Redacted: U S D C

Case 2:23-mj-00050-KJN Document 7 Filed 04/03/23 Page 1 of 46
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT

for the
FILED
Eastern District of California Apr 03, 2023
CLERK, U.S. DISTRICT COURT
United States of America )

EASTERN DISTRICT OF CALIFORNIA
v. )
) Case No. 2:23-mj-0050 KJN
JAGNINDER SINGH BOPARAI, )
REDACTED
RAMESH KUMAR BIRLA JR., and )
SHAMINDERJIT SIGNH SANDHU, )
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of 2/14/2023 through 3/29/2023 in the county of San Joaquin in the
Eastern District of California , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1958 Conspiracy to Commit Murder for Hire
This criminal complaint is based on these facts:
Please see attached affidavit of FBI Special Agent Brian Toy
☒ Continued on the attached sheet.
/s/
Complainant’s signature
Special Agent Brian Toy, FBI

Printed name and title
Sworn to me and signed via telephone.
Date: 03/29/2023 @ 3:45 p.m.

Judge’s signature
City and state: Sacramento, California Kendall J. Newman, U.S. Magistrate Judge
Printed name and title
Contents
I. AFFIDAVIT ................................................................................................................................................. 3
II. INTRODUCTION ........................................................................................................................................ 3
III. AGENT BACKGROUND ......................................................................................................................... 4
IV. APPLICABLE LAW ................................................................................................................................. 5
V. PROBABLE CAUSE .................................................................................................................................... 5
A. The Confidential Source ...................................................................................................................... 5
B. The TARGET SUBJECTS’ Criminal Histories and Roles ................................................................ 6
C. Overt Acts Committed by TARGET SUBJECTS .............................................................................. 7
1. February 16, 2023 – BOPARAI’s Initial Meeting with the CHS: BOPARAI Tells the CHS He
Wants to Hire Him/Her to Assault VICTIM 1 ............................................................................................. 7
2. February 17, 2023 – BOPARAI Second Meeting with the CHS: Continued Discussion of Job to
Assault VICTIM 1; BOPARAI Describes this Job as a Test and Says He has Another “Big Job” After...11
3. March 3, 2023 – BOPARAI’s Third Meeting with the CHS: BOPARAI Pays $1,000 to the CHS as
a Down payment for the Assault of VICTIM 1 ...........................................................................................15
4. March 8, 2023 – BOPARAI or His Associates send Two Surveillance Pictures to VICTIM 1 in an
Attempt to Intimidate VICTIM 1 .................................................................................................................20
5. March 14, 2023 – BOPARAI’s Fourth Meeting with the CHS: Payment of Another $5,000 for the
Assault of VICTIM 1, and Discussion of Two Other Jobs, Including the Murder-For-Hire Job of
VICTIM 2 ....................................................................................................................................................23
6. March 20, 2023 – BOPARAI’S Fifth Meeting with the CHS: BOPARAI, and SANDHU Gives the
CHS Information on VICTIM 2 and BOPARAI pays the CHS a $10,000 Down Payment for the Murder
of VICTIM 2................................................................................................................................................27
7. March 24, 2023 – Meeting between BIRLA, SANDHU, and the CHS (Monitored by BOPARAI) to
discuss how to kill VICTIM 2......................................................................................................................32
D. Interview of VICTIM 2 / Potential Motive for Murder-For-Hire Plot.............................................38
E. Probable Cause for Locations and Vehicles ......................................................................................41
1. BOPARAI’s Residence - 2235 Capistrano St, Manteca, CA. ...........................................................41
2. ’S RESIDENCE - Manteca, CA 95337 ...........................................41
3. BOPARAI’S FORESTER ................................................................................................................42
4. BOPARAI’S RAM............................................................................................................................42
5. SANDHU’S ACCORD .....................................................................................................................42
F. Training and Experience Regarding Murder-For-Hire Offenses ....................................................43
VI. AUTHORIZATION REQUEST REGARDING APPLICATION FOR WARRANTS TO OBTAIN
PRECISE LOCATION DATA FROM A CELLULAR TELEPHONE .................................................................43
VII. REQUEST FOR SEALING ......................................................................................................................45
1 I. AFFIDAVIT
2 I, Brian Toy, being first duly sworn, hereby depose and state as follows:
3 II. INTRODUCTION
4 1. I make this affidavit in support of an application under Rule 41 of the Federal Rules of
