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AO 91 (REV-5/85) Criminal Complaint AUSA Michael Z. Gurland, 312-353-5310

UNITED STATES DISTRICT COURT

   

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

UNITED STATES OF AMERICA  

v.

CRIMINAL COMPLAINT

SANDRA STEWART,
also known as "Guera"
(Name and Address of Defendant)

05CRO494

  Under Seal
  MAGISTRATE JUDGE BROWN

I, Frank Jack Sodetz III, the undersigned complainant, being duly sworn state the following is true and correct to the best of my knowledge and belief. From at least May 21, 2005 through and including May 25, 2005, in Cook county, in the Northern District of Illinois, defendants knowingly and intentionally conspired to possess with the intent to distribute a controlled substance; namely, approximately one kilogram of heroin, a Schedule II Narcotic Drug Controlled Substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b) and Section 846. I further state that I am a Special Agent Federal Bureau of Investigation 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,

June 1, 2005                                                                     at Chicago, Illinois
Date                                                                                 City and State


Geraldine Soat Brown, U.S. Magistrate Judge                ___________________________
Name & Title of Judicial Officer                                                    Signature of Judicial Officer
 


STATE OF ILLINOIS              )

COUNTY OF COOK              )

AFFIDAVIT OF FRANK JACK SODETZ III

I, Frank Jack Sodetz III, having been duly sworn according to law, depose and state as follows:

I. PRELIMINARY MATTERS

1. I am a Special Agent employed by the Federal Bureau of Investigation ("FBI"), United States Department of Justice. I have been so employed for over four (4) years, and am presently assigned to the Chicago (Illinois) Field Division. I have received specialized training in the enforcement of federal narcotics laws, and I have participated in investigations of Mexico and Colombia-based narcotics trafficking organizations operating nationwide. My training and experience has involved, among other things, (a) the debriefing of defendants, witnesses, and informants, as well as others who have knowledge of the distribution and transportation of controlled substances, and of the laundering and concealment of proceeds of drug trafficking; (b) surveillance; and (c) analysis of documentary and physical evidence. I have also received training and have extensive experience in investigations involving the interception of wire communications. Further, I have received training in testifying for judicial proceedings and prosecutions relating to violations of federal narcotics laws. Based on my training and experience as a FBI agent, I am familiar with the manner in which

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narcotics traffickers conduct their drug-related businesses, including the methods employed by narcotics traffickers to import and distribute narcotics, their use of telephones in furtherance of their illegal activities, and their use of coded language to refer to narcotics, drug proceeds, and other aspects of narcotics trafficking.

2.      I am responsible for investigating crimes that involve, among other things, the unlawful importation and exportation of illegal narcotics, the possession with the intent to distribute controlled substances, the distribution of controlled substances, the use of communication facilities to further these offenses, as well as the related laundering of monetary instruments, in violation of Title 21, United States Code, Sections 841(a)(1), 843(b), 846, 952(a), 960 and 963, and Title 18, United States Code, Sections 1956 and 1957. In conducting these investigations, I have used a variety of investigative techniques and resources in several investigations which have included physical and electronic surveillance, monitoring court-authorized wiretaps, managing the use of cooperating witnesses ("CWs") and informants, and securing other relevant information using other investigative techniques. Through these investigations, my training and experience and conversations with other Special Agents as well as other law enforcement personnel, I have become familiar with methods used by narcotic traffickers to safeguard their narcotics, to distribute narcotics, and to collect and launder related narcotic proceeds.

3.      I am familiar with the methods employed by narcotics dealers to conduct their

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drug-related business, including, but not limited to, their use of both prepaid cellular and cellular phones, as well as normal land line phones, public phones, debit calling cards, counter-surveillance, elaborate smuggling schemes tied to legitimate businesses, the use of false and/or fictitious identities, and the use of coded language during conversations when referring to narcotics in an attempt to disguise the true meaning of the conversation.

4.     I have participated in this investigation since early February 2005. The information in this affidavit was gained by me as a result of my personal participation in this investigation; through interviews with and analysis of reports submitted by other Special Agents of the FBI, Special Agents of the Drug Enforcement Administration (DEA), Troopers from the Illinois State Police (ISP), Officers from the Chicago Police Department, as well as other law enforcement personnel; information furnished by confidential sources; my review of consensually recorded conversations; a review of pen register and trap and trace information; and a review of information derived from court-authorized interception of wire communications. This affidavit does not contain all of the information I know regarding the persons and events described herein, and it contains a summary of the relevant facts.

5.                     This affidavit is submitted in support of a criminal complaint charging STEWART for violations of 21 U.S.C. §§ 841(a)(1) and 846; and for an application for a warrant to search the premises located at 213 May Street, Bensenville, Illinois 60106 and to seize evidence concerning the commission of offenses under 21 U.S.C. § § 841(a)(1) and 846,

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namely, conspiring to possess with intent to distribute and distribution of more than a kilogram of heroin by GEORGE A. PRADO; NORA RIVAS, a/k/a NORA E. RIVAS, a/k/a NORA ELENA LEON, a/k/a "FLACA"; ALEXANDER MILLAN, a/k/a ALEXANDER MILLAN ZAPATA, a/k/a "ALEXILLO"; JAVIER HERNANDEZ, a/k/a "HARVEY"; MICHAEL D. HART, a/k/a "DADA"; ANTHONY C. RITACCO, a/k/a "TONE"; VITO J. RENTERIA; Individual A (also referred to herein as CW2), and others known and unknown.

II. OVERVIEW OF THE CONSPIRACY

6.                     Since February 2005, the FBI in Chicago has been investigating the drug trafficking and related activities of the Chicago based operations of a Columbian drug trafficking organization and the distribution network of a distributor for the organization, namely, Chicago distributor GEORGE A. PRADO. The investigation has focused on several members of the organization, including drug suppliers, distributors, couriers, and wholesale customers who have been responsible for the distribution of kilogram quantities of heroin in the Chicago area.

7.                     The investigation has revealed that NORA RIVAS, a/k/a NORA E. RIVAS, a/k/a NORA ELENA LEON, a/k/a "FLACA"; and ALEXANDER MILLAN, a/k/a ALEXANDER MILLAN ZAPATA, a/k/a "ALEXILLO" lead the organization's efforts to bring heroin to Chicago. GEORGE A. PRADO is a high level distributor of heroin who is

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supplied by RIVAS and MILLAN. PRADO communicates with his narcotics suppliers by telephone and in person to coordinate deliveries of heroin, as well as drug proceeds. PRADO also received deliveries of heroin on credit from his suppliers, then distributes or attempts to distribute this heroin to dealers, to whom he sells the heroin, namely, JAVIER HERNANDEZ, a/k/a "HARVEY"; ANTHONY C. RITACCO, a/k/a "TONE"; and MICHAEL D. HART, a/k/a "DADA." These dealers generally purchase 100 gram quantities of heroin from PRADO and sell in the Chicago market. VITO J. RENTERIA is a courier who handled the exchange of narcotics from MILLAN and RIVAS directly to PRADO's distributors/wholesale customers.

8. Since March 20, 2005, pursuant to Court orders, the FBI has been intercepting wire communications on Target Phone One (defined below), which has been used principally by GEORGE A. PRADO. During the time period of the interception, the agents have confirmed through intercepted calls and physical surveillances that GEORGE A. PRADO used Target Phone One in connection with his distribution of controlled substances, including heroin. Agents seized heroin on three occasions, once prior to the interception period and twice during the interception period. The interceptions and related surveillances have indicated that GEORGE A. PRADO, with the assistance of persons including but not limited to NORA RIVAS, a/k/a NORA E. RIVAS, a/k/a NORA ELENA LEON, a/k/a "FLACA"; ALEXANDER MILLAN, a/k/a ALEXANDER MILLAN

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ZAPATA, a/k/a "ALEXILLO"; JAVIER HERNANDEZ, a/k/a "HARVEY"; MICHAEL D. HART, a/k/a "DADA"; ANTHONY C. RITACCO, a/k/a "TONE"; VITO J. RENTERIA; Individual A (CW2), and others known and unknown, have together caused the distribution of over a kilogram of heroin supplied by the Columbian organization to customers in Chicago

9.                  This investigation has revealed the following about the roles of the defendants in the organization:

A. Organizers/Leaders

10.             SANDRA STEWART, a/k/a SANDRA RANGEL, a/k/a, "GUERA"(hereinafter STEWART), is an Hispanic female, born May 1, 1974 with a residential address of 213 May Street, Bensenville, Illinois 60106 as listed in Secretary of State drivers license records. STEWART delivers narcotics to RIVAS and MILLAN and retrieves narcotics proceeds from them.

