United States District Court Eastern District of New York
United States District Court Eastern District of New York
United States District Court Eastern District of New York
FI LED
IN CLERK'S OFFICE
U.S. DISTRICT COURT E.D.N.Y.
JJD:JD/MWS/SMY
F. #2020R00632
* DEC 1t%o *
LONG ISLAND OFFICE
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA
~1ltCT~6T 5 71
- against- Cr. N o . - - - - - - - - - - , ~ - -
(T. 18, U.S.C., §§ 981(a)(l)(C),
BORROMEO ENRIQUE HENRIQUEZ, 981(a)(l)(G), 2332b(a)(l)(A), 2332b(a)(2),
also known as "Diablito de Hollywood," 2332b(b)(l)(A), 2332b(b)(l)(B), 2332b(c),
ELMER CANALES-RIVERA, 2339A(a), 2339C(a)(l)(B), 2339C(a)(2) and
also known as "Crook de Hollywood," 3551 et~.; T. 21, U.S.C., §§ 853(a),
EFRAIN CORTEZ, 853(p), 960a(a), and 970); T. 28, U.S.C.,
also known as "Tigre de Park View" and § 2461(c))
"Viejo Tigre de Park View,"
RICARDO ALBERTO DIAZ,
also known as "Rata de Leewards"
and "Mousey de Leewards,"
EDUARDO ERAZO-NOLASCO, BROWN, J.
also known as "Colocho de Western"
and "Mustage de Western," TISCIONE, M.J.
EDSON SACHARY EUFEMIA,
also known as "Speedy de Park View,"
JOSE FERNANDEZ FLORES-CUBAS,
also known as "Cola de Western,"
FREDYIVAN JANDRES-PARADA,
also known as "Lucky de Park View" .
and "Lacky de Park View,"
LEONEL ALEXANDER LEONARDO,
also known as "El Necio de San Cocos,"
CESAR HUMBERTO LOPEZ-LARIOS,
also known as "El Grenas de Stoners"
and "Oso de Stoners,"
JOSE LUIS MENpOZA-FIGUEROA,
also known as "Pavas de 7-11" and
"Viejo Pavas de 7-'1 l ,"
HUGO ARMANDO QUINTEROS-MINEROS,
also known as "Flaco de Francis,"
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Defendants.
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INTRODUCTION
organization with ~ens of thousands of members worldwide whose members engaged in "terrorist
activity," as defined by Title 8, United States Code, Section l l 82(a)(3)(B)(iii) and (iv), and in
"terrorism," as defined by Title 22, United States Code, Section 2656f(d)(2). MS-13 and its
members used violence against law enforcement, military members, government officials and
achieve political goals and retaliate for government actions against MS-13' s members and
leaders. MS-13 's leaders also directed members to commit acts of violence, including murder, in
the United States.· In order to achieve its goals in El Salvador, the United States and elsewhere,
MS-13 's leaders recruited large numbers of members; established an organizational leadership
structure; issued rules to govern MS-13's members; established military-style training camps;
obta~ed weapons such as rifles, handguns, grenades, improvised explosive devices ("IEDs") and
I
rocket launchers; negotiated with El Salvador government officials; engaged in public relations
efforts; controlled neighborhoods; and directed acts of violence and murder in El Salvador, the
United States and elsewhere. Further, MS-13 used its large membership in the United States to
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engage in criminal activities such as drug trafficking and extortion to raise money to support
MS-13's terrorist activities and terrorism in El Salvador and elsewhere, and directed members in
the United States to commit acts of violence, including murders, in furtherance of MS-13's goals
I
and to retaliate against the United States for actions, or perceived actions, taken against MS-13
History of MS-13
American immigrants in southern California.. Many of these immigrants were refugees from
civil wars in Central America. Immigrants from El Salvador, Honduras and Guatemala joined
together into neighborhood groups calling themselves the "Mara Salvatrucha Stoners." The
"Mara Salvatrucha Stoners" evolved into a street gang that engaged in drug trafficking, extortion
and acts of violence, and dropped the reference to "Stoners" in their name. As. members were
arrested and incarcerated, they encountered members of the Mexican Mafia, which controlled
large portions of the Hispanic prison population in California. In order to gain protection while
in prison, Mara Salvatrucha members pledged loyalty to the prison gang, the Mexican Mafia, and
added the number 13 to their name, which became "La Mara Salvatrucha 13," or "MS-13."
neighborhood groups known as "cliques." These cliques often were named after streets or
neighborhoods in the Los Angeles area, such as Hollywood, Park View, Normandie, Francis,
Fulton and Coronado. MS-13 also developed symbols and signs to signify gang membership and
territory through use of tattoos, hand signs and graffiti. These symbols included the "devil's
horns" and tattoos of the letters Mand Sand the number 13. MS-13 developed intense rivalries
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with other street gangs with members who were Central American immigrants, particularly with .
