AO 91 (Rev.

02/09) Criminal Complaint
UNITED STATES DISTRICT COURT
Ior the
¸¸¸¸¸¸¸¸¸¸ District oI ¸¸¸¸¸¸¸¸¸¸
United States oI America )
)
)
)
)
v.
Case No.
Defendant
CRIMINAL COMPLAINT
I, David L. Crosby, the complainant in this case, state that the Iollowing is true to the best oI my knowledge and belieI.
On or about the date oI in the county oI in the District oI
, the deIendant violated U. S. C. §
, an oIIense described as Iollows:
This criminal complaint is based on these Iacts:
u Continued on the attached sheet.
Complainant’s signature
Printed name and title
Sworn to beIore me and signed in my presence.
Date:
Judge’s signature
City and state:
Printed name and title
DistrictoIColorado
SEE ATTACHED
Boulder
Colorado 21 841 & 846
From in or about April 2012 through December 2012, the defendants did knowingly and intentionally conspire to
distribute and possess with intent to distribute 50 grams of methamphetamine and 500 grams or more of a mixture or
substance containing a detectable amount of methamphetamine, in violation of Title 21, United States Code, Sections
841 and 846

s/David L. Crosby
Special Agent David L. Crosby, DEA
//////////
August 25, 2012 20 Feb 2013
Judge’s signature
Denver, CO Kristen L. Mix, U.S. Magistrate Judge
13-mj-01029-KLM
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 1 of 21
ATTACHMENT TO COMPLAINT
Hilario Rodela,
George Luis Pedroza,
Jorge Giovany Lugo-Lugo
Martin Lopez,
Marc Alan Brooks,
Ranell Lynn Navarrette,
Jesus Rodela,
Defendants.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 2 of 21
1
AFFIDAVIT IN SUPPORT OF COMPLAINT
Your affiant, David L. Crosby, being duly sworn, does depose and state that:
1. Your affiant, David L. Crosby, is a Special Agent with the Drug Enforcement
Administration (DEA), currently assigned to the Denver Division Office, Front Range Task
Force. Your affiant has been with the DEA for approximately twenty-one (21) years. During that
time, I have investigated narcotic traffickers/distributors within Denver, Salt Lake City, and
Washington DC metropolitan areas.
2. Except as otherwise noted, the information set forth in this affidavit is from your affiant's
personal knowledge. Unless otherwise noted, wherever in this affidavit your affiant asserts that a
statement was made, the information was provided by another law enforcement officer or a
confidential informant (who may have had either direct or hearsay knowledge of the statement)
to whom your affiant has spoken or whose report your affiant has reviewed. Such statements are
among many statements made by others and are stated in substance and part, unless otherwise
indicated. Likewise, information resulting from surveillance sets forth either your affiant's
personal observations or information provided directly or indirectly through other law
enforcement officers who conducted such surveillance. Your affiant has not included details of
every aspect of this investigation. Facts not set forth herein are not being relied upon in reaching
my conclusion that a complaint should issue. In addition, your affiant does not request that the
Court rely on any facts not set forth herein in reviewing this affidavit.
3. Your affiant has personally participated in the investigation of the offenses referred to in
this affidavit, and from this participation, and from oral and written reports of other law
enforcement agents, your affiant is familiar with the facts and circumstances of this
investigation. Based upon this knowledge, your affiant alleges the facts in the paragraphs below
to demonstrate that:
4. Your affiant submits that this affidavit sets forth probable cause to believe that Hilario
Rodela, Martin Lopez, George Pedroza, Marc Brooks, Ranell Navarrette, Jesus Rodela,
and Jorge Lugo-Lugo have violated 21 U.S.C. Section 846, conspiracy to distribute and possess
with intent to distribute 500 gram or more of a mixture or substance containing a detectable
amount of methamphetamine.
5. On October 25, 2011, Utah Highway Patrol Sergeant Steve Salas was patrolling on
Interstate 70 near mile post 156 in Emery County, Utah. Sergeant Salas observed a silver
passenger car pass his stationary location with window tinting that was darker than Utah law
allows. Sergeant Salas initiated a stop on the silver passenger car with California license plate
6NDF719. Sergeant Salas approached and made contact with the two adult female occupants.
The driver, Mary Beltran, provided Sergeant Salas with a California Identification card.
Sergeant Salas asked Beltran if she would be willing to allow him to make sure there was
nothing illegal inside the vehicle, and Beltran gave Sergeant Salas consent to search her vehicle.
Sergeant Salas opened a bag and observed clothes and a yellow plastic bag. Inside the bag were
four bricks of what appeared to Sergeant Salas to be cocaine. The bricks were wrapped in plastic
and axle grease. Beltran was arrested and subsequently charged in the United States District
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 3 of 21
2
Court for the District of Utah with possession with intent to distribute cocaine. The suspected
cocaine was analyzed by the DEA Western Laboratory and found to be 3972 grams of 70.5%
pure cocaine.
6. On April 2, 2012, agents from the DEA Salt Lake City, Utah office conducted a safety
valve interview of Mary Carmen Beltran at the Unites States Attorney's Office. Beltran stated
she was dating a brother of Martin Lopez. Beltran stated she thought Lopez lived in Aurora,
Colorado, and that his supplier lives in Mexico. Beltran stated Lopez asked her to transport
drugs for him and, because she was out of money and did not have a job, she consented. Beltran
stated the first time she transported narcotics was in March of 2011. She said that on her first
trip, she transported two to two and one half kilograms of cocaine, and was paid two to three
thousand dollars. Beltran said that Lopez flew to California from Colorado and met with her.
They then drove to an apartment complex in Southgate, California, where Beltran pulled to the
front of a garage and met an individual named "Compa.” From there, Beltran stated she would
start driving directly to Lopez's place in Colorado. She said that Lopez traveled with her only on
the first trip, and that Lopez was the only person making the deliveries to Colorado before she
started. When she arrived in Colorado she would drive to an apartment complex in Aurora.
Beltran stated she was paid approximately $2,000 per trip for a total of four trips. Beltran said
she usually split the money with whoever accompanied her. She was paid upon completion of
each trip.
7. In April 2012, the DEA Front Range Task Force received information from a
Confidential Source (CS) regarding the drug trafficking activities of Hilario Rodela. The CS
said that approximately three weeks ago he/she ran into “Junior” at the flea market at 88
th
and
Highway 76. The CS said that Junior told the CS that he was currently in a half-way house but
was also selling methamphetamine. The CS said that Junior offered him/her a sample of what he
had and the CS said that he would acquire some later. The CS was subsequently shown a
photograph of Hilario Rodela, who the CS identified as Junior. The CS has been cooperating
with law enforcement since February 2012, after the CS’s arrest for conspiracy to distribute
methamphetamine. During the CS’s cooperation, he/she has provided information that has been
proven truthful through independent investigation and has not provided information which has
proven to be intentionally false. The CS is cooperating for consideration in the criminal case and
has not received any monetary consideration. Information provided by the CS has resulted in the
seizure of methamphetamine and directly led to the arrest of six defendants for possession of
drugs and conspiracy to distribute drugs. Also, the CS’s information has assisted in the
prosecution of two additional individuals.
8. On April 26, 2012, the CS made a controlled purchase of one ounce of methamphetamine
from Rodela. This purchase was arranged by the CS, who called Rodela. The CS and Rodela
then discussed the purchase of larger amounts. The suspected methamphetamine was analyzed
by the DEA Western Laboratory and found to be 28.3 grams of 86.2% pure methamphetamine.
