Case 2:14-cr-00652-MAK Document 1 Filed 11/21/14 Page 1 of 15

CRIMINAL COMPLAINT

AO 91, Rev. 11/82 (LABRUM Authorizing)

# 14-112

DISTRICT

Eastern District of Pennsylvania

United States District Court

DOCKET NO.

UNITED STATES OF AMERICA

v.
GABRIEL VARGAS

MAGISTRATE'S CASE NO.

ff ~ I{ C/OM..
Complaint for violation of Title 21 United States Code 846, 841{A)(l), (b)(l)(A).
NAME OF JUDGE OR MAGISTRATE

OFFICIAL TITLE

LOCATION

Honorable Carol Sandra Moore Wells

Chief United States

Magistrate Judge

Philadelphia, PA

DATE OF OFFENSE

PLACE OF OFFENSE

ADDRESS OF ACCUSED (if known)

Summer 2009 to November 21,

Philadelphia, PA

2014
COMPLAINANT'S STATEMENT OFF ACTS CONSTITUTING THE OFFENSE OR VIOLATION:

From in or about the summer of2009, to on or about November 21, 2014, in Philadelphia, in the Eastern District of Pennsylvania,
and elsewhere, defendant GABRIEL VARGAS and others known and unknown conspired to distribute and possess with intent to
distribute 1 kilogram or more ofa mixture and substance containing a detectable amount of heroin, in violation of Title 21, United
States Code, Sections 846 and 841(a)(l), (b)(l)(A).

BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED:

SEE AFFIDAVIT ATTACHED HERETO AND INCORPORATED HEREIN.

MATERIAL WITNESSES IN RELATION AGAINST THE ACCUSED:

S<GNATURE~WNANT (offio;.i <;do)

Being duly sworn, I declare that the foregoing is

true and correct to the best of my knowledge.

,~ /\fVv.::_
Patrick Moym an
OFFICIAL TITLE

Special Agent, DEA

Sworn to before me and subscribed in my presence.

S<GNATURE

Ho

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FMAG>STRAT

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arol Sandr

oore Wells, Chief United States Magistrate Judge

I) See Federal Rules of Criminal Procedure rules 3 and 54.

DATE

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Case 2:14-cr-00652-MAK Document 1 Filed 11/21/14 Page 2 of 15

AFFIDAVIT

Your affiant, Special Agent Patrick Moynihan, being duly sworn, deposes and states as
follows:
1. I, Patrick Moynihan, am a Special Agent (SA) of the Drug Enforcement
Administration (DEA), Philadelphia Field Divisional Office, and have been employed by DEA
since September 2002. During my employment as a SA, I have received seventeen weeks of
full-time, formalized training at the DEA Basic Agent Training Academy in Quantico, Virginia.
That training involved comprehensive, formal instruction in areas including, but not limited to:
United States narcotics laws; drug identification; drug interdiction; drug detection; financial
investigations; money laundering techniques and schemes; identification and seizure of drugrelated assets; and investigation of individuals and organizations involved in smuggling,
cultivation, manufacturing, and illicit trafficking of controlled substances, including cocaine,
methamphetamine, and heroin.
2. Prior to joining the DEA, I was a Police Officer with the Baltimore County, Maryland,
Police Department from July 1996 through September 2002. During my employment as a Police
Officer, I received twenty-six weeks of full-time, formalized training at the Baltimore County
Police Academy in Dundalk, Maryland. The training included topics such as interview and
interrogation, preservation of physical evidence, constitutional law, and drug identification.
3. I have specialized training and experience in narcotics smuggling and distribution
investigations, including but not limited to, the means and methods used by traffickers to import
and distribute narcotics, interdiction, smuggling methods, and the concealment and laundering of
proceeds from illicit drug trafficking activities. I have participated in numerous narcotics