·America ended. Ultimately, thousands· of MS-13 members who had committed crimes in the
United States were deported to El Salvador and other Central American countries. These
deported MS-13 members brought MS-13 to El Salvador, Honduras and Guatemala where it
begaq to grow dramatically. Eventually, MS-13 grew to include tens of thousands of members
in El Salvador, Honduras, Guatemala, Mexico, the United States and elsewhere. As MS-13
members immigrated throughout the United States, MS-13 grew to include thousands of
members located in dozens of states, including New York, Massachusetts, Virginia, Maryland,
crimes in El Salvador, including acts of violence, drug trafficking and extortion. MS-13
members were incarcerated in prisons in El Salvador in large numbers and, in the early 2000s,
began to organize and sought to control the prisons where they were incarcerated. This
organization included the creation <?fa formal hierarchy, set of rules and leadership body to
control and profit from the activities of the gang in El Salvador, the United States and elsewhere.
· In approximately 2002, MS-13 members in a Salvadoran prison organized the first leadership
body for MS-13, known as the "Twelve Apostles of the Deyil," which included the defendants
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LEONARDO, also known as "El Necio de San Cocos," CESAR HUMBERTO LOPEZ-
LARIOS, also known as "El Grenas de Stoners" and "Oso de Stoners," JOSE LUIS
MENDOZA-FIGUEROA, also known as "Pavas de 7-11" and "Viejo Pavas de 7-11," HUGO
transferred to a new prison and renamed themselves as the "Ranfla." Members of the original
Ranfla became known as the "Ranfla Historica." Subsequently, the original leaders of the
Ranfla Historica and other high-ranking leaders such as the defendants EFRAIN CORTEZ, also
known as "Tigre de Park View" and "Viejo Tigre de Park View," JOSE FERNANDEZ.
also known as "Lucky de Park View" and "Lacky de Park View," and ARISTIDES DIONISIO
UMANZOR, also known as "Sirra de Teclas," formed the "Ranfla Nacional," which was the
highest level of leadership in MS-13 and provided overall direction for the gang, acting as the
equivalent of a "board of directors." Each of the defendants was a member of the Ranfla
Nacional.
Organization of MS-13
manage gang activities in El Salvador, the United States and elsewhere. MS-13 was organized at
its lowest level into groups known as "cliques" that held regular meetings to coordinate gang
activities. Each clique was run by a senior leader, who was designated the "Primera Palabra,"
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or "First Word," and, in some cases, a second-in-command, who was designated the "Segunda .
Pal~bra" or "Second Word." The other members of the cliqu~ took their orders from the First .
Word or Second Word. The leaders of the respective cliques attended larger general mee~ings to
manage gang operations on a regional and international level. Some cliques had members in
both the United States and El Salvador or other Central American countries.
8. MS-13 members attended clique meetings and were required to p·ay dues.
MS-13 members obtained money through illegal means, including, but not limited to, extortion
and drug trafficking. The money was provided to clique leaders and used to finance clique
activities, to provide support for clique members who were in jail, and, with respect to the United
States-based cliques, to send funds to MS.:. 13 in El Salvador to support gang activities there,
"Programs." Cliques within a Program were responsible for assisting one another with obtaining
firearms, sharing drug trafficking connections, responding to territorial disputes with rival gangs
and providing safe havens for members who were wanted by law enforcement. Programs were
"Corredors." These Program leaders controlled cliques located in the United States.
10. Above the Program level, MS-13 in El Salvador was divided into "Zones."
Numerous. Programs fell under each zone. Individuals holding the title of "Zone Corredor"
often supervised multiple Program Corredors. Zone Corredors supervised the Program
activities occurring in large zones of El Salvador and were tasked :with supervising multiple
Programs.
