Affidavit is to set forth probable cause in support of an arrest warra t for Sergio quezada-lopez, DOB 11 / 1111978. Defen ant violated 21 u.s.c. Section 841 (a)(i), (b)(1 )(C) and an offense described as follows: Distribution of Heroin Resulting in Death.
Affidavit is to set forth probable cause in support of an arrest warra t for Sergio quezada-lopez, DOB 11 / 1111978. Defen ant violated 21 u.s.c. Section 841 (a)(i), (b)(1 )(C) and an offense described as follows: Distribution of Heroin Resulting in Death.
Affidavit is to set forth probable cause in support of an arrest warra t for Sergio quezada-lopez, DOB 11 / 1111978. Defen ant violated 21 u.s.c. Section 841 (a)(i), (b)(1 )(C) and an offense described as follows: Distribution of Heroin Resulting in Death.
United States District Court United States of America v. SERGIO QUEZADA-LOPEZ, Defendant. for the DISTRICT OF OREGON ) ) ) ) ) ) ) Case No. CRIMINAL COMPLAINT '12-MJ-068 I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date of April 19,20 12, in the county ofMultnomah, in the District of Oregon, the defen ant violated 21 U.S.C. Section, 841 , (aXI), (b)(1 )(C) and an offense described as follows: Distribution of Heroin Resulting in Death, 21 U.S.C. Section 841 (a)(I), (b)(I)(C), and Conspiracy to Distrib te Heroin in violation of 21 U .S.C. Section 846. This criminal complaint is based on these facts: See Attached affidavit of Task Force Officer Gerrit Roelof. Continued on the attached sheet. T D Prinled ?e_and lille Sworn to before me and signed in my presence. ) Date: -t/2t{ (2-01 L City and state: Portland, Oregon Honorable Paul Papak. U.S. Magistrate udge Printed name and title Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 1 of 8 Page ID#: 1 AFFIDAVIT OF DEA TASK FORCE OFFICER GERRIT C. ROELOF I, TFO Gerrit C. Roelof, do hereby state as follows: INTRODUCTION I. The purpose of the affidavit is to set forth probable cause in support of an arrest warra t for Sergio Quezada Lopez, DOB 11 / 1111978 for the charge of Distribution of Heroin Res ting in Death and for the charge of Conspiracy to Distribute Heroin in a Quantity Greater T an One Kilogram, in violation of; Title 21 , United States Code, Section 841 (a)(1)(b)(1)(c) and 846. 2. I am a Salem Police Department (SPD) Detective currently assigned as a Task Force 0 ficer (TFO) to the Drug Enforcement Administration (DEA) Salem Resident Office (RO) a9d an investigative or law enforcement officer of the United States within the meaning of Sedtion 2510(7) of Title 18 of the United States Code. I am empowered to conduct investigatij ns and to make arrests for federal offenses enumerated in Title 18, United States Code, S tion 2516. I have been employed by the Salem Police Department as a police officer since une 2004. I have been assigned as a Task Force Officer with the DEA Salem RO since February 2010. I have attended the DEA Basic Investigation School where I received specialized training from the DEA. This training focused on methods of unlawful d r u ~ trafficking; the identification of controlled substances; the means by which drug trafficf ers derive, launder, and conceal their profits from drug trafficking; the use of assets to facilitate unlawful drug trafficking activity; and the laws relating to the forfeiture to the United I tates of assets purchased with drug proceeds or assets used or intended to be used to facilita e the drug violations. As a TFO with the DEA, my duties have included investigating violat ons of federal laws concerning the unlawful importation of controlled substances, the distribution of controlled substances, and the possession with the intent to distribute controlled substances, including heroin, cocaine, methamphetamine, and marijuana. rrring my law enforcement career I have participated in investigations that have involved cOf - authori zed access to latitude and longitude data for cellular telephones, as well as TitlellII wiretap investigations. During this time I have attended specialized training provided fY the DEA and other law enforcement agencies and I have become familiar with the types and Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 2 of 8 Page ID#: 2 amounts of profits made by narcotics smugglers and the methods, language and terms that are used to disguise the source and nature of the profits from their illegal narcotic deali hgs. I have also attended training on techniques and tools used to examine cellular telephon Is and GPS devices. I have personally interviewed confidential sources and executed se ch warrants for evidence of trafficking controlled substances. SUMMARY OF THE INVESTIGATION 3. On April 16, 2012, the Keizer Police Department responded to the residence of21 ye old Laurin Putnam, who was found deceased. The resulting investigation indicates that her death was probably caused by a heroin overdose based on eyewitness