JASON DAVIS, ) aka Lil G Red, ) aka G-Thang, ) LEO RICKEY EVANS, ) aka Lemon Head, ) aka Paper, ) ROBBIONTA MONSON, ) aka Lil Rob, ) aka Fred, )

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1 1 1 1 UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA February Grand Jury UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) GARY WHITE, ) aka JC, ) aka Big J-Killa ) aka Big Killa, ) KEVIN ELEBY, ) aka L, ) LEE HENDERSON, ) aka Lee-Dog, ) LAVERT LITTLETON, ) aka Weedamac, ) aka Pee Wee, ) aka Chili Sauce, ) JERMAINE HARDIMAN, ) aka J-Killa, ) LESCO WOOTEN, ) aka Too Tall, ) aka D-Bo, ) JOHN JAMAR TERRELL, ) aka G-Sta, ) LYNN MCGRUDER, ) aka Sweets, ) aka PZ, ) aka Pony Loc, ) ANTHONY HILL, ) aka Dr. Dirt, ) aka Dirt, ) STEVEN WILLIAMS, ) aka Baby Ben, ) aka Brazy, ) aka Little Stevie, ) CR No. I N D I C T M E N T [ U.S.C. (d): Conspiracy to Engage in Racketeering Activity; U.S.C. : Violent Crimes in Aid of Racketeering; U.S.C. : Conspiracy to Distribute Cocaine, Cocaine Base in the Form of Crack Cocaine, Heroin, and Marijuana; U.S.C. (c)(1): Use and Carry a Firearm During and In Relation to, and Possess a Firearm in Furtherance of, a Crime of Violence and a Drug Trafficking Crime; U.S.C. 0: Distribution and Manufacturing of Narcotics in and Near Schools, Playgrounds, and Public Housing Facilities; U.S.C. (a)(1): Maintaining a Drug-Involved Premises; U.S.C. 1(a)(1), 1(b)(1)(C): Distribution and Possession with Intent to Distribute Heroin, Cocaine, and Cocaine Base in the Form of Crack Cocaine]

2 1 1 1 JASON DAVIS, ) aka Lil G Red, ) aka G-Thang, ) LEO RICKEY EVANS, ) aka Lemon Head, ) aka Paper, ) ROBBIONTA MONSON, ) aka Lil Rob, ) aka Fred, ) STEPHEN PATTERSON, ) aka Lil KO, ) aka KO, ) PHILLIP GILLIARD, ) aka Big Phil, ) BRETT BAILEY, ) aka BJ, ) DEON DANIELS, ) aka D, ) aka Railroad, ) aka S-Man, ) CEDRIC CARTER, ) aka Big Sexy, ) JOSE LEON, ) aka Beto, ) LUIS ESPINOZA, ) aka Pelon, ) KEYMONT HOOD, ) aka Keymonty, ) HERMAN NIXON, ) aka Money Moe, ) CARLOS IVAN MUNOZ, ) aka Big Bird, ) DAWAYNE HAROLD WHITE, ) aka Wayne-Wayne, ) TROY KENSEY, ) aka Big Droop, ) DEON BULLOCK, ) aka Bo, ) aka Bogart, ) WILLIAM REED, ) aka No-Kutt, ) DERRICK RAY SEXTON, ) aka Crazy, ) aka Ball, ) JK GRAY, ) aka Lil Money, ) ANTHONY GABOUREL, ) aka Bandit, ) RONDALE YOUNG, ) aka Devil, ) aka P-Grump, ) JUSTIN MOORE, ) aka Crispy Strips, ) RODNEY BOUGERIOUS, ) aka Boxer, ) NICOLE WILLIAMS, )

3 1 1 1 JASON HANFORD, ) aka Fish, ) JOSEFINA VARGAS-LEON, ) BRUCE HOWARD, ) aka BR, ) DARRIN DENT, ) aka Bo, ) JOSE PORTILLO, ) aka Cuco, ) NATALIE PORTILLO, and ) TINA MARIE EPPS, ) aka Tina Tresevant, ) ) Defendants. ) )

4 1 1 1 The Grand Jury charges: GENERAL ALLEGATIONS A. The Enterprise 1. At all times relevant to this indictment, defendants GARY WHITE, also known as ( aka ) JC, aka Big J-Killa, aka Big Killa ( G. WHITE ); KEVIN ELEBY, aka L ( ELEBY ); LEE HENDERSON, aka Lee-Dog ( HENDERSON ); LAVERT LITTLETON, aka Weedamac, aka Pee Wee, aka Chili Sauce ( LITTLETON ); JERMAINE HARDIMAN, aka J-Killa ( HARDIMAN ); LESCO WOOTEN, aka Too Tall, aka D-Bo ( WOOTEN ); JOHN JAMAR TERRELL, aka G-Sta ( TERRELL ); LYNN MCGRUDER, aka Sweets, aka PZ, aka Pony Loc ( MCGRUDER ); ANTHONY HILL, aka Dr. Dirt, aka Dirt ( HILL ); STEVEN WILLIAMS, aka Baby Ben, aka Brazy, aka Little Stevie ( S. WILLIAMS ); JASON DAVIS, aka Lil G Red, aka G-Thang ( DAVIS ); LEO RICKEY EVANS, aka Lemon Head, aka Paper ( EVANS ); ROBBIONTA MONSON, aka Lil Rob, aka Fred ( MONSON ); STEPHEN PATTERSON, aka Lil KO, aka KO ( PATTERSON ); PHILLIP GILLIARD, aka Big Phil ( GILLIARD ); BRETT BAILEY, aka BJ ( BAILEY ); DEON DANIELS, aka D, aka Railroad, aka S-Man ( DANIELS ); CEDRIC CARTER, aka Big Sexy ( CARTER ); JOSE LEON, aka Beto ( JOSE LEON ); LUIS ESPINOZA, aka Pelon ( ESPINOZA ); CARLOS IVAN MUNOZ, aka Big Bird ( MUNOZ ); DAWAYNE HAROLD WHITE, aka Wayne-Wayne ( D. WHITE ); TROY KENSEY, aka Big Droop ( KENSEY ); DEON BULLOCK, aka Bo, aka Bogart ( BULLOCK ); DERRICK RAY SEXTON, aka Crazy, aka Ball ( SEXTON ); JK GRAY, aka Lil Money ( GRAY ); ANTHONY GABOUREL, aka Bandit ( GABOUREL ); RONDALE YOUNG, aka Devil, aka P-Grump ( YOUNG ); JUSTIN MOORE, aka