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investigations, debriefed or participated in debriefings of numerous defendants, informants, and

witnesses who had personal knowledge regarding major narcotics trafficking organizations, and
have participated in all aspects of drug investigations including conducting surveillance,
analyzing information obtained from court-ordered pen register and trap and trace intercepts, and
analyzing telephone toll information obtained as a result of subpoenas issued by the DEA. I
have initiated Title III investigations and have also assisted in several other wiretap
investigations. I am aware that drug traffickers commonly use cellular telephones and pagers in
furtherance of their drug trafficking activities and frequently change cellular telephone numbers
and cellular telephones in an effort to thwart law enforcement's use of electronic surveillance. I
am also aware that drug traffickers often speak in vague, guarded, or coded language when
discussing their illegal business in an effort to further prevent detection. In addition, during my
career as an SA, I have participated in several drug investigations, including investigations
during which I conducted physical surveillance, executed search warrants, and reviewed taped
conversations and records of drug traffickers. I have made undercover purchases of narcotics
from drug traffickers. These investigations have resulted in the arrest of numerous individuals
and the seizure of illicit drugs and drug-related evidence and the forfeiture of drug-related assets.
During these investigations, I have had contact with drugs users and sellers, informants, other
agents, and experts in the field of narcotics enforcement. I have discussed with them various
aspects of drug use, sales, packaging, smuggling, and transporting and transferring drugs,
including cocaine, methamphetamine, and heroin in the United States.
4. I am an investigative or law enforcement officer of the United States within the
meaning of Title 18, United State Code, Section 2510(7), as I am empowered by law to conduct

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investigations of, and to make arrests for, offenses enumerated in Title 18, United States Code,
Section 2516.
5. This affidavit contains information provided by four (4) Cooperating Witnesses
(hereafter CW) and a Source of Information (hereafter "SOI"), who have provided detailed
information pertaining to Gabriel VARGAS, who has been identified in an ongoing investigation
by DEA Philadelphia as a key member of a heroin trafficking organization operating in
Philadelphia which has been supplied with over 500 kilograms of heroin from an organization
based in Mexico since 2010. The CWs referenced in this affidavit are currently incarcerated.
CW-1, CW-2, CW-3 and CW-4 are motivated to cooperate with law enforcement in exchange
for court consideration regarding their respective cases. CW-1 is a former money launderer for
the organization based in Mexico. CW-2 is a former transporter and kilogram distributor of
heroin for this Mexican based organization. CW-3 is a former Philadelphia based heroin mill
operator who was supplied with heroin from the VARGAS DTO until his/her arrest in July,
2012. CW-4 is a former heroin courier for the Mexican based organization who was arrested
while transporting a car battery containing approximately three kilograms of heroin. CW-1, CW2, CW-3 and CW-4 were each interviewed separately and all have provided detailed,
corroborating statements regarding Gabriel VARGAS, as well as other members of this targeted
heroin trafficking organization. Information provided by CW s in this investigation has been
determined by law enforcement to be truthful and reliable information. Furthermore, this
information has been independently verified by physical surveillance, investigative reports,
banking records, Western Union records, utility records and commercial database inquiries.
a. CW-1 is currently incarcerated and is motivated to cooperate with law enforcement in
exchange for court consideration regarding his/her respective case. CW-1 is a former

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money launderer and heroin kilogram distributor for this organization, who has
coordinated the shipment of heroin concealed in car batteries directly from Mexico
and Chicago, IL to heroin distributors based in Philadelphia, PA. CW-1 has worked
for this Mexican based heroin organization since 2009. CW-1 was arrested in 2013
for possession of heroin. Specifically, CW-1 advised he/she worked for a heroin
trafficking organization based in Mexico which processes raw opium, cultivated in
Mexico, into heroin which is equal in quality to heroin imported from South America
After the heroin is processed, it is further concealed into packages of heroin which are
placed into car batteries, each containing approximately three kilograms of heroin.
The car batteries are placed into couriers' vehicles which are subsequently driven
from Mexico into the United States. CW-1 advised that the batteries containing
heroin are either driven from Mexico to Chicago, IL, Atlanta, GA or Texas, where
multi-kilogram shipments of heroin are stored for later distribution to organization
members based in Philadelphia, PA. CW-1 advised that between August of 2009 to
September, 2012, CW-1 assisted in coordinating the importation of kilograms of
heroin from Mexico to the VARGAS DTO in Philadelphia, PA, however CW-1 's
primary role with in the Mexican based organization was to launder proceeds
generated from the sale of kilogram quantities of heroin in Philadelphia. Therefore,
CW-1 routinely collected proceeds generated from the sale of kilograms of heroin in
Philadelphia by the VARGAS DTO. These proceeds were subsequently laundered
and transported back to the source of supply based in Mexico. CW-1 has positively
identified a Pennsylvania Driver's License Photograph of Gabriel VARGAS, date of
birth December 4, 1988, as a member of the VARGAS DTO from whom CW-1 had

