MS13 Intelligence

JJD:RAT/PGS
F.#2016R00
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
936115
- - - X
UNITED STATES OF AMERICA
- against - C O M P L A I N T
ELMER ALEXANDER LOPEZ,
also known as "Smiley" (18 U.S.C. §§ 1959 (a) (5),
and "Little Smiley," 924 (c) (1) (A) (iii) and 2)
Defendant.
- - - - - - X
EASTERN DISTRICT OF NEW YORK, SS:
SEAN C. MCMULLEN, being duly sworn, deposes and states
that he is a Special Agent with the Federal Bureau of Investigation
("FBI"), duly appointed according to law and acting as such.
Upon information and belief, in or about and between
June 2016 and July 2016, such dates being approximate and
inclusive, within the Eastern District of New York, the defendant
ELMER ALEXANDER LOPEZ, also known as "Smiley" and "Little Smiley,"
together with others, for the purpose of gaining entrance to and
maintaining and increasing position in La Mara Salvatrucha, also
known as the MS-13 street gang (the "MS-13"), an enterprise that
was engaged in racketeering activity, did knowingly and
intentionally attempt to murder John Doe, an individual whose
1
identity is known to the government, in violation of New York Penal
Law Section 125.25(1).
(Title 18, United States Code, Sections 1959(a) (5) and
2) .
Upon information and belief, on or about July 3, 2016,
within the Eastern District of New York, the defendant ELMER
ALEXANDER LOPEZ, also known as "Smiley" and "Little Smiley,"
together with others, did knowingly and intentionally use and carry
a firearm during and in relation to a crime of violence, to wit,
the above-violation of 18 U.S.C. § 1959(a) (5), which firearm was
discharged.
(Title 18, United State Code, Sections
924 (c) (1) (A) (iii) and 2).
The source of your deponent's information and the grounds
for his belief are as follows: 11
1. I have been a Special Agent with the FBI for
approximately 20 years. I am currently assigned to the FBI's Long
Island Gang Task Force (the "Task Force"), which is comprised of
agents and officers of the FBI, Nassau County Police Department,
Nassau County Sheriff's Department, Suffolk County Police
Department ( "SCPD"), Suffolk County Probation, Suffolk County
!I Because the purpose of this affidavit is to establish only

probable cause to arrest the defendant, I have not set forth a
description of all the facts of which I am aware.
2
Sheriff's Department and Rockville Centre Police Department. The
primary mission of the Task Force is to combat violent crime
perpetrated by street gang members. The information contained in
this affidavit comes from first-hand knowledge, surveillance,
interviews of gang members, my discussions with witnesses involved
in the investigation, my discussions with other agents and
officers, and a review of reports and evidence related to this
investigation.
La Mara Salvatrucha
2. Many of the cases investigated by the Task Force
involve members of the MS-13. The MS-13 constitutes an
"enterprise" as defined in Section 1959 (b) (2) of Title 18, United
States Code, that is, a group of individuals associated in fact
that engages in, and the activities of which affect, interstate
and foreign commerce. Furthermore, the MS-13, through its members
and associates, engages in racketeering activity, as defined in
Title 18, United States Code, Sections 1959 {b) (1) and 1961 (1),
that is, acts and threats involving murder, in violation of the
laws of the State of New York, and narcotics trafficking, in
violation of Title 21, United States Code, Sections 841 and 846.
Over the past several years, dozens of MS-13 members have been
indicted and convicted in the Eastern District of New York for,
3
among other things, murder, conspiracy and assaults, all committed
in violation of Title 18, United States Code, Section 1959(a).
3. The MS-13, primarily comprised of immigrants from
El Salvador and Honduras, has members located throughout Long
Island and the United States. In the United States, major MS-13
chapters, or "cliques," have been established in New York,
Maryland, Virginia, North Carolina, Texas, California and
elsewhere. Following induction, members of the MS-13 sometimes
signify their membership with gang-related tattoos. On Long
Island, MS-13 cliques have been established in various towns
including Hempstead, Freeport, Westbury, Roosevelt, Huntington,
Brentwood and Islip. The cliques routinely hold meetings to plan
criminal activity and members pay dues into a clique treasury.
The treasury funds are used to purchase firearms and ammunition
and to promote other illegal activity. Inter-clique meetings,
called "Universals," are used to coordinate criminal activities
among different cliques. Participation in criminal activity by a
member, especially violence directed at rival gangs or police
informants, increases the respect accorded to that member and could
result in a promotion to a leadership position. On Long Island,
MS-13 members are frequently involved in violent altercations with
members of rival gangs such as the 18 th Street gang, Salvadorans
With Pride, the Latin Kings, the Bloods and Goon Squad. Long
4
Island MS-13 members have repeatedly carried out assaults,
stabbings and shootings targeting members of rival gangs and
others, including MS-13 members believed to be cooperating with
law enforcement. Long Island MS-13 members have committed
numerous murders on behalf of the gang.
4. The defendant ELMER ALEXANDER LOPEZ, also known as
"Smiley" and "Little Smiley," has been identified as a member of
the Centrales Locos Sal vatruchas ( "CLS") clique of the MS-13 by
numerous sources of evidence, including information provided by
multiple confidential sources, whose identities are known to the
government, and admissions the defendant made to members of the
Task Force when he was arrested on October 18, 2016. Additionally,
the defendant has tattoos symbolizing his membership in the MS-
13, including a skull on his left hand and the "three dots" on his
left wrist, which, in sum and substance, symbolize the cemetery,
prison and hospital, the three places MS-13 members will end up.
Still further, at the time of his arrest, the defendant was wearing
blue and white clothing, which is another symbol of MS-13
membership, including a t-shirt that stated "Rest in Peace," in
Spanish, followed by the nicknames of two suspected deceased MS-
13 members, "Doguie" and "Lil Gato," as well as a reference to
"CLS," the defendant's clique in the MS-13.
5
Attempted Murder of John Doe
5. John Doe and several of his associates had a series
of confrontations with members of the MS-13 during the early summer
of 2016, including a fight where John Doe's associates beat up a
member of the MS-13. Thereafter, on June 3, 2016, John Doe was
assaulted by multiple individuals, some of whom he recognized as
being MS-13 members, which he reported to the SCPD. Further,
during the latter part of June 2016, John Doe was walking on Spruce
Street in Brentwood, New York, when two individuals driving in a
Ford Mustang ( "the Mustang") drove toward him. As the vehicle
approached, the front passenger shouted "La Mara, La Mara," which
means MS-13, at John Doe, and the driver, an MS-13 member, whose
identity is known to the government, ( "Co-Conspirator-1") , drove
directly at John Doe and attempted to run him over with the
Mustang, but John Doe avoided being struck and escaped.
7. On July 3, 2016 at approximately 7:50 p.m., John
Doe was playing basketball with a group of individuals in front of
61 Lukens Avenue in Brentwood, New York, which is an address
associated with members of the Goon Squad. Further, the SCPD
confirmed that there have been multiple shootings at that address
and when crime scene responded to the July 3, 2016 shooting they
found multiple bullet holes in the side of the house. Once again,
John Doe saw the Mustang approach the group he was with and, as
6
the Mustang passed, John Doe observed the Mustang slow, heard a
gunshot and he was struck in the shoulder. John Doe recognized
one of the occupants in the Mustang to be the same individual who
shouted "La Mara" during the earlier incident in June of 2016 when
the occupants of the Mustang attempted to run him over.
7. Subsequent to the shooting, the SCPD responded,
opened an investigation and obtained surveillance video depicting
the Mustang from nearby residences. On July 18, 2016, SCPD patrol
officers located the Mustang, which was registered in the name of
a family member of Co-Conspirator-1.
6. On October 18, 2016, John Doe was shown a binder of
photographs containing photographs of more than a dozen MS-13
members and associates, including a photograph of the defendant
ELMER ALEXANDERLOPEZ, also known as "Smiley" and "Little Smiley."
John Doe identified the photograph of the defendant and stated
that: (1) in June 2016, he observed the defendant in the Mustang
and heard him shout "La Mara, La Mara," when they tried to run him
over; and (2) on July 3, 2016, he observed the defendant in the
Mustang when he was shot in the shoulder.
8. Additionally, on October 18, 2016, in Central
Islip, New York, members of the Task Force observed the defendant
ELMER ALEXANDERLOPEZ, also known as "Smiley" and "Little Smiley,"
placed him under arrest and transported him to a Task Force Office.
7
' .
During arrest processing, the defendant made the following
statements: (1) the defendant admitted that he is a member of the
CLS clique of the MS-13; (2) the defendant admitted that he
illegally entered the United States and does not have any legal
status in the United States; and (3) that he has been in the United
States for approximately two years. Thereafter, the defendant
invoked his right to counsel, at which time his interview was
terminated by agents.
WHEREFORE, your deponent respectfully requests that the
defendant ELMER ALEXANDERLOPEZ, also known as "Smiley" and "Little
Smiley," be dealt with according to law.
SPECIAL AGENT SEAN C. MCMULLEN

Federal Bureau of Investigation
Sworn to before me this

19 th day of October, 2016
/." I-
#HE HONORABL~ ARLENt: R. LINDSAY
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK
8
Case 1:15-cr-10338-FDS Document 40 Filed 01/26/16 Page 1 of 64
UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS
UNITED STATES OF AMERICA ) Cr. No. 15-10338-FDS
)
v. ) VIOLATIONS:
)
l. OSCARNOE RECINOS-GARCIA, ) 18 U.S.C. § 922(g) (5) (A)
A/K/A "PSYCHO," ) Alien in Possession of a
2. JULI~ ESAU AVALOS-ALVARADO, ) Firearm and Ammunition
A/K/A \\VIOLENTO,It )
HERNANDEZ-ESCOBAR,
3. GERMl:!.N ) 18 U.S.c. § 1962(d) --
A/K/A "TERIBLE," ) Conspiracy to Conduct
4. NOE i3ALVADOR PEREZ-VASQUEZ, ) Enterprise Affairs Through
A/K/ A "CRAZYI II ) a Pattern of Racketeering
5. SANTOSPORTILLO-ANDRADE, ) Activity
A/K/A "FLACO,II )
6. HERZ:mN SANDOVAL, ) 21 u.s.c. § 846 --
A/K/A "CASPER,II ) Conspiracy to Distribute
7. EDWIU GUZMAN, ) Cocaine, Cocaine Base,
A/K/A "PLAYA, II ) Heroin, and Marijuana
8. JOSE HERNANDEZ-MIGUEL, )
A../
K/ A \\MUERTO
I II ) 18 u.s.c. § 924(c) (1)
9. EDGARPLEITEZ, ) Using and Carrying a
A/K/A "CADEJO," ) Firearm During the Commission
10. CHRISTIAN ALVARADO, ) Of a Drug Trafficking Offense
A./K/A "CATRACHO," )
11. CES,?,RMARTINEZ, ) 21 u.s.c. § 841(a) (1) --
A/K/A "CHECHE,II ) Distribution of Cocaine Base
12. )
) 42 U.S.C. § 408(aJ (7) (C)
13. FNU LNU, A/K/A "CABALLO," ) Purchase of Fraudulent
14. ERICK ARGUETALARIOS, ) Social Secu~ity Card
A/K/A "LOBO, II )
15. LUIS SOLIS-VASQUEZ, ) 18 U.S.C. § 1546(a) --
A/K/A "BRUJO," ) Possession of a Counterfeit
16. JOSE MIGUEL-HERNANDEZ, ) Resident Alien Card
~\./K/A "SMILEY," )
i.';./K/A "DANGER," ) 18 u.s.c. § 1028(a) (2)
17. CARLOSMELARA, ) Transfer of a False
l"i./K/A "CHUCHITO,II ) Identification Document
l"i./K/A "CRIMINAL1 " )
18. JOEL MARTINEZ, ) 8 u.s.c. § 1326 --
l.._/K/A "ANIMAL," ) Unlawful Re-Entry of a
} Deported Alien
9
19. JOS:3: RENE ANDRADE, ) 18 U.S.C. § 1963

A/K/A "TRISTE, ) RICO Forfeiture
A/K/A "INNOCENTE, 11 ) Allegations
2 o . HEC'roR ENAMORADO, )
A/K/A "VIDA LOCA, 11 } 21 U.S. C. § 853
21. HENRY SANTOS-GOMEZ, } Drug Forfeiture
A/K/A "RENEGADO, 11 ) Allegations
A/K/A "PINO I II )
22. RAFJ~EL LEONER-AGUIRRE, ) 18 U.S.C. § 924 (d} and

A/ K/ A "TREMENDO , 11 } 2 8 U • S . C . § 2 4 61 ( c )
23. HEC1~OR RAMIRES, ) Firearms Forfeiture
A./K/A "CUERVO," ) Allegations
24. DANIEL MENJIVAR, )
A/K/A "ROCA," ) 18 U.S.C. § 982 (a) (2} (B)
A/K/A "SITIKO, 11 } & (a} (6) {ii} --
25. ANGE:L PINEDA, ) Identification Fraud
A/K/A "BRAVO," ) Forfeiture Allegations
A/K/A "JOSE LOPEZ," )
26. JOSE VASQUEZ, )
i\/K/A "LITTLE CRAZYI II )
27. DAVID LOPEZ, )

A/K/A "CILINDRO, 11 }
]\,/K/A "VILLANO, II }
28. BRYAN GALICIA-BARILLAS, )

l\/K/A "CHUCKY I II }
29. DOMINGO TIZOL, }

l\./K/A "CHAPIN, 11 )
3 0 • FNU LNU, A/K/ A "VIOLENTO, " )

31 . OSCAR DURAN, }
J\./K/A "DEMENTE, II }
32. EDWIN GONZALEZ, }

J~/K/A "SANGRIENTO, II )
33. HENRY JOSUE PARADA MARTINEZ,)

J:;./K/A "STREET DANGER, 11 )
34. JOSUE MORALES, )

J~/K/A "GALLITO I II )
35. KEVIN AYALA, }

1'1./K/A "BLANCITO, II )
36. MARI~ AGUILAR RAMOS, )

37. RUTILIO PORTILLO, )
J../K/A "PANTERA, II )
38. EDWI~ DIAZ, A/K/A "DEMENTE, 11 )
3 9 • MARVIN MELGAR, )
J../K/A "NINJA, II )
40. JAIR::> PEREZ, A/K/A "SECO," )
10
41. RAMlRO GUERRA, )

~':>,./K/A"CAMELLO,II )
42. MA.Nt'ELMARTINEZ, )
1\/K/A "GORDO,11 )
43. ALEiANDERALVARENGA, )
44. MA.NtELFLORES-VALLE, )
1\./K/A "MANNY,11 )
45. HEINER YOVANIGOMEZ, )
l\/K/A "FIERO I// )
46. FNU LNU, A/K/A )
''THE COLUMBIAN 1
11
)
47. CARLOS LOVATO, }
48. FNU LNU, A/K/A \\MIGUE,11 }
49. LUIS LNU, }
50, JOSE NELSIN REYES-VELASQUEZ,}
A/K/A "DIABLITO, II }
51. OSCAR RIVERA, }
1'¼./K/A"JOSE," }
52. ROBERTOA. LOPEZ, }
53. FRANKLINRODRIGUEZ, }
1'.,./K/A "HOLLYWOOD, 11
}
54. OSCAR RAMIREZ-CORNEJO, }
}'\./K/A "VAGO,II }
55. MAURICIO SANCHEZ, }
1'\./K/A "TIGRE, 11
}
56. JOSE ADANMARTINEZCASTRO, }
}'¼./K/A \\CHUCKY I II AND }
57. ELENILSON GUSTAVO }
GONZALEZ-GONZALEZ, A/K/A}
,,s INIESTRO I II }
Defendants. }
11
SECOND SUPERSEDING INDICTMENT
COUNTO1'i'.E: (18 u.s.c. § 922(g) (5) (A)--Alien in Possession

of a Firearm and Ammunition)
The Grar.d Jury charges that:
1. On or about July 8, 2015, at Somerville, in the
District of Massachusetts,
l. OSCAR NOE RECINES-GARCIA, A/K/A "PSYCHO," and

2. JULIO ESAU AVALOS-ALVARADO,A/K/A "VIOLENTO,"
the defendants herein, aliens who were then illegally and
unlawfully in the United States, did knowingly possess in and
affecting commerce a firearm and ammunition, to wit: a .22
caliber Sterling model semi-automatic pistol bearing serial
number Al4546 and twelve rounds of .22 caliber ammunition.
All in violation of Title 18, United States Code, Section
922(g} (5) (A}.
4
12
COUNTTW'O: (18 u.s.c. § 1962{d)--Conspiracy to Conduct

Enterprise Affairs through a Pattern of
Racketeering Activity)
The Grand Jury further charges that:
Introduction
At all times relevant to this Second Superseding

Indictme,nt:
2. La Mara Salvatrucha, also known as the MS-13 criminal
organization (hereinafter "MS-13"}, is composed primarily of
immigrants or descendants of immigrants from El Salvador, with
members operating throughout Massachusetts, including East
Boston, ~verett, Chelsea, Somerville, Lynn, and Revere, and
elsewher,:.
3, The name "Mara Salvatrucha" is a combination of
several ::dang terms. In its most common usage, the word "Mara"
is the tE~rm used in El Salvador for "gang" ; the phrase
"Salvatrucha" is a combination of the words "Salva," which is an
abbreviation for "Salvadoran," and ''trucha," which is a slang
term for "fear us," "look out," or "heads up."
4. In the United States, MS-13 originated in Los Angeles,
California, where MS-13 members engaged in turf wars for the
control cf drug distribution locations. MS-13 quickly spread to
states across the country, including Massachusetts and
elsewhere. MS-13 has been operating in the United States since
at least the 1980s.
5
13
5. In 2012, MS-13 became the first, and remains the only,
street Hang to be designated by the United States government as

11
a trammational criminal organization." Today, MS-13 is one of
the lar9est criminal organizations in the United States, and is
a national and international criminal organization with over
6,000 me,mbers in the United States with a presence in at least
forty-six states and the District of Columbia, as well as over
30,000 members internationally, mostly in Mexico, Honduras,
Guatemala, and El Salvador. MS-13 members actively recruit
members -- often juveniles inside high schools -- from
communities such as Chelsea and East Boston, MA, which have a
large number of immigrants from El Salvador. Members, however,
can alsc have ethnic heritage from other Central and Latin
Americar:. countries.
6. MS-13 was organized in Massachusetts and elsewhere in
the forrr. of so-called "cliques" - - that is, smaller groups
acting under the larger mantle of MS-13 and operating in a
specific region, city, or part of a city. In order to organize
and coordinate hundreds of cliques made up of tens of thousands
of MS-13 members located in numerous disparate locations, MS-13
leadersl:.ip in El Salvador organized the criminal organization
into "programs." MS-13 generally organized its programs either
by name -- for example, major cliques, such as the Hollywood
clique -- or by geography, such as the L.A. Program and the East
6
14
Coast P:-:ogram. Grouping the various cliques into these programs
created a hierarchy that expedited the process of getting orders
from leadership in El Salvador to the street and remitting money
from thE! street back to leadership in El Salvador. MS-13
cliques worked both independently and cooperatively to engage in
criminal activity and assist one another in avoiding detection
by law emforcement. The cliques operated under the umbrella
rules of MS-13 leadership in El Salvador.
7. All of the cliques under the various MS-13 programs,
includir ..g those in Massachusetts, most of which fall under the
East Coa.st Program, held meetings to collect dues from
individt:.al MS-13 members. The dues from each clique were then
generally provided to the program leader (e.g., the East Coast
Program leader), who transferred the money, usually via wire
transfeI, to the incarcerated MS-13 leaders in El Salvador,
known as "La Ranfla." La Ranfla used the U.S.-provided money to
pay for cell phones, shoes, food, and legal services for
incarceiated MS-13 members, as well as to procure weapons and
other supplies to facilitate criminal activity. Some of these
items were used in El Salvador, but others, especially cell
phones, enabled La Ranfla to have a direct impact on the United
States. La Ranfla used the money to obtain contraband cell
phones, which they used to call U.S. MS-13 leaders and order
them to generate more money or to "green light,, (i.e., order the
7
15
killing of) members or associates believed to be cooperating
with law enforcement. If a clique did not fall under a
particular program, such as the Eastside Loco Salvatrucha
("ESLS") in Massachusetts, which has been resisting joining the
East Coa.st Program, that clique nevertheless fell under the
umbrella of MS-13 and held meetings in which dues were collected
and transferred to MS-13 members in El Salvador.
8. In Massachusetts, some of these cliques are identified
by names such as East Boston Loco Salvatrucha ("EBLS"); Eastside
Loco Salvatrucha ("ESLS"); Everett Loco Salvatrucha ("ELS");
Enfermos Criminales Salvatrucha ("ECS"); Trece Loco Salvatrucha
("TLS"); Hollywood Loco Salvatrucha ("HLS"); Chelsea Loco
Salvatru.::ha ("CLS"); Syko Loco Salvatrucha ("SLS"); and Molinos
Loco Sal·,atrucha ( \\MLS") .
9. The leaders of MS-13 cliques in Massachusetts and
elsewhere were frequently called the "palabras" - - i.e., the
"words" or "voices" -- or the "runners." The leader of a clique
was often referred to as the "first word," "first voice," or
''runner 1
1
• and the second in command was called the "second word"
or "second voice."
10. MS-13 members from different cliques attended meetings
together. In Massachusetts and elsewhere, the MS-13 cliques met
to discu1:1s, plan, and report on, among other things,
organizational issues; membership issues; illegal activity on
8
16
behalf of MS-13; acts of violence committed by MS-13 members
against rival gang members and others with the goal of achieving
control of territory; law enforcement activity against MS-13
members; and those suspected of cooperating with law
enforcement. Members of the cliques were required to make
regular "dues" payments at these clique meetings, which money
the clic;ue used for a variety of purposes, including, but not
limited to, to send to El Salvador for MS-13 clique members who
were deforted and/or imprisoned in El Salvador, to purchase
"clique firearms'' (i.e., firearms held by a clique member to be
used on request by any clique member), and to send to clique
members imprisoned in the United States.
11. In order to join MS-13, members generally were
required to complete an initiation process. That process
started with a prospective member being allowed to "hang around"
with members of MS-13 and be observed by the criminal
organization, sometimes for a period of months or years. Such
prospective members were referred to as "pares." During this
investigation, pares were often recruited in the local high
schools, including Chelsea High School, Everett High School, and
East Boston High School, often when they were 14 or 15 years
old. Faros were observed for trustworthiness and required to do
whatever a "homeboy" (full member of MS-13} or "chequeo" (see
below} requested. Usually a paro was sponsored by a homeboy who
17
would seirve as that individual's mentor/sponsor throughout the
initiation process. If a prospective member passed the paro
stage, t.e became a "chequeo. 11