accounts of LaurIn Putnam buying heroin an hour before her death and evidence of heroin use found at thd scene of her death. An autopsy on the deceased has been conducted and we are awaitiJ r toxicology reports. The medical examiner found an injection site on the body with no ther apparent cause of death for such a young person. TFO Nelson interviewed Nicole Liljequist, Putnam's roommate. Liljequist admitted to being a heroin user, and stated t , Nelson that both she and Putnam normally purchased their heroin from John Doe # I. I Investigators determined that John Doe #1 had already attempted to reach Liljequist, t meet and discuss Putnam's death. Liljequist, at the direction of investigators, agreed to meet with John Doe # 1. During this subsequent meeting, John Doe # 1 admitted to supplyin Putnam with heroin. John Doe #1 was subsequently arrested, and admitted to TFO's Nelson and Roelof that he had arranged to sell Putnam 1 gram of heroin for $120 approximately one hour before she was found deceased. I Due to my ongoing concerns that the suspects who cooperated in this matter may face retalia l ion for their cooperation from members of the high-level drug organization that distributed the s U I ~ e c t heroin, I have elected to refer to them as John Does rather than disclose their true name at this early juncture in the case. All of the individuals listed as John Doe in this affidavit have been positi ely identified and have been arrested. They are currently either in state or federal custody at this tIme or on a controlled release status pending adjudication of their own charges stemming from their invol vement in the supply chain of heroin believed to have resulted in the death Laurin Putna . I do not believe that listing the actual names of these cooperating defendants is necessary for a I determination of probable cause at this stage in the investigation. I have detailed an abundance of evidence in this affidavit that corroborates the statements of the John Does. 2 Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 3 of 8 Page ID#: 3 4. John Doe # I agreed to cooperate with law enforcement, and provide information on his heroin supplier. He stated that he had brokered the one gram deal with John Doe #2. Jdhn Doe #1 placed several recorded phone calls to John Doe #2, ordering another gram of heroin while being monitored by law enforcement. John Doe #2 responded to deliver t IS heroin, and was arrested. One gram of heroin was subsequently found on John Doe #2's person. John Doe #2 was interviewed by TFO's Roelof and Nelson, and admitted to se ling the one gram of heroin to John Doe # I the night before. John Doe #2 also identified a photograph of Putnam, stating that she had purchased heroin from him, through John Doe # I, in the past. 5. John Doe #2 agreed to cooperate with law enforcement, and provide information on his heroin supplier. He stated that he was supplied solely by John Doe #3. While being monitored and directed by law enforcement, John Doe #2 made several recorded calls 0 John Doe #3, and ordered two "pieces" of heroin. I know that among heroin purchaSerj and sellers, a "piece" refers to 25 grams of heroin. John Doe #3 was arrested when he arriv d at the agreed location of the deal. During a search of his person, John Doe #3 was found 0 have two "pieces" of heroin in his front jacket pocket. John Doe #3 was arrested, and refused to cooperate with law enforcement. 6. On the next day, Apri l 17, 2012, after speaking to his attorney, John Doe #3 and hi s attorney advised law enforcement that John Doe #3 was willing to cooperate with this investigation, and provide information on his heroin supplier. John Doe #3 stated that e purchased heroin solely from John Doe #4. John Doe #3 placed several recorded call s [0 John Doe #4, ordering 5 pieces of heroin. John Doe #4 subsequently responded to the eet location and was arrested. During the search of his person and vehicle, approximately 69 grams of heroin (gross weight), 21 grams of cocaine (gross weight) and $800 in US currency was located and seized. John Does #4 refused to cooperate with law enforce ent. 7. On the next day, April 18,2012, after speaking to his attorney, John Doe #4 re-contac d law enforcement and advised that he was wi lling to cooperate with this investigation, Jnd provide information on his heroin supplier that supplied the heroin that John Doe #4 st ld to John Doe #3. This is some ofthe same heroin that John Doe #3 had earl ier told law I enforcement that he had sold to John Doe #2 who told officers that he had sold to Jo Doe # I who told officers that he had sold to Laurin Putnam, an hour before her death. Jo Doe 3 Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 4 of 8 Page ID#: 4 #4 stated that he had recently purchased heroin from John Doe #5. John Doe #4 furthe stated that he had initially contacted "Cheche" (later identified as Sergio Quezada-Lop z), and that "Pariente" or John Doe #5 was "Cheche's" worker, and would normally be th one to deliver the heroin for Sergio Quezada Lopez. John Doe #4 placed several recorded ails to John Doe #5, ordering 20 pieces of heroin. John Doe #5 was arrested upon his arriv II at the agreed location for the deal and was arrested. During the search of his vehicle, approximately 1.42 pounds (gross weight) of heroin was seized. 