5 Criminal Procedure for a warrant to search the following people, premises, and property described below.
6 Additionally, I submit this affidavit in support of my request to arrest Jagninder Singh BOPARAI,
7 Ramesh Kumar BIRLA Jr., Shaminderjit Singh SANDHU (the TARGET SUBJECTS) for a violation of
8 18 U.S.C. 1958(a) - Conspiracy to Use Interstate Commerce Facilities in the Commission of Murder-for-
9 Hire (the TARGET OFFENSE).
10 Attachment Person/Property Process Sought

SUBJECTS
11 A-1 Jagninder Singh BOPARAI
A-2 Ramesh Kumar BIRLA Jr. Arrests warrant;
12 Search warrant
A-3 Shaminderjit Singh SANDHU
13 A-4 Search warrant
TARGET RESIDENCES
14
A-5 2235 Capistrano St, Manteca, CA 95337 (BOPARAI’S RESIDENCE)
Search warrant
15 A-6 Manteca, CA 95337 ( ’S RESIDENCE)
TARGET VEHICLES
16 A-7 2019 Subaru Forester, CA MEHAR07 (BOPARAI’S FORESTER)
A-8 2022 Dodge Ram, CA PBOOOO4 (BOPARAI’S RAM)
17 Search Warrant
A-9 2019 Honda Accord, CA 8MNE924 (SANDHU’S ACCORD)
18 A-10 2023 Tesla ( ’S TESLA)
TARGET CELLULAR PHONES
19 A-11 (209) 740-6740 (BOPARAI’s Phone)
A-12 (925) 664-8315 (BOPARAI’S Burner Phone
20 Precise location data
A-13 (925) 549-8778 (BIRLA’s Phone)
warrants
21 A-14 (209) 900-7168 (SANDHU’s Phone)
A-15 ( ’s Phone)
22
23 2. The subjects and property to be searched are further described in Attachments A-1 through
24 A-15. The applications seeks to search them for the things described in Attachment B-1 through B-15.
25 As explained throughout this affidavit, and specified on the relevant attachments, I believe these TARGET
26 SUBJECTS are engaged in a Conspiracy to Use Interstate Commerce Facilities in the Commission of
27 Murder-for-Hire, a violation of 18 U.S.C. § 1958(a) (the TARGET OFFENSE). This affidavit also
28 supports my application for arrest warrants for the TARGET SUBJECTS for this offense.
AFFIDAVIT 3
1 III. AGENT BACKGROUND
2 3. I am an investigator or law enforcement officer of the United States within the meaning of
3 Title 18, United States Code, § 2510(7), empowered to conduct investigations of, and to make arrests for,
4 the offenses enumerated in Title 18, United States Code, § 2516.
5 4. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have served in this
6 role since May 2010. I am currently assigned to the Sacramento Division, Stockton Resident Agency.
7 Prior to becoming a Special Agent, I completed 20 weeks of training (the FBI’s Special Agent Basic
8 Training Program) at the FBI Training Academy, Quantico, Virginia. During this program, I received
9 extensive training on all aspects of investigations and investigative methods, including human source
10 handling, physical and electronic surveillance, interrogation methods, drug identification, criminal
11 enterprises, drug trafficking, violent crimes including kidnapping and murder, and financial investigations.
12 5. While serving as an FBI Special Agent, I have investigated criminal violations relating to
13 criminal street gangs, violent crime, and narcotics. I have participated in all aspects of criminal
14 investigations, including interviews, physical surveillance, execution of search warrants, and the arrest of
15 criminals. I have personally investigated an investigation involving violations of Title 18, United States
16 Code, Section 1958, Use of interstate commerce facilities in the commission of murder-for-hire. I am
17 familiar with, and have participated in conventional investigative methods, including electronic
18 surveillance, visual surveillance, the use of GPS/E-911 data, questioning witnesses, applying for and
19 executing search warrants, handling confidential informants, and using pen registers and trap-and-trace
20 devices.
21 6. Through my training and experience, I have become familiar with the identification of
22 violent crime offenders, their communication methods, motivations, weapons used for committing violent
23 acts, as well as how they plan violent acts. During my employment with the FBI, I have been involved
24 with dozens of violent crime investigations including firearms trafficking, gang violence, bank robberies,
25 kidnappings, and murders. I have become knowledgeable in the methods used by violent crime offenders,
26 how they utilize communication devices to evade law enforcement, how they obtain intelligence on their
27 victims, and how they attempt to thwart law enforcement’s investigation into their criminal acts.
