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Case 3:11-mj-00131-BH Document 1 Filed 03/31/11 Page 1 of 12 PageID 1

.~,
United States District COU"'~lQ"
~""~
SOUTHERN DISTRICT OF INDIANA
OOTED 'STATES OF AMERICA
CRIMINAL COMPLAINT
. v. (SEALED)
CASE NUMBER~ 3:11-mj- 5~" ~H

3~ 1\ ;.MJ"'13 .\
JUAN GERARDO SEGOVIA alkla Carnal

1. the und.etsigued comp;lainant being duly swam state the following is trw: aDd eotreet to the best 'D,f my
knowledge,8i1d bellef. Between on or abtn1t J8nuatY. 2011 and ~h 28, 2011 in Vanderburgh County, in the
SouthemDistiict ofIndUma defendant di~ cn-st-.,.~lll'~l '
. '
consp:i!e to poSsess 'With. the intent to distribute and to distribute 500 grams or more of cocaine. a Sehedul~ II
eonttollecl S U b S t a n e e , " o J .

in violation ofTitle 21. United S1I.tes cOde. SeCtiODS &41(a) and 846. I fi.u1:ber state tbat I am a Task Foree Officer
and that this complrdnt is ba!ed on th~ fallowmg fac;~: ' u.s. DISTRICT COURT
NORTHERNDISTRICTOF1'EXAS
, FILED
See attached Affidavit
MAR 3* 2011

COlltinued tin flie attaebed Ibeet led bllde • part henof.:

•••a17

•Tuk Fott:e Of:!.1.cer

Drug Bl:IforcsmeM Adl!l1Dis1:rltion
, J

SWOTD to before 'IIl~ and sabserlb8t!l ill my prue1lCle

~2ml
&isibord L. Ygppi US, pimietCpgn. Qi;flpdp
Name and Title ofJtld.1dalOftleer

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AFFIDAVIT

Ethan Smith, being duly sworn under oath states as follows:

1. ThiS affidavit is submitted in support of a criminal complaint for tb.e arrest of

Juan Gerardo SEGOVIA a/kIa 'Camal (hereinafter, SEGOVIA), charging him with conspiring to

possess with intent to clistribute and to disttl"bute 500 grams or mote of cocaiD.e:. a Schedule n

controlled substance, in violation of Title 21, United States Code. Sections 841 and 846.

. 2. I am a Task Force Qfficer with the Drug Enfotcement Administnltion, United.

States Deputrnent of J'ustice. I am en inwstigative Dr law eDfoIceme:Dt a,ffieet' within. the .

meaning ofTitle 18, United S1ate5 Code, .Section2S10(7); that is, 8.11 officer of the Ubited States

who is l!mpowered by lllW to conduct investi.gati.onsof, and to make arrests for, ot'leDses
, ,

eD.UlDerated in Title 18, United States Code, Section 2516.

3. I have heeD employe:d by the VaDderbui'gh County ~s Office ~er

·'Veso") as a shetif.rs deputy since Septe:m~ 1997. I am cur:rent!;y,lISSigned to the Drug'

Emo:cemem Adm.inist.ndion (h~ "DBA"), EV1mSVille Post ofDt1ty, as a federally

. Task"Porce Officer and have been, so asSigned since January 2006. In coonection with
deputized "

my ~cia1 DBA d~es, I iDwstig&te ~al violations of the feel. narcacics Jaws, including,

but not limited to, TItle 21, United S1ateS Code, SectioDs 84.1~ 843, 846;md 848. I have received

special training in the eDfmccmeat of laws cemcer.mng controlled SlJbsbmces as found in Title 21
ofthe United States Code. I bave testified in judicial proceediD,gs and pro~OiUI for

violations ,of ~troUed substance laws. I also have bee11 involved in various typeS of elCCll'Oiuc

surveillance. md in the debriefing of defendEm1~witnesses, and infonDants. as We11a others

who haYe knowledge of the distribution and tnmsportalion of con1z011ed substances, and ofthe

1
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laundering and concealing of proceeds from ~ trafficking inviolaticl1 ofTitle 18, United

States Code, Section 1956.