11.             ALEXANDER MILLAN, a/k/a ALEXANDER MILLAN ZAPATA, a/k/a "ALEXILLO," (hereinafter MILLAN) is a high level member of the Columbian organization who is responsible for supervising the supply of kilogram quantities of heroin to Chicago. Alexander MILLAN is an Hispanic male, born on February 21, 1963, with a listed address of 8313 Northern Boulevard, Apt. 128, Jackson Heights, New York 11372. MILLAN is the user of cellular telephone number (312) 771-9309, discussed below. Subscriber information for telephone number (312) 771-9309, lists the name Carlos Arturo Ruiz and the address

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1235 North Damen Street, Chicago, Illinois 60618. MILLAN was arrested on September 13, 2004 by the Immigration and Naturalization Service (USINS) Border Patrol Swanton, Vermont for illegal entry into the United States and deported. At the time of his arrest, MILLAN had a New York drivers license listing a residential address of 21 Del Ray Court, Staten Island, New York 10304. MILLAN was first observed by surveillance agents on May 6, 2005 (See ¶*[ 71-73) and identified on May 20, 2005 after a comparison of photos taken during surveillances with MILLAN's New York drivers license photo.

12. NORA RIVAS, a/k/a NORA E. RIVAS, a/k/a NORA ELENA LEON, a/k/a "FLACA," (hereinafter RIVAS) is an Hispanic female, born on December 7, 1968, with a residential address of 5315 North Damen Avenue, Chicago, Illinois listed in Secretary of State records and in the subscriber information for cellular telephone number (773) 263-2297 (Target Telephone Two) used by RIVAS. RIVAS is the user of Target Telephone Two described below. RIVAS manages the Columbian organization's supply of narcotics in Chicago and handles the collection of drug proceeds.

a. On February 10, 2005, DEA Agents conducted surveillance of RIVAS and observed her depart a residence at 5315 North Damen Avenue, Chicago, Illinois and arrive at La Kayana Express located at 1625 West Montrose, Chicago, Illinois.1 Agents
______________________
1     La Kayana Express is the legal name of the business. The sign posted outside La Kayana Express, however, reads "La Tienda Express."

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observed RIVAS working at La Kayana Express throughout the day. On February 10, 2005, at approximately 9:10 a.m., a DEA agent placed a telephone call to cellular telephone number (773) 263-2297 (Target Telephone Two) while conducting surveillance on RIVAS. RIVAS was observed answering the telephone. On the same day, at approximately 5:00 p.m.. another DEA agent, while observing RIVAS, placed a second call to cellular telephone number (773) 263-2297 Target Telephone Two). As the call connected, RIVAS was observed looking at the caller ID screen on her phone. RIVAS did not answer the call. Target Telephone Two is a cellular telephone serviced by Sprint Spectrum LLP and subscribed to in the name of NORA RIVAS, 5315 North Damen Avenue, Chicago, Illinois, 60625, born on December 7, 1968.

b. On April 26, 2005, FBI agents conducted surveillance of La Kayana Express and observed RIVAS entering and exiting the business throughout the day. That same day, agents observed RIVAS operating a vehicle registered to Nora RIVAS and Jose Rivas, 5315 North Damen Avenue, Chicago, Illinois.

13. GEORGE A. PRADO, (hereinafter PRADO) is an Hispanic male born on April 19, 1958 residing at 5856 South Nordica, Chicago, Illinois, 60638. Based upon City of Chicago records, PRADO is an employee of the Department of Water Management where he serves as a "Hoisting Engineer." PRADO is the user of Target Telephone One, described below. PRADO is the head of a Chicago cell that receives shipments of heroin on

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consignment from the Columbian organization.

B.          Distributors/Wholesale Customers

14.             JAVIER HERNANDEZ, a/k/a "HARVEY" (hereinafter HERNANDEZ) is an Hispanic male born May 24, 1965. Based on public records, HERNANDEZ resides at 1439 South 59th Avenue, Cicero, Illinois. HERNANDEZ is a heroin distributor/wholesale customer of the Chicago cell run by PRADO.

15.             MICHAEL D. HART, a/k/a "DADA" (hereinafter HART) is an African American male, born on December 20, 1965, with a listed residential address in both public records and law enforcement databases of 1651 North Long, Chicago, Illinois, 60639. Based upon City of Chicago records, HART is an employee of the Department of Water Management where he serves as a "Laborer."

C.          Couriers

16.                VITO J. RENTERIA, (hereinafter RENTERIA) is an Hispanic-Italian male, born June 20, 1961. RENTERIA is the user of telephone number (708) 906-8705. RENTERIA is a courier for PRADO responsible for exchanging narcotics and proceeds between the suppliers and PRADO's wholesale customers and distributors.

17.                Other couriers, known and unknown, are also used by MILLAN and RIVAS.

D.          Customers

18. ANTHONY C. RITACCO, a/k/a "TONE" (hereinafter RITACCO) is a white

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male, born July 16, 1959, residing at 5414 South Sayre Street, Chicago, Illinois, 60638. RITACCO has no known criminal history. Based upon City of Chicago records, RITACCO is an employee of the Department of Water Management where he serves as a "Cement Mixer." RITACCO is one of PRADO's customers.

19.          INDIVIDUAL A (also referred to herein as CW2), is a drug customer of PRADO's. On March 10, 2005, INDIVIDUAL A received approximately 100 grams of heroin from PRADO's courier, RENTERIA. See ¶*[ 25-33.

 

III. PROBABLE CAUSE FOR THE SEARCH WARRANTS

A Information Provided by Cooperating Witness (CW1)

20.          CW 1 began cooperating with the FBI as a result of his/her arrest on September 3, 2001 by members of the Chicago Police Department (CPD) for possession of heroin. Ultimately, CPD agreed not to charge CW1 in that case, and CW1 began to cooperate with the FBI. CW1 has an extensive criminal history including convictions for prior drug related offenses. CW1 has had no further arrests since he/she began cooperating on September 3, 2001. Since 2001, CW1's information has led to the arrest of seventeen individuals and the seizure of approximately 170 grams of brown tar heroin; approximately eleven and one quarter kilograms of cocaine; and approximately 3,225 grams of white heroin. To date, the FBI has paid CW1 approximately $7,500.00 for his/her assistance.

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21         In January 2005, CW1 provided information that INDIVIDUAL A;2 a second individual known to CW1 as MICHAEL LNU (later identified during the investigation as MICHAEL D. HART); and an unknown Colombian male were involved in the trafficking of heroin. According to CW1, the unknown Colombian male supplied quantities of heroin to INDIVIDUAL A and HART who in turn sold the heroin to others.

22.                 Since January 2005, CW1 has participated in several consensually recorded conversations with INDIVIDUAL A to discuss narcotics related activities.