28 7. I have personally led and participated in investigations of violent crime over the last
AFFIDAVIT 4
1 thirteen years. I have interviewed violent criminal offenders in order to better understand their state-of-
2 mind, motives, and the methods and tactics which they use for their criminal acts. During the course of
3 these investigations, I have conducted consensual monitoring, physical surveillance, telephone analysis,
4 wiretaps, search warrants, and arrest warrants.
5 8. This affidavit is intended to show that there is sufficient probable cause for the requested
6 search warrants, and does not purport to set forth all of my knowledge of the investigation of this matter.
7 9. The facts in this affidavit come from my personal observations, my training and
8 experience, and information obtained from other agents and witnesses. This affidavit is intended to show
9 merely that there is sufficient probable cause for the requested warrant and does not set forth all of my
10 knowledge about this matter.

11 IV. APPLICABLE LAW
12 10. 18 U.S.C. § 1958 prohibits the use of interstate commerce facilities in the commission of a
13 murder-for-hire. Subsection (a) of this statute provides:

14 Whoever travels in or causes another (including the intended victim) to travel in interstate or
foreign commerce, or uses or causes another (including the intended victim) to use the mail or any
15 facility of interstate or foreign commerce, with intent that a murder be committed in violation of
the laws of any State or the United States as consideration for the receipt of, or as consideration for
16 a promise or agreement to pay, anything of pecuniary value, or who conspires to do so, shall be
fined under this title or imprisoned for not more than ten years, or both; and if personal injury
17 results, shall be fined under this title or imprisoned for not more than twenty years, or both; and if
death results, shall be punished by death or life imprisonment, or shall be fined not more than
18 $250,000, or both.
19 A “facility in interstate or foreign commerce” includes means of transportation and communication. 18

20 U.S.C. § 1958(b)(2). The intent that murder be committed must have existed when the defendant used or
21 conspired to use the facility of interstate commerce. United States v. Driggers, 559 F.3d 1021, 1023 (9th
22 Cir. 2009).
23 V. PROBABLE CAUSE
24 A. The Confidential Source
25 11. This case involves the use of an FBI Confidential Human Source (“CHS”) posing as a
26 hitman. The CHS was opened by the FBI in June 2020. The CHS was subject to the FBI’s direction and
27 control at all times during this investigation. In February 2023, the CHS and BOPARAI arranged to meet
28 to discuss services which BOPARAI needed from the CHS. In total, the CHS met with BOPARAI on five
AFFIDAVIT 5
1 separate occasions and met with BOPARAI’s associates without BOPARAI on one occasion. During
2 these meetings, BOPARAI paid the CHS $7,000 for the assault of VICTIM 1 and a $10,000 down
3 payment for the agreed amount of $30,000 for the murder of VICTIM 2. These funds are currently held in
4 FBI evidence.
5 12. The CHS has participated in dozens of investigations. The CHS is motivated by a desire to
6 help the community by preventing violence and also for financial compensation. During this
7 investigation, the CHS has been paid a total of $3,500 for his/her services during this investigation. The
8 CHS’s criminal history includes a 1998 arrest for engaging in organized criminal activity; a 1998 arrest
9 for burglary of vehicle, a 1999 arrest for theft; a 2000 arrest and conviction for burglary of habitation; a
10 2001 arrest and conviction for burglar of habitation, a 2003 arrest and conviction for violation course
11 order enjoining organized crime act; a 2003 arrest and conviction for theft; a 2004 conviction for
12 marijuana; a 2016 arrest for criminal trespass habit shelter superfund infrastructure; and a 2017 conviction
13 for bail jumping and failure to appear, tamper/fabricate physical evidence w/ intent to impair.
14 13. During this investigation, much of the CHS’s reporting has been independently
15 corroborated by me and other law enforcement officers. Further, all of the CHS’ meetings with the
16 TARGET SUBJECTS were either audio and/or video recorded. To my knowledge, the CHS has not
17 provided me or any other investigator with any false information about this investigation. For these
18 reasons, I consider the CHS’s information regarding the TARGET SUBJECTS to be reliable and
19 trustworthy.