9. On May 3, 2012, at approximately 10:01 am, the CS received a call from Hilario
Rodela. The CS asked Rodela if he would see Rodela in “20 minutes,” referring to meeting
Rodela to purchase two ounces of methamphetamine. RODELA said that he was able to reach
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 4 of 21
3
“the guy,” his source of supply, and was going to meet him at Highway 7 and I-25. Rodela said
he would give the CS a call and confirmed that the CS wanted "two."
10. Records for Rodela’s phone show that immediately before calling the CS, Rodela called a
phone subscribed to Groege Peoroza (sic) at 6530 Gifford Drive, Commerce City, Colorado.
Subsequently, this phone number was identified as being utilized by George Luis Pedroza when
Pedroza was stopped by police for a traffic offense on May 3, 2012, and he provided this number
as his telephone number. Additionally, Mary Carmen Beltran said she used this address to mail
documents to Martin Lopez.
11. On May 3, 2012, at approximately 10:30 am, the CS called Rodela. The CS asked if
Rodela was “almost there,” and Rodela said "my friend," meaning his source of supply, was
coming to his house from Aurora. Rodela said he would call as soon as he heard from the guy.
The call-detail records for Rodela’s phone show that Rodela received a call from Pedroza
immediately before the call from the CS.
12. At approximately 12:38 pm, Rodela called the CS. Rodela told the CS, “very ready over
here.” The CS said they were on their way. At this same time, surveillance observed a vehicle
arriving at Rodela's residence. Subsequently, George Pedroza was identified as the driver. The
CS and your affiant, acting in an undercover capacity, then met with Rodela and purchased from
him two ounces of suspected methamphetamine for $2,400. This suspected methamphetamine
was analyzed by the DEA Western Laboratory and found to be 54.8 grams of 59.6% pure
methamphetamine.
13. On May 10, 2012, George Pedroza and his brother, Isaac Gonzalez-Pedroza, were
arrested by the Denver Police Department in the area of 2096 South Colorado Boulevard,
Denver, Colorado. A search of their vehicle revealed one package containing 432.2 grams of
89% methamphetamine and a second package containing 27.023 grams of 91%
methamphetamine.
14. Based on an analysis of call-detail records for Pedroza, Rodela and Lopez, as well as
statements subsequently made by Lopez to your affiant, your affiant believes that George
Pedroza was Hilario Rodela’s supplier for methamphetamine and, following his arrest, Rodela
began to receive his drug supply from Martin Lopez who had been Pedroza’s supplier. Pedroza
also is the brother of Lopez’s paramour, Tania Pedroza.
15. On May 18, 2012, the CS called Hilario Rodela and discussed the purchase of a “q.p.”
(referring to 1/4 pound of methamphetamine) and the acquisition of a sample of “chiva”
(referring to heroin). The CS and Rodela agreed that the deal was going to be conducted the
following Tuesday.
16. On May 21, 2012, at approximately 1:42 pm, the CS called Rodela and confirmed the
transaction for the following day. At approximately 4:04 pm, the CS received the following text
message from Rodela: "I got those 4 tires U needed for tomorrow already." The CS understood
this to mean that Rodela had obtained the 1/4 pound (or four ounces) of methamphetamine, as
agreed.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 5 of 21
4
17. On May 22, 2012, at approximately 1:10 pm, the CS received the following text message
from Rodela: "How long til you get to my house." At approximately 1:18 pm, the CS received a
call from Rodela. The CS told Rodela that he/she was about to arrive. Rodela asked what time,
and the CS told Rodela to go on outside as he/she was just arriving. At approximately 1:20 pm,
the CS again called Rodela. Rodela asked if the CS was outside and directed him/her to come
inside. The CS declined and said that he/she was with his/her “brother-in-law,” which was a
reference to SA David Crosby, acting in an undercover capacity. Rodela said he would be
outside shortly.
18. At approximately 1:23 pm, SA Crosby observed Rodela coming from 10 9th Avenue, Lot
1. Rodela walked to the passenger side of the CS's vehicle and shook hands with your
affiant. Rodela then handed your affiant a "Slime" Tire Inflator box. Inside the box, your affiant
observed what appeared to be approximately four ounces of methamphetamine. Your affiant
then handed Rodela $4,800 in official funds, which Rodela placed in his front pants
pocket. Your affiant asked Rodela about obtaining a sample of heroin. Rodela said that he did
not have the sample but was going to see his heroin supplier that afternoon in Denver. Rodela
quoted your affiant a price of $500 for 1/4 ounce of heroin. Rodela explained that your affiant
would have to "front" the money to him, and he would obtain the heroin within two hours. Your
affiant said he needed to speak with someone else and then let Rodela know. Shortly thereafter,
your affiant and the CS departed. Your affiant made an audio and video recording of this
transaction. The suspected methamphetamine was analyzed by the DEA Western Laboratory
and found to be 110.6 grams of 99.9% pure methamphetamine.
19. On May 25, 2012, at approximately 12:44 pm, the CS called Rodela. The CS asked if
“the stuff was different,” referring to the methamphetamine, and Rodela said it should be the
same because “it was from the same guy.” The CS said it seemed “darker,” and Rodela said that
it was someone different because the “other guy” was in California and sent that through
somebody else. Rodela said it was the “same connect.” Rodela repeated that it was from the
same guy, but had been “sent through somebody else.” The CS said sometimes when you
“change people, that's when you get low quality.” Rodela agreed. During this conversation,
Rodela confirmed that the methamphetamine was coming from the same source, indicating that
there had been no interruption in supply after the arrest of George Pedroza. Rodela also said this
supplier had gone to California and another person delivered the drugs to Rodela’s residence
during the supplier’s absence.
20. On June 8, 2012, at approximately 9:52 am, the CS called Rodela. The CS asked if
Rodela would be ready for “next week,” meaning supply methamphetamine for the planned
transaction. Rodela said he was just picking up once a week and asked how many the CS
needed. The CS said he was unsure because he had not talked to his brother-in-law. Rodela
restated that he was “picking up once a week.” The CS asked if Rodela picked up on “Fridays,”
and Rodela agreed. The CS said he would make some calls and then call Rodela. Rodela said he
was leaving around “one o’clock,” and the CS said he would call before then. The CS
subsequently called Rodela back and told him that he needed two ounces of methamphetamine.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 6 of 21
5
21. At approximately 11:28 am, the CS called Hilario Rodela. The CS said that he talked to
his brother-in-law, who said “2 or 3 but most likely 2,” referring to ounces of methamphetamine.
Rodela said he would get “3” to make sure. Call-detail records reflect that shortly after this call,
at 11:44 am, Rodela called Martin Lopez. Your affiant believes that Rodela was reporting to
Martin Lopez the quantity of drugs that were needed.
22. At approximately 2:11 pm, call-detail records reflect a call from Lopez to Rodela. At
approximately 2:55 pm, agents observed a tan Jeep Cherokee parked outside of 10 9
th
Avenue,
Lot 1, Longmont, Colorado. This vehicle had Colorado license 101XUW, which is registering to
Aurora Gonzalez at 6530 Gifford Drive, Commerce City, Colorado. The examination of public
database records, criminal history records, and driver’s license records, revealed that Aurora
Gonzalez is an alias used by Tania Aurora Pedroza-Gonzalez, the sister of George Pedroza and
paramour of Martin Lopez. Martin Lopez was observed meeting with Rodela outside of 10 9
th
Avenue, Longmont, Colorado. At approximately 3:00 pm, Lopez was observed departing.
23. At approximately 3:09 pm, the CS received a text message from Rodela. Rodela said, “I
got those whenever ur ready.” The CS understood this to mean that Rodela had obtained the
methamphetamine requested by the CS. Your affiant believes that the receipt of the text message
soon after the departure of Lopez indicates that Rodela obtained the methamphetamine from
Lopez.