During this stage, the
prospective member was allowed closer access to members of MS-13
and was again observed for trustworthiness and required to do
whatever a homeboy asked.
12. To pass from chequeo stage to homeboy status,
prospective members usually had to engage in some significant
criminal activity on behalf of MS-13, usually at least one
murder of a rival gang member and a demonstration of loyalty by
coming to the aid of or supporting an MS-13 member. The members
of the particular MS-13 clique had to vote to approve elevation
to homeb~y status. The clique would then hold a meeting during
which the prospective member would be "jumped in" or "beat in"
to MS-13 -- that is, members of the MS-13 clique would beat the
new member with their hands and feet, usually until one of the
leaders ~f the clique finished counting aloud slowly to
thirteen.
13. When used in this Second Superseding Indictment, the
term MS-13 "associate" refers to prospective members, including
so-callej paras and chequeos, as well as individuals who
associated with MS-13 members through engagement in criminal
activity, such as drug trafficking.
10
18
14, Some members of MS-13 who achieved homeboy status or
rank siHnified their membership by wearing tattoos reading MARA

11
SALVATRUCHA,""MS," or ''MS 13," or similar slogans, often
written in gothic lettering. In addition, MS-13 members often
have tattoos that signify membership in a particular clique.
MS-13 cclors are generally blue and white, sometimes with the
number 11
13"; MS-13 members and associates are not permitted to
wear the color red, the color of MS-13's chief rival, the 1a th
Street gang. MS-13 members often wear Nike Cortez sneakers, in
white or blue, to signify their MS-13 membership. Chequeos and
paros ar= not permitted to get MS-13 or clique tattoos; only
homeboys are permitted to get such tattoos. Chequeos are
consider,?d to represent MS-13, however, and can wear the MS-13
colors and the MS-13 sneakers, and are not permitted to wear
red.
15. MS-13 members on occasion marked their territory or
signified their presence through the use of graffiti with the
words 11
MH," a clique's initials, or other identifying slogan.
Some MS-J.3 members were more discreet and less public about
their membership, by hiding and avoiding such clothing and
tattoos in order to avoid detection by law enforcement. During
the cours:e of this investigation, the leadership of the various
cliques jn Massachusetts at times instructed their members and
chequeos to avoid law enforcement attention by dressing
11
19
discreetly and carrying certain weapons. For example, after two
Boston a.rea cliques (the Everett Loco Salvatrucha ("ELS") and
the Mol:.nos Loco Salvatrucha ( \'MLS")) were involved in two
murders in East Boston in September 2015, NOE SALVADORPEREZ-
VASQUEZ, A/K/A \\CRAZY," an MS-13 leader for ELS, instructed his
members to dress discreetly; not display the MS-13 colors, Nike
Cortez e:neakers, and tattoos; and carry a bicycle chain with a
lock for a weapon, rather than a gun or knife, because there was
a heightened chance that they would be stopped by police on the
street.
16. MS-13 members refer to one another by their MS-13
names ar.d often do not know fellow MS-13 members except by these
MS-13 na.mes. When a "chequeo" becomes a "homeboy," the MS-13
clique s·enerally gives him a new MS-13 name to replace any prior
nickname. Where two aliases are used herein, it is usually
because the individual in question was elevated from chequeo
status t.o homeboy status during the course of the investigation.
17. Members of MS-13 were expected to protect the name,
reputation, and status of MS-13 and its members from rival gang
members or any other person. MS-13 members generally believe
that all individuals should show respect and deference to the
MS-13 criminal organization and its members. To protect the MS-
13 criminal organization and to enhance its reputation, MS-13
members are expected to use any means necessary to get respect
12
20
from these who show disrespect, including acts of intimidation
and violence, up to and including murder.
18. Members of MS-13 engaged in criminal activity
including, but not limited to, murder, attempted murder, drug
trafficking, illegal possession of firearms, robbery, and
obstructing justice in the form of threatening and intimidating
witnesses whom they believed were cooperating with law
enforcement. MS-13 members were often required to commit acts
of violence to maintain membership and discipline within the MS-
13 criminal organization, including violence against rival
gangs. Participation in criminal activity by an MS-13 member,
particularly violent acts directed at rival gangs or as directed
by the MS-13 leadership, increased the level of respect accorded
that member, resulting in that member maintaining or increasing
his position in the MS-13 criminal organization, and possibly
resulting in a promotion to a leadership position.
19. MS-13 has a set of rules that govern the conduct of
its members and associates. These rules include attacking rival
gang men.bers on sight, particularly members of the 18 th Street
gang, ar..d supporting fellow "homeboys" in any dispute. Leaders
act to resolve disputes, address organizational issues, and
participate in MS-13 decisions such as whether to assault or
murder, known as "green light," those suspected of cooperating
with law enforcement.
13
21
20, Violence is a central tenet of MS-13, as evidenced by
its motto -- "mata, viola, controla," translated as kill, rape,
control. This violence is directed against rival gangs,
particularly the la th Street gang, and anyone who is perceived to
have disrespected MS-13. MS-13 members and associates often
commit rrurders and attempted murders using machetes, knives, and
chains in order to intimidate rival gang members.
21. MS-13 members communicated about their MS-13
activities with other MS-13 members in Massachusetts and
elsewher: in the United States, and in El Salvador, using mobile
telephon:s and other modes of communication. Additionally, MS-
13 members used transnational and international money wire
transfer:3 to conduct and promote the activities of the MS-13
criminal organization.
The Racketeering Conspiracy
22. At all times relevant to this Second Superseding
Indictment, the following defendants were leaders, members, and
associateis of MS-13:
l. OSCAR NOE RECINOS-GARCIA, A/K/A "PSYCHO,"

2. JULIO ESAU AVALOS-ALVARADO,A/'K/A "VIOLENTO,"
3. GERMANHERNANDEZ-ESCOBAR,A/K/A "TERIBLE,"
4. NOE SALVADORPEREZ-VASQUEZ, A/'K/A "CRAZY,"
5. SANTOS PORTILLO-ANDRADE,A/'K/A "FLACO,"
6. HERZZONSANDOVAL, A/'K/A "CASPER,"
7. EDWIN GUZMAN,A/K/A "PLAYA,"
8. JOSE HERNANDEZ-MIGUEL,A/K/A "MUERTO,"
9. EDGAR PLEITEZ, A/K/A "CADEJO,"
10. CHRISTIAN ALVARADO,A/K/A "CATRACHO,"
11. CESAR MARTINEZ, A/K/A "CHECHE,"
14
22
12.
13. FNU LNU, A/K/A "CABALLO,"
14. ERICK ARGUETA LARIOS, A/K/A "LOBO,"
15. LUIS SOLIS-VASQUEZ, A/K/A "BRUJO,"
16. JOSE MIGUEL-HERNANDEZ, A/K/A "SMILEY,"
A/K/A "DANGER,"
17. CARLOS MELARA,A/K/A "CHUCHITO,"
A/K/A "CRIMINAL,"
18 JOEL MARTINEZ, A/K/A "ANIMAL,"
19. JOSE RENE ANDRADE, A/K/A "TRISTE,"
A/K/A "INNOCENTE,"
20. HECTOR ENAMORADO,A/K/A "VIDA LOCA,"
21. HENRY SANTOS-GOMEZ, A/K/A "RENEGADO,"
A/K/A "PINO,"
22. RAFAEL LEONER-AGUIRRE, A/K/A "TREMENDO,"
23. HECTOR RAMIRES, A/K/A "CUERVO,"
24. DANIEL MENJIVAR, A/K/A "ROCA," A/K/A "SITIKO,"
25. ANGEL PINEDA, A/K/A "BRAVO," A/K/A "JOSE LOPEZ,"
26. JOSE VASQUEZ, A/K/A "LITTLE CRAZY,"
27. DAVID LOPEZ, A/K/A "CILINDRO", A/K/A "VILLANO,"
28. BRYAN GALICIA-BARILLAS, A/K/A "CHUCKY,"
29. DOMINGO TIZOL, A/K/A "CHAPIN,"
30. FNU LNU, A/K/A "VIOLENTO,"
31. OSCAR DURAN, A/K/A "DEMENTE,"
32. EDWIN GONZALEZ, A/K/A "SANGRIENTO,"
33. HENRY JOSUE PARADAMARTINEZ,
A/K/A "STREET DANGER,"
34. JOSUE MORALES, A/K/A "GALLITO,"
35. KEVIN AYALA, A/K/A "BLANCITO,"
36. MARIO AGUILAR RAMOS,
37. RUTILIO PORTILLO, A/K/A "PANTERA,"
38. EDWIN DIAZ, A/K/A "DEMENTE,"
39. MARVIN MELGAR, A/K/A "NINJA,"
40. JAIRO PEREZ, A/K/A "SECO,"
55. MAURICIO SANCHEZ, A/K/A "TIGRE," and
56. JOSE ADAN MARTINEZ CASTRO, A/K/A "CHUCKY."
The Enterprise
23. MS-13, including its leadership, members and
associates, in the District of Massachusetts, numerous other
states, I:l Salvador, and elsewhere, constituted an "enterprise"
as define:d in Title 18, United States Code, Section 1961(4),
15
23
that is, a group of individuals associated in fact that engaged
in, and the activities of which affected, interstate and foreign
commerce. The enterprise constituted an ongoing organization
whose mE~mbers functioned as a continuing unit that had a common
purpose of achieving the goals of the enterprise.
Purposes of the Enterprise
24, The purposes of the MS-13 enterprise included the
following:
a. Preserving and protecting the power, territory,
reputation, and profits of the enterprise through the use of
intimidcLtion, violence, threats of violence, assaults, and
murder;
b. Promoting and enhancing the enterprise and its
members' and associates' activities, including, but not limited
to, dru9 trafficking, robberies, firearms possession, and other
criminal activities;
c. Keeping victims, potential victims, and community
members in fear of the enterprise and its members and associates
through violence and threats of violence;
d. Providing financial support and information to
MS-13 mEimbers, including those incarcerated in the United States
and El ~:al vador; and
e. Providing assistance to other MS-13 members who
committed crimes for and on behalf of the MS-13 criminal
16
24
organization, to hinder, obstruct, and prevent law enforcement
officers from identifying, apprehending, and successfully
prosecuting and punishing the offenders.
25. From a time unknown to the Grand Jury and continuing
until in or about January 2016, at East Boston, Chelsea,
Somerville, Revere, Cambridge, and Everett, and elsewhere in the
District of Massachusetts, in Richmond, in the Eastern District
of Virginia, in Salem, and elsewhere in the District of New
Hampshire, in the District-of Arizona, in the District of New
Jersey, :ind at other places presently known and unknown,
1. OSCAR NOE RECINOS-GARCIA, A/K/A "PSYCHO,"

2. JULIO ESAU AVALOS-ALVARADO, A/K/A "VIOLENTO,"
3. GERMANHERNANDEZ-ESCOBAR, A/K/A "TERIBLE,"
4. NOE SALVADORPEREZ-VASQUEZ, A/K/A "CRAZY,"
5. SANTOS PORTILLO-ANDRADE, A/K/A "FLACO,"
6. HERZZON SANDOVAL, A/K/A "CASPER,"
7. EDWIN GUZMAN,A/K/A "PLAYA,"
8. JOSE HERNANDEZ-MIGUEL, A/K/A "MUERTO,"
10. CHRISTIAN ALVARADO, A/K/A "CATRACHO,"
12.
14. ERICK ARGUETALARIOS, A/K/A "LOBO,"
A/K/A "DANGER,"
17. CARLOS MELARA, A/K/A "CHUCHITO,"
A/K/A "CRIMINAL,"
A/K/A "INNOCENTE,"
A/K/A "PINO,"
17
25
22. RAFAEL LEONER-AGUIRRE,A/K/A "TREMENDO,"

23. HECTORRAMIRES, A/K/A "CUERVO,"
27. DAVID LOPEZ, A/K/A "CILINDRO," A/K/A "VILLANO,"
29. DOMINGOTIZOL, A/K/A "CHAPIN,"
3 6. MARIO AGUILAR RAMOS,
55. MAURICIO SANCHEZ, A/K/A "TIGRE," and
56. JOSE ADAN MARTINEZCASTRO, A/K/A "CHUCKY,"
the defendants herein, and others known and unknown to the Grand
Jury, being persons employed by and associated with MS-13, an
enterprise which was engaged in, and the activities of which
affected, interstate and foreign commerce, did knowingly
conspire with each other, and with other persons known and
unknown to the Grand Jury, to violate Title 18, United States
Code, Section 1962(c), that is, to conduct and participate,
directly and indirectly, in the conduct of the affairs of the
MS-13 enterprise through a pattern of racketeering activity, as
that term is defined in Title 18, United States Code, Sections
19 61 ( 1) and ( 5 ) .
18
26
26. The aforementioned pattern of racketeering activity

consiste,d of:
a. multiple offenses involving trafficking in

narcotics, including cocaine, cocaine base,
heroin, and marijuana, in violation of 21 U.S.C.
§§ 846 and 841(a) {1);
b. multiple acts involving murder, in violation of

Massachusetts General Laws, Chapter 265, Section
l(murder), Section 15 (assault with intent to
murder), Section 16 (attempt to murder), and
Section 18 (armed assault with intent to rob or
murder) 1 and in violation of Massachusetts
General Laws, Chapter 274, Section 7 (conspiracy
to commit murder); and
c. multiple acts involving robbery, in violation of

17 {armed robbery), and in violation of
6 (attempted robbery) and Section 7 {conspiracy
to rob).
27. It was part of the conspiracy that each defendant
agreed that a conspirator would commit at least two acts of
racketeering activity in the conduct of the affairs of the MS-13
enterprise.
Means and Methods
28. Among the means and methods by which the defendants
and their co-conspirators conspired to conduct and participate
in the conduct of the affairs of the MS-13 enterprise were the
following:
a. Leaders, members, and associates of MS-13 used
the MS-13 criminal enterprise to commit, attempt and threaten to
19
27
commit, acts of violence, including murder and attempted murder,
to prot,=ct and expand MS-13' s criminal operations, including
intimidating potential witnesses to MS-13's illegal activities.
b. Leaders, members, and associates of MS-13 used
the MS-:.3 criminal enterprise to promote a climate of fear
through violence and threats of violence in order to intimidate
potentia.l rivals to MS-13 and its illegal activities, and to
intimidate potential witnesses to MS-13's illegal activities.
c. Leaders, members, and associates of MS-13
promulgated certain rules to be followed by all participants in
the MS-13 criminal enterprise including the rule that a
participant in the enterprise not act as an informant for law
enforcement authorities regarding the criminal activities of the
MS-13 encerprise, and the rule that MS-13 members and associates
attempt ·:o kill members of rival gangs, including the 18 th Street
gang, whenever possible.
d. To enforce the rules of the MS-13 criminal
enterpriue, and to promote discipline, leaders, members, and
associatE!S of MS-13 murdered, attempted to murder, assaulted and
threatene?d those participants in the MS-13 enterprise and others
who violcLted the rules or posed a threat to MS-13.
e. Leaders, members, and associates of MS-13 were
advised c,f the rules of MS-13, and MS-13 members voted on the
initiation of new members into MS-13.
20
28
f. Leaders, members, and associates of MS-13 were
required to send a certain amount of money each month to the
leadership of the MS-13 enterprise in El Salvador, which money
was used for, among other things, buying guns, drugs, and
cellular telephones to facilitate the MS-13 criminal enterprise,
and supporting incarcerated MS-13 members.
g. To generate income for MS-13, participants in the
MS-13 criminal enterprise were required to conduct, and, in
fact, conducted illegal activities under the protection of the
MS-13 er..terprise.
h. To perpetuate the MS-13 criminal enterprise,
participants in the enterprise attempted to conceal from law
enforcement the existence of MS-13, the identity of its
participants, the ways in which it conducted its affairs, and
the locations at which it discussed and conducted its affairs.
i. Leaders, members, and associates of the MS-13
criminal enterprise possessed, carried, and used firearms, as
well as •:>ther weapons, to protect their operations from theft,
robbery, and competition from others. These weapons were
possessed, carried, and used for various reasons, including but
not limi·:ed to: protecting MS-13' s narcotics and the proceeds
of drug distribution; ensuring that drug distribution activities
were controlled by MS-13 and its leaders, members, and
associatHs; intimidating others from attempting to steal MS-131 s
21
29
narcoti:s and proceeds from drug distribution; robbing others;
killing and attempting to kill rival gang members; and ensuring
the per;::onal safety of leaders, members, and associates of MS-

13.
29. The means and methods of the conspiracy included
numeroui; acts of murder and attempted murder, including the
following acts:
MURDERS
a. The murder of Katerin Gomez.
(i) On or about October 18, 2014, in Chelsea,
MA, HEC~'ORRAMIRES, A/K/A "CUERVO"i and BRYANGALICIA-BARILLAS,
A/K/A "CHUCKY," acting deliberately with premeditated malice
aforethc,ught, and with extreme atrocity and cruelty, murdered
Katerin Gomez, in violation of M.G.L. Ch. 265 § 1.
(ii) On or about October 18, 2014, in Chelsea,
MA, HECTORRAMIRES, A/K/A "CUERVO"; and BRYANGALICIA-BARILLAS,
A/K/A "CHUCKY," unlawfully killed Katerin Gomez with malice
aforethcught in Chelsea, MA, in violation of M.G.L. Ch. 265 § 1.
b. The murder of Javier Ortiz.
(i) On or about December 14, 2014, in Chelsea,
MA, HEC'IORENAMORADO,
A/K/A "VIDA LOCA"; LUIS SOLIS-VASQUEZ,
A/K/A "BRUJO"; NOE SALVADORPEREZ-VASQUEZ,A/K/A "CRAZY"; and
JOSE MIGUELHERNANDEZ,A/K/A "DANGER," acting deliberately with
premeditated malice aforethought, and with extreme atrocity and

22
30
cruelty. murdered Javier Ortiz, in violation of M.G.L. Ch. 265

§ 1.
(ii) On or about December 14, 2014, in Chelsea,
MA, HEC~~ORENAMORADO,A/K/A "VIDA LOCA"; and LUIS SOLIS-VASQUEZ,
A/K/A "HRUJO"; NOE SALVADORPEREZ-VASQUEZ, A/K/A "CRAZY"; and
JOSE MIGUEL HERNANDEZ, A/K/A "DANGER," unlawfully killed Javier
Ortiz with malice aforethought, in violation of M.G.L. Ch. 265
§ 1.
(iii) Following the murder of Javier Ortiz,
HERZZONSANDOVAL, A/K/A "CASPER," and EDWIN GUZMAN, A/K/A
"PLAYA, 11
leaders of the ESLS clique of MS-13, convened a clique
meeting to congratulate ENAMORADO

and SOLIS-VASQUEZ on the
murder. At this ESLS clique meeting, to maintain discipline
within rv:S-13, SANDOVALand GUZMANalso ordered the 13-second
beating of another MS-13 member who did not come to ENAMORADO's
aid the night before the murder of Javier Ortiz, when ENAMORADO
had an a.ltercation with Ortiz.
c. The murder of Wilson Martinez.
(i) On or about September 7, 2015, in East
Boston, MA, CARLOS MELARA, A/K/A "CHUCHITO," A/K/A "CRIMINAL";
HENRY JOSUE PARADA MARTINEZ, A/K/A "STREET DANGER"; EDWIN
GONZALE2, A/K/A "SANGRIENTO"; and a juvenile known to the Grand
Jury, acting deliberately with premeditated malice aforethought,
23
31
and with extreme atrocity·and cruelty, murdered Wilson Martinez,
in violation of M.G.L. Ch. 265 § 1.
(ii) On or about September 7, 2015, in East
Boston, MA, CARLOSMELARA,A/K/A "CHUCHITO, A/K/A "CRIMINAL11 ; 11
HENRYJOSUE PARADAMARTINEZ, A/K/A "STREET DANGER

11 ; EDWIN
GONZALE2, A/K/A "SANGRIENTO

11
; and a juvenile known to the Grand
Jury, ur:.lawfully killed Wilson Martinez with malice
aforethcught, in violation of M.G.L. Ch. 265 § 1.
(iii) Prior to the murder of Wilson Martinez,
NOE SALVADORPEREZ-VASQUEZ, A/K/A "CRAZY," the leader of ELS,
and OSCARDURAN, A/K/A "DEMENTE," the leader of MLS, encouraged
the above defendants to murder rival gang members and associates
to prove themselves worthy of promotion in the MS-13 criminal
organization.
After the Martinez murder, the ELS clique promoted CARLOS
MELARA,.A./K/A "CHUCHITO,11 A/K/A "CRIMINAL,11 and a juvenile known
to the Grand Jury, from chequeo to homeboy status (i.e., they
were beat into the MS-13 criminal organization), and the MLS
clique promoted HENRYJOSUE PARADAMARTINEZ, A/K/A "STREET
DANGER," from pare to chequeo, all because of their involvement
in the m·~rder. Similarly, because of his involvement in the
Martinez murder, on December 6, 2015, at Deer Island in
Winthrop, the MLS clique promoted EDWINGONZALEZ, A/K/A
"SANGRIENTO," from chequeo to homeboy in a 13-second "beat in."