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11. Above the Zone Corredors were higher levels of leadership. Immediately
above the Zone Corredors were the "Ranfla en las Calles," or the "Ranfla in the Streets," which
consisted of leadership that was not in prison. Some Zone Corredors were also considered to be
"Ranfla en las Calles." The most powerful leaders in the "Ranfla en las Calles" formed a group
to coordinate their activities that was called the Federacion. The "Ranfla en las Calles" reported
to the "Ranfla en los Penales," or the "Ranfla in the Prisons," which consisted of senior MS-13
leaders who were incarcerated in El Salvador. The "Ranfla en las Calles" and the "Ranfla en los
Penales" reported to the highest level of leadership, which was the Ranfla Nacional. All major
organized into more than 200 cliques and dozens of Programs in El Salvador, Honduras,
Guatemala, Mexico, the United States and elsewhere. Since 2015, there have been additional
MS-13 Rules
Nacional developed rules to govern the behavior of members. The Ranfla Nacional distributed
these rules from prison to leaders in El Salvador, who then distributed the rules to members in El
Salvador, the United States and elsewhere. Only the Ranfla Nacional could change the rules or
add new rules. As circumstances changed, the Ranfla Nacional made changes to the rules. For
example, after law enforcement in the United States began to use MS-13 tattoos as evidence
against MS-13 members at trial, the Ranfla Nacional changed the rules to restrict members from
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14. A central theme of the rules was the requirement ofloyalty to MS-13, or
to the "barrio." The requirement for loyalty was central to all aspects of life for MS-13
m~mbers. Members who disobeyed the rules, showed disloyalty to the gang or ·to its leaders,
cooperated with law enforcement or disrespected other members were subject to severe
Eastern District of New York, and elsewhere engaged in criminal activity to finance MS-13
legitimate and illegitimate.· This extortion was known as paying "rent" to MS-13, and was a
16. MS-13 also engaged in drug trafficking to earn money to support its
operations. MS-13 members and cliques trafficked in marijuana, cocaine, heroin and
methamphetamine in El Salvador, the United States, including in the Eastern District of New
York, and elsewhere. Proceeds from drug trafficking were collected by MS-13 leaders to
support gang activities, including purchasing weapons in ·El Salvador and the United States.
Drug trafficking proceeds were also sent by wire transfer from members and cliques in the
United State_s to MS-13 in El Salvador, often using non-gang members to send or receive the
were incarcerated, but continued to manage the activities ofMS-13 in El Salvador and the United
States through the use of contraband cellular telephones, the smuggling of written messages
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known as "wilas" out of prisons, intermediaries and the organizational structure of subordinate
leaders .. The Ranfla Nacional established the organizational structure, in part, to ensure its
ability to maintain control ofMS-13 when Ranfla Nacional members were incarcerated and
The Role of the Ranfla Nacional in the United States and the Eastern District ofNew York
18. The Ranfla Nacional exercised control over the activities of MS-13 in the
United States, including in the Eastern District of New York. The actions of MS-13 cliques and
members in the United States were regulated by the rules and organizational structure put in ,
place by the Ranfla Nacional. The rules issued by the Ranfla Nacio~al controlled the process for
recruitment of new members and advancement to higher ranks for members in the United States.
The Ranfla Nacional required MS-13 members to 9btain the approval of the Ranfla Nacional
prior to immigrating to the United States. Certain murders in the United States by members of
MS-13, including the murder ofMS-13 members suspected of cooperating with law enforcement
or otherwise violating the rules ofMS-13, required the approval of the Ranfla Nacional. Cliques
in the United States were also required to send money from dues and proceeds of drug
trafficking, extortion and other criminal activity to MS-13 in El Salvador. In order to exert
gre3:ter control over the operation of cliques in the United States, the Ranfla Nacional sent
trusted, subordinate leaders to the United States to manage the activities of cliques and enforce
19. MS-13 established multiple cliques in the Eastern District ofNew York.
Members of these cliques operated under the rules and followed orders issued by the Ranfla I
Nacional in El Salvador. The Ranfla Nacional resolved disputes between cliques in the Eastern
District of New Yark. In accordance with the rules and orders issued by the Ranfla Nacional,
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members of these cliques committed multiple acts of violence in the Eastern District of New
York, including murders, attempted murders, assaults and kidnappings; trafficked drugs in the
Eastern District of New York and sent proceeds back to MS-13 in El Salvador; engaged in
extortion of individuals and businesses in the Eastern District of New York; and sent dues and
the proceeds of criminal activity by wire transfer from the Eastern District of New York to MS-
13 in El Salvador.
Expansion to Mexico
20. The Ranfla Nacional directed the expansion ofMS-13 activities into
Mexico and sent several high-ranking leaders to Mexico to organize operations there. In
Mexico, MS-13 leaders made connections to obtain narcotics and firearms, conducted business
with Mexican drug cartels such as the Zetas, Gulf Cartel, Jalisco New Generation Cartel
("CJNG") and Sinaloa Cartel, and engaged in human trafficking and smuggling.
