on Diversey. At approximately 9:02 p.m.,

surveillance units observed CONSUEGRA arrive by vehicle at the gas

station and meet with LUCHO. CONSUEGR.A was observed standing at

the passenger side door of LUCHO's vehicle. Surveillance units

observed a hand-to-hand transaction between LUCHO and CONSUEGRA.

CONSUEGRA placed an object in his back pocket and walked back to

his vehicle. LUCHO then left the parking lot and drove east on

Diversey Avenue. At approximately 9:06 p.m., CONSUEGRA returned

to his vehicle and began looking around the street. At

approximately 9:07 p.m., surveillance units observed LUCHO walking

west on Diversey Avenue. LUCHO was carrying what appeared to be a

plastic grocery bag with an item inside. LUCHO walked to

i

CONSUEGRA's vehicle. Surveillance units then observed LUCHO

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walking east on Diversey Avenue without the plastic bag.

279. On August 16, 2002, at approximately 3:01 p.m., LUCHO

placed a call on Target Phone IV to CONSUEGR.A at (773) 510-0537.

During this conversation, CONSUEGRA told LUCHO that the CD's

[heroin quantity] were incomplete by "five (5)" [heroin quantity].

LUCHO then asked "fifty (50)?" [heroin quantity]. CONSUEGR.A

answered "No, five (5)" [heroin quantity]. LUCHO asked how much

the total was to which CONSUEGRA responded "nine nine five (995)"

[heroin quantity]. LUCHO then stated that if CONSUEGR.A needed more

CD's, he (LUCHO) had some.

280. On August 16, 2002, at approximately 5:32 p.m., LUCHO

placed a call on Target Phone IV to VALENCIA. During this

conversation, VALENCIA asked if LUCHO gave CONSUEGRA "two hundred

(200)" [heroin quantity]. LUCHO stated that he gave CONSUEGRA "a

complete one (1)" [heroin quantity]. LUCHO added it was "a

thousand (1,000) pesitos" [heroin quantity].

281. On September 12, 2002, at approximately 4:36 p.m., LUCHO

received a call from VIBENCIO CONSUEGR.A. LUCHO stated that he

wasn't ready yet, and that he was EL Llano restaurant. LUCHO and

CONSUEGRA agreed to meet at El Llano restaurant on Lincoln Avenue.

282. On September 12, 2002, at approximately 6:06 p.m.,

surveillance agents in the area of El Llano restaurant observed

LUCHO and CONSUEGRA exit the restaurant and walk south on Lincoln.

CONSUEGR.A and LUCHO stopped at a black Oldsmobile Bravada.

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t - l l i. ~~ ~ ~ I 1. 1 1 ._ - -. L ,

CONSUEGR.A appeared to be placing an object inside the vehicle

through the passenger door. CONSUEGRA then entered the vehicle.

283. On September 12, 2002 at approximately 6:26 p.m., LUCHO

using Target Phone VI called VALENCIA and stated "I picked sixty

[money quantity] up for you from 'Consu' [CONSUEGRAJ". VALENCIA

told LUCHO to put "50" [quantity of money] aside for "Mono" and to

take the "rest" [quantity of money) to "Nano" [Cosme CHACON].

284. At approximately 6:30 p.m., surveillance observed

CONSUEGRA parked across from the residence at 1921 Monticello in

Chicago, Illinois. Agents observed CONSUEGRA enter the residence

at 1921 Monticello carrying a white plastic bag and a small black

bag.

285. On October 16, 2002, at approximately 8:00 p.m., KELLY

JONES received a call on Target Phone I from JAMES VALENCIA.

VALENCIA advised JONES to "bring two hundred [quantity of heroin]

to, to CONSUEGR.A, please, right now". JONES stated that he would.

286. On October 17, 2002, at approximately 11:44 a.m., KELLY

JONES received a call on Target Phone VIII from JAMES VALENCIA.

VALENCIA asked JONES if he (JONES) had called CONSUEGRA the night

before. JONES advised VALENCIA that CONSUEGRA was "bitching and

talking shit on the phone". VALENCIA then told JONES "don't bring

him nothing [heroin]". JONES further advised VALENCIA that he

(JONES) had "passed" one hundred [quantity of heroin] to Individual

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~.i f~J ~ 1 ~l - 1 '_~ i !~. ~ ~-_J ~1 ~ ~ i. _ .t i .~J ~i 1 ~1 1

~~

Shantell Hill

287. During the wire interception investigation, SHANT~LL

HILL was intercepted on numerous occasions - on average

approximately twice a week - in which HILL discussed with JONES the

purchase of heroin by HILL from JONES. On var ous occasions, HILL

~r G ~ ~5~

mentions needing to obtain heroin f~m his customer. During a

meeting between THOMAS and law enforcement, THOMAS identified a

photograph of SHANTELL HILL. According to THOMAS, "SHANTELL" is a

black, male who purchases heroin from KELLY JONES and has done so

since approximately March 2001. On May 9, 2002, agents/officers met

with THOMAS. During this meeting, THOMAS stated that on April 30,

2002, he was in the vehicle of KELLY JONES and he (JONES) met a

male driving a motorcycle, on Narragansett, North of Diversey, in

Chicago. JONES parked his Navigator and approached the male and

gave him a bag. THOMAS did not see what was in the bag, but

believed it could have contained heroin, based on THOMAS's prior

experience with the organization. JONES then met SHANTELL HILL in

the same area, on Narragansett. JONES asked THOMAS to approach the

vehicle of HILL and obtain money from him. THOMAS received a

quantity of currency from HILL, that HILL reported to be $2,705.00.

THOMAS gave the currency to JONES. THOMAS stated that he believed

this money was payment for heroin, since HILL at one time used to

be a heroin customer of THOMAS.

288. On August 19, 2002, at 8:18 p.m., JONES received a call

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from Shantell HILL at (630) 670-2532 on Target Phone I. During

that conversation, HILL asked JONES "what was my tab, yo, about

ninteen"? (drug debt]. JONES responded "yeah". HILL then stated,

"yeah, they a11...I think I'm at about eighteen and a half". JONES

then said "all right".

a. On September 9, 2002, at approximately 7:30 p.m.,

JONES received a call on Target Phone I from SHANTELL HILL. HILL

discussed with JONES how much money HILL owed JONES in drug debts.

b. On September 16, 2002, at approximately 6:32 p.m.,

JONES received a call on Target Phone I from SHANTELL HILL. During

that call, JONES asked HILL how much HILL owed JONES [drug debt],

and HILL replied "thirteen-forty" [$1,340 in drug debt]. HILL

later asked JONES for "10" [heroin quantity].

