federal indictment of chino sinners gang

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA October 2009 Grand Jury UNITED STATES OF AMERICA, Plaintiff, v. VICTOR MANUEL HURTADO, III, aka “Vic”; JAIME BANUELOS, aka “JB”; SILVINO PEREZ, aka “Fat Boy”; MICHAEL ANGEL MONSIVAIS, aka “Rascal”; ALBERT ROBERTO HERNANDEZ, aka “Fighter”; ALEXANDER JOHN HERNANDEZ; DAVID LYLE DARNALL, aka “D”; FREDRICK MALGRA GARCIA, JR., aka “Freddy,” aka “Freddy G”; MATTHEW PAUL REINA, aka “Lumps,” aka “Lumpy,” aka “Cobra”; ROMEO ROY ARANDA, aka “Criminal”; LORENA AGUIRRE; CRYSTINE MINCHAU RAMIREZ, aka “Chau,” aka “Crystine Thach,” aka “Chau Thach”; ANTHONY JESUS RAMIREZ; RICHARD ALLEN GALVAN, aka “Animal”; and NICK EVERETT CERVANTEZ, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CR _________________ I N D I C T M E N T [21 U.S.C. §§ 846, 841(a)(1), (b)(1)(A), (b)(1)(C): Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances; 21 U.S.C. §§ 841(a)(1), (b)(1)(A), (b)(1)(B): Possession with Intent to Distribute and Distribution of Methamphetamine; 18 U.S.C. § 924(c)(1)(A)(i): Use or Carrying of Firearm During Drug Trafficking Crime; 18 U.S.C. § 922(g)(1): Felon in Possession of a Firearm and/or Ammunition; 21 U.S.C. § 843(b): Use of a Communication Facility in Committing a Felony Drug Offense] CLS:cls

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A multi-agency taskforce investigation has resulted in the federal indictment of members a Chino, Calif., gang for allegedly operating a drug distribution network.

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UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

October 2009 Grand Jury

UNITED STATES OF AMERICA,

Plaintiff,

v.

VICTOR MANUEL HURTADO, III, aka “Vic”;JAIME BANUELOS, aka “JB”; SILVINO PEREZ, aka “Fat Boy”;MICHAEL ANGEL MONSIVAIS, aka “Rascal”;ALBERT ROBERTO HERNANDEZ, aka “Fighter”; ALEXANDER JOHN HERNANDEZ;DAVID LYLE DARNALL, aka “D”; FREDRICK MALGRA GARCIA, JR., aka “Freddy,” aka “Freddy G”; MATTHEW PAUL REINA, aka “Lumps,” aka “Lumpy,” aka “Cobra”;ROMEO ROY ARANDA, aka “Criminal”;LORENA AGUIRRE; CRYSTINE MINCHAU RAMIREZ, aka “Chau,” aka “Crystine Thach,” aka “Chau Thach”;ANTHONY JESUS RAMIREZ; RICHARD ALLEN GALVAN, aka “Animal”; andNICK EVERETT CERVANTEZ,

Defendants.

) ) ) ) ) ) ))))))))))))))))))))))))))))))))

CR _________________

I N D I C T M E N T

[21 U.S.C. §§ 846, 841(a)(1),(b)(1)(A), (b)(1)(C):Conspiracy to Distribute andPossess with Intent toDistribute ControlledSubstances; 21 U.S.C. §§ 841(a)(1), (b)(1)(A), (b)(1)(B): Possession withIntent to Distribute andDistribution ofMethamphetamine; 18 U.S.C.§ 924(c)(1)(A)(i): Use orCarrying of Firearm DuringDrug Trafficking Crime; 18U.S.C. § 922(g)(1): Felon inPossession of a Firearm and/orAmmunition; 21 U.S.C. § 843(b): Use of aCommunication Facility inCommitting a Felony Drug Offense]

CLS:cls

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The Grand Jury charges:

COUNT ONE

[21 U.S.C. §§ 846, 841(a)(1), 841(b)(1)(A), (b)(1)(B), (b)(1)(C)]

A. OBJECTS OF THE CONSPIRACY

Beginning on an unknown date but prior to May 4, 2006, and

continuing to the date of the filing of this indictment, in Los

Angeles County, San Bernardino County, and Riverside County,

within the Central District of California, and elsewhere,

defendants VICTOR MANUEL HURTADO, III, also known as (“aka”)

“Vic” (“HURTADO”); JAIME BANUELOS, aka “JB” (“BANUELOS”); SILVINO

PEREZ, aka “Fat Boy” (“PEREZ”); MICHAEL ANGEL MONSIVAIS, aka

“Rascal” (“MONSIVAIS”); ALBERT ROBERTO HERNANDEZ, aka “Fighter”

(“ALBERT HERNANDEZ”); ALEXANDER JOHN HERNANDEZ (“ALEXANDER

HERNANDEZ”); DAVID LYLE DARNALL, aka “D” (“DARNALL”); FREDRICK

MALGRA GARCIA, JR., aka “Freddy,” aka “Freddy G” (“GARCIA”);

MATTHEW PAUL REINA, aka “Lumps,” aka “Lumpy,” aka “Cobra”