21. The Ranfla Nacional had the power to approve a "green light" on anyone
it chose. A "green light" was an order to murder the subject of the "green light." The Ranfla
Nacional approved "green lights" on rival gang members, law enforcement officers, military
members, government officials, witnesses, MS-13 members who cooperated with law
enforcement, MS-13 members who appeared to be challenging the leadership of the Ranfla
Nacional, MS-13 members who disobeyed the rules and anyone it felt ha~ disrespected them or
MS-13. The Ranfla Nacional could order a "green light" on individuals or on a group. For
example, in approximately 2004, the Ranfla Nacional ordered a "green light" on all members of
the Coronados clique due to a dispute between the Coronados and other cliques. The "green
light'~ applied to specific.leaders and to all members of the clique who did notjoin other cliques.
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22. In addition to ordering a "green light" to kill a specific person, the Ranfla
rivals, law enforcement cooperators, police officers, witnesses, violators of MS-13 rules and
anyone else believed to be worthy of death. The Ranfla Nacional called this '~opening the
valves." Only the Ranfla Nacional could order the "opening of the valves," to generally
authorize members to commit murders. Orders to "open the valves" were ·also transmitted and
applied to members in the United States. When the Ranfla Nacional determined that it was no
longer in its interest to_ authorize murder generally, "the valves were closed" on the Ranfla
Nacional's order. The purposes of"opening the valves" were to cause fear and intimidation, to
23. The Ranfla Nacional gained political influence as a result of the violence
and intimidation MS-13 exerted on the government and population of El Salvador. Through
extortion and violence, MS-13 controlled large parts of El Salvador's economy, particularly the
mass transportation industry. Through control of the level of violence, the Ranfla Nacional
exercised leverage over the government of El Salvador. In approximately 2012, the Ranfla
Nacional engaged in secret negotiations with members of the ruling Farabundo Marti National
Liberation Fr~nt ("FMLN") party of El Salvador, and MS-13 's principal rival, the 18th Street, to
. enter into a "truce" to reduce homicides in El Salvador in exchange for improved prison.
conditions, benefits and money. Ultimately, the leaders of the Ranfla Nacional agreed to reduce
violence in exchange for prisoner transfers to a less secure prison, increased benefits such as
conjugal visits and cash payments. The Ranfla Nacional also negotiated with the FMLN and its
rival political party, the Alianza Republicana Nacionalista ("ARENA"), to provide votes to
11
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political candidates in exchange for benefits for MS-13 and the members of the Ranfla Nacional
themselves. From approximately 2012 until approximately 2015, the Ranfla Nacional directed
that MS-13 should reduce homicides in El Salvador. In exchange, the Ranfla Nacional received
improved prison conditions, benefits for MS-13 and cash payments. ·However, in approximately
2015 the "truce" collapsed and-was terminated. The Ranfla N_acional blamed the end of the
"truce" on the United States, believing that the United States government pressured the
government of El Salvador to end the "truce" as a condition of receiving funds from the United
States.
24. After the end of the "truce," the government of El Salvador moved several
of the defendants back to more secure prisons with harsher conditions. In retaliation, and in an
effort to force the government of El Salvador to enter into new negotiations, the Ranfla Nacional _
violence and murders, especially of police officers and government officials. Because they
. . .
believed that the United States government was to blame for the collapse of the "truce," the
Ranfla Nacional- directed MS-13 leaders in the United States to increase violence in the United
States.
25. In early 2016, the Ranfla Nacional began planning for a major campaign
of coordinated violence in El Salvador in retaliation for the harsher measures imposed on its
members after the end of the truce. All cliques in El Salvador were ordered to provide two
members to create a specialized unit of MS-13 members to be used to attack the police. These
members were to undergo military training at MS-13 military training camps in El Salva~or. All
cliques, including those in the Eastern District of New York and elsewhere in the United States,
were ordered to provide all of their profits from select months for a special collection to be used
12
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to purchase weapons for the planned attacks on ·police in El Salvador. These weapons included
machine guns, grenades, IEDs and rocket launchers. Over $600,000 was collected for this fund,
and MS-13 began purchasing weapons. Cliques in El Salvador were directed to identify the
names and addresses of police officers, military members and government officials in their areas
Salvador and to use its control of the level of violence to influence the actions of the government
in El Salvador.
Special Designations
27. On July 24, 2011, United States President Barack Obama issued Executive
Order 13581, which declared a national emergency with respect to the activities of significant
transnational criminal organizations. Executive Order 13581 was based on a presidential finding.
threat to the national security, foreign policy, and economy of the United States." Executive
Order 13581 applied to specific significant transnational criminal organizations named in the
annex to the order and to any person or entity designated by the Secretary of the Treasury as a
significant transnational criminal organization. Among other things, Executive Order 13581
prohibited transactions by United States persons or involving United States property with
28. On October 11, 2012, the Secretary of the Treasury designated MS-13 as a
13
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defendants HENRIQUEZ and TURCIOS, members of the Ranfla Nacional, as leaders ofMS-13
of the Ranfla Nacional, as leaders ofMS-13 subject to the sanctions imposed by Executive Order
13581.