289. On September 24, 2002, at 6:17 p.m., JONES made a call to

HILL at (630) 750-6571 on Target Phone I. During that

conversation, HILL advised JONES that he (HILL) needed "a twelve

piece". JONES and HILL then agree to meet between 7:30-8:00 p.m.

Surveillance team members followed HILL to 5406 W. Congress

Parkway. HILL was observed by surveillance entering the residence

at approximately 7:45 p.m. HILL returned to his vehicle at

approximately 8:14 p.m.

290. At 8:20 p.m., on September 24, 2002, JONES again called

HILL on Target Phone I. JONES and HILL agree to meet in the area

of Central Avenue and Washington Street, Chicago, in "ten minutes".

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'\

291. At approximately 8:27pm HILL traveled to Shell Gas

Station at Austin and Harrison in Chicago, Illinois. HILL parked

next to JONES at a gas pump. JONES was driving his black Lincoln

Navigator. HILL and JONES met by the driver door of the Navigator.

HILL left the area at approximately 8:29pm. Surveillance team

members followed HILL to the area of Fillmore and Harlem. In the

area of 7720 West Fillmore in Forest Park, officers conducted a

traffic stop at approximately 8:35 p.m. During a search of the

Chrysler van by the officers, approximately 13 grams of heroin were

recovered under some papers between the front seats. HILL turned

over approximately 3 grams of cannabis from his shoe to Officer

Watkins.

292. On September 26, 2002, at 6:49 p.m., JONES received a

call from HILL at (630) 750-6571 on Target Phone I. During that

call, HILL stated to JONES, "when I left you that Tuesday night",

"I got hit". JONES asked HILL what happened. HILL stated that

"motherfuckers stuck me up". JONES asked "who"? HILL continued to

describe that he thought that he was set up and that it was not

really the police who stopped him. HILL continued to state that he

did not see any badges, bullets or radios and that the vehicle the

men were driving did not have "green plates". JONES asked HILL why

he did not call JONES to tell him, HILL stated that he was

"puzzled" about what had happened. HILL also told JONES that the

men took "the twelve piece, and they was out".

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i ~.

~ `l

RICARDO ARNOLD aka "Ricky" and "Chino"

293. On June 22, 2002, surveillance was directed to the area

of Irving Park Road and Western Avenue. Information was

intercepted on the wire tap that Kelly JONES was meeting a subject

at the Amoco Gas station located at that intersection to deliver

heroin to the subject, "CHINO" (RICARDO ARNOLD) The surveillance

team observed JONES arrive in his black, Lincoln Navigator. The

surveillance identified three other individuals in the Navigator

with JONES. These subjects were identified as Marcus JONES, seated

in the front passenger seat, and two juveniles seated in the rear

seat (Kelly JONES' two children). Agents and officers observed

JONES exit the Navigator and stand just outside the open front

door. JONES was then seen, motioning as if he was putting

something is his front pants pocket. JONES then walked to the other

side of the gas station, where the view was obstructed, but

surveillance was able to see JONES meet with a male, black subject

wearing an orange shirt. The two subjects walked to a car parked

in the corner of the lot, the hood on the vehicle was up. JONES

was seen conversing with the subject and walk around the vehicle,

at one point out of the sight of the surveillance team to the trunk

of the vehicle. One agent was able to position himself to have a

view of the vehicle, and it was reported that the vehicle was a

silver/blue, Chevrolet, Lumina with Illinois registration 2267903.

This vehicle is registered to ARNOLD.

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~~ \

294. On September 1, 2002, at approximately 10:10 a.m., KELLY

JONES made a call on Target Phone III to RICARDO ARNOLD. During

this conversation, ARNOLD informed JONES that "I need twenty two

right now" [quantity of drugs]. JONES agreed and asked ARNOLD if

he wanted to "come grab it". ARNOLD agreed. JONES instructed

ARNOLD to "come over" and "come through the back". ARNOLD agreed.

295. On September 29, 2002, at approximately 10:48 p.m., KELLY

JONES received a telephone call on Target Phone I from RICARDO

ARNOLD. During this conversation, ARNOLD stated that his "man"

[drug customer] wanted "twenty-five" [quantity of heroin] tonight

and "fifty" [quantity of heroin) the following day. JONES informed

ARNOLD that he (JONES) only had "thirty" or "forty" [quantity of

heroin]. JONES advised ARNOLD that he should meet him (JONES)

later on that night and could pay him (JONES) the following day

[pay JONES for the heroin].

296. On September 30, 2002, at approximately 2:16 p.m., KELLY

JONES received a telephone call on Target Phone I from RICARDO

ARNOLD. During this conversation, ARNOLD informed JONES that he

(ARNOLD) needed "ten more" [quantity of heroin]. JONES suggested

they meet sometime between 3:00 p.m. and 4:00 p.m., and ARNOLD

agreed. JONES stated that he (JONES) would travel to ARNOLD's

residence.

297. On October 16, 2002, at approximately 1:00 p.m., KELLY

JONES received a call on Target Phone I from `CHINO" (RICARDO

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ARNOLD) at (773) 491-1352. During that conversation, JONES asked

ARNOLD, "what's up with your boy" [ARNOLD's drug customer]? JONES

further stated that he had "200" [quantity of heroin] and wanted to

see if ARNOLD wanted to "work" with it [distribute the heroin].

ARNOLD advised JONES that he (ARNOLD) was interested and would call

JONES back later.

298. On August 24, 2002, at approximately 1:22 P.M., JONES

received a call on Target Phone III from ARNOLD at (773) 617-9272.

During this conversation, ARNOLD ("Chino") stated that he had to

"shoot at some niggers that were trying to roll on him".

299. On August 30, 2002, at approximately 3:29 P.M., JONES

received a call on Target Phone I from ACEVEDO at (773) 206-0694.

During this conversation JONES and ACEVEDO talk about an

unidentified individual who sells rims for tires. JONES states

that at approximately two o'clock he [unidentified individual]

should be getting off work. JONES then states "I got to go see him

anyway, `cause his boy is getting me a strap [gun]". JONES

continued "yeah, for two fifty (250) [quantity of money] a three

eighty (380) [.380 caliber gun]". ACEVEDO then asked about the

"Glock" [type of handgun]. JONES responded that the "dude" already

sold it. JONES then stated that he should "grab this [.380] for

now and then grab a Glock later".

300. On October 21, 2002, at approximately 2:41 P.M., JONES

received a call on Target Phone I from ARNOLD at (773) 491-1352.

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rr ~

JONES made reference to an unidentified individual and said that he

"got some straps" [guns]. JONES continued that he (unidentified

individual) had a couple little things "like athirty-eight (38) or

a three eighty (380) and a twenty-two (22)" [different caliber

guns]. JONES later stated that he (unidentified individual) wants

"380" [quantity of money] for both guns or "a bill" [$100] for the

.22 caliber gun alone. JONES stated that he was going to "check

them out" and told ARNOLD "you never know". ARNOLD then stated

that he had a "hook up" on a "Desert Eagle" [type of handgun] but

that the individual selling it wanted seven hundred dollars for it.

