Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 1 of 43 DETENTION AFFIDAVIT OF SPECIAL AGENT MATTHEW R. ZAREMBA I, Matthew R. Zaremba, being duly sworn, depose and state as follows: I. INTRODUCTION 1. I submit this affidavit in support of the government’s motion that the following individuals be detained pending trial or in support of the government’s request for conditions of pretrial release for: a. SARATH YUT, a/k/a “BLACK,” a/k/a “KHMAO,” a/k/a “ASIAN WARRIOR,” a/k/a “CEASAR,” a/k/a “JASON CHAN,” a/k/a “S. KONG,” b. VIRAK PRUM, a/k/a “POLO,” a/k/a “CAPO,” a/k/a “LIPS,” c. PEOUVEASNAH PIN, a/k/a “POE,” a/k/a “PANDA PO,” d. SAMBO BUTH, a/k/a “CHEWY, a/k/a “CHING,” e. SAMBATH LAY, a/k/a “G,” a/k/a “GRIMEY,” f. MARK YIN, a/k/a “MARKASS,” g. CHRISTOPHER PHANN, a/k/a “KREE,” h. DARASY CHHIM, a/k/a “MYSTIKAL,” a/k/a “RIZZUS,” i. SRIPHAN KEOMANY, a/k/a “C-PON,” a/k/a “C,” a/k/a “OLE MAN,” j. VONGNARHOTH PROEUNG, a/k/a SUNNY,” a/k/a “OG DEUCE,” k. VICTORY THORN, l. CHOMROEUN KEO, a/k/a “SHREK,” a/k/a “LONG HAIR SHREK,” m. GAUIS MONTEYRO, a/k/a “G-MADE,” n. SAMOEUN KEM, a/k/a “CRAZY ONE,” a/k/a “CRAZY,” a/k/a “SAM,” and o. RICHARD SAM, a/k/a “LIL STOMPER,” a/k/a “BOY.” Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 2 of 43 II. BACKGROUND OF INVESTIGATION 2. Leading up to and during the summer of 2018, the city of Lowell experienced a dramatic spike in shootings and gang violence. In an article posted in the Lowell Sun on July 31, 2018, highlighting the violence, Lowell City Manager Eileen Donoghue stated, “it’s clear that nobody is happy about the recent incidents” and “it will not be tolerated.”1 The Interim Lowell Police Superintendent, Jack Webb, attributed the series of recent shootings to two competing gangs, Cambodian Mob Family, or CMF, and the Outlaws. Webb stated, “they’re responsible for the vast majority of violence” and “the violence is happening wherever these members happen to live, and they live all over the city.”2 The Lowell Police made great strides in solving cases and addressing the increase in violence, to include reaching out to community partners as well as other law enforcement agencies. 3. In August of 2018, Lowell Police contacted the FBI, Lowell Resident Agency (RA) to address the recent uptick in gang-related shootings and violence. Since that time, the FBI, Lowell (RA) and Lowell Police Department, alongside other federal agencies to include the United States Postal Inspector Service (USPIS), the Drug Enforcement Administration (DEA) and the Internal Revenue Service (IRS), have been engaged in an investigation into the One Family Clique (“OFC”), which is an alliance of several local gangs primarily based out of Lowell, Massachusetts, with ties to California and other states throughout the country. OFC is an association of primarily Asian gangs but also has alliances of convenience with other non-Asian gang members. SARATH YUT (“YUT”) is a founder and leader of OFC and a member of Crazy Mob Family (“CMF”). 1 Lowell Sun News – Lowell Police: Gang dispute behind recent violence, July 31, 2018 String of violence continues in Lowell with gunfire, stabbing – Lowell Sun 2 Lowell Sun News – Lowell Police: Gang dispute behind recent violence, July 31, 2018 String of violence continues in Lowell with gunfire, stabbing – Lowell Sun 2 Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 3 of 43 4. Since the start of this investigation, Lowell Police attribute twelve incidents involving gunfire to the growing tensions between OFC and rival gang members. On June 18, 2018, there was a shooting that resulted in the death of OFC / CMF member Sarom YUT, a/k/a “EVO.” Sarom YUT is the brother of SARATH YUT, a main target of this investigation. I believe that this shooting was related to a rivalry between OFC and rival Lowell gang members, the PHAN Family / the Outlaws. Numerous incidents, including a physical assault on YUT in May 2018 and Billy PHAN surviving a gunshot wound to the head (on the same day, June 18, 2018), led to the shooting. III. HISTORY OF GANG VIOLENCE 5. Crazy Mob Family, also known at one time as Crazy Mafia Family, a/k/a “CMF” originated in California and formed locally in Lowell, Massachusetts in the late 1990’s to early 2000’s. Dating back to 2007, YUT had self-identified as a member of CMF, according to law enforcement. 