Professional Documents
Culture Documents
state:
SUMMARY
PURPOSE OF AFFIDAVIT
herein are related in part and, except where quotation marks are
-2-
statements made or reported by confidential informants; (c)
party; (d) documents and records received by the FBI; and (e)
records.
. . .
-3-
form of Federal assistance, . . . shall be fined under
North and Independence Avenue to the South, and Salt Lake Avenue
company and bought a 2,777 acre (11 km²) ranch east of Los
Angeles. Cudahy subdivided his ranch into one acre lots and sold
-4-
the city’s population graduated high school and only ten percent
Vice Mayor and three City Council members who are elected at
community.”
www.cudahy.ca.us:
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a. SILVA is the Mayor of Cudahy. (A copy of the
January 2012 through March 2012, the Mayor of Cudahy was current
April 2012, SILVA was elevated to Mayor, and City Council member
Frank Gurule became the Vice Mayor of Cudahy; CONDE and Barrios
-6-
environment, carry out land use policy, and preserve the quality
the urging of President Barack Obama, who signed it into law four
days later.”
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c. The goals were to be achieved by “providing $787
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Lake Ave.”
Exhibit D.)
1
The CI related that a high-ranking official in the city
where the CI’s dispensary was located had solicited bribery
payments from the CI, and that the CI had paid more than $10,000
in bribes to that official over the course of several months.
After the CI reported the bribery scheme to the FBI and became an
informant, the CI received a notice from the city requiring him
to close his marijuana dispensary. The FBI instructed the CI to
sever all ties with his marijuana dispensary by mid-March 2012.
The CI informed FBI agents that he had sold his marijuana
dispensary. I am informed that the CI was present at the
marijuana on or about May 14, 2012, when the dispensary when city
officials performed an examination at the dispensary.
2
Based on my familiarity with this investigation, I know
that Coronado’s position as Cudahy City Prosecutor is a part-time
contract position. According to the State Bar of California’s
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At that time the City of Cudahy had a moratorium on the
conversation.
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Cudahy. The conversation then turned to politics in the City of
Cudahy.
PERALES: Yup.
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good.
CI: Yeah.
PERALES: Yeah.
PERALES: Yeah.
3
References to “o/v” refer to overlapping voices in a
recording.
4
Based on my familiarity with this investigation, I know
that George Perez was Cudahy City Manager until late March 2011,
when he was terminated after approximately eleven years.
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left there was, you know, a need for
Conde? Or -- <o/v>
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CI: Oh. Yeah cause I, I only know the last
names, I -- <o/v>
PERALES: Yeah.
--”
CI: Geez!
-14-
Coronado: Um, one of the reasons that we’re here too.
PERALES: Uh, they asked me how long did you put the,
dispensaries in Cudahy].
March.
Coronado: <unint>.
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dispensary in Cudahy]?
CI: Uh-huh.
<o/v>
CI: Exactly.
people.
<o/v>
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kidding aside --
leaves table.>
dispensaries].
dispensary in Cudahy].
get it?
-17-
Coronado: <unint>
this.”
CI: Mm-hmm.
friend.
CI: Right.
PERALES: <unint>.
PERALES: Yeah.
CI: Mm-hmm.
-18-
goes, “Hey, I’m getting serious about this.
CI: OK.
law?
CI: Mm-hmm.
PERALES: Here.
CI: OK.
the --
is worth a shit.
council.
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for reelection and, just between you and I
--
donations.
CI: OK.
PERALES: Right.
CI: OK.
CI: Mm-hmm.
CI: Mm-hmm.
CI: OK.
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Coronado: Yeah, they don’t have any outside income.
PERALES: Right. So --
CI: Uh -- <o/v>
CI: OK.
CI: Right.
problem.”
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Coronado: I would do this. I would do this. I
CI: Mm-hmm.
money.
basis.
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at, just to have an idea?
CI: Yeah.
dollars].
PERALES: Yeah.
SILVA].
CI: OK.
OK?
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wouldn’t even be asking I just wanted her
to come.
mention.
CI: Mm-hmm.
<o/v>
CI: OK.
CI: Mm-hmm.
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think you guys should talk privately. You
guys discuss.