20 B. The TARGET SUBJECTS’ Criminal Histories and Roles
21 14. I have identified the TARGET SUBJECTS listed using the following information sources
22 and criminal indices: the California Department of Motor Vehicles (DMV), the California Law
23 Enforcement Teletype System (CLETS), the National Crime Information Center (NCIC), FBI, multiple
24 local police Records Management Systems (RMS), physical surveillance, conversations with other agents
25 and officers participating in the investigation, and my own participation in the investigation.
26 a. Jagninder Singh BOPARAI has been identified as “Homie Boy,” who is the “boss.”
27 BOPARAI attended five meetings with the CHS and provided payments to the CHS to
28 include $7,000 for the successful assault of VICTIM 1, and a $10,000 down payment for
AFFIDAVIT 6
1 the killing of VICTIM 2. BOPARAI is described as an Indian male born in 1976;
2 approximately 6’00”, 220 pounds with black hair and brown eyes. BOPARAI has a
3 California DMV driver’s license issued to him, under number ending in 1972, with an
4 associated photo of his likeness dated 2020. On March 21, 2023, BOPARAI contacted the
5 Manteca Police Department (MPD) to report suspicious vehicles. He provided his phone
6 number as (209) 740-6740 (“BOPARAI’S PHONE”) (serviced by Verizon Wireless) and
7 his residence as 2235 Capistrano St, Manteca, CA. BOPARAI has no criminal history.
8 b. Ramesh Kumar BIRLA Jr. has been identified as an associate of BOPARAI. BIRLA
9 provided intelligence to BOPARAI and instructions to the CHS on how to conduct the
10 murder of VICTIM 2. BIRLA is described as an Indian male, born in 1978;
11 approximately 6’00”, 240 pounds with black hair and brown eyes. BIRLA has a
13 associated photo of his likeness dated 2019. On March 24, 2023, BOPARAI placed a call
14 identifying the subject as BIRLA asking for BIRLA to send the Facebook profile photo of
15 VICTIM 2. That phone number was identified through tolls as (925) 249-8778
16 (BURLA’S PHONE”)(serviced by AT&T Wireless). BIRLA’s criminal history includes a
17 2002 conviction for annoying phone calls: obscene/threat.
18 c. Shaminderjit Singh SANDHU has been identified as an associate of BOPARAI. He
19 obtained a burner phone for BOPARAI and provided instructions to the CHS on how to
20 conduct the murder of VICTIM 2. SANDHU is described as an Indian male born in
21 1974; approximately 5’09”, 172 pounds with black hair and brown eyes. SANDHU has a
23 associated photo of his likeness dated 2021. On March 20, 2023, SANDHU provided the
24 address of VICTIM 2 which was provided to the CHS through BOPARAI. SANDHU
25 also gave the CHS specific instructions on how to discard VICTIM 2’s body by cutting,
26 burning, and moving the body to Mexico in a suitcase. SANDHU has no criminal history.
27 C. Overt Acts Committed by TARGET SUBJECTS
28 1. February 16, 2023 – BOPARAI’s Initial Meeting with the CHS: BOPARAI Tells the
AFFIDAVIT 7
1 CHS He Wants to Hire Him/Her to Assault VICTIM 1
2 15. Through an intermediary, BOPARAI got in touch with the CHS and arranged to meet. On
3 February 16, 2023, BOPARAI and the CHS arranged to meet in person. BOPARAI sent the CHS a text
4 message with the address of a Starbucks located at 2168 Daniels St, in Manteca, CA.1 After BOPARAI
5 ordered a coffee, he sat down with the CHS2 at an outside table. BOPARAI immediately began the
6 conversation with the below exchange with the CHS (BOPARAI is identified below as “JB”):
7 JB: There’s one guy [VICTIM 1] bust my balls. Talking shit to, about my family,
sending movies to all my buddies, our friends. Staying home and fucking, he’s
8 like a, you know, meth, crack addict. He have no license, not even license, not
even fuckin’, no job, no like, he’s busting my ball.
9
CHS: What do you want?
10
JB: Teach him a lesson.
11
CHS: Huh?
12
JB: Teach him a lesson.
13
CHS: You want to teach him a lesson, you want to get him killed? I’m all for the
14 business. I don’t ask questions.