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picked up proceeds from VARGAS on numerous occasions which were generated

from the sale of kilograms of heroin in Philadelphia, PA.
b. CW-2 is a former heroin transporter for the organization based in Mexico. CW-2 has
positively identified a Pennsylvania Driver's License photograph Gabriel VARGAS,
date of birth December 4, 1988, as a member of the VARGAS DTO who distributed
kilogram quantities of heroin in Philadelphia, PA. CW-2 advised between 2009 and
2011, he/she maintained a stash location for the VARGAS DTO located at 7116
Lynford St., Philadelphia, PA.
c. CW-3 was a former heroin distributor based in Philadelphia who operated a heroin
mill which was supplied by the VARGAS DTO, prior to CW-3 's arrest by
Philadelphia Police Narcotics Officers in July, 2012. CW-3 has positively identified
a Pennsylvania Driver's License Photograph of Gabriel VARGAS, date of birth
December 4, 1988 as a member of the VARGAS DTO who supplied samples of
heroin to CW-3 prior to receiving large quantities of heroin from the VARGAS DTO.
d. CW-4 was a former courier for the organization based in Mexico which supplied the
VARGAS DTO in Philadelphia with kilograms of heroin until CW-4' s arrest in
September, 2011. CW-4 advised he/she maintained a stash location for heroin and
cocaine for the organization at 8719 Frankford Avenue, Philadelphia, PA. CW-4 has
positively identified a Pennsylvania Driver's License Photograph of Gabriel
VARGAS, date of birth December 4, 1988 as a member of the VARGAS DTO who
received a kilogram and a half of cocaine from CW-4 at 8719 Frankford Avenue
during the summer of201 l. CW-4 further advised he/she had witnessed Gabriel
VARGAS in possession of approximately three kilograms of heroin during the

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summer of 2011.
CASE BACKGROUND
6. On November 18, 2014, at approximately 12:15 pm, DEA Newark High Intensity
Drug Trafficking Area (HIDTA) Group 3 was conducting surveillance pursuant to a narcotics
investigation near the intersection of North 9th St. and Bristol St., Philadelphia, PA.
7. At approximately 1:30 pm, DEA Agents and Task Force Officers (TFO) from
HIDTA Group 3 observed a silver 2013 KIA sedan, bearing New Jersey registration plate
R24DES, registered to Hertz rental car corporation, conducting counter-surveillance in the area.
Members ofHIDTA Group 3 further observed this vehicle make several U-tums on North 9th St.
between Bristol St. and West Luzerne St. This same vehicle made several stops on North 9th St.,
then subsequently began moving again. Believing that this vehicle was engaged in countersurveillance in connection with drug trafficking activity, agents approached the vehicle and
detained the driver. The driver of the vehicle was subsequently identified as Gabriel VARGAS,
who produced a valid Pennsylvania Driver's License, with a date of birth of December 4, 1988.
VARGAS told the agents he resided at 4052 North Franklin St., Philadelphia, PA with his
girlfriend and two small children. This was the same address displayed on VARGAS' s
Pennsylvania Driver's License. Agents subsequently asked Gabriel VARGAS for consent to
search his vehicle for weapons or contraband. VARGAS agreed to a consent search of his
vehicle. Pursuant to the search, agents seized a shoebox with approximately $21,000 in bulk U.S.
Currency.
8. Special Agent Christopher Lyons, HIDTA Group 3, conducted a debrief of VARGAS
at the location of the stop. SA Lyons asked VARGAS how he obtained the money. VARGAS
told SA Lyons that he was approached by an older Dominican Male at his mother's restaurant in