CI: Haha.
PERALES: Osvaldo.
Garcia: <unint>.
Coronado: Osvaldo.
dispensary]?
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CI: Which one of those two will be -- <o/v>
point.
decide this.
PERALES: No one.
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And I think that’s where it’s going to be
religious.
oppose to -- <o/v>
<o/v>
- <o/v>
-27-
. .
dispensary in Cudahy.
there.
Coronado: I know.
CI: Yeah.
CI: Right.
PERALES: He’s, he’s the one that, he’s been the, uh,
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took George [Perez] down.
exposed everything?
<o/v>
make a move.
CI: OK.
CI: Uh-huh.
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<Discussion of job performance and alleged
manipulate them.
Garcia: Yeah.
Garcia: Uh-huh.
CI: Uh --
. . .
in Cudahy is Conde?
PERALES: Uh-huh.
me.
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PERALES: I’m, I’m gonna tell you this -- <o/v>
CI: Uh-huh.
your pot. . . .
together as a collector --
CI: Um-hum.
then?
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Coronado: OK. I’ve dealt with Conde on a personal
CI: Yeah.
Coronado: Yeah.
CI: Yeah.
PERALES: So -- <o/v>
secrets -- <o/v>
PERALES: Exactly.
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Coronado: Dude, that’s the difference -- <o/v>
CI: Wow!
<o/v>
PERALES: And think, and you know who, who, who uh,
CI: Um-hum.
<o/v>
PERALES: No.
5
According to elections information website
www.smartvoter.org, CONDE finished third of five candidates in a
March 6, 2007, election for three of the five seats on the Cudahy
City Council. CONDE received 472 votes. The candidate who came
in fourth place received 439 votes. Accordingly, CONDE remained
in office by a margin of 33 votes.
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CI: -- say, “Hey, look, I really appreciate
that”?
election].
CI: Oh.
Coronado: Yeah.
him hard.
CI: Um-hum.
making it happen.
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Coronado: Oh --
Coronado: Yeah.
CI: Yes.
PERALES: Yeah.
altogether --
CI: Um --
dispensary in Cudahy.
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half million dollars.
PERALES: Yeah.
CI: <Laughs>
Garcia: <Chuckles>
-36-
PERALES: <Chuckles>
PERALES: Yeah.
PERALES: Yeah.
Garcia: <Chuckles>
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other massage parlor in the ten mile
Garcia: Yeah.
my building.[6]
6
On April 11, 2012, the CI met with CONDE at Mazatlan
restaurant in Paramount, California. The meeting was audio
recorded. The meeting was conducted in the Spanish language, and
I have reviewed a recording of the meeting. During the meeting,
CONDE described a “massage parlor” business he would be opening
several partners, including PERALES. CONDE described the
location of the “massage parlor” as on “Atlantic and, uh, between
Cecilia [Street] and Santa Ana [Street].” CONDE stated that the
“massage parlor” would have twelve rooms, including “one room
with a jacuzzi.” CONDE answered, “I imagine some fifteen,” in
response to the CI’s question, “And how many girls do you plan to
have there?” CONDE thereafter described and, using a pen and a
place mat, diagramed the partnership and the physical layout of
the “massage parlor.” In response to the CI’s inquiry whether
there would “be sex from, from, from morning to evening,” CONDE
responded, “Yeah, yeah.”
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well, how many buildings you own?
dispensary] up there.
-39-
free.”
CI: Yeah.
business for --
over here.
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CI: Yeah, because that’s a cash business.
PERALES: Yeah.
. . .
dispensary in Cudahy].
CI: Right.
everything.”
CI: Wow!
Garcia: <Chuckles>
PERALES: Yeah.
margins omitted.>
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there. Yeah.
PERALES: Right.
omitted.>
he came in.
County].
there. Yeah.
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PERALES: Yeah. So ‘cause watch, I know his number,
relieved. Yeah.
possible. . . .
called the CI, in response to several calls from the CI. The
meeting with CONDE and SILVA that PERALES had arranged for the
next day.
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CI: All right. 12:30. And, uh, eh, do you
Silva.
CI: Uh-huh.
PERALES: Yeah.
PERALES: Yeah.
