Surfos Indictment

1 IND
STEVEN B. WOLFSON
2 Clark County District Attorney
Nevada Bar #001565
3 BINU PALAL
Chief Deputy District Attorney
4 Nevada Bar #010178
200 Lewis Avenue
5 Las Vegas, Nevada 89155-2212
(702) 671-2500
6 Attorney for Plaintiff
7
DISTRICT COURT
8 CLARK COUNTY, NEVADA
9 THE STATE OF NEVADA,
10 Plaintiff, CASE NO:
11 -vs- DEPT NO:
12 DANIEL MENDOZA-BARGOZA,
aka, Daniel Mendozabargoza, #8324605
13 JOSHUA SIBLEY, #8377076
OSBALDO ROJAS-GASPAR,
14 aka, Osbaldo Rojas, #5482382
ANTHONY LOPEZ-MEZA, aka,
15 Anthony Lopezmeza #7042468,
OSCAR RODRIGUEZ #1913193,
16 ELADIO MURILLO #5921152
ELIZAR GOMEZ #1990381
17 JORGE MARTINEZ-NARANJO #5552800
CHRISTIAN ROJAS-GASPAR #7040916 SECOND SUPERSEDING
18 WILLIAM ROJAS-GASPAR #7764059
ALEJANDRO RODRIGUEZ #8257461 INDICTMENT
19 JULIAN BARBOZA #8296413
SUSANA CUEVAS #8268495
20 RAUL LARA #1413642
WILLIAM KENTROS #1970705
21 RAFAEL BONILLA #1688217
RICHARD MCCOULOUGH #8014995
22 ALEXIS DELAROSA #1978057
JACOBO RODRIGUEZ #7051217
23
Defendant(s).
24
25 STATE OF NEVADA )
) ss.
26 COUNTY OF CLARK )
27 The Defendant(s) above named, DANIEL MENDOZA-BARGOZA, aka, Daniel
28 Mendozabargoza, JOSHUA SIBLEY, OSBALDO ROJAS-GASPAR, aka, Osbaldo Rojas,
Document1
1 ANTHONY LOPEZ-MEZA, aka, Anthony Lopezmeza, OSCAR RODRIGUEZ, ELADIO
2 MURILLO, ELIZAR GOMEZ, JORGE MARTINEZ-NARANJO, CHRISTIAN ROJAS-
3 GASPAR, WILLIAM ROJAS-GASPAR, ALEJANDRO RODRIGUEZ, JULIAN
4 BARBOZA, SUSANA CUEVAS, RAUL LARA, WILLIAM KENTROS, RAFAEL
5 BONILLA, RICHARD MCCOULOUGH, ALEXIS DELAROSA and JACOBO
6 RODRIGUEZ accused by the Clark County Grand Jury of the crime(s) of CONSPIRACY TO
7 COMMIT MURDER (Category B Felony - NRS 200.010, 200.030, 199.480 - NOC 50038);
8 MURDER WITH USE OF A DEADLY WEAPON (FIRST DEGREE) (Category A Felony -
9 NRS 200.010, 200.030.1, 193.165 - NOC 50006); ATTEMPT MURDER WITH USE OF A
10 DEADLY WEAPON (Category B Felony - NRS 200.010, 200.030, 193.330, 193.165 - NOC
11 50031); OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSON
12 (Category B Felony - NRS 202.360 - NOC 51460), ASSAULT ON A PROTECTED PERSON
13 WITH USE OF A DEADLY WEAPON (Category B Felony - NRS 200.471 - NOC 50205);
14 DISCHARGE OF FIREARM FROM OR WITHIN A STRUCTURE OR VEHICLE
15 (Category B Felony - NRS 202.287 - NOC 51445); DISCHARGING FIREARM AT OR
16 INTO OCCUPIED STRUCTURE, VEHICLE, AIRCRAFT, OR WATERCRAFT (Category
17 B Felony - NRS 202.285 - NOC 51442); CONSPIRACY TO COMMIT ROBBERY (Category
18 B Felony - NRS 200.380, 199.480 - NOC 50147); BURGLARY WHILE IN POSSESSION
19 OF A FIREARM (Category B Felony - NRS 205.060 - NOC 50426); ROBBERY WITH USE
20 OF A DEADLY WEAPON (Category B Felony - NRS 200.380, 193.165 - NOC 50138);
21 ASSAULT WITH A DEADLY WEAPON (Category B Felony - NRS 200.471 - NOC 50201);
22 SALE OF CONTROLLED SUBSTANCE (Category B Felony - NRS 453.321 - NOC 51090);
23 POSSESSION OF CONTROLLED SUBSTANCE WITH INTENT TO SELL (Category D
24 Felony - NRS 453.337 - NOC 51141); and RACKETEERING (Category B Felony NRS
25 207.350, 207.360, 207.370, 207.380, 207.390, 207.400) committed at and within the County
26 of Clark, State of Nevada, on or about January 1, 2010 through October 1, 2017, as follows:
27 ///
28 ///
2
DOCUMENT1
1 COUNT 1 - CONSPIRACY TO COMMIT MURDER
2 Defendants RAUL LARA and OSBALDO ROJAS-GASPAR on or about April 15,