31. On August 24, 2015, the Supreme Court of El Salvador designated MS-13
The Defendants
"Diablito de Hollywood," was a member of MS-13, was an original member of the Twelve
Hollywood," was a member ofMS-13, was an original member of the Twelve Apostles of the
34. The defendant EFRAIN CORTEZ, also known as "Tigre de Park View"
and "Viejo Tigre de Park View," was a member ofMS-13 and was a member of the Ranfla
Nacional.
Leewards" and "Mousey de Leewards," was a member of MS-13, was an original member of the
Twelve Apostles of the Devil and was a member of the Ranfla Nacional.
14
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de Western"· and "Mustage de Western," was a member ofMS-13, was an original member o·f
the Twelve Apostles of the.Devil and was a member ofthe Ranfla Nacional.
de Park View," was a member ofMS-13, was an original member of the Twelve Apostles of the
"Cola de Western," was a-member ofMS-13 and was a memb~r of the Ranfla Nacion~/.
"Lucky de Park View" and "Lacky de Park View," was a member ofMS-13 and was a member
Necio de San C9cos," was a member ofMS-13, was an original member of the Twelve Apostles
"El Grenas de Stoners" and "Oso de Stoners," was a member ofMS-13, was an original member
of the Twelve Apostles of the Devil and was a member of the Ranfla Nacional.
"Pavas de 7-11" and "Viejo Pavas de 7-11," was a member ofMS-13, was an original member
of the Twelve Apostles of the Devil and was a member of the Ranfla Nacional.
· known as "Flaco de Francis," was a member ofMS-13, was an original member of the Twelve
15
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Teclas," was a member ofMS-13, was an original member of the Twelve Apostles of the Devil
de Teclas," was a member ofMS-13 and was a member of the Ranfla Nacional.
46. The overall purpose ofthe Ranfla Nacional was to direct-the criminal
activities ofMS-13 in El Salvador, the United States, including in the Eastern District ofNew
reputation ofMS-:13 in El Salvador, the United States, including the Eastern District of New
York, and elsewhere through the use of violence, threats of violence and intimidation;
the purpose of obtaining benefits in return when members of such parties took office;
Salvador, the United States, including the Eastern District ofNew York, and elsewhere that MS-
and associates in El Salvador, the United States, including the Eastern District of New York, and
16
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elsewhere by committing crimes, including, but not limited to, murder, attempted murder,
members of law enforcement in El Salvador, the United States, including the Eastern District of
New York, and elsewhere in fear ofMS-13 and its members through violence, threats of
United States, including the Eastern District of New York, and elsewhere through the use ·of
believed to be cooperating with law enforcement authorities in El Salvador, the United States,
apprehend and successfully prosecute offending MS-13 members in El Salvador, the United
incarcerated MS-13 members in El Salvador, the United· States, including the Eastern District of
criminal activities, including extortion and drug trafficking, from members and cliques in El
Salvador, the United States, including the Eastern District of New York, and elsewhere.
17
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47. In order to carry out the aforementioned goals, the Ranfla Nacional,
together with other members ofMS-13, within El Salvador, the United States, including in the
Eastern District of New York, and elsewhere, used a variety of manner and means, including the
following:
members in El Salvador, the United States, including the Eastern District ofNew York, and
elsewhere were re.quired to follow. The rules included procedures for investigating violations of
the rules and punishments for violators that included beatings and death;
government of El Salvador, including police officers, military members, and other government
officials, and their families, in retaliation for taking actions against MS-13;
States, including murders, in retaliation for what it believed was the role of the United States
· Investigation special agent assigned to official duties in El Salvador .on account of the special
authorization from the Ranfla _Nacional to commit murders in El Salvador, the United States,
called "opening the valves," to MS-13 members in El Salvador, the United States, including the
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Eastern District of New York, and elsewhere to commit murders of rival gang members,
members of law enforcement, individuals cooperating with law enforcement and others in
specific murders in El Salvador, the United States, including the Eastern District ofNew York,
Salvador, the United States, including the Eastern District of New York, and elsewhere;
Salvador to obtain benefits and concessions for itself and for MS-13 members;
its image, make demands of the government of El Salvador, issue threats and publicize acts of
violence to intimidate the police and civilian population of areas under its control;
clique, including cliques in the Eastern District_ of New York and elsewhere in the United States,
to be used to fund the purchase of weapons, including machine guns, handguns, grenades, IEDs
and body armor to be used to attack police, military and· government officials in El Salvador, in
MS-13 members to be trained in military tactics and the use of military-grade weapons;