15 JB: I know.
16 CHS: That’s what I’m saying. All you gotta let me know is this is what I want done,
show me a picture of the guy, (UI) who he hangs around, you know, you let me
17 know, I go do my intel and I go do my thing. You know what I mean?
18 JB: Ok.
19 CHS: I’m serious about this. This is, this is what I do. This is like what I fuckin’ do.
You know what I mean, I don’t play no games. I’m being straight up with you.
20
JB: I don’t want to game you. That’s why I’m serious. Pay you, you do your thing.
21 We don’t know it.
22 16. Based on my training, experience, and knowledge of this investigation, I believe that
23 BOPARAI knew that the purpose of the meeting was to discuss hiring the CHS to commit acts of violence
24 against his (BOPARAI’s) enemies. BOPARAI immediately started the conversation explaining that he
25 had a feud with VICTIM 1, who, according to BOPARAI was harassing him, his family, and associates.
26
27 1
All meets between the CHS and BOPARAI or his associates occurred at this location.
28 2
All meetings between the CHS and BOPARAI or his associates were audio and/or video recorded.
AFFIDAVIT 8
1 When the CHS asked BOPARAI what he wanted, BOPARAI responded, “Teach him a lesson.” The CHS
2 understood this to mean some act of violence to be committed against VICTIM 1, but asked to what
3 extent, and if it included killing VICTIM 1. BOPARAI explained to the CHS that he did not want to
4 “game [the CHS],” which I believe meant BOPARAI was signaling he was serious and was not playing
5 around. BOPARAI said he would “pay [the CHS]” to have the CHS “do your thing,” or in other words, to
6 commit the act of violence. By “We don’t know it,” I believe BOPARAI meant he wanted to be able to
7 insulate himself or “[not] know [about the act of violence].”
8 17. Later on in the conversation, the CHS again asked for clarification on exactly what
9 BOPARAI wanted, asking, “That’s what I’m saying, do you want me to disappear him? Do you want me
10 to fuckin’, you know? You gotta let me know. I’m down. I don’t give a fuck. I’m being for reals.”
11 BOPARAI responded, “I don’t want…my name anything like”. I believe instead of being specific about
12 what he meant by “teach him a lesson,” BOPARAI explained that he did not want his name associated in
13 any way to what he wanted done to VICTIM 1. I believe this shows the intent and knowledge that what
14 BOPARAI was asking the CHS to do was criminal in nature.
15 18. Later in the conversation, BOPARAI clarified that “…whatever price we discuss, beat up
16 this, that, I’m down, just tell me the price.” I believe BOPARAI was telling the CHS that he was willing
17 to pay the CHS a price that they could agree on to have VICTIM 1 “beat up.” BOPARAI was “down”
18 which shows his willingness to have the CHS commit this violent act. Further, BOPARAI showed his
19 willingness to help the CHS commit this act when he told the CHS, “Tell me all the information you need,
20 I’ll give you all that. (OV)3 I have the house address. (OV)...house addresses.” I believe this shows
21 BOPARAI knew the CHS needed information on VICTIM 1 in order to accomplish the “beat up” of
22 VICTIM 1. As such, BOPARAI showed a willingness to provide intelligence to help the CHS.
23 19. The CHS again asked for clarification to ensure that the CHS knew exactly what
24 BOPARAI wanted of the CHS:
25 CHS: Out of respect, you gotta let me know specifically what you want. Cause I know
26 you can say, “Take care of him.”
27
28 3
“OV” throughout this affidavit is a notation of “Overlapping Voice,” a fact that makes the recording difficult to decipher.
AFFIDAVIT 9
1 JB: I don’t want, I don’t want to-
2 CHS: It’s its, by you saying take care of him, I could just beat him up. I can just go
3 break his jaw. I could just go break, fuck. You know. (OV) You know what I
4 mean. So whatever you want done that’s what’s gotta be done. It’s not what I
5 want done. It’s what you want done. Cause that’s (UI), you know what I mean?
6 You’re the customer man, you know what I mean? You gotta keep the customer
7 happy, you know what I mean?
8 JB: (BOPARAI laughs). No, it’s not (UI), just my heart is burning, man. My inside
9 is burning. He’s just saying shit and staying home.