3 2016, did willfully, unlawfully, and feloniously conspire with each other to commit murder,
4 by the Defendants committing the acts as set forth in Count 2, said acts being incorporated by
5 this reference as though fully set forth herein.
6 COUNT 2 - MURDER WITH USE OF A DEADLY WEAPON (FIRST DEGREE)
7 Defendants RAUL LARA and OSBALDO ROJAS-GASPAR, on or about April 15,
8 2016, did willfully, unlawfully, feloniously and with malice aforethought, kill DAVION
9 MCKINZIE, a human being, with use of a deadly weapon, to wit: a firearm, by shooting at
10 and/or into the body of the said DAVION MCKINZIE, the said killing having been willful,
11 deliberate and premeditated 1) by directly committing this crime; and/or (2) by aiding or
12 abetting in the commission of this crime, with the intent that this crime be committed, by
13 counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other
14 to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent
15 that this crime be committed, Defendants aiding or abetting and/or conspiring with each other
16 and/or an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in
17 concert throughout.
18 COUNT 3 - ATTEMPT MURDER WITH USE OF A DEADLY WEAPON
20 2016, did willfully, unlawfully, feloniously and with malice aforethought attempt to kill
21 ANDRE MCKINZIE, a human being, with use of a deadly weapon, to wit: a firearm, by
22 shooting at the said ANDRE MCKINZIE with said firearm 1) by directly committing this
23 crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this
24 crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or
25 otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to
26 commit this crime, with the intent that this crime be committed, Defendants aiding or abetting
27 and/or conspiring with each other and/or an unknown co-conspirator, Defendants and/or
28 unnamed co-conspirator acting in concert throughout.
3
DOCUMENT1
3 2016, did willfully, unlawfully, feloniously and with malice aforethought attempt to kill
4 MITCHELL CHRISTMAS, a human being, with use of a deadly weapon, to wit: a firearm,
5 by shooting at the said MITCHELL CHRISTMAS with said firearm 1) by directly committing
6 this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that
7 this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or
10 and/or conspiring with each other and/or an unknown co-conspirator, Defendants and/or
12 COUNT 5 - OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSON
13 Defendant RAUL LARA did, on or about April 15, 2016, willfully, unlawfully, and
14 feloniously own, or have in his possession and/or under his custody or control, a firearm, to
15 wit: a firearm, the Defendant being a convicted felon, having in 2013, been convicted of
16 Battery Domestic Violence with Substantial Bodily Injury, in Case No. C289831, in the Eighth
17 Judicial District Court, Clark County, a felony under the laws of the State of Nevada.
18 COUNT 6 - CONSPIRACY TO COMMIT MURDER
19 Defendants JULIAN BARBOZA, CHRISTIAN ROJAS-GASPAR, and DANIEL
20 MENDOZA-BARGOZA did willfully, unlawfully, and feloniously conspire with each other
21 to commit murder, by the Defendants committing the acts as set forth in Count 7, said acts
22 being incorporated by this reference as though fully set forth herein.