(“REINA”); ROMEO ROY ARANDA, aka “Criminal” (“ARANDA”); LORENA

AGUIRRE (“AGUIRRE”); CRYSTINE MINCHAU RAMIREZ, aka “Chau,” aka

“Crystine Thach,” aka “Chau Thach” (“CRYSTINE RAMIREZ”); ANTHONY

JESUS RAMIREZ (“ANTHONY RAMIREZ”); RICHARD ALLEN GALVAN, aka

“Animal” (“GALVAN”); and NICK CERVANTEZ (“CERVANTEZ”)

(collectively, “the defendants”), and others known and unknown to

the Grand Jury, conspired and agreed with each other to knowingly

and intentionally distribute and possess with intent to

distribute controlled substances, in violation of 21 U.S.C.

§§ 841(a)(1). It is further alleged that this conspiracy was

intended to involve, and did involve, at least the following

substances: at least 50 grams of methamphetamine, a schedule II

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controlled substance, in violation of 841(b)(1)(A); at least 100

kilograms of a mixture or substance containing a detectable

amount of marijuana, a schedule I controlled substance, in

violation of 841(b)(1)(B); a mixture or substance containing a

detectable amount of cocaine, a schedule II controlled substance,

in violation of 841(b)(1)(C); and a mixture or substance

containing a detectable amount of heroin, a schedule I controlled

substance, in violation of 841(b)(1)(C).

B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE

ACCOMPLISHED

The objects of the conspiracy were to be accomplished in

substance as follows:

1. Defendant HURTADO would oversee and direct a drug

trafficking organization involving the substances specified

above. Defendant HURTADO would have other individuals obtain and

distribute controlled substances, and collect payment from

customers and redistributors.

2. Defendant PEREZ would supply the drug trafficking

organization with methamphetamine.

3. Acting at the direction of defendant HURTADO, and

independently, defendant BANUELOS would obtain drugs from

defendant HURTADO and from various suppliers, and would

distribute methamphetamine and cocaine to defendant MONSIVAIS and

others.

4. Defendant MONSIVAIS would act as the local distributor

of controlled substances for defendant HURTADO’s drug trafficking

organization in the Chino, California area. Defendant MONSIVAIS

would distribute the methamphetamine and cocaine obtained from

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defendant BANUELOS to various customers, including defendants

GALVAN, REINA, CRYSTINE RAMIREZ, ANTHONY RAMIREZ, and CERVANTEZ,

for further distribution.

5. Defendants AGUIRRE, CRYSTINE RAMIREZ, and ANTHONY

RAMIREZ would assist defendant MONSIVAIS in his drug distribution

activities by receiving deliveries from BANUELOS, cutting

deliveries up into smaller portions, taking orders from

customers, making deliveries to customers, and collecting money.

6. Defendants CRYSTINE RAMIREZ and ANTHONY RAMIREZ would

also acquire methamphetamine from defendant MONSIVAIS to sell to

customers on their own behalf.

7. Defendant ALBERT HERNANDEZ would also distribute

methamphetamine in Chino, California and in surrounding areas.

8. Defendant GARCIA would send messages from inside the

California Institute for Men in Chino, California (“Chino

Prison”) to defendants HURTADO, MONSIVAIS, DARNALL, REINA, ARANDA

and others to direct the importation of heroin and other

controlled substances into the prison.

9. Defendant MONSIVAIS would acquire heroin from defendant

BANUELOS and other sources for distribution to defendant GARCIA

and others.

10. Defendants DARNALL, REINA and MONSIVAIS would

contribute money to pay for the heroin for defendant GARCIA.

11. Defendant HURTADO would assist defendant MONSIVAIS in

acquiring the heroin for defendant GARCIA.

12. Defendant ARANDA would secrete the heroin on his person

and transport it into Chino Prison, where he would distribute it

to defendant GARCIA and others, for further distribution.

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13. Defendants MONSIVAIS and BANUELOS would acquire

marijuana from unindicted co-conspirators, and distribute it to

defendants ALBERT HERNANDEZ, ALEXANDER HERNANDEZ, DARNALL,

ARANDA, and other individuals, for further distribution.

C. OVERT ACTS

In furtherance of the conspiracy and to accomplish the

objects of the conspiracy, the defendants and others known and

unknown to the Grand Jury committed various overt acts in Los

Angeles County, San Bernardino County, and Riverside County,

within the Central District of California, including but not

limited to the following acts committed on or about the following

dates:

1. On May 4, 2006, defendant HURTADO possessed

approximately $24,000 in cash and a .22 caliber pistol loaded

with five rounds of ammunition.

2. On August 29, 2007, an unindicted co-conspirator

obtained approximately four pounds of methamphetamine from a

supplier, for further delivery to defendant HURTADO.

3. On April 3, 2008, defendant ALBERT HERNANDEZ sold one-

half ounce of methamphetamine to a person whom he believed to be

a drug trafficker, but who was in fact a confidential source

working at the direction of the Federal Bureau of Investigation

(“CS1").