5 1 1 1 Crispy Strips ( MOORE ); RODNEY BOUGERIOUS, aka Boxer ( BOUGERIOUS ); and JASON HANFORD, aka Fish ( HANFORD ) (collectively, defendants ), and others known and unknown to the Grand Jury, were members and associates of an organization engaged in, among other things, conspiracy to traffic in narcotics and controlled substances, murder, conspiracy to commit murder, attempted murder, robbery, extortion, and witness intimidation. This organization, known alternately as the Pueblo Bishops Bloods, the - Pueblo Bishops, and the Five- Deuce Pueblo Bishops (hereinafter referred to as the Pueblo Bishops or PBB ), operated in the Central District of California and elsewhere. The Pueblo Bishops, including its leaders, members, and associates, constituted an enterprise, as defined by Title, United States Code, Section 1(), that is, a group of individuals associated in fact. The Pueblo Bishops engaged in, and its activities affected, interstate and foreign commerce. The Pueblo Bishops constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise.. The Pueblo Bishops gang is a multi-generational street gang that was formed in the mid 0s and claims the area roughly between 1st Street to the north, Slauson Avenue to the south, Alameda Avenue to the east, and Compton Avenue to the west in South Los Angeles, California. Located within this geographical area is the Pueblo Del Rio Housing Project. (The area immediately in and around this housing complex, which is contained within 1st Street to the north, th Street to the south, Compton Avenue to the west, and Alameda to the east, is

6 1 1 1 hereinafter referred to as the PDRHP ). The Pueblo Bishops gang has approximately 00 active members and associates.. The PDRHP is a public housing complex that is maintained by the Housing Authority of the City of Los Angeles and funded by moneys from the United States Department of Housing and Urban Development. The complex includes approximately 0 units, including a pre-school, elementary school, and playground.. The PDRHP is also the central location for the Pueblo Bishops criminal activities. The Pueblo Bishops dominate the PDRHP, and use it as a central location within which to congregate and from which to sell drugs and firearms, and engage in robberies and violence throughout the surrounding neighborhood. The Pueblo Bishops maintain strict control of the PDRHP by attacking and threatening rival gang members who enter the PDRHP or surrounding area; intimidating and threatening residents of the PDRHP; confronting and attacking law enforcement officers who patrol or respond to calls in the PDRHP; using graffiti, gang signs, and gang paraphernalia within the PDRHP; and maintaining a highly visible and intimidating presence within the PDRHP. Senior members of the Pueblo Bishops exhort younger members to possess and carry firearms, and to violently and swiftly retaliate against rival gang members who venture into the PDRHP without the PBB gang s permission.1. The Pueblo Bishops gang was initially formed, at least in part, as a way to protect its members from other gangs in South Los Angeles. Over the years, this purpose has grown in scope, so that the core objective of protecting the PDRHP has changed to encompass, among other things, drug trafficking, gun

7 1 1 1 trafficking, armed robbery, extortion, and murder.. Members of the Pueblo Bishops are organized into two main groups -- the original gangstas, or the OGs, and the young gangstas, or the YGs. OGs and senior YGs control the business of the gang by imposing mandates on young members. OGs and senior YGs also control the gang by ordering the gang s members to participate in armed robberies and murders, supplying Pueblo Bishops gang members with narcotics for resale, instructing Pueblo Bishops gang members on how to avoid police detection, instructing Pueblo Bishops gang members on how to arm themselves and defend their territory in and around the PDRHP, and determining who can become members of the Pueblo Bishops.. The Pueblo Bishops gang is generally only open to membership by African-American males. Young men who seek to become members of the gang must first put in work, by conducting violent and drug-related reputation-building acts before being invited into membership. Once a prospective member is deemed qualified to join the gang, the prospect must be jumped in by other Pueblo Bishops members. This will generally involve ordering the prospective member to fight one or more already-initiated PBB members for a set period of time.. The Pueblo Bishops hold an important annual celebration on May, known as Five-Deuce Day (in reference to nd Street, a symbolic thoroughfare within the gang s territory). Members are required to attend Five-Deuce Day, and risk severe discipline, in the form of beatings or theft, and/or the loss of gang status, if they do not attend. At Five-Deuce Day celebrations, members engage in gang activities like jumping-in

8 1 1 1 new members, recognizing deceased/incarcerated members, placing graffiti in and around the PDRHP, and disparaging rival gangs. Outside of Five-Deuce Day, members of the Pueblo Bishops are also required to attend ad hoc meetings called by OGs and senior YGs.. All active members of the Pueblo Bishops gang engage in either armed robbery or in drug trafficking, or both. Those who engage in drug trafficking purchase cocaine, which they later convert into cocaine base in the form of crack cocaine ( crack cocaine ), and heroin from other gang members who have drug trafficking connections. Pueblo Bishops members generally sell drugs to addicts who visit the parking lots within the PDRHP. Members of the gang do not allow non-members and non-associates of the gang to sell drugs within the PDRHP, and will violently punish those who attempt to do so. Those members who engage in armed robbery use guns to take property from nearby residents and pedestrians, stores, and banks. OGs and senior YGs encourage gun use and possession in order to facilitate these activities as well as to protect PBB gang territory.. Pueblo Bishops gang members generally identify one another through the use of hand gestures, or gang "signs." They typically display the letter "P" for Pueblo, by making a fist, and then point their thumb down, and a letter "B" for Bishops, by making a circle with the index finger and thumb of their other hand, with the remainder of their fingers pointing straight up completing the letter "B." Gang members frequently wear the baseball cap of the Philadelphia Phillies, whose team insignia includes a "P," for Pueblo, and whose color is red, for "Bloods." Gang members also wear the baseball cap of the Pittsburgh