23 COUNT 7 - MURDER WITH USE OF A DEADLY WEAPON (FIRST DEGREE)
25 MENDOZA-BARGOZA, on or about Feburary 12, 2017, did willfully, unlawfully,
26 feloniously and with malice aforethought, kill DAVID ESPINOSA, a human being, with use
27 of a deadly weapon, to wit: a firearm, by shooting at and/or into the body of the said DAVID
28 ESPINOSA, the said killing having been willful, deliberate and premeditated 1) by directly
4
DOCUMENT1
1 committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with
2 the intent that this crime be committed, by counseling, encouraging, hiring, commanding,
3 inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a
4 conspiracy to commit this crime, with the intent that this crime be committed, Defendants
5 aiding or abetting and/or conspiring with each other and/or an unknown co-conspirator,
6 Defendants and/or unnamed co-conspirator acting in concert throughout.
9 MENDOZA-BARGOZA, on or about Feburary 12, 2017, did willfully, unlawfully,
10 feloniously and with malice aforethought attempt to kill ABISAI AQUIRRE, a human being,
11 with use of a deadly weapon, to wit: a firearm, by shooting at the said ABISAI AQUIRRE
12 with said firearm 1) by directly committing this crime; and/or (2) by aiding or abetting in the
13 commission of this crime, with the intent that this crime be committed, by counseling,
14 encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit
15 the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this
16 crime be committed, Defendants aiding or abetting and/or conspiring with each other and/or
17 an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in concert
18 throughout.
19 COUNT 9 - DISCHARGE OF FIREARM FROM OR WITHIN A STRUCTURE OR
VEHICLE
20
21 Defendants JULIAN BARBOZA, on or about February 12, 2017, did willfully,
22 unlawfully, maliciously, and feloniously, while in, on or under a vehicle, located at 3600 block
23 of Thomas Ave., North Las Vegas, Clark County, Nevada, discharge a firearm within or from
24 the vehicle, while being within an area designated by a City or County Ordinance as a
25 populated area for the purpose of prohibiting the discharge of weapons; the Defendants being
26 criminally liable under one or more of the following principles of criminal liability, to-wit: (1)
27 by directly committing this crime; and/or (2) by aiding or abetting in the commission of this
28 crime, with the intent that this crime be committed, by counseling, encouraging, hiring,
5
DOCUMENT1
1 commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3)
2 pursuant to a conspiracy to commit this crime, with the intent that this crime be committed,
3 Defendants aiding or abetting and/or conspiring with each other and/or an unnamed co-
4 conspirator, Defendants and/or unnamed co-conspirator acting in concert throughout.
VEHICLE
6
7 Defendants CHRISTIAN ROJAS-GASPAR, on or about February 12, 2017, did
8 willfully, unlawfully, maliciously, and feloniously, while in, on or under a vehicle, located at
9 3600 block of Thomas Ave., North Las Vegas, Clark County, Nevada, discharge a firearm
10 within or from the vehicle, while being within an area designated by a City or County
11 Ordinance as a populated area for the purpose of prohibiting the discharge of weapons; the
12 Defendants being criminally liable under one or more of the following principles of criminal
13 liability, to-wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the
18 an unnamed co-conspirator, Defendants and/or unnamed co-conspirator acting in concert
19 throughout.
21 Defendants DANIEL MENDOZA-BARGOZA, JOSHUA SIBLEY, OSBALDO
22 ROJAS-GASPAR and ANTHONY LOPEZ-MEZA, on or about March 20, 2017, did
23 willfully, unlawfully, feloniously and with malice aforethought attempt to kill A. BURIC, a
24 human being, with use of a deadly weapon, to wit: a firearm, by shooting at the said A. BURIC
25 with said firearm; the Defendants being criminally liable under one or more of the following
26 principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by
27 aiding or abetting in the commission of this crime, with the intent that this crime be committed,
28 by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the
6
DOCUMENT1
1 other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the
2 intent that this crime be committed, Defendants aiding or abetting and/or conspiring with each
3 other and/or an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in
4 concert throughout.