4. On May 6, 2008, defendant ALBERT HERNANDEZ sold CS1 one

ounce of methamphetamine.

5. On June 6, 2008, defendant ALBERT HERNANDEZ sold CS1

four ounces of methamphetamine.

6. On June 18, 2008, using coded language in a telephone

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conversation, defendant MONSIVAIS told a person whom he believed

to be a drug trafficker, but who was in fact a confidential

source working at the direction of the Federal Bureau of

Investigation (“CS2"), that defendant MONSIVAIS had both cocaine

and methamphetamine, and agreed to sell CS2 two ounces of

methamphetamine for $900 per ounce.

7. On November 14, 2008, using coded language in a

telephone conversation, defendant GALVAN ordered two 1/8 ounce

quantities of methamphetamine from defendant MONSIVAIS.

8. On November 18, 2008, using coded language in a

telephone conversation, defendant AGUIRRE told defendant GALVAN

that defendant MONSIVAIS would provide defendant GALVAN 1/8 ounce

of methamphetamine.

9. On November 19, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

co-conspirator that there were three people who would pool their

money to purchase marijuana from the unindicted co-conspirator,

and they would take more than 300 kilograms of marijuana if the

product was good.

10. On November 19, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

ALEXANDER HERNANDEZ that defendant MONSIVAIS would have a supply

of marijuana in the near future.

11. On November 19, 2008, using coded language in a

telephone conversation, defendant ALEXANDER HERNANDEZ told

defendant MONSIVAIS that he had a customer who needed one pound

of marijuana at that time.

12. On November 19, 2008, using coded language in a

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telephone conversation, defendant MONSIVAIS told an unindicted

co-conspirator that the price for methamphetamine was $900 per

ounce for mid-grade methamphetamine, and $1,600 per ounce for

high-grade methamphetamine.

13. On November 22, 2008, using coded language in a

telephone conversation, defendant GALVAN asked defendant AGUIRRE

for two 1/8 ounce portions of methamphetamine.

14. On November 22, 2008, using coded language in a

telephone conversation, defendant AGUIRRE told defendant GALVAN

that defendant MONSIVAIS only had a single 1/8 ounce portion of

methamphetamine, and instructed defendant GALVAN to call her when

he had arrived at defendant MONSIVAIS’s residence.

15. On November 22, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS placed an order with

defendant BANUELOS for two ounces of methamphetamine.

16. On November 23, 2008, using coded language in a

telephone conversation, defendant ALBERT HERNANDEZ told defendant

MONSIVAIS that he had a supply of methamphetamine, and asked

defendant MONSIVAIS for defendant DARNALL’s telephone number.

17. On November 24, 2008, using coded language in a

telephone conversation, defendant ANTHONY RAMIREZ ordered 1/8

ounce of methamphetamine from defendant MONSIVAIS.

18. On November 24, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

ANTHONY RAMIREZ to go over to defendant MONSIVAIS’s residence and

take the methamphetamine himself, and that defendant CRYSTINE

RAMIREZ knew where it was.

19. On November 25, 2008, using coded language in a

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telephone conversation, defendant ALBERT HERNANDEZ told defendant

MONSIVAIS that he had a supply of methamphetamine.

20. On November 26, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS requested two ounces

of methamphetamine from defendant BANUELOS, who agreed to deliver

the methamphetamine.

21. On November 28, 2008, using coded language in a

telephone conversation, defendant CERVANTEZ ordered 1/8 ounce of

methamphetamine from defendant MONSIVAIS.

22. On November 29, 2008, using coded language in a

telephone conversation, defendant BANUELOS agreed to bring

another one or two ounces of methamphetamine to defendant

MONSIVAIS.

23. On November 29, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

BANUELOS that there were police on his street, and that he would

see where defendant AGUIRRE was and have her collect the

methamphetamine instead.

24. On November 29, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS called defendant

AGUIRRE and asked her to get in touch with defendant BANUELOS to

pick up methamphetamine from defendant BANUELOS.

25. On November 29, 2008, defendant AGUIRRE met with

defendant BANUELOS to collect the methamphetamine.

26. On November 29, 2008 defendant AGUIRRE drove with the

methamphetamine back to the residence of defendant MONSIVAIS,

while defendant MONSIVAIS followed in another vehicle.

27. On November 29, 2008, using coded language in a

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telephone conversation, defendant REINA ordered a 1/16 ounce

portion of methamphetamine from defendant MONSIVAIS for another

customer.

28. On November 29, 2008, using coded language in a

telephone conversation, defendant CRYSTINE RAMIREZ told defendant

MONSIVAIS that she was going to drop off money and pick up a 1/16

ounce portion of methamphetamine from his house.

29. On November 29, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

CRYSTINE RAMIREZ that there was one 1/16 ounce portion of

methamphetamine there, and the rest were 1/8 ounce portions.

30. On December 1, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

co-conspirator that defendant BANUELOS would give defendant

MONSIVAIS one or two ounces of methamphetamine on credit at a

time, and that he believed that a pound of methamphetamine would

cost $13,500.

31. On December 1, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

co-conspirator about 1000 pounds of marijuana being delivered.