23.                 Among other calls, on February 8, 2005, at approximately 11:55 a.m., CW1 made a consensually recorded call to INDIVIDUAL A's cellular telephone.3 CW1 informed INDIVIDUAL A that CW1 had spoken with his friend. INDIVIDUAL A advised CW1 that the heroin was in "fingers," each weighing 12 grams. Based upon my training and experience and subsequent discussions with INDIVIDUAL A, the term "fingers" refers to packets of heroin which are swallowed by human couriers and smuggled into the United
________________________
2     CW1 provided information that led to the arrest of INDIVIDUAL A while INDIVIDUAL A was in possession of approximately 100 grams of heroin. Charges have not yet been brought against INDIVIDUAL A. INDIVIDUAL A is cooperating with the FBI in this investigation with the hopes that if charged and convicted, he/she will receive a reduced sentence.

3     For some of the calls summarized in the Affidavit, I have placed in brackets my understanding of what is being said during the call. My understanding of the conversation is based on the contents and context of the conversations, my experience as a law enforcement officer and the experience of other law enforcement officers in this investigation, including our experience listening to the intercepted conversations as a whole as well as the information provided by CW1 and INDIVIDUAL A regarding their conversations. The times listed for these calls are approximate. All of the consensually recorded conversations were in English. The summaries of the consensually recorded conversations are based on your Affiant's review of the conversations.

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States. INDIVIDUAL A informed CW1 that he could not "break it up" (meaning to divide the heroin into packets containing smaller quantities) and that CW 1 needs to buy "12" or "24" (meaning 12 gram or 24 gram increments of heroin, or increments of 12 grams only). CW1 asked INDIVIDUAL A if the price per kilogram of cocaine was "21" (meaning $21,000 per kilogram of cocaine). INDIVIDUAL A said yes. Towards the end of the conversation, INDIVIDUAL A advised CW1 to let him know (about the purchase of the drugs).

24.               On February 10, 2005 and February 18, 2005, CW1 and INDIVIDUAL A engaged in several telephone conversations to discuss the purchase of varying quantities of heroin from CW1's source, later determined to be PRADO.

 

25.               On February 22, 2005, CW1 received a call from INDIVIDUAL A which was not recorded. According to CW1, INDIVIDUAL A said that he/she would need to obtain the money for the purchase of 100 grams of heroin from CW1 in advance. Once INDIVIDUAL A had the money, his/her supplier would deliver the heroin within an hour. CW1 told INDIVIDUAL A that he/she would get back with him/her.

B. PRADO Directs Delivery of 100 Grams of Heroin to INDIVIDUAL A on March 10, 2005

26.               On March 10, 2005, CW1 participated in several consensually recorded calls and two recorded meetings with INDIVIDUAL A to arrange for the delivery of 100 grams of heroin. Specifically, on March 10, 2005, at approximately 10:00 a.m., CW1 placed a recorded phone call to INDIVIDUAL A. During this conversation, INDIVIDUAL A asked

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CW1 what the time was? CW1 replied that it was after 10:00 a.m. and that CW1 would see INDIVIDUAL A around 11:00 a.m. Telephone records for Target Telephone One revealed that at approximately 10:04 a.m., after the recorded phone call was made, INDIVIDUAL A called Target Telephone One (PRADO's telephone) for approximately two minutes. Then, at approximately 10:15 a.m., Target Telephone One received a two minute incoming call from (773) 319-3529, the number which your affiant believes was used by PRADO's drug courier, RENTERIA. Immediately after this call, at approximately 10:16 a.m., a call was placed by Target Telephone One to INDIVIDUAL A which lasted approximately three minutes.

27. On March 10, 2005, at approximately 10:22 a.m., CW1 and his/her car were searched for contraband. After agents determined that there were no narcotics in CW 1's car, or on CW 1's person, CW1 was equipped with transmitting and recording devices. CW1 then drove to INDIVIDUAL A's place of employment in Chicago, Illinois and met with INDIVIDUAL A at approximately 10:29 a.m. This meeting was recorded and monitored by FBI agents. The following is based on a review of the recorded conversation by your Affiant. During the meeting between CW1 and INDIVIDUAL A, CW1 showed INDIVIDUAL A the purchase money for the 100 grams of heroin. CW1 said that INDIVIDUAL A never counted the money and that he/she would not give the money to INDIVIDUAL A. INDIVIDUAL A asked CW1 to provide him/her with the money and said

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he/she (INDIVIDUAL A) would contact CW1 in approximately an hour once he/she (INDIVIDUAL A) had it (the heroin). CW1 refused to provide INDIVIDUAL A with the money until INDIVIDUAL A had the heroin. Towards the end of the meeting, INDIVIDUAL A advised CW1 he/she (INDIVIDUAL A) would call CW1 in approximately one hour. The meeting concluded at approximately 10:33 a.m.

28.             On March 10, 2005, at approximately 11:41 a.m., agents observed an Hispanic male driving a dark blue Chevrolet Avalanche and using a cellular telephone in the area of INDIVIDUAL A's place of employment in Chicago, Illinois. The Chevy Avalanche, bearing Illinois license plate number 708 0670, was registered to: JUVENAL RENTERIA with a listed address of 8050 Roberts Road, Bridgeview, Illinois, 60455 (the "Chevy"). The driver of the Chevy, later identified as VITO RENTERIA, parked his truck directly across the street from INDIVIDUAL A's place of employment.

29.             On March 10, 2005, at approximately 11:42 a.m., CW1 received an incoming call from INDIVIDUAL A. During this conversation, INDIVIDUAL A informed CW1 he was ready and for CW1 to come to the same spot where they had met previously. This conversation was recorded.

30.             At approximately 11:45 a.m., surveillance agents observed INDIVIDUAL A exit his/her place of employment, walk to the Chevy, and enter the passenger side front door. A few moments later, INDIVIDUAL A exited the vehicle and walked back to and went

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inside his/her place of employment. The Chevy then drove away and was followed by surveillance. According to an interview later with INDIVIDUAL A, INDIVIDUAL A said he/she obtained the heroin from the driver of the Chevy (RENTERIA) at that time.

31.                   On March 10, 2005, at approximately 12:01 p.m., surveillance agents observed RENTERIA meet with PRADO in a local restaurant on Taylor Street, Chicago, Illinois. PRADO was later observed entering and driving away in a black Ford F150, displaying Illinois license plates E161513 registered to: GEORGE A. PRADO, with a listed address of 5856 South Nordica, Chicago, Illinois. The meeting between PRADO and the narcotics courier lasted until approximately 12:23 p.m.

32.                  On March 10, 2005, at approximately 12:05 p.m., CW1 drove to INDIVIDUAL A's place of employment as directed by INDIVIDUAL A. CW1 and CW 1's car had been previously searched for narcotics and other contraband. No narcotics or contraband were found. The meeting was consensually recorded by CW 1 and monitored by FBI agents. After CW1 arrived, INDIVIDUAL A entered CW 1's car and advised CW1 to pull into the parking lot of INDIVIDUAL A's place of employment. CW 1 declined and told INDIVIDUAL A that CW 1 had the money in the trunk of CW 1's vehicle and that INDIVIDUAL A should retrieve the stuff (heroin).

33.                On March 10, 2005, at approximately 12:06 p.m., INDIVIDUAL A exited CW1's car and entered his/her place of employment out of the view of surveillance agents.

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34.                 On March 10, 2005, at approximately 12:08 p.m., INDIVIDUAL A returned to CW1's car carrying a brown paper bag and entered the front passenger side of the car. INDIVIDUAL A was immediately arrested by FBI agents. At the time of his/her arrest, approximately 100 grams of heroin were on the floorboard of the front passenger seat of CW 1's car. The heroin was subsequently field tested and tested positive for the presence of heroin. The heroin was determined to have a net weight of approximately 135.5 grams.