4. In late 2010, Speeial Agl!ll1ts and Task. Oflicers ofthoDEA Evansville Post of
Duty Offi,ee, itlitiated an investigation intc th. illegal dtug actiVities of OCUviBDO RadriglleZ-

RamireZ and others, who, ~ believed ~ponsible fOttbe distribution of ~l1ed substances

thro.out the EwmJvi11e area This investigation ev~y led to the court aU'th0ri2ed

interception of multiple ce11u1a1' pbO!ies used by tbis~DD., and ultimately Confirmed that

these individuals were inVolved iU obtaining methamphetamine and cocaine from Texas, and

then distributing tb.o~ COlrtrolled sUbstances to individuals in EvanMlle. Indiana md

StttrouDdibg areas. As set forth in greater detail below, .through thiSinvestigat100, I leemed. that

SBOOVIA was a Dallas. Texas-bMed source of supply for Rodrlguez..J..arnirez.

S. Begimnng in January 2011, D£A !v~e 'receivedauthorlzatian to intercept

wire Communications ofR.Qdri.guez-Rmnirez and otbm involved in his drug trafticking

activities. As of the date of'UUs complaint, this court has BI1thorb'.ed intereeption of a total of
'. ,

seven cellular phones used by members ofR.odrigaie;z-Ramirez~s org8!li:lstiOD., including a total

of four celNl.ar phones used by Rod1iguez~RamireZbim..jf. Two such phones, Target Phones 6

8I1G '1 (mote tbUy described.ss cellUlar phones, usirag phone Dmnbers (812.) 305-7142, and (812)

305.7559,. respectively), ate CUEleD.t1y being iDtereepted by laW euforcement; Tmzet Phones 2·

and S were ph~ previously intercepted by'1aw enforcement tbs:t bad been used by Rodri~

Ramim (mare fully described IS cellular phones usins ph~ DUlDbers '(812) 3QS-7S11 and
(812) 208~6473).

6. Based on investigation to date. I k:now thai SEGOVIA is a source ofcocaine for

Rodri'gUe2-Ramit'ez. At approximately 3:28 p.m. on February 24,2011; 'RodrigDe2-Ra1:rI.ftz was

1_"
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intercepted over Target Phone's speaking "oilPith SEGOVIA. In this c:onversati~ SSGOVIA told

Rodriguez-Ramirezs "Little things rtte happening here." Rodrlguez-Ramirez asked, c~en: do

you think you'll have a cha:Dce to head out and get ~g? These guys are asking for some

'waters.·... SEOOVIA _ '1' m planning on tomorrow. Tomotl:ow. rm trYingta take at least a

half... ofa goat.ft Rodriguez.Ratmrez~,""Soundsgooci That'll be gone'in right away.... 1

belie:ve that in this converaation.SBGOVIA was telling RbdrlgueZ-.Ramitez that there were not a

I
I
lot of controlled substmc:es to be 'obtained down in Texas, and that his business ~f disuibuting
\
drugs was, slaw. RDdrigu=-R.8milu asked when SEGOVIA ~ going to be able to send a
I'
quantity of contrOlled S11bstan~ to him in EvausvUle. teniug SEGOVIA that many of his

I distributors did not have anything to sell. SEGOVIA mid RodrigUez-Ramirez tbat he hoped to

obtain a cha1fofa goat' (one hs.likilogram of.cocaine) the fOllowing day, and Rodriguez-

Ramirez then told SEGOVIA" tbat he would sell that amount pretty qUickly upoitits receipt

, 7. In facts Rodriguez·Ramirez did travel to Dallas. Texas within days following the

above summarized Fe~ 24, 2011 conversation, and ob'tafnecl coc8.ine Doni SEGOVIA. At

approximately 3:24 p.m..'on February.26, 2011~ Rodrl.&Uez..RamiIez was inteteeptecl over TBtget

Phone 5 ~ving an: incotning call from SEOOVIA. Dt.tring th1s call, SEOOVIA asked

Rodriguez.oRamitez,' -So,on me coming ,doWD, dude (would ltodriguez.Ramuez,'be traveliDg to

Texas to obtain controlled snbstanoes)'l'" R.odriguez-Ramirez ~ "Yea.b, \Vbat de you think?