10 20. I believe the above exchanges show that although the CHS understood that BOPARAI
11 wanted a violent act committed against VICTIM 1, the CHS wanted further clarification as to the degree
12 of violence BOPARAI wanted. BOPARAI stated that “[he, BOPARAI] don’t want…” I believe
13 BOPARAI was hesitant about being overly explicit about what he wanted knowing that what he wanted
14 was criminal in nature. Further, since it was the first meeting with the CHS, BOPARAI likely felt uneasy
15 and had not built up the requisite level of trust. 4
16 21. Mid-way through the conversation, one of BOPARAI’s associates (later identified as
17 joined the conversation. BOPARAI identified as his “cousin.” It was at this time that
18 BOPARAI disclosed to the CHS that BOPARAI had previously hired an individual for something similar
19 but got scammed: “Man, I already give to somebody. They, they just took my money and fuckin’ left.” I
20 believe this statement shows that BOPARAI had a long-standing motivation to find a “hitman.” However,
21 even though BOPARAI had paid the hitman, this person did not follow through with what he/she was paid
22 to do. As such, BOPARAI was skeptical about whether the CHS would actually do the job or just take his
23 money.
24 22. During this meeting, Boparai relayed to the CHS that “[ ’s] concern is now you
25 know us. You know, like, in case anything happen.” I believe this tends to show that was aware
26
1. 4
It is important to note that later in the investigation on March 14, 2023, when the CHS provided photographic
27 proof of VICTIM 1 being beat up, BOPARAI would later tell the CHS that he trusted the CHS. It is also important to note
that later in this conversation on February 16, 2023, BOPARAI explains how he was scammed previously when he attempted
28 to hire another individual.
AFFIDAVIT 10
1 that what was discussed with the CHS was criminal in nature. I believe also was part of the
2 conspiracy to harm VICTIM 1 and murder VICTIM 2. The CHS told BOPARAI that the CHS only
3 wanted to meet one person and that it was their decision (BOPARAI and ’s) to allow to
4 come along. BOPARAI explained that the reason was present was “Cause they both hurting, you
5 know. He hurting him, he hurting me.” I believe BOPARAI was explaining that both he and
6 were being hurt by VICTIM 1. By “hurt” I believe BOPARAI was referring to the alleged harassment by
7 VICTIM 1 of the TARGET SUBJECTS and their associates, something he described numerous times over
8 multiple meetings. I also believe that there was an additional reason, which was the financial fallout
9 involving among other issues, a disputed property located at , Stockton, CA5. As such, I
10 believe that shares in the same motive in seeking for both VICTIMS to be harmed.
11 23. During the meeting, either BOPARAI or played an audio clip for the CHS. I
12 recognized the voice on this audio clip to belong to VICTIM 1. VICTIM 1 was discussing the “history of
13 the [M] brothers in India.” BOPARAI explained that “[VICTIM 1 was] talking shit, sending you know,
14 everybody. He’s our friend attorney, he send to him. We block him so forward to us.” I believe
15 BOPARAI was sharing that audio clip because it was VICTIM 1 sending the clip to their attorney friend
16 who forwarded the audio to BOPARAI and his associates. As such, I believe the playing of this audio clip
17 of VICTIM 1 for the CHS shows that VICTIM 1 was the intended victim of the assault-for-hire.
18 24. The first meeting concluded with the CHS and BOPARAI agreeing to meet the next day to
19 further discuss BOPARAI’s plans. Based on the initial meeting, I believe that BOPARAI and
20 were interested in hiring a person to assault VICTIM 1. I also believe that BOPARAI had previously
21 hired a similar person who took his money and did not complete the job.
22 //
23
24 //
25 2. February 17, 2023 – BOPARAI Second Meeting with the CHS: Continued Discussion
26 of Job to Assault VICTIM 1; BOPARAI Describes this Job as a Test and Says He has
27
28 5
Details of this property dispute are further detailed below.
AFFIDAVIT 11
1 Another “Big Job” After
2 25. During the second meeting which occurred on the next day, BOPARAI attended the
3 meeting with the CHS and brought along another associate (later identified as BIRLA). The meeting
4 occurred outside in the patio of Starbucks. BOPARAI immediately expressed his desire to have VICTIM
5 1 assaulted. Below is an excerpt of that conversation ( BIRLA is identified as “RB”):

6 JB: For now, I just want to beat that shit, the shit out of that guy. For the next one, I
have big job. Let’s start with the, you know, I want to prove, you know, for right
7 now. Because everybody, see if good, then you can do it. Then the next one, very
easy, he’s always in Stockton, very easy and but that will be totally different-
8
RB: Yeah that guy’s easy.
