AO 91 (REV.5/85) Criminal Complaint AUSA ANDREW PORTER 312-353-5358 AUSA T. DIAMANTATOS 312-353-4317 AUSA NANCY MILLER 312-353-4224 W4444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444444 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION UNITED STATES OF AMERICA CRIMINAL COMPLAINT v. CASE NUMBER VICENTE GARCIA, aka “DK” and others UNDER SEAL I, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. Beginning in or aroundSeptember 2007 and continuing to present, in Cook County, in the Northern District of Illinois, and elsewhere, defendants, knowingly and intentionally conspired to possess with intent to distribute and to distribute in excess of 500 grams of mixtures containing cocaine, a Schedule II Narcotic Drug Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1), all in violation of Title 21 United States Code, Section 846. I further state that I am a(n) Special Agent, FBI and that this complaint is based on the following facts: See Attached Affidavit. Continued on the attached sheet and made a part hereof: X Yes No Signature of Complainant Sworn to before me and subscribed in my presence, September , 2008 at Chicago, Illinois Date City and State Maria Valdez, Magistrate Judge Name & Title of Judicial Officer Signature of Judicial Officer 2. VALENTIN BAEZ, aka “Baby 24,” “Valentin Biez;” 3. ROLANDO BAUTISTA, aka "Shorty;" 4. ALPHONSO CHAVEZ, aka "Ponch;" 5. JUAN DEJESUS, aka "Baby 28;" 6. DANNY DOMINGUEZ, aka "Baby Trigger,” “Baby T;” 7. JOSE DOMINGUEZ, aka "Silent;" 8. DANIEL GALINDO, aka "Horse;" 9. LUIS GARCIA, aka "Wild,” “Jose Campos;” 10. CHRISTOPHER GONZALEZ, aka "Jouster;" 11. POL GONZALEZ, aka “Hustler;” 12. SAMUEL GUTIERREZ, aka "Wedo;" 13. JOSE GUZMAN, aka "Boo Boo;" 14. ROBERTO GUZMAN, aka "Devious;" 15. DAVID HERNANDEZ, aka "Cubby;" 16. POLIN LOPEZ, aka "Baby 23;" 17. GREGORY MENDOZA, aka "Lil Psycho;" 18. JOSE PEREZ, aka "Chaqual,” “Ricardo Fernandez,” “Arturo Hernandez;” 19. JAVIER RAMIREZ, aka "Convict;" 20. STEVEN RANGEL, aka "Stevie,” “Crazy K;” 21. WILFREDO RIVERA, JR., aka "Boy;" 22. BELSAIN RODRIGUEZ, aka "Lil Diablo;” 23. JOSEPH SEGURA, aka “JD;” 24. FERNANDO VAZQUEZ, aka "Pac Man;” 25. ADOLFO ZUNIGA, JR., aka "KING MENACE;" STATE OF ILLINOIS ) ) COUNTY OF COOK ) AFFIDAVIT I. INTRODUCTION I, James G. McDonald, being duly sworn, state as follows: 1. I am a Special Agent (SA) of the United States Department of Justice, Federal Bureau of Investigation (FBI). I have been so employed for approximately five years. I am currently assigned to a FBI/Chicago Police Department (CPD) Joint Task Force on Gangs, FBI Chicago Field Division, and have been so assigned for the past five. As a part of my official duties, I investigate criminal violations of the federal narcotics laws, including, but not limited to, Title 21, United States Code, Sections 841, 843 and 846. I have received special training in the enforcement of laws concerning controlled substances and gang-related activities. I have also been involved in various types of electronic surveillance, in the debriefing of defendants, witnesses, and informants, as well as others who have knowledge of the distribution of controlled substances 2. The following information is based upon my personal observations, knowledge and information I received from other Federal Law Enforcement Officers, CPD, and others, and Cooperating Witnesses (CWs) who have proven reliable and provided information which has been independently corroborated, as set forth in part, herein. 3. Because this affidavit is being submitted for the limited purpose of establishing probable cause for the issuance of a complaint charging VICENTE GARCIA, aka “Disciple 1 Killer,” “DK,” “Black,” “The Coon,” “The Possum;” VALENTIN BAEZ, aka "Baby 24,” “Valentin Biez;” ROLANDO BAUTISTA, aka "Shorty;" ALPHONSO CHAVEZ, aka "Ponch;" JUAN DEJESUS, aka "Baby 28;" DANNY DOMINGUEZ, aka "Baby Trigger,” “Baby T;” JOSE DOMINGUEZ, aka "Silent;" DANIEL GALINDO, aka "Horse;" LUIS GARCIA, aka "Wild,” “Jose Campos;” CHRISTOPHER GONZALEZ, aka "Jouster;" POL GONZALEZ, aka “Hustler;” SAMUEL GUTIERREZ, aka "Wedo;" JOSE GUZMAN, aka "Boo Boo;" ROBERTO GUZMAN, aka "Devious;" DAVID HERNANDEZ, aka "Cubby;" POLIN LOPEZ, aka "Baby 23;" GREGORY MENDOZA, aka "Lil Psycho;" JOSE PEREZ, aka "Chaqual,” “Ricardo Fernandez,” “Arturo Hernandez;” JAVIER RAMIREZ, aka "Convict;" STEVEN RANGEL, aka "Stevie,” “Crazy K;” WILFREDO RIVERA, JR., aka "Boy;" BELSAIN RODRIGUEZ, aka "Lil Diablo;” JOSEPH SEGURA, aka “JD;” FERNANDO VAZQUEZ, aka "Pac Man;” and ADOLFO ZUNIGA, JR., aka "KING MENACE;" with conspiracy to possess with intent to distribute and to distribute in excess of 500 grams of cocaine, in violation of Title 21, United States Code, Section 846, it does not contain all the information known to me concerning this investigation. II. BACKGROUND A. The 26th Street Region of the Latin Kings Street Gang. 4. This investigation was initiated in September of 2004 based on information derived from confidential informants, local police investigations, and arrest reports concerning gang members of the Latin Kings Street Gang. These sources revealed that members of the 26th Street Region of the Latin Kings Street Gang were actively involved 2 in the sale of cocaine and, to a lesser extent, crack cocaine in the neighborhoods in and around the Little Village area of Chicago, Illinois. 