24. On June 11, 2012, at approximately 4:36 pm, the CS called Hilario Rodela. The CS said
his brother-in-law called and said he had gotten some "chiva" (heroin) but it was not that good.
The CS mentioned his brother-in-law could do “250,” and Rodela said he had “a quarter.”
Rodela said he could give the CS a “quarter for 4.” Rodela said “400 for a quarter” and
mentioned that he only had a quarter right now. Rodela said he might have to re-up tomorrow.
The CS said he would see Rodela tomorrow and he would get two of "those" and then he may
have enough for the quarter. The CS said otherwise, just half of the quarter, and Rodela said at
least a "ball." The CS agreed and mentioned that his brother-in-law wanted to try it out because
his people had complained. Rodela said it was not pure, and the CS said that it would never be
pure. The CS mentioned that his brother-in-law had been “grabbing junk” and did not want to
lose people. The CS said his brother-in-law wanted at least half of a quarter. The CS asked if
Rodela could give him “200” worth, and Rodela said he would be ready tomorrow morning. The
CS asked for a call back first thing in the morning and said he would call Rodela.
25. At approximately 4:49 pm, the CS called Rodela. The CS said he would be able to get
the “whole quarter,” and Rodela asked if he should call the CS around 8 or 8:30 am. The CS
said around 12 or 1 in the afternoon. During these two telephone calls, the CS was discussing
with Rodela the acquisition of two additional ounces of methamphetamine and a quarter ounce of
heroin. Chiva is a common euphemism for heroin. On June 12, 2012, at approximately 10:12
am, the CS received a text message from Rodela. Rodela said, “Hit me up whenever ur ready.”
At approximately 11:15 am, the CS responded to Rodela with “Cody will hit u up around 12 or
1. I had to run to the hospital my kid got sick.” The CS was telling Rodela in this last text that
his “brother- in-law, Cody” (your affiant’s undercover persona) would be coming without the
CS.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 7 of 21
6
26. At approximately 1:00 pm, SA Crosby called Rodela. SA Crosby told Rodela that he
was near his house. Rodela said he was ten blocks away, and asked SA Crosby to wait if SA
Crosby arrived before Rodela returned. This call was recorded. At approximately 1:10 pm, SA
Crosby arrived at 10 9th Avenue, Longmont, Colorado, and parked beside Lot 1. SA Crosby
then called Rodela and told him that SA Crosby was at Rodela's house. Rodela said that he
would be there shortly.
27. At approximately 1:15 pm, SA Crosby observed a white Range Rover parking in front of
SA Crosby's vehicle. Rodela was the driver and an individual subsequently identified as Marc
Brooks was in the passenger's seat. Rodela and Brooks then got out of the Range Rover and
walked over to the passenger side of SA Crosby's vehicle. SA Crosby exchanged greetings with
Rodela and general conversation ensued. Rodela said he would go get the "stuff" and then
walked into the house. A few minutes later, SA Crosby observed Rodela walking out of the
house and to the passenger side of SA Crosby's vehicle. Rodela then leaned in and handed SA
Crosby a clear ziplock bag containing approximately two ounces of suspected methamphetamine
and approximately 1/4 ounce of suspected heroin. SA Crosby gave Rodela $2,400 for the
methamphetamine and $400 for the heroin. SA Crosby and Rodela then talked briefly about the
quality of the heroin, and SA Crosby said he would call after testing the quality. Shortly
thereafter, SA Crosby departed. The suspected heroin and methamphetamine were analyzed by
the DEA Western Laboratory was found to be 54.4 grams of 98.5% pure methamphetamine and
6.7 grams of 39.6% pure heroin.
28. On June 21, 2012, at approximately 10:20 am, SA Crosby called Hilario Rodela. SA
Crosby told Rodela that he was interested in getting some more “black paint,” meaning heroin.
SA Crosby asked Rodela what he could do with “4 of what he got last time.” Rodela then
confirmed that SA Crosby had gotten a “quarter” (ounce) last time. Rodela then quoted SA
Crosby a price of “16,” meaning $1600. SA Crosby said he would call Rodela the following
week.
29. On June 29, 2012, at approximately 11:20 am, SA Crosby called Hilario Rodela. SA
Crosby told Rodela that he was interested in getting an “OZ of the black paint,” meaning one
ounce of heroin. SA Crosby said that Rodela had said it would be “1600,” meaning $1600.
Rodela agreed and asked when SA Crosby was planning to arrive. SA Crosby said, “late
Monday or Tuesday morning.” Rodela told SA Crosby to call him when he was “downtown,”
meaning in Longmont. Rodela confirmed that he would have the heroin and confirmed that the
heroin was the same as last time.
30. On July 2, 2012, at approximately 10:00 pm, SA Crosby received the following text
message from Rodela: “Hey his [sic] is jr I just got a new phone number. When you coming
down.” SA Crosby responded with,”Btwn 10 ad 11.” Rodela responded, “Tomorrow,” and SA
Crosby replied, “Yes.” Rodela then said, “Cool.” SA Crosby asked Rodela, “What is your new
number,” and Rodela said, “Just call me on this one. The other will be disconnected soon.” This
exchange was a follow-up to the conversation with Rodela on June 29, 2012 regarding getting a
quantity of heroin.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 8 of 21
7
31. On July 3, 2012, at approximately 10:00 am, SA Crosby received a text message from
Rodela. "Running late can we meet at noon." SA Crosby responded, "Noon it is. You already
have it [heroin]?" Rodela responded, "On my way. Meeting my guy now." SA Crosby
understood this to mean that Rodela was meeting the heroin source.
32. Shortly thereafter, surveillance located Rodela in Longmont and began to follow him. At
approximately 11:40 am, Rodela arrived in the parking lot of Tacos y Salsas restaurant, located
on the southeast corner of Mississippi and Federal Boulevard, Denver, Colorado. Rodela met
with Jorge Giovany Lugo-Lugo and then departed. Rodela was then followed back to I-25,
where he proceeded north.
33. At approximately 12:50 pm, SA Crosby received a call from Rodela. SA Crosby asked
Rodela where he had been, and Rodela said that he was picking up the “stuff,” meaning
the heroin, and was on his way back. SA Crosby said he was half way to Fort Collins, but would
turn around. SA Crosby asked if Rodela was “all set,” meaning in possession of the heroin, and
Rodela responded, “yes.”
34. At approximately 1:10 pm, SA Crosby received a text message from Rodela. Rodela
said, "Almost to Longmont exit do u want to me to keep going north." SA Crosby responded
that he was "almost to your (Rodela's) place."
35. At approximately 1:15 pm, your affiant responded to 10 9th Avenue and parked his
undercover vehicle beside Lot #1. At approximately 1:27 pm, Rodela arrived and parked his
white Range Rover in front of him. An unknown Hispanic female was in the front passenger
seat. Rodela got out of his vehicle and walked to the passenger side window of the undercover
vehicle. Your affiant and Rodela exchanged greetings, and Rodela said that he had been driving
all morning and had just returned from Denver. Rodela said that he went to south Denver to
meet his guy, meaning his heroin source of supply. Rodela said he then delivered cocaine to
another person, but had to wait a half an hour for payment. From his pocket, Rodela took a clear
plastic bag, containing a brown powder substance. From the bag, he removed another bag,
containing approximately one ounce of the brown substance, which he handed to SA
Crosby. Rodela said that he had gotten two ounces from his supplier. The bag that Rodela
removed the ounce from contained another ounce of the same substance, as observed by SA
Crosby. SA Crosby gave Rodela $1600 as payment. Your affiant asked if Rodela meets his
source at his house, and Rodela said that he met him on the street. Rodela said that he met him
near Kentucky [Avenue]. Kentucky Avenue is two blocks from the Tacos y Salsas restaurant.