24
32
Because the Molinos clique did not have enough members in
Massachusetts to "jump in" GONZALEZ,members from the ELS, EBLS,
and the MLS cliques attended tne meeting, including SANTOS
PORTILLO-ANDRADE,A/K/A "FLACO,11 the leader of EBLS; NOE
SALVADORPEREZ-VASQUEZ, A/K/A "CRAZY," the leader of ELS; OSCAR
DURAN,11./K/A "DEMENTE,11 the leader of MLS; HENRYJOSUE PARADA
MARTINE~;,A/K/A "STREET DANGER,11 a member of ELS; and CARLOS
MELARA,A/K/A "CHUCHITO, A/K/A "CRIMINAL,

11 11
a member of ELS, as
well as other members of MS-13 known to the Grand Jury.
d. The murder of Irvin De Paz.
(i) On or about September 20, 2015, in East
Boston, MA, JOEL MARTINEZ, A/K/A "ANIMAL"; and other members of
MS-13 kr.own to the Grand Jury, acting deliberately with
premeditated malice aforethought, and with extreme atrocity and
cruelty, murdered Irvin De Paz, in violation of M.G.L. Ch. 265 §
1.
(ii) On or about September 20, 2015, in East
Boston, MA, JOEL MARTINEZ, A/K/A "ANIMAL"; and other members of
MS-13 kr..own to the Grand Jury, unlawfully killed Irvin De Paz
with malice aforethought, in violation of M.G.L. Ch. 265 § 1.
(iii) Prior to the murder of Irvin De Paz, NOE
SALVADOR
PEREZ-VASQUEZ, A/K/A "CRAZY," the leader of the ELS
clique cf MS-13, encouraged the above defendant and others to
25
33
murder rival gang members and associates to prove themselves
worthy of promotion in the MS-13 criminal organization. After

1
De Paz :3 murder, the ELS clique disciplined JOEL MARTINEZ, A/K/A
"ANIMAL'' (i.e., he was beaten for 13 seconds at a clique
meeting), for outstanding violations, and did not make him a
homeboy. On January 8, 2016, the ESLS clique of MS-13 held a
clique rr.eeting at an auto repair shop in Everett, MA, during
which ESLS promoted JOEL MARTINEZ, A/K/A "ANIMAL," to homeboy
status for the murder of Irvin De Paz. HERZZONSANDOVAL,A/K/A
"CASPER,11 and EDWIN GUZMAN,A/K/A "PLAYA,11 the leaders of ESLS,
presided over the meeting. After the MS-13 members beat JOEL
MARTINEZfor 13 seconds, EDWINGUZMAN,A/K/A "PLAYA," said,
"[W]elcane to the Mara."
e. The murder of Christofer Perez-De la Cruz.
(i) On or about January 10, 2016, in East
Boston, MA, EDWINGONZALEZ,A/K/A "SANGRIENTO"; EDWINDIAZ,
A/K/A "DI~MENTE";MARVINMELGAR,A/K/A "NINJA"; and JAIRO PEREZ,
A/K/A 11
S:E!CO, acting
11
deliberately with premeditated malice
aforethot.ght, and with extreme atrocity and cruelty, murdered
Christofer Perez-De la Cruz, in violation of M.G.L. Ch. 265 § 1.
(ii) On or about January 10, 2016, in East
Boston, MA, EDWINGONZALEZ,A/K/A "SANGRIENTO"; EDWINDIAZ,
A/K/A "DEMENTE"; MARVINMELGAR,A/K/A "NINJA"; and JAIRO PEREZ,
26
34
A/K/A "SECO," unlawfully killed Christofer Perez-De la Cruz with
malice aforethought, in violation of M.G.L. Ch. 265 § 1.
(iii} In December 2015, in Richmond, Virginia,
JOSE AD.ANMARTINEZCASTRO, A/K/A "CHUCKY," the leader of MS-13's
East Coast Program in the United States, presided over a meeting
of East Coast Program clique leaders throughout the United
States, including OSCAR DURAN, A/K/A "DEMENTE," the leader of
the MLS clique in Massachusetts. During this meeting, MARTINEZ
CASTROtold the leaders that their cliques needed to be more
active in killing rival gang members.
On January 15, 2016, JOSE VASQUEZ, A/K/A "LITTLE CRAZY,"
the leader of the TLS clique of MS-13, and JAIRO PEREZ, A/K/A
"SECO, 11 attempted to hide evidence related to the murder of
Christof,~r Perez-De la Cruz, including knives and a machete used
in the murder, as well as bloody clothes worn by the
participants during the murder, by burying the evidence at a
location in Massachusetts.
ATTEMPTEDMURDERS
f. On or about March 28, 2014, in Chelsea,
Massachue:etts, HECTORRAMIRES, A/K/A \\CUERVO", attempted to
murder Victim No. 5, an individual known to the Grand Jury, by
stabbing him with a knife.
g. On or about April 6, 2014, in Chelsea,
Massachusetts, RAFAEL LEONER-AGUIRRE,A/K/A "TREMENDO",
27
35
attempted to murder Victim No. 6 and Victim No. 7 1 individuals
known tJ the Grand Jury, by attacking them with a machete, and
strikin3" Victim No. 6.
h. On or about April 16, 2014, in Chelsea,
Massachusetts, RAFAEL LEONER-AGUIRRE,A/K/A \\TREMENDO";JOSUE
MORALES,A/K/A \\GALLITO"; and KEVIN AYALA, A/K/A \\BLANCITO, 11
agreed to, and attempted to, murder Victim No. 9 and Victim No.
10, individuals known to the Grand Jury, by shooting at Victim 9
and Victim 10 with a gun and striking Victim 9.
i. On or about May 29, 2014, in Chelsea,
Massachusetts, DANIEL MENJIVAR, A/K/A \\ROCA,11 A/K/A \'SITIKO";
and DAVID LOPEZ, A/K/A "CILINDRO, 11 A/K/A \\VILLANO," agreed to,
and attempted to, murder Victim No. 11, an individual known to
the Grand Jury, by stabbing Victim 11 with a knife and shooting
Victim 11 with a gun.
j. On or about September 8, 2014, in Chelsea,
Massachusetts, ANGEL PINEDA, A/K/A \\BRAVO

I II A/K/A \\JOSE LOPEZ11 i
JOSE VASQUEZ, A/K/A '\LITTLE CRAZY"; and BRYANGALICIA-BARILLAS,
A/K/A \\C:{UCKY, agreed 11

to, and attempted to, murder Victim No.
12, an individual known to the Grand Jury, by stabbing him with
a knife.
k. On or about December 4, 2014, in Somerville,
Massachunetts, JOSE RENE ANDRADE,A/K/A \\TRISTE, II A/K/A
\\INNOCEN~:E"
; and MARIOAGUILARRAMOS, agreed to, and at tempted
28
36
to, murder Victim No. 13, Victim No. 14 and Victim No. 15,
individuals known to the Grand Jury, by attacking Victim No. 13,
Victim Uo. 14, and Victim No. 15 with a knife and stabbing
Victim No. 13.
1. On or about January 13, 2015, in Lynn,
Massacht:setts, HENRYSANTOS-GOMEZ,A/K/A "RENEGADO," A/K/A
"PINO, 11 attempted to murder Victim No. 16, an individual known
to the Grand Jury, by shooting Victim No. 16 with a gun.
m. From a time unknown to the Grand Jury, but at
least by in or about March 2015, and continuing thereafter until
at least April 2015, in Chelsea, and in the District of New
Jersey, and elsewhere, DANIEL MENJIVAR, A/K/A "ROCA,11 A/K/A
"SITIKO 11 ; DAVID LOPEZ, A/K/A "CILINDRO," A/K/A "VILLANO"; BRYAN
GALICIA-BARILLAS, A/K/A \\CHUCKY";RAFAEL LEGNER-AGUIRRE,A/K/A
"TREMENDO
11
i and FNU LNU, A/K/A "VIOLENTO," agreed to, and
attempted to, murder Victim No. 22, an individual known to the
Grand Jury, with a machete.
Prior to the attempted murder of Victim No. 22, RAFAEL
LEONER-AGUIRRE,A/K/A "TREMENDO,"the leader of the Enfermos in
Chelsea, Massachusetts, told MS-13 leadership that Victim No. 22
was coope.rating with law enforcement, and FNU LNU, "VIOLENTO," a
leader of the Enfermos in Arizona, gave the order to kill Victim
No. 22,
29
37
n. On or about May 12, 2015, in Chelsea,
Massach1setts, JOSE HERNANDEZ-MIGUEL,

A/K/A "MUERTO"; and LUIS
SOLIS-VASQUEZ, A/K/A "BRUJ0, 11

agreed to, and attempted to,
murder 'lictim No. 1 7, an individual known to the Grand Jury, by
stabbin9 him with a knife.
o. On or about May 26, 2015, in Chelsea,
Massachusetts, BRYANGALICIA-BARILLAS, A/K/A "CHUCKY"; and
DOMINGOTIZOL, A/K/A "CHAPIN," agreed to, and attempted to,
murder Victim No. 18 and Victim No. 19, individuals known to the
Grand Jury, by attacking Victim No. 18 and Victim No. 19 with a
knife and stabbing Victim No. 19.
p. On or about August 23, 2015, in Chelsea,
Massachusetts, EDWIN GONZALEZ,A/K/A "SANGRIENT0,11 attempted to
murder Victim No. 20 and Victim No. 21, individuals known to the
Grand Jury, by attacking Victim No. 20 and Victim No. 21 with a
machete, striking Victim No. 20.
q. On or about December 27, 2015, in Chelsea,
Massachusetts, JOEL MARTINEZ, A/K/A "ANIMAL"; and MAURICIO
SANCHEZ, A/K/A \\TIGRE, 11 and others known to the Grand Jury,
agreed to, and attempted to, murder Victim No. 23, an individual
known to the Grand Jury, by stabbing him with a knife.
r. On or about December 7 1 2008, in Malden,
Massachusetts, GERMANHERNANDEZ
I a/k/a ''TERIBLE" i and SANTOS
PORTILLO-ANDRADE,a/k/a ''FLACO,II agreed to, and attempted to,
30
38
murder ,,ictim No. 24, an individual known to the Grand Jury, by
hitting Victim No. 24 over the head with an aluminum baseball
bat.
30. Further means and methods of the conspiracy included
numerouf! acts of trafficking in illegal controlled substances,
including cocaine, cocaine base, heroin, and marijuana, which
leaders, members, and associates of the MS-13 criminal
enterprise engaged in to generate income for MS-13. Those acts
included, among others, the following:
DRUG TRAFFICKING
a. Starting in at least October 2013, and continuing
until at. least July 2014, at Chelsea, East Boston, and elsewhere
in the District of Massachusetts, JOSE HERNANDEZ-MIGUEL, A/K/A
"MUERTO," knowingly and intentionally conspired with Manuel
Martine2;, A/K/A "Gordo"; Manuel Flores, A/K/A "Manny"; Ramiro
Guerra, A/K/A "Camella," and others to possess with intent to
distribute and to distribute cocaine, a Schedule II controlled
substance, and cocaine base, a Schedule II controlled substance,
all in violation of Title 21, United States Code, Section 846.
b. Starting in at least February 2014, and
continuing until at least December 2014, in Saugus, and
elsewhere in the District of Massachusetts, and in Salem, and
elsewhere in the District of New Hampshire, NOE SALVADOR PEREZ-
VASQUEZ, A/K/A "CRAZY"; JOSE HERNANDEZ-MIGUEL, A/K/A "MUERTO";
31
39
CESAR MA.RTINEZ,A/K/A "CHECHE";
; FNU LNU A/K/A "CABALLO"; ERICK ARGUETALARIOS, A/K/A
"LOBO"; and JOSE MIGUEL-HERNANDEZ,A/K/A "SMILEY," A/K/A
"DANGER," knowingly and intentionally conspired with each other,
and othHrs, to possess with intent to distribute and to
distribute cocaine, a Schedule II controlled substance, all in
violatiCJn of Title 21, United States Code, Section 846.
This conspiracy involved five kilograms or more of a
mixture and substance containing a detectable amount of cocaine,
a Schedule II controlled substance, in violation of Title 21,
United States Code, Section 841(b) (1) (A). Accordingly, Title
21, United States Code, Section 84l(b) (1) (A) (ii) is applicable
to this =onspiracy.
c. Starting in at least March 2015, and continuing
until at least in or about October 2015, at Boston, Lynn,
Everett, Revere, and elsewhere in the District of Massachusetts,
SANTOSPORTILLO-ANDRADE,A/K/A "FLACO"; EDGARPLEITEZ, A/K/A
"CADEJO 11
• CHRISTIAN ALVARADO,A/K/A "CATRACHO, knowingly 11
and
intentionally conspired with each other and with FNU LNU, A/K/A
"The Columbian 1
'; Carlos Lovato; FNU LNU, A/K/A "Migue 11
; and Luis
LNU; and others, to possess with intent to distribute and to
distribute heroin, a Schedule I controlled substance, and
cocaine, a Schedule II controlled substance, all in violation of
Title 21, United States Code, Section 846.
32
40
Thi= conspiracy described herein involved 100 grams or more
of a mixture and substance containing a detectable amount of
heroin, a Schedule I controlled substance, in violation of Title
21, United States Code, Section 841(b) (1) (B). Accordingly, Title
21, United States Code, Section 841(b) (1) (B) (i) is applicable to
this cor:.spiracy.
The conspiracy described herein also involved 500 grams or
more of a mixture and substance containing a detectable amount
of cocaine, a Schedule II controlled substance, in violation of
Title- 21, United States Code, Section 84l(b) (1) (B). Accordingly,
Title 21, United States Code, Section 841 (b) (1) (B) (ii) is
applicable to this conspiracy.
d. Starting in at least 2014, and continuing until
January :1016, at Somerville and elsewhere in the District of
MassachuBetts, GERMANHERNANDEZ,A/K/A 11
TERIBLE"i NOE SALVADOR
PEREZ-VAHQUEZ,A/K/A "CRAZY"i JOSE RENE ANDRADE, A/K/A "TRISTE,"
A/K/A "INOCENTE"; and RUTILIO PORTILLO, A/K/A "PANTERA,"
knowingly and intentionally conspired with each other and with
others tci possess with intent to distribute and to distribute
marijuana., a Schedule I controlled substance, all in violation
of Title 21, United States Code, Section 846.
31, The means and methods of the conspiracy also included
conspiracy to commit, and the commission of, robberies,
including armed robberies, in part to generate income for MS-13.
33
41
These conspiracies to rob and robberies included, among others,
the following:
a. On or about April 9, 2014, in Chelsea,
Massachusetts, HECTORRAMIRES, A/K/A "CUERVO", robbed Victim No,
8, an individual known to the Grand Jury, with a gun.
1962 (d) .
34
42
COUNT T::IREE: (21 u.s.c. § 846--Conspiracy to Distribute

Cocaine)
32 From a time unknown to the Grand Jury, but at least by
in or about February 2014, and continuing thereafter until at
least in or about De.cember 2 014, at Saugus, and elsewhere in the
District of Massachusetts, and at Salem, and elsewhere in the
District of New Hampshire,
4. NOE SALVADOR PEREZ-VASQUEZ~ A/K/A "CRAZY,"

12.
13. FNU LNU A/K/A "CABALL0, 11
14. ERICK ARGUETA LARIOS, A/K/A "LOBO," and
16. JOSE MJ:GUEL-HERNANDEZ,A/K/A "SMILEY,"
A/K/A "DANGER,"
the defendants herein, did knowingly and intentionally combine,
conspire, confederate, and agree with each other, and with other
persons known and unknown to the Grand Jury, to possess with
intent to distribute and to distribute cocaine, a Schedule II
controlh::d substance, in violation of Title 21, United States
Code, se,:tion 841 (a) (1).
33. The Grand Jury further charges that the conspiracy
described herein involved five kilograms or more of a mixture
and substance containing a detectable amount of cocaine, a
Schedule II controlled substance, in violation of Title 21,
United St:ates Code, Section 841 (b) ( 1) (A) . Accordingly, Title
35
43
21, United States Code, Section 841(b) (1) (A) (ii), is applicable
to this Count.
34. The Grand Jury further charges that five kilograms or
more of a mixture and substance containing a detectable amount
of cocaine, a Schedule II controlled substance, are attributable
to and "rere reasonably foreseeable by the following defendants:

13. FNU LNU A/K/A "CABALLO,"
14. ERICK ARGUETALARIOS, A/K/A "LOBO," and
16. JOSE MIGUEL-HERNANDEZ,A/K/A "SMILEY,"
A/K/ A "DANGER''
Accordingly, Title 21, United States Code, Section
84l(b) (1) (A} (ii), is applicable to this Count as to these four
defendar..ts.
35. The Grand Jury further charges that 500 grams or more
cocaine, a Schedule II controlled substance, are attributable to
and were reasonably foreseeable by the following defendants:

11. CESAR MARTINEZ, A/K/A "CHECHE," and
12.
Accordir,.gly, Title 21, United States Code, Section
84l(b} (J) (B) (ii), is applicable to this Count as to these three
defendar.ts.
846.
36
44
COUNT FOUR: (18 U.S.C. § 924(c) (1)--Possession of a Firearm

in Furtherance of a Drug Trafficking Crime)
36. On or about December 8, 2014, at Saugus, in the
District. of Massachusetts,
the defendant herein, knowingly possessed a firearm, to wit: a
black .380 handgun, in furtherance of a drug trafficking crime,
to wit: conspiracy to possess with intent to distribute and to
distrib1.:.te cocaine, a Schedule II controlled substance, in
violaticn of 21 U.S.C. § 846, as charged in Count Three of this
Second Euperseding Indictment.
924(c)(l).
37
45
COUNTF:CVE: (21 u.s.c. § 846--Conspiracy to Distribute Heroin

and Cocaine)
37, From a time unknown to the Grand Jury, but at least by
in or about March 2015, and continuing thereafter until at least
in or about October 2015, at Boston, Lynn, Everett, Revere, and
elsewheLe in the District of Massachusetts,
5. SANTOS PORTILLO-ANDRADE,A/K/A "FLACO,"

46. FNU LNU, A/K/A "THE COLUMBIAN,"
47. CARLOS LOVATO,
48. FNU LNU, A/K/A "MIGUE," and
49. LUIS LNU,
the defe:1.dants herein, did knowingly and intentionally combine,
conspire. confederate, and agree with each other, and with other
intent to distribute and to distribute heroin, a Schedule I
controllEid substance, and cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Section
841 (a) (1).
38. The Grand Jury further charges that the conspiracy
described herein involved 100 grams or more of a mixture and
substance containing a detectable amount of heroin, a Schedule I
controlled substance, in violation of Title 21, United States
Code, Section 841(b) (1) (B). Accordingly, Title 21, United States
Code, Section 841{b) (1) {B} (i} is applicable to this Count.
38
46
39 The Grand Jury further charges that the conspiracy
describE:d herein involved 500 grams or more of a mixture and
substance containing a detectable amount of cocaine, a Schedule
II controlled substance, in violation of Title 21, United States
Code, Section 841(b) (1) (B}. Accordingly, Title 21, United States
Code, Section 841 (b) (1) (B} (ii) is applicable to this Count.
heroin are attributable to and were reasonably foreseeable by
the following defendants:
5. SANTOS PORTILLO..ANDRADE, A/K/A "FLACO,"

9. EDGARPLEITEZ, A/K/A "CADEJO,"
49. LUIS LNU,
Accordin3ly, Title 21, United States Code, Section
841(b} (1) (B) (i), is applicable to this Count as to these five
defendants.
of a mixT::.ure and substance containing a detectable amount of
cocaine are attributable to and were reasonably foreseeable by
the following defendant:
S. SANTOS PORTILLO-ANDRADE,A/K/A "FLACO"
Accordin!Jly, Title 21, United States Code, Section
84l(b) (l:· (B) (ii) is applicable to this Count as to this
defendant.
39
47
846.
40
48
COUNT S'.CX: (18 u.s.c. § 924(c) (1)--Possession of a Firearm

in Furtherance of a Drug Trafficking Crime)
42. On or about October 25, 2015, at Boston, Lynn,
Everett, and Revere, in the District of Massachusetts,
the defemdant herein, knowingly possessed a firearm, to wit: a
9 millimeter Luger semi-automatic pistol, bearing serial number
PO93088, in furtherance of a drug trafficking crime, to wit:
conspira.cy to possess with intent to distribute and to
distribt:.te heroin, a Schedule I controlled substance, in
violation of 21 U.S.C. § 846, as charged in Count Five of this
Second Superseding Indictment.
924(c) (1).
41
49
COUNT s:aVEN: (21 u.s.c. S 846--Conspiracy to Distribute

Cocaine and Cocaine Base)
43. From a time unknown to the Grand Jury, but at least by
in or about October 2013, and continuing thereafter until at
least in or about July 2014, at Chelsea, East Boston, and
elsewheJ:e in the District of Massachusetts,
8. JOSE HERNANDES-MIGUEL,A/K/A "MUERTO,"

41. RAMIROGUERRA, A/K/A "CAMELLO,"
42. MANUELMARTINEZ, A/K/A "GORDO," and
44. MANUELFLORES-VALLE, A/K/A "MANNY,"
the defemdants herein, did knowingly and intentionally combine,
conspire?, confederate, and agree with each other, and with other
intent to distribute and to distribute cocaine, a Schedule II
controlled substance, and cocaine base, a Schedule II controlled
substance, in violation of Title 21, United States Code, Section
841 (a) (l).
846.
42
50
COUNTEJ:GHT: (21 U.S.C. § 84l(a) (1)--Distribution of Cocaine