MIGUEL SANCHEZ aka "Mikey"

301. On August 5, 2002, at approximately 2:08 p.m., KELLY

JONES using Target Phone I called "MIKEY" at telephone number (773)

680-9781. During this conversation, MIKEY told JONES that he would

probably "go pick up that other shit [heroin quantity] up from you

today" and advised JONES to give him (MIKEY) a call whenever he

(JONES) was ready, and JONES concurred.

302. On August 14, 2002, at 2:00 p.m., JONES received a call

from SANCHEZ at (773) 680-9781, on Target Phone I. SANCHEZ stated

to JONES "I need four times, bro". SANCHEZ then asked JONES ~~you

gonna have them with you"? JONES stated that he would. JONES then

asked SANCHEZ, "sure that you want them, right"? SANCHEZ replied

"yeah". Affiant believes that SANCHEZ was requesting to receive a

quantity of heroin from JONES.

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303. On August 14, 2002, at 2:35 p.m., JONES received a call

from SANCHEZ at (773) 680-9781, on Target Phone I. During that

conversation, JONES and SANCHEZ are making arrangements to meet in

the area of Cicero and Fullerton in Chicago, Illinois. JONES asked

SANCHEZ if he had "the money". SANCHEZ told JONES, "nah, I'm gonna

to flip it". It is understood by agents and officers that JONES

was asking SANCHEZ if he had the money to pay for the heroin. It

is also understood that when SANCHEZ said that he was going to

"flip it", he was referring to taking the heroin and selling it for

a profit and then paying JONES from the proceeds.

304. On August 21, 2002, at approximately 12:27 a.m., JONES

received a call from SANCHEZ on Target Phone I. During that

conversation, SANCHEZ stated "sorry to call you so late dog,...man,

I got...I got bad news, real bad". JONES asked SANCHEZ what had

happened. SANCHEZ stated, "I think we've been opened. Don't...don't

get all...over nothing, man. Just be careful, on the look out, I mean

they raided my sister-in-law, dog, they took my brother-in-law".

JONES asked SANCHEZ "why"? SANCHEZ stated "they found that shit,

bro". SANCHEZ continued to state, "he threw that shit out the

window and fucking 5-0 shook the tree and found a lot...I don't know

what they found". JONES asked SANCHEZ who the police were looking

for, SANCHEZ said that the police were looking for his sister-inlaw. JONES then stated "see, and you showed her where I stay at"

JONES stated "Mikey, man, you better handle this, bro". SANCHEZ

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stated that he would "handle it".

305. On September 1,,2002, at approximately 5:13 p.m., Kelly

JONES received a call on Target Phone I from "MIKEY". During this

conversation, MIKEY told JONES, "I got a little something for you

. ." [referring to money]. MIKEY further stated that his "guy is

coming from, from the, from the burbs" . MIKEY stated that whenever

JONES was ready he (MIKEY) would "give you some money and you know

get them four [quantity of drugs] for him [the individual from the

"burbs"]". JONES agreed and advised MIKEY to get the money first

and MIKEY agreed. JONES informed MIKEY that he (JONES) would be

available to meet after 7:00 p.m.

306. On October- 16, 2002, at approximately 5:39 p.m., KELLY

JONES received a call on Target Phone I from "MIKEY" (MIGUEL

SANCHEZ) at (773) 680-9781. During this call, SANCHEZ told JONES

that he (SANCHEZ) "needs another bag, another twenty-five, two,

bro" [quantity of heroin]. SANCHEZ then stated to JONES, "he

[SANCHEZ' drug customer] got this for right now then ah, he

[SANCHEZ' drug customer] wanna go turn this around right quick and

get this other twenty-five [quantity of heroin]". JONES then

stated "all right, well where are you at"?

307. On October 16, 2002, at approximately 7:55 p.m., KELLY

JONES received another call from SANCHEZ on Target Phone I. During

that call, JONES asked SANCHEZ if "you got the loot already" [money

to buy heroin from JONES]? SANCHEZ replied that "yeah, I got the

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a_ , c ~-

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loot for this twenty-five [quantity of heroin]."

MILENA P. PUPO aka "Paisa" and "Paisita"

308. On July 16, 2002, at approximately 7:40 p.m., LUCHO using

Target Phone V called KELLY JONES on Target Phone III. LUCHO

stated that "LA PIASITA" [PUPO] would contact JONES regarding the

"1" [heroin quantity]. JONES agreed and stated that he would stop

by tomorrow with the "papers" [money]. LUCHO agreed and provided

the telephone number 551-5017 for "PIASITA" [PUPO].

309. On July 17, 2002, at approximately 4:44 p.m., LUCHO using

Target Phone IV called KELLY JONES on Target Phone III. JONES

asked what happened with "PIASA" [PUPO]. LUCHO asked JONES if

JONES had talked to her. JONES stated that he did not and that

"JOTA" [VALENCIA] told him (JONES) when she (PIASA) comes up with

the money [for the heroin], then JONES can give her "that"

[heroin].' 4 JONES continued "if there's no money [paid up front],

there's nothing [no heroin given to PIASA]". JONES stated that he

needed the money for tomorrow48 but added that he had some right

47As discussed earlier, on or about July 17, 2002, at

approximately 3:32 a.m., DAVID ACEVEDO and ANGEL MELENDEZ, JR.

returned from their drug-related trip to New York to pick up

heroin. Surveillance agents/officers observed KELLY JONES' white

Nissan Altima parked in front of KELLY JONES' residence at 1433

W. Warner, Chicago, Illinois. Surveillance observed DAVID

ACEVEDO walking to the residence carrying a bag over his shoulder

and ANGEL MELENDEZ, JR. following ACEVEDO into the residence. At

approximately 3:58 a.m., surveillance observed ACEVEDO, MELENDEZ,

and MARCUS JONES exiting the residence and leaving the area.

4aLater on that same day, at approximately 1:12 p.m., KELLY

JONES using Target Phone III called VALENCIA, in which they

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~_ C I. l S._ ,. c 1. ' c l.. t.. ~ ~

now. JONES stated that he had "1500" [quantity of heroin] and

asked LUCHO if he needed "some" [heroin]. LUCHO stated that he did

not have anything at present and that he was going to talk to "him"

[VALENCIA]. LUCHO also stated "let's wait for `PIASITA' [PUPO] to

pay", and JONES agreed.

310. On August 4, 2002, at approximately 6:39 p.m., KELLY

JONES using Target Phone 2II called LUCHO at Target Phone IV.