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Philadelphia who asked VARGAS if he wanted to make some extra money. VARGAS further
advised that his brothers were "in the game" and VARGAS only recently got into picking up
money through a Dominican subject who used he used to go to school with in Philadelphia with
but has since been deported. SA Lyons asked VARGAS for the name of this Dominican subject;
however VARGAS replied that he did not know his name.
9. VARGAS told SA Lyons that the unknown Dominican subject directed VARGAS
earlier that day to go a Home Depot location in Philadelphia. VARGAS advised he drove to the
Home Depot store, where a second unknown Dominican subject placed a shoebox containing
U.S. Currency in the trunk of the rental vehicle operated by VARGAS. The unknown
Dominican subject contacted VARGAS and instructed him to go to North 9th St. and meet with
an additional unknown subject. SA Lyons asked VARGAS how much money was in the shoe
box. VARGAS initially replied that he did not know, and then advised the shoe box contained
approximately $20,000.
10. VARGAS told SA Lyons that the unknown Dominican directed VARGAS to pick up
the rental vehicle on the street on the day prior (Monday, November 1ih) however; agents were
able to find a Hertz rental receipt which showed that the vehicle had been rented by Gabriel
VARGAS. SA Lyons asked about the subject in the Dominican Republic directing VARGAS,
and how VARGAS could know a subject for a long time but not recall his name. VARGAS
replied that this subject used to frequent his family's restaurant and VARGAS's parents were
closer to this subject than he was. SA Lyons asked VARGAS how it was possible to obtain a
phone number to contact this "unknown subject" if he resides in the Dominican Republic?
VARGAS first replied that he did not know, then changed his answer and advised that the
unknown Dominican subject had mailed VARGAS his phone number. SA Lyons subsequently

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asked VARGAS to retrieve the telephone number of the unknown Dominican subject in his
cellular telephone. According to SA Lyons, VARGAS advised he could not recall the number,
then deliberately entered the wrong password into the phone, which subsequently locked the
phone. Agents subsequently seized the U.S. Currency and three mobile phones in Gabriel
VARGAS's possession. VARGAS was provided with a DEA Form 12 as a receipt. Shortly
thereafter, VARGAS was released.
11. Subsequent to the traffic stop, your affiant was contacted by TFO Charles Myers,
FBI Philadelphia Violent Crimes Task Force. TFO Myers reported that he had debriefed a
Source oflnformation (SOI) who had encountered Gabriel VARGAS after VARGAS's contact
with DEA HIDTA Group 3 on Tuesday, November 18, 2014. The SOI reported that VARGAS
told the SOI he had encountered the police, who had taken a large amount of money and phones
from VARGAS. The SOI told TFO Myers that VARGAS was "paranoid" of being placed under
arrest because police had seized money from VARGAS in the past.
12. On Wednesday, November 19, 2014, agents from DEA Philadelphia Group 23
established surveillance at known locations for Gabriel VARGAS, including his residence at
4052 North Franklin St. and Las Delicias Restaurant, located at 4200 North Reese St.,
Philadelphia, PA.
13. At approximately 3:50 pm, members of DEA Group 23 located the a silver 2013
KIA sedan, bearing New Jersey registration plate R24DES, registered to Hertz rental car
corporation, which was parked at the northeast corner of North Rees Street and Hunting Park
Avenue. Surveillance was maintained on this vehicle.
14. At approximately 4:00 pm, SA Michael Beck attempted to verify the plate on the
silver 2013 Kia Sedan. While SA Beck was approaching the vehicle, members of DEA Group

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23 observed VARGAS on foot near the intersection of Hunting Park Ave and North Reese St.
At that time, VARGAS recognized SA Beck from a previous encounter on July 28, 2011, when
SA Beck interviewed Gabriel VARGAS pursuant to a money seizure. Moments later, Gabriel
VARGAS fled from the location on foot and was able to evade further detection from law
enforcement.
15. Previously, on July 28, 2011, the Philadelphia Police Department conducted a traffic
stop on a white 2009 white Chevrolet Impala, bearing PA registration HFW-9518, registered to
Ronny ESPINAL. At the time of the stop, police identified Wilmer VARGAS as the driver and
Gabriel VARGAS as the passenger of the vehicle. A consensual search of the vehicle was
conducted which resulted in the seizure of $314,820.00, which was recovered from the trunk of
the vehicle. This money was packaged in a manner consistent with drug proceeds. Both males
made statements denying knowledge or ownership of the U.S. Currency. Neither male was
arrested.
16. CW-1 has identified the July 28, 2014 seizure from Gabriel VARGAS and Wilmer
VARGAS of $314,820 as cash proceeds which were generated from the distribution of
approximately ten (10) kilograms of heroin by the VARGAS DTO in Philadelphia, PA. CW-1,
who was a money launderer for the organization based in Mexico, advised that the 10 kilograms
of heroin had been supplied on credit to the VARGAS DTO. CW-1 advised that following the
seizure, members of the VARGAS DTO had provided CW-1 with a copy of the receipt
documenting the seizure by police, however, the source of supply based in Mexico was angered
that Gabriel VARGAS and Wilmer VARGAS did not utilize a hidden compartment within the
Chevrolet Impala, which was identified by CW-1 as a vehicle supplied by the organization based
in Mexico. CW-1 advised as a result of the seizure, the sources of supply held the VARGAS