After a brief conversation, Rodela walked back to his vehicle and your affiant departed. The
heroin was analyzed by the DEA Western Laboratory and found to be 27.8 grams of 31% heroin
hydrochloride.
36. On August 2, 2012, Senior Judge David M. Ebel, United States Court of Appeals for the
Tenth Circuit, issued an Order authorizing the interception of wire and electronic
communications over telephones used by Hilario Rodela and Martin Lopez. Subsequently, court
orders were obtained for three additional phones used by Lopez. The following conversations
were intercepted and recorded pursuant to these Orders or were monitored by consent.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 9 of 21
8
37. On August 7, 2012, at approximately 9:15 am, SA Crosby called Hilario Rodela. SA
Crosby said that "Luis" (Undercover name used by the CS) wanted SA Crosby to “pick up some
windows (meaning methamphetamine) tomorrow.” Rodela said he was going to "Sturgis" and
wanted to see if they could do it early. SA Crosby and Rodela agreed to conduct the transaction
between 10:00 am and 11:00 am the next day.
38. At approximately 2:14 pm, a telephone call was intercepted between an unknown male
and Rodela. The unknown male said “they” were in southwest Denver and asked if Rodela was
coming. Rodela said he would be there in about an hour. A person subsequently identified as
Jorge Giovany Lugo-Lugo (based on surveillance and subsequent undercover purchases of drugs,
as detailed below) then got on the phone and said they had gone to get the car plates. Rodela
said he wanted a “whole black one.” Lugo-Lugo asked if that was it, and Rodela said “yes.”
39. At approximately 4:33 pm, Lugo-Lugo called Rodela. Lugo-Lugo asked where Rodela
was, and Rodela said he was in front of the lunch shop in a gray car by the Family Dollar Store.
Rodela asked if Lugo-Lugo was at 48
th
and Pecos, and Lugo-Lugoi said he was at 70. Rodela
said he would go over there.
40. Shortly thereafter, surveillance agents observed Rodela meeting with the driver of a red
Volkswagen Jetta at the Family Dollar Store parking lot at 72nd/Pecos. After they met for a
couple of minutes, surveillance followed the red Volkswagen Jetta as it departed. This vehicle
subsequently was stopped, and Lugo-Lugo was identified as the person with whom Rodela met.
41. At approximately 5:44 pm, Jesus Rodela called Hilario Rodela and asked if he had any of
the white, meaning cocaine. Hilario Rodela replied in the affirmative and asked how much Jesus
Rodela needed. Jesus Rodela said he would like to get a whole one, meaning one ounce, and
Hilario Rodela said he only had a half. Jesus Rodela said that would do.
42. At approximately 6:33 pm, Hilario Rodela spoke again to Jesus Rodela and directed him
to find the drugs secreted in the storage drawer of his stove. Hilario Rodela said that Jesus
Rodela would find baggies, a scale, and a bag with 5 or 6 ounces of ice, meaning
methamphetamine. Jesus Rodela said he would grab just a half and leave the rest to Hilario
Rodela.
43. At approximately 8:47 pm, Hilario Rodela called Jesus Rodela and asked him if he “got
that work,” meaning drugs. Jesus Rodela said that he was about to.
44. On August 8, 2012, at approximately 10:07 am, SA Crosby sent the following text
message to Rodela: "Leavig ft collins. Be there in 30." Rodela, responded with the following
text: “I'll meet u.” SA Crosby then asked, “At house?" Rodela, responded: "McDonald's on 19th
and Main.”
45. At approximately 11:03am, Jesus Rodela called Hilario Rodela and said he needed “a
half.” Hilario Rodela asked if he wanted the “glass kind,” meaning methamphetamine. Jesus
Rodela replied in the affirmative and said he could give Hilario Rodela the money before he left.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 10 of 21
9
46. At approximately 11:05 am, SA Crosby arrived at the McDonalds restaurant, called
Rodela, and advised him that he had arrived at the meeting location. Rodela said he would be
there in a minute. Several minutes later, SA Crosby observed Rodela arrive in a tan Mazda 6 and
park next to SA Crosby. SA Crosby then entered the passenger side of the Mazda 6. After an
exchange of greetings, Rodela reached into his pants pocket and handed SA Crosby a clear
plastic bag containing a clear substance. SA Crosby then handed Rodela a small Dorito's bag
containing $4,800 in official funds. After a short conversation with Rodela regarding his trip to
Sturgis and his parole status, SA Crosby got out of the Mazda 6 and entered his undercover
vehicle. Shortly thereafter, Rodela and SA Crosby departed the area. The crystal substance
obtained from Rodela was sent to the DEA Western Laboratory for analysis and found to be
111.9 grams of 77.4% pure methamphetamine.
47. At approximately 6:34 pm, a telephone call was intercepted between Hilario Rodela and
Martin Lopez. Rodela said he was going out of state to “Sturgis” to a motorcycle rally. Rodela
said he “had everything ready” and wanted to know if Lopez could “head over.” Rodela
explained that he was going to leave “the lady in charge” of “his people.” Rodela asked if Lopez
could bring him “something” more. Lopez said he could go but that Rodela needed to give him
some time. Rodela said he was going to leave Lopez’s money with Rodela's “homie, the
white/blonde guy” (Marc Brooks) and stated that Lopez could “leave the work” (narcotics) with
him (Brooks).” Rodela asked Lopez to make sure “the work” was sealed so “the guy” (Brooks)
would not be tempted to take anything. Lopez asked if the guy could go to Lopez’s house
instead. Rodela said it could be at any time though, as long as it was not too late, “like 12
[midnight] or so.” Lopez asked if Rodela wanted him [Lopez] to go over there. Rodela replied
in the affirmative and said he would leave Lopez's money with “him,” adding that it was “5,”
meaning $5,000. Rodela stated that he could have the guy meet Lopez by the highway. Lopez
asked if Rodela was going to need the same, “8,” meaning eight ounces of methamphetamine.
Rodela replied in the affirmative. Lopez asked if the guy was going to give him “5 bucks,” and
Rodela reiterated that he would leave “the 5” ($5,000) with “the guy.” Lopez said he would give
the guy “8,” meaning eight ounces of methamphetamine.
48. Lopez said he would call Rodela when he met with the guy. Rodela said he would have
both of his phones on him on the road. Rodela said he would be back on Sunday. Rodela stated
that he did not want to leave “his girlfriend without work,” meaning narcotics. Rodela said he
asked her if she could handle it if he “left her with his people,” meaning his customers, and she
agreed. Rodela added that everyone knew her anyway. Rodela stated that he was going to leave
the “entire 8” with her. Your affiant believes this to be a reference to Ranell Navarrette, based
on Lopez’s use of the name “Ranell” in subsequent conversations and subsequent interception of
conversations between Navarrette and Rodela and between Navarrette and Lopez. Rodela said
he told her that if she could move all of them between her people and his people to go ahead and
do so. Lopez said he was going to give “all of them the same way he always gives them” to
Rodela. Lopez said it would probably be later in the night, but before midnight. Lopez asked if
he should call Rodela when he [Lopez] was ready, and Rodela agreed. Lopez asked if the guy
could meet him on “the 120 by Hooters.” Initially, Rodela stated that he did not know, but then
said he did not think so because the guy had his daughter with him. Lopez asked where he
would meet the guy “over there,” and Rodela said there was a truck stop with a “McDonalds off
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 11 of 21
10
the highway.” Lopez remarked that he had this phone on all day, and asked if Rodela
remembered now that Lopez called him. Rodela replied in the affirmative. Rodela told Lopez to
call when he was on his way and Rodela would tell the guy to head over there. Based in training
and experience, your affiant believes that Rodela was arranging to give Lopez $5,000 for drugs
previously supplied, and Lopez was going to supply Rodela with eight more ounces of
methamphetamine. SA Crosby believes that a large portion of the $5,000 was from the $4,800
provided to Rodela earlier in the day by your affiant. Rodela told Lopez that he was going out of
town but was going to leave someone in charge of supplying drugs to his customers. Also,
Rodela told Lopez that Marc Brooks would deliver the money to Lopez and pick up the
additional drugs.