INDIVIDUAL A Cooperates With FBI Agents

35.          On March 10, 2005, after INDIVIDUAL A (hereinafter CW2) was advised of his/her rights, CW2 voluntarily waived his/her Miranda rights and agreed to cooperate with law enforcement. CW2 reported that PRADO was distributing heroin and cocaine within the Chicago Metropolitan area. CW2 identified PRADO as the supplier of the 100 grams of heroin found in CW 1's car. CW2 informed agents that he was contacted by PRADO prior to meeting with the driver of the Chevy Avalanche who told him/her that the individual delivering the heroin was outside his (CW2's) place of employment. CW2 then went to the Chevy and obtained the heroin from the driver. CW2 provided agents with PRADO's cellular telephone number: (773) 510-0232 (Target Telephone One). CW2 said he/she had known PRADO for approximately three years and had met PRADO through their mutual employment. Approximately one year ago, PRADO told CW2 that he (PRADO) was involved in narcotics trafficking and that he worked with multiple drug trafficking families

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in Colombia who pay people to smuggle heroin into the United States. PRADO told CW2 that the smugglers used various techniques to conceal the heroin including swallowing the heroin and then later defecating it out as well as concealing the heroin in the soles of their shoes. PRADO admitted to once meeting with a courier in Chicago, Illinois who had concealed heroin in their shoes.

36.          According to CW2, a search warrant was executed on PRADO's residence approximately one year ago by the Chicago Police Department. At the time of the search, the local authorities found weapons within PRADO's residence, but failed to locate any narcotics. Some time after the search, PRADO informed CW2 that he (PRADO) had, at the time of the search, enough drugs in his residence to put him away for life.

37.          CW2 said he/she also knew HART. Approximately one year ago, HART showed CW2 several pellet like objects which he said were heroin. HART told CW2 that he had obtained the heroin from PRADO and that he distributed heroin for PRADO on the West side of Chicago, Illinois. CW2 provided agents with HART's cellular telephone number, (773) 879-9563. At the time of CW2's arrest, HART's phone number was programmed in CW2's cell phone under the name "DADA."

38.          CW2 subsequently made recorded calls to PRADO at Target Telephone One to arrange a meeting with PRADO so that he/she (CW2) could pay PRADO for the 100 grams of heroin provided to CW1. For example, on March 10, 2005, at approximately 12:49

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p.m., CW2 made a consensually recorded call to PRADO on Target Telephone One. Prior to the conversation, agents verified the telephone digits dialed by CW2. Furthermore, your Affiant reviewed PRADO's telephone records and confirmed this call. CW2 told PRADO that he/she (CW2) was stuck at work. PRADO advised CW2 that was okay, and that CW2 should take his/her time because he (PRADO) was at the airport. PRADO asked CW2 why CW2 took so long. CW2 asked PRADO if he (PRADO) wanted CW2 to hold onto "it" (the money for the 100 grams of heroin). PRADO said yes and asked CW2 if CW2 "went on a shopping spree or something." CW2 and PRADO arranged to meet later in the day. CW2 asked PRADO if they could meet before work ended. PRADO said they could do something like that.


Meeting Between PRADO and CW2 On March 10, 2005

39. On March 10, 2005, at approximately 2:55 p.m., CW2 met PRADO at the intersection of Kostner and Shakespeare, Chicago, Illinois. The meeting was recorded and monitored by agents of the FBI. PRADO arrived at the meet location in a black Ford F150 truck. The meeting occurred in PRADO's truck. The following summary is based on a review of the recorded conversation by your Affiant. PRADO asked CW2 to see the money

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and CW2 gave PRADO $8,300.4 Specifically, PRADO asked, "How much is here?" CW2 informed PRADO that CW2 kept "$1,700" (meaning $1,700 dollars for brokering the deal with CW1). PRADO asked, "Do I need to count it." CW2 told PRADO to call CW2 if "its wrong" and advised PRADO that he/she (CW2) counted "it." CW2 informed PRADO that CW2 told CW2's customer that next time it would be CW2's way.5 PRADO asked if "he" (CW2's customer) brought anyone with him. CW2 told PRADO that he/she came alone and that his/her customer was an "old man." CW2 also told PRADO his/her guy would call back to "get more" and that he/she (CW2's customer) is from Milwaukee where his/her brother lives. PRADO asked CW2 if he (PRADO) could give CW2 "95" (meaning an additional 95 grams of heroin) and if PRADO could trust him/her (CW2). CW2 asked PRADO, "What if the guy wants more tomorrow?" PRADO told CW2 that CW2's customer has "till tomorrow" and after that PRADO will be out for a week. PRADO instructed CW2 to let "the guy" (CW2's customer) know that his/her "guy" (PRADO) is gone Saturday to Saturday, that he (PRADO) has "95" (meaning 95 grams of heroin) and to find out if he (CW2's customer) "want this to hold you over or what do you want to do?" PRADO stated, among other things, that CW2 was going to "make some big money" and that CW2 "can pay off the motorcycle


_______________________

             The FBI provided the CW2 with $8,300.00 in U.S. currency (government funds), which was utilized as payment to PRADO for the 100 grams of heroin seized by the FBI.

             When CW2 is referring to his/her customer, it is a reference to CW 1.

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in no time." PRADO also advised CW2 that "this was the easiest $1,700 CW2 has ever made." Just before the meeting ended, PRADO instructed CW2 not to tell anyone.

40.                After the meeting, agents followed PRADO to his residence located at 5856 South Nordica, Chicago, Illinois. After parking his truck in the garage, PRADO was seen entering the side door of his residence.

B.         Intercepted Conversations, Surveillance, and Related Investigation.

41.                On April 20, 2005, United States District Court Chief Judge Charles P. Kocoras, Northern District of Illinois, signed an order authorizing the interception of wire communications over cellular telephone number (773) 510-0232 (Target Telephone One), which is used by PRADO, for a period of thirty days. Target Telephone One is a cellular telephone serviced by T-Mobile USA subscribed to in the name of JOSEPH R. CORTEZ, 7334 West 63rd Street, Apartment 2, Summit Argo, Illinois, 60501-1818, date of birth August 19, 1956. On May 18, 2005, Chief Judge Kocoras signed an order authorizing the continued interception of communications over Target Telephone One for an additional period of thirty days. Authorized interceptees over Target Telephone One included, among others, RIVAS; RENTERIA; and First Name Unknown Last Name Unknown (FNU LNU 1). FNU LNU 1 was subsequently identified as ALEXANDER MILLAN, a/k/a ALEXANDER MILLAN ZAPATA, a/k/a "ALEXILLO."

42.                On May 13, 2005, United States District Court Chief Judge Charles P. Kocoras,

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Northern District of Illinois, signed an order authorizing the interception of wire communications over cellular telephone number (773) 263-2297 (Target Telephone Two), which is used by RIVAS. The interception of wire communications over Target Telephone Two commenced on May 16, 2005. Authorized interceptees included PRADO and MILLAN, among others.

STEWART Delivers Drugs to RIVAS on May 22, 2005

43.     As detailed below, based on communications intercepted over Target Telephone Two, affiant believes that on May 22, 2005, STEWART met with RIVAS and gave RIVAS heroin. Specifically, on May 21, 2005 at approximately 1:57 p.m., RIVAS received an incoming call over Target Telephone Two from MILLAN, who was using telephone number (312) 773-9309. During that call, among other things, MILLAN asked RIVAS if she was going to see "GUERA" [STEWART] now. RIVAS told MILLAN that GUERA was going to call her after lunch. Later in the call, MILLAN again asked if RIVAS would see her [STEWART] today. RIVAS told MILLAN that yes, "we agreed on, on... for this girls thing. I told her five-eight and she said yes." RIVAS and MILLAN then agreed to talk later in the evening. Based on the context and nature of the conversation, I believe that MILLAN wanted to know if STEWART was going to bring narcotics to RIVAS, and that RIVAS told MILLAN that STEWART was going to provide drugs to RIVAS. The conversation also indicates that the drugs would cost fifty eight dollars per gram ("five-

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eight").

44.            On May 21, 2005, at approximately 6:25 p.m., RIVAS received an incoming call over Target Telephone Two from STEWART, who was using telephone number (773) 551-6269.6 During the call, STEWART asked RIVAS if she could wait until the morning [for her to deliver the drugs] because "her mom is going for a ride with her dad" [narcotics were not ready]. Among other things, both agreed to meet the following day.