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DTO accountable for the loss of currency by Gabriel VARGAS and Wilmer VARGAS. CW-1
further advised that the Mexican based suppliers of the heroin directed the members of the
Vargas DTO that they would have to sell additional kilograms of heroin without profit in order to
recoup the loss to the organization of the $314,820 representing the proceeds of sale of the 10
kilograms of heroin previously supplied.
17. On September 19, 2012, Gabriel VARGAS's two brothers, John VARGAS and
Wilmer VARGAS were both arrested at 6634 Sylvester St., Philadelphia, PA, following the
controlled delivery of 12 cans of Mexican processed food which further concealed heroin which
had been sealed inside. The total seizure was approximately seven (7) kilograms of heroin.
According to CW-1, the heroin seized from Wilmer VARGAS and John VARGAS at 6634
Sylvester St., Philadelphia, PA was provided by the same heroin trafficking organization based
in Mexico which had supplied the VARGAS DTO since 2009.
18. CW-1 further advised that he/she had coordinated the pickup of bulk proceeds from
the sale of kilogram quantities of heroin from the VARGAS DTO since 2009. CW-1 advised in
2010, he/she would travel to Philadelphia and stay in hotels. During CW-1 's trips to
Philadelphia, CW-1 identified Gabriel VARGAS and Wilmer VARGAS as subjects who would
meet with CW-1 at his/her hotel room for the purpose of delivering bulk U.S. Currency which
was received as payment for kilograms of heroin received by the VARGAS DTO on credit.
CW- I advised that the VARGAS DTO would receive approximately eight kilograms of heroin
every three weeks, for which the VARGAS DTO paid approximately $56,000 per kilogram.
19. CW-1 advised in early 2011, CW-1 was directed by the source of supply based in
Mexico to meet with members of the VARGAS DTO at a residence in the vicinity of ih St. and
Cumberland Ave., Philadelphia, PA. While CW-1 was at the location, he/she observed John

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VARGAS, Wilmer VARGAS and Gabriel VARGAS break open a car battery, which contained
packets of heroin concealed inside. CW- I had identified car batteries as a method which was
utilized by the organization based in Mexico to smuggle heroin into the United States. All three
VARGAS brothers requested that CW- I witness them weigh the heroin packages to settle a
dispute between the VARGAS DTO and the source of supply in Mexico over the weight of the
packages. Because the packages were light, the source of supply in Mexico directed CW-I to
credit the VARGAS DTO for the loss and prorate their payment based on the actual weight of
the under-weight packages.
20. CW-I advised that during the summer of 20I l (prior to the traffic stop) CW-I was
asked by the source of supply in Mexico to assist in the transfer of approximately $500,000 in
bulk currency from Philadelphia, PA to Mexico. CW-I advised the source of supply in Mexico
sent two couriers from Mexico to drive a vehicle from Philadelphia, PA to back to Mexico. CWI advised that he/she was directed by the source of supply to a body shop located in the 2500
block of North Reese St., Philadelphia, PA. CW-I advised when he got to the shop, he
witnessed Gabriel VARGAS, John VARGAS and Wilmer VARGAS packaging stacks of $5,000
into heat sealer bags, which were further wrapped in duct tape. These packages were
subsequently concealed in a white Toyota Forerunner, which was provided to the courier by the
VARGAS DTO. This vehicle was subsequently driven to Mexico by one of the couriers sent by
the source of supply.
21. On March 13, 20I4, Virginia State Police, conducted a traffic stop on a 2006 Honda
Pilot, bearing Pennsylvania registration plate JGE8080, for a traffic infraction which occurred on
northbound Interstate 85 in close proximity to the Virginia - North Carolina border. Troopers
subsequently identified the driver of the Honda Pilot as Ronny ESPINAL, the same subject who