9 1 1 1 Pirates, whose team insignia includes a "P" for Pueblo. Gang tattoos, gang names, and slogans are also used to identify members and territory controlled by the gang.. The Pueblo Bishops use spray-painted "tagging" to demonstrate control of their neighborhood to rival gang members and the local community. Pueblo Bishops tagging is evident throughout the area in and around the PDRHP. Members will use the letters "PBB" for Pueblo Bishop Bloods and "PB" for Five Deuce Pueblo Bishops. Members are also known to tag letters and numbers of rival gangs, and then cross them out, in a show of disrespect to the rival gang. Members do this to issue challenges to rival gang members and to communicate among Pueblo Bishops gang members. Members generally engage in tagging not only to identify territory claimed by the Pueblo Bishops gang, but also to warn and/or terrorize members of the public and law-abiding residents of the neighborhoods with threats that the neighborhood is under control of the Pueblo Bishops gang. 1. The Pueblo Bishops gang does have rivals throughout South Los Angeles, the most prominent of which is the th Street gang. The Pueblo Bishops enemies also include the Swan and Florencia-1 gangs. In an ongoing effort to assert dominance and power over these rival street gangs, Pueblo Bishops members are strongly encouraged to engage in shootings, beatings, murders, and attempted murders directed at members of these rival gangs. B. PURPOSES OF THE ENTERPRISE 1. The purposes of the Pueblo Bishops gang included, but were not limited to, the following: a. Enriching members and associates of the Pueblo

10 1 1 1 Bishops gang through, among other things, the control of and participation in the distribution of narcotics within the PDRHP, as well as through engaging in armed robberies of local citizens, businesses, and banks. b. Maintaining the control and authority of the Pueblo Bishops gang over the PDRHP, often through threats, intimidation, and acts of violence against local residents and rival gangs. c. Promoting and enhancing the Pueblo Bishops gang members and its members and associates activities. d. Exposing and punishing Pueblo Bishops gang members and associates, as well as potential witnesses to crimes committed by Pueblo Bishops gang members, who are suspected of cooperating with law enforcement. e. Violently retaliating against rival gang members who challenge the Pueblo Bishops authority both inside and outside the PDRHP. C. THE MEANS AND METHODS OF THE ENTERPRISE 1. The means and methods by which the defendants and their associates conducted and participated in the conduct of the affairs of the Pueblo Bishops gang included the following: a. Members and associates of the Pueblo Bishops gang committed, attempted, and threatened to commit acts of violence to protect and expand the enterprise s criminal operation, including assaults, murders, acts of intimidation, and threats of violence directed against rival gang members and witnesses in criminal cases, and to violently discipline insubordinate members of the enterprise.

11 1 1 1 b. Members and associates of the Pueblo Bishops gang promoted a climate of fear, particularly among rival gang members and unaffiliated local residents in and near the PDRHP, through acts of violence and threats to commit acts of violence. c. Members and associates of the Pueblo Bishops gang engaged in drug trafficking, gun trafficking, armed robbery, and extortion as a means to generate income.

12 1 1 1 COUNT ONE [ U.S.C. (d)] Paragraphs 1 through 1 of the General Allegations are realleged and incorporated by reference as if fully set forth herein. A. OBJECTS OF THE CONSPIRACY 1. Beginning on a date unknown, and continuing to on or about August,, in Los Angeles County, within the Central District of California, and elsewhere, defendants G. WHITE, ELEBY, HENDERSON, LITTLETON, HARDIMAN, WOOTEN, TERRELL, MCGRUDER, HILL, S. WILLIAMS, DAVIS, EVANS, MONSON, PATTERSON, GILLIARD, BAILEY, DANIELS, CARTER, JOSE LEON, ESPINOZA, MUNOZ, D. WHITE, KENSEY, BULLOCK, SEXTON, GRAY, GABOUREL, YOUNG, MOORE, BOUGERIOUS, and HANFORD, and others known and unknown to the Grand Jury, being persons employed by and associated with the Pueblo Bishops, an enterprise which was engaged in, and the activities of which affected, interstate and foreign commerce, knowingly and intentionally conspired to violate Title, United States Code, Section (c), that is, to conduct and participate, directly and indirectly, in the conduct of the affairs of that enterprise through a pattern of racketeering activity, as that term is defined in Title, United States Code, Sections 1(1) and 1(), consisting of multiple acts chargeable under the following provisions of state law: a. acts involving murder, committed in violation of California Penal Code Sections 1,,,,.1, and ; b. acts involving robbery, committed in violation of 1

13 1 1 1 California Penal Code Sections 1,., and ; and multiple offenses involving c. the distribution of controlled substances and the involvement in a conspiracy to distribute controlled substances, including heroin, cocaine, and crack cocaine, in violation of Title, United States Code, Sections 1(a)(1), 1(b)(1)(A), and ; and multiple acts indictable under the following provisions of federal law: d. the interference of interstate commerce by robbery, committed in violation of Title, United States Code, Section 1; and e. witness tampering, committed in violation of Title, United States Code, Section 1.. It was a further part of the conspiracy that each defendant agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise. 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. Defendants G. WHITE, ELEBY, and HENDERSON, as the Pueblo Bishops active OGs, would convene and preside over PBB meetings in order to discuss the gang's business, would exhort younger members to violently guard the gang's territory against 1