contraband cellular telephones illegally smuggled into jails and prisons, and encrypted
19
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activities ofMS-13 in EI Salvador, the United States, including the Eastern District of New
prison when the conditions of the prison made it impossible for the Ranfla Nacional to
communicate directly with members outside of prison, including using co-conspirators to create
United States, including in the Eastern District of New York, to pay dues, often the proceeds of
drug trafficking and extortions, to send to MS-13 leadership in El Salvador to provide financial
support for MS-13, including for the purchase of weapons for use in committing acts of violence
in El Salvaqor;
entities in El Salvador, the United States, including the Eastern District of New York, and
elsewhere;
members to engage in drug trafficking to earn money to support the activities of MS-13 and
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memb~rs to send and receive funds such as dues payments from members and cliques in the
United States, including in the Eastern District of New York, to MS-13 in El Salvador in order to
ranflas, zones, Programs and cliques to manage the activities of MS-13 in El Salvador, the
United States, including the Eastern District of New York, and elsewhere. When necessary, the
w. The Ranft.a Nacional issued rules and created a rank structure for
controlling the recruitment of new members and their advancement within MS-13;
to the United States to manage and improve MS-·13 operations in the United States, often
to Mexico to develop and manage MS-13 operations in Mexico related to drug trafficking,
21
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to intimidate the local civilian population in El Salvador, to influence the civilian population to
vote for political parties associated with MS-13, to influence the actions of the government of El
Salvador, to retaliate against government actions, to attempt to force the government to negotiate
COUNT ONE
(Conspiracy to Provide and Conceal Material Support and Resources to Terrorists)
49. In or about and between 2002 and the date of this Indictment, both dates
being approximate and inclusive, within the Eastern District of New York, El Salvador, and
CORTEZ, also known as "Tigre de Park View" and "Viejo Tigre de Park View," RICARDO
ALBERTO DIAZ, also known as "Rata de Leewards" and "Mousey de Leewards," EDUARDO
SACHARY EUFEMIA, also known as "Speedy de Park View," JOSE FERNANDEZ FLORES-
CUBAS, also known as "Cola de Western," FREDY IVAN JANDRES-PARADA, also known
as "Lucky de Park View" and "Lacky de Park View," LEONEL ALEXANDER LEONARDO,
also known as "El Necio de San Cocos," CESAR HUMBERTO LOPEZ-LARIOS, also known
as "El Grenas de Stoners" and "Oso de Stoners," JOSE LUIS MENDOZA-FIGUEROA, also
known as "Pavas de 7-11" and "Viejo Pavas de 7-11," HUGO ARMANDO QUINTEROS-
MINEROS, also known as "Flaco de Francis," SAUL ANTONIO TURCIOS, also known as
•
"Trece de Teclas," and ARISTIDES DIONISIO UMANZOR, also known as "Sirra de Teclas-,''
22
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together with others, did ~owingly and intent_ionally combine, conspire, confederate and agree
with each other and o~ers known and unknown to the Grand Jury, to provide material support
and re~ources, and to conceal and disguise the nature, location, source and ownership of material
support and resources, including, but not limited to, personnel, including themselves, currency
and monetary instruments, training, weapons, explosives and services, knowing and intending
that they were to be used in preparation for, and in carrying out, violations of Title 18, United
States Code, Section 956(a)(l) (conspiracy to kill or maim persons outside the United States);
Title 18, United States Code, Sections 1114( I) (killing or attempting to kill an officer or
employee of the United States); Title 18, Uniteq States Code, Section 2332(b) (conspiracy to kill
United States nationals); Title 18, United States Code, Section 2332b (acts of terrorism
transcending national boundaries); and Title 21, United States Code, Section 960a (narco-
(Title 18, United States Code, Sections 2339A(a) and 3551 et seq.)
COUNTTWO
(Conspiracy to Commit Acts of Terrorism Transcending National Boundaries)
50. The allegations contained in paragraphs one through 47 are realleged and
51. In or about and between 2002 and the date of this Indictment, both dates
being approximate and inclusive, within the Eastern District of New York, El Salvador, and
"Tigre de Park View" and "Viejo Tigre de Park View," RICARDO ALBERTO DIAZ, also
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also known as "Cola de Western," FREDY IVAN JANDRES-PARADA, also known as "Lucky
de Park View" and "Lacky de Park View," LEONEL ALEXANDER LEONARDO, also known
as "El Necio•de San Cocos," CESAR HUMBERTO LOPEZ-LARIOS, also known as "El Grenas
de Stoners" and "Oso de Stoners," JOSE LUIS MENDOZA-FIGUEROA, also known as "Pavas
known as "Flaco de Francis," SAUL ANTONIO TURCIOS, also known as "Trece de Teclas,"
and ARISTII)ES DIONISIO UMANZOR, also known as "Sirra de Teclas," together with others,
did knowingly and intentionally combine, conspire, confederate and agree with each other and
others known and unknown to the Grand Jury, to kill, kidnap, maim, commit assaults resulting in ·
serious bodily injury and assault with a dangerous weapon any person within the United States in
violation of the laws of any State, and the death of one or more persons resulted.