8. John Doe #5 subsequently agreed to cooperate with law enforcement. John Doe #5 sta d to investigators that he worked for a male named "Cheche" (later identified as Sergio Quezada-Lopez). He stated that Quezada-Lopez would receive orders for heroin, and then direct John Doe #5 to deliver the heroin to the buyer, collect the money, and return the l money to Quezada-Lopez. John Doe #5 further stated that Quezada-Lopez was out oft wn, and would be returning the next day on April 19,2012. COOPERATION OF JOHN DOE #5 AND CONSENT SEARCH OF 1809 W 24T11 ST ET, VANCOUVER, WASHINGTON I 9. On April 18,2012, after John Doe #5 was arrested and advised of his Miranda Rights . y TFO Jose Salas, John Doe #5 agreed to speak with investigators. I know this informati n, as well as information articulated below regarding this interview, from speaking directly 0 TFO Jose Salas and from being present during portions of these interviews. John Doe 5 stated to TFO Salas that he lived at 1809 W 24th Street in Vancouver, Washington. He explained that he lived there with "Checho" (heretofore referred to as Quezada-Lopez) and that he worked for Quezada-Lopez, selling heroin. John Doe #5 stated that Quezada-L pez would instruct him to deliver heroin to certain persons. John Doe #5 would then pick up the heroin and place it behind the stereo in the silver Ford Focus which he used to deliver heroin on this date to John Doe #4. He would then receive money from the customer, r d place that behind the same stereo, and deliver it back to Quezada-Lopez. John Doe #5 jtated to TFO Salas that there was approximately $17,000 in US currency stored at their resi1ence, at 1809 W 24th Street, Vancouver, Washington. John Doe #5 stated that Quezada-Lop, z had been in Las Vegas for the past couple of months, and that he had left John Doe #5 in charge 4 Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 5 of 8 Page ID#: 5 of this residence while Sergio Quezada-Lopez frequently called John Doe #5 on phones with instructions on how to keep the drug operation running with specific directions a+ ut multiple deliveries of large quantities of heroin to various customers. John Doe #5 furtr er stated that the only two keys for this residence were retained by John Doe #5, as Quezada- Lopez had given his key to John Doe #5 before departing to Las Vegas. John Doe #5 j ave written consent to investigators, authorizing them to search this residence. 10. Investigators searched the residence on W 24th St. As a result of this search, a still-to-Ile counted amount of US currency, drug ledgers and drug packaging materials were seizdd from the residence. A Mexican Photo Identification card was also seized. This card wl in the name Carlos Arias-Castillo. John Doe #5 was later shown a photograph of this 1 Identification card taken by TFO Salas during the search, and John Doe #5 identified t e person in the photograph as "Checho" (Sergio Quezada-Lopez). RECORDED CALLS BETWEEN JOHN DOE #5 AND SERGIO UEZADA-LOPElZ II. On April 19 th , 2012, TFO Salas, TFO Chris Nelson and I met again with John Doe #5, and hi s attorney. John Doe #5 reiterated his intent to cooperate with law enforcement, and stated that 1e would attempt to communicate with Quezada-Lopez and assist in our attempts to locate and ar est him. John Doe #5 then made a series of recorded phone calls to Quezada-Lopez. John Doe #5ised telephone number (4 I 4-215-1685) to make these calls, and Quezada-Lopez was contacted at pr one number (702-235-1117). The recorded conversations between John Doe #5 and Quezada-Lopez primarily concerned Quezada-Lopez's plan to return to Oregon on a bus, the direction of John Doe #5 to pick him up, and the direction of John Doe #5 as to the distribution of heroin to customers, Sergio Quezada- Lopez was not aware that John Doe #5 was in the custody of police officers when Quezada-Lopez spoke freely to John Doe #5 about their heroin business, thereby providing an incriminating recording of hi s own voice discussing the distribution of heroin. TFO Salas translated these Spanish conversations to English. TFO Salas compared the voice talking to Jo n Doe #5 with a recording of Quezada-Lopez's voice after he was later arrested and concluded tr at the voice talking to John Doe #5 was Quezada Lopez. TFO Salas stated to me that some of the conversations discussed selling heroin to persons named "TJ", "Buki" and John Doe #6. John r oe #5 stated to me that "TJ" (identified as John Doe #4), "Buki", and John Doe #6 are heroin customers. In these conversations, Quezada-Lopez instructed John Doe #5 to sell portions oft eir 5 Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 6 of 8 Page ID#: 6 remaining heroin to these customers. Quezada-Lopez further instructed John Doe #5 to contact "Buki" and John Doe #6 to arrange these deliveries. 