Base)
44. On or about August 7, 2013, at Chelsea, in the
43 • ALEXANDER ALVARENGA,
the defe:ndant herein, did knowingly and intentionally possess
with intent to distribute and distribute cocaine base, a
Schedule: II controlled substance.
Al] in violation of Title 21, United States Code, Section
841 {a) (l) .
43
51
COUNT N:CNE: (21 u.s.c. § 841(a) (1)--Distribution of Cocaine

Base)
45 On or about August 21, 2013, at Chelsea, in the
43. ALEXANDER ALVARENGA,
the defendant herein, did knowingly and intentionally possess
with intent to distribute and distribute cocaine base, a
Schedule II controlled substance.
841 (a) (l) .
44
52
COUNTTUN: (21 u.s.c. § 84l(a} (1)--Distribution of Cocaine)
46. On or about September 3, 2015, at Chelsea, in the
45. HEINER YOVANI GOMEZ, A/K/A "FIERO,"
the defe:ndant herein, did knowingly and intentionally possess
with intent to distribute and distribute cocaine, a Schedule II
controlled substance.
841 (a) (1).
45
53
COUNTELEVEN: (21 U.S.C. § 846--Conspiracy to Distribute

Marijuana)
47. From a time unknown to the Grand Jury, but at least by
in or about 2014, and continuing thereafter until January 2016,
at Somerville, and elsewhere in the District of Massachusetts,
3. GERMANHERNANDEZ,A/K/A "TERIBLE,"
19. JOSE RENE ANDRADE, A/K/A "TRISTE," A/K/A
"INNOCENTE," and
37. RUTILIO PORTILLO, A/K/A "PANTERA"
the defemdants herein, did knowingly and intentionally combine,
conspire, confederate, and agree with other persons known and
unknown to the Grand Jury, to possess with intent to distribute
and to distribute marijuana, a Schedule I controlled substance,
in violcition of Title 21, United States Code, Section 841 (a) (1).
846.
46
54
COUNT TWELVE: (18 U.S.C. § 922(g) (5) (A)--Alien in Possession

of a Firearm and Ammunition)
48. On or about August 5, 2008, at Somerville, in the
the defendant herein, an alien who was then illegally and
unlawfully in the United States, did knowingly possess in and
affectir..g commerce a firearm and ammunition, to wit: a 9
millimeter Beretta semi-automatic pistol bearing serial number
889945 and eight rounds of Winchester brand .380 caliber
ammunition.
922 (g) (5) (A) •
47
55
COUNT THIRTEEN: (18 u.s.c. § 1546(a)--Possession of a

Counterfeit Resident Alien Card)
49, On or about December 16, 2015, at Boston and
Burlington, in the District of Massachusetts,
50. JOSE NELSIN REYES-VELASQUEZ, A/K/A "DIABLIT0, 11
the defendant herein, did knowingly possess a document
prescribed by statute and regulation for entry into, and as
evidence of authorized stay and employment in the United States,
that is, a Permanent Resident Alien Card, knowing it to be
forged, counterfeited, altered, and falsely made.
1546 (a) .
48
56
COUNTFOURTEEN: (42 u.s.c. § 408 (a) (7) (C)--Purchase of

a Fraudulent Sociai Security Card)
50. In or about April 2015, at Boston, in the District of
Massachusetts,
50. JOSE NELSIN REYES-VELASQUEZ, A/K/A "DIABLITO, 11
the defemdant herein, knowingly bought a card that was, and
purportE!d to be, a card issued by the Commissioner of Social
Security, for the purpose of obtaining something of value from
any peri:::on and for any other purpose, to wit: as a means of
identification to secure employment.
408 {a) (7) {C} •
49
57
COUNTFIFTEEN: (18 U.S.C. § 1028(a) (2)--Transfer of False

Identification Document)
51. On or about June 4, 2014, at Chelsea, in the District
of Mass,ichusetts,
51. OSCAR RIVERA, A/K/A "JOSE,"
the def13ndant herein, did knowingly transfer a false
identif.Lcation document, to wit, a fraudulent social security
card and fraudulent resident alien card, knowing that such
documen':s were produced without lawful authority, and such
identification documents were and appeared to be documents
issued by and under the authority of the United States, and the
transfe:::- of such documents was in and affected interstate and
foreign commerce.
1028 (a) (2) .
50
58
COUNT SU:TEEN: (18 U. S.C. § 1028 (a) (2) --Transfer of False

Identification Document)
The Grancl Jury further charges that:
52. On or about June 14, 2014, at Chelsea, in the District
of Massachusetts,
52. ROBERTOA. LOPEZ,
the defendant herein, did knowingly transfer a false
identification document, to wit, a fraudulent social security
card and fraudulent resident alien card, knowing that such
documentH were produced without lawful authority, and such
identification documents were and appeared to be documents
issued by and under the authority of the United States, and the
transfer of such documents was in and affected interstate and
foreign 1:!ommerce.
1028 (a) ( .2) •
51
59
COUNTSHVENTEEN: (8 U.S.C. § 1326--Unlawful Re-entry of

Deported Alien)
53. On or about April 14, 2015, at Boston, in the District
of MasSclchusetts,
53. FRANKLIN RODRIGUEZ, A/IC/A "HOLLYWOOD,"
the def;~ndant herein, being an alien and having been excluded,
removed, and deported from the United States on or about August
21, 2006, was found in the United States without having received
the express consent of the Secretary of the Department of
Homeland Security to reapply for admission to the United States.
1326(a), and Title 6, United States Code, Sections 202(3)-(4),
and 557.
52
60
COUNT E:CGHTEEN: (8 u.s.c. § 1326--Unlawful Re-entry of

Deported Alien)
54. On or about July 7, 2015, at Boston, in the District
of Massachusetts,
54. OSCAR RAMIREZ-CORNEJO, A/K/A "VAGO,"
the def,~ndant herein, being an alien and having been excluded,
removed, and deported from the United States on or about July
11, 200B, was found in the United States without having received
the ex:press consent of the Secretary of the Department of
Homeland Security to reapply for admission to the United States.
1326(a}, and Title 6, United States Code, Sections 202(3}-(4},
and 557.
53
61
COUNT N::NETEEN: (8 u.s.c. § 1326--Unlawful Re-entry of

Deported Alien)
55. On or about December 6, 2015, at Winthrop, in the
57. ELENILSON GUSTAVOGONZALEZ-GONZALEZ,A/K/A

"SINIESTRO,"
the defendant herein, being an alien and having been excluded,
removed, and deported from the United States on or about May 21,
2012, Wets found in the United States without having received the
express consent of the Secretary of the Department of Homeland
Security to reapply for admission to the United States.
1326 (a), and Title 6, United States Code, Sections 202 (3) - (4},
and 557.
54
62
RICO FORFEITURE ALLEGATIONS

(18 u.s.c. § 1963)
The: Grand Jury further charges that:
56. The allegations of Count Two of this Second
Superseding Indictment are hereby re-alleged and incorporated by
reference for the purpose of alleging forfeiture pursuant to
Title lE, United States Code, Section 1963.
57. Upon conviction of the offense in violation of Title
18, United States Code, Section 1962, set forth in Count Two of
this Second Superseding Indictment,
1. OSCAR NOE RECINOS-GARCIA, A/K/A "PSYCHO,"

2. JULIO ESAU AVALOS-ALVARADO, A/K/A "VIOLENTO,"
3. GERMANHERNANDEZ-ESCOBAR,A/K/A "TERIBLE,"
6. HERZZON SANDOVAL, A/K/A "CASPER,"
7. EDWIN GUZMAN, A/K/A "PLAYA,"
10. CHRISTIAN ALVARADO, A/K/A "CATRACHO,"
12.
14. ERICK ARGUETA LARIOS, A/K/A "LOBO,"
A/K/A "DANGER,"
17. CARLOS MELARA, A/K/A "CHUCHITO,"
A/K/A "CRIMINAL,"
A/K/A "INNOCENTE,"
A/K/A "PINO,"
22. RAFAEL LEONER-AGUIRRE, A/K/A "TREMENDO,"
23. HECTOR RAMIRES, A/K/A "CUERVO,"
55
63

27. DAVID LOPEZ, A/K/A "CILINDRO", A/K/A "VILLANO,"
29. DOMINGOTIZOL, A/K/A "CHAPIN,"
36. MARIO AGUILAR RAMOS,
55 . MAURICIO SANCHEZ,A/K/ A "TIGRE," and
56. JOSE ADAN MARTINEZCASTRO, A/K/A "CHUCKY"
the defendants herein, shall forfeit to the United States,
jointly and severally, pursuant to Title 18, United States Code,
Section 1963:
(a) all interests the defendants have acquired or
maintain.ed in violation of Title 18, United States Code, Section
1962, wherever located, and in whatever names held;
(b) all interests in, securities of, claims against,
or properties or contractual rights of any kind affording a
source of influence over, any enterprise which the defendants
have established, operated, controlled, conducted, or
partici:pated in the conduct of, in violation of Title 18, United
States Code, Section 1962; and
(c) all property constituting, and derived from, any
proceedE which the defendants obtained, directly and indirectly,
56
64
from racketeering activity and unlawful debt collection in
violation of Title 18, United States Code, Section 1962.
58. If any of the property described in paragraph 57
hereof as being forfeitable pursuant to Title 18, United States
Code, Section 1963, as a result of any act and omission of the
defendants --
(a) cannot be located upon the exercise of due

diligence;
{b) has been transferred to, sold to, or deposited

with a third party;
(c) has been placed beyond the jurisdiction of this

Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which

cannot be divided without difficulty;
it is the intention of the United States, pursuant to Title 18,
United States Code, Section 1963(m), to seek forfeiture of any
other property of the defendants up to the value of the property
described in paragraph 57 above.
Al:. pursuant to Title 18, United States Code, Section 1963.
57
65
DRUG FORFEITUREALLEGATIONS
(21 u.s.c. § 853)
59. The allegations of Counts Three, Five, and Seven
through Eleven of this Second Superseding Indictment are hereby
re-alle9ed and incorporated by reference for the purpose of
allegin9 forfeiture pursuant to Title 21, United States Code,
Section 853.
60. Upon conviction of one or more of the offenses alleged
in Counts Three, Five, and Seven through Eleven of this Second
Superseding Indictment,
3. GERMANHERNANDEZ-ESCOBAR,A/K/A "TERIBLE"
5. SANTOS PORTILLO-ANDRADE,A/K/A "FLACO,"
12.
13. FNU LNU A/K/A "CABALLO,"
14. ERICK ARGUETALARIOS, A/K/A "LOBO," and
16. JOSE MIGUEL-HERNANDEZ,A/K/A "SMILEY,"
A/K/A "DANGER,"
19. JOSE RENE ANDRADE, A/K/A "TRISTE," A/K/A
"INNOCENTE,"
41. RAMIROGUERRA, A/K/A "CAMELLO,"
42. MANUELMARTINEZ, A/K/A "GORDO,"
43. ALEXANDERALVARENGA,
44. MANUELFLORES-VALLE, A/K/A ''MANNY,"
45. HEINER YOVANI GOMEZ, A/K/A "FIERO,"
46. FNU LNU, A/K/A "THE COLUMBIAN,"
47. CARLOS LOVATO,
49. LUIS LNU,
58
66
the defe?ndants herein, shall forfeit to the United States,
jointly and severally as to Counts Three, Five, Seven, and
Eleven, pursuant to 21 U.S.C. § 853, any and all property
constituting, or derived from, any proceeds the defendant
obtained, directly or indirectly, as a result of such offenses;
and/or a.ny property used or intended to be used, in any manner
or part, to commit, or to facilitate the commission of, any such
violations.
61, If any of the property described in paragraph 60,
above, as a result of any act or omission of the defendants
{a) cannot be located upon the exercise of due

diligence;
{b) has been transferred or sold to, or deposited

with, a third party;
(c) has been placed beyond the jurisdiction of the

Court;
{e) has been commingled with other property which

it is the intention of the United States, pursuant to 21 U.S.C.
§ 853{p), to seek forfeiture of any other property of the
defendant up to the value of the property described in paragraph
60.
All pursuant to Title 21, United States Code, Section 853.
59
67
FIREARMS FORFEITURE ALLEGATIONS

(18 U.S.C. § 924(d) and 28 u.s.c. § 246l(c))
62. The allegations of Counts One, Four, Six, and Twelve
of this Second Superseding Indictment are hereby re-alleged and
incorpOJ:ated by reference for the purpose of alleging forfeiture
pursuant to Title 18, United States Code, Section 924(d) and
Title 2H, United States Code, Section 2461(c}.
63. Upon conviction of one or more offenses alleged in
Counts One, Four, Six, and Twelve of this Second Superseding
Indictment,
1. OSCAR NOE RECINES-GARCIA, A/K/A "PSYCHO,"

2. JULIO ESAU AVALOS-ALVARADO,A/K/A "VIOLENTO,"
4. NOE SALVADORPEREZ-VASQUEZ, A/K/A
"CRAZY,"
5. SANTOS PORTILLO-ANDRADE, A/K/A "FLACO," and
pursuant to 18 U.S.C. § 924(d) and 28 U.S.C. § 246l(c}, any
firearm or ammunition involved in, or used in, any knowing
commission of the offense, including but not limited to the
following:
(a) one .22 caliber Sterling model semi-automatic pistol

bearing serial number A14546;
(bl twelve rounds of .22 caliber ammunition;
(c) one .380 caliber Cobra Enterprises Model CA-380 semi-
automatic pistol bearing serial number CP033661;
(d) one 9 millimeter Luger model semi-automatic pistol,
bearing serial number P093088; and
60
68
(e) one 9 millimeter Beretta model semi-automatic pistol,

bearing serial number 889945, and eight rounds of
Winchester brand ammunition.
64. If any of the property described in paragraph 63,
above, as a result of any act or omission of any of the
defendants -
(a) cannot be located upon the exercise of due diligence;
(a} has been transferred or sold to, or deposited with, a

third party;
(c) has been placed beyond the jurisdiction of the Court;
(e) has been commingled with other property which cannot

be divided without difficulty;
it is the intention of the United States, pursuant to Title 21,
United States Code, Section 853(p), as incorporated in Title 28,
United States Code, Section 2461{c}, to seek forfeiture of any
other property of the defendants up to the value of the property
described in paragraph 63.
All pursuant to Title 18, United States Code, Section
924{d) and Title 28, United States Code, Section 246l{c).
61
69
IDENTIFICATION FRAUD FORFEITURE ALLEGATIONS

(180.S.C. §982(a)(2)(B) & (a)(6)(ii))
65, The allegations of Counts Thirteen, Fifteen, and
Sixteen of this Second Superseding Indictment are hereby re-
alleged and incorporated by reference for the purpose of
allegin9 forfeiture pursuant to Title 18, United States Code,
Section 982 (a) (2) (B) & (a) (6) (A) {ii).
66 Upon conviction of one or more offense alleged in
Counts ~~hirteen, Fifteen, and Sixteen of this Second Superseding
IndictmEmt,
SO. JOSE NELSIN REYES-VELAZQUEZ, A/K/A "DIABLITO,"

51. OSCAR RIVERA, A/K/A "JOSE," and
52. ROBERTOA. LOPEZ,
pursuant to 18 U.S.C. § 982{a)(2)(B) &(a)(6)(ii):
(i) any property, real or personal, constituting, or
derived from, proceeds the defendant obtained, directly or
indirectly, as a result of such offense; and
(ii) any property, real or personal, used to facilitate, or
is intended to be used or facilitate, the commission of the
offense1;: of which the defendants are convicted.
67. If any of the property described in paragraph 66,
above, a.s a result of any act or omission of the defendants
{a) cannot be located upon the exercise of due

diligence;
62
70
(b) has been transferred or sold to, or deposited

with, a third party;
(c) has been placed beyond the jurisdiction of the

Court;
(e) has been commingled with other property which

it is tbe intention of the United States, pursuant to 21 U.S.C.
§ 853(p), as incorporated by 18 U.S,C. § 982(b) (1), to seek
forfeiture of any other property of the defendant up to the
value of the property described in paragraph 66.
All pursuant to Title 18, United States Code, Section
982 (a) (2) (B) & (a) (6) (ii).
63
71
A TRUE BILL,
~AA~
FPERNO~E GRAND JURY
..
_D;Z##f:_
PETER I~. LEVITT
CHRIS~C'<lPHERPOHL
Assistant U.S. Attorneys
DISTR::CT OF MASSACHUSETTS January 26, 2016
HE!turned into the District Court by the Grand Jurors and

filed.
64
72
Case 8:17-cr-00382-PX Document 79 Filed 11/29/17 Page 1 of 25
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UNITED STATES :* f!i~~_-_"_ ,,'-~~~y~
* ['"-- ~- .. , -~-(
v. * CRIMINAL NO. PX-17-0382
CRIMINAL
*
CARLOS
CARLOS ROBERTO TEJADA- TEJADA- * (Conspiracy to Participate in a
CRUZ,,
CRUZ * Enterprise,e, 18 U.S.C.
Racketeering Enterpris U.S.c.
a/kla "Krusty,"
a/k/a "Krusty," * Conspiracy to Commit
§ 1962(d); Conspiracy
~
KEVIN ALEXIS HERNANDEZ-
KEVIN * Murder in Aid of Ra. cketeering ,
Racketeering,
GUEVARA,,
GUEVARA * 18 U.S.C.
U.S.c. ~§ 1959(a)(5); Conspiracy
Conspiracy
a/kla "Stop ,"
a/k/a "Stop," * Distribnte and to Possess with
to Distribute
JUAREZ-
ARISTIDES JUAREZ-
ROLANDO ARISTIDES * Controlled
Intent to Distribute Controlled
VASQUEZ, ,
VASQUEZ * Substances , 21 U.S.C.
Substances, U.S.c. ~§~§ 846, 841(a)(I)
841(a)(l)
a/kla " Virus ,"
a/k/a "Virus," * Conspirac y to
841(b)( l )(B)(i); Conspiracy
and 84I(b)(I)(B)(i);
a/kla "Daffy ,"
a/k/a "Daffy," * Commerce
Interfere with Interstate Commerce
JEFFRY RODRIG
RODRIGUEZ,UEZ , * Extortion, , 18 U.S.C.
by Extortion U.S.c. ~§ 1951(a);
a/k/a "Hyper ,"
a/kla "Hyper," * Forfeiture, , 18 U.S.C. ~
Forfeiture 981(a)(l)(C) ,
§ 981(a)(1)(C),
JUNIOR
JUNIOR NOE ALVARADO-
ALVARADO- * 18 U.S.C. ~ § 1963(a)(3),
I963(a)(3), 21 U.S.C. § 853,
U.S.c. ~
REQUENO ,
REQUENO, * 28 U.S.C.
U.S.c. § ~ 2461(c))
2461(c»
a/kla "Insolente ,"
a/k/a "Insolente," *
a/kla "Trankilo,"
a/k/a "Trankilo ," *
EDUARDO
MICHAEL EDUARDO *
CONTRERAS,
CONTRERAS, *
a/kla
a/k/a "Katra,"
"Katra ," *
a/kla "lnsoportabIe,"
a/k/a "Insoportable ," *
LUIS FERNANDO ORELLANA-
ORELLANA- *
ESTRADA, ,
ESTRADA *
a/kla "Pinguino ," and
a/k/a "Pinguino," *
DONALD ROBERTO MENDEZ- *
LOPEZ, *
a/kla
a/k/a "Chuekie,"
" Chuckie ," *
*
Defendants *
*
***** *j:
*******
FOlmTH
FO URTH SUPERSEDING INDICTMENT
SUPERS EDING INDICTME NT
COUNT
COUN T ONE
(Conspiracy
(Conspirac y to Participate in a Racketeering Enterprise)
Enterprise)
The Grand Jury for the District

The Grand District of Maryland
Maryland charges that:
charges that:
73
At all times
times relevant
relevant to this Fourth Superseding Indictment:
Fourth Superseding Indictment:
Introduction
Introduction
1. La Mara Salvatru cha, also known

Salvatrucha, known as the MS-13 gang ("MS-13
MS-13 gang "), was
("MS-13"), was a gang
gang
composed
composed primarily
primarily of immigrants
immigrants or descendants
descendants of immigrants from El Salvador,
immigrants from Salvador with
members
members operating in the State
operating iiJ State of Maryland
Maryland, , including
including in Montgomery
Montgomery County
County and Prince
Prince
George's County,
George's County, and
and throughout
throughout the United States.
States.
2. The name "Mara

The "Mara Salvatrucha"
Salvatrucha" was combination of several
was a combination several slang
slang terms.
terms. The
The
word "Mara"
word "Mara" was the term
term used in El Salvador
Salvador for "gang." The phrase
"gang." The "Salvatrucha" was a
phrase "Salvatrucha"
combination of the words

combination "Salva ," which
words "Salva," was an abbreviation
which was abbreviation for "Salvadoran,"
"Salvadoran ," and
and "trucha,"
"trucha,"
which
which was a slang
slang term
term for "fear
"fear us
us,"" "look out," or "heads
"look out," "heads up."
up."
3.
3. In the United States MS-13
United States, MS-13 has been
been functioning
functioning since
since at least
least the 1980s.
1980s. MS-13
MS-13
originated in Los Angeles,

originated California, where
Angeles, California MS-13 members
where MS-13 banded together
members banded together for protection
protection
against the larger

against larger Mexican groups. MS-13
Mexican groups. MS-13 evolved
evolved into a gang
gang that
that engaged
engaged in turf
turf wars
wars for the
control
control of drug
drug distribution locations. MS-13
distribution locations. MS-13 quickly
quickly spread
spread to states
states across
across the country,
country,
including Maryland.
including Maryland.
4. MS-13
MS-13 was a national and international
national and criminal organization
international criminal organization and
and was
was one
one of the
largest
largest street gangs in the United States.
street gangs Gang members
States. Gang members actively
actively recruited members , including
recruited members, including
juveniles, from communities

juveniles , from communities with
with a large number of Salvadoran
large number immigrants. .
Salvadoran immigrants
5. CARLOS ROBERTO TEJADA-CRUZ,