9 JB: We want him to be done.
10 CHS: Ok.
11 JB: But this one, let’s start with this.

CHS: You want me, you want me to start with this guy-
12
JB: Yeah.
13
26. I believe BOPARAI made his plans clear in this conversation that he had in fact, not only
14
desired for the CHS to assault VICTIM 1 but that he had a “next one,” or second job, ready for the CHS.
15
BOPARAI described it as a “big job.” BOPARAI wanted to use the first job as a way of proving, or
16
testing, the CHS. And if BOPARAI and his associates saw that it was “good, then [the CHS could] do
17
[the second job].” I believe BOPARAI had an interest in harming VICTIM 1, but that another purpose in
18
harming VICTIM 1 was to test the CHS because BOPARAI had previously been scammed by a purported
19
hitman.
20
27. BOPARAI described the next job as “very easy, he’s always in Stockton, very easy and but
21
that will be totally different”. In BOPARAI’s own words, the second job was totally “different.” Based
22
on the totality of all the meetings, I believe the difference between the jobs was that VICTIM 1 was
23
supposed to be assaulted while the next job against VICTIM 2 would be an actual murder. The next job
24
would also be easy, since VICTIM 2 was located in Stockton, CA. BIRLA added, “Yeah that guy’s easy.”
25
This is the first indication that BIRLA was involved in the conspiracy to have VICTIM 2 murdered.
26
Further, BOPARAI elaborated that for the next job, “We want him to be done.” Based on my training,
27
experience, and the facts of this investigation, I believe BOPARAI used the word “done” as a euphemism
28
AFFIDAVIT 12
1 for “killed.”
2 28. BOPARAI and BIRLA then began providing intelligence on VICTIM 1, describing
3 VICTIM 1’s alcohol and drug use, VICTIM 1’s significant other’s activities, and where VICTIM 1 would
4 go in public. The CHS again asked for clarification as to the extent to which BOPARAI wanted VICTIM
5 1 assaulted. Below is an excerpt of that conversation:

6 CHS: You know but I need to know what you want done so I can get it done and be like,
“Look, this is what you-”
7
JB: Let’s start with a good beat up, very good.
8 CHS: This is what you want, this is what you want?
9 JB: Then I have another job.
10 CHS: Ok.
JB: Very good and very easy. Easy one.
11
CHS: There’s no such thing as hard.
12
RB: That guy’s out in in the open.
13 CHS: There’s nothing hard for me.
14 JB: That one is like open yard and he’s-
15 RB: Yeah, he’s out in open air.

CHS: I got my people, there’s nothing hard for me, there’s nothing hard for me. I don’t
16 give two fucks, there’s nothing hard for me.
17 RB: Well, this guy is very evasive. (UI).
18 JB: He’s just motherfucker, faggot, big mouth.

RB: He’s just sits in his house all day-
19
JB: Hide at home and talk.
20
CHS: The first guy?
21 RB: Yeah, this guy (OV).
22
23 29. After the CHS asked for clarification regarding what BOPARAI wanted, BOPARAI made
24 clear that he wanted VICTIM 1 to have a “good beat up, very good.” BOPARAI then told the CHS that
25 after VICTIM 1 was beat up, “Then I have another job.” BOPARAI explained that it was a “very good
26 and very easy” job. BIRLA added that for the second job it was easy because “[VICTIM 2’s] out in the
27 open” and also “out in the open air.” The topic then went back to VICTIM 1 where BIRLA described
28 VICTIM 1 as being “evasive.” BOPARAI further elaborates on the difficulty of the first job involving
AFFIDAVIT 13
1 VICTIM 1 since VICTIM 1 was home all day and did not leave his/her home much. In speaking with
2 both victims, I know that the description of VICTIM 1 and 2 matched my understanding of their lifestyle.
3 30. During the meeting, BIRLA showed his phone to the CHS, allowing the CHS to capture a
4 photo of the CHS and the address of the CHS. I was able to positively identify the photo as that of
5 VICTIM 1 and the address as that of VICTIM 1’s. The CHS again asked for clarification of what
6 BOPARAI wanted, below is an excerpt of the conversation that followed:
7 CHS: Now, you just want, you say you want a beat down. (OV) But that’s all you want,
to do that.