32. On December 1, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

co-conspirator that the price for cocaine was $24,500 per

kilogram.

33. On December 2, 2008, using coded language in a

telephone conversation, defendant DARNALL told defendant

MONSIVAIS that he had received a letter from defendant GARCIA and

an unindicted co-conspirator, who wanted some drugs sent into

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Chino prison for them.

34. On December 2, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS asked defendant

HURTADO to put him in touch with an individual to help fulfill

the request from defendant GARCIA.

35. On December 2, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant REINA

that he had received a letter from defendant GARCIA, who wanted

drugs sent into prison for him as soon as possible.

36. On December 2, 2008, using coded language in a

telephone conversation, defendant REINA confirmed with defendant

MONSIVAIS that defendant GARCIA just wanted heroin.

37. On December 2, 2008, using coded language in a

telephone conversation, defendant REINA indicated that obtaining

heroin would be no problem, and discussed with defendant

MONSIVAIS possible sources from which they could acquire the

heroin.

38. On December 2, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS asked defendant REINA

to contribute $100 towards the purchase of at least one-half of

an ounce of heroin for defendant GARCIA.

39. On December 3, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

DARNALL that he had arranged to acquire the heroin for defendant

GARCIA, and asked defendant DARNALL if he could contribute to the

cost.

40. On December 3, 2008, using coded language in a

telephone conversation, defendant DARNALL agreed to contribute

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$100 towards the heroin for defendant GARCIA.

41. On December 3, 2008, defendant CERVANTEZ purchased a

1/8 ounce portion of methamphetamine from defendant MONSIVAIS

42. On December 3, 2008, using coded language in a

telephone conversation, defendant CERVANTEZ told defendant

AGUIRRE that he wanted to purchase two additional 1/8 ounce

portions of methamphetamine from defendant MONSIVAIS.

43. On December 3, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

CERVANTEZ that defendant AGUIRRE would deliver defendant

CERVANTEZ’s methamphetamine order.

44. On December 3, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS and defendant

BANUELOS discussed the price for a pound of methamphetamine.

45. On December 3, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

BANUELOS that their supplier would have 1000 pounds of marijuana

the next day.

46. On December 4, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

DARNALL that he was getting 1000 pounds of marijuana from a

supplier.

47. On December 4, 2008, using coded language in a

telephone conversation, defendant DARNALL told defendant

MONSIVAIS that he could help sell the marijuana.

48. On December 4, 2008, using coded language in a

telephone conversation, defendant REINA told defendant MONSIVAIS

and that his cousin was going to call defendant MONSIVAIS to

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order more methamphetamine.

49. On December 4, 2008, using coded language in a

telephone conversation, defendant GALVAN told defendant MONSIVAIS

that he would pick up 1/8 ounce of methamphetamine and would pay

MONSIVAIS the next day.

50. On December 4, 2008, using coded language in a

telephone conversation, defendant ANTHONY RAMIREZ agreed to

provide methamphetamine to a customer at defendant MONSIVAIS’s

direction.

51. On December 5, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

BANUELOS that their supplier had sent 2000 pounds instead of 1000

pounds of marijuana across the border.

52. On December 5, 2008, using coded language in a

telephone conversation, defendant REINA asked defendant MONSIVAIS

to prepare a 1/16 ounce portion of methamphetamine for him.

53. On December 6, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

BANUELOS that he could obtain uncut cocaine from Mexico for

$24,500 per kilogram.

54. On December 7, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS agreed to distribute

1000 pounds of marijuana.

55. On December 12, 2008, using coded language in a

telephone conversation, defendant AGUIRRE told defendant ANTHONY

RAMIREZ that she and defendant MONSIVAIS were going to collect

money from another drug customer and would be right back to

collect money from defendants ANTHONY RAMIREZ and CRYSTINE

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RAMIREZ.

56. On December 12, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

BANUELOS that he needed three ounces of methamphetamine,

57. On December 12, 2008, using coded language in a

telephone conversation, defendant BANUELOS agreed to deliver the

three ounces of methamphetamine to defendant MONSIVAIS.

58. On December 12, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant ARANDA

that defendant GARCIA had sent a letter and wanted some drugs

brought into prison.

59. On December 12, 2008, using coded language in a

telephone conversation, defendant ARANDA agreed to smuggle the

heroin into prison for defendant GARCIA.

60. On December 12, 2008, using coded language in a

telephone conversation, defendant ARANDA told defendant MONSIVAIS

that he was interested in purchasing marijuana for $350 per

pound.

61. On December 12, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS contacted an

unindicted co-conspirator and arranged to put defendant ARANDA in

touch with the unindicted co-conspirator for the purpose of

purchasing marijuana.

62. On December 17, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant ALBERT

HERNANDEZ that he had a supply of marijuana for sale for $375 per

pound.

63. On December 18, 2008, using coded language in a

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telephone conversation, defendant MONSIVAIS told defendant

DARNALL that he would sell marijuana to defendant DARNALL, and

defendant DARNALL could sell it for an increased price.

64. On December 19, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant REINA

that he had two 1/8 ounce portions of methamphetamine, and agreed

to sell a 1/16 ounce portion to one of defendant REINA’s

customers.