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was the registered owner the 2007 Chevrolet Impala operated by Wilmer VARGAS and Gabriel
VARGAS at the time of the seizure of $314, 820 from them on July 28, 2011. Troopers
conducted a consent search of the Honda Pilot, which yielded approximately 17 kilograms of
heroin contained in a trap compartment. Ronny ESPINAL was subsequently placed under arrest.
During a post arrest interview, ESPINAL advised he was directed to travel to Atlanta, GA by a
subject in Mexico named "GORDO" LNU. CW-1 has identified "GORDO LNU" as the subject
who had supplied kilograms of heroin to the VARGAS DTO.
22. CW-2 is a former transporter of kilogram quantities of heroin for the organization
based in Mexico, who was member of this organization from 2007 until his/her arrest in July
2013. CW-2's role in the organization was to coordinate the movement of kilograms of heroin
from Mexico to Philadelphia, PA. CW-2 also maintained heroin stash locations in Philadelphia
on behalf of the organization based in Mexico. CW-2 has identified 7116 Lynford St.,
Philadelphia, PA as a former stash location for the Mexico based organization.
23. CW-2 has positively identified Gabriel VARGAS as a member of the VARGAS
DTO, a heroin distribution network based in Philadelphia, PA. CW-2 advised between 2009 and
2010, CW-2 received approximately ten (10) deliveries of eight kilograms of heroin at the stash
location at 7116 Lynford St., Philadelphia, PA. CW-2 advised at any given time, he/she had
approximately four to five kilograms of heroin available. CW-2 further advised that Gabriel
VARGAS and Wilmer VARGAS had access to the stash location. CW-2 advised that Gabriel
VARGAS and Wilmer VARGAS would pick up large, multi-kilogram amounts of heroin which
was subsequently distributed to their respective customers in Philadelphia, PA.
24. CW-3 was a subject who was arrested in July 2012 by Philadelphia Police for
possession with intent to distribute approximately 700 grams of heroin. CW-3, who operated a

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heroin mill at the time of his/her arrest, identified the VARGAS DTO as a heroin source of
supply. CW-3 positively identified Gabriel VARGAS as a subject who would deliver CW-3
samples of heroin prior to delivery of bulk amounts received by CW-3 from the VARGAS DTO.
25. CW-4 was previously a heroin courier for the organization based in Mexico, who
maintained heroin kilogram stash locations in Philadelphia prior to his/her arrest in September,
2011. CW-4 was arrested while driving enroute from Mexico to Philadelphia while in possession
of a car battery containing approximately three kilograms of heroin. During the summer of
2011, while maintaining a stash location at 8719 Frankford Avenue, Philadelphia, PA, CW-4
advised he/she had distributed one and a half kilograms of cocaine to two subjects, whom CW-4
positively identified as Wilmer VARGAS and Gabriel VARGAS. CW-4 advised the transaction
occurred in the basement of 8719 Frankford Avenue, where the cocaine had been stashed
beneath the floor.
26. CW-4 had recalled a separate occasion prior to his/her arrest when he/she went to a
stash location operated by the VARGAS DTO. While CW-4 was at the location, he observed
Gabriel VARGAS, Wilmer VARGAS and John VARGAS inside the residence, where they were
"drying out" approximately three kilograms of heroin which had been damaged. CW-3 advised
that he/she observed five small tables in the dining room and living room of the residence where
the VARGAS brothers had set up heat lamps to dry the heroin out. CW further advised that
he/she could "breathe" the heroin in the air inside of the residence.
27. Wherefore, based on the foregoing averments, it is your affiant's belief that there is
probable cause to believe that Gabriel VARGAS is a member of the VARGAS heroin trafficking
and money laundering conspiracy and has committed violations of Title 21, United State Code,

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Sections 846 (Conspiracy to distribute and possess with intent to distribute 1 kilogram or more of

Drug Enforcement Administration

Sworn To and Subscribed Before Me This

~;/oay of November, 2014.

onorable Carol andra Moore Wells
Chief United States Magistrate Judge

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