14 1 1 1 rival gangs, would instruct younger gang members to commit narcotics trafficking and firearms-related offenses, and would call for retaliation against rival gangs.. Defendants GRAY, MUNOZ, JOSE LEON, GABOUREL, and YOUNG would commit murder and conspire and attempt to commit murder in order to enhance the violent reputation of the PBB gang, to enhance their status within the gang, and to retaliate against rival gang members.. Defendants HARDIMAN and S. WILLIAMS, as leaders of the YGs, would encourage younger PBB members to engage in violence against rival gang members and participate in armed robberies in order to enhance their status within the gang.. Defendants LITTLETON, TERRELL, EVANS, MONSON, JOSE LEON, ESPINOZA, and HILL would supply controlled substances and firearms to the PBB gang, and would ensure that younger members of the PBB gang had sufficient quantities of controlled substances to sell.. Defendants BAILEY, CARTER, DAVIS, GILLIARD, MOORE, MUNOZ, JOSE LEON, and D. WHITE would sell drugs within the PBB gang's territory, protect the gang's territory by carrying firearms, and use violence against the gang's rivals and enemies, with such violence including attempted murders, acts of intimidation, assaults, and shootings.. Defendants BULLOCK and PATTERSON would sell drugs in PBB gang territory and participate in armed robberies with other members of the gang.. Defendants BOUGERIOUS, DANIELS, HANFORD, KENSEY, MCGRUDER, SEXTON, and WOOTEN would sell drugs within the PBB 1

15 1 1 1 gang's territory and would protect that territory from the gang s rivals. C. OVERT ACTS In furtherance of the conspiracy and to accomplish the objects of the conspiracy, on or about the following dates, the defendants, and others known and unknown to the Grand Jury, committed various overt acts within the Central District of California, and elsewhere, including but not limited to the following: 1. On July,, at the PDRHP, defendant MCGRUDER attacked a group of police officers who were conducting a traffic stop.. On February, 00, at the PDRHP, defendant WOOTEN flashed a gun at a group of passers-by, and demanded to know if they were affiliated with the PBB.. On February, 00, at the PDRHP, defendant ELEBY possessed a firearm.. On May, 01, at the PDRHP, defendant HILL possessed crack cocaine for sale.. On January, 0, defendant PATTERSON, along with unindicted co-conspirators, committed an armed robbery of the Banco Popular bank in Downey, California, and unlawfully took approximately $,. in cash.. On December, 0, at the PDRHP, defendant TERRELL purchased approximately one kilogram of cocaine for resale.. On December, 0, at the PDRHP, defendant HILL possessed crack cocaine for sale, possessed a gun holster, and assaulted officers of the Los Angeles Police Department ( LAPD ).

16 On March, 0, at the PDRHP, defendant HILL possessed crack cocaine for sale, two assault rifles, a. caliber pistol, and several rounds of ammunition.. On March, 0, at the PDRHP, defendant MOORE possessed crack cocaine for sale.. On May, 0, defendant HARDIMAN, and other unindicted co-conspirators, armed with a gun, robbed the Bank of the West in La Mirada, California, and unlawfully took approximately $, in cash.. On May, 0, at the PDRHP, defendant S. WILLIAMS used a gun to rob a victim of his cellular telephone. 1. On April 1, 0, at the PDRHP, defendant DAVIS, while congregating with several other PBB members, possessed an SKS assault rifle. 1. On May, 0, at the PDRHP, defendant MOORE possessed crack cocaine for sale. 1. On May, 0, at the PDRHP, defendant KENSEY sold crack cocaine to an individual defendant KENSEY believed to be a drug customer, but who, in fact, was an undercover law enforcement officer.. On May, 0, at the PDRHP, defendant CARTER sold crack cocaine to an individual defendant CARTER believed to be a drug customer, but who, in fact, was a confidential informant working for law enforcement ( CI ).. On July, 0, at the PDRHP, defendant EVANS possessed crack cocaine for sale and approximately $0 in cash.. On July, 0, at the PDRHP, defendant EVANS possessed crack cocaine for sale and approximately $1 in cash.

17 On October, 0, at the PDRHP, defendant BAILEY used a firearm to shoot several bullets into a vehicle driven by victims C.G., A.B., E.B., and T.G.. On December, 0, in the vicinity of the PDRHP, defendant HENDERSON and other PBB members robbed a victim at gunpoint.. On March, 0, at the PDRHP, defendant MCGRUDER sold crack cocaine to a customer.. On March, 0, in the vicinity of the PDRHP, defendant D. WHITE assaulted, and then threatened to shoot, two victims at a community center after demanding to know the victims' gang affiliation.. On September, 0, defendant GRAY, along with an unindicted PBB co-conspirator, drove to rival th Street gang territory and, using a firearm, shot at a crowd of friends and family of a murder victim who had gathered at the scene to clean the blood remaining on the street, and, in so doing, defendant GRAY and the unindicted PBB co-conspirator wounded one person.. On April, 0, at the PDRHP, defendant D. WHITE possessed crack cocaine for sale.. On July, 0, at the PDRHP, defendant MCGRUDER possessed,-methylenedioxymethamphetamine ( MDMA ) for sale.. On January 1, 0, at the PDRHP, defendant BAILEY possessed marijuana for sale, a loaded. caliber revolver, and a loaded. caliber revolver.. On February, 0, at the PDRHP, defendant HARDIMAN sold approximately grams of cocaine to a CI.. On March, 0, at the PDRHP, defendant HARDIMAN