65. On December 19, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant REINA

to have his customer call defendant CRYSTINE RAMIREZ to pick up

the methamphetamine.

66. On December 19, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant ARANDA

that he had the heroin to send into Chino Prison for defendant

GARCIA.

67. On December 20, 2008, using coded language in a

telephone conversation, defendant GALVAN ordered three 1/8 ounce

portions of methamphetamine from defendant MONSIVAIS.

68. On December 20, 2008, using coded language in a

telephone conversation, defendant REINA asked defendant MONSIVAIS

for more methamphetamine,

69. On December 20, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant REINA

that he only had cocaine.

70. On December 21, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS arranged to bring the

heroin intended for defendant GARCIA to defendant DARNALL.

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71. On December 21, 2008, using coded language in telephone

conversation, defendant MONSIVAIS told defendant ARANDA that

defendant DARNALL had the heroin for defendant ARANDA to pick up,

and that defendant MONSIVAIS had included some marijuana for

defendant ARANDA to use to make money while defendant ARANDA was

in prison.

72. On December 23, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS asked defendant

BANUELOS to bring him one or two ounces of methamphetamine,

73. On December 23, 2008, using coded language in a

telephone conversation, defendant BANUELOS agreed to supply

defendant MONSIVAIS with more methamphetamine.

74. On December 23, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told a customer that

he (defendant MONSIVAIS) had methamphetamine, marijuana, and

cocaine.

75. On December 26, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told a customer that

he would get ounces of cocaine for $600 per ounce from defendant

BANUELOS.

76. On December 27, 2008, using coded language in a

telephone conversation, defendant ARANDA told defendant MONSIVAIS

that he was going to turn himself in the following Monday, but

needed to repackage the heroin for defendant GARCIA.

77. On December 27, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS agreed to put

defendant ARANDA in touch with unindicted co-conspirators who

would be able to supply heroin to defendant ARANDA’s nephew and

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mother while defendant ARANDA was in prison.

78. On December 27, 2008, using coded language in a

telephone conversation, defendant BANUELOS told defendant

MONSIVAIS that he was interested in purchasing a whole ounce of

heroin.

79. On December 29, 2008, defendant ARANDA attempted to

surrender to authorities for a violation of parole in order to

bring the heroin in to Chino Prison for defendant GARCIA.

80. On December 29, 2008, using coded language in a

telephone conversation, defendant ARANDA told defendant MONSIVAIS

that he was not successful in attempting to turn himself in, and

had been told to come back.

81. On December 29, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant ARANDA

to bring the heroin with him the next time in case he was allowed

to surrender.

82. On December 30, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

coconspirator seeking to purchase methamphetamine to call

defendant CRYSTINE RAMIREZ because defendant CRYSTINE RAMIREZ was

on standby to handle defendant MONSIVAIS’s drug orders.

83. On December 31, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told an unindicted

coconspirator that he had no cocaine at that time, only

methamphetamine, and that defendant CRYSTINE RAMIREZ was holding

drugs for defendant MONSIVAIS.

84. On December 31, 2008, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

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BANUELOS that he needed two portions of cocaine, one in the

amount of 1/8 ounce and one in the amount of 1/16 ounce.

85. On December 31, 2008, using coded language in a

telephone conversation, defendant CRYSTINE RAMIREZ told defendant

AGUIRRE that some customers were looking to purchase cocaine.

86. On January 8, 2009, using coded language in a telephone

conversation, defendant GALVAN told defendant MONSIVAIS that he

had been stopped by the police after leaving MONSIVAIS’s

residence, and had swallowed the 1/8 ounce portion of

methamphetamine he had purchased from defendant MONSIVAIS.

87. On January 11, 2009, using coded language in a

telephone conversation, defendant MONSIVAIS asked defendant

BANUELOS to drop off two ounces of methamphetamine for him with

defendant CRYSTINE RAMIREZ. Defendant BANUELOS agreed.

88. On January 11, 2009, using coded language in a

telephone conversation, defendant MONSIVAIS told defendant

CRYSTINE RAMIREZ that defendant BANUELOS was going to come to her

house and drop off two whole ounces of methamphetamine, and that

she should cut one of those portions exactly in half.

89. On February 11, 2009, at the direction of defendant

HURTADO, defendant BANUELOS delivered approximately 5 pounds of

methamphetamine to an unindicted co-conspirator.

90. On March 6, 2009, using coded language in a telephone

conversation, defendant DARNALL sold one ounce of methamphetamine

to CS2.

91. On April 10, 2009, using coded language in a telephone

conversation, defendant DARNALL sold more than two ounces of

methamphetamine to CS2

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92. On June 14, 2009, defendant GARCIA provided several

letters to an unindicted co-conspirator for transportation

outside of Chino Prison which requested that defendant HURTADO,

defendant REINA and others arrange to transport heroin and

methamphetamine into Chino Prison.

93. On November 10, 2009, using coded language in a

telephone conversation, defendant ALBERT HERNANDEZ asked

defendant HURTADO to put him in touch with either defendant PEREZ

or defendant BANUELOS in order to purchase methamphetamine.