52. In engaging ~ the unlawful conspiracy set forth in this Count, at least one
of the following circumstances is applicable to· at least one offender: ( 1) a facility of interstate
and foreign commerce, including, but not limited to, a cellular telephone, tablet computer and
Internet-based social media accounts, was used in furtherance of the offense; and (2) the offense
obstructed, delayed and affected interstate and foreign commerce, and would have affected
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COUNT THREE
(Conspiracy to Finance Terrorism)
53. The allegations contained in paragraphs one through 47 are realleged and
54. In or about and between 2002 and the date of this Indictment, both dates
being approximate and inclusive, within the Eastern District of New York, El Salvador, and
CORTEZ, also known as "Tigre de Park View" and "Viejo Tigre de Park View," RICARDO
ALBERTO DIAZ, also known as "Rata de Leewards" and "Mousey de Leewards," EDUARDO
SACHARY EUFEMIA, also known as "Speedy dt: Park View," JOSE FERNANDEZ FLORES-
CUBAS, also known as "Cola de Western," FREDY IVAN JANDRES-PARADA, also known
as "Lucky de Park View" and "Lacky de Park View," LEONEL ALEXANDER LEONARDO,
also known as "El Necio de San Cocos," CESAR HUMBERTO LOPEZ-LARIOS, also known
as "El Grenas de Stoners" and "Oso de Stoners," JOSE LUIS MENDOZA-FIGUEROA, also
known as "Pavas de 7-11" and "Viejo Pavas de 7-11," HUGO ARMANDO QUINTEROS-
MINEROS, also known as "Flaco de Francis," SAUL ANTONIO TURCIOS, also known as
"Trece de Teclas," and ARISTIDES DIONISIO UMANZOR, also kriown as "Sirra de Teclas,"
together with others, did knowingly and intentionally combine, conspire; confederate and agree
with each other and others known and unknown to the Grand Jury to unlawfully and willfully
provide and collect funds, by any means, directly and indirectly, with the intention that such
funds be used, and with the knowledge that such funds were to be used, in full or in part, in order
to carry out any act intended to cause death and serious bodily injury to a civilian, and to any
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other person not taking an active part in hostilities in a situation of armed conflict, when the
purpose of such act, by its nature and context, was to intimidate a population, and to compel a
(Title 18, United States Code, Sections 2339C(a)(l)(B), 2339C(a)(2) and ~551 et
COUNTFOUR
(Narco-Terr~rism Conspiracy)
56. In or about and between 2002 and the date of this Indictment, both dates
being approximate and inclusive, within the Eastern District of New York, El Salvador, and
CORTEZ, also known as "Tigre de Park View" and "Viejo Tigre de Park View," RICARDO
ALBERTO DIAZ, also known as "Rata de Leewards" and "Mousey de Leewards," EDUARDO
SACHARY EUFEMIA, also known as "Speedy de Park View," JOSE FERNANDEZ FLORES-
CUBAS, also known as "Cola de Western," FREDY IVAN JANDRES-PARADA, also known
as "Lucky de Park View" and "Lacky de Park View," LEONEL ALEXANDER LEONARDO,
also known as "El Necio de San Cocos," CESAR HUMBERTO LOPEZ-LARIOS, also known
as "El Grenas de Stoners" and "Oso de Stoners," JOSE LUIS MENDOZA-FIGUEROA, also
~own as "Pavas de 7-11" and "Viejo Pavas de 7-11," HUGO ARMANDO QUINTEROS-
MINEROS, also known as "Flaco de Francis," SAUL ANTONIO TURCIOS, also known as
"Trece de Teclas," and ARISTIDES DIONISIO UMANZOR, also known as "Sirra de Teclas,"
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together with others, did knowingly and intentionally combine, conspire, confederate and agree
. with each other and others known and unknown to the Grand Jury, to engage in conduct that
would be punishable under Title 21, United States Code, Section 841(a), if committed within the
jurisdiction of the United States, that is to knowingly and intentionally distribute and possess
with intent to distribute marijuana, cocaine, heroin, methamphetamine and other controlled
substances, knowing and intending to provide, directly and indirectly, anything of pecuniary
value to any person and organization, to wit: MS-13, that has engaged and engages in terrorist
activity as defined in Title 8, United States Code, Section l 182(a)(3)(B), and terrorism as
(Title 21, United States Code, Section 960a(a); Title 18, United States Code,
57. The United States hereby gives notice to the defendants charged in Counts
One through Three that, upon their conviction of any such offenses, the government will seek
forfeiture in accordance with: (a) Title 18, United States Code, Section 981(a)(l)(C) and Title
28, United States Code, Section 2461 (c), which require any person convicted of such offenses to