18 1 1 1 sold approximately grams of crack cocaine and grams of cocaine to a CI.. On April, 0, at the PDRHP, defendant HARDIMAN delivered approximately. grams of crack cocaine to a CI, and offered to sell a new mm handgun, an Uzi, an AK- assault rifle, and body armor to the CI.. On April, 0, at the PDRHP, using a threat of force, defendant WOOTEN robbed a victim of the victim's camera. 0. On May, 0, at the PDRHP, defendant HARDIMAN sold approximately 1 grams of cocaine to a CI. 1. On May, 0, at the PDRHP, defendant PATTERSON sold approximately. grams of crack cocaine to a CI.. On May, 0, at the PDRHP, defendant HENDERSON possessed marijuana for sale and approximately $, in cash.. On May, 0, at the PDRHP, defendants BAILEY and PATTERSON sold approximately grams of cocaine to a CI.. On June, 0, in a transaction that started at the PDRHP, defendant HARDIMAN sold approximately grams of cocaine to a CI.. On June, 0, defendants PATTERSON and HARDIMAN sold approximately grams of cocaine to a CI.. On July, 0, at the PDRHP, defendant HILL sold approximately grams of cocaine to a CI.. On July 0, 0, at the PDRHP, defendant LITTLETON sold crack cocaine to a customer.. On August 1, 0, at the PDRHP, defendant MCGRUDER sold crack cocaine to a customer.. On August, 0, at the PDRHP, defendant BAILEY sold

19 1 1 1 crack cocaine to a customer. 0. On August 1, 0, at the PDRHP, defendant SEXTON sold crack cocaine to a customer. 1. On August 1, 0, at the PDRHP, defendant GILLIARD sold crack cocaine to a customer.. On August 1, 0, at the PDRHP, defendant MCGRUDER sold crack cocaine to a customer.. On August 1, 0, at the PDRHP, defendant HARDIMAN sold crack cocaine to a customer.. On August, 0, at the PDRHP, defendant BAILEY sold marijuana to various customers.. On September, 0, at the PDRHP, defendants HARDIMAN and TERRELL sold approximately 1 grams of cocaine to a CI, and defendant HARDIMAN offered to sell a firearm to the CI.. On September, 0, at the PDRHP, defendant BOUGERIOUS sold crack cocaine to a customer.. On September, 0, at the PDRHP, defendant HENDERSON sold approximately. grams of crack cocaine to a CI.. On September, 0, at the PDRHP, defendants HENDERSON and DANIELS sold approximately.0 grams of crack cocaine to a CI.. On September, 0, at the PDRHP, defendant HENDERSON sold approximately. grams of crack cocaine to a CI. 0. On September, 0, at the PDRHP, defendant SEXTON sold approximately.1 grams of crack cocaine to a CI. 1. On September 0, 0, at the PDRHP, defendant JOSE LEON offered to sell a. caliber revolver to a CI.. On September 0, 0, at the PDRHP, defendant JOSE

20 1 1 1 LEON sold approximately grams of cocaine to a CI.. On September 0, 0, at the PDRHP, defendants JOSE LEON and HILL sold approximately grams of cocaine to a CI.. On October 1, 0, defendant CARTER physically assaulted a crack cocaine customer who owed a drug debt to defendant CARTER.. On October, 0, at the PDRHP, defendant KENSEY sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant D. WHITE sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant BOUGERIOUS sold crack cocaine to a customer.. On October, 0, at the PDRHP, defendant SEXTON sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant D. WHITE sold approximately. grams of crack cocaine to a CI. 0. On October, 0, defendant CARTER visited a crack cocaine customer's family and demanded that the family members pay defendant CARTER in order to satisfy the customer's drug debt to defendant CARTER. 1. On October, 0, at the PDRHP, defendant GILLIARD sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant BAILEY sold crack cocaine to a customer.. On October, 0, at the PDRHP, defendant LITTLETON sold approximately one gram of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant DAVIS sold approximately. grams of crack cocaine to a CI.

21 On October, 0, at the PDRHP, defendant HENDERSON sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant WOOTEN sold crack cocaine to a customer.. On October, 0, at the PDRHP, defendant GILLIARD sold approximately 1. grams of crack cocaine to a CI.. On October, 0, using coded language in a telephone conversation, defendant JOSE LEON offered to sell crack cocaine to a CI.. On October, 0, at the PDRHP, defendant BOUGERIOUS sold crack cocaine to a customer. 0. On October, 0, at the PDRHP, defendant MOORE sold crack cocaine to two different customers. 1. On October, 0, at the PDRHP, defendant JOSE LEON sold a firearm to a CI.. On October, 0, at the PDRHP, defendant HENDERSON sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant MONSON sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant DAVIS sold approximately one gram of crack cocaine to a CI.. On October, 0, at the PDRHP, defendant DAVIS sold approximately. grams of crack cocaine to a CI.. On October, 0, at the PDRHP, defendants BAILEY and DAVIS sold approximately 1. grams of crack cocaine to a CI.. On November, 0, at the PDRHP, defendant KENSEY sold approximately four grams of crack cocaine to a CI.. On November, 0, at the PDRHP, defendant PATTERSON

22 1 1 1 sold approximately. grams of crack cocaine to a CI.. On November, 0, at the PDRHP, defendant BOUGERIOUS sold approximately. grams of crack cocaine to a CI. 0. On November, 0, at the PDRHP, defendants HARDIMAN and DAVIS offered to sell crack cocaine to a CI. 1. On November, 0, at the PDRHP, defendant G. WHITE told a CI that defendant G. WHITE was interested in carrying out robberies, and asked the CI to inform defendant G. WHITE of any potential robbery targets.. On November, 0, at the PDRHP, defendant EVANS sold approximately grams of cocaine to a CI.. On December, 0, at the PDRHP, defendant SEXTON possessed crack cocaine for sale and approximately $ in cash.. On December, 0, at the PDRHP, defendant SEXTON sold approximately.1 grams of crack cocaine to a CI.. On December, 0, at the PDRHP, defendant DAVIS physically assaulted victim E.F. after E.F. asked defendant DAVIS to stop selling drugs around E.F.'s vehicle.. On December, 0, at the PDRHP, defendant EVANS sold approximately grams of cocaine to a CI.. On December, 0, at the PDRHP, defendants JOSE LEON and HARDIMAN sold approximately seven grams of cocaine to a CI.. On December, 0, at the PDRHP, defendants D. WHITE and HARDIMAN sold a loaded. caliber rifle to a CI.. On December, 0, defendant DAVIS possessed a. caliber rifle, bearing serial number, inside his residence at the PDRHP.