During this conversation, JONES asked LUCHO what was going on with

"PIASITA" [PUPO] and LUCHO told JONES that he (LUCHO) had given one

(1) [heroin quantity] to her (PUPO) on Friday [possibly August 2,

2002] and that she (PUPO) had passed [given] him (LUCHO) some

receipts [money quantity]. LUCHO also told JONES that he needed to

speak with CONSUEGRA to find out how much he (CONSUEGRA) needed [of

heroin quantity].

311. On June 15, 2002, at approximately 2:42 p.m., VALENCIA

called KELLY JONES on Target Phone I. During this conversation,

JONES advised VALENCIA that he took care of CONSUEGRA with 200

[quantity of heroin] and that LUCHO wanted 300 [quantity of

heroin], one [heroin quantity] for NEGR.A [VELAZQUEZ] and two

[heroin quantity] for PIASA [PUPO].

discuss sending the couriers back to New York for another pick up

of heroin the next day (July 18). VALENCIA told KELLY JONES that

he (VALENCIA) would call LUCHO and LA PIASA [PUPO] regarding

giving JONES money to bring to New York [via the drug couriers

the next day]. Subsequent intercepted calls between KELLY JONES

and ANGEL MELENDEZ, JR. and DANIEL MALDONADO on July 17 and 18,

2002, indicate that another trip was being planned for July 18.

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~^. r-~~, ~--~

312. On August 15, 2002, at approximately 2:45 p.m., LUCHO

received an incoming call on Target Phone IV from (773) 610-2229.

LUCHO spoke with an individual he identified as "PAISA" (PUPO).

PUPO asked LUCHO where he was, to which he responded that he was on

Montrose sending some mail. PUPO asked if LUCHO would meet her.

LUCHO asked for what and PUPO responded "It's good news for you".

LUCHO and PUPO agreed to meet at an unidentified gas station in the

vicinity of Touhy Avenue. PUPO stated that she needed to meet LUCHO

so "we can check the accounts and everything else". LUCHO stated

that he would meet PUPO approximately forty-five minutes later.

Based on subsequent surveillance and an intercepted conversation

between LUCHO and VALENCIA described below, Affiant believes PUPO

wanted to meet with LUCHO to give him $11,860 in drug proceeds.

313. On August 15, 2002, at approximately 3:00 p.m.,

.surveillance units drove to the vicinity of the United States Post

Office located at 2011 W. Montrose. Surveillance units observed a

vehicle known to be utilized by LUCHO parked at the corner of West

Montrose and Damen Avenue. LUCHO was later observed entering this

vehicle and departing the area. Surveillance units continued to

follow LUCHO and observed him park. his vehicle near the

intersection of North Coyle and West Campbell. At approximately

3:45 p.m., surveillance units observed LUCHO exit his vehicle and

enter the passenger side of a vehicle occupied by an individual

later identified as PUPO. Surveillance units observed PUPO exit

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her vehicle and open the trunk. PUPO then reentered her vehicle.

At approximately 3:57 p.m., LUCHO exited PUPO's vehicle, reentered

his vehicle, and departed the area. PUPO also departed the area in

her vehicle.

314. On August 15, 2002, at approximately 4:39 p.m., LUCHO

received a call on Target Phone IV from James VALENCIA from an

unidentified telephone number. During this conversation, LUCHO

stated that "Paisa" (PUPO) called him (LUCHO) and gave him "eleven

thousand eight sixty" (11,860) [currency].

315. On September 1, 2002, at approximately 2:03 p.m., KELLY

JONES received a call on Target Phone III from MILENA PUPO. During

this conversation, JONES asked PUPO "what are you looking for"?

PUPO informed JONES "not much, maybe like five hundred dollars"

[quantity of drugs].

316. On September 1, 2002, at approximately 2:04 p.m., KELLY

JONES received a call on Target Phone III from PUPO. During this

conversation, JONES asked PUPO, "when do you need it"? PUPO stated

"tonight". JONES stated that "we could probably do this tonight.

That would be no problem". PUPO asked JONES, "do you know what's

J's [JAMES VALENCIA] number? I need to talk to him". JONES told

PUPO, "439-1876".

317. On September 15, 2002, at approximately 9:56 P.M., LUCHO

received a call on Target Phone VI from an unidentified telephone

number, and spoke with JAMES VALENCIA. VALENCIA stated that was

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r-~..~ f--~_~ --~ '~-1 rte'---, 

r'_

"here [in Colombia] with 'Paisita' [MILENA PUPO]". PUPO could be

heard in the background stating "I gave him (LUCHO) the twelve(12),

eight(8), sixty(60) [quantity of money]". Affiant believes PUPO

traveled to Colombia to meet with VALENCIA in order to discuss

discrepancies related to her payment of money for heroin quantities

received.

318. On September 15, 2002, at approximately 9:59 P.M., LUCHO

placed a call from Target Phone VI to 011573104216075, an

international number, and spoke with PUPO. PUPO stated that there

were "2 pesitas" [quantity of money] that she gave LUCHO that she

never "wrote down". PUPO asked if LUCHO remembered the time they

met on Touhy and Western Avenues when PUPO told LUCHO there were

"3,800" [quantity of money] and another amount in another bag.

PUPO stated that she didn't write it down at the time and asked if

LUCHO remembered how much it was. LUCHO responded it was "three(3)

and seven(7)" [quantity of money] and "like six(6) something or

seven(7)" [quantity of money]. LUCHO stated that he didn't have

the "receipts" [transaction records] anymore that they were "stored

in another car". PUPO continued that there was another time that

she did not have written down and that she remembered it was

"eleven(11), eight(8), sixty(60)" [quantity of money]. PUPO also

mentioned that "Luis" [RIVERA] gave LUCHO "15" [quantity of money].

PUPO asked if LUCHO had "gone out with Luis" or "given him

anything" [delivered heroin to RIVERA]. LUCHO stated that he had

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~' ~`

not. PUPO asked if LUCHO gave RIVERA "100 pesos" [heroin

quantity]. LUCHO stated that "Kelly" [JONES] gave him "that" but

that RIVER.A was going to give it back because JONES took two days

to deliver it and then the "client" [customer of RIVERA] did not

want it. PUPO asked ~~besides the `26' [quantity of money] and the

`18' [quantity of money], has he (RIVERA) given you (LUCHO)

anything else". LUCHO stated that the last thing "he" [RIVERA]

gave him was "18" [quantity of money]. LUCHO continued "he

[RIVERA] told me there were `18', I counted the money separately

and there were '17' [quantity of money]".