Do you "Wmt me to 80'1 BCcmse these guys (Rodriguez-Ram.ilez's drug customers) have the

paper 90 I am leave today. Later in the evening." SEGOVIA stated, I~~ if you bri.D3 the

paper, then yes dlJde." Rodrip2-Ramirez said, wrhat's good. Then rn leave ill the evening. Do

you think it can be done in B. NiSsan Maxima?" SBGOVlA~. "Yes, bUt dcm..t say i~"

. can, {believe that Rodrlguez-Ramirez

During this . 'MIS p]8IlQ;ing e. trip 10 tbtDaUas, Texas sra.

-.. ~--~,
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to pick up the cqnt:rolled. substances from SEGOVIA. Rodriguez-Ramirez asked SEGOVIA if be

, should come down., and he told SEGOVIA that cthese guys' (cocain.e distribUtors in Evansville)

have tbe 'paper' (money tb8.t Rodriguez-Ramirez could Uge to, buy mote drugs). SEGOVIA told

I
him to oome do"M1 ifhe had the money to pay for past drugs acId to Rodriguez-Ramirez. Then.

Rodriguez-Ramirez asked if lit can, be done in a N"lSSa11 Maxima.) I believe that R:odriguez-
I Ram.ireZ W'8S letting SEGOVIA know that he was planning to drive a Nissan Maxima to Dallas

to pick. up the controlled substances, and wanted to make sure~ tbd it was possible to seem the
'

I
controlled 9ubstaDces imo some sort of trap or Datura! wid during tmrisport.
I 8.'· At ~1Y 7:42 p.m.; 011 Febnwy 26, 20'11, RODRIGUEZ-Ramirez was
I
I
, in~ over Target Phcme 5, placing an outgoing call to SEGOVIA.. During tl:Iis call,
,i

RODRIGUEZ-Ramirtz told SEGOVIA., .'1 tbiDk this guy didn't get the invoice (drug proceeds)

for the
,
car: He bSsn't called
. .me."
. .'SEGOVIA
. told RCdrlguez.oRsmi.re:z. uAJrlght Welt, I warmed

up aU this!' R.odriguez-Ramirez thal asked SBGOVlA,Dlt's 1'e8dy (did SBGOVIA have the

controlled ~bstmces awilalrle for him to get)?" SEGOVIA replied., "These &U)'S need you to
, "

hmre the money on baDd ~d thty'U have it (SeGoVIA was not willing to 'front' the controlled

substances on this occasion, Rodriguez..Rsmirez Wou1dn~ cash up front).," ~gveZ­

Rsmnz then stated, '.Alright.. ru wait mrt:il9:00for this guy (a remrence to Ricbnl ~
one ofRoc1.rigue:z.Ramirez's drug eusl:omers) to call tOe HDd ~ whet he says." In tbiscall, I

believe that Rodriguez-R:Bi:ni:rez was u~g SEGOVIA.. tel1iIlg SEGOVIA that his customer

bad. nat been br to rlrop off the needed drug money (eoDtrary to his promise earlier in the day to

do &0); and SEGOVIA. W8S ensuring that Rodriguez-Rsmitez tmdetstood be (Rodriguez-

. Ramirez) would need the money up front to ~ for any new quantities of drags he wanted to

,obtain.

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9. At approximately 10:07 pm.. on PebIuary26~ 2011, lodriguez-Ramirez W8S

intercepted eVe!" Target Phone 5 placing an outgOing can to BL no. During this can, EL no

asked Rod1"igue.Ramize.z "I'm here. What's the deal with m'Y~hew (SBGOVIA)?"