12. John Doe #5 subsequently identified to officers Quezada-Lopez as he exited a bus later that ev ning in Portland near 148 1h Street and Stark Street, and Quezada-Lopez was arrested. COOPERATION OF JOHN DOE #S AND CONSENT SEARCH OF 4701 72"d A VENUE, APARTMENT #84, VANCOUVER, WASHINGTON I. On April 23, 2012, investigators again interviewed John Doe #5. During this interview, John 9 0e #5 stated to TFO Salas that there was still some information for which he was afraid to speak about. TFO Salas and TFO Nelson reminded John Doe #5 of the agreement discussed with his attorn11y on April 19th, 2012, and that his total disclosure of relevant facts during this investigation was important. John Doe #5 then disclosed that he and Quezada-Lopez maintained a second "stash house" location, where additional drugs and money were being kept. John Doe #5 stated that hi had not wanted to talk about this location earlier, for fear that he would be charged for these additi t nal drugs. John Doe #5 then led me to 4701 72"d Avenue, which is the Camden Place Apartments. ohn Doe #5 showed me the front door of apartment #84, and stated that this was the location wherJ. he and Quezada-Lopez stored additional drugs. John Doe #5 stated that Quezada-Lopez stored thJ drugs here, and that he would instruct John Doe #5 to pick up the heroin from there, in order t subsequently deliver it to the customers of Quezada-Lopez .. John Doe #5 gave written consent to search thi s location, and also identified a key from hi s key ring which opened the door at this location. A subsequent search of this apartment resulted in the seizure of approximately two to three pounds of heroin, a still-to-be counted amount of US Currency, documents with Sergio Queza a- Lopez's name on them, multiple discarded wrappers likely used to contain drugs and drug packaging materials. In my experience, the two stash houses and the amount of drugs being di stri buted by Sergio Quezada-Lopez together with the statements about him from John Does 4, #5 and #6 (see below) to his customers in Oregon and Washington was on a very high level both r terms of sophistication and great quantities far exceeding on a regular basis more than one kilor ram of heroin. The operation was likely yielding a yearly gross profit of over one-hundred thousan1 dollars. The investigation is ongoing and it is unknown at this time if Sergio Quezada-Lopez was operating a similar scheme in Las Vegas. A review of Sergio Quezada-Lopez's criminal history indicates he has been convicted of Delivery of Heroin in Multnomah County i 2000, Illegal Reentry in 2002 in Tucson Arizona, Conspiracy to Violate the Uniform 6 Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 7 of 8 Page ID#: 7 Controlled Substances Act in Las Vegas, Nevada, in 2005, and Dangerous Drugs in 2007 in Colorado. COOPERATION OF JOHN DOE #5 RESULTING IN THE ARREST OF JOHN DOE #6. 2 0" A p';' 23, 2012, d ,,;"' <h, w;<h 30h" Doo #5, h' ;d,"';fiod ",<Om" o"jdO as a nickname for John Doe #6. John Doe #5 subsequently made recorded phone calls to John Doe I #6, who ordered 8-9 pieces of heroin /Tom John Doe #5. John Doe #6 used telephone number 360- 600-094 I) during these conversations. John Doe #6 was arrested upon his arrival at the agreed location for the deal. Approximately $9,200 in US Currency was seized from his vehicle. John Doe was subsequently read hi s Miranda Rights in Spanish by TFO Salas. John Doe #6 agreed to spr ak with investigators. He stated that he had been contacted earlier by a male he knew as "Hijo". Jf hn Doe #6 stated that "Hijo" worked for a man known as "Loca", and that " Loca" and "Hijo" sold him heroin regularly. John Doe #6 stated that he ordered 8-9 pieces of heroin from " Hijo". John Ode #6 was shown a photo lineup, and identified a photo of Sergio Quezada-Lopez as "Loca". John Dbe #6 also identified three phone numbers which he had saved in his phone, which he had used to c+ tact Quezada-Lopez in the past. These numbers were; (559-45 I -580 I), (559-2 I 7-0734) and (702-2B5- I I 17). John Doe #6 also identified a phone number he stated that he used to contact " Hijo" to order the heroin that evening, as (414-215-1685). As note , Task Force Officer Drug Enforcement Administration Sworn to before me, and subscribed to in this (L!; day of April 2012 dktfi irA 7 U.S. Magistrate Judge Paul Papak United States District Court District of Oregon Case 3:12-mj-00068 Document 1 Filed 04/26/12 Page 8 of 8 Page ID#: 8