45.            On May 22, 2005, at approximately 3:47 p.m., RIVAS received an incoming call over Target Telephone Two from STEWART, who was using telephone number (773) 551-6269. During that call, STEWART asked RIVAS, "Do you still want your cart [narcotics]?" RIVAS replied, "Of course GUERA." STEWART said, "okay" and that she "had it all ready, already." RIVAS told STEWART she would call her today [let her know when to deliver the drugs].

46.            On May 22, 2005, at approximately 4:13 p.m., RIVAS using Target Telephone Two placed an outgoing call to MILLAN, who was using telephone number (312) 771-9309. During that call, among other things, RIVAS told MILLAN that she had spoken to GUERA [STEWART] and that "it could be one [one kilogram] or just a half" [half

________________
   No subscriber information is currently available for telephone number (773) 551-6269. The user of the telephone is an Hispanic female and the voice mail message identifies the holder of the phone as "Sandra Jimenez." Affiant believes that "Jimenez" is a fake last name used to hide the identity of the true phone holder.

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a kilogram]. MILLAN said he was not sure and asked what did the girl [customer] say. RIVAS replied, "No, the girl [customer], half [only wants a half kilogram], but this man [PRADO]." MILLAN replied, "Oh, we'll have to talk to him and see." Later in the call, RIVAS asked MILLAN "well then, what should I say one or just half' [should RIVAS get a kilogram or a half kilogram)? In response, MILLAN told RIVAS, among other things, to tell her [STEWART] one. After some discussion, in sum and substance, RIVAS agreed.

47.                   On May 22, 2005, at approximately 4:16 p.m., RIVAS using Target Telephone Two called STEWART at telephone number (773) 551-6269. During that call, RIVAS asked STEWART if she was on her way to meet with her [RIVAS]. STEWART told RIVAS, among other things, she was cooking and that she would meet her later in the evening.

48.                   On May 22, 2005, at approximately 7:05 p.m., RIVAS using Target Telephone Two called STEWART at telephone number (773) 551-6269. During that call, STEWART told RIVAS that she was on her way and would arrive at RIVAS' around 7:40 p.m. RIVAS told STEWART she was going to put some clothes in the washer and for STEWART to call her when she arrived.

49.                   At approximately 7:25 p.m., an FBI Agent established surveillance on RIVAS at her residence, 5315 North Damen Avenue. The Agent observed RIVAS depart her residence driving a white Jeep Grand Cherokee registered to RIVAS at the Damen address

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(hereinafter the Jeep). RIVAS drove to a laundromat. At approximately 7:45 p.m., RIVAS was observed standing in front of the laundromat talking on her cellular telephone.

50.          At approximately 7:46 p.m., RIVAS using Target Telephone Two called STEWART at telephone number (773) 551-6269. During that call, STEWART told RIVAS she was going to be there in five minutes. RIVAS told STEWART she would go over there now.

51.                   At approximately 7:48 p.m., RIVAS got in the Jeep and drove to the intersection of Cullom Avenue and California Avenue where she parked.

52.          At approximately 7:54 p.m., RIVAS using Target Telephone Two called STEWART at telephone number (773) 551-6269. During that call, STEWART told RIVAS she was driving a small blue four door car. RIVAS said okay and told STEWART that she was there already.

53.           At approximately 8:00 p.m., surveillance agents observed STEWART exiting a blue Mercury Grand Marquis registered to Hertz (the Grand Marquis) 7 STEWART got out of the Grand Marquis and walked up to the Jeep's passenger side window. STEWART and RIVAS had a conversation. After a few minutes, STEWART returned to the Grand Marquis and departed. Because the area where STEWART and RIVAS met was poorly lit,

__________________
7    A check of the rental agreement for the vehicle showed that the vehicle was rented by Armando Rangel, 213 May Street, Bensenville, Illinois from the Elmhurst rental facility on May 16, 2005. 213 May Street is the address listed on STEWART'S Illinois drives license.

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agents were unable to see what, if anything, was passed between STEWART and RIVAS.



May 24, 2005: Agents Seize One Kilogram of Heroin from VITO RENTERIA After a Transaction Involving ALEXANDER MILLAN, NORA RIVAS and VITO RENTERIA Engineered by GEORGE A. PRADO.

54. Based on intercepted calls from Target Telephones One and Two and related surveillance, I believe that on May 24, 2005, PRADO arranged to have RENTERIA pick up a kilogram of heroin from MILLAN, which had been stashed in RIVAS' house. Calls intercepted during the course of the investigation also reveal that the heroin was provided by STEWART. (Seen 57). In summary, the conversations and surveillance described below shows that on May 24, 2005, PRADO directed his courier, RENTERIA, to meet with MILLAN outside of RIVAS' residence so that MILLAN could give RENTERIA approximately one kilogram of heroin for which PRADO would owe MILLAN and RIVAS $60,000. RENTERIA followed PRADO's directions and met with MILLAN on May 24, 2005 at approximately 1:43 p.m. at which time MILLAN gave heroin to RENTERIA in exchange for $8,000. The Illinois State Police subsequently stopped RENTERIA, who did not have a valid license. RENTERIA's car was towed and the drugs were seized by the FBI. RENTERIA subsequently tried to explain the loss of the drugs to PRADO, but PRADO did not believe RENTERIA. PRADO then reached out to a third party to assist in beating the "truth" out of RENTERIA. PRADO made calls to MILLAN to discuss the kidnaping, beating and possibly killing of RENTERIA. In PRADO's words, if he was dissatisfied with

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RENTERIA's answers, "they will get the knives out and they will fuck him up and that will be real fast."

Communications and Surveillance of the May 24, 2005 Heroin Deal

55.                   On May 23, 2005, at approximately 6:43 p.m., PRADO, using Target Telephone One, contacted MILLAN at telephone number (312) 771-9309. During that call, PRADO told MILLAN, in sum and substance, that he [PRADO] would send a friend [believed to be RENTERIA] tomorrow. PRADO also told MILLAN to have the other one ready of "just one hundreds and he [RENTERIA] is going to give you another seven or eight [$7,000 or $8,000] . . . ." Among other things, MILLAN replied, "if she has it ready for me now, I can go fix it over by La Flaca's" [RIVAS's house]. PRADO and MILLAN agreed to speak in the morning.

56.                   On May 23, 2005, at approximately 6:48 p.m., MILLAN, using telephone number (312) 771-9309, contacted PRADO at Target Telephone One. During the call, MILLAN told PRADO that he had just talked to the woman and she will give MILLAN the car [heroin] tomorrow morning so that MILLAN could get it ready.

57.                   On May 23, 2005, at approximately 7:04 p.m., RIVAS using Target Telephone Two called MILLAN at telephone number (312) 771-9309. During that call, MILLAN told RIVAS that the friend [PRADO] had called and that he needed the car [a kilogram of heroin]. RIVAS asked if MILLAN had called GUERA [STEWART] yet.

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MILLAN said, yes and that she [STEWART] would give it to him tomorrow. Later during the call, among other things, RIVAS asked MILLAN "what time is GUERA, she can't do it this evening?" MILLAN replied, "I asked her if she could do it now and she said no." MILLAN added, in sum and substance, that he would talk to GUERA to find out when she would be ready and that he would call the "friend" [PRADO] and give it to him early. RIVAS agreed. Later in the call, RIVAS told MILLAN, "I called you because you . . . and you tell me, no, sixty? [Charge PRADO $60,000 for the kilogram of heroin]. MILLAN replied, "no, at sixty, it used to be sixty for her before." [STEWART charged $60,000 for the heroin so they would need to charge PRADO more]. RIVAS and MILLAN agreed to talk about it later.