30. PERALES then discussed another person who, like the CI,
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marijuana dispensary in Cudahy. PERALES informed the CI that
PERALES inform him how much he should offer to pay CONDE and
the CI, on the one hand, and CONDE and SILVA, on the other.
CI: Uh-huh.
CI: Right.
PERALES: Um, this other guy came in on, on, on, uh,
PERALES: Yeah.
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PERALES: But these guys don’t want shit like that.
CI: Exactly.
PERALES: Those are the ones that, uh, the ones that,
PERALES: Uh, you know, you can, this is the way you
be there.”
CI: OK.
PERALES: Now --
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PERALES: -- there’s, there’s a lot of people trying,
works.
PERALES: Uh-huh.
CI: Now, um, well, I’m sure that also you have
with anybody.
CI: Yes.
-47-
CI: Exactly.
happen.”
CONDE and SILVA, and that CONDE and SILVA were not interested in
-48-
PERALES: You know, and once you get your thing and
CI: I see.
CI: So -- <o/v>
true.
PERALES: Right.
PERALES: Right.
-49-
SILVA that he was willing to “make contributions to the
were the city councilmembers who “have the votes” and “control
everything” in Cudahy.
CI: OK.
CI: Hello?
PERALES: Yeah.
CI: OK.
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don’t mention how much money, because
CI: OK.
CI: OK.
I’m willing.”
contributions.”
PERALES: Yeah.
CI: I’ll, I’ll use that then. And, uh, OK, and
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Yup!
PERALES: Yeah.
PERALES: Yes.
34. On January 27, 2012, the CI met PERALES and CONDE and
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CI: All right? Oh, great. OK. Well, listen,
restaurant?
CONDE: Yes.
in Cudahy. PERALES told CONDE and SILVA that the CI wanted “open
CI “that right now we have a good program,” and that the CI had
there.”
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he has a chance, to open up something there
make it happen.
CI: Mm-hmm.
CI: Mm-hmm.
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CI: Yes, yes, yes, yes.
CI: Yes.
. . .
support. Mm-hmm.
CI: Yes.
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CONDE: -- eh, sometimes we think a little
differently, eh?
CI: Mm-hmm.
CONDE: And --
CONDE: Yeah.
CI: Yes.
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nothing on, on paper.”
CONDE: Eh --
CI: That --
CI: Mm-hmm.
you know--
CONDE: Yeah.
understand?
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CONDE: Oh, I mean, wi-, within what, what, what,
CI: Mm-hmm.
CI: Yes.
CONDE: Yeah.
twenty guys.
CI: Yeah.
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[no gratuities are paid]. ‘Cause of
on, on paper.
CI: Mm-hmm.
give the CI the “bottom line,” after which the CI asked CONDE to
“cut to the chase” and tell the CI what it was “going to take,”
dispensary in Cudahy.
understand?
CONDE: Yeah.
CONDE: Uh-huh.
the table.
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CI: Mm-hmm.
understand?
what -- <o/v>
CI: Mm-hmm.
CI: Yeah.
-60-
take to, to be one of the two? You tell
truth -- <o/v>
- <o/v>
CI: Mm-hmm.
<o/v>
but -- <o/v>
-61-
three people, for example. You hear the
too.
--
which the CI stated that he would be ready to open soon, and that
something along,” but that he could not “give [the CI] a number.”
CI: Hmm.
-62-
PERALES: -- how bad do you wanna be number one or
number two?
<unint> --
direct -- <o/v>
PERALES: Eh --
PERALES: Yeah.
--
PERALES: Right.
CI: Yes.
-63-
cost you this much.” And, time is money.
CI: Yes. Oh --
<o/v>
<o/v>
understand?
CI: Yes.
CI: Mmm.
CONDE: Yeah.
-64-
CI: What is it going to take for? I mean, for
--
CI: -- <unint>
help to -- <o/v>
CI: Yes.
CI: Mm-hmm.
CI: Mm-hmm.
--
CI: <unint>
-65-
offer you this,” you understand? I mean,
example -- <o/v>
CI: OK.
CI: Mm-hmm.
CI: Yes.
CI: Yes.