CARLOS ROBERTO TEJADA-CRUZ, a/k/a
a/k/a "Krusty";
"Krusty"; KEVIN ALEXIS
ALEXIS
HERNANDEZ-GUEVARA, a/k/a
HERNANDEZ-GUEVARA, a/k/a "Stop";
"Stop"; ROLANDO ARISTIDES
ARISTIDES JUAREZ-VASQUEZ,
JUAREZ-VASQUEZ,
aka
aka "Virus,"
"Virus," a/k/a "Daffy"; JEFFRY
a/k/a "Daffy"; RODRIGUEZ, aka
JEFFRY RODRIGUEZ, aka "Hyper";
"Hype r"; JUNIOR
JUNIOR NOE
ALVARADO-REQUENO,
ALVARADO a/k/a "Insolcnte,"
-REQ UENO, a/k/a "lnsolente, " a/k/a
a/k/a "Trankilo"; MICHAEL EDUARD
"Tr-ankilo"; MICHAEL EDUARDOO
74
CONTRERAS,
CONTRERAS, a/k/a
a/kla "Katra,"
"Katra," a/k/
a/klaa "lnsoportable";
"Insoportablc"; LUIS
LUIS FERNANDO
FERNANDO ORELLANA-
ORELLANA-
ESTRADA,
ESTRADA, a/k/a "Pinguino"; and DONALD
a/kla "Pinguino"; DONALD ROBERTO
ROBERTO MENDEZ-LOPEZ,
MENDEZ-LOPEZ, a/k/a
a/kla
"Chuckic," were members

"Chuckie," members and associates
associates ofMS-13.
ofMS-13.
6. Member
Memberss ofMS- 13 from time to time sigrufied
of MS-13 signified their member ship by wearing
membership wearing
tattoos
tattoos reacting
reading "MARA
"MARA SALV
SALVAATRUCHA,"
TRUCHA," "MS,"
"MS," "MS-13,"
"MS-13," or similar
similar tattoos,
tattoos, often written
written in
gothic
gothic lettering.
lettering. Members
Members also signified
signified their membership
membership through
through tattoos of devil horns
horns in
various
various places
places on their bodie
bodies.s. Member
Memberss and associates
associates sometimes
sometimes avoided
avoided consp icuous MS-
conspicuous 13
MS-13
tattoos,
tattoos, instead
instead wearing
wearing discreet
discreet ones such as "503," spider webs,
webs, three dots in a triangle
triangle
formation signifying "mi vida loca," or clown

formation signifying clown faces with phrases
phrases such as "laugh
"laugh now
now,, cry later."
later."
Some MS-13 members

members and associates
associates have chosen
chosen not to have
have. tattoos at all, or to have them
placed
placed on areas such as the hairline
hairline where they can be easily
easily covered,
covered, in order
order to conceal
conceal their
gang affiliation
affiliation from law enforcement.
enforcement.
7. The gang colors

colors ofMS-
ofMS-1313 were blue
blue,, black
black,, and white, and members
members often
often wore
clothing,
clothing, particularly
particularly sports
sports jer seys, with the number
jerseys, number ""13,"
13," or with number
numberss that, when
when added
together,
together, totaled
totaled 13, such as "76." MS-13
MS-13 members
associates also wore blue and white
clothing
clothing to represent
represent their allegiance,
allegiance, including
including blue and white shoes
shoes such as the Nike "Cortez
"Cortez."."
As with
with tattoos,
tattoos, some MS-13 members
associates have selected
selected more discreet
discreet ways of
dressing
dressing in order to signify
signify their membership
membership and at the same time,
time, avoid
avoid detection
detection by law
enforceme nt.
enforcement.
8. MS-13
MS-13 member
memberss and associates
associates referred to one another
another by their
their "gang names," or
monikers
monikers, , and often did not know fellow
fellow gang member
associates except by their monikers.
monikers.
75
9. Members
Members and associates
associates of MS-13 were expected
ofMS-13 expected to protect
protect the name,
name, reputation
reputation, ,
and status
status of the gang
gang from rival gang members
members and other persons.
persons. MS-13 members required that
all individuals
individuals show respect
respect and deference
deference to the gang and its membership.
membership. To protect
protect the gang
and to enhance
enhance its reputation,
reputation, MS-13 members
associates were expec ted to use any means
expected
necessary
necessary to force respect
respect from those who showed
showed disrespect,
disrespect, including
including acts of intimid ation and
intimidation
violence.
violence. MS-1
MS-133 had mottos consistent
consistent with its rules,
rules, beliefs
beliefs,, expectations
expectations, , and reputation
reputation
including "mata,
"mata. viola,
viola. controla,"
controla," which translates
translates as, "kill
"kill., rape,
rape, control
control,"," and,
and, "ver oir y
caUar,"
callar," which translates
translates to, "see nothin g, hear nothing and say nothin
nothing, g."
nothing."
10.
IO. Member
Memberss and associates
associates of MS-13 frequently
frequently enga ged in crirninal
engaged criminal activity,
activity,
includin
including,g, but not limited to, murder,
murder, assault, extortion
extortion, , and dealing
dealing in illegal
illegal controll ed
controlled
substances.
substances. MS-13 members and associates
associates were
were required
required to commi
committ acts of violence
violence to maintain
maintain
membership
membership and discipline
discipline within the gang,
gang, as well as against
against rival gang
gang members.
members. Participation
Participation
in criminal
criminal activity
activity by a member
member or associate,
associate, particularly
particularly in violent
violent acts directed
directed at rival
rival gangs
or as directed
directed by gang
gang leadership
leadership, , increased
increased the respect accorded
accorded to that member or associa te,
associate,
resulted
resulted in that member
member or associate
associate maintainin
maintainingg or increasing
increasing his position
position in the gang, and
opened
opened the door to a promotion to a leadership
leadership position. One of the principal rules ofMS-13
of MS-13 was
that its members,

members, and persons seeking
seeking to become
become members,
members, must attack and kill rivals whenever
whenever
possible. Rivals were often referred to as "chavalas."

"chavalas." MS-13, in the areas of Prince George's
George's
Count
Countyy and Montgomery
Montgomery County,
County, Maryland
Maryland, , maintain ed rivalries
maintained rivalries with the 18th Street Gang
Gang,,
Latin Kings,
Kings, Adelphi
Adelphi Crew
Crew,, and Lewisdale Crew,
Crew, amon
amongg others.
others.
11.
II. Prospective
Prospective members
members who sought
sought to join MS-13 were required
requircd to complete
complete an
initiation
initiation proce ss. Individu
process. als who
Individuals who assoc iated with and were friends
associated friends of the gang were called
76
"paisas."
"paisas." Individuals
Individuals who did favors and other
other acts for the gang were called
called "paros."
"paras ." Persons
Persons
being
being observed
observed by the gang for potential
potential membership
membership were
were known
known as "observations."
"observations."
Individuals
Individuals who had advanced
advanced to the final level before
before being
being ')umped
'Jumped in" were called
were ~alled
"chequeos
"chequeos,"," or "cheqs."
"cheqs." Chequeos
Chequeos underwent
underwent a probationary
probationary period during
during which
which they were
were
required
required to commit
commit crimes
crimes on behalf
behalf of MS-13 to achieve
achieve trust and prove
prove their loyalty
loyalty to the
gang.
gang. To join MS-13 and become
become full members
members or "homeboys
"homeboys,"," prospective
prospective members
members were
were
required
required to complete
complete an initiation
initiation process
process,, often referred ')umped in" or "beat
referred to as being 'Jumped ''beat in" to
the gang. During that initiation

initiation, , other
other members
members of MS-13
MS-13 would
would beat the new member
member, , usually
usually
until a gang member

member finished
finished counting
counting aloud to the number
number thirteen
thirteen, , representing
representing the 13" in
the""13"
MS-13.
MS-13.
12. MS-13
MS-13 was an international
international criminal
criminal organization
organization, , and was
was organized
organized in
Maryland
Maryland and elsewhere
elsewhere into "cliques,"
"cliques," that is, smaller
smaller groups
groups operating
operating in a specific
specific city or
region
region.. Cliques
Cliques operated
operated under the umbrella
umbrella rules ofMS-13.
of MS-13. MS-13
MS- I 3 cliques
cliques often
often worked
worked
together
together cooperatively engage in criminal
cooperatively to engage criminal activity
activity and to assist
assist one another
another in avoiding
avoiding
detection
detection by law enforcement.
enforcement. In Maryland
Maryland and the surrounding
surrounding area,
area, these
these cliques
cliques included
included
Sailors
Sailors Locos Salvatrucha
Salvatrucha Westside
Westside ("SLSW"
("SLSW" or "Sailors "), Parkview
"Sailors"), Parkview Locos Salvatrucha
Locos Salvatrucha
("PVLS "), Normandie

("PVLS"), Norn1andie Locos Salvatrucha
Salvatrucha ("NLS"
("NLS" or "Normandie "), Langley
"Norrnandie"), Langley Park Salvatrucha
Salvatrucha
("LPS")
("LPS"), , Weedoms
Weedoms Locos
Locos Salvatrucha
Salvatrucha ("Weedoms"),
("Weedoms"), and Cabanas
Cabanas Locos Salvatruchas
Locos Salvatruchas
("Ca ban as").

("Cabanas").
13. TEJADA-CRUZ,
TEJADA-CRUZ, HERNANDEZ-GUEVARA,
HERNANDEZ-GUEVARA, JUAREZ-VASQUEZ,
JUAREZ-VASQUEZ,
RODRIGUEZ,
RODRIGUEZ, AL VARADO-REQUENO, CONTRERAS,
ALVARADO-REQUENO, CONTRERAS, ORELLANA-ESTRADA and
ORELLANA-ESTRADA, , and
MENDEZ-LOPEZ were
MENDEZ-LOPEZ were members
associates of the Sailors
Sailors Clique
Clique ofMS-13.
ofMS-l3.
77
14. Each clique

clique was presided
presided over by the "First Word,"
Word," the leader
leader or president
president of the
clique.
clique. The leader
leader was also
also referred
referred to as "Primera
"Primera Palabra,"
Palabra," or "Shotca ller," or "Corredor"
"Shotcaller," "Corredor" or
"Runner."
"Runner." The "Second
"Second Word,"
Word," or "Segundo
"Segundo Palabra,"
Palabra," was the second-in-command
second-in-command of the
clique.
clique. General
General members
members were
were required
required to take orders
orders from the First
First Word or Runner
Runner and Second
Second
Word.
15. MS-13
MS-13 cliques
cliques kept in contact
contact and reported
reported to the supreme
supreme Runners
Runners for their
respective
respective cliques,
cliques, who were
were oftentimes
oftentimes based
based in El
EI Salvador.
Salvador. Cliques
Cliques contacted
contacted their
their leaders
leaders
based
based in El Salvador
Salvador using
using mobile
mobile telephone
telephoness during
during clique
clique meetings
meetings to keep them
them updated
updated on
gang business
business, , for advice,
advice, and to resolve
resolve disagreements
disagreements regarding
regarding operations
operations among
among local
local
cliques
cliques.. Incarcerated
Incarcerated clique
clique leaders
leaders based
based in El Salvador
Salvador regularly
regularly communicated
communicated and directed
directed
orders
orders to Maryland-based
Maryland-based cliques
cliques through
through phones
phones smuggled
smuggled into Salvadoran
Salvadoran prisons.
prisons.
16.
16. MS-13
MS- 13 members
associates met on a regular
regular basis to, among
among other things
things,,
discuss
discuss gang affairs
affairs and report
report on acts of violence
violence committed
committed by their members
members, , with the goal of
inciting
inciting and encouraging
encouraging further
further violence.
violence. Each clique
clique held
held clique
clique meetings
meetings where business
business
specific
specific to that clique
clique was discussed.
discussed. Any perceived
perceived indiscretions
indiscretions by members
associates or
violations
violations of MS-13 rules were talked
talked about at clique
clique meetings
meetings and punishments
punishments known as
"courts"
"courts" or "violations
"violations"" were issued.
issued. Courts
Courts or violations
violations often took the form of beatings
beatings by
fellow
fellow MS-13 members.
members. More serious
serious violations
violations resulted
resulted in the issuance
issuance of a "greenlight."
"greenlight." A
greenlight
greenlight was an order
order and/or
and/or approval
approval to kill.
17. MS-
MS- 13
I3 leaders
leaders from various
various cliques
cliques also held regional
regional meeting
meetingss to discuss
discuss issues
between
between cliques
cliques and discuss
discuss criminal
criminal ventures
ventures among
among the cliques.
cliques. Clique
Clique leaders
leaders from across
across the
United
United States,
States, from other
other countries,
countries, and within
within regions
regions of the United States
States would meet or
78
communicate by telephone
communicate telephone conference
conference to discuss
discuss gang rules and gang
gang rules gang business
business, to resolve
resolve
problems issues among

problems or issues among cliques gang members
cliques and gang different cliques,
members of different cliques , and
and to unite gang
gang
members from across

members from across the country.
country.
18. MS-13 cliques would

MS-13 cliques combine and work
would combine work together
together for various
various purposes
purposes known
known as
"programs." A person
"programs." within the participating
person within participating cliques
cliques would
would be selected
selected as program
program leader.
leader.
19. MS-13
MS-13 received
received money
money and income
income from sources
sources including
including member dues and the
member dues
extortion, or "taxing,"
extortion, "taxing," of brothels other illegitimate
brothels and other illegitimate busine es. Such
businesses. Such funds
funds,, often
often referred
referred to
by MS-13
MS-13 members
associates as "rent,"
"rent " were used for gang
gang purposes
purposes, including
including obtaining
obtaining
weapons and providing

weapons providing support
support for MS-13
MS-13 gang
gang members who were
members who were imprisoned
imprisoned in the United
United
States, both
States, inside and
both inside and outside
outside of Maryland
Maryland, , and
and in El Salvador.
EI Salvador.
20. MS-13
MS-!3 members associates communicated
members and associates communicated about
about gang
gang activities
activities with
with other
other
MS-13
MS-13 members associates in Maryland
members and associates elsewhere using mobile
Maryland and elsewhere mobile telephones telephone
telephones, telephone
text messages
text messages, , social
social media
media such Facebook and e-mail
such as Facebook e-mail accounts,
accounts, and other
other modes
modes of
communication. Further,
communication. Further, MS-13
MS-13 members associates would
members and associates would promote
promote MS-13 activities
MS-13 and its activities
through
through the creation
creation and dissemination
dissemination of rap songs
songs and
and other
other communication
communication facilitated
facilitated by
various
various internet Additionally, MS-13
internet means. Additionally, MS-13 members
members and associates used transnational
associates used and
transnational and
international
international money
money wire transfers
transfers to conduct
conduct and promote gang activities.
promote gang activities.
The Racketeering
The Racketeering Enterprise
Enterprise
21. MS-13
MS-13,, including
including its leadership
leadership, , membership,
membership, and
and associates,
associates , constituted
constituted an
enterprise as defined
enterprise U.S.C. S§ 1961(4),
defined in 18 U.S.C. 1961(4), that is, a group
group of individuals
individuals associated
associated in fact that
that
engaged
engaged in, and the activities
activities of which
which affected, interstate and
affected, interstate foreign commerce
and foreign ("the
commerce ("the
Enterprise"). The
Enterprise"). Enterprise constituted
The Enterprise constituted an ongoing
ongoing organization
organization whose members and associates
whose members associates
79
functioned
functioned as a continuing
continuing unit for a common purpose of achieving
common purpose achieving the objectives
objectives of the
Enterprise.
Enterprise.
Purposes of the
the Enterprise
22. The purposes of the Enterprise

Enterprise included:
included:
a. Preserving
Preserving and protecting
protecting the power, territory
territory, , and
and profits of the Enterprise
Enterprise
through the use of intimidation violence , including

intimidation and violence, assaults, murders
including assaults, murders, , and threats
threats of violence;
violence;
b. Promoting and enhancing

Promoting Enterprise and its member
enhancing the Enterprise members' ' and associates'
associates '
activities
activities; ;
c. Enriching
Enriching the members
as ociates of the Enterprise through extortion
Enterprise through extortion
and the distribution controlled substances;

distribution of controlled substances·
d. Keeping victims
victims and potential
potential witnesses
witnesses in fear of the Enterprise
Enterprise and in
fear of its members associates through

members and associates threats of violence
through threats violence and actual
actual violence;
violence; and
e. Providing assistance
Providing members and associates
assistance to members associates in order hinder,,
order to hinder
obstruct, , and prevent

obstruct prevent law enforcement
enforcement officers
officers from identifying
identifying offenders,
offenders , apprehending
apprehending
offenders, , and trying and punishing

offenders punishing offenders.
offenders.
Means and Methods

Methods of the Enterprise
Enterprise
23. Among
Among the means and methods
methods by which
which the defendants
defendants and others
others conducted
conducted
and participated conduct of the affairs

participated in the conduct affairs of the Enterprise
Enterprise were the following:
following:
a. Members and associates

Members associates of the Enterprise
Enterprise used
used,, attempted
attempted to use,
use, and
conspired
conspired to use extortion;
extortion;
b. Members and as
Members associates
ociates of the Enterprise
Enterprise obtained
obtained and distributed
distributed
controlled substances;
controlled substances ·
80
c. Members
Members and associates
associates of the
the Enterprise
Enterprise committed, attempted, and
committed, attempted, and
threatened commit acts

threatened to commit acts of violence,
violence, including
including murder,
murder, to protect and expand
protect and expand the
the Enterprise's
Enterprise's
criminal operations ;
criminal operations;
d. Members and aassociates

Members and sociates of the Enterprjse
Enterprise promoted climate of fear
promoted a climate
through
through violence and threats
violence and threats of violence;
violence; and
e. Members and associates

Members and associates of the
the Enterprise
Enterprise used and threatened
used and threatened to use
use
physical
physical violence against various
violence against various individuals.
individuals.
The Racketeering Conspiracv

24.
24. Beginning
Beginning on a date
date unknown
unknown to the
the Grand Jury, but
Grand Jury, but at least
least prior
prior to in or about
about
2015, and continuing

2015, and continuing through
through at least
least in or about
about September
September 2017,
2017, in the District Maryland
District of Maryland
and elsewhere,
elsewhere,
CARLOS ROBERTO TEJADA-CRUZ,

a/k/a "Krusty,"
a/k/a "Krusty,"
KEVIN ALEXIS
KEVIN HERNANDEZ-GUEVARA,
ALEXIS HERNANDEZ-GUEVARA,
a/k/a "Stop,"
a/k/a "Stop,"
ROLANDO ARISTIDES
ROLANDO ARISTIDES JUAREZ-VASQUEZ,
JUAREZ-VASQUEZ,
a/k/a "Virus,"
a/k/a "Virus,"
a/k/a "Daffy,"
a/k/a "Daffy,"
JEFFRY RODRIGUEZ,
JEFFRY RODRIGUEZ,
a/k/a
a/k/a "Hyper,"
"Hyper,"
JUNIOR NOE ALVARADO-REQUENO,
JUNIOR NOE AL V ARADO-REQUENO,
a/k/a "lnsolente,"
a/k/a "Insolente,"
a/k/a
a/k/a "Trankilo,"
"Tranldlo,"
MICHAEL EDUARDO
MICHAEL EDUARDO CONTRERAS,
CONTRERAS,
a/k/a "Katra,"
a/k/a "Katra,"
a/k/a "Insoportable,"
a/k/a "lnsoportable,"
LUIS FERNANDO
LUIS FERNANDO ORELLANA-
ORELLANA- ESTRADA,ESTRADA,
a/k/a
a/k/a "Pinguino,"
"Pinguino," and and
DONALD ROBERTO
DONALD ROBERTO MENDEZ-LOPEZ,
MENDEZ-LOPEZ,
a/k/a
a/k/a "Chuckie,"
"Chuckie,"
81
being persons employed

employed by and associated
associated with MS-13
MS-13,, an enterprise
enterprise engaged
engaged in
in, and the
activities of which affected,

activities affected, interstate
interstate and foreign commerce,
commerce , together with others
others known and
unknown to the Grand Jury,

Jury , did knowingly intentionally conspire
knowingly and intentionally conspire to conduct and participate,
directly and indirectly, in the conduct

conduct of the affairs of MS-13 through a pattern of
ofracketeering
racketeering
activity U.S.c. SS
activity,, as defined in 18 U.S.C. §§ 1961(1)
1961(I) and (5),
(5), which pattern of racketeering
racketeering activity
activity
consisted
consisted of multiple acts involving: (I) murder, , in violation of Maryland Code,
(1) murder Code , Criminal
Criminal Law
SS 1-201, 1-202,
§§ 2-201, 2-204 , 2-205, and 2-206, and the Common
1-202,2-201,2-204,2-205, Common Law of Maryland, puni hable
punishable
pursuant to Maryland Code,

Code , Criminal Law SS 1-201,
Criminal Law§§ 1-202, 2-201 , 2-204 , 2-205 , and 2-206;
1-201, 1-202,2-201,2-204,2-205, 2-206 ·
extortion, in violation
(2) extortion, violation of Maryland Code, Criminal Law SS 3-701 and 3-705,
Criminal Law§ 3-705, and the
Common Maryland; (3) robbery, in violation

Common Law of Maryland· violation of Maryland Code
Code,, Criminal Law SS 3-402
Criminal Law§§
and 3-403, and the Common