58. On May 24, 2005, at approximately 8:20 a.m., Agents of the FBI and Officers of the Illinois State Police (ISP) initiated surveillance at 5315 North Damen Avenue, in Chicago, Illinois, RIVAS's residence. 5315 North Damen is a three-floor red brick apartment building located on the eastside of Damen Avenue near the intersection between Summerdale and Damen. At approximately 9:59 a.m., Agents observed MILLAN – driving a grey Jeep Cherokee, bearing Illinois plate 766-1862 – arrive at the residence. MILLAN parked near RIVAS's residence. The Jeep was also occupied by an older, unidentified Hispanic male. Both individuals got out of the Jeep and MILLAN was seen retrieving a plastic bag marked "Aldi" from the car's rear passenger side. MILLAN, carrying the bag,

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and the unidentified male then entered 5315 North Damen Avenue.

59.            At approximately 10:06 a.m., RIVAS was seen exiting 5315 North Damen. RIVAS got in her car, a white Jeep Grand Cherokee, and used her cell phone. After approximately one minute, RIVAS got out of her car and reentered the residence. Subsequently, at approximately, 10:09 a.m. RIVAS was again seen exiting 5315 North Damen after which she got in her car and drove off.

60.            On May 24, 2005, at approximately 11:08 a.m., PRADO using Target Telephone One called RENTERIA at telephone number (708) 906-8705. PRADO got RENTERIA's voice mail and left a message that it was 11:09 a.m. to the effect that RENTERIA needed to get up because he was "fucking up the operation ...."

61.            On May 24, 2005, at approximately, 12:03 p.m., RIVAS, using Target Telephone Two, called MILLAN at (312) 771-9309. During that call, among other things, MILLAN informed RIVAS, in summary, that they were still waiting on PRADO's "friend" [drug courier, RENTERIA] and had been doing so for over an hour. RIVAS asked MILLAN if he was leaving today? MILLAN said, "Yes." In response, RIVAS said, "If not they can come at night and I'll deliver it" [believed to be the heroin].

62.            On May 24, 2005, at approximately 12:27 p.m., RENTERIA, using telephone number (708) 906-8705, called PRADO at Target Telephone One. During that call, among other things, PRADO told RENTERIA that the man [MILLAN] was waiting for him because

28


he [MILLAN] wanted to leave town but he [RENTERIA] was sleeping. RENTERIA asked PRADO if he was going to the same place. PRADO said, "Yes, way up North." PRADO explained that was why he wanted RENTERIA to get a jump start and get it done, to get that [heroin] and put it away. RENTERIA told PRADO he would leave in ten minutes. PRADO told RENTERIA to bring the eight [$8,000] with him. PRADO then told RENTERIA to call him when he was close, or when he was there.

63.           On May 24, 2005, at approximately 12:28 p.m., PRADO, using Target Telephone One, contacted MILLAN at telephone number (312) 771-9309. During the call, PRADO told MILLAN that he woke the guy up, and that his [RENTERIA's] phone was off. PRADO told MILLAN that he [RENTERIA] was leaving in about ten minutes and that he [RENTERIA] would arrive in about half an hour. PRADO explained that RENTERIA would call PRADO when he arrived and PRADO would in turn contact MILLAN so that MILLAN could come down. PRADO then told MILLAN that RENTERIA would give him [MILLAN] eight [$8,000]. PRADO then asked MILLAN how much he was going to give him? MILLAN said, "995" [995 grams of heroin]. PRADO also asked, "if they're all marked?" MILLAN replied, "yes, one by one." Based on the context and nature of the conversation as well as other information obtained during the course of the investigation, affiant believes that "one by one" means 10 bags containing 100 grams of heroin each.

64.          On May 24, 2005, at approximately 1:40 p.m., RENTERIA, using telephone

29


number (708) 906-8705, contacted PRADO, who was using Target Telephone One. During the call, RENTERIA told PRADO that he had arrived. PRADO asked RENTERIA if he had the "8 dollars [$8,000] with him?" RENTERIA replied, "Yes." PRADO told RENTERIA he would tell him [MILLAN] to come down.

65.            At approximately 1:41 p.m., surveillance observed RENTERIA arrive in a blue Chevy Avalanche, bearing Illinois plate 708-0670 (the "Chevy"). RENTERIA parked the Chevy on Summerdale Street across from 5315 North Damen Avenue. MILLAN was then seen exiting 5315 North Damen Avenue carrying the same plastic bag marked "Aldi," which he was previously seen carrying into 5315 North Damen. MILLAN gave the plastic bag to RENTERIA through the Chevy's passenger window and retrieved a red plastic bag from RENTERIA. MILLAN returned to RIVAS' residence, and RENTERIA drove off followed by surveillance.

66.            On May 24, 2005, at approximately 1:43 p.m., PRADO, using Target Telephone One, contacted MILLAN at telephone number (773) 518-6152. During the call, in summary, among other things, MILLAN told PRADO that he had the meeting and received the eight dollars [$8,000].

67.            On May 24, 2005, at approximately 1:45 p.m., RENTERIA, using telephone number (708) 906-8705, called PRADO at Target Telephone One. During the call, among other things, PRADO told RENTERIA, in sum and substance, that the reason he wanted

30


RENTERIA to make that move [pick up the heroin] this morning was because he [PRADO] was supposed to make a move for three [sell three hundred grams] and that they did not have three [three hundred grams of heroin] on hand, and that it would have been a bum deal [PRADO would have lost the deal with the customer]. PRADO instructed RENTERIA to go home, "be careful, put it together and put it away."

68. At approximately 1:56 p.m., the Illinois State Police, working with the FBI, conducted a traffic stop of RENTERIA near George Street and Damen Avenue after observing RENTERIA driving 45 miles per hour in a 30 mile per hour zone. ISP Trooper Javier Martinez asked for RENTERIA's license. RENTERIA advised the trooper he was driving on a suspended license as a result of a prior DUI. RENTERIA was then taken into ISP's custody, and the Chevy was towed. RENTERIA was ultimately issued two citations and released on bond. FBI Agents, along with ISP, maintained surveillance of the Chevy as it was towed to a nearby impoundment lot, after which Agents removed and took custody of the bag which FBI agents had seen MILLAN give to RENTERIA and which was suspected to contain heroin. The bag was seized from the floor in the back of the Chevy. Further inspection revealed that the bag contained a shoe box inside of which Agents found suspected heroin. The substance field tested positive for the presence of heroin and weighed approximately one kilogram. The heroin was packed in 10 ziplock bags, 9 which were marked "100" and 1 which was marked, "95."

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69.     On May 24, 2005, at approximately 2:37 p.m., RENTERIA, using telephone number (708) 906-8705, contacted PRADO at Target Telephone One. During the call, in sum and substance, RENTERIA told PRADO that the Chevy had been towed. RENTERIA explained that he was stopped by a state trooper. PRADO asked, "for what?" RENTERIA said he was going five miles over the limit on Damen Avenue on the North side. RENTERIA goes on to explain the everything [heroin] was in there and that he would need his (RENTERIA's) father to get the Chevy back. RENTERIA explained that they (the police) took the Chevy because he had no license and that he got a ticket. Later in the call, RENTERIA told PRADO that the stuff [heroin] was in the car in the back on the ground on a jacket. Among other things, PRADO told RENTERIA that he better hope that they [the police] don't find it [the heroin] and that he [RENTERIA] needed to hurry up and do something.

70.     On May 24, 2005, at approximately 2:50 p.m., RENTERIA, using telephone number (708) 906-8705, called PRADO at Target Telephone One. During the call, RENTERIA explained that his dad was angry and he asked why he [RENTERIA] had been on the North side. RENTERIA then asked PRADO what time he was going by [to pick up RENTERIA's dad]. PRADO told RENTERIA he was on his way, and that they better get there quick hope that no one finds it [the heroin].

71. On May 24, 2005, at approximately 4:01 p.m., PRADO, using Target

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Telephone One, contacted RENTERIA who was using telephone number (708) 906-8705. During the call, PRADO asked where RENTERIA was at? RENTERIA told PRADO he was in the truck with his dad. PRADO asked, "And?" RENTERIA replied, "No." PRADO told RENTERIA not to tell him that. RENTERIA went on to explain that everything was in the truck except "that" [the heroin].