<Laughs>
-66-
CONDE: <Laughs>
CONDE: <Laughs>
CI: <unint>
--
CI: <Laughs>
<o/v>
<Laughter>
So -- <o/v>
understand you.
right door,” and that he and SILVA were “the leaders” and “were
-67-
understand? They want -- <Laughs>
everything --
CI: Mmm.
understand? Because--
CONDE: Yeah.
well.
<o/v>
-68-
-
CI: Yes.
along.
CI: Yes.
understand? I mean --
CI: Mm-hmm.
of the conversation.
-69-
had with CONDE concerning bribe payments from the CI.
going to be --
CI: Yeah.
CI: Yeah.
councilman.
CI: Uh-huh.
CI: Alright.
-70-
bit more and you will get lot less, but
or what?
tell me that.
-71-
choices. Is it going to be [CI’s first
now?
CI: Yeah.
-72-
CI: So, does he [CONDE] want some money now or
yet?
-73-
and going to throw the clients to us.
so far.
day.
PERALES: Yeah.
-74-
PERALES asked the CI how much he expected to make and suggested
work.
CI: What?
percentage.
of unfair.
-75-
no one to worry about until <unint> no one.
PERALES: Let me tell you, you know how much you will
be making around?
sure thing.
CI: Yeah.
that is it.
-76-
are counted?
CI: Yes.
CI: Uh-huh.
now?
CI: OK.
-77-
Coronado, Cudahy’s City Prosecutor, and that PERALES previously
would have easily gotten the money back in the form of a higher
PERALES: Yeah.
PERALES: Nothing.
PERALES: Yeah.
doesn’t prosecute.
position right?
-78-
PERALES: Yeah.
month.
it to him <unint>.
CI: Yeah.
bye.”>
PERALES: <unint>.
. . .
-79-
You got to invest in shit. You have to
invest in things.
right.
evening, Rojas and Alcala brought drinks and women, from both the
7
According to the CI, CONDE informed the CI that he
carries a firearm at all times.
8
According to the CI, the women being provided alcohol
included a 17-year female subsequently identified by agents as
A.T. (The El Potrero nightclub is an “18 and over” club with a
“21 and over” section.)
-80-
conducted in both the English and Spanish languages, and I have
of the conversation.
Cudahy.
as a bribe].
PERALES: Yeah.
more then.
-81-
CI: Uh-huh.
to the CI that CONDE wanted the CI to pay SILVA less than the CI
CI: Uh-huh.
CI: OK.
PERALES: He --
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to me, a straight up. Uh -- <o/v>
PERALES: Yeah, let’s say, and he, let’s say you, uh,
percent.
-83-
PERALES: No, no, we’ll, we’ll, we’ll give, what he,
us, per se --
PERALES: Uh-huh.
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PERALES: Don’t, don’t, don’t, don’t uh, do the
. . .
PERALES: Uh-huh.
“Hey, here.”
PERALES: OK, um, this is, this is what I’m gonna do.
CI: OK.
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PERALES: Tomorrow, I, he comes, he’ll come in [to
CI: OK.
CI: OK.
their way.
CI: OK.
CI: OK.
-86-
PERALES informed the CI that CONDE said that he hadn’t “thought
about it, but . . . wants to, to be, uh, reasonable” about the
that CONDE and SILVA wanted monetary payments only. PERALES also
CI: But tell me, how’s, uh, what, did you talk
to Conde?
-87-
week or the following week.
uh, reasonable.
right?
PERALES: Yeah.
name], uh -- <o/v>
what I mean?
-88-
CI: Yeah, yeah. <o/v>
PERALES: Yeah.
those -- <o/v>
PERALES: Yes.
PERALES: Right.
‘cause, <o/v>
<o/v>
PERALES: Yeah.
impress him.
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PERALES: Yeah. No, no, well you see, the, the, the
CI: Uh-huh.
[Coronado] did.
PERALES: That --
Here.
CI: Uh-huh.
-90-
I don’t need a fuckin’ laptop, I need
cash.”
CI: <Laughs>
<o/v>
reiterated that CONDE and SILVA wanted cash payments from the CI.
-91-
PERALES also explained that the purpose of his role “in the . . .
PERALES: Right.
me.
the CI].