R~-~~~~~.~~~~~~~~~

Richard An:nstead) just bro. the paper,(money needed for the trip to see SEGOVIA in Texas

to obtain·more dragS) and rm leaviog now."

10. At approximately 10:30 p.m. on FebnJary 2~ 2011, suxveillance officers obsen'ed

a Light colored Nissan Altima depart RQdriguez-RJmdrez' apartment ca~Ptex. The vebiele was.

tbllowed a short dJ!lt'8nce~ until it was obsmred south boUDd on HighWay 41 enteting into

Kentucky. Per precision Iocaang infoImstioo received for Target Phone S, Rodriguez-Ramirez

appearedtD travc110 Tex~ leaViDg BV8DSVille, Indiana at approximately 10:30 p.m.. onFebruaIy

~6, 2011. Rodriguez..~ made tbis trip with two other iadiv:iduab: an indi~dua1 ~OWl1

only as'-Rau1~t1 md Dis girlfriend Maria Del Refugio Ramires--Maciss. On February 21, 2011, at

approximately 11:00 am., a cbeok ofTarget Phone S pet pn:cisicn locatingiDfmmation revealed

tJmt RODRlQtJEZ.Ramin:2 had mim into the Dallas, Texas area.

11. At approximately 3~3S p.m. on Februlry27,2011, Rod1igaez-Ratrdiez was

Urtercepted tMr Tapt Phone 5 p.ing a call to JU8D Juarez. During this oaIl, ~ .told
RODRIGUEZ-1bmrlre.z, "This IU1 is calliDg .me. How tnuehforthe -whole fridp, tI:te big CDS (a
&11 pcn.md of metbamphfltBmine)T' Rcdtiguez-Rmnitez ~licd. c'twmty_~ (522,000 pet pound

of methamphetamiDe)." lW!1'e"Z then. asked, 'COkay, what about the goat (cocaiDf!:)? J'ust lot half

(half a kilogram at cocmn~)." Rodriguez-Ramirez then told Juarez that there W8SD tt much dawn

there. Rodrlguez-R.amirez ~ ''Only ~ balls (ounces). Maybe 8.bout l~ ~ (18

ounces, or half a ldlogtam)." JtJa:reZ then tOld Rodriguez-Ramirez that be was going to have to

.......- - .. - " _ . , - _ _. _ ' 0 . _

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check to make sure the guy (unstated cltu:g customer) wanted the "fridse (the pound of

methamphetamine)." Rodrigue2-Ramirez told Juarez tOt "Tell him (the customer) to' let you

know for sure so I can take it ftoin here. Tell mID. to at least give us 21 (the cost of the pound of

methamphetamine would be at least S21,OOO).~' During this ca11, I believe that Rodriguez-

Ramirez was telling .nJAREZ dmt there wun't much cocaine available from SEGOVIA, and

that it was ahead.y packaged into ounce quantities. RDdriiuez·R.ami1'CZ told juarez that ifhe was

sure that the uatlamed drng cnstomer ~ the pound ofmethamphewnine, to let him, know

and he would transport it from the DBIlas ares. to Evansville.

12: ' ~t ,approximately 4:51 p.m. on February 27, 2011.R.odriguez-Ramirez was

intercepted over Target Phone 5 receiving a eall from J~. During this call, Juarez told

RodrigtteZ-R.amixez, CIYc~ bring that (Juarez bad confirmed the urmamed drug customer

~ed the pOUDd.ofIDetbamphaamine).n Juarez eontiJm.~ '''It's a sure thing. aDd I thiDk. that

be told me timt..:thosejust put a price on those ~ec:es (the ounces ofcocaine they had diSCU3sed
approximately an hour earUx) 'you're bringing and it's a done dea]," Rodriguez-~

replied, "alright, ~.lOO eaCb one ($1,100 per Dun" of cocaine).'" During this QS)J.l beli~ that

Juarez was eonfirmtng with Rodrl.guez.Ra.crlrez that be 'WBS to bridg back ~ CODb'Ol1ed

substances and ~ Rochiguez-RarniIu what the price per ball wouJdbe for the ~pieces.'
,.13. ,A~ appmxi.mately 4:57 p.m. on Fe'broarY27, 2011, Rodriguez.'Rimi:rcz was

intercepted over Target'Phone S placing an outgoiDg call to SBOOVIA. During the call.