LUIS E. RIVERA aka "Tito"

319. On September 11, 2002, at approximately 10:19 a.m., LUCHO

placed a call on Target Phone VI to JAMES VALENCIA. LUCHO stated

that he spoke with "Paisa's husband" [Luis RIVERA] yesterday, but

he didn't give me that money [narcotics-related debt]". LUCHO

stated that he was going to RIVERA's office at twelve (12:00).

320. On September 11, 2002, at approximately 12:15 p.m.,

surveillance units in the area of The House of Gift Baskets and

Mini Mart, located at 3827 N. Lincoln, observed Luis RIVERA arrive

at the store. RIVERA appeared to be bringing supplies into the

store from a Grey in color Chevrolet Blazer.

321. On September 11, 2002, at approximately 12:16 p.m., KELLY

JONES placed a call on Target Phone 22I to LUCHO. LUCHO asked if

JONES had "something" [heroin quantity]. JONES stated that he had

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~_ i • ~ 1 i _ t ~ ~ ~ ~ t

"1,500" [heroin quantity]. LUCHO then stated that he was going to

talk to "Paisita" [MILENA PUPO] to see if he (LUCHO) could pass at

least "1,000" [heroin quantity] to her. LUCHO continued that if

"Paisita" [Pupo] gives him the money [drug debt owed], "then we'll

give her the ." [deliver a quantity of heroin].

322. On September 11, 2002, at approximately 12:50 p.m.,

surveillance units observed LUCHO arrive in the vicinity of 3727 N.

Lincoln Ave., Chicago, IL. LUCHO parked the Gold Sebring in a

parking lot at the intersection of Berenice and Lincoln Avenue.

LUCHO then proceeded to walk over across the street to The House of

Gift Baskets and Mini Mart. LUCHO then entered the store. According

to surveillance agents, LUCHO and RIVER.A were believed to be the

only individuals inside the store. At approximately 12:55 p.m.,

LUCHO exited the store carrying a small black bag in his hand and

departed the area.

323. On September 11, 2002, at approximately 2:56 p.m., KELLY

JONES using Target Phone III called LUCHO. LUCHO told JONES that

he needed JONES to give "a check of one thousand (1,000) dollars"

[heroin quantity] to "Paisita" [MILENA PUPO] JONES asked if he

should give it to LUCHO or directly to "them" [PUPO and Luis

RIVER.A] LUCHO stated that JONES could give it to him (LUCHO) or

directly to them [PUPO and LUIS RIVER.A] . LUCHO told JONES that

"they" [PUPO and RIVER.A] would not get "anything" [heroin quantity]

until they gave him "the money" [paid their drug debt]. LUCHO

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stated that he was going to meet "them" [PUPO and/or RIVERA]

between 3:00 and 3:30 P.M.

324. On September 11, 2002 at approximately 5:05 p.m., KELLY

JONES using Target Phone III called LUCHO. LUCHO stated that "he

[RIVER.A] already gave me the receipts".

326. On September 13, 2002, at approximately 10:19 a.m., LUCHO

received a call on Target Phone VI from Luis RIVER.A. LUCHO stated

that he "counted that personally" [the money that LUCHO picked-up

from RIVERA] and that "it wasn't eighteen (18) [quantity of money],

there were seventeen (17) [quantity of money]".

327. On September 14, 2002, at approximately 2:44 p.m., LUCHO

received a call on Target Phone VI from JONES. LUCHO told JONES

that "Paisa's husband" (RIVERA) is going to return the check for

"100" [heroin quantity] because he lost the customer and couldn't

sell it".

328. On September 23, 2002, at approximately 2:48 p.m., LUCHO

received a call on Target Phone VI from (773) 677-6119. LUCHO

spoke with LUIS RIVERA and told him that he (LUCHO) talked to

"Jotita" (VALENCIA), who said that "until you (RIVERA) get things

going, you cannot go out to breakfast [until RIVERA pays his debts,

he would not receive any more heroin]". RIVERA stated that he had

another "seven (7) pesitos" [quantity of money] if LUCHO could come

by and get it.

329. On September 29, 2002, at approximately 5:22 p.m., LUCHO

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received a call on Target Phone VI from (773) 677-6119, and spoke

with LUIS RIVERA. RIVERA asked LUCHO if they could meet that

night. LUCHO stated that he could not because the "boys just got

here" [heroin courier arrived in Chicago]. LUCHO asked RIVERA how

much [heroin quantity] he needed. RIVERA stated that he needed

"fifteen" [heroin quantity].

330. On September 29, 2002, at approximately 3:15 P.M., LUCHO

received a call on Target Phone VI from Luis RIVER.A at (773) 677-

6119. RIVERA asked if LUCHO was coming to see him that night.

LUCHO said he could not because the "muchachitos" [couriers] just

arrived. LUCHO asked how much RIVER.A needed. RIVER.A stated "15"

[heroin quantity].

331. On October 2, 2002, at approximately 4:24 P.M., LUCHO

received a call on Target Phone v2 from RIVER.A at (773) 551-5017.

RIVERA asked LUCHO for "200 pesos" [heroin quantity] that he needed

for "the rent". LUCHO stated that his "calculator" [possibly a

scale] didn't work and that he needed to buy a new one. RIVERA

said that he was at "the store" [The House of Gift Baskets and Mini

Mart, located at 3827 N. Lincoln Avenue or DC Communications,

located at 7213 N. Western Avenue] if LUGHO wanted to meet. LUCHO

stated that he was going to buy the "calculator" and then "come by

there" [meet at RIVERA's store].

332. On October 4, 2002, at approximately 9:41 A.M., LUCHO

received a call on Target Phone VI from RIVERA at (773) 551-5017.

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/ ~~

LUCHO stated that some "T-shirts" [heroin quantity] had arrived.

LUCHO added that they arrived "wrinkled" [not ready for

distribution]. RIVERA stated that he thought he could receive them

"just like that". RIVERA stated that he would "call first and I'll

call you back" [RIVERA needed to call the customer to verify that

he could deliver the heroin quantity as is]. LUCHO asked how many

"T-shirts". RIVER.A stated "3" [heroin quantity].

333. On October 4, 2002, at approximately 6:29 P.M., LUCHO

received a call on Target Phone VI from RIVER.A at (773) 551-5017.

LUCHO stated that he was "ironing clothes" and that he didn't think

he could meet RIVER.A that night. LUCHO stated that he would "lend"

RIVERA "the five CD's" [heroin quantity]. RIVERA asked if LUCHO

could "lend" him "one dollar" [heroin quantity]. LUCHO stated that

he would talk with his "father" [VALENCIA].