5. The following background information is derived from Affiant's knowledge of and prior experience in Chicago area street gang investigations and violent crime, including those at the local, state and federal levels; published sources of information concerning Chicago area street gangs; information obtained during past interviews with numerous gang members and criminal informants conducted by Affiant and other law enforcement officers; recorded conversations obtained during this investigation; and information obtained by the Affiant from other investigators experienced in street gang investigations. 6. The Latin Kings Street Gang, also referred to as the Almighty Latin King Nation (ALKN), is a violent, well organized street gang, controlled through a hierarchical system. The Latin Kings gang members active within Chicago are organized by geographic locations into "Regions." Generally, each Region has a rank structure consisting of a "Regional Officer" and one or more "Regional Enforcers." The Regional Officer is the highest authority within the Region. Regional Enforcers serve to support the Regional Officer, and enforce discipline and adherence by gang members of established Latin King rules and by-laws. These Regional Officers report to an individual known as the "Supreme Regional Officer." Similar to the Regional Enforcers, the Supreme Regional Officer employs at least one "Supreme Regional Enforcer" who enforces the Latin King rules and by-laws on the Regional Officers. 3 7. The Supreme Regional Officer is the second highest ranking Latin King on the South Side of Chicago. In turn, the Supreme Regional Officer reports to the "Corona," the highest ranking Latin King gang member on the South side of the Chicagoland area. 8. Each Region is comprised of "Sections," "Branches," or "Chapters," hereinafter referred to as "Sections." Each Section is typically named after a street or streets that run through the Section. Each section has its own rank structure, a leader or "Inca," a second in command or "Casique," an "Enforcer," a "Treasurer" and "Crown Council" members, all of whom are in charge of the non-ranking gang members or "Soldiers" within the section. Each section's membership of Soldiers numbers between approximately 12 to 80 individuals. 9. There are several Regions of Latin Kings operating throughout the Chicago and Northern Illinois area. One such Region is located in the Chicago neighborhood known as “Little Village.” Located on the city’s Southwest side, the territory of the Latin Kings operating in Little Village lies along a main East-West thoroughfare, 26th Street. The general East-West boundaries of this Region stretch between Fairfield Avenue (East) to Millard Avenue (West), and the North-South boundaries are generally between 21st Street (North) to 33rd Street (South). The Latin Kings who operate within the Little Village are known as the "26th Street Region of the Latin Kings Street Gang." 10. The 26th Street Region of the Latin Kings Street Gang contains approximately 24 Sections, all of whom answer to the Regional officers, also referred to as "Nation" leadership. The 24 Sections under the 26th Street Region of the Latin Kings include 21st and Albany; 21st and California; 21st and Fairfield; 22nd and Sawyer; 23rd and Homan; 23rd and 4 Spaulding; 23rd and Whipple; 24th and Drake, aka "Chi-Town;" 24th and Sacramento, aka "The Boulevards;" 24th and St. Louis, aka "Coulter Kings;" 24th and Trumbull, aka "The Motherland;" 25th and California; 25th and Millard; 25th and Spaulding, aka "Spanish Harlem;" 25th and Trumbull; 27th and Drake; 27th and Homan; 28th and Lawndale; 28th and Spaulding; 30th and Sawyer, aka "Redrum City;" 30th and Trumbull; 31st and Drake; 33rd and Morgan and 57th and Cicero. 11. Source information from multiple informants and law enforcement officers indicates that from January of 2007 until January of 2008, VICENTE GARCIA held the position of “Regional Officer” for the 26th Street Region of the Latin Kings Street Gang. In approximately January of 2008, VICENTE GARCIA was promoted to the position of "Supreme Regional Officer" in charge of all of the Regions on the South Side of the Chicagoland area. VICENTE GARCIA is a known distributor of illegal narcotics to various Sections within the 26th Street Region of the Latin Kings in the Little Village area of Chicago, Illinois. 12. In his former position as Regional Officer above the 26th Street Region of the Latin Kings Street Gang, GARCIA had at least three Regional Enforcers below him in rank – JOSE L. GUZMAN, aka "Boo Boo;" Victor Aviles, aka "Baby A;"1 and CW1. Together, GARCIA, GUZMAN, Aviles, and CW1 were in charge of all 24 Sections within the 26th Street Region of the Latin Kings Street Gang.