8 willfully, unlawfully, feloniously and with malice aforethought attempt to kill B. MOORE, a
9 human being, with use of a deadly weapon, to wit: a firearm, by shooting at the said B.
10 MOORE with said firearm; the Defendants being criminally liable under one or more of the
11 following principles of criminal liability, to wit: (1) by directly committing this crime; and/or
12 (2) by aiding or abetting in the commission of this crime, with the intent that this crime be
13 committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise
14 procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this
15 crime, with the intent that this crime be committed, Defendants aiding or abetting and/or
16 conspiring with each other and/or an unnamed co-conspirator, Defendants and/or unnamed co-
17 conspirator acting in concert throughout.
21 willfully, unlawfully, feloniously and with malice aforethought attempt to kill E. STAFFORD,
22 a human being, with use of a deadly weapon, to wit: a firearm, by shooting at the said E.
23 STAFFORD with said firearm; the Defendants being criminally liable under one or more of
24 the following principles of criminal liability, to wit: (1) by directly committing this crime;
25 and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime
26 be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise
7
DOCUMENT1
6 willfully, unlawfully, feloniously and with malice aforethought attempt to kill W. YOUNG, a
7 human being, with use of a deadly weapon, to wit: a firearm, by shooting at the said W.
8 YOUNG with said firearm; the Defendants being criminally liable under one or more of the
9 following principles of criminal liability, to wit: (1) by directly committing this crime; and/or
10 (2) by aiding or abetting in the commission of this crime, with the intent that this crime be
11 committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise
16 COUNT 15 - ASSAULT ON A PROTECTED PERSON WITH USE OF A DEADLY
WEAPON
17
20 willfully, unlawfully, feloniously and intentionally place another person in reasonable
21 apprehension of immediate bodily harm and/or did willfully and unlawfully attempt to use
22 physical force against another person, to wit: A. BURIC, a protected person employed as a
23 Police Officer with Las Vegas Metropolitan Police Department, while A. BURIC was
24 performing his duties as a Police Officer with Las Vegas Metropolitan Police Department,
25 which Defendants knew, or should have known, that A. BURIC was a Police Officer with Las
26 Vegas Metropolitan Police Department, with use of a deadly weapon, to wit: a firearm, by
27 shooting at the said Officer A. BURIC with said firearm; the Defendants being criminally
28 liable under one or more of the following principles of criminal liability, to wit: (1) by directly
8
DOCUMENT1
5 aiding or abetting and/or conspiring with each other and/or an unnamed co-conspirator,
WEAPON
8
13 physical force against another person, to wit: B. MOORE, a protected person employed as a
14 Police Officer with Las Vegas Metropolitan Police Department, while B. MOORE was
16 which Defendants knew, or should have known, that B. MOORE was a Police Officer with
17 Las Vegas Metropolitan Police Department, with use of a deadly weapon, to wit: a firearm, by
18 shooting at the said Officer B. MOORE with said firearm; the Defendants being criminally
26 ///
27 ///
28 ///
9
DOCUMENT1
COUNT 17 - ASSAULT ON A PROTECTED PERSON WITH USE OF A DEADLY
1 WEAPON
6 physical force against another person, to wit: E. STAFFORD, a protected person employed as
7 a Police Officer with Las Vegas Metropolitan Police Department, while E. STAFFORD was
9 which Defendants knew, or should have known, that E. STAFFORD was a Police Officer with
11 shooting at the said Officer E. STAFFORD with said firearm; the Defendants being criminally
WEAPON
20
25 physical force against another person, to wit: W. YOUNG, a protected person employed as a
26 Police Officer with Las Vegas Metropolitan Police Department, while W. YOUNG was
28 which Defendants knew, or should have known, that W. YOUNG was a Police Officer with
10
DOCUMENT1
2 shooting at the said Officer W. YOUNG with said firearm; the Defendants being criminally
VEHICLE
11
15 Las Vegas Boulevard North, North Las Vegas, Clark County, Nevada, discharge a firearm
19 liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the
25 throughout.