334. On October 5, 2002, at approximately 10:14 A.M., LUCHO

placed a call from Target Phone VI and spoke with VALENCIA. LUCHO

stated that "Paisa's husband" [RIVERA] wanted a "full CD" [heroin

quantity]. VALENCIA asked "for money or what" to which LUCHO

responded that RIVERA may have "a few receipts" [quantity of

money]. VALENCIA the stated "Okay then, but tell him to behave,

we're giving it to him but to behave .".

335. On October 5, 2002, at approximately 3:17 P.M., LUCHO

received a call on Target Phone VI from RIVERA at (773) 551-5017.

RIVERA asked LUCHO not to forget to "separate the food" [package

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! ~

the heroin a certain way]. RIVERA told LUCHO to "separate the five

(5) songs and the rest of it in small ones of one hundreds

~T[7AN LOZADA aka "Mono", "Monito" and "Pablito"

340. On August 19, 2002, at approximately 12:23 p.m., LUCHO

received a call on Target Phone IV from Individual M. During this

conversation, LUCHO and Individual M agreed to meet at a car wash

near Magnum [Magnum Insurance]. Individual M agreed to call LUCHO

at approximately 2:30 p.m. Individual M asked LUCHO to bring one

hundred (100) "pesitos" [heroin quantity] for him. Individual M

then passed the phone to an individual believed to be JUAN LOZADA.

LOZADA and LUCHO then began a conversation. LUCHO stated that he

could meet at approximately 3:00 p.m. LOZADA stated that

Individual M needed one hundred (100) (heroin quantity] but he

(LOZADA) needed twenty-five (25) "pesitos" [heroin quantity].

LUCHO agreed and asked if it was twenty-five (25) "little ones"

[heroin quantity]. LOZADA said that it was and asked LUCHO to keep

them separated if he could.

341. On August 19, 2002, at approximately 3:21 p.m.,

surveillance units in the area of the 4300 block of North Western

Avenue observed LUCHO driving southbound on Western in the

previously identified Chrysler Sebring. LUCHO proceeded to park in

the rear of the Magnum Insurance company building.

342. On August 19, 2002, at approximately 3:24 p.m., LUCHO

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l i _ ~ '~ 4 ~ i_ _ it ' ~ l _ V

i

placed a call from Target Phone IV to (773) 793-9169. LUCHO spoke

with Individual M, stated that he was in the alley by the car wash,

and asked where Individual M was. Individual M stated that he was

across the street from the insurance place. LUCHO stated that they

should meet at another location. Individual M agreed and said that

he would follow LUCHO.

343. On August 19, 2002, at approximately 3:22 p.m.,

surveillance units observed LUCHO walking Eastbound on Cullom from

Western carrying a small plastic bag in his hand. Surveillance

units also observed a silver colored Mercedes Benz in the immediate

area of LUCHO. Surveillance units observed an unidentified male

exit the passenger seat of the Mercedes. Both LUCHO and the

unidentified male walked Eastbound on Collum. At approximately

3:23 p.m., surveillance units observed the plastic bag that LUCHO

was carrying being given to the unidentified male. This individual

then returned to the passenger side of the Mercedes Benz and

entered the vehicle.

344. On August 20, 2002, at approximately 3:01 p.m., LUCHO

received a call on Target Phone IV from (773) 983-4116. LUCHO had

a conversation with an individual known as "Mono" or "Monito"

(believed to be Juan Pablo LOZADA). LOZADA stated that he had the

receipt for "ten (10), the money order" [quantity of drug money].

LUCHO and LOZADA agreed to meet at approximately 5:00 p.m.

345. On August 20, 2002, at approximately 6:29 p.m., LUCHO

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L L. _. i ~ ~ ~i ~. ~.. l _ ~ i i 1 _ ~ !.

i

received a call on Target Phone IV from LOZADA at (773) 983-4116.

LOZADA stated that he was at the Wendy's near Addison. LUCHO

stated that he would arrive in ten (10) minutes.

346. On August 20, 2002, at approximately 6:51 p.m., LUCHO

placed a call on Target Phone IV to LOZADA at (773) 983-4116.

LOZADA stated that he was at 3626 N. Western.

347. On August 20, 2002, at approximately 6:53 p.m.,

surveillance units observed a Chrysler Sebring previously utilized

by LUCHO parked next to a black Nissan Altima in the Wendy's

parking lot on the 3600 block of North Western Avenue. An

unidentified male was observed standing between the two vehicles

and appeared to be speaking with the driver of the Sebring (LUCHO).

Shortly thereafter, the unidentified male entered the Nissan Altima

and both vehicles departed the area. At approximately 7:50 p.m.,

Chicago Police Department personnel initiated a traffic stop of the

vehicle for an observed traffic violation. The driver of the

Nissan Altima, who was earlier observed meeting .with LUCHO, was

identified as Juan P. LOZADA.

348. On September 17, 2002, at approximately 12:22 P.M., LUCHO

received a call on Target Phone VII from LOZADA. LOZADA and LUCHO

agreed to meet later in the day to compare LOZADA's "account"

[narcotics-related ledger]. LOZADA wanted to meet so that he could

"square things away with him [VALENCIA] because he's calling me".

349. On September 17, 2002, at approximately 5:56 P.M., LUCHO

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received a call on Target Phone VII from LOZADA. LUCHO stated that

he was on his way to "Llano" [E1 Llano restaurant]. LUCHO stated

that he had "the little notes" [narcotics-related ledger]. LOZADA

agreed to meet LUCHO.

350. On September 17, 2002, at approximately 6:20 P.M.,

surveillance units in the area of E1 Llano restaurant observed

LUCHO's vehicle in the area. At approximately 6:45 P.M., LUCHO was

observed leaving the restaurant. At approximately 6:46 P.M.,

surveillance units observed LOZADA walk to and enter a black Nissan

Altima bearing Illinois license plate number 3936333 and depart the

area.

351. On September 17, 2002, at approximately 6:54 P.M., LUCHO

received a call on Target Phone VII from LOZADA. LOZADA stated

that he was lent "100 dollars" [heroin quantity] and that "it's

fucking stuck together". LOZADA further stated that "it's a mess

and I need to iron it" [heroin quantity is not ready for

distribution]. LUCHO stated "ironing 100 pesos is a hard thing to

do" [preparing that quantity of heroin for distribution is

difficult].

352. On September 24, 2002, at approximately 1:14 p.m., LUCHO

received a call on Target Phone VI from (773) 425-0493. LUCHO

spoke with "Mono" (Juan P. LOZADA) and told him that he (LUCHO) had

"five (5) pesitos" [quantity of heroin] for him. LUCHO said that

JONES stopped by the night before. LOZADA said that he already met

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with JONES and that he got "some" [quantity of heroin] from JONES.

LUCHO explained to LOZADA that JONES gave him (LUCHO) "one (1) of

the one, three (1.3)" [heroin quantity] that he asked JONES for.