94. On November 10, 2009, defendant HURTADO called

defendant BANUELOS and asked defendant BANUELOS to call defendant

ALBERT HERNANDEZ.

95. On November 16, 2009, defendant ALEXANDER HERNANDEZ

possessed approximately 90 grams of methamphetamine.

96. On November 17, 2009, using coded language in a

telephone conversation, defendant HURTADO and defendant PEREZ

agreed to meet to discuss the sale of methamphetamine.

97. On December 5, 2009, using coded language in a

telephone conversation, defendant HURTADO instructed defendant

BANUELOS not to lower the price for ounces of methamphetamine

even though defendant BANUELOS was able to obtain pounds of

methamphetamine for a lower price.

98. On December 13, 2009, using coded language in a

telephone conversation, defendant BANUELOS told defendant HURTADO

that defendant BANUELOS had given the last two ounces of

methamphetamine to defendant MONSIVAIS, and owed defendant

HURTADO money for a total of six ounces of methamphetamine.

99. On December 23, 2009, defendant HURTADO obtained

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approximately eight ounces of methamphetamine from a supplier.

100. On December 23, 2009, using coded language in a

telephone conversation, defendant HURTADO agreed to drop off four

ounces of methamphetamine to an unindicted co-conspirator.

101. On December 23, 2009, defendant HURTADO delivered

approximately one ounce of methamphetamine to an individual he

believed to be a methamphetamine customer.

102. On January 5, 2010, defendant PEREZ received a

delivery of approximately five pounds of methamphetamine from an

unindicted co-conspirator, which he transported in his car.

103. On January 5, 2010, defendant PEREZ possessed slightly

less than one pound of methamphetamine inside the oven in the

kitchen of in his house.

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COUNT TWO

[18 U.S.C. § 924(c)(1)(A)(i)]

Beginning on an unknown date and continuing until on or

about May 4, 2006, in San Bernardino County, within the Central

District of California, defendant VICTOR MANUEL HURTADO, III,

also known as “Vic,” knowingly possessed a firearm, namely, a

North American Arms .22 caliber pistol, in furtherance of a drug

trafficking crime, namely, conspiracy to distribute and possess

with intent to distribute controlled substances, in violation of

Title 21, United States Code, Sections 841 and 846, as charged in

Count One.

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COUNT THREE

[18 U.S.C. § 922(g)(1)]

Beginning on an unknown date and continuing until on or

about May 4, 2006, in San Bernardino County, within the Central

District of California, defendant VICTOR MANUEL HURTADO, III,

also known as “Vic,” (“HURTADO”) knowingly possessed a firearm,

namely, a North American Arms .22 caliber pistol, and ammunition,

in and affecting interstate and foreign commerce.

Such possession occurred after defendant HURTADO had been

convicted of at least one of the following felonies, each

punishable by a term of imprisonment exceeding one year:

(1) Burglary, in violation of California Penal Code

Section 459, in the Superior Court of California, County of San

Bernardino, case number FCH01189, on or about February 9, 1995;

(2) Possession of a Controlled Substance, in violation of

California Health & Safety Code Section 11377(a), in the Superior

Court of California, County of San Bernardino, case number

FCH03139, on or about February 11, 1999; and

(3) Possession of a Controlled Substance for Sale, in

violation of Health & Safety Code Section 11378, in the Superior

Court of California, County of San Bernardino, case number

FCH04941, on or about August 14, 2003.

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COUNT FOUR

[21 U.S.C. §§ 841(a)(1), (b)(1)(A); 18 U.S.C. § 2]

On or about August 29, 2007, in Riverside County, within the

Central District of California, an unindicted co-conspirator

knowingly and intentionally possessed with intent to distribute

at least 50 grams, that is, approximately 1600 grams, of actual

methamphetamine, a schedule II controlled substance.

At the above time and place, defendant VICTOR MANUEL

HURTADO, III, also known as “Vic,” aided, abetted, counseled,

commanded, induced and procured the commission of the offense

alleged above.

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COUNT FIVE

[21 U.S.C. §§ 841(a)(1), (b)(1)(B); 18 U.S.C. § 2]

On or about April 3, 2008, in San Bernardino County, within

the Central District of California, defendant ALBERT ROBERTO

HERNANDEZ, also known as “Fighter,” knowingly and intentionally

distributed at least 5 grams, that is, approximately 12 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNT SIX

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)]

On or about May 6, 2008, in San Bernardino County, within

the Central District of California, defendant ALBERT ROBERTO

HERNANDEZ, also known as “Fighter,” knowingly and intentionally

distributed at least 5 grams, that is, approximately 21 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNT SEVEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)]

On or about June 6, 2008, in San Bernardino County, within

the Central District of California, defendant ALBERT ROBERTO

HERNANDEZ, also known as “Fighter,” knowingly and intentionally

distributed at least 50 grams, that is, approximately 105 grams,

of actual methamphetamine, a schedule II controlled substance.