26 ///
27 ///
28 ///
11
DOCUMENT1
COUNT 20 - DISCHARGE OF FIREARM FROM OR WITHIN A STRUCTURE OR
1 VEHICLE
15 throughout.
VEHICLE
17
12
DOCUMENT1
3 throughout.
VEHICLE
5
19 throughout.
VEHICLE
21
13
DOCUMENT1
7 throughout.
8 COUNT 24 - DISCHARGING FIREARM AT OR INTO OCCUPIED STRUCTURE,
VEHICLE, AIRCRAFT, OR WATERCRAFT
9
11 ROJAS-GASPAR and ANTHONY LOPEZ-MEZA, on or about March 20, 2017, did then and
12 there willfully, unlawfully, maliciously, and feloniously discharge a firearm at or into a
13 vehicle, said vehicle, not having been abandoned, located at Las Vegas Boulevard North,
14 North Las Vegas, Clark County, Nevada; the Defendants being criminally liable under one or
15 more of the following principles of criminal liability, to wit: (1) by directly committing this
20 and/or conspiring with each other and/or an unnamed co-conspirator, Defendants and/or
23
14
DOCUMENT1
9
23
15
DOCUMENT1
9
22 COUNT 29 - CONSPIRACY TO COMMIT ROBBERY
23 Defendant SUSANA CUEVAS, on or about August 8, 2017, did willfully, unlawfully,
24 and feloniously conspire with one or more unnamed co-conspirators to commit a robbery, by
25 the Defendant and/or one or more unnamed co-conspirators committing the acts as set forth in
26 Counts 28 and 29, said acts being incorporated by this reference as though fully set forth
27 herein.
28 ///
16
DOCUMENT1
1 COUNT 30 - BURGLARY WHILE IN POSSESSION OF A FIREARM
2 Defendant SUSANA CUEVAS, on or about August 8, 2017, did then and there
3 willfully, unlawfully, and feloniously enter, with intent to commit larceny and/or a felony, to
4 wit: robbery, that certain building occupied by CIRCLE K, located at 5400 West Vegas Drive,
5 Las Vegas, Clark County, Nevada, said Defendant did possess and/or gain possession of a
6 firearm during the commission of the crime and/or before leaving the structure, the
7 Defendant(s) being criminally liable under one or more of the following principles of criminal
12 crime be committed, Defendant and/or one or more unnamed co-conspirators aiding or
13 abetting and/or conspiring by Defendant and/or one or more unnamed co-conspirators acting
14 in concert throughout.
15 COUNT 31 - ROBBERY WITH USE OF A DEADLY WEAPON
17 and feloniously take personal property, to wit: Modelo beer, from the person of ELIZABETH
18 WALDORF, or in her presence, by means of force or violence, or fear of injury to, and without
19 the consent and against the will of ELIZABETH WALDORF, with use of a deadly weapon,
20 to wit: a firearm, Defendant using force or fear to obtain or retain possession of the property,
21 to prevent or overcome resistance to the taking of the property, and/or to facilitate escape, the
22 Defendant(s) being criminally liable under one or more of the following principles of criminal
27 crime be committed, Defendant and/or one or more unnamed co-conspirators aiding or
28 abetting and/or conspiring by Defendant and/or one or more unnamed co-conspirators acting
17
DOCUMENT1
1 in concert throughout.
2 COUNT 32 - ASSAULT WITH A DEADLY WEAPON
4 feloniously and intentionally place another person in reasonable apprehension of immediate
5 bodily harm and/or did willfully and unlawfully attempt to use physical force against another
6 person, to wit: ELIZABETH WALDORF, with use of a deadly weapon, to wit: a fiream, by
7 displaying and/or racking the slide of said firearm and/or pointing said firearm at or toward
8 the said ELIZABETH WALDORF.