-92-
CI: Yeah.
PERALES: Yeah.
at you.
CI: OK. Uh, so, oh, oh, OK, so what, what, OK.
-93-
Let, let me, OK. You’re right, I’m not
PERALES: Yeah.
amount, dude?
you said.
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the middle of everything? ‘Cause I told
CI: Uh-huh.
to do. OK?
<o/v>
-95-
“You cannot be in the fuckin’ front.”
fuckin’ deals.
CI: Uh-huh.
PERALES: No --
-96-
methods by which bribes had previously been paid to city
officials in Cudahy.
Number One.”
CI: Uh-huh.
the end.
run brotha’.
<o/v>
-97-
PERALES: You know, how, how much, how much is it,
CI: Yeah.
CI: Uh-huh.
that he would put money in envelopes and pass them to the city
PERALES: Yeah.
-98-
CI: “This is for you and, and, um,” OK, w-,
PERALES: Yeah.
PERALES: No, put it this way, OK? I’m not, I’m not
CI: Right.
CI: <Sighs>
-99-
you’re looking at one or two, or for, five
something, ‘kay?
CI: Um --
moratorium is done.
CI: Right.
-100-
you? These fuckers are already aware.
or number two.”
CI: Uh-huh.
you.
CI: Right.
and PERALES.
-101-
this, OK? I’ll try to get a, a, fuckin’,
whatever.
CI: Uh-huh.
CI: OK.
PERALES: OK? And then you give me, you give me, uh,
CI: OK. You got it. You got it. OK. Sounds
PERALES: Yeah.
then.
set it up.
-102-
the English language. The bracketed language is my
“the envelopes” and that CONDE, SILVA, and PERALES would each get
them to “consider” the CI and a second for the City Council “to
pass it.”
PERALES: Yeah.
to him.
or give it to individually?
-103-
mean if you think I, ‘cause what I was
me.
you!”
I mean --
-104-
you giving them each?
CI: OK.
-105-
CI: Yeah, but now do you think they’ll ask me
-106-
Administration (“TSA”).
64. During the meeting, the CI told CONDE and SILVA that he
help [him] get my license for the city. That's the only thing I
them for taking the time out of their schedules to have the
meeting.
-107-
issues. I want you to guarantee me that --
PERALES: Yeah.
PERALES: Yeah.
CI: Yes?
CI: OK.
CI: OK.
-108-
CI: Yes, yes, yes, uh.
<o/v>
CI: Uh.
Cudahy].
CONDE: Uh-huh.
to --
-109-
CI: You understand? Then, uh, well, then let's
CONDE: Uh-huh.
-110-
<Chuckles>
in pain.
laughter>
the needed third vote would be. CONDE assured the CI that he and
SILVA were “leading the group.” SILVA agreed, adding that he and
CONDE were the “big ones.” Later, CONDE added that, although
Josue Barrios was then the Mayor of Cudahy, he and SILVA “put”
<o/v>
permitted to in Cudahy]."
-111-
I mean --
PERALES: <unint>
group.
CI: Mm.
like that.
it's like --
-112-
the support for the rest.
SILVA: Uh.
<unint>
CI: Yes.
-113-
mean, if the-<o/v>
mean --
CONDE: No.
CI: Uh-huh.
CI: Uh-huh.
. . .
CI: Oh!
-114-
CI: Uh-huh.
mayor.
CI: Uh-huh.
mayor.
CI: Uh-huh.
. . .
CI: OK.
CONDE: So.
CI: Uh.
you understand?
-115-
CI: Yes, uh.
. . .
CI: Uh-huh.
<Chuckles>
CI: Yes.
. . .
up.
CI: Yes.
CI: Yes.
-116-
CONDE: Others have constructed <unint>, you
understand?
CI: Uh.
CI: Uh-huh.
CI: Yeah.
CI: Uh-huh.
outside the nightclub and observed PERALES meeting with the CI.
-117-
FEBRUARY 28, 2012, TELEPHONE CALL WITH CONDE
paid SILVA, and that the CI had additional bribe money for CONDE.
-118-
That’s why -- <o/v>
me.
CI: OK.