LOZADA states that he told JONES to let LUCHO know about the

"things" [heroin quantities] that he (LOZADA) got from JONES.

SANDRA P. VELAZQUEZ aka "La Negra" and `~Negrita"

353. As discussed earlier, on June 15, 2002, at approximately

2:42 p.m., VALENCIA called KELLY JONES on Target Phone I. During

this conversation, JONES advised VALENCIA that he took care of

CONSUEGRA with 200 [quantity of heroin] and that LUCHO wanted 300

[quantity of heroin], one [heroin quantity] for NEGRA [VELAZQUEZ]

and two [heroin quantity] for PIASA [PUPO].

354. On September 2, 2002, at approximately 9:33 A.M., LUCHO

received a call on Target Phone VII from "Negrita" (Sandra P.

VELASQUEZ). LUCHO stated that he had some "clothes" [heroin

quantity] for her. VELAZQUEZ asked where they could meet. LUCHO

and VELAZQUEZ agreed to meet at approximately 12:00 P.M. "by the

lady, the Puerto Rican lady" [TORRES].

355. On September 2, 2002, at approximately 10:45 A.M.,

surveillance was set up in the vicinity of 4715 W. McLean in

Chicago. Surveillance units observed LUCHO's vehicle parked in the

alley beside the residence. At approximately 11:50 A.M.,

surveillance units observed a silver Toyota truck bearing Illinois

license plate 3455589 arrive at 4715 W. McLean. VELAZQUEZ walked

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to the side alley entrance to 4715 W. McLean and appeared to be

talking to someone at the door. VELAZQUEZ then entered the 4715 W.

McLean.

356. On October 2, 2002, at approximately 11:52 A.M., LUCHO

placed a call from Target Phone VI and spoke with JAMES VALENCIA.

LUCHO stated that he spoke with "Negrita" [VELAZQUEZ] and was going

to meet her over "here" [4715 W. McLean] at 12:00 P.M.

357. On October 2, 2002, at approximately 12:00 P.M., LUCHO

exited the side entrance and he walked to the back of his vehicle.

LUCHO entered the trunk area and removed a bag. LUCHO walked to the

driver's side and placed the bag in the car. LUCHO began examining

his vehicle. LUCHO opened the hood of the car and appeared to be

looking around the engine compartment. At approximately 12:05

P.M., LUCHO closed the hood of the car. LUCHO walked and removed

the bag from the driver's side of the car and re-entered the side

entrance to 4715 W. McLean. At approximately 12:25 P.M., LUCHO

exited the residence and walked to the front of 4715 W. McLean to

the silver Toyota. LUCHO entered the driver's side of the Toyota.

Surveillance observed LUCHO remove a plastic bag from the Toyota

4x4. At that point, LUCHO re-entered the residence. At

approximately 12:28 P.M., LUCHO exited the residence and placed

something in his trunk. LUCHO re-entered the residence.

358. On October 2, 2002, at approximately 12:34 P.M., LUCHO

placed a call from Target Phone VI and spoke with VALENCIA. LUCHO

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stated that he talked with "Negrita" [VELAZQUEZ] VALENCIA asked

what she said. LUCHO responded "84 receipts" [quantity of money].

VALENCIA told LUCHO to give "50" [quantity of money] to "Comadre"

[HERNANDEZ].

359. On October 2, 2002, at approximately 12:43 P.M.,

VELAZQUEZ exited the residence carrying a plastic bag, which

appeared to be the same style of bag LUCHO had earlier removed from

the Toyota. Shortly thereafter, VELAZQUEZ entered the Toyota and

departed the area.

COSME CHACON aka "Memo" and "Nano" and VIVIANA HERNANDEZ

360. On September 12, 2002 at approximately 6:26 P.M., LUCHO

placed a call from Target Phone VI to JAMES VALENCIA at

011573104216075. LUCHO stated "I picked 60 [money quantity] up for

you from `Consu' [CONSUEGRA]". VALENCIA told LUCHO to put "50"

[quantity of money] aside for "Mono" and to take the "rest"

[quantity of money] to "Nano" [CHACON].

361. On September 12, 2002, at approximately 6:46 P.M., LUCHO

placed a call from Target Phone VI to JAMES VALENCIA at

011573104216075. LUCHO stated that he was going to give "40"

[money quantity] to "Nanito" [CHACON].

362. On September 12, 2002, at approximately 7:11 P.M., LUCHO

placed a ca11 from Target Phone VI to (773) 851-3021. LUCHO

reached the voicemail message for this phone, which stated "You

have reached Cosme, please leave your message at the tone". LUCHO

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stated "I have the receipts [quantity of money] here in your

office, but I'll have to come back because the girl who always

opens the office for me is not here".

363. On September 12, 2002, at approximately 7:13 P.M., LUCHO

placed a call from Target Phone VI to VALENCIA. LUCHO asked

VALENCIA if he (VALENCIA) spoke with "Cosme" [CHACON] or "comadre"

[Viviana HERNANDEZ] LUCHO stated that he went to the "office"

[Covitel wire remitter] and the "other" receptionist was there,

"the new one". LUCHO continued that she doesn't have the keys to

the office, "otherwise I would have been able to lock it [quantity

of money] up in the office". VALENCIA stated that he would call

"her" [HERNANDEZ] and let her know that LUCHO was at the office.

LUCHO stated that he had been trying to call CHACON but only

reached the voicemail. VALENCIA stated that "Cosme" [CHACON] is

"here" [in Colombia] and that he would tell "her" [HERNANDEZ] that

LUCHO was at the office. LUCHO stated that he would wait at the

office.

364. On September 12, 2002, at approximately 8:19 P.M., LUCHO

placed a call from Target Phone VI to VALENCIA. LUCHO stated that

he "dropped-off the 40" [delivered a quantity of money] for

VALENCIA and that "she" [HERNANDEZ] was going to "check that it's

all there" [verify the amount of money]. LUCHO continued that when

"she" [HERNANDEZ] counts the "money" the following day, "she"

[HERNANDEZ] would tell LUCHO how much is missing because LUCHO

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didn't have time to count the money.

365. On October 5, 2002, at approximately 1:09 A.M., JONES

received a call on Target Phone I from an unidentified number and

spoke with JAMES VALENCIA. JONES stated that he was on his way

home [from Detroit]. VALENCIA told JONES to see "Nano" [CHACONE]

the next day and asked JONES how much he had. JONES stated "66"

[quantity of money]. VALENCIA then told JONES to bring "16" to

"Nano" [CHACONEJ.

366. On October 5, 2002, at approximately 1:27 P.M., JONES

placed a call on Target Phone I to DANIEL MALDONADO and DAVID

ACEVEDO at (773) 895-1206. JONES told MALDONADO that he was

"heading out south right now by the laundromat [Covitel wire

remitter business]." JONES stated that he was going to "handle

some business".