49. At approximately 8:42 pm, a call At approximately 8:42 pm, a call was intercepted
between Hilario Rodela and Martin Lopez. Rodela asked if Lopez had a timeframe of when he
would “head to Longmont.” Lopez asked if Rodela had people ready and “waiting for that shit.”
Rodela said he spoke with “the lady”, who said she was out but would be there as soon as
possible. Your affiant believes this is another reference to Ranell Navarrette. Lopez asked if
they could get close to “the 120” so it would be faster. Rodela said the guy would not be able to
because the guy was with Rodela's niece and her daughter. Rodela explained that the guy did not
have the chance to do much. Lopez said he could meet “around 10:30,” explaining that he had to
go get “that” (drugs), measure it, and then “head over there” (Longmont). Lopez said he would
call Rodela so he could “be on alert.” Your affiant believes that during this conversation Lopez
asked Rodela if he had customers waiting for drugs. Rodela told Lopez that the person handling
Rodela’s customers is out of drugs for her own customers and is interested in acquiring some
soon. Lopez said that he could meet someone at 10:30 pm that evening.
50. At approximately 9:36 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Lopez said he never lets Rodela down, but it would be better if he could meet Rodela's
“buddy” (Brooks, as explained below) tomorrow. Lopez said early, for sure, unless “they”
(Brooks) could come see him instead. Rodela said tomorrow was fine. Lopez said early
tomorrow, and then apologized because this thing “caught him off guard.” Rodela said it was
no problem, adding that he would have to hold off business until tomorrow. Lopez said it would
be better if they could meet half way, adding that the problem was that “he [Lopez] did not have
a license” and did not want to be out. Lopez said he did not mind going to “120,” but anything
beyond that on the “lonely highways was too much.” Rodela said he would ask “him” (Brooks)
if he could meet Lopez at Hooters. Lopez told Rodela to call quickly because he (Lopez) “had to
go to a storage” first “to get that” (drugs). Based in training and experience, your affiant
believes that during this conversation Rodela and Lopez were discussing the exchange of a
quantity of drugs.
51. At approximately 9:39 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Rodela said that the third party (Brooks) said he would go “to 120.” Lopez said he
would “have to grab that” (narcotics) and “measure it” (possibly weigh it) and then he would
head over. Lopez said it would be a lot faster if he could give Rodela a “whole one.” Lopez
asked what Rodela thought, but Rodela did not respond. Lopez stated that it would be a “whole
one” instead of giving Rodela “eight.” Rodela asked if that was a "libreta," which appears to be
a coded reference to a pound, and Lopez agreed and said that way he would not have to go back
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 12 of 21
11
home and measure anything, and would not keep Rodela's people waiting. Rodela agreed.
Lopez told Rodela to make sure he is on top of things, like always, and Rodela agreed. Lopez
asked if the guys had a place to store it or if they would “just take it like that.” Rodela said he
had all that set up. Lopez advised that the guys not take anything “just like that” because that
was tough to do, and they should secure it. Rodela told Lopez to call once he wanted him
(Brooks) to take off to 120. Lopez told Rodela to have the guy leave from his house in 10-15
minutes. Based on training and experience, your affiant believes that Lopez told Rodela that he
will give him a pound of methamphetamine, instead of eight ounces, and this would cut down on
the time required to weigh and package the smaller quantity.
52. At approximately 9:45 pm, a call was intercepted between Hilario Rodela and Marc
Brooks. Rodela told Brooks to meet him (Lopez) at the “Hooters on 120.” Rodela told Brooks
to leave in “about 10 minutes.” Brooks said he was just sitting down to dinner, but would head
down in 10 minutes to “take care of that.” Rodela told Brooks that “it was going to be a full
one” this time, so “double what it was last time.” Brooks was surprised and asked if everything
was going to “Ranell.” Rodela said “yes.” Rodela told Brooks to call “as soon as he (Brooks)
had it in hand.” Both agreed. Based on training and experience, your affiant believes that
Rodela was directing Brooks where to meet Lopez, how much he was to receive from Lopez, and
who he was to give the drugs to afterward. Your affiant believes that “Ranell” is Ranell
Navarrette.
53. At approximately 10:19 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Lopez told Rodela that he was at the storage place but it was closed. Lopez told Rodela
to have the “guy take off” (referring to Brooks) and “he” (Lopez) would pick up the “paper
(money) tomorrow” since that was not a problem. Lopez told Rodela to tell him what time and
he (Lopez) “would be ready.” Rodela said at around 12:00 noon. Lopez said that he could be
ready earlier if needed. Lopez said he would take it to Rodela “all the way over there” tomorrow
because of “what happened today.” Both agreed. Your affiant believes that Lopez told Rodela
that the storage unit he used to store drugs closed at 10:00 pm so he would pick up the money
and make the exchange of drugs the following day.
54. Approximately 10:20 pm, a call was intercepted between Hilario Rodela and Marc
Brooks. Rodela asked where Brooks was, and Brooks said he just passed “Del Camino” on I-25.
Rodela told Brooks to go back because the guy (Lopez) said the “storage” closed at 10:00.
Rodela said that Lopez said he would go all the way to Brooks' house the next day. Brooks told
Rodela to keep him posted because he was ready.
55. On August 9, 2012, at approximately 8:40 am, a call was intercepted between Hilario
Rodela and Martin Lopez. Lopez said he kept “that pending one” last night so he was going to
get up early to call Rodela. Rodela explained that “his buddy was not awake yet.” Lopez asked
if Rodela's “buddy gets up late.” Rodela replied in the affirmative, and Lopez said that one must
be ready when there are obligations. Lopez asked how they should do it and suggested that
Rodela call Lopez because Lopez had “that pending one” and did not want to continue waiting.
Lopez added that it was going to be “9” soon. Rodela said he was going to call his buddy.
Lopez asked Rodela to call him back “whenever” because Lopez was ready anytime. Your
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 13 of 21
12
affiant believes that Lopez was inquiring about when the exchange of the money and drugs
would happen.
56. At approximately 10:42am, SA Crosby received a telephone call from Rodela. Rodela
said he was cruising in the Black Hills of South Dakota. SA Crosby said he had somebody that
wanted another window (ounce of methamphetamine). Rodela said he left his lady (Ranell
Navarrette) to be in charge with the stuff and told SA Crosby to call Rodela whenever SA
Crosby would need it so Rodela could have her meet SA Crosby.
57. At approximately 10:50 am, a call was intercepted between Hilario Rodela and Marc
Brooks. Rodela said Martin had said he was ready and did not know if Brooks was “ready to go
down there.” Brooks said that Lopez was supposed to go to him. Rodela agreed and said Lopez
was supposed to go to Brooks, but Rodela wanted to make sure that Brooks was up. Rodela
asked if he should tell Lopez to meet at “McDonald's or something.” Brooks said anywhere
because Brooks was “ready.” Rodela said he would call Lopez. Brooks asked if he was going to
“get that order,” and Rodela agreed and said that Lopez was going to give Brooks “the package.”