72. On May 24, 2005, at approximately 4:47 p.m., RENTERIA, using telephone number (708) 906-8705, called Target Telephone One and spoke with PRADO. During that call, PRADO advised RENTERIA, in sum and substance, that he did not believe that RENTERIA was being honest and that he had a big problem. Among other things, PRADO told RENTERIA, that "he is fucking around with the wrong people"; that he needs to go get "60,000 dollars" because "it is on him"; that he has to figure out which one [option] he wants to take. RENTERIA tried to persuade PRADO that he did nothing wrong. Among other things, PRADO said, "that is bullshit and that he [RENTERIA] should have been locked up and that could have been his only way out." PRADO also told RENTERIA that he would turn him in and that he does not need any problems. After some conversation, RENTERIA asked PRADO if PRADO actually thinks RENTERIA took "it" [the drugs]? PRADO said, "you're fucking right." RENTERIA replied, "I don't believe you." PRADO asked what RENTERIA expects him [PRADO] to do, "fucking eat it" [meaning accept responsibility for the lost drugs]. RENTERIA said no, I don't. PRADO informed RENTERIA to get "it" [the

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drugs] from his buddy or whatever he is going to do, just get "it" [the drugs] back by tonight or RENTERIA will have the whole force coming at him . . . and if "they" [referring to law enforcement] found "it" [the drugs] . . . the fucking DEA will be by his father's house and they will let RENTERIA see where he goes. RENTERIA replied that he only has the "other thing" [possibly referring to additional quantities of drugs on hand]. PRADO replied, among other things, that if he [RENTERIA] is masterminding something with his friends . .RENTERIA has a big problem. RENTERIA informed PRADO that he is unsure what PRADO is talking about and said he is not lying. PRADO told RENTERIA that he [RENTERIA] knew the consequences when "they" [PRADO and RENTERIA] first started .. PRADO told RENTERIA to tell his father what went down and have his father give him "a 60,000 loan." PRADO advised RENTERIA that he [PRADO] cannot help him and will call him after his [PRADO's] meeting [with the suppliers].

73.     On May 24, 2005, at approximately 7:06 p.m., Target Telephone One placed an outgoing call to MILLAN at (773) 518-6152. During the call, MILLAN informed PRADO that he is on the highway [likely returning to New York]. Among other things, PRADO asked MILLAN how he [MILLAN] gave "it" to the guy [RENTERIA]. MILLAN said that he gave "it" [the drugs] to him inside a small shoe box. In summary, PRADO told MILLAN about what happened to RENTERIA and the Chevy and that "the thing [the heroin] was not there." PRADO indicated that he did not know if RENTERIA was lying or what the

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police would do, so PRADO was going to wait a couple of days. MILLAN replied that things were difficult now. PRADO also told MILLAN, among other things, that he [PRADO] was yelling at the "SOB" and told him (1) [RENTERIA] to find "that shit" [drugs] or something is going to happen to him"; (2) to go get some money from the bank because that was the only way that nothing would happen to him; (3) that he (PRADO) has to talk to his people [referring to MILLAN and RIVAS] and they do not play games and that PRADO does not know what they are going to do to him. PRADO indicated that he made the last comment to scare the guy [RENTERIA]. MILLAN agreed. After more conversation about the details surrounding the loss of the heroin, PRADO said, in summary, that he told RENTERIA that his people [possibly referring to MILLAN, RIVAS and others] are going to "kill" him [RENTERIA] and that [RENTERIA] should not to play games. After some more discussion, the conversation ended.

74. On May 24, 2005, at approximately 7:15 p.m., RIVAS, using Target Telephone Two, placed an outgoing call to (773) 518-6152 and spoke with MILLAN. During the conversation, MILLAN told RIVAS that her boyfriend [PRADO] called him. RIVAS replied, "What did he say?" MILLAN said he had bad news. RIVAS asked, "Why?" MILLAN said that the guy [RENTERIA] he gave the car [heroin] to, was stopped by the police... , and "they" [law enforcement] took the car.... MILLAN told RIVAS that when "they" picked up the car, the "shit" [heroin] was not there. Among other things, MILLAN

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said that he [PRADO] is scaring him [RENTERIA] to see what he [RENTERIA] is going to do and that he [PRADO] is going to wait a couple of days to see what happens. RIVAS said she was in shock and asked what was going to happen? MILLAN told RIVAS that "they" are going to wait a couple of days to see what is happening [meaning see what the fall out will be as a result of the seized drugs]. RIVAS asked MILLAN if it is a scam. MILLAN advised RIVAS, in part, that he [PRADO] thinks he [referring to RENTERIA] wants to steal "it" [the drugs]. MILLAN said that if it were real "they" would have locked him up. RIVAS asked MILLAN, if "the shit" was there [the drugs]. MILLAN replied, when they went to pick up the car "the shit" [drugs] was not there.
 

75. On May 24, 2005, at approximately 8:39 p.m., RIVAS, using Target Telephone Two, called telephone number (773) 518-6152 and spoke with MILLAN. During the conversation, among other things, MILLAN said he was told to go back to see what is going on, and to see what they are going to do. MILLAN also said that he was told [possibly by PRADO] to wait until tomorrow after RIVAS' boyfriend [PRADO] talks to the guy [RENTERIA]. MILLAN said that they will have to scare him anyway. MILLAN told RIVAS to light up a candle to the virgin to make sure that everything comes out alright. RIVAS said she did it already. RIVAS asked MILLAN where he was? MILLAN replied that he is about an hour away from Pennsylvania, and that he will be in around at 3 to 4 in the morning.

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76.     On May 25, 2005, at approximately 5:46 p.m., Target Telephone One received an incoming call from an unknown telephone number at which time PRADO spoke with MILLAN. During that call, MILLAN asked PRADO how things were going? PRADO replied that he is going to talk to "some guys" who he knows . . . and asked MILLAN not to say anything. PRADO told MILLAN that he is going to get the guy [RENTERIA] inside a garage and is going beat him up to see if he talks. MILLAN stated in summary that he thought [RENTERIA] was lying and stole the drugs. PRADO replied that he is checking all the papers and everything else. Among other things, PRADO advised MILLAN that he thinks that if after "they [PRADO and others] beat up the guy [RENTERIA], he does not talk, that the guy is probably telling the truth . . . but if he talks . . . they will get the knives out and they will fuck him up and that will be real fast." After some discussion, PRADO and MILLAN agreed that they do not believe RENTERIA's story. PRADO told MILLAN that tomorrow "this other boy" [referring to an unknown party] is going to pay him off. MILLAN advised that he needs to tell his sister to finish with "those people" [referring to unknown individuals]. MILLAN advised PRADO that as soon as he [PRADO] has "the papers" [money] to call him since he has to deliver "it" to "this lady." PRADO agreed.