Common Law of Maryland;
Maryland; and (4) drug trafficking
trafficking in violation of21 U.S.C.
of 21 U.S .C.
SS
§§ 841 and 846. It was part of the conspiracy
conspiracy that each defendant
defendant agreed that a conspirator
conspirator would
commit at least two acts ofracketeering

of racketeering in the conduct
conduct of the affairs ofthe
of the Enterprise.
Manner and Means

Manner and Means of the
the Racketeering Conspiracy
Racketeering Conspiracv
25. Among the manners and means used by the defendants

defendants and their co-conspirators
co-conspirators
to achieve the objects of the conspiracy

con piracy were the following:
a. MS-13 members and associates

associates met and communicated
communicated about,
about , among
other things: the structure and organization

organization of the gang·
gang; past criminal acts committed
committed against
rival gang members and others;

others · MS-13 members and aassociates
sociate who were arrested
arrested or
incarcerated; the disciplining

incarcerated; disciplining of MS-13 members and associates;
ofMS-13 associates ; police interactions
interactions with MS-13
associates; the identities of individuals

members and associates; individuals suspected of cooperating
cooperating with law
enforcement
enforcement and the proposed actions to be taken against them;
them ; plans and agreements
agreements regarding
10
82
the commission
commission of future
future crimes,
crimes, as well as ways
ways to conceal
conceal these
these crime
crimes;s; and
and the enforcement of
the enforcement
gang rules.
rules.
b. MS-13
MS-13 members
associates agreed
agreed to purchase
purchase, , maintain
maintain, , and
and
circulate
circulate weapons
weapons and firearms
firearms for use in criminal
criminal activity
activity by MS-13
MS-13 memb ers.
members.
c. MS-13 members
associates received
received money and
and income
income from sources
sources
including
including the extortion
extortion of persons
persons engaged
engaged in business
business activities,
activities, and the distribution
distribution of
controlled
controlled substances.
substances. Such
Such funds
funds were used for gang
gang purposes
purposes such
such as obtaining
obtaining weapon
weaponss and
providing
providing support
support for MS-13
MS-13 gang members
members, , including
including those imprisoned
imprisoned in the United
United States
States
(inside
(inside and outside
outside of Maryland)
Maryland) and in El
EI Salvador.
Salvador.
d. MS-13 members
associates agreed
agreed that acts of violence,
violence, including
including
murder and attempted

attempted murder,
murder, would
would be committed
committed by members
associates of MS-13
MS-13 against
against
rival
rival gang
gang members
members and others
others when it suited the Enterprise's
Enterprise's purpo ses. MS-13
purposes. MS-13 member
memberss and
and
associates
associates also
also used
used violence
violence to impose
impose discipline
discipline within
within the gang.
gang.
e. MS- 13 members
MS-13 members and associates
associates would
would obstruct
obstruct ju stice and harm,
justice threaten ,
harm, threaten,
and intimidate
intimidate witnes ses and victims
witnesses victims who cooperated
cooperated with law enforcement.
enforcement.
f. MS-13 members
associates would
would investigate rival gang
investigate rival gang members
members or
other persons
persons targeted
targeted for violence;
violence; would
would obtain
obtain information
information about such
such targets,
targets, including
including
location
locationss frequented
frequented by them;
them; and would
would use such information
infomlation in their plans
plans to attack
attack such
targets.
targets.
g. MS-13 members
associates agreed
agreed that acts involving
involving murder,
murder,
including
including conspirac
conspiracyy and attempts
attempts to commit
commit murder,
murder, and other
other acts of violence
violence, , would
would be
committed
committed by member
associates of MS-13
MS-13 against
against rival gang members and
gang members and persons
persons
11
I1
83
deemed threats to MS-13

deemed as threats MS-13 and for the purpose
purpose of imposing
imposing discipline
discipline within gang, and
within the gang, and on
other
other occasions
occasions as deemed
deemed necessary.
necessary.
Overt
Overt Acts
26. In furtherance
furtherance of the conspiracy
conspiracy, , and
and to effect
effect the illegal
illegal objects thereof, the
objects thereof,
defendants
defendants and their co-conspirators
co-conspirators performed
performed, , participated
participated in, and
and did
did the following acts,
following acts,
among others, in the District

among others, District of Maryland elsewhere:
Maryland and elsewhere:
a. Between
Between in or about
about 2015 through in or about
2015 through 2017 in the Langley
about 2017, Langley Park
area of Prince George's

George's County,
County, Maryland and the Wheaton
Maryland and area of Montgomery
Wheaton area Montgomery County
County, ,
Maryland
Maryland, , JUAREZ-VASQUEZ,
JUAREZ-VASQUEZ , CONTRERAS,
CONTRERAS , ORELLANA-ESTRADA
ORELLANA-ESTRADA, MENDEZ-
MENDEZ-
and other
LOPEZ, and
LOPEZ, other MS-13
MS-13 members
associates extorted
extorted sums
sums of money
money from persons
persons
including
including owners
owners and operators
operators of illegal
illegal businesses
businesses, , including brothels , illegal
including brothels, illegal food and
and beer
beer
stores,
stores, and drug dealers, the proceeds
drug dealers, proceeds of which
which benefited
benefited the gang.
gang.
b. Between
Between in or about
about 2015 through in or about
2015 through about 2017,
2017, TEJADA-CRUZ,
TEJADA -CRUZ ,
JUAREZ-VASQUEZ,
JUAREZ-VAS CONTRERAS, , ORELLANA-ESTRADA,
QUEZ, CONTRERAS ORELLANA-ESTRADA, and other
other MS-13
MS-13 members
members
and associates
and associates sent
sent money
money obtained
obtained from
from the extortion
extortion of the owners
owners and
and operators
operators of illegal
illegal
businesses
businesses to El
EI Salvador.
Salvador. Often
Often the money was sent
money was sent to females
females in order
order to disguise
disguise the origin
origin of
the money
money as well as the purpose
purpose of the funds
funds (which was to support
(which was MS-13 in El
support MS-13 Salvador).
EI Salvador).
c.
c. Between
Between in or around
around 2016
2016 and
and in or around
around 2017,
2017, ALVARADO
AL VARADO- -
REQUEN CONTRERAS , and other

REQUENO,O, CONTRERAS, other MS-13
members and associates created
created and
disseminated
disseminated rap songs
songs promoting
promoting MS-13
MS-13 on various ocial media platforms.
various social platforms.
d. On or about
about May 27 2016, TEJADA-CRUZ
27,2016, sent $300
TEJADA-CRUZ sent $300 by Western
Western Union
Union
to a female
female in El
EI Salvador.
Salvador.
12
84
e. On or about
about June 15, 2016,
2016, and June 16, 20 16, ALVARADO
2016, AL VARADO--
REQUENO
REQUENO planned with and directed other MS-13 members
associates to murder
murder Yictim
Victim--
1,
I, who was believed
believed to be a member
member of the 18th Street gang.
f. Pursuant
Pursuant to the plan and as directed
directed by AL VARADO-REQUENO , on or
ALVARADO-REQUENO,
about June 16, 2016, MS-13

16,2016, MS-l3 members
associates murdered Victim
Victim-l-I in Gaither sburg,
Gaithersburg,
Maryland.
Maryland.
g. On or about July 23, 2016, TEJADA-CRUZ

23,2016, TEJADA-CRUZ sent $300 by
by Western Union
to a female
female in
in El
EI Salvador.
Salvador.
h. Between in or about 20 15 through

2015 through in or about 20 I 7, in the Langley Park
2017,
area of Prince George's

George's County
County,, Maryland
Maryland, , TEJADA-CRUZ
TEJADA-CRUZ, , HERNANDEZ-GUEVARA
HERNANDEZ-GUEVARA, ,
RODRIGUEZ,
RODRIGUEZ, CONTRERAS
CONTRERAS, , ORELLANA-ESTRADA
ORELLANA-ESTRADA, , MENDEZ-LOPEZ,
MENDEZ-LOPEZ, and other

associates distributed
distributed marijuana
marijuana and cocaine
cocaine,, the proceeds of which
benefited
benefited the gang
gang..
1.
I. On or about July 29, 2016
2016,, TEJADA-CRUZ
TEJADA-CRUZ, , HERNANDEZ-
HERNANDEZ-
GUEVARA
GUEVARA, , and other members
associates ofMS-13
of MS-13 planned to murder Yictim-2.
Victim-2.
J. Pursuant to the plan to murder

murder Victim-2
Victim-2, , on or about
about July 29, 2016, two
29,2016,
member
memberss and associate
associatess ofMS-13
ofMS-13 lured Victirn-2
Victim-2 (who was believed
believed to be a rival gang member
member))
to a secluded
secluded location
location in Hyattsville,
Hyattsville, Maryland,
Maryland, and then TEJADA -CRUZ attempted
TEJADA-CRUZ attempted to shoot
Victim-2 when Yictim-2

Victim-2 arrived at the secluded
secluded location.
location.
k. On or about July 29, 20 16, when Victim-2 attempted

2016, attempted to flee,
flee, one of the
member
associates ofMS-13
ofMS-13 chased down Victim-2,
Victim-2, and then TEJADA-CRUZ
TEJADA-CRUZ and other
member
associates of MS-13 stabbed
stabbed Yictim -2.
Victim-2.
13
85
1. On or about July 29, 2016 , HERNANDEZ-GUEVARA

29,2016, HERNANDEZ-GUEVARA picked up the
shell casings from the shots fired by TEJADA -CRUZ at Victim-2.

TEJADA-CRUZ Victim-2.
m. On or about Augu 2016,, TEJADA-CRUZ

st 9, 2016
August TEJADA-CRUZ, , HERNANDEZ-
HERNANDEZ-
GUEVARA
GUEVARA, , and RODRIGUEZ
RODRIGUEZ planned to purchase marijuana to sell.
n. On or about August 9, 20 16, HERNANDEZ-GUEVARA

2016, HERNANDEZ-GUEVARA and
RODRIGUEZ entered a car in the Hyattsville

RODRIGUEZ Hyattsville, , Maryland area with the intent of obtaining
man Juana.
marIJuana.
o. 2016,, HERNANDEZ-GUEVARA
On or about August 9, 2016 HERNANDEZ-GUEVARA and
RODRIGUEZ
RODRIGUEZ attempted to steal marijuana by brandishing a firearm and knife
knife..
pp.. On or about August 9, 20 16, during the course of the attempted robbery by
2016,
HERNANDEZ-GUEVARA
HERNANDEZ-GUEVARA and
and RODRIGUEZ
RODRIGUEZ, , Victim-3 was shot and stabbed and Victim-4
was shot.
q. August
On or about Augu 2016,, when questioned regarding the robbery
st 9, 2016 robbery, ,
TEJADA-CRUZ
TEJADA-CRUZ provided false and misleading information to the po
police.
lice.
r. 2016,, JUAREZ-VASQUEZ
On or about October 26, 2016 JUAREZ- VASQUEZ sent $200 by
Union to a female in El
Western Union EI Salvador
Salvador. .
s. On or about October 31, 2016, JUAREZ-VASQUEZ

31,2016, JUAREZ-VASQUEZ sent $$100
100 by
female
Western Union to a fema EI Salvador.
le in El
t. 2016,, CONTRERAS
On or about November 5, 2016 CONTRERAS sent $300 by Western
Union to a female in El
Union EI Salvador.
u. On or about 2016,, JUAREZ-VASQUEZ

about November 12, 2016 JUAREZ-VASQUEZ sent $250
$250 by
Western Union to a female in El Salvador.
14
86
v. On or about November 15, 201 6, JUAREZ-VASQUEZ

15,2016, JUAREZ-VASQUEZ sent $200 by
Western
Western Union to a female in El
EI Salvador.
w. On or about Decemb 2016,, JUAREZ-VASQUEZ

er 6, 2016
December JUAREZ-VASQUEZ sent $400 by
Western Union to a female in El Salvador.
x. On or about March
March 20,2017,
20, 2017, in the Langley
Langley Park
Park area of Prin ce George
Prince George's's
County,
County, Maryland
Maryland,, an MS-13 member and associa
associatete collected "rent"
"rent" from Victirn -7.
Victim-7.
y. On or about March 2017,, CONTRERAS

March 27, 2017 CONTRERAS arranged for memb ers of the
members
Sailors Clique ofMS-13 to trave

travell from Maryland to Lync hbur g, Virginia, wher
Lynchburg, wheree they met with
other MS-13
MS-13 memb ers and associa
members tes.
associates.
z. On or about March
March 27, 20 17, memb
2017, ers and associates of the Sai
members lors Clique
Sailors Clique
of MS-13, includin
includingg persons
persons who had trave led from Mary
traveled land as arranged by CONTRERAS
Maryland CONTRERAS, ,
murdered Victim-5 in Bedford Count y, Virginia.

County,
aa. On or about April 10, 2017 , in the Langley Park area of Princ
10,2017, Princee George's
County
County,, Mar yland , an MS-1
Maryland, MS-133 member and associate collected "rent"
"rent" from Victim -7.
Victim-7.
bb
bb.. On or about April 30, 2017
2017,, in the Langley Park area of Prin ce George's
Prince
County
County,, Maryland, an MS-1
MS-133 member and associate coll ected "rent"
collected "rent" from Victim -7.
Victim-7.
cc
cc.. On or about Jun
Junee 1, 2017, in the Adelphi
1,2017, Adelphi area of Prince
Prince George's Count y,
County,
Maryland, JUAREZ-VASQUEZ
Maryland, JUAREZ-VASQUEZ, , together with other members
members and associates of MS-13
MS-13,, began
exchanging words with Victim-6

Victim-6 and throwin
throwingg MS-13 gang signs.
dd
dd.. , 2017 , JUAREZ-VASQUEZ
On or about June I1,2017, JUAREZ-VASQUEZ shot Victim-6
Victim-6 in the
head,
head, killing Victim-6.
15
87
ee. Between June 1, 2017 and June 5, 2017, ALVARADO-REQUENO

1,2017, ALVARADO-REQUENO and
JUAREZ-VASQUEZ in evading arrest for the

other MS-13 members and associates assisted JUAREZ-VASQUEZ
murder of Victim-6.
ofVictim-6.
ff. On or about June 9, 2017,

2017 , in the Langley Park area of Prince George
George's's
County, Maryland
County Maryland, ORELLANA-ESTRADA
ORELLANA-ESTRADA collected "rent" from Victim-7.
gg. On or about June 15,

15,2017,
2017 , ORELLANA-ESTRADA
ORELLANA-ESTRADA sent $400 by
EI Salvador.
Western Union to a female in El
hh. On or about June 16,

16,2017,
2017, in the Langley Park area of Prince George's
County, Maryland, ORELLANA-ESTRADA

ORELLANA-ESTRADA collected ."rent
,"rent"" from Victim-7.
11.
II. 2017 , in the Langley Park area of Prince George
On or about June 30, 2017, George's's
County
County, , Maryland ORELLANA-ESTRADA
Maryland, ORELLANA-ESTRADA collected "rent"
"rent'' from Victim -7.
Victim-7.
JJ. 21, 2017, in the Langley Park area of Prince George's

On or about July 21,2017,
County, MENDEZ-LOPEZ
County MENDEZ-LOPEZ collected "rent" from Victirn-7.
Victim-7.
kk. On or about August 4,

4, 2017
2017,, in the Langley Park area of Prince George's
County,, MENDEZ-LOPEZ
County MENDEZ-LOPEZ collected "rent" from Victim-7
Victim-7. .
Special Sentencing
Special Sentencing Factors
Factors Regarding
Regarding Count One
Count One
27. On or about June 15

15, 2016 and June 16, 2016,
2016 , in the District of Maryland,
ALVARADO-REQUENO
AL VARADO -REQUENO unlawfully conspired with others known and unknown to the Grand
feloniously, , willfully
Jury to feloniously willfully, , and with deliberately
deliberately premeditated malice, murderVictim
murder Victim-I,
- 1, in
violation of Maryland Code, Law S 2-20

Code , Criminal Law§ 2-2011(a)(l)
(a)(I), , and the common law of Maryland
Maryland, and
Law S 1-202
punishable pursuant to Maryland Code Criminal Law§ 1-202..
16
88
28. On or about July 29, Maryland, TEJADA-CRUZ

2016, in the District of Maryland,
29,2016, TEJADA-CRUZ and
HERNANDEZ-GUEVARA
HERNANDEZ-GUEVARA unlawfully
unlawfully conspired
conspired with each other and others known and
unknown to the Grand Jury to feloniously,

feloniously, willfully,
willfully, and with deliberately
deliberately premeditated
premeditated malice
malice,,
murderVictim-2,
murder Victim-2, in violation ofMaryland Law S 2-20l(a)(I)
of Maryland Code, Criminal Law§ 2-201(a)(I), , and the common
common
law of Maryland
Maryland, , and punishable
punishable pursuant to Mary land Code Criminal
Maryland Law S 1-202.
Criminal Law§
29. On or about July 29, Maryland, TEJADA

2016 , in the District of Maryland,
29,2016, -CRUZ and
TEJADA-CRUZ
HERNANDEZ-GUEVARA
HERNANDEZ-GUEVARA feloniously
feloniously, , willfully
willfully,, and with deliberately
premeditated malice,
murdered Victim-2, in violation of Maryland Code, Criminal Law S 2-201

Criminal Law§ 2-20l(a)(l).
(a)(1).
30. On or about June 1,

I, 2017 Maryland, , JUAREZ-VASQUEZ
2017,, in the District of Maryland JUAREZ-VASQUEZ
feloniously,
feloniously, willfully,
willfully, and with deliberately
premeditated malice, murdered Victirn-6
Victim-6, , in
violation
violation of Maryland Code
Code,, Crimina Law S 2-201
Criminall Law§ (a)(l).
2-20 I(a) (1).
18
18 U.S.C S 1962(d)
U.S.C.. §
17
89
COUNT TWO
COUNT TWO
(Conspiracy
(Conspiracy to Commit
Commit Murder
Murder in Aid
Aid of Racketeering)
Racketeering)
The Grand Jury for the District of Maryland

Maryland further charges
charges that:
that :
1.
I. Paragr aphs 1 through
Paragraphs through 22 and 26(i) through
through (1) of Count
Count One of this Fourth
...
Superseding Indictment
Superseding Indictment are incorporated
incorporated herein
herein..
2.
2. MS-13
MS-13,, including
including its leader
leaders,s, member
members,s, and associates
associates, , constituted
constituted an enterpris
enterprise,e
defined in Title 18, Uruted

as defined Code , Section
United States Code, Section lI959(b)(2),
959(b )(2) , that is,
is, a group of individuals
associated
associated in fact that engaged
engaged in, and the activities
activities of which affected,
affected , inter state and foreign
interstate
commerce . The enterprise

commerce. enterprise constituted
constituted an ongoing organization whose
ongoing organization whose members functioned
functioned as a
continuing
continuing unit for a common
common purpose of achieving
achieving the objectives
objectives of the enterprise
enterprise. . The above-
above-
described enterprise
described enterprise, , MS-13
MS-13, , through its members
associates, , engaged
engaged in racketeering
racketeering
activity as defined
defined in Title 18, United States Code
Code,, Sections
Sections 1959(b)(l)
I959(b )(1) and 1961(1)
1961(I),, namely,
(1) murder
(I) murder,, in violation of Maryland Code
Code,, Criminal Law SS§ 1-201, 1-202,
Criminal Law§ 1-202,2-201,2-204,2-205,
2-201 , 2-204 , 2-205
and 2-206
2-206,, and the Common
Common Law of Maryland
Maryland, , punishable
punishable pursuant to Maryland
Maryland Code, Criminal
Code , Criminal
Law SS 1-201,
Law§§ 1-201, 1-202, 2-201 , 2-204 , 2-205 , and 2-206
1-202,2-201,2-204,2-205, 2-206;; (2) extortion
extortion, , in violation
violation of Maryland
Maryland
Code
Code,, Criminal Law SS 3-701 and 3-705
Criminal Law§§ 3-705,, and the Common
Common Law of Maryland
Maryland; ; (3) robbery
robbery, , in
Maryland Code,
Code, Criminal SS 3-402 and 3-403
Criminal Law §§ 3-403;; and (4) drug trafficking
trafficking in
violation of 21 U.S.C. SS
violation of21 §§ 841 and 846.
18
90
3. On or about July 29, 2016, in the District of Maryland

29,2016, Maryland, ,

TEJADA-CRUZ,
a/k/a
a/k1a "Krusty,"
"Krusty," and
and
KEVIN ALEXJS
HERNANDEZ-GUEVARA,
a/k/a
a/k1a "Stop,"
"Stop,"
for the purpose

purpose of gaining
gaining entrance
entrance to and maintaining
maintaining and increasing
increasing position
position in MS-13
MS-I3, , an
enterprise
enterprise engaged
engaged in racketeering
activity,, did knowingly
knowingly and willfully
willfully combine
combine, , conspire
conspire, ,
confederate
confederate and agree with others known and unknown
unknown to the Grand Jury to murder Victim-2
Victim-2, , in
violation
Maryland Code,
Code, Criminal SS 2-201
Criminal Law §§ 2-201,, 2-204,
2-204, and 1-202, and the Common
Common Law of
Maryland
Maryland, , all in violation U.S.C. §S 1959(a)(5).
violation of 18 U.S.C. 1959(a)(5).
18 U.S.C. S 1959(a)(5)
U.S.C. § 1959(a)(5)
19
91
COUNT THREE
COUNT THREE
(Conspiracy to Distribute and to Possess with Intent
(Conspiracy to Distribute and to Possess with to Distribute
Intent to Controlled Substances)
Distribute Controlled Substances)
Grand Jury for the District of Maryland