SA Crosby believes that Rodela and Brooks discussed the exchange that was to take place with
Lopez.
58. At approximately 7:42 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Lopez asked about the money, and Rodela said “his friend had it in Longmont.” Lopez
asked if he could “go get it,” and Rodela said “yes.” Lopez asked if Rodela wanted Lopez to
leave “it” with the third party, and Rodela told him to “seal everything up well.” Lopez agreed
and said he would call when he was on his way. Your affiant believes that Lopez was making
arrangements with Rodela to pick up money and deliver more drugs.
59. At approximately 7:45 pm, the following text message was intercepted from Rodela to
Marc Brooks: “Hey dude is on his way to town to drop that to you.”
60. At approximately 8:23 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Rodela asked when Lopez was headed to “Longmont” so he could tell the third party
(Brooks). Rodela asked if he would meet him at the “McDonalds at the highway.” Lopez
confirmed and said he would shower and then leave because “the stuff” was ready. Lopez said
around 9:30 pm to 10:00 pm.
61. At approximately 9:50 pm, the following text message was intercepted from Rodela and
Marc Brooks: “He’s gonna give you one sealed package.”
62. At approximately 10:53 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Lopez said he was there. Rodela said “he” (Brooks) was in a grey Mazda, and Lopez
said he was in “a van, an Odyssey.” Surveillance subsequently observed Lopez meeting with
Brooks at the McDonalds on Hwy 119 and I-25 in Longmont, Colorado. The vehicle Lopez
arrived in was driven by a female, who Lopez was later observed hugging and kissing.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 14 of 21
13
63. At approximately 11:02 pm, a call was intercepted between Hilario Rodela and Martin
Lopez. Lopez said he saw “the guy” and left him the “stuff sealed and marked.” SA Crosby
believes that Lopez was referring to the drugs he left with Brooks.
64. At approximately 11:03 pm, a call was intercepted between Hilario Rodela and Marc
Brooks. Rodela asked if they were “done,” and Brooks said yes. Rodela asked if he got “one or
2 separate.” Brooks said he got “1 half package…half key.” Your affiant believes that Rodela
was confirming with Brooks the weight of the drugs he received from Lopez.
65. At approximately 11:18 pm, the following text message was received by Rodela from
Marc Brooks: ”Hay boss its all good he gave me a half pound on my way back home ill text u to
let u know I made it ok.”
66. On August 10, 2012, at approximately 10:45 am, SA Crosby received a call from Rodela,
who asked if SA Crosby still wanted to meet in Longmont. SA Crosby said yes. Rodela said he
had to call his "buddy" and asked what time SA Crosby would take off. SA Crosby said around
2:00 pm, and Rodela said to meet at the gas station at 66 and Main. SA Crosby asked if it was
someone else and not his girl, and Rodela said it was the “dude” he was always with.
67. At approximately 2:39 pm, SA Crosby arrived at the gas station at Colorado 66 and Main
Street, and called Rodela. SA Crosby informed RODELA that he was at the location and
provided a description and location of his car. Several minutes later, SA Crosby observed a tan
Mazda 6 parking on his left. SA Crosby recognized this vehicle as the one driven by Rodela
during a previous purchase. This time, Marc Brooks was the driver and only occupant. SA
Crosby got out of his undercover vehicle and entered the passenger side of the Mazda 6. After
exchanging greetings, Brooks admitted knowing SA Crosby from a previous transaction with
Rodela. Brooks then produced a clear baggy containing a crystal substance and placed it on a
scale. SA Crosby said he was going to go get the money and walked back to his undercover
vehicle. After returning to the Mazda 6, SA Crosby handed Brooks a paper cup containing
$1,200. The substance obtained from Brooks was analyzed by the DEA Western Laboratory
and found to be 27.8 grams of 85.4% methamphetamine.
68. On August 13, 2012, Rodela was the passenger in a vehicle traveling through Torrington,
Wyoming when the vehicle was stopped for speeding. At the time of the stop, Rodela received a
call from Marc Brooks. Rodela told Brooks that they had been stopped for speeding and they
agreed to talk later. Rodela was arrested on an outstanding warrant for probation violation and
escape from a halfway house. A search incident to arrest revealed a 9mm handgun in a duffle
bag in the rear of the vehicle. Currently, Rodela remains incarcerated for the violation of
probation.
69. Subsequent to his arrest, Hilario Rodela made several calls from the jail to Jesus Rodela.
These telephone calls were recorded by the correctional institute. During one call in August
2012, Hilario Rodela asked Jesus Rodela if he had spoken to “Martin” (Lopez). Jesus Rodela
said he had not. Hilario Rodela gave him a telephone number and told him to call him. Jesus
Rodela then made a three-way telephone call to Martin Lopez. Hilario Rodela told Martin Lopez
that he was using Jesus Rodela’s telephone and told Lopez to save the number and let Jesus
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 15 of 21
14
Rodela know whenever he changed numbers. Jesus Rodela said to save the number under
“Jesse.” Lopez said that he could count on him for “work,” meaning drugs. Hilario Rodela said
that Jesus Rodela would be there for anything. Jesus Rodela asked Hilario Rodela if “Martin”
was the one with the “brown,” meaning heroin, or the “white one,” meaning cocaine. Hilario
Rodela said the “ice,” meaning methamphetamine.
70. During subsequent conversations between August 17, 20012 and September 25, 2012,
Hilario Rodela and Jesus Rodela discussed what Hilario Rodela was paying for the various drugs
and what Jesus Rodela was to charge when they were sold. Hilario Rodela said that he would be
able to get the “white,” meaning cocaine, and the “brown one,” meaning heroin. Jesus Rodela
said he had about three guys asking if could get the other one. During another conversation,
Jesus Rodela asked where he would get the “white”, meaning cocaine, from. Hilario Rodela said
he was getting it from “Giovany” (Jorge Lugo-Lugo) as well. Hilario Rodela said he was going
to call “Martin” (Lopez) and said he wanted to keep in touch with him since he was a good
contact for “ice”, meaning methamphetamine. During another conversation, Jesus Rodela said
he had spoken to “Giovany” (Jorge Lugo-Lugo) but he did not want to talk to HIlario Rodela
because the jail recorded all the telephone calls. During another conversation), Jesus Rodela put
Hilario Rodela on a three-way telephone call with Martin Lopez. Hilario Rodela asked Martin
Lopez if it was okay for his brother (Jesus Rodela) to go pick up three or four (ounces of
methamphetamine) from him and added that it was going to be with cash “up front.” Lopez said
it would be okay.
71. On August 16, 2012, at 10:07 am, the CS called Jorge Lugo-Lugo and asked if he knew
“Gordo” (Hilario Rodela). Lugo-Lugo asked which Gordo, and the CS said “Gordo, Junior”
(Rodela). Lugo-Lugo said he knew him and asked what happened. The CS explained that Junior
was caught going toward Sturgis. Lugo-Lugo asked how the CS got his number, and the CS
explained that he/she used to work with Rodela, who gave him/her the number. The CS assured
Lugo-Lugo that he/she would not jump over Rodela. Lugo-Lugo indicated that he understood
and said that he knew that Rodela had been arrested after being stopped for speeding. The CS
added that Rodela was caught with a fusca, which is a slang reference to a firearm. The CS said
that he wanted to make sure Lugo-Lugo knew so he could be on alert. Lugo-Lugo asked if the
CS was working, and the CS responded in the affirmative and said he/she “moved” for Rodela.