6. In the mid to late 2000’s, under the direction of YUT, several of the gang sets in Lowell, both Bloods and Crips, to include Crazy Mob Family (CMF), Crazy Brother Clan (CBC), Insane Blood Gang (IBG), Ruthless Cambodian Bloods (RCB), Moonlight Strangers (MLS), Dangerous Little Bloods (DLB), Original Bloods (OB), Diamond Crips (DC), Sworn Brothers (SB), and the Outlaws created an informal alliance under the umbrella One Family Clique, or OFC. The gang sets retained their independence but worked in conjunction with one another to expand their criminal network. YUT has established himself as the leader of this more expansive group, which is well known and feared within the City of Lowell. Below is a photograph of OFC members and associates gathered at the West Lawn Cemetery in Lowell, at the gravesite of Sarom YUT on September 5, 2019. 3 Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 4 of 43 Left to right standing: Chomroeun KEO, a/k/a SHREK (wearing dark colored plaid shirt and jeans with “LA” hat), Peouveasnah PIN, a/k/a POE (wearing a black hoodie (up) and a baseball cap holding a plastic cup), Sriphan KEOMANY, a/k/a C-PON (wearing a black and white hoodie and black Red Sox hat), Sarath YUT, a/k/a BLACK (wearing a black hoodie with unk letterings and a back hat. YUT appears to be brandishing a firearm in his right hand. Darasy CHHIM, a/k/a MYSTIKAL, (wearing a black jacket, black shirt, and a black hat), Sambath LAY, a/k/a G, (wearing a blue working shirt with white name tapes, holding a beer). Kneeling in first row: Richard SAM, a/k/a LIL STOMPER (wearing a back jacket with the word “CAMBODIA,”black hat, holding a plastic cup in right hand). 7. Historically, OFC and their subsets were rivals with, among others, the Asian Boyz (ABZ) and Tiny Rascal Gang (TRG). Since about 2018, the Outlaws ended the alliance they had with OFC, reportedly over a debt owed, and have become one of OFC’s biggest rivals. Members and associates from both sides have been involved in acts of violence, back and forth, to including fatal and non-fatal shootings. 4 Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 5 of 43 8. The feud between OFC and the Outlaws started in or around early 2018. In May 2018, YUT was allegedly jumped and robbed of a gold chain. It’s unknown where this incident took place, as it was not reported to the police; however in a recorded jail call with CMF member Michael MAO, a/k/a “SPOOK,”3 YUT suggested that the Outlaws robbed him of his chain in an act motivated by gang rivalry. YUT: My necklace was snatched from my neck …uh last Saturday. MM: Who di – Do you know who it was? YUT: Yeah, Outlaw crew. YUT: Ah Noy and them. Ah Boy and his brothers. MM: What? YUT: Yeah. MM: Oh. I mean what’s going – what’s going – I mean what’s up? YUT: Yeah – you already know the deal. MM: All the bitch ass niggers man. YUT: Yep [laughs] It is what it is, right? 9. The following month, in June, another member of OFC was assaulted and robbed of his necklace outside of P&P Jewelry on Middlesex Street in Lowell. The surveillance video shows three Asian males fitting the description of the Phan brothers, in the immediate area at the time of the assault. A day later, on June 18, 2018, a member of the Phan Family Outlaws was shot in the head. He managed to survive his injuries. The suspected vehicle involved in the shooting belonged to an OFC member and was later recovered in Providence, Rhode Island at a residence 3 MAO is currently incarcerated at Buckingham. 5 Case 1:21-cr-10183-WGY Document 18 Filed 06/10/21 Page 6 of 43 associated with another OFC member. That same day, Sarom Yut, a/k/a EVO, member of OFC and YUT’s brother, was shot and killed outside of 70 Smith Street while he was streaming live on social media. Another OFC member, and YUT’s relative, was also shot but survived. The vehicle seen fleeing the scene was registered to a member of one of the Phan Family Outlaws. Three days later, another member of OFC was shot at while in his car. In a recorded call on June 23, 2018, with MAO, YUT spoke about on the violence and stated that it all stemmed from the incident when he was jumped and robbed of his chain. MM: Hello? YUT: Yo MM: Whats up bruh? YUT: Man, its been a long week but what’s up? MM: What you say? YUT: Its been a long week.