The Grand Maryland further charges
charges that:
I.
1. Beginning at least
Beginning least in or about
about January 2017,, and continuing
January 2017 continuing through
through at least on or
about October
about October 9,2017,
9, 2017 , in the District
District of Maryland elsewhere, the defendant,
Maryland and elsewhere, defendant,
MICHAEL EDUARDO
CONTRERAS,
a/k/a "Katra,"
a/kla "Katra,"
a/kla "Insoportable,"
did knowingly
knowingly combine,
combine , conspire,
conspire , confederate,
confederate , and agree
agree with others, known and unknown
others , known unknown to
Grand Jury,
the Grand Jury, to distribute
distribute and to possess
possess with the intent to distribute:
distribute : (I)
(1) a mixture
mixture and
substance containing
substance containing a detectable
detectable amount
amount of marijuana,
marijuana , a Schedule
Schedule I controlled
controlled substance;
substance;
mixture and substance

(2) a mixture substance containing
containing a detectable
detectable amount
amount of cocaine,
cocaine , a Schedule
Schedule II controlled
controlled
substance ; and (3) 100

substance; grams or more of a mixture
I00 grams mixture and substance
substance containing
containing a detectable
detectable amount
amount
of heroin,
heroin , a Schedule
Schedule I controlled
controlled substance, violation of Title 21,
substance, in violation 21, United States
States Code,
Code ,
Sections
Sections 841 (a)(I), , (b)(
841(a)(l) I)(B)(i),, and (b)(I
(b)(l)(B)(i) )(C).
(b)(l)(C).
U.S.C . §S 846
21 U.S.C.
20
92
COUNT FOUR
COUNT FOUR
(Conspiracy
(Conspiracy to Interfere
Interfere with
with Interstate
Interstate Commerce
Commerce by
by Extortion)
Extortion)
The Grand Jury for the District of Maryland

Maryland further charges
charges that:
At all times relevant to this Fourth Superseding

Superseding Indictment:
Indictment:
Introduction
Introduction
I.
1. La Mara Salvatru cha, also known as the MS-13 gang ("MS-13"),
Salvatrucha, ("MS-13 "), was an
international criminal
international criminal enterprise
enterprise that was active throughout
throughout the United States. In the
Washington, , D.C. metropolitan

Washington metropolitan area, including
including in Prince
Princc George
George's's County
County, , Maryland
Maryland, , MS-13
generated
generated income from various sources
sources,, including extortion of sum
including the extortion sums of money from persons
persons
engaged in business activities

who engaged activities such as controlled
controlled substances
substances sales
sales,, illegal brothels
brothels, , and
unlicensed
unlicensed "stores
"stores"" where items
itcms such as food
food,, alcoholic
alcoholic beverages
beverages, , and cigarettes sold .
cigarettes were sold.
2.
2. LIDS
LUIS FERNANDO
FERNANDO ORELLANA-ESTRADA,
ORELLANA-ESTRADA, a/k/a "Pinguino,"
a/kla "Pinguino," and
and DONALD
DONALD
ROBERTO
MENDEZ-LOPEZ, a/k/a "Chuckie,"
a/kla "Chuckie," were members associate of
members and associates ofMS-13
MS-13 and
the "Sailors"
"Sailors " clique of MS-13.
3. Victim-7 operatcd
operated a busines affected interstate
busincss that affected commerce .
interstate commerce.
The Charge
The Charge
4. Beginning
Beginning at least in or about
about June 2017
2017,, and continuing
continuing through
through at least on or
2017 , in the District of Maryland

about August 10, 2017, Maryland and elsewhere
elsewhere, , the defendants,
defendants ,
LIDS
LUIS FERNANDO
FERNANDO ORELLANA-ESTRADA,
ORELLANA-ESTRADA,
a/k/a "Pinguino,"
and
DONALD ROBERTO
DONALD ROBERTO MENDEZ-LOPEZ,
MENDEZ-LOPEZ,
a/k/a "Chuekie,"
a/kla "Chuckie,"
knowingly combine,
did knowingly combine , conspire, confcderate, , and agree with each other and others kriown
conspire , confederate known and
unknown to the
unknown thc Grand Jury to obstruct
obstruct, , delay, and affect commerce
commerce and the movem
movcment
nt of any
21
21
93
article and commodit

commodityy in commerce by extortion
extortion, , as tho se terms are defin
those ed in
defined in 18 U .s.c.. §9 1951,
18 U.S.C
to wit, the defendant

defendantss conspired
conspired to obtain the prop erty ofVictim-7
property ofVictim-7, , with Victim- Ts consent
Victim-Ts
induced by the wron gful use of actua

wrongful actuall and threatened force, violence,
violence, and fear.
18 U.S.C. §9 1951(a)
18
22
94
FORFEITURE ALLEGATION
FORFEITURE ALLEGATION
The Grand Jury for the District of Maryland further finds that:
1.
I. Pursuant to Fed. R. Crim. P. 32.2, notice is hereby given to the defendants that the
States will seek forfeiture as part of any sentence in accordance with Title 18, United States
United State
Code,
Code , Sections 981(a)(I)(C)
98l(a)(l )(C) and 1963(a);
I963(a); Title 21
21,, United States Code,
Code , Section
Sec_tion853;
853 ; and Title 28
28,,
Code, Section 2461

United States Code (c), in the event of the defendants' convictions
2461(c), conviction on Counts One,
One ,
Three, and Four of this Fourth Superseding Indictment.
RICO
RICO Forfeiture
Forfeiture
2. Pursuant to Title 18, United States Code, 1963(a)(I) ) and (3),

Code , Section 1963(a)(l (3), upon a
conviction of an offense u1
in violation of Title 18
18, United States Code,
Code , Section 1962, as alleged in
.· Count One of this Fourth Superseding Indictment

ofthis Indictment, ,
CARLOS ROBERTO
CARLOS TEJADA-CRUZ,
ROBERTO TEJADA-CRUZ,
a/k/a "Krusty,"
a/kla "Krusly,"
KEVIN
KEVIN ALEXIS
HERNANDEZ-GUEVARA,
a/kla
a/k/a "Stop,"
"Stop,"
a/k/a
a/k/a "Virus,"
"Virus,"
a/k/a "Daffy,"
a/kla "Daffy,"
JEFFRY
JEFFRY RODRIGUEZ,
RODRIGUEZ,
a/k/a "Hyper,"
a/kla "Hyper,"
JUNIOR
JUNIOR NOE ALVARADO-REQUENO,
ALVARADO-REQUENO,
a/kla "Insolente,"
a/k/a "lnsolente,"
a/k/a "Trankilo,"
a/kla "Trankilo,"
MICHAEL
EDUARDO CONTRERAS,
a/k/a "Katra,"
a/kla "Katra,"
a/kla "Insoporlable,"
LUIS FERNANDO
LIDS FERNANDO ORELLANA
ORELLANA- - ESTRADA,
ESTRADA,
a/k/a "Pinguino,"
and
DONALD
DONALD ROBERTO
MENDEZ-LOPEZ,
a/k/a "Clmckie,"
a/k/a "Chuckie,"
23
95
shall
shall forfeit
forfeit to the United
United States
States of America
America any interest acquired and maintained
interest acquired maintained in violation
violation of
Title 18, United

Title States Code,
United States Section 1962,
Code, Section which interests
1962, which are subject
interests are subject to forfeiture
forfeiture to the United
United
States
States pursuant
pursuant to Title
Title 18, United
United States Code, Section
States Code, Section 1963(a)(l )- and any property
1963(a)( I); constituting,
property constituting,
or derived
derived from,
from, any proceeds obtained, directly
proceeds obtained, indirectly, from
directly or indirectly, from racketeeting activity in
violation
violation of Title
Title 18, United States Code,
Section 1962,
1962, which
which property
property is subject
subject to forfeiture
forfeiture to
the United
United States
States pursuant
pursuant to Title
Title 18
Section 1963(a)(3).
1963(a)(3).
Narcotics
Narcotics Forfeiture
Forfeiture
3. Pursuant to Title
Pursuant Title 21, United States
Code, Section
Section 853(a), upon conviction
853(a), upon conviction of an
offense in violation
offense Controlled Substances
violation of the Controlled Act, as alleged
Substances Act, alleged in Count
CoW1tThree
Three of th.is
this Fourth
Fourth
Superseding
Superseding Indictment
Indictment, , the defendant,
defendant ,
MICHAEL
EDUARDO CONTRERAS,
a/k/a "Katra,"
a/kla "Katra,"
shall
shall forfeit to the United
United States America:
States of America:
a. any other
other property constituting, or derived
property constituting, derived from,
from, any proceeds obtained , directly
proceeds obtained, directly
or indirectly
indirectly, , as the result of such violations · and
such violations; and
b. any property
property used or intended
intended to be used,
used, in any manner
manner or part, to commit,
commit , or to
facilitate commission of, such

facilitate the commission such violations.
violations.
Extortion Forfeiture
Extortion Forfeiture
4. Pursuant Title 18, United

Pursuant to Title United States Code, Section
States Code, Section 981(a)(l)(C), Title 28, United
981 (a)(I )(C), and Title United
States Code,
States Code, Section
Section 2461
2461, upon a conviction
conviction of an offense
offense in violation
violation of Title
Title 18, United States
States
Code,
Code, Section 1951(a),
Section 1951(a), as alleged
alleged in Count Fourth Superseding
Count Four of this Fourth Superseding Indictment
Indictment, , the
defendants,
defendants,
24
96
FERNANDOO ORELLANA
LUIS FERNAND
LUIS -ESTRA DA,
ORELLANA-ESTRADA,
a/k/a "Pinguino,"
a/k1a and
"Pinguino ," and
DONALD ROBERT
DONALD ROBERTOO MENDEZ-L OPEZ,
MENDEZ-LOPEZ,
"Chuckie,"
a/k/a "Chuckie,"
a/k1a
forfeit to the United

shall forfeit
shall property constituting
States, all property
United States, from, proceed
derived from,
constituting, , or derived obtained,
proceedss obtained,
directly or indirectly,
directly such violation.
result of such
indirectly as a result violation.
Substitute Assets
Substitute Assets
5. If any
any of the property described above,
property described above, as a result any act
result of any omission of the
act or omission
defendants:
defendants:
a. cannot located upon the exercise

cannot be located diligence ;
due diligence;
exercise of due
b. has been transferred

transferred or sold to, or deposited
sold to, with, aa third
deposited with, party;;
third party
c. placed beyond
has been placed beyond the jurisdiction court;
the court;
jurisdiction of the
d. bas been substantially

has been value· or
diminished in value;
substantially diminished
e. has been commingled

commingled with
with other property which
other property cannot be divided
which cannot without
divided without
difficulty,
difficulty,
United States
the United States of America
America shall
shall be entitled forfeiture of substitute
entitled to forfeiture property pursuant
substitute property Title
pursuant to Title
United States
18 United States Code,
Code, Section 1963(m) and Title
Section 1963(m) 21, United
Title 21, States Code,
United States 853(p).
Section 853(p).
Code, Section
U.S.C. §
18 U.S.C. S 981(a)(l)(C)
981(a)(I)(C)
U.S.c. S§ 1963
18 U.S.C. 1963
U.S.c. . S§ 853
2 1 U.S.C
21 853
U.S.c. S§ 2461(c)
28 U.S.C. 2461(c)
Step en M.
Step Schenning
M. Schenning
Acting United States
Acting United States Attorney
Attorney
A TRUE
TRUE BILL:
Date:
Date: \ \~ \ C\ \\ ~I.
Q...C\
Q_ \7 .
SIGNATURE
SIGNATURE REDACTED
REDACTED .
25
97
Case 1:17-cr-00589-JKB Document 46 Filed 03/29/18 Page 1 of 24
FILED
U.S.DISTRICT
COURT
SM:USAO#20l7R00635 DISTRICT
Of'MARYLAND
IN THE UNITED STATES DIST~f~RfH 3: 49

FOR THE DISTRICT OF MAR~~ OFFICE
ATBALTIMORE
UNITED STATES OF AMERICA CRIMINAL NO. JKB-17-5 9
BY____ QEPUTY
v. (Conspiracy to Participate in a
Racketeering Enterprise, 18 U.S.C.
MOISES ALEXIS REYES-CANALES, § 1962(d); Conspiracy to Commit
a/k/a Sicopata, Murder in Aid of Racketeering,
18 U.S.C. § 1959(a)(S); Murder
MARLON CRUZ-FLORES, in Aid of Racketeering, 18 U.S.C.
a/k/a Little S, § 1959(a)(l); Use, Carry, Brandish,
and Discharge a Firearm During and
FERMIN GOMEZ-JIMENEZ, in Relation to a Crime of Violence,
18 U.S.C. § 924(c); Attempted Murder
MANUEL MARTINEZ-AGUILAR, in Aid of Racketeering, 18 U.S.C.
a/k/a El Lunatic, § 1959(a)(S); Conspiracy to Use, Carry,
a/k/a Zomb, Brandish, and Discharge a Firearm
During and in Relation to a Crime of
JUAN CARLOS SANDOVAL- Violence, 18 U.S.C. § 924(0); and
RODRIGUEZ, Aiding and Abetting, 18 U.S.C. § 2)
a/k/a Picaro,
a/k/a El Pastor,
a/k/a Gasper,
DAVID DIAZ-ALVARADO,
Defendants.
.oOo.
SUPERSEDING INDICTMENT
COUNT ONE
(Conspiracy to Participate in a Racketeering Enterprise)
The Grand Jury for the District of Maryland charges that:
At all times relevant to this Superseding Indictment:
98
Introduction
I. La Mara Salvatrucha, also known as the MS-13 gang ("MS-13"), was a gang
composed primarily of immigrants or descendants of immigrants from El Salvador, with
members operating in the State of Maryland, including in Anne Arundel County, Montgomery
County, Prince George's County, and Frederick County, and throughout the United States.
2. The name "Mara Salvatrucha" was a combination of several slang terms. The
word "Mara" was the term used in El Salvador for "gang." The phrase "Salvatrucha" was a
combination of the words "Salva," which was an abbreviation for "Salvadoran," and "trucha,"
which was a slang term for "fear us," "look out," or "heads up."
3. In the United States, MS-13 has been functioning since at least the 1980s. MS-
13 originated in Los Angeles, California, where MS-13 members banded together for protection
against the larger Mexican groups. MS-13 evolved into a gang that engaged in turf wars for the
control of drug distribution locations. MS-13 quickly spread to states across the country,
including Maryland.
4. MS-13 was a national and international criminal organization and was one of the
largest street gangs in the United States. Gang members actively recruited members, including
juveniles, from communities with a large number of Salvadoran immigrants.
5. MOISES ALEXIS REYES-CANALES, a/k/a Sicopata; MARLON CRUZ-
FLORES a/k/a Little S; FERMIN GOMEZ-JIMENEZ; MANUEL MARTINEZ-
AGUILAR, a/k/a El Lunatic, a/k/a Zomb; JUAN CARLOS SANDOVAL-RODRIGUEZ,
99
a/k/a Picaro, a/k/a El Pastor, a/k/a Gasper; and DAVID DIAZ-ALVARADO; and others
known and unknown to the Grand Jury, were members and associates ofMS-13.
6. Members of MS-13 from time to time signified their membership by wearing
tattoos reading "MARA SALVA TRUCHA," "MS," "MS-13," or similar tattoos, often written in
gothic lettering. Members also signified their membership through tattoos of devil horns in
various places on their bodies. Members sometimes avoided conspicuous MS-13 tattoos,
instead wearing discreet ones such as "503," spider webs, three dots in a triangle formation
signifying "mi vida loca," or clown faces with phrases such as "laugh now, cry later." Some
MS-13 members have chosen not to have tattoos at all, or to have them placed on areas such as
the hairline where they can be easily covered, in order to conceal their gang affiliation from law
enforcement.
7. The gang colors ofMS-13 were blue, black, and white, and members often wore
clothing, particularly sports jerseys, with the number "13 ," or with numbers that, when added
together, totaled 13, such as "76." MS-13 members also wore blue and white clothing to
represent their membership, including blue and white shoes such as the Nike "Cortez." As with
tattoos, some MS-13 members selected more discreet ways of dressing in order to signify their
membership and at the same time avoid detection by law enforcement.
8. MS-I 3 members referred to one another by their gang names, or monikers, and
often did not know fellow gang members except by their gang names.
9. Members ofMS-13 were expected to protect the name, reputation, and status of
the gang from rival gang members and other persons. MS-13 members required that all
individuals show respect and deference to the gang and its membership. To protect the gang
3
100
and to enhance its reputation, MS-13 members were expected to use any means necessary to
force respect from those who showed disrespect, including acts of intimidation and violence.
MS- 13's creed was based on one of its mottos, "Mata, roba, viola, control/a," which translated
in sum and substance to, "Kill, steal, rape, control."
I 0. Members and associates of MS-13 frequently engaged in criminal activity,
including, but not limited to, murder, assault, drug trafficking, robbery, and extortion, as well as
attempts and conspiracies to commit such offenses. MS-13 members were required to commit
acts of violence to maintain membership and discipline within the gang, as well as against rival
gang members. Participation in criminal activity by a member, particularly in violent acts
directed at rival gangs or as directed by gang leadership, increased the respect accorded to that
member, resulted in that member maintaining or increasing his position in the gang, and opened
the door to a promotion to a leadership position. One of the principal rules of MS-13 was that
its members must attack and kill rivals whenever possible. Rivals were often referred to as
"chavalas," MS-13, in the area of Anne Arundel County, Prince George's County and
Montgomery County, Maryland, maintained rivalries with the 18th Street Gang and the Bloods,
among others.
11. Prospective members who sought to join MS-13 were required to complete an
initiation process. Individuals who associated and committed crimes with the gang were called
"paisas," "paros," or "observaciones." Individuals who were attempting to join the gang were
called "chequeos," or "cheqs." Chequeos underwent a probationary period during which they
were required to commit crimes on behalf of MS-13 to achieve trust and prove their loyalty to
the gang. To join MS-13 and become full members or "homeboys," prospective members were
4
101
required to complete an initiation process, often referred to as being "jumped in" or "beat in" to
the gang. During that initiation, other members of MS-13 would beat the new member, usually
until a gang member finished counting aloud to the number thirteen, representing the "13" in
MS-13.
12. MS-13 was an international criminal organization, and was organized in
Maryland and elsewhere into "cliques," that is, smaller groups operating in a specific city or
region. Cliques operated under the umbrella rules ofMS-13. MS-13 cliques often worked
together cooperatively to engage in criminal activity and to assist one another in avoiding
detection by Jaw enforcement. In Maryland and the surrounding area these cliques included,
among others, the Hempstead Locos Salvatrucha ("HLS" or "Hempstead"), Fulton Locos
Salvatrucha ("FLS" or "Fulton"), Hollywood Locos Salvatrucha ("HWLS"), Normandie Locos
Salvatrucha ("NLS" or "Normandie"), Sailors Locos Salvatrucha Westside ("SLSW" or
"Sailors"), Coronados Locos Salvatrucha ("CLS"), Parkview Locos Salvatrucha ("PVLS"),
Guanacos Little Psychos Salvatrucha ("GLS"), and Langley Park Salvatrucha ("LPS").
13. REYES-CANALES, CRUZ-FLORES, GOMEZ-JIMENEZ, MARTINEZ-
AGUILAR, and DIAZ-ALVARADO were members and associates of the Hempstead Clique of
MS-13. SANDOVAL-RODRIGUEZ was a member and associate of the Fulton Clique ofMS-
13.
14. Each clique was presided over by the "First Word," the leader or president of the
clique. The leader was also sometimes referred to as "Primera Palabra," or "Corredor." The
"Second Word," or "Segundo Palabra," was the second-in-command of the clique. General
members were required to take orders from the First Word and Second Word.
5
102
15. MS-13 cliques kept in contact and reported to the leaders for their respective
cliques, who were oftentimes based in various states or in El Salvador. Cliques contacted their
leaders based in other states or El Salvador using cellular telephones during clique meetings to
keep them updated on gang business, for advice, and to resolve disagreements regarding
operations among local cliques. Incarcerated clique leaders based in El Salvador regularly
communicated and directed orders to Maryland-based cliques through phones smuggled into
Salvadoran prisons.
16. MS-13 members met on a regular basis to, among other things, discuss gang
affairs and report on acts of violence committed by their members, with the goal of inciting and
encouraging further violence. Each clique held clique meetings where business specific to that
clique was discussed. Any perceived indiscretions by members or violations ofMS-13 rules
were talked about at clique meetings and punishments or "violations" were issued. Violations
often took the form of beatings by fellow MS- I 3 members. More serious violations resulted in
the issuance of a "greenlight." k greenlight was an order and/or approval to kill.
17. MS-13 leaders from various cliques also held regional meetings to discuss issues
between cliques and discuss criminal ventures among the cliques. Clique leaders from across
the United States, from other countries, and within regions of the United States would meet or
communicate by telephone conference to discuss gang rules and gang business, to resolve
problems or issues among cliques and gang members of different cliques, and to unite gang
members from across the country.
18. MS-13 received money and income from sources including member dues and the
extortion or "taxing" of brothels and other illegitimate businesses, as well as narcotics trafficking
6
103
and the commission ofrobberies. Such funds were used for gang purposes, including obtaining
weapons and providing support for MS-13 gang members who were imprisoned in the United
States, both inside and outside of Maryland, and in El Salvador.
19. MS-13 members communicated about gang activities with other MS-13 members
in Maryland and elsewhere using mobile telephones, telephone text messages, social media such
as Facebook and e-mail accounts, and other modes of communication. Additionally, MS-13
members used international money wire transfers to conduct and promote gang activities.
The Racketeering Enterprise
20. MS-13, including its leadership, membership, and associates, constituted an
enterprise as defined in 18 U.S.C. § 1961(4), that is, a group of individuals associated in fact that
engaged in, and the activities of which affected interstate and foreign commerce ("the
Enterprise"). The Enterprise constituted an ongoing organization whose members functioned as
a continuing unit for a common purpose of achieving the objectives of the Enterprise.
Purposes of the Enterprise
21. The purposes of the MS-13 Enterprise included:
a. Preserving and protecting the power, territory, reputation, and
profits of the enterprise through the use of intimidation, threats of violence, and violence,
including assaults and murder;
b. Promoting and enhancing the enterprise and its leaders', members',
and associates' activities, including, but not limited to, murder, extortion, drug trafficking,
robbery, and other criminal activities;
c. Keeping victims, potential victims, and community members in
fear of the enterprise through violence and threats of violence;
104
d. Providing financial support and information to gang leaders,
members, and associates, including individuals incarcerated in the United States and in El
Salvador;
e. Providing assistance to gang leaders, members, and associates who
committed crimes on behalf of the enterprise; and
f. Hindering, obstructing, and preventing law enforcement officers
from identifying participants in the enterprise's criminal activity; from apprehending the
perpetrators of those crimes; and from successfully prosecuting and punishing the offenders.
Means and Methods of the Enterprise
22. Among the means and methods by which the members and associates of MS-13
conducted and participated in the conduct of the affairs of the Enterprise were the following:
a. The members and associates of MS-13 used intimidation, threats of
violence, and violence, including assaults and murder, to preserve, expand, and protect MS-13 's
territory and activities, to promote and enhance its prestige, reputation, and position in the
community, and to discipline gang members who had been disloyal or had violated gang rules;
b. The members and associates ofMS-13 attended regular gang
meetings and communicated with other MS-13 members to discuss, among other things: the
structure and organization of the gang; past criminal acts committed against rival gang members
and others; MS-13 leaders, members, and associates who had been arrested or incarcerated;
disciplining MS-13 leaders, members, and associates who had violated gang rules; police
interactions with MS-13 leaders, members, and associates; the identities of individuals suspected
of cooperating with law enforcement, and proposed actions to be taken against them; and plans
105
and agreements regarding the commission of future crimes, as well as ways to conceal these
crimes;
c. The members and associates of MS-13 also communicated with
other MS-13 members in Maryland and elsewhere, and represented their gang allegiance,
through social media such as Facebook, including by posting photographs of themselves with
other gang members, showing gang hand signs, wearing colors or clothing associated with MS-
13, and posing with weapons or gang-related graffiti, and by sending and/or posting messages
referencing their affiliation with MS-13.
d. The members and associates of MS-13 financed the enterprise
through a variety of activities, including the extortion of money - sometimes referred to as "rent"
- from gang members and from legitimate and illegitimate businesses operating on the gang's
turf, as well as through the commission of robberies;
e. The members and associates of MS- I 3 distributed and agreed to
distribute controlled substances on behalf of the gang;
f. The funds raised by the gang were used for gang purposes,
including obtaining weapons and providing support for MS-13 gang members, including those
imprisoned in the United States, inside and outside of Maryland, and in El Salvador.
g. The members and associates of MS-I 3 hindered and obstructed the
efforts of law enforcement to identify, apprehend, and successfully prosecute and punish gang
. members;
h. The members and associates of MS-13 would investigate rival
gang members or other persons targeted for violence; would obtain information about such
9
106
targets, including locations frequented by them; and would use such information in their plans to
attack such targets.
1. The members and associates of MS-13 would and did agree that
acts of murder, including conspiracy and attempts to commit murder, and other acts of violence,
would be committed by members and associates ofMS-13 against rival gang members and
persons deemed as threats to MS-13 and for the purpose of imposing discipline within the gang,
and on other occasions as deemed necessary.
23. Beginning on a date unknown to the Grand Jury, but at least prior to in or about
2015, and continuing through at least in or about 2017, in the District of Maryland and
elsewhere,
MOISES ALEXIS REYES-CANALES,