23 On January, 0, at the PDRHP, defendant HARDIMAN told a CI that defendant HARDIMAN suspected that PBB members who were released from jail or prison too early were probably cooperating with law enforcement. 1. On January, 0, at the PDRHP, defendant LITTLETON sold approximately grams of cocaine to a CI.. On January, 0, at the PDRHP, defendant MOORE possessed a loaded New Titan Tiger. caliber revolver, bearing serial number N.. On January 0, 0, at the PDRHP, defendant LITTLETON sold approximately. grams of crack cocaine to a CI.. On February 1, 0, at the PDRHP, defendant WOOTEN sold approximately.1 grams of crack cocaine to a CI.. On February 1, 0, at the PDRHP, defendant BAILEY sold approximately three grams of crack cocaine to a CI.. On February, 0, defendant S. WILLIAMS, in the vicinity of the PDRHP, possessed crack cocaine for sale.. On February, 0, at the PDRHP, defendants HARDIMAN and JOSE LEON sold approximately. grams of cocaine to a CI.. On February, 0, at the PDRHP, defendant JOSE LEON gave a CI approximately three grams of cocaine that defendant JOSE LEON owed to the CI, and offered to sell the CI two additional ounces of cocaine.. On April 1, 0, at the PDRHP, defendant D. WHITE possessed a loaded. caliber handgun, bearing serial number D. 0. On April, 0, at the PDRHP, defendants MCGRUDER and JOSE LEON sold approximately grams of cocaine to a CI.

24 On April, 0, at the PDRHP, defendant G. WHITE offered to help a CI purchase heroin.. On April, 0, at the PDRHP, defendant JOSE LEON sold approximately grams of cocaine to a CI.. On April, 0, at the PDRHP, defendant JOSE LEON sold approximately grams of heroin to a CI.. On May, 0, at the PDRHP, defendant GILLIARD assaulted a victim and then stole the victim's money and bicycle.. On May, 0, at the PDRHP, unidentified PBB members and associates intimidated a victim from testifying against defendant GILLIARD while defendant GILLIARD was facing potential criminal charges for his role in an assault.. On May, 0, at the PDRHP, defendant GILLIARD sold approximately.1 grams of crack cocaine to CI.. On May, 0, at the PDRHP, defendant WOOTEN sold approximately. grams of crack cocaine to a CI.. On June, 0, using coded language in a telephone conversation, defendant JOSE LEON told a CI that defendant JOSE LEON did not have any cocaine at that time.. On June, 0, using coded language in a telephone conversation, defendant JOSE LEON told a CI that while defendant JOSE LEON did not have any cocaine available, defendant JOSE LEON did have heroin available. 0. On June, 0, at the PDRHP, defendant JOSE LEON sold approximately grams of heroin to a CI. 1. On June, 0, at the PDRHP, defendant CARTER forced a CI to pay him approximately $00 in response to the threat that defendant CARTER would assault the CI because of an alleged

25 1 1 1 unpaid drug debt.. On June 1, 0, at the PDRHP, defendant CARTER sold approximately.0 grams of crack cocaine to a CI.. On June, 0, at the PDRHP, defendant CARTER sold approximately. grams of crack cocaine to a CI and collected $ in additional drug proceeds.. On August, 0, defendants GABOUREL and YOUNG, and unindicted PBB co-conspirators, conspired to murder rival th Street gang members in retaliation for the shooting death of a PBB member that day. 1. On August, 0, defendants GABOUREL and YOUNG, and unindicted PBB co-conspirators, drove to a car wash in rival th Street gang territory and shot victim F.C., a Hispanic male, in the back, killing F.C. in the presence of F.C. s two year-old son. 1. On August, 0, defendant BOUGERIOUS took possession of and concealed a pistol-grip shotgun that had, as defendant BOUGERIOUS knew, just been used in a violent retaliatory attack against perceived PBB rivals. 1. On August, 0, defendant G. WHITE, using coded language in a telephone conversation, offered to sell grams of cocaine to defendant JOSE LEON. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, told a co-conspirator that defendant JOSE LEON possessed a firearm while selling narcotics at the PDRHP during the previous night. 1. On August, 0, defendant S. WILLIAMS, using coded language in a telephone conversation, ordered ammunition from

26 1 1 1 defendant JOSE LEON. 1. On August, 0, defendant HENDERSON, using coded language in a telephone conversation, ordered a firearm from defendant JOSE LEON for $0. 1. On August, 0, defendant TERRELL, using coded language in a telephone conversation, ordered cocaine from defendant JOSE LEON. 1. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered a firearm from defendant JOSE LEON for $ On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered a firearm from defendant JOSE LEON for $0. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, told an unindicted coconspirator that defendant JOSE LEON had cocaine available for sale. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, encouraged an unindicted co-conspirator to commit an armed carjacking on a nearby occupied vehicle. 1. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON. 1. On August, 0, defendant MONSON, using coded language in a telephone conversation, agreed to deliver approximately. grams of cocaine to defendant JOSE LEON. 1. On August, 0, defendant MONSON, using coded