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COUNT EIGHT

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)]

On or about June 18, 2008, in San Bernardino County, within

the Central District of California, defendant MICHAEL ANGEL

MONSIVAIS, also known as “Rascal,” knowingly and intentionally

distributed at least 5 grams, that is, approximately 34 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNT NINE

[21 U.S.C. §§ 841(a)(1), (b)(1)(C)]

On or about November 20, 2008, in San Bernardino County,

within the Central District of California, defendant MICHAEL

ANGEL MONSIVAIS, also known as “Rascal,” knowingly and

intentionally distributed approximately 3 grams of a mixture or

substance containing a detectable amount of methamphetamine, a

schedule II controlled substance.

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COUNT TEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(C)]

On or about November 20, 2008, in San Bernardino County,

within the Central District of California, defendant RICHARD

ALLEN GALVAN, aka “Animal,” knowingly and intentionally possessed

with intent to distribute approximately 3 grams of a mixture or

substance containing a detectable amount of methamphetamine, a

schedule II controlled substance.

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COUNT ELEVEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(C)]

On or about December 3, 2008, in San Bernardino County,

within the Central District of California, defendant MICHAEL

ANGEL MONSIVAIS, also known as “Rascal,” knowingly and

intentionally distributed approximately 7 grams of a mixture or

substance containing a detectable amount of methamphetamine, a

schedule II controlled substance.

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COUNT TWELVE

[21 U.S.C. §§ 841(a)(1), (b)(1)(C)]

On or about December 3, 2008, in San Bernardino County,

within the Central District of California, defendant NICK EVERETT

CERVANTEZ knowingly and intentionally possessed with intent to

distribute approximately 7 grams of a mixture or substance

containing a detectable amount of methamphetamine, a schedule II

controlled substance.

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COUNT THIRTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)]

On or about March 6, 2009, in San Bernardino County, within

the Central District of California, defendant DAVID LYLE DARNALL,

also known as “D,” knowingly and intentionally distributed at

least 5 grams, that is, approximately 27 grams, of actual

methamphetamine, a schedule II controlled substance.

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COUNT FOURTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)]

On or about April 10, 2009, in San Bernardino County, within

the Central District of California, defendant DAVID LYLE DARNALL,

also known as “D,” knowingly and intentionally distributed at

least 50 grams, that is, approximately 56 grams, of actual

methamphetamine, a schedule II controlled substance.

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COUNT FIFTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)]

On or about April 24, 2009, in San Bernardino County, within

the Central District of California, defendant DAVID LYLE DARNALL,

also known as “D,” knowingly and intentionally possessed with

intent to distribute at least 5 grams, that is, approximately 5.3

grams, of actual methamphetamine, a schedule II controlled

substance.

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COUNT SIXTEEN

[18 U.S.C. § 924(c)(1)(A)(i)]

Beginning on unknown date and continuing to on or about April

24, 2009, in San Bernardino County, within the Central District of

California, defendant DAVID LYLE DARNALL, also known as “D,”

knowingly possessed a firearm, namely, a Smith & Wesson Model 49

.38 caliber revolver, in furtherance of a drug trafficking crime,

namely, conspiracy to distribute and possess with intent to

distribute methamphetamine, in violation of Title 21, United

States Code, Section 846, as charged in Count One, and possession

with intent to distribute methamphetamine, in violation of Title

21, United States Code, Section 841(a)(1), as charged in Count

Fifteen.

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COUNT SEVENTEEN

[18 U.S.C. § 922(g)(1)]

On or about April 24, 2009, in San Bernardino County, within

the Central District of California, defendant DAVID LYLE DARNALL,

also known as “D,” (“DARNALL”) knowingly possessed a firearm,

namely, a Smith & Wesson Model 49 .38 caliber revolver, and

ammunition, namely, five rounds of .38 caliber ammunition, in and

affecting interstate and foreign commerce.

Such possession occurred after defendant DARNALL had been

convicted of at least one of the following felonies, each

punishable by a term of imprisonment exceeding one year:

(1) Receiving Known Stolen Property, in violation of

California Penal Code Section 496(A), in the Superior Court of

California, County of San Bernardino, case number FCH04453, on or

about July 9, 2001;

(2) Possession of a Narcotic Controlled Substance, in

violation of California Health & Safety Code Section 11350(a), in

the Superior Court of California, County of San Bernardino, case

number FCH06124, on or about November 17, 2003; and

(3) Possession of a Dangerous Weapon, in violation of

California Penal Code Section 12020(a)(1), in the Superior Court

of California, County of San Bernardino, case number FWV038516,

on or about July 27, 2006.

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COUNT EIGHTEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)]

On or about January 5, 2010, in San Bernardino County, within

the Central District of California, defendant ALEXANDER JOHN

HERNANDEZ knowingly and intentionally possessed with intent to

distribute at least 50 grams, that is, approximately 90 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNT NINETEEN

[21 U.S.C. §§ 841(a)(1), (b)(1)(B)]

On or about December 23, 2009, in San Bernardino County,

within the Central District of California, defendant VICTOR MANUEL

HURTADO, III, also known as “Vic,” knowingly and intentionally

distributed at least 5 grams, that is, approximately 27 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNT TWENTY

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)]

On or about January 5, 2010, in San Bernardino County, within

the Central District of California, defendant SILVINO PEREZ, also

known as “Fat Boy,” knowingly and intentionally possessed with

intent to distribute at least 50 grams, that is, approximately

2170 grams, of actual methamphetamine, a schedule II controlled

substance.