367. On October 5, 2002, at approximately 1:45 P.M.,

surveillance units observed KELLY JONES arrive at COVITEL, a wire

remitter business located at 1842 W. Blue Island, Chicago,

Illinois. Agents observed JONES exit the Navigator and remove a

black bag from the back seat of the vehicle. JONES entered COVITEL

only to quickly exit and return to the Navigator. JONES departed

the area in the Navigator. At approximately 1:52 P.M., agents

observed the Navigator return to COVITEL and JONES exit the vehicle

with the black bag. Due to traffic, Agents were unable to maintain

surveillance of JONES.

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368. On October 5, 2002, at approximately 2:01 P.M., JONES

placed a call on Target Phone I to MORCIGLIO at (847) 530-0014.

JONES stated that he was waiting and "this lady" [HERNANDEZ] would

be coming in twenty minutes. JONES stated that he had a "fifty

pack" [quantity of money] with him. JONES stated that he had to

wait twenty minutes and added "I know this bitch by, all the way by

her house, that's like 95t'' and Harlem". JONES later added that he

"got all this loot, sixty-four stacks out here [quantity of

money]."

369. On October 5, 2002, at approximately 2:20 P.M., agents

observed JONES arrive at COVITEL and park just southwest of the

business on the West side of Blue Island. JONES did not

immediately exit the vehicle. At approximately 2:40 P.M., agents

observed a White Ford Navigator, Bearing Illinois License Plate

3079420, park next to the Lincoln Navigator. Two females exited

the vehicle. One of the females was identified as Viviana

HERNANDEZ. JONES exited the Navigator with the black bag and

entered COVITEL with HERNANDEZ. At approximately 3:00 P.M., JONES

exited COVITEL carrying the previously observed black bag. JONES

entered the Navigator and departed the area.

370. The premises to be searched is the residence of KELLY

JONES located at 1433 W. Warner, Unit #2, Chicago, Illinois.

According to COMED records, the utility subscriber to this address

is Individual B, who based on surveillance and intercepted

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telephone calls is the live-in girlfriend of JONES. On multiple

occasions during the investigation, surveillance agents have

observed JONES enter the door directly beneath the number "1433."

NATHAN THOMAS had informed Customs during the period of his

cooperation that entrance to JONES' residence could be gained by

entering the front door of the building and then entering the door

on the immediate left (east-inner side), and going up the stairway.

This information is consistent with surveillance agents

observations during this investigation, that JONES enters the front

main door, and then turns left. During an intercepted call over

Target Phone I on October 29, 2002 at approximately 11:01 a.m.,

KELLY JONES told DANIEL MALDONADO that JONES was at the "lab" and

that there was some kind of emergency. JONES said that "dude

[VALENCIA] came in with all these problems... all these people are

returning the stuff....so we've got a bunch of soldiers, so it

shouldn't take long." During the morning of October 29, 2002,

surveillance agents observed VALENCIA, JONES, JIRON, MORCIGLIO,

ROLDAN, MALDANDO arrive at various times at JONES's residence at

1433 W.Warner.

371. Based on my experience and the experience of other

agents, drug traffickers commonly keep books, records, receipts,

notes, ledgers, airline tickets, money orders, and other papers

relating to the transportation, purchase, packaging, sale, and

distribution of controlled substances. They also maintain books,

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papers, and documents that reflect names, addresses, and/or

telephone numbers of their suppliers, couriers, customers, and

other associates in the drug trafficking organization. Many of

these items may be maintained in either paper form or on computers,

computer disks, CD-Rom disks, and related equipment. These

documents are commonly maintained where the drug traffickers have

ready access to them, such as in homes, offices, and automobiles.

Drug traffickers commonly hide contraband, proceeds of drug

sales, and records of drug transactions, drug sources, and drug

customers, in secure locations within their residences, offices,

garages, storage buildings, vehicles, and safe deposit boxes for

ready access, and also to conceal such items from law enforcement

authorities.

Drug traffickers commonly keep large amounts of United States

currency at their disposal in order to maintain and finance an

ongoing drug business.

Drug traffickers conceal in their residences and/or places of

business the proceeds of their illegal activity, including large

amounts of United States currency, financial instruments, precious

metals, jewelry, rare coins, works of art, and other items of

value, as well as books and records regarding the acquisition, use,

and disposition of such items of value.

When drug traffickers amass large proceeds from the sale of

drugs, they attempt to legitimize these profits, often by using the

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services of foreign and domestic banks, other financial

institutions, and real estate brokers, and that books and papers

related to such efforts, including, but not limited to, cashier's

checks, money orders, telegrams, telexes, letters of credit, and

ledgers, are maintained in their residences and/or places of

business.

Drug traffickers usually keep paraphernalia related to the

packaging, cutting, weighing, and distribution of drugs, including,

but not limited to, scales, plastic bags, sifters, strainers,

spoons, cutting agents, and money counting machines, and that such

paraphernalia is often secreted or stored in their residences

and/or places of business.

Drug traffickers frequently take, or cause to be taken,

photographs of themselves, their associates in the drug trade,

property acquired from the distribution of drugs, and their

product, and that such photographs are often kept in their

residences and/or places of business.

Drug traffickers very often place assets, including real and

personal property, such as vehicles, in different names to avoid

detection and forfeiture of such assets by government agencies, and

that the drug traffickers continue to use these assets and to

exercise dominion and control over them even though the assets are

nominally owned by others

Drug traffickers often possess weapons, including firearms for

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protection.

Drug traffickers often use cellular phones and pagers to

conduct their business.

372. Because of the ongoing and undercover nature of the

investigation and the need for allowing flexibility in arresting

the individual defendants named herein, along with executing the

search warrant at or around the time that KELLY JONES residing at

is arrested, the search warrant requests permission to execute the

warrant at any time in the day or night. This is necessary in

order to ensure that evidence is not destroyed if the individuals

are arrested during the evening hours.

373. Based on my training and experience, and based on the

information contained in paragraphs 298 and 300, I believe that

announcing law enforcement's presence prior to the execution of the

arrest warrant for RICARDO ARNOLD would result in the destruction

of evidence and would endanger law enforcement officers executing

the warrant.

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374. Based on the foregoing, I believe there is probable

cause to support the requested criminal complaint and search

warrant.

SUBSCRIBED AND SWORN TO BEFORE

ME THIS ~TH DAY OF OCTOBER 2002.

GERALDINE SOAT BROWN

UNITED STATES MAGISTRATE JUDGE

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FURTHER AFFIANT SAYETH NOT.

Colberd Almeida

Special Agent, Customs