27 1 1 1 language in a telephone conversation, ordered cocaine from defendant JOSE LEON. 1. On August, 0, an unindicted co-conspirator, using coded language in a telephone conversation, told defendant JOSE LEON that the unindicted co-conspirator wanted to buy 1 grams of cocaine from defendant JOSE LEON, and asked defendant JOSE LEON how much that would cost.. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON for $0.. On August, 0, defendant MUNOZ, using coded language in a telephone conversation, ordered. grams of cocaine from defendant JOSE LEON for $0. 1. On August, 0, defendant PATTERSON, using coded language in a telephone conversation, stated that he possessed a firearm while in the PDRHP. 1. On August, 0, defendant BULLOCK, using coded language in a telephone conversation, ordered 0 grams of heroin from defendant JOSE LEON. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered 0 grams of heroin from defendant ESPINOZA. 1. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, stated that he was about to manufacture crack cocaine. 1. On August, 0, an unindicted co-conspirator, using coded language in a telephone conversation, ordered grams of cocaine from defendant JOSE LEON for $1,00.

28 On August, 0, defendant JOSE LEON provided defendant ESPINOZA with approximately $,000 in drug proceeds. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of heroin from defendant ESPINOZA. 1. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered seven grams of cocaine from a co-conspirator.. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered 0 grams of heroin from defendant ESPINOZA. 1. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered one gram of crack cocaine from defendant JOSE LEON for $0. 1. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered one gram of crack cocaine from defendant JOSE LEON for $0. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, told defendant MONSON that defendant MONSON had stolen one of defendant JOSE LEON s customers. 1. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered. grams of cocaine from defendant JOSE LEON. 1. On August, 0, defendant HILL, using coded

29 1 1 1 language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON. 1. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, discussed with defendant ESPINOZA the amount of money defendant ESPINOZA owed defendant JOSE LEON for previously-fronted drugs. 1. On August, 0, an unindicted co-conspirator, using coded language in a telephone conversation, offered to sell a G-1 rifle to defendant JOSE LEON. 1. On August, 0, defendant HILL, using coded language in a telephone conversation, ordered seven grams of cocaine on behalf of defendant LITTLETON from defendant JOSE LEON. 0. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON. 1. On August, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered seven grams of cocaine from defendant JOSE LEON.. On August, 0, defendant MUNOZ, using coded language in a telephone conversation, ordered. grams of crack cocaine from defendant JOSE LEON for $0.. On August 1, 0, defendant G. WHITE, using coded language in a telephone conversation, ordered. grams of cocaine from defendant JOSE LEON.. On August 1, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.

30 On August 1, 0, an unindicted co-conspirator, using coded language in a telephone conversation, discussed with defendant JOSE LEON plans to conduct a drive-by shooting to exact vengeance on rival gang members.. On August 1, 0, defendant S. WILLIAMS, using coded language in a telephone conversation, ordered. grams of cocaine from defendant JOSE LEON.. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered one kilogram of cocaine from defendant ESPINOZA for approximately $,000.. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, told defendant PATTERSON that defendant JOSE LEON possessed a firearm with a -round magazine.. On August 1, 0, defendant PATTERSON, using coded language in a telephone conversation, instructed an unindicted co-conspirator to hide a. caliber rifle that was then stored in a van at the PDRHP. 0. On August 1, 0, defendants PATTERSON, MONSON, HARDIMAN, and JOSE LEON, using coded language in a telephone conversation, discussed how law enforcement had recently seized five firearms from PBB members in the PDRHP, including a firearm owned by defendant MONSON. 1. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of cocaine from defendant ESPINOZA.. On August 1, 0, defendant MONSON, using coded language in a telephone conversation, ordered 1 grams of cocaine 0

31 1 1 1 from defendant JOSE LEON for himself and defendant TERRELL.. On August 1, 0, defendant PATTERSON, using coded language in a telephone conversation, ordered seven grams of heroin from defendant JOSE LEON.. On August 1, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On August 1, 0, defendant DANIELS, using coded language in a telephone conversation, ordered illegal drugs from defendant JOSE LEON.. On August 1, 0, defendant MONSON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On August 1, 0, an unindicted co-conspirator, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON, and then picked up that cocaine from defendant JOSE LEON at the PDRHP.. On August 1, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On August 1, 0, defendant TERRELL, using coded language in a telephone conversation, ordered cocaine from defendant JOSE LEON. 0. On August 1, 0, defendant S. WILLIAMS, using coded language in a telephone conversation, agreed to sell crack cocaine to a customer for defendant JOSE LEON. 1. On August, 0, defendant HILL, using coded language in a telephone conversation, ordered cocaine from 1

32 1 1 1 defendant JOSE LEON.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered heroin and cocaine from defendant ESPINOZA for approximately $,000.. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered crack cocaine from defendant JOSE LEON for $.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, discussed paying defendant ESPINOZA $,000 for previously-fronted drugs supplied by defendant ESPINOZA.. On or about August, 0, defendant TERRELL, using coded language in a telephone conversation, ordered cocaine from defendant JOSE LEON.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, told an unindicted coconspirator that none of defendant JOSE LEON s drug suppliers had any narcotics available for sale to the unindicted coconspirator.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of heroin and an unknown amount of cocaine from defendant ESPINOZA.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered crack cocaine from defendant S. WILLIAMS.. On August, 0, defendant PATTERSON, using coded language in a telephone conversation, ordered ten rounds of ammunition from defendant JOSE LEON.