Rodriguez-Ramirez u1c:edSEOOVIA if they coul~ "[unintelligible] the l"Wef1ty..two ldnd. man. 1

was wondering ifyciu could b1iDg by anOther one (could SEGOVIA pt'OVide lloQriguez.Ramirez

with mother pound of methamphetamine)." sEGOVIA told llodriguez-R.am.ire:z tbat be 'WaS

going to come to bis locatiOlL ! belieVe that based. ':lJ'OD the previous c:onvematiODS" Rodriguez-
i
i ,6
I

I
1._-, '.. .
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Ramirez asked SBG9VIA ifhe could receive an 8d~tioaal pound of mcthamphetamin.e. Due tel

the fact that SEGOVIA did not wish to have that conversation"over the phone, he told

Rodriguez-Ramirez that he would come to his looation and taik: in Person·

14. On ~ 1, 20 t 1. based on iirtercepts as well as precision location data far
T.arget ppone 5, Rodrlguez.Ramire:z and others were detetmiDed to be en route from Dallas to
, "

Evansville dril'itig a 1igbt gteCE1 colored Nissan Altima with an unknown quantity of cocaine and

metbamphetamiDe. At approximately 1:10 p.m. that ~ Rodrigaez-Ram.U:ezwu ,

iD.~ over T~ Phone S talking to his cocame customer, Richard Armstead. .During this
call, Rodriguez-Ramirez told Ar.t;nst~ '~ ... chi.Uin. tight now. Wsiting for leave tonight.".

Armstead 8!ked R~drlguez.Rmnirez,'·Okay. EVQ)'thiDg is gaoet (had Radrigu~.Ramirez .

obtained. the drugs tbst A!m~ wamed to purobase from Rodriguez-Ramirez)?" R.odriguez-

Ramirez tOld Armstead, "Yeah. Yeab..Everytbirtg is IOod.'~ Armstead asked Rodriguez·

Ramirez. "'Okay. So...Two? Three (how much cocaine had Rodriguez -~ obtained. two
Ol'"three kilc,grsms)r Rddriguez-R.ami:rez mused to cbuify" teUmgbim, "Yeah:' Armstead "

then asked. Rodriguez-R.mW:ez. ""Okay. Alright. Um... So wheEl? It'd be totDon'OW moming~

Rodriguez -Ramirez told ARMSTEAD "Yeab. CaD. me in the momiq, or rn call you."
. IS. . At ~9:0fi a.m., on M8rcb. 2, 2011. ~ ~ed Rodriguez-

:R.amirq at Target Phone S. During the ean. Rodrlgoez-Ramire2; inforined .AmIstead. that he was
a~ to atrlve at his reside.acc~ Armstead and ,Radriguez-~~ agreed. tbat~ would .
" .
meet at Rodngbez-Rami%ez' residence in thirty minutes. At appraxirtts.tely 9:18 Lm. oD March

2. 2011 ~ sarveiJlan<:e ofBcezs DbsC'Ned the same Al1ima that had been ~ ~ leaving

EVansville on Febrwuy 2~, 2'011.attrive at 3301 W~D Aveaue (Radri&lJez-Ramirez'

apartr:o.ent). Su:rvdlJaace offi~ obServed Rodri~:Ram.ira retrieve a da%k cOlored. dutrel

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bag from flle tnmk of the vehicle and enter into his apartment, followed by Target Subjects

Ramires-Macias andtlJUul." ,

16. At BI'PIOximately 9~3S un,. on March 2, 2011, survei1lanceofti=rs observed

Armstead driving a white Chmolet 1mlb1azer wm on Washirag'tem Avenue.toward Rodriguez.