forfeit any property, real or personal, constituting, or derived from, proceeds obtained directly or
indirectly as a result of such offenses; and (b) Title 18, United States Code, Section 98l(a)(l)(G)
and Title 28, United States Code, Section 2461 (c), which require the forfeiture of all assets,
perpetrating any Federal crime of terrorism (as defined in Title 18, United States Code, Section
2332b(g)(5)) against the United States, citizens or residents of the United States or their property,
and all assets, foreign or domestic, affording any person a source of influence over any such
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entity or organization; (ii) acquired or maintained by any person with the intent and for the
purpose of supporting, planning, conducting or concealing any Federal crime of terrorism (as
defined in Title 18, United States Code, Section 2332b(g)(5)) against the United States, citizens
or residents of the United States or their property; (iii) derived from, involved in or used or
intended to be used to commit any Federal crime of terrorism (as defined in Title 18, United
States Code, Section 2332b(g)(5)) against the United States, citizens or residents of the United
States or their property; or (iv) of any individual, entity or organization engaged in planning or
perpetrating any act of international terrorism (as defined in Title 18, United States Code,
Section 2331) against any international organization (as defined in.Title 22, United States Code,
(b) has been tran~ferred or sold to, or deposited with, a third party;
(e) has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendants up to the value of the forfeitable property
(Title 18, United States Code, Sections 981(a)(l)(C) and 98l(a)(l)(G); Title 21,
United States Code, Section 853(p); Title 28, United States Code, Section 246l(c))
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59. The United States hereby gives notice to the d~fendants charged in Count
Four that, upon their conviction of such offense, the government will seek forfeiture in
accordance with: (a) Title 21, United States Code, Sections 853(a) and 970, which require any
person convicted of such offense to forfeit (i) any property constituting, or derived from, any
proceeds obtained directly or indirectly as the result of such offense; and (ii) any property used,
or intended to be used, in any manner or part, to commit, or to facilitate the commission of, such
offense; and (b) Title 18, United States Code, Section 981(a)(l)(G) and Title 28, United States
Code, Section 2461 (c), which require the forf~iture of all assets, foreign or domestic, (i) of any
terrorism (as defined in Title 18, United States Code, Section 2332b(g)(5)) against the United
States, citizens or residents of the United States or their property, and all assets, foreign or
domestic, affording any person a source of influence over any such entity or organization;
(ii) acquired or maintained by any person with the intent and for the purpose of supporting,
planning, conducting or concealing any Federal crime of terrorism (as defined in Title 18, United
States Code, Section 2332b(g)(5)) against the United States, citizens or residents of.the United
States or the~r property; (iii) derived from, involved in, or used or intended to be used.to commit
any Federal crime of terrorism (as defined in Title 18, United States Code, Section 2332b(g)(5))
against the United States, citizens or residents of the United States or their property; or (iv) of
international terrorism (as defined in Title 18, United States Code, Section 2331) against any
international organization (as defined in Title 22, United States Code, Section 4309(b)) or
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(b) has ~een transferred or sold to, or deposited with, a third party;
(e) has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendants up to the value of the forfeitab~e property
(Title 18, United States Code, Section 98l(a)(l)(G); Title 21, United States
Code, Sections 853(a), 853(p) and 970; Title 28, Umted States Code, Section 246l(c))
A TRUE BILL
SETH D. DUCHARME
ACTING UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW ·voRK
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F.#: 2020R00632
FORMDBD-34 No.
JUN. 85
CRIMINAL DIVISION
Defendants.
INDICTMENT
(T. 18, U.S.C., §§ 981(a)(l)(C), 981(a)(l)(G), 2332b(a)(l)(A),
2332b(a)(2), 2332b(b)(l)(A), 2332b(b)(l)(B), 2332b(c), 2339A(a),
2339C(a)(l)(B), 2339C(a)(2), and 3551 et seq.; T. 21, U.S.C., §§ 853(a),
853(p), 960a(a), and 970); T. 28, U.S.C., § 2461(c))
A true bill, - - - - - - - - - - - ~ - ~ - - - - - - -
Foreperson
Clerk
Bail,$ __________ _