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COUNT TWENTY-ONE

[21 U.S.C. §§ 841(a)(1), (b)(1)(A)]

Beginning on an unknown date and continuing to on or about

January 5, 2010, in San Bernardino County, within the Central

District of California, defendant SILVINO PEREZ, also known as

“Fat Boy,” knowingly and intentionally possessed with intent to

distribute at least 50 grams, that is, approximately 300 grams, of

actual methamphetamine, a schedule II controlled substance.

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COUNTS TWENTY-TWO THROUGH FORTY-FIVE

[21 U.S.C. § 843(b)]

On or about the dates and times set forth below, in Los

Angeles County, San Bernardino County, and Riverside County,

within the Central District of California, the defendants listed

below knowingly and intentionally used a communication facility,

namely, a telephone, in committing and causing and facilitating

the commission of a felony drug offense, namely, conspiracy to

possess with intent to distribute and to distribute controlled

substances in violation of Title 21, United States Code, Sections

841 and 846, as charged in Count One:

Count Date/Time Defendants

TWENTY-TWO 11/14/08

4:25 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and RICHARD ALLEN GALVAN, aka “Animal”

TWENTY-THREE 11/19/08

11:56 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ALEXANDER JOHN HERNANDEZ

TWENTY-FOUR 11/22/08

3:43 PM

LORENA AGUIRRE and RICHARD ALLEN

GALVAN, aka “Animal”

TWENTY-FIVE 11/22/08

3:55 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and JAIME BANUELOS, aka “JB”

TWENTY-SIX 11/23/08

7:29 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ALBERT ROBERTO HERNANDEZ

TWENTY-SEVEN 11/24/08

8:32 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ANTHONY JESUS RAMIREZ

TWENTY-EIGHT 11/25/08

10:44 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ALBERT ROBERTO HERNANDEZ

TWENTY-NINE 11/26/08

9:55 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and JAIME BANUELOS, aka “JB”

THIRTY 11/28/08

1:34 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and NICK EVERETT CERVANTEZ

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Count Date/Time Defendants

THIRTY-ONE 11/29/08

3:13 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and MATTHEW PAUL REINA, aka “Lumps,”

aka Lumpy,” aka “Cobra”

THIRTY-TWO 11/29/08

6:24 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and CRYSTINE MINCHAU RAMIREZ, aka

“Chau,” aka “Crystine Thach,” aka

“Chau Thach”

THIRTY-THREE 12/2/08

4:05 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and DAVID LYLE DARNALL, aka “D”

THIRTY-FOUR 12/3/08

8:03 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and NICK EVERETT CERVANTEZ

THIRTY-FIVE 12/3/08

8:40 PM

LORENA AGUIRRE and NICK EVERETT

CERVANTEZ

THIRTY-SIX 12/4/08

9:50 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ANTHONY JESUS RAMIREZ

THIRTY-SEVEN 12/4/08

9:46 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and MATTHEW PAUL REINA, aka “Lumps,”

aka Lumpy,” aka “Cobra”

THIRTY-EIGHT 12/10/08

10:16 AM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ALEXANDER JOHN HERNANDEZ

THIRTY-NINE 12/12/08

6:50 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ROMEO ROY ARANDA, aka “Criminal”

FORTY 12/19/08

6:42 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and CRYSTINE MINCHAU RAMIREZ, aka

“Chau,” aka “Crystine Thach,” aka

“Chau Thach”

FORTY-ONE 12/19/08

8:26 PM

MICHAEL ANGEL MONSIVAIS, aka “Rascal,”

and ROMEO ROY ARANDA, aka “Criminal”

FORTY-TWO 4/10/09

4:08 PM

DAVID LYLE DARNALL, aka “D”

FORTY-THREE 11/17/09

6:12 PM

VICTOR MANUEL HURTADO, III, aka “Vic”

and SILVINO PEREZ, aka “Fat Boy”

Page 42: Federal indictment of Chino Sinners gang

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Count Date/Time Defendants

FORTY-FOUR 11/18/09

2:14 PM

VICTOR MANUEL HURTADO, III, aka “Vic”

and SILVINO PEREZ, aka “Fat Boy”

FORTY-FIVE 12/5/09

6:03 PM

VICTOR MANUEL HURTADO, III, aka “Vic”

and JAIME BANUELOS, aka “JB”

A TRUE BILL

_____________________________Foreperson

ANDRÉ BIROTTE JR. United States Attorney

DANIEL S. GOODMANAssistant United States AttorneyActing Chief, Criminal Division

TIMOTHY J. SEARIGHTAssistant United States AttorneyChief, OCDETF Section

ANDREW BROWNAssistant United States AttorneyDeputy Chief, OCDETF Section

CAMERON L. SCHROEDERAssistant United States AttorneyOCDETF Section