CS again said that he/she told Rodela that he/she would not jump over him, but just wanted to
avoid being left “dry,” meaning without drugs. Lugo-Lugo instructed him/her to join him so
they could talk. The CS said he would get off from work around 5:00 and would call him.
Lugo-Lugo agreed and said he would give the CS another number because he just changed his
number. Lugo-Lugo said he would give the CS the new number when they met. Lugo-Lugo
instructed the CS to go to Lugo-Lugo’s location around 5:00 or 6:00 so they could talk. Lugo-
Lugo said that if they needed to work, they would work; that the idea was to work and for things
not to stop.
72. Lugo-Lugo asked about the “other guy,” who “hung around” Rodela, referring to
Brooks. The CS explained that he/she did not get along with Brooks, who was too raggedy.
Lugo-Lugo agreed. The CS said that he/she was around Fort Collins and had his/her own people.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 16 of 21
15
73. Lugo-Lugo instructed the CS to call so they could talk and added that it was up to the CS
whether he/she wanted to take “some.” The CS explained that he/she had the papeles [literally
papers, which is a common code for money]. Lugo-Lugo instructed the CS to call that afternoon
to let Lugo-Lugo know so they would see what may happen. CS agreed to call when he/she got
off from work.
74. At approximately 3:20 pm, the CS called Lugo-Lugo and said that he/she was going now
to talk to the people so that he/she would be ready in the next morning. Lugo-Lugo asked for
clarification. The CS said that he/she would be going by about noon. Lugo-Lugo asked if the
deal had come to a halt, but the CS said no, that it had only calmed down for a bit of time. The
CS said he/she did not have another connection, and Lugo-Lugo asked if the CS was referring to
“work.” The CS agreed. Lugo-Lugo asked the CS how he/she worked and the amount he/she
gets. The CS said that he/she gets a whole one, and Lugo-Lugo asked how the CS gives that to
the guy. CS said he/she gives it to third party at 16 ($1,600 an ounce). Lugo-Lugo said that was
perfectly fine. Lugo-Lugo told the CS that he wanted to clear things between them, and
explained that they liked to work directly only, such as between Lugo-Lugo's buddy and Lugo-
Lugo, and then asked if CS understood. Lugo-Lugo added that, in the past, he always worked
directly with the third party and never with the guy who was with him, in order to avoid any
scandals with the other guys. The CS agreed and said that he/she would only meet with Gordo
for a while and then leave in a flash. Lugo-Lugo stated that was the way it had to be - the work
and then go. Lugo-Lugo told the CS that he managed the two things, but then clarified that he
managed three things. Lugo-Lugo stated he managed "agua" [means water], "blanca" [means
white], and “those.”
75. CS said they could start working something new and assured Lugo-Lugo that he/she
would have the papers, meaning money. Lugo-Lugo said he would not go “over there,” and the
CS told Lugo-Lugo not to worry because he/she would “go there.” Lugo-Lugo said he would
see the “other buddy” close to his house and they would do their “thing” and take off in a flash.
Lugo-Lugo told the CS to let him know and get prepared. Lugo-Lugo said he would call the CS
from another number so the CS could get the new number and they could meet the next day.
Lugo-Lugo said they could continue working and it would not stop. Lugo-Lugo said that he had
the “water,” the “glass,” also and guaranteed the “glass” one hundred percent. The CS said that
he/she “worked that” [glass] in the past but people left because of all poor quality. Lugo-Lugo
assured the CS that if “one point” would come out dirty, he would give it to the CS. The CS
laughed. Lugo-Lugo reiterated that it was 100%, and explained that it did not benefit him to lie
about the “work” because the people would leave him. The CS said that was what happened to
him. The CS said that was fine and that talking directly with Lugo-Lugo was what mattered.
Lugo-Lugo agreed and added between all three, only the white one varied. CS said he/she would
call Lugo-Lugo the next day at noon so they could arrange where they could see each other to eat
something and talk.
76. On August 17, 2012, at approximately 10:47 am, the CS called Lugo-Lugo and asked if
they could meet around 2 pm. Lugo-Lugo said he would be ready at 2 pm, and they agreed to
meet at 72nd and Pecos. Lugo-Lugo asked how much he should get ready, but the CS said
he/she did not want to talk about numbers over the phone. Lugo-Lugo said he wanted to be
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 17 of 21
16
ready because he did not have “those quantities” in the car. The CS said he/she would check
how much he could get together and would call back.
77. At approximately 10:51 am, the CS called Lugo-Lugo. The CS said that he/she and
his/her brother-in-law had “two bucks” ($2,000). The CS said he/she wanted “a dark one” and “a
half of water” or less, depending on the “number” that Lugo-Lugo could give him/her. Lugo-
Lugo asked if/she he meant the water for the cars, and the CS agreed. Lugo-Lugo said he would
help them out right now. Lugo-Lugo said that was not a problem since they had to work. CS
said his/her brother-in-law would be with him/her and asked if that was a problem. Lugo-Lugo
said it was not a problem at all and asked the CS to call back 2.
78. At approximately 2:00 pm, the CS and SA David Crosby, acting in an undercover
capacity as the CS’s brother-in-law, responded to the parking lot of 7067 Pecos Street,
Westminster, Colorado, and parked in front of the Family Dollar store. The CS called Lugo-
Lugo, who advised the CS that it would be approximately ½ hour.
79. At approximately 2:45 pm, the CS received a call from Lugo-Lugo, who asked what
“device” the CS had. CS asked for clarification, and Lugo-Lugo asked what that CS was in. The
CS said in a gray Lexus. Lugo-Lugo asked if the CS was in front of the Family [Family Dollar].
CS said yes and then asked what Lugo-Lugo was in. Lugo-Lugo said he was in a red Jetta and
would be there in a minute.
80. Shortly thereafter, SA Crosby observed a red VW Jetta, driven by Lugo-Lugo, parking
next to the CS’s vehicle. The CS got out of the vehicle and walked around to the passenger side
of the Jetta. The CS talked to Lugo-Lugo about Rodela, and Lugo-Lugo said that the police were
at Rodela’s house because he had a dirty UA. Lugo-Lugo told the CS that Brooks was on his
way, and Lugo-Lugo said that he met a “fat boy” from Longmont earlier. Lugo-Lugo quoted the
CS prices of $1500 for an ounce of heroin, $1300 for an ounce of methamphetamine, and $800
for an ounce of cocaine.
81. The CS then returned to his/her vehicle, and SA Crosby gave the CS $2000. The CS
returned to the passenger side of the Jetta, where the CS gave the money to Lugo-Lugo in
exchange for one ounce of suspected heroin, ½ ounce of suspected methamphetamine, and a free
sample of cocaine. The CS returned to his/her vehicle and gave the drugs to SA Crosby. The
drugs provided by Lugo-Lugo were analyzed by the DEA Western Laboratory and found to be
28.3 grams of 34.2% heroin hydrochloride, 12.8 grams of 98% methamphetamine, and 1 gram of
42.2% cocaine hydrochloride.
82. On August 27, 2012, at approximately 7:58 am, SA David Crosby called Jorge Giovany
Lugo-Lugo. SA Crosby introduced himself as the CS’s "brother-in-law" and asked if he could
see Lugo-Lugo later that day. Lugo-Lugo agreed and told SA Crosby to call him.
83. At approximately 1:45 pm, SA Crosby called Lugo-Lugo. SA Crosby said he was
leaving Fort Collins and would be down in Lugo-Lugo's area in 45 minutes to an hour. Lugo-
Lugo said to meet in an hour. SA Crosby asked if he wanted to meet in the same location as last
time, and Lugo-Lugo said “no,” they should meet in the area of Peoria Street and 47th
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 18 of 21
17
Avenue. SA Crosby agreed and said he wished to get "one of the brown paint" (one ounce of
heorin) and "one of the windows" (one ounce of methamphetamine). Lugo-Lugo confirmed "one
and one."