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
FERMIN GOMEZ-JIMENEZ,
MANUEL MARTINEZ-AGUILAR,
a/k/a El Lunatic,
a/k/a Zomb,
defendants herein, and others known and unknown to the Grand Jury, being persons employed
by and associated with MS-13, an enterprise engaged in, and the activities of which affected,
interstate and foreign commerce, did knowingly conspire to violate Title 18 U.S.C. § 1962(c),
that is to conduct and participate, directly, and indirectly, in the conduct of the affairs of the MS-
13 Enterprise through a pattern of racketeering activity, as defined in 18 U.S.C. §§ I 961(1) and
(5), which pattern of racketeering activity consisted of:
(a) Multiple acts involving:
10
107
(I) murder, in violation of Maryland Code, Criminal Law§§ 2-201, 2-
204, 2-205, and 2-206, 1-202, and the Common Law of Maryland,
punishable pursuant to Maryland Code, Criminal Law§§ 1-201, 1-
202, 2-201, 2-204, 2-205, and 2-206;
(2) extortion, in violation of Maryland Code, Criminal Law§§ 3-701
and 3-705, 1-202, and the Common Law of Maryland;
(3) robbery, in violation of Maryland Code, Criminal Law§§ 3-402
and 3-403, 1-202, and Common Law of Maryland; and
(b) Multiple offenses involving drug trafficking in violation of21 U.S.C. §§ 841 and
846;
(c) Multiple acts indictable under:
(1) 18 U.S.C. §§ 1512 and 1513 (relating to tampering or retaliation
against a witness, victim, or informant); and
(2) 18 U.S.C. § 1951 (relating to interference with commerce, robbery
or extortion).
24. It was further part of the conspiracy that each defendant agreed that a conspirator
would commit at least two acts ofracketeering activity in the conduct of the affairs of the
enterprise.
Overt Acts
25. In furtherance of the conspiracy, and to effect the illegal object thereof, the
defendants and their co-conspirators performed, participated in, and did the following acts,
among others, in the District of Maryland and elsewhere:
11
108
a. On or about September 27, 2015, MARTINEZ-AGUILAR and other
members and associates of MS-13 confronted a person known to the Grand Jury and identified
for the purposes of this Superseding Indictment as Victim-4, and threatened Victim-4 that
Victim-4 must pay money to MS-13 to continue selling marijuana in MS-13 territory.
b_- On or about September 27, 2015, MARTINEZ-AGUILAR and others
then assaulted and struck Victim-4 with a blunt object during an altercation between MS-13
members and associates and friends ofVictim-4.
c. In or about September 2015, MARTINEZ-AGUILAR and another
member and associate of MS-13 assaulted Victim-4.
d. In or about February 2016, members and associates ofMS-13 conspired to
murder a member or associate of the rival 18th Street gang, known'to the Grand Jury and
identified for the purposes of this Superseding Indictment as Victim-!. As part of the plan,
members and associates ofMS-13 spoke with MS-13 leaders outside of the District of Maryland
to seek approval to commit the murder.
e. On or about March 11, 2016, SANDOVAL-RODRIGUEZ and another
member or associate of MS-13 lured Victim-! to a park in Annapolis, Maryland with the intent
to murder Victim-!.
f. On or about March 11, 2016, CRUZ-FLORES, GOMEZ-JIMENEZ,
SANDOVAL-RODRIGUEZ, and DIAZ-ALVARADO, and other members and associates of
MS-13 murdered Victim-! in Annapolis, Maryland.
g. In or around October 2016, REYES-CANALES, CRUZ-FLORES,
GOMEZ-JIMENEZ, MARTINEZ-AGUILAR, and other members and associates ofMS-13
12
109
conspired to murder a member or associate of the rival 18'h Street gang, known to the Grand Jury
and identified for the purposes of this Superseding Indictment as Victim-2, using guns and
knives.
h. On or about October 23, 2016, CRUZ-FLORES and REYES-
CANALES each possessed a firearm to use during the murder of Victim-2.
1. On or about October 23, 2016, GOMEZ-JIMENEZ armed himself with a
sharp weapon for the purpose of killing Victim-2.
J. On or about October 23, 2016, CRUZ-FLORES lured Victim-2 to an area
of Annapolis, Maryland with the intent to murder Victim-2.
k. On or about October 23, 2016, REYES-CANALES, CRUZ-FLORES,
decided to kill an individual known to the Grand Jury and identified for the purposes of this
Superseding Indictment as Victim-3 because Victim-2 was with Victim-3 and would be a
witness to the murder of Victim-2.
I. On or about October 23, 2016, REYES-CANALES, CRUZ-FLORES,
attempted to kill Victim-2 by stabbing Victim-2 multiple times.
m. On or about October 23, 2016, REYES-CANALES, CRUZ-FLORES,
attempted to kill Victim-3 by shooting Victim-3 multiple times and stabbing Victim-3 multiple
times.
13
110
n. On or about October 23, 2016, MARTINEZ-AGUILAR and another
member and associate of MS-13 attempted to kill Victim-2 by running over Victim-2 with
Victim-2's car.
o. On or about October 23, 2016, MARTINEZ-AGUILAR and another
member and associate ofMS-13 attempted to dispose ofVictim-2's car by burning the car.
p. On or about October 24, 2016, REYES-CANALES and CRUZ-
FLORES fled to Georgia to avoid detection by law enforcement.
q. Between in or about January 2016 and February 2017, REYES-
CANALES, CRUZ-FLORES, GOMEZ-JIMENEZ, MARTINEZ-AGUILAR, and other
members and associates ofMS-13 sold cocaine and marijuana to raise funds for MS-13. The
drug proceeds were used for, among other reasons, the purchase of more narcotics, weapons, and
to send to MS-13 members and associates in other states and El Salvador.
r. Between in or about January 2016 and February 2017, REYES-
CANALES collected the proceeds from the narcotics sales from the other members and
associates of MS-13.
Special Sentencing Factors Regarding Count One
26. On or about March I I, 2016, in the District of Maryland, GOMEZ-JIMENEZ,
CRUZ-FLORES, SANDOVAL-RODRIGUEZ, and DIAZ-ALVARADO unlawfully
conspired with each other and others known and unknown to the Grand Jury to feloniously,
willfully, and with deliberately premeditated malice, kill and murder Victim-I, in violation of
Maryland Code, Criminal Law§ 2-20l(a)(l) and the Common Law of Maryland, and punishable
pursuant to Maryland Code, Criminal Law § 1-202.
14
111
27. On or about March 11, 2016, in the District of Maryland, GOMEZ-JIMENEZ,
CRUZ-FLORES, SANDOVAL-RODRIGUEZ, and DIAZ-ALVARADO feloniously,
willfully, and with deliberately premeditated malice, killed and murdered Victim-I, in violation
of Maryland Code, Criminal Law§ 2-20J(a)(l).
28. In or about October 2016, in the District of Maryland, REYES-CANALES,
GOMEZ-JIMENEZ, CRUZ-FLORES, and MARTINEZ-AGUILAR unlawfully conspired
with others known and unknown to the Grand Jury to feloniously, willfully, and with deliberately
premeditated malice, kill and murder Victim-2 and Victim-3, in violation of Maryland Code,
Criminal Law§ 2-20l(a)(l) and the Common Law of Maryland, and punishable pursuant to
Maryland Code, Criminal Law§ 1-202.
29. On or about October 23, 2016, in the District of Maryland, REYES-CANALES,
GOMEZ-JIMENEZ, CRUZ-FLORES, and MARTINEZ-AGUILAR feloniously, willfully,
and with deliberately premeditated malice attempted to murder Victim-2 in violation of
Maryland Code, Criminal Law§§ 2-205 and 2-201, and the Common Law of Maryland, and
punishable pursuant to Criminal Law§ 1-201.
30. On or about October 23, 2016, in the District of Maryland, REYES-CANALES,
GOMEZ-JIMENEZ, CRUZ-FLORES, and MARTINEZ-AGUILAR feloniously, willfully,
and with deliberately premeditated malice attempted to murder Victim-3 in violation of
Maryland Code, Criminal Law§§ 2-205 and 2-201, and the Common Law of Maryland, and
punishable pursuant to Criminal Law§ 1-201.
All in violation of 18 U.S.C. § 1962(d)'
15
112
COUNT TWO
(Murder in Aid of Racketeering)
The Grand Jury for the District of Maryland further charges that:
1. Paragraphs 1 through 22 of Count One of this Superseding Indictment are
incorporated here.
2. MS-13, including its leadership, membership, and associates, constituted an
enterprise as defined in 18 U.S.C. § 1959(b)(2), that is, a group of individuals associated in fact
that engaged in, and the activities of which affected interstate and foreign commerce ("the
Enterprise"). The Enterprise constituted an ongoing organization whose members functioned as
a continuing unit for a common purpose of achieving the objectives of the Enterprise.
3. The Enterprise, through its members, leaders, and associates, engaged in
racketeering activity, as defined in 18 U.S.C. §§ 1959(b)(l), and 1961(1), that is acts involving
murder, extortion, and robbery, in violation of Maryland Law; and offenses involving drug
trafficking, in violation of21 U.S.C. §§ 841 and 846; and offenses indictable under 18 U.S.C. §§
1512 and 1513 (relating to tampering or retaliation against a witness, victim, or informant) and
18 U.S.C. § 1951 (relating to interference with commerce, robbery or extortion).
4. On or about March 11, 2016, in the District of Maryland,
MARLON CRUZ-FLORES,
a/k/a Little S,
JUAN CARLOS SANDOVAL-RODRIGUEZ,
a/k/a Picaro,
a/k/a El Pastor,
a/k/a Gasper,
16
113
together with others, known and unknown, for the purpose of gaining entrance to, and
maintaining and increasing position in MS-13, an enterprise engaged in racketeering activity, did
murder Victim- I, in violation of and punishable pursuant to Maryland Code, Criminal Law §§ 2-
201 and 2-204, and the Common Law of Maryland, all in violation of 18 U.S.C. § 1959(a)(l).
18 U.S.C. § 1959(a)(l)
18 u.s.c.§ 2
17
114
COUNT THREE
(Conspiracy to Commit Murder in Aid of Racketeering)
I. Paragraphs I through 3 of Count Two of this Superseding Indictment are
incorporated here.
2. On or about March 11, 2016, in the District of Maryland,
MARLON CRUZ-FLORES,
a/k/a Little S,
JUAN CARLOS SANDOVAL-RODRIGUEZ,
a/k/a Picaro,
a/k/a El Pastor,
a/k/a Gasper,
for the purpose of gaining entrance to, and maintaining and increasing position in MS-13, an
enterprise engaged in racketeering activity, did knowingly and willfully combine, conspire,
confederate, and agree with each other and others known and unknown to the Grand Jury to
murder Victim-I, in violation of and punishable pursuant to Maryland Code, Criminal Law §§ 2-
201, 2-204, and 1-202, and the Common Law of Maryland, all in violation of 18 U.S.C. §
l 959(a)(5).
18 U.S.C. § 1959(a)(5)
18
115
COUNT FOUR
(Attempted Murder in Aid of Racketeering)
1. Paragraphs 1 through 3 of Count Two of this Superseding Indictment are
incorporated here.
2. On or about October 23, 2016, in the District of Maryland,
. MOISES ALEXIS REYES-CANALES,

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
together with others known and unknown, for the purpose of gaining entrance to and maintaining
and increasing position in MS-13, an enterprise engaged in racketeering activity, attempted to
murder and aided and abetted in the attempted murder ofVictim-2, in violation of Maryland
Code, Criminal Law,§§ 2-201 and 2-205, and the Common Law of Maryland.
18 U.S.C. § 1959(a)(5)
18 U.S.C. § 2
19
116
COUNT FIVE
(Conspiracy to Commit Murder in Aid of Racketeering)
I. Paragraphs 1 through 3 of Count Two of this Superseding Indictment are
incorporated here.

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
for the purpose of gaining entrance to, and maintaining and increasing position in MS-13, an
enterprise engaged in racketeering activity, did knowingly and willfully combine, conspire,
confederate, and agree with each other and others known and unknown to the Grand Jury to
murder Victim-2 and Victim-3, in violation of and punishable pursuant to Maryland Code,
Criminal Law§§ 2-201, 2-204, and 1-202, and the Common Law of Maryland, all in violation of
18 U.S.C. § 1959(a)(5).
18 U.S.C. § 1959(a)(5)
20
117
COUNT SIX
(Use and Carry a Firearm During and In Relation to a Crime of Violence)
I. On or about October 23, 2016, in the District of Maryland,

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
together with others known and unknown, did knowingly possess, brandish, and discharge a
firearm, and aided and abetted, the knowing possession, brandish, and discharge of a firearm in
furtherance of a crime of violence for which he may be prosecuted in a court of the United
States, to wit: Attempted Murder in Aid of Racketeering, as set forth in Count Four of this
Superseding Indictment, in violation of 18 U.S.C. § l 959(a)(5), which is incorporated by
reference.
18 U.S.C. § 924(c)
18 U.S.C. § 2
21
118
COUNT SEVEN
(Attempted Murder in Aid of Racketeering)
I. Paragraphs I through 3 of Count Two of this Superseding Indictment are
incorporated here.

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
together with others known and unknown, for the purpose of gaining entrance to and maintaining
and increasing position in MS-13, an enterprise engaged in racketeering activity, attempted to
murder and aided and abetted in the attempted murder of Victim-3, in violation of Maryland
Code, Criminal Law,§§ 2-201 and 2-205, and the Common Law of Maryland.
18 U.S.C. § 1959(a)(5)
18 U.S.C. § 2
22
119
COUNT EIGHT
{Use and Carry a Firearm During and In Relation to a Crime of Violence)

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
together with others known and unknown, did knowingly possess, brandish, and discharge a
firearm, and aided and abetted, the knowing possession, brandish, and discharge of a firearm in
furtherance ofa crime of violence for which he may be prosecuted in a court of the United
States, to wit: Attempted Murder in Aid of Racketeering, as set forth in Count Seven of this
Superseding Indictment, in violation of 18 U.S.C. § 1959(a)(5), which is incorporated by
reference.
18 U.S.C. § 924(c)
18 U.S.C. § 2
23
120
COUNT NINE
(Conspiracy to Possess a Firearm in Furtherance of Crime of Violence)

a/k/a Sicopata,
MARLON CRUZ-FLORES,
a/k/a Little S,
a/k/a El Lunatic,
a/k/a Zomb,
together with others known and unknown, did knowingly and intentionally conspire and agree
with each other and other to possess, brandish, and discharge firearm in furtherance of a crime of
violence for which he may be prosecuted in a court of the United States, to wit: Attempted
Murder in Aid of Racketeering, as set forth in Count Four and Count Seven of this Superseding
Indictment, in violation of 18 U.S.C. § 1959(a)(5), which is incorporated by reference.
18 U.S.C. § 924(0)
"
Stephe M. Schenning
Acting United States Attorney
. A TRUE BILL: ___ _
SIGNATURE
REDACTED Date: s/4,r
/;,r
_ _,_, -'--'-, -'----=-----
-Foreperson
24
121

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UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

EASTERN DISTRICT OF NEW YORK, SS:

SEAN C. MCMULLEN, being duly sworn, deposes and states

that he is a Special Agent with the Federal Bureau of Investigation

("FBI"), duly appointed according to law and acting as such.

Upon information and belief, in or about and between

inclusive, within the Eastern District of New York, the defendant

ELMER ALEXANDER LOPEZ, also known as "Smiley" and "Little Smiley,"

together with others, for the purpose of gaining entrance to and

maintaining and increasing position in La Mara Salvatrucha, also

known as the MS-13 street gang (the "MS-13"), an enterprise that

was engaged in racketeering activity, did knowingly and

intentionally attempt to murder John Doe, an individual whose

Law Section 125.25(1).

(Title 18, United States Code, Sections 1959(a) (5) and

Upon information and belief, on or about July 3, 2016,

within the Eastern District of New York, the defendant ELMER

ALEXANDER LOPEZ, also known as "Smiley" and "Little Smiley,"

a firearm during and in relation to a crime of violence, to wit,

the above-violation of 18 U.S.C. § 1959(a) (5), which firearm was

(Title 18, United State Code, Sections

924 (c) (1) (A) (iii) and 2).

The source of your deponent's information and the grounds

for his belief are as follows: 11

1. I have been a Special Agent with the FBI for

approximately 20 years. I am currently assigned to the FBI's Long

Island Gang Task Force (the "Task Force"), which is comprised of

agents and officers of the FBI, Nassau County Police Department,

Nassau County Sheriff's Department, Suffolk County Police

Department ( "SCPD"), Suffolk County Probation, Suffolk County

!I Because the purpose of this affidavit is to establish only

primary mission of the Task Force is to combat violent crime

perpetrated by street gang members. The information contained in

this affidavit comes from first-hand knowledge, surveillance,

interviews of gang members, my discussions with witnesses involved

in the investigation, my discussions with other agents and

officers, and a review of reports and evidence related to this

2. Many of the cases investigated by the Task Force

involve members of the MS-13. The MS-13 constitutes an

"enterprise" as defined in Section 1959 (b) (2) of Title 18, United

States Code, that is, a group of individuals associated in fact

that engages in, and the activities of which affect, interstate

and foreign commerce. Furthermore, the MS-13, through its members

and associates, engages in racketeering activity, as defined in

that is, acts and threats involving murder, in violation of the

laws of the State of New York, and narcotics trafficking, in

indicted and convicted in the Eastern District of New York for,

in violation of Title 18, United States Code, Section 1959(a).

3. The MS-13, primarily comprised of immigrants from

El Salvador and Honduras, has members located throughout Long

chapters, or "cliques," have been established in New York,

Maryland, Virginia, North Carolina, Texas, California and

elsewhere. Following induction, members of the MS-13 sometimes

signify their membership with gang-related tattoos. On Long

Island, MS-13 cliques have been established in various towns

including Hempstead, Freeport, Westbury, Roosevelt, Huntington,

Brentwood and Islip. The cliques routinely hold meetings to plan

criminal activity and members pay dues into a clique treasury.

The treasury funds are used to purchase firearms and ammunition

and to promote other illegal activity. Inter-clique meetings,

called "Universals," are used to coordinate criminal activities

among different cliques. Participation in criminal activity by a