-119-
surveilled by agents, including myself, and it was audio
stills from the meeting are attached hereto as Exhibit E.) The
placed the Cudahy City Attorney and the Cudahy City Manager in
their positions.
CONDE: Yeah.
-120-
CONDE: OK, we’ll go outside to the car.
I mean --
CI: Yes.
CI: Uh-huh.
all that.
person too --
of each one --
CONDE: Yeah.
-121-
CI: -- so nobody’s feelings would get hurt, you
CONDE: Uh-huh.
CI: Yes.
you see?
-122-
bring all these ideas.9
CONDE: Uh-huh.
CONDE: Yeah.
CI: OK?
9
Immediately following this discussion, the CI asked Rojas
whether there were “many code enforcement violations . . . in the
City of Cudahy.” Rojas responded, “I wouldn’t know, you will
have to ask, uh . . . .” Then, after the CI interjected, “Oh,
Angel,” Rojas added, “Yeah, my department is something else.”
When the CI then asked, “Oh, and what do you do?,” CONDE
interjected and said, “No, the -- the usual, the usual . . . .”
-123-
CONDE: No, I’ll just tell you. Uh, the others are
CI: Yes.
After greeting SILVA and thanking him for having met with the CI
discuss the matter over the phone. The CI then told SILVA that
-124-
"We'll talk later." The CI asked Silva, "I have your vote,
italics.
know?
to PERALES, who had called the CI earlier the same day. The
-125-
of the conversation, which was conducted in both the English and
he had spoken with CONDE and SILVA after the CI’s March 2, 2012,
CONDE and SILVA anymore. PERALES also told the CI that CONDE
demanded that PERALES count out, before CONDE and SILVA, the
yesterday.
-126-
anymore.
CI: OK.
CI: No, no, I did not, bro, what I did is, uh,
so --
dispensary]?
CI: No, no, no, no, the only thing I, no, bro
PERALES: Right.
-127-
CI: The only thing I told him was that if he
Alright bro.
PERALES: Yeah,
-128-
weeds for his, whatever he said, for his
kind of <unint>.
each other.
. . .
mind.
me.
-129-
CI: Who was upset with you?
PERALES: Conde.
front of us.”
CI: Ahh!
PERALES: No, no, don’t worry about it. You know but
-130-
demeanor, his greed is going to get you
And, uh --
PERALES: Yeah.
me giving it to you?
envelopes remember?
jacket.
PERALES: Yeah.
that.
10
As described above, the envelopes were each marked.
-131-
get you the application, and that way we’re
good to go.
PERALES: Right.
money.
back.>
-132-
PERALES: Like I said, don’t worry about it, bro, but
application?
dude?
PERALES: Yeah.
PERALES: No problem.
76. On the evening of March 24, 2012, the CI met with CONDE
evening, CONDE gave his firearm and his Cudahy City Council badge
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to an unknown female (“UF”) who was accompanying CONDE that
Potrero club, and she was served drinks from CONDE’s table
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ROJAS: It’s nothing personal, but I can’t look
nothing.
wrong.
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ROJAS: Everything is good. It’s gravy. Me? It
else.
to say --
. . .
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be taken care of, I could be a totally
hostile environment.
said, “No.”
CI: Yeah.
11
I interpret this statement as Rojas indicating a
willingness to commit violent acts that would result in him
serving a prison sentence up to life imprisonment. I am familiar
with Rojas’ criminal history, and I know that he has previously
been arrested for accesory after the fact to murder.
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world. But if you get made into a martyr -
. . .
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have everything that I stand for to contend
. . .
call to the CI. The conversation was audio recorded, and I have
the conversation.
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CONDE’s conversation with PERALES about “errors” in the handling
envelope...”
CI: Mm-hmm.
[thousand dollars].”
CI: Yes.
CI: Right.
envelopes?”
CI: Yes.
one out.
CI: Right.
envelope].
CI: Mm-hmm.
other words --
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CI: Yeah, that’s fine.
five -- <o/v>
yes, yes.
small failure.
with Angel.
CI: Mm-hmm.
because -- <o/v>
CI: For me, yes. The truth yes, but uh, uh, in
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other words, You know, because I also
that.
him?”
later, yeah.
CI: Right.
CI: Mm-hmm.
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