84. At approximately 2:51 pm, SA Crosby responded to the Shell Gas station at 4650 Peoria
Street, Aurora, Colorado, called Lugo-Lugo, and informed him of his location and car
description. Lugo-Lugo said he would be there shortly.
85. At approximately 3:15 pm, SA Crosby received an incoming call from Lugo-Lugo, who
asked if SA Crosby saw him and said that he was driving a Nissan. SA Crosby then stepped out
of his vehicle and observed Lugo-Lugo across the parking lot sitting in a tan Nissan
Pathfinder. SA Crosby walked over to this vehicle and got in the passenger seat. Inside the car,
Lugo-Lugo removed a clear plastic bag, containing a brown powder, from his front pants pocket
and placed it on the center console. Lugo-Lugo also placed a clear plastic bag, containing a
crystal substance, on the center console. Lugo-Lugo confirmed the price of the heroin was
$1500 and the methamphetamine was $1300, and SA Crosby gave Lugo-Lugo a paper cup
containing $2800. Lugo- Lugo looked in the cup and appeared to see the money. SA Crosby
took the drugs, and Lugo-Lugo said to call if SA Crosby wanted anything else. The two
suspected drug exhibits field tested positive for heroin and methamphetamine, respectively, and
were sent to the DEA Western Laboratory for analysis.
86. On August 31, 2012, at approximately 11:05 am, Denver detectives were in the area of
the 700 block of Jackson Street when they observed Jorge Giovany Lugo-Lugo engaged in what
appeared to be a drug transaction. The detectives followed Lugo-Lugo and stopped him in the
700 block of Clayton Street. A subsequent search of the Pathfinder Lugo-Lugo was driving
revealed 116.1 grams of suspected heroin and 7.35 grams of suspected cocaine in the center
console; $2000, 77.87 grams of suspected heroin, and 6.915 grams of suspected cocaine in the
glovebox; and 14.097 grams of suspected heroin and 6.357 grams of suspected cocaine under the
front passenger side of the center console. Lugo-Lugo plead guilty to possession of a controlled
substance and is currently incarcerated.
87. On September 6, 2012, at 1:29 pm, Martin Lopez spoke to Ranell Lynn Navarrette.
Lopez told Navarrette that he [Lopez] “had new work” and “it is fire.” Lopez said he was also
calling to see how Navarrette was doing. Navarrette said she was doing “good” and might “be
ready” the following day. Lopez asked if there was any way for Navarrette to do “anything
today,” and Navarrette said she could. Lopez said he would even go towards “her” [Navarrette].
Navarrette said that if Lopez “needed cash,” he “could come and get it.” Lopez asked if she
could meet Lopez “on 120
th.
” Lopez asked what Navarrette “could cover,” and added that it was
“no shake” and “was all pieces.” Navarrette said she would call back in five minutes to tell
Lopez what she had. Your affiant believes that Lopez and Navarrette were discussing new drugs
to be provided to Navarrette and meeting her to receive money owed to him. When Lopez talked
about “new work” and “it was fire,” he was saying that he had new drugs of a good quality.
When Lopez asked what she “could cover” and said that it was “no shake” and “was all pieces,”
he was asking how much money she had and assuring her the methamphetamine was of a good
quality.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 19 of 21
18
88. On November 20, 2012, at approximately 5:35 pm, Ranell Navarrette called Martin
Lopez. Navarrette asked Lopez if she “could see him tomorrow,” but Lopez said that he needed
her “to come tonight.” Navarrette said that she would leave now, adding that she “was waiting
for traffic.” Lopez said that he could wait, but he really needed her “to come through.” Lopez
added that he would talk to her when she got there.
89. At approximately 6:00 pm, surveillance units observed Ranell Navarrette depart her
residence in a white Blazer bearing Colorado registration 867SFO. At approximately 7:30 pm,
surveillance observed Navarrette arriving at Martin Lopez’s apartment complex. At
approximately 7:53 pm, Navarrette departed and returned to Longmont, where a stop was
conducted for traffic violations. Navarrette was found to be in possession of approximately 100
grams of suspected methamphetamine. Navarrette was then arrested.
90. SA Crosby decided to “cold contact” Lopez via a cell phone to attempt to set up a meeting
with him to buy methamphetamine. SA Crosby contacted Lopez and told him he was calling about
Navarrette and another individual. Lopez told SA Crosby that he did not know what he was talking
about and hung up.
91. On December 11, 2012, Lopez contacted SA Crosby and SA Crosby was able to set up a
meeting for the following day to discuss narcotics related matters. On December 12, 2012, SA
Crosby and Lopez met in Commerce City, Colorado. Lopez and SA Crosby discussed the sale of
methamphetamine, including the prices SA Crosby would be charged and code words to be used
when SA Crosby spoke with Lopez on the phone. A purchase of methamphetamine was set up for
December 14, 2012, between SA Crosby and Lopez, who stated he was going to bring another person
with whom SA Crosby would deal in the future. They agreed to meet at the Hooters restaurant
located off of I-25 and 120th Avenue, in Westminster, Colorado.
92. On December 14, 2012, SA Crosby and Lopez confirmed their meeting at the Hooters
restaurant. At that location, Lopez parked near SA Crosby’s car in the parking lot. SA Crosby got
into Lopez’s vehicle, and Lopez drove around the parking lot and parked in a different location.
Lopez then provided SA Crosby with two ounce of methamphetamine, which was in a heat-sealed
package. The suspected methamphetamine was analyzed by the DEA Western Laboratory and found
to be 56 grams of 75.7% methamphetamine.
93. On December 20, 2012, a second controlled purchase of four ounces of methamphetamine
was set up by SA Crosby with Lopez at the same location. On that date, Lopez was followed from
his residence to the meeting location, where he got into SA Crosby’s undercover vehicle. Inside the
vehicle, Lopez provided SA Crosby with four ounces of suspected methamphetamine and then
returned to his vehicle and departed. The suspected methamphetamine was in a heat-sealed package
and was consistent with the appearance and packaging of the methamphetamine purchased on
December 14, 2012. The methamphetamine is pending analysis at the DEA Western Laboratory.
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 20 of 21
19
94. Based on the foregoing, your affiant submits that there is probable cause to believe that
Hilario Rodela, Martin Lopez, George Pedroza, Marc Brooks, Ranell Navarrette, Jesus Rodela
and Jorge Lugo-Lugo have violated 21 U.S.C. Section 846, conspiracy to distribute and possess
with intent to distribute 500 gram or more of a mixture or substance containing a detectable
amount of methamphetamine.
Dated this 20
th
day of February, 2013 at Denver, Colorado
s/David L. Crosby
DAVID L. CROSBY
SPECIAL AGENT
DRUG ENFORCEMENT ADMINISTRATION
SUBSCRIBED AND SWORN to before me this 20
th
day of February, 2013
__________________________________________
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT OF COLORADO
This affidavit was reviewed and is submitted by AUSA Barbara S. Skalla on February 20, 2013.
________ __ ____ __ ___ _ ___________ _ ___ _ __ __ ____ __ __ _____ __ ____ __ ____ _ ___ ____
UN UN UNIT IT ITED STATES MAAAGGI G STTTRA RA RATE TTE JUDDDGE GE GE
UN UU ITED STATES DISTRICT OF COLORAD
///////
Case 1:13-mj-01029-KLM Document 1 Filed 02/20/13 USDC Colorado Page 21 of 21