9 COUNT 33 - SALE OF CONTROLLED SUBSTANCE
10 Defendants ALEXIS DELAROSA and OSCAR RODRIGUEZ did on or about August
11 23, 2017, willfully, unlawfully, and feloniously sell to C.I., a controlled substance, to wit:
12 Marijuana.
13 COUNT 34 - POSSESSION OF CONTROLLED SUBSTANCE WITH INTENT TO SELL
14 Defendant OSCAR RODRIGUEZ did on or about September 30, 2017, willfully,
15 unlawfully, and feloniously possess, for the purpose of sale, a controlled substance, to wit:
16 THC Concentrate and/or Marijuana.
17 COUNT 35 - RACKETEERING
18 Defendants, did on or between January 1, 2013 and October 1, 2017, did then and there,
19 within Clark County, Nevada, knowingly, willfully and feloniously, while employed by or
20 assossiated with an enterprise, conduct or participate either directly or indirectly, in
21 racketeering activity throught the affairs of said enterprise including but not limited to
22 racketeering activity; and/or with criminal intent receive any proceeds, derived directly on
23 indirectly, from racketeering activity to use or invest, whether directly or indirectly, any part
24 of the proceeds from racketeering activity; and/or intentionally organize, manage, direct,
25 supervise, or finance a criminal syndicate; and/or knowingly incite or induce others to engage
26 in violence or intimidation to promote or futher the criminal objectives of the criminal
27 syndicate, and/or transporting propert or attempt to transport property or to provide property
28 to another person knowing that the other person intendes to use the property to further
18
DOCUMENT1
1 racketeering activity and or did conspire to engage in said acts, to wit: defendants being
2 members of the criminal syndicate Southern United Raza First Onda Sureos aka SURFOS,
3 whereby all were involved in the operations SURFOS by organizing, managing, directing and
4 supervising the SURFOS criminal syndicate including admitting specific members by the use
5 of violence and/or threatening members with violence if said members sought to leave the
6 criminal syndicate, and/or selling illegal narcotics on behalf or by way of the SURFOS, and/or
7 establishing territory for the SURFOS through the use of violence and/or threatening violence
8 upon others, and/or transporting firearms and/or illegal narcotics on behalf of the SURFOS,
9 and/or having engaged in racketeering activity as alleged in prior Counts and fully
10 incorporated herein or previously being convicted of racketeering activity: Defendants being
11 responsible under one or more of the following principles of criminal liability, to wit (1) by
12 the defendants directly committing the crime; and/or (2) by the defendants aiding or abetting
13 others in the commission of the crime; and/or (3) by the Defendants conspiring to commit the
14 crime.
15 DATED this day of October, 2017.
16 STEVEN B. WOLFSON
Clark County District Attorney
18
BY
19 BINU PALAL
Deputy District Attorney
21 ENDORSEMENT: A True Bill
22
23
24 Foreperson, Clark County Grand Jury
25
26
27
28
19
DOCUMENT1
1 Names of Witnesses and testifying before the Grand Jury:
2 AGUIRRE, ABISAI, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
3 ARZOLA, ISRAEL, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
4 BOURQUE, STEPHAN, LVMPD# 7045
5 BURIC, ANES, LVMPD# 14904
6 CASILLAS, FERNANDO ZEPEDA, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
7 CRUZ, GUSTAVO, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
8 ESHE, MARK, LVMPD
9 GRANTHAM, ROBERT, LVMPD
10 MCKINZIE, ANDRE, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
11 NESTOR, SHANE, SPECIAL AGENT DRUG ENFORCEMENT
12 OCONNER, MICHAEL, LVMPD DETECTIVE
13 RAFALOVICH, MARCO, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
14 REINER, JENNIFER, LVMPD# 8167
15 STAFFORD, ERIC, LVMPD# 13642
16 WALDORF, ELIZABETH, c/o CCDA, 200 Lewis Ave., Las Vegas, NV
17
18 Additional Witnesses known to the District Attorney at time of filing the Indictment:
19 CUSTODIAN OF RECORDS, CCDC
20 CUSTODIAN OF RECORDS, LVMPD COMMUNICATIONS
21 CUSTODIAN OF RECORDS, LVMPD RECORDS
22 MOORE, BRYAN, LVMPD# 14318
23 PRICE, SHANE, LVMPD# 7207
24
25
26
27
16BGJ136A-T/17FN0562A-C/17F09504X/mc-GJ
28 LVMPD EV# 1703203181
20
DOCUMENT1

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