33 On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered two kilograms of cocaine from defendant ESPINOZA. 1. On August, 0, defendant S. WILLIAMS, using coded language in a telephone conversation, agreed with defendant JOSE LEON to sell crack cocaine to another person.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered crack cocaine from defendant TERRELL.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant TERRELL.. On August, 0, an unindicted co-conspirator, using coded language in a telephone conversation, tried to order grams of cocaine from defendant JOSE LEON, and defendant JOSE LEON told defendant the unindicted co-conspirator that defendant JOSE LEON did not have cocaine available.. On August, 0, at a meeting of the PBB at the PDRHP, defendants ELEBY, G. WHITE, and HENDERSON, and other unindicted co-conspirators, urged younger PBB gang members to use violence to protect PBB territory from rivals.. On August, 0, at a meeting of the PBB at the PDRHP, defendant HENDERSON instructed a group of PBB members to make sure that there was a firearm on every corner of the PDRHP in order to protect the gang from rivals.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of heroin from defendant ESPINOZA.

34 On August, 0, defendant HANFORD, using coded language in a telephone conversation, ordered one gram of crack cocaine from defendant JOSE LEON for $0.. On August, 0, defendant HANFORD, using coded language in a telephone conversation, ordered. grams of crack cocaine from defendant JOSE LEON. 0. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered a firearm from defendant JOSE LEON. 1. On August, 0, an unindicted co-conspirator, using coded language in a telephone conversation, discussed purchasing a firearm with defendants JOSE LEON and MONSON.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of cocaine from defendant HILL.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of cocaine from defendant LITTLETON for $00.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, told an unindicted coconspirator that defendant JOSE LEON had successfully purchased a firearm.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, stated to defendant LITTLETON that defendant JOSE LEON needed to go manufacture crack cocaine.. On August, 0, defendant PATTERSON, using coded language in a telephone conversation, ordered grams of heroin

35 1 1 1 and grams of cocaine from defendant JOSE LEON.. On August, 0, defendant HANFORD, using coded language in a telephone conversation, ordered. grams of crack cocaine from defendant JOSE LEON for $0.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered seven grams of cocaine from defendant TERRELL.. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered seven grams of cocaine from defendants JOSE LEON and TERRELL. 0. On August, 0, defendant HARDIMAN, using coded language in a telephone conversation, ordered cocaine from defendant JOSE LEON. 1. On August, 0, defendant HILL, using coded language in a telephone conversation, ordered seven grams of cocaine from defendant JOSE LEON.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered heroin and cocaine from defendant ESPINOZA, and defendant JOSE LEON complained that the quantity of cocaine that he had just received from defendant ESPINOZA was grams short.. On August, 0, defendant JOSE LEON, using coded language in a telephone conversation, stated to defendants LITTLETON and HILL that defendant JOSE LEON needed to go test his crack cocaine.. On August, 0, defendant MONSON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON for $,000.

36 On August 0, 0, defendant MONSON, using coded language in a telephone conversation, ordered heroin from defendant JOSE LEON.. On August 0, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered 1,1 grams of heroin from defendant ESPINOZA for $,000.. On August 1, 0, defendant MONSON, using coded language in a telephone conversation, agreed to sell approximately grams of cocaine to defendant JOSE LEON in exchange for $0.. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, agreed to sell. grams of crack cocaine to defendant HANFORD, and instructed defendant HANFORD to retrieve the crack cocaine from the home of a coconspirator.. On August 1, 0, defendant HILL, using coded language in a telephone conversation, ordered grams of cocaine from defendant JOSE LEON. 0. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of heroin from defendant ESPINOZA for approximately $, On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered grams of cocaine from defendant ESPINOZA for approximately $,00.. On August 1, 0, an unindicted co-conspirator, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On August 1, 0, defendant JOSE LEON, using coded

37 1 1 1 language in a telephone conversation, ordered one kilogram of cocaine from defendant ESPINOZA for approximately $,000.. On August 1, 0, defendant JOSE LEON, using coded language in a telephone conversation, agreed to pay defendant ESPINOZA $,000 for 1,000 grams of previously-fronted cocaine supplied by defendant ESPINOZA.. On September 1, 0, defendant HENDERSON, using coded language in a telephone conversation, ordered a firearm from defendant JOSE LEON.. On September 1, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered seven grams of cocaine from defendant JOSE LEON.. On September 1, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On September 1, 0, defendant MONSON, using coded language in a telephone conversation, ordered. grams of cocaine from defendant JOSE LEON.. On September, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On September, 0, an unindicted co-conspirator, using coded language in a telephone conversation, ordered grams of cocaine from defendant JOSE LEON.. On September, 0, defendant MONSON, using coded language in a telephone conversation, ordered heroin from defendant JOSE LEON.. On September, 0, defendant JOSE LEON, using coded

38 1 1 1 language in a telephone conversation, stated to defendant LITTLETON that defendant JOSE LEON needed to go manufacture crack cocaine.. On September, 0, defendant MONSON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On September, 0, defendant LITTLETON, using coded language in a telephone conversation, ordered 1 grams of cocaine from defendant JOSE LEON.. On September, 0, defendant JOSE LEON, using coded language in a telephone conversation, ordered 0 grams of cocaine from defendant ESPINOZA for approximately $,000.. On September, 0, defendant MUNOZ, using coded language in a telephone conversation, ordered seven grams of cocaine from defendant JOSE LEON.. On September, 0, defendant PATTERSON, using coded language in a telephone conversation, stated that he possessed cocaine.. On September, 0, defendants JOSE LEON and MUNOZ, and other unindicted co-conspirators, conspired to murder a rival 1st Street gang member in retaliation for shootings targeting PBB gang members.. On September, 0, defendants JOSE LEON and MUNOZ, and other unindicted co-conspirators, used firearms to shoot at victims E.G. and P.G. at the victims residence. 0. On September, 0, defendant MONSON, using coded language in a telephone conversation, asked defendant JOSE LEON to get defendant MONSON's gun because they were "at war."

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