Ramite:z' residence. At approximatelY '9:42 a.m., Armstead was SUiWiUed miving at

, RodrigUeZ-Ramirez' apattm.eDt complex, and· s~ entering Rodtiguez-Ramirt:z' apartment. ;,.,t
. approximately 10:03 a.m. on March 2,2011, surveillance offiee:rs observed 8 tan colored

Mercedes Benz being driven by Eric Baker atrive at Rodriguez-Rsmi:teZ' IeSideDce.

, .
Surveillance otliCI!:l'S observed Baker exit the MereedClsand enter intQ Rodriguez-Ramirez'

apartment. At approximately 10':28 a.m., su:rve:illan~e officers observed Baker' cxitthe

apartment, enter his vehicle, and leave the area; Atmstc:ad left theapamnen:t two min~ after

that, and he was folloWed back to his ,miden~ 712 South Bmtbardt in E'\rabSville.

17. Slirvei1laade'ofllcers were watcbiDg ~'s Iesidence tbB.t moming CvWcb ~

2011), and at approximatel}" 11:17 a.m., Bam"! Mercedes ~ seeziparked at ~'s

resi~ 112 S~ B~ A1.lppIOxinmtely 11:45 aJIL, Arms1ead and Bakm' ~

survet11ed as they exi'll!ld Am:IStea4's residence and entered Baker's MeIcedes. 1)ey were
followed back to Delaware Tmce apattma1ts. At ~ 1;42<pm. 011 Match 2, 2011, a
. '

white Toyota Cmmy mived atth~ apartmeat complex and badcecl into Ii parking space located

near Baker's Mercedes. An unidentified blsclc male (UM) exited·the vehicle, 8Ild went into the

apartment, leB'YiDg a black female, later identified as Sbeftcll Lesch, in tbe vehicle. At
. . I ·
approximately 2:00 pl'I1., Q gurvci11ance o·ft'icer saw Amastead... BaPt. and the UJ1i.c1em:ified ,black

male e:dt the apartment and waDe toWard tbevebic1ea. A1 aPvtQ~lY 2:08 P'.IJL, both

vewcles exited the apllrtnient c:otI1p1e'x wi~,Baker, ArmsIead. and the t1M in the.Mercedes, aDd
B

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Lesch driving thewtUte vehicle with no pass~. Both vehicles traveled in tandem to

Annstead's residence, where: they stopped just long enough to drop off A.r:mstead. Prom there,

the two vehicles continued traveling in tandem, witb the Mercedes as the lead vehicle..

18. Survei11tnce officers iD8intBined observation ofthese two vehicles, fot

approxime.te1y fifty miles as they 'continued east on 1-64. At approxitDatety 4:00 p.m.~11 tratlic

stop was initiated by the Indiaaa State Police on the ~ driven by Leach. During the C01J13c
ofthe stop, Troopers asked Leach if she was in POssessi011 of my lege m:c:Qunts of US Currency

or cocaine..She stated that there was a quantity of ~e ~ the bag 011 the front. seat passenger

floorbo&rd ofher vehicle. 'troopm located the beg in the vehicle and iDside the bag he

discoveted 'approximately thret: polDlCls of wbatfield-tested positive as cocaine. Troopers tlW:o

tookLeachmto custody.

19. Buedon all a/the events ofMareb. 2, 20"11,1 be1ievetbatRo~lRamirez

had traveled down to Texas the eveniDg ofFebrumy 2, 2011, and,~ed. 'With cocaine he bad

obtamed from SEGOVIA, the moming of Msrch 2, 2011. RoQriguez.Ram.irez then distributed.

that cocmne to Amsstead and Bakert "Who in tum sold three pounds oftbat cocaine ~ LeaCh and
the male with whom she had traveled..