77.     Subsequent to the seizure of the kilogram of heroin, as described above, calls intercepted over the Target Telephones further revealed that the drugs were supplied by STEWART. Specifically, between May 28, 2005 and May 31, 2005, calls intercepted over

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Target Telephone One and Target Telephone Two indicated, in substance, that PRADO, MILLAN and RIVAS had agreed not to tell "Guera" [STEWART] about the lost drugs and to get more drugs from STEWART so that PRADO could make money and pay off the debt owed to STEWART. Among other calls, on May 30, 2005, at approximately 1:33 p.m., STEWART called RIVAS and told RIVAS that she had dropped her telephone and was getting a new number. RIVAS told STEWART that the people [PRADO] were out for the weekend. STEWART asked RIVAS if there was any news [information about when STEWART would be paid]. RIVAS said, in substance, that there was no news. Subsequently, on May 30, 2005, at approximately, 7:27 p.m., MILLAN called PRADO at Target Telephone One. During that conversation, PRADO, among other things, told MILLAN that he needed more work to keep going so that he could pay off his debt. PRADO also indicated that he could pay fifteen or ten [$15,000 or $10,000] at a time. The next day, on May 31, 2005 at approximately 10:38 a.m., MILLAN called RIVAS at Target Telephone Two. During the conversation, in sum and substance, MILLAN asked RIVAS if "Guera" [STEWART] had called and also told RIVAS that he had tried to call "Guera" [STEWART] but her phone was busy. RIVAS said that "Guera" [STEWART] had called and that she was getting a new phone. Among other things, MILLAN told RIVAS that his friend [PRADO] called and that he needed "one" [one kilogram of heroin] to keep working so that he could pay off his debt. MILLAN also stated that that was the reason he was calling "Guera"

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[STEWART] to speak to her about that, but that he was not going to mention anything in relation to what the other one lost [PRADO's loss of the drugs]. On May 31, 2005, affiant made a test call to STEWART original telephone number, (773) 551-6269, and heard a busy signal as described by MILLAN in his call to RIVAS on the same day.

 

IV. REQUESTED SEARCH WARRANT.

78. T    hrough my training, my discussions with other experienced agents, and my personal experience, I am familiar with the methods, schemes and operations used by drug traffickers and know that such traffickers commonly:

a.          maintain ledgers, books, or other records relating to the transportation, purchase, packaging, sale and distribution of controlled substances, even though some documents may be in code. That drug traffickers commonly "front" drugs (provide controlled substances on consignment) to their customers.

b.          maintain books or papers which reflect the names, addresses and/or telephone numbers of their suppliers, couriers, customers and other associates in the illegal drug trade;

c.          maintain the aforementioned books, papers and documents in secure locations within their residences and/or places of business so that the drug traffickers have ready access to such information;

d.          conceal in their residences and/or places of business the proceeds of their illegal activity, including large amounts of United States currency, financial instruments, and other items of value, as well as books and records regarding the acquisition, use and disposition of such items of value;

e.          when amassing large proceeds from the sale of controlled substances, attempt to legitimize these profits, often accomplishing this goal by

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using the services of foreign and domestic banks, other financial institutions, and real estate brokers; and that books and papers related to such efforts, including, but not limited to, cashier checks, money orders, telegram, telexes, letter of credit and ledgers, are maintained in the residences and/or places of business of the drug traffickers;

f. take or cause to be taken photographs of themselves, their associates in the drug trade, property derived from the distribution of narcotics, and their product, and that such photographs are often kept in their residences and/or place of business; and

g. place assets, including real and personal property, such as vehicles, in names other than their own to avoid the detection and forfeiture of such assets by government agencies; and the drug traffickers continue to use these assets and to exercise dominion and control over them even though the assets are nominally owned by others.

h. keep paraphernalia for packaging, cutting, weighing, and distributing cocaine, including but not limited to scales, plastic bags, and cutting agents.

79.          Below are set forth additional facts and circumstances in support of the issuance of a search warrant for the location specified below which belongs to STEWART, the supplier of the heroin sold to PRADO by RIVAS and MILLAN.

 

A.       213 May Street, Bensenville, Illinois 60106

80.          213 May Street, Bensenville, Illinois 60106 is a one-story single family residence on the East side of the street at the North end of the 200 block of May Street. The residence has white siding and a faded red shingle roof. The number "213" is written in black numbers horizontally to the right of the front door. The residence has a black asphalt driveway on the South side of the house, and a cyclone fence surrounds the rear of the

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residence.

81.           Based on the communications intercepted over Target Telephones One and Two as detailed above, and the surveillance conduced on May 22, 2005, STEWART is believed to be a supplier of kilogram quantities of heroin to RIVAS and MILLAN. See ¶¶ 43-53, 57 and 77. Specifically, as detailed above, it is believed that STEWART supplied one-half a kilogram of heroin to the coconspirators on May 22, 2005 and one kilogram of heroin to the coconspirators on May 24, 2005.

82.           On May 31, 2005, Agents conducted surveillance at 213 May Street, Bensenville, Illinois. Agents observed STEWART arrive at the residence driving a black Lincoln Navigator bearing Illinois registration No. 712-3709, registered to Emmanuel B. Rangel, 213 May Street, Bensenville, Illinois.8 Rangel is STEWART's maiden name. STEWART stopped at the residence, picked up an unidentified female teenager and departed. On June 1, 2005, at approximately 7:00 a.m., Agents again observed the Lincoln Navigator parked in the driveway at the May Street address. 213 May Street is the same address that was listed on the rental agreement for the Grand Marquis that was rented from Hertz for the May 22, 2005 meeting between STEWART and RIVAS.

83.          STEWART is further connected to the May Street address because her drivers

________________
8     On May 12, 2005, Agents observed the Lincoln Navigator driven by an unidentified Hispanic Male, who met with MILLAN shortly after MILLAN  had received drug proceeds from PRADO.

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license, based on Secretary of State records, indicates that her home address is 213 May Street, Bensenville, Illinois. The photo contained on the drivers license is the same person who agents observed meeting with RIVAS on May 22, 2005 after communications were intercepted indicating that STEWART would be providing narcotics to RIVAS at the meeting. See  53. Additionally, on or about October 24, 2004, STEWART was arrested by the Chicago Police Department for Obstruction of Justice. The arrest photo matches the photo contained in STEWART's drivers license. At the time of her arrest, STEWART told the police that her home address was 213 May Street, Bensenville, Illinois. Finally, credit history reports for Sandra STEWART list a residence of 213 May Street, Bensenville, Illinois.

84.     Based upon my training and experience persons who traffic in large scale quantities of narcotics, such as those distributed by STEWART in this case, often keep records of such transactions, including money and drug ledgers. Moreover, the wire intercepts indicate that STEWART receives approximately $58,000 for each kilogram of heroin which she sells. Given the significant amounts of cash recently received by STEWART, it is likely that STEWART still has possession of drug proceeds.

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V.      Requested Authority for Search Warrants for Each of the Foregoing Locations.

85.       Based on the foregoing it appears that there is probable cause to seize from the foregoing locations the following items:

a.              United States Currency, precious metals, jewelry, and financial instruments, including stocks and bonds;

b.             Records, notebooks, memoranda, receipts, ledgers, photographs, lists and supplier or customer information relating to the purchase, sale or distribution of narcotic controlled substances;

c.              Books, records, lists, receipts, bank savings and loan records of deposit, statements, and other bank records, letters of credit, money orders, cashiers' checks, passbooks, canceled checks, certificates of deposit, lease agreements, loan records, customer account information, income and expense summaries, cash disbursement journals, financial statements, state and federal income tax returns, financial information pertaining to the purchase, lease, sale or other disposition of real or personal property, including real estate, automobiles, jewelry, and furniture;

d.             Indicia of ownership, occupancy or residency of the premises being searched, including utility and telephone bills, lease agreements, and mortgage records, loan documents, service, remodeling and repair contracts and keys;

e.              Photographs, including still photos, negatives, video tapes, films, undeveloped film and the contents thereof, of co-conspirators identified in the application and/or controlled substances;

f.               Address and/or telephone books, Rolodex indices and any papers reflecting names, addresses, telephone numbers, pager numbers, FAX numbers and/or telex numbers of co-conspirators identified in the application, sources of supply, customers, financial institutions and other individuals, businesses and institutions with whom a financial

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relationship exists and safes and the contents within;

g.          Controlled substances and drug paraphernalia for packaging, cutting, weighing and distributing controlled substances.

 

 

FURTHER AFFIANT SAYETH NOT.

___________________
Frank Jack Sodetz III
Special Agent
Federal Bureau of Investigation

 

Sworn to before me this 1st day of June, 2005

s/GERALDINE SOAT BROWN

GERALDINE SOAT BROWN

UNITED STATES MAGISTRATE JUDGE

 

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