20. On Marcb 12, 2011., law ettfcm::ement inte.rcept!da ea1i bet~ J.odri~

Ramirez ~, his ~Jfriend, Matis. Del' ~CUgio Macias-Ramires Over Target Phone S. DurirJg the

conversation, Macias-Ramires advised ·Rodriguez-Ramirez advised that"Camal" (SEGOVIA)

bad arrived. at their apartment.·~-Ramitez then asked'"Wb8t did,he come in?" Macias- .

RmUreS "In a van. ,The one we came in." A short time later, Rodriguez-RamiIez was

inteLcepted speaking with JUoanlZ OWl" Target Phone S. DuriDg tbe 'call, ~Ramirez told

J~ "t's that ElCamal arrived. e:nd 1 don't know what's up. So I need to see what's up.
. ' .

, .. _._--_ -.'-'--., '., . --._

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Fucking guys (drug customers) haven''\: called you, rightrJuarez replied, -No, I'll give them 8

call now. Now, I'll send the dudes messages or call the.m. lt Rodriguez-Ramirez then stated,

"Fucking Chino, what happen~d with his cous~ the dude too. moth«fucker, makes me look

bad, the dudfl." I believe 1n this call, Rodriguez-Ramirez ~ telliDg Juarez that he had received

an unexpected visit from' SEGOVIA, and was as yet unsure ofwhySEOOVIA was in town.

Rodriguez-Ramirez was further relaying that be was upset t'bat their dNg customers wtre-not

purcbasmg the drugs (or.paying for than) in a timely lDSJU1et.

21. Surveillance was then conducted CD. Rodriguez-Ramirez' apartment. wlJae Blight

colored Honda minivan bt:aring Texas phlte (CD1Y831) '\VIS observed parked. near Rodriguez-

Ramixez' apartment. The registration on thE! Honda returned to Juan ~c SEGOVIA at 24~S

Clint Ct, klington. Texas. Surveillance officers observed SEGOVIA, as well as his wife and.

two small children, as they ~ga.ted outside ofR.odriguezoRamirez' Bpartm.ent. A short time

later; R.odriguez.~pu11ed upJto the &p8rtmmt and met"with SEQOVIA. Based on ~

inter~ I believe that one ofthe plUposes oftbis visit from SBGOVIA was to colled overdue

drug proceeds, which Rodriguez~Ramixez bad previOusly promised to SEGO~ that be WDUld

bring dOwn 10 Texas on his next trip'there.

22. .More .recently, on March ,26, 2011, .R.odrigaez-Ram.irez md SBGOVIA. spoke

over Taqet Phone 7. IDtbat call, ~Ramirez repottecl

. ihatbe was going 10,. a~e by
.

the ranch. (go to Texas to see SEGOVIA and get cooEline from hittl)." telling SEGOVIA. "l don"t
. . I I

have my ~ for the horses (RocIrigue'z-Rsmitez, who does not own any horseS, ,needed more

cocaine to seU to his customers)." ~ision location iJ:aformaticm fox'Target Pheme 7

demODBtr8teS that :Rodri~z-Ramirez trAveled to Texas aD March 27, 2011.• Bued on this fa~ I

believe that SEGOVIA and ROOriguez-Ramirez contim1e toeogagein a conspi:racy to distn17Ute

. 10

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Case 3:11-mj-00131-BH Document 1 Filed 03/31/11 Page 12 of 12 PageID 12

cocaine.
23. Based on the information contained hereiD.I believe there is probable cause to

beliew the.t beginning at a date UDbo~ and continuing up to cd including Much 28. 2011,

SEGOVIA engaged in a conspim:)' to possess with the inUmt to distribute SOO grams or more of

cocaine, in violationofTltle 21, United States eocle, Sections 841 and..846.

Si~~sUbscribed to before me.

on " ' ofMtm:h, 2011.

~~(
United States
Southern Disttiet of'Indiea
. .

"-

j 11

I
\_-'. . ....,... '