8
JB: Let’s start with this.
9 RB: The beat down has to be decent, man, this fool got to be tore, tore up.
10 CHS: That’s what I’m saying, I-
11 RB: We want to see bruises, we want that fool fucked up not just pop knocking, right?
We want to see some blood, we want to see some, we want the fool fucked up.
12 Not just like, slap him.
31. After the CHS asked if a “beat down” was what BOPARAI wanted, he stated that he
13
wanted to “start with this.” I believe this was just the first of multiple violent acts that BOPARAI wanted
14
the CHS to commit. BIRLA emphasized that the beat down had to be “decent, man, this fool got to be
15
tore, tore up.” I believe BIRLA wanted the CHS to know that VICTIM 1 needed a serious beating.
16
BIRLA wanted VICTIM 1 to have bruises, bleeding, and for VICTIM 1 to be “fucked up.”
17
32. While discussing payment, BOPARAI and the CHS agreed on an amount for the first job
18
and a payment structure for the second. Below is an excerpt of that conversation:
19
JB: Let’s start with the six, I give you one advance, five when you do it. Then next
20 one, after we know, then we half, half.
21 CHS: Ok, on the next one you’ll work with me on the price (OV).
22
RB: We got a few others so if you’ll be good.
23
JB: We’ll give you 50% down after you know, done this part and then-
24
CHS: Ok, sounds good.
25
33. BOPARAI proposed paying $6,000 for the entire job with a $1,000 payment upfront,
26
followed by $5,000 after the job was completed. BOPARAI told the CHS that for the next job involving
27
VICTIM 2, BOPARAI would pay half upfront and half when the job was done. BIRLA told the CHS that
28
AFFIDAVIT 14
1 there were “a few others,” which I believe shows that BIRLA was trying to entice the CHS by telling the
2 CHS that the TARGET SUBJECTS had other jobs or victims for the CHS in the future.
3 34. Later in the conversation, BOPARAI told the CHS that he had multiple jobs and wanted to
4 see how the CHS would do with the first job. Below is an excerpt of that conversation:
5 JB: Let’s, let’s fast, we have two more good jobs after this.
6 CHS: Ok, yeah.
7 JB: We just want to see like, you know, what you say it comes down so that way we
have big job.
8
35. I believe that BOPARAI was telling the CHS to accomplish the first job quickly, as the
9
TARGET SUBJECTS had two other “good jobs.” BOPARAI explained that “we,” (the TARGET
10
SUBJECTS) wanted to see if the CHS could actually follow through with the first job so they could
11
determine if the CHS could do the second, “big job,” which I believe is the killing of VICTIM 2. I also
12
believe that this meeting showed BIRLA’s participation in the conspiracy for the assault of VICTIM 1 and
13
the murder of VICTIM 2.
14
3. March 3, 2023 – BOPARAI’s Third Meeting with the CHS: BOPARAI Pays $1,000 to
15
the CHS as a Down payment for the Assault of VICTIM 1
16
36. On March 3, 2023, the CHS met with BOPARAI for the payment of $1,000 as an initial
17
payment for the assault of VICTIM 1. Prior to the CHS arriving at Starbucks, BOPARAI and multiple
18
associates were observed at Starbucks. During the meeting, BOPARAI asked, “When do you think you
19
can do it? I need that so bad.” I believe BOPARAI was asking when the CHS would conduct the assault
20
of VICTIM 1. BOPARAI then said he had another “very good job after.” I believe BOPARAI was
21
asking the CHS when he/she would complete this first job of assaulting VICTIM 1 and that he
22
(BOPARAI) had another “very good job after [the first job]” for the CHS. Based on future meetings
23
between the two, I believe this second “very good job” was the plot to have the CHS kill VICTIM 2. I
24
believe the assault of VICTIM 1 was merely a test to determine if BOPARAI could trust the CHS before
25
paying the CHS for the murder of VICTIM 2.
26
37. The CHS told BOPARAI that he/she would take care of the first job and that the CHS was
27
waiting for BOPARAI, a reference to receiving an initial payment. BOPARAI stated, “I need to get it
28
AFFIDAVIT 15
1 done fast. Just fucking, crossing the limit. Son of a big mouth motherfucker, talk, talk, talk.” I believe
2 BOPARAI wanted the first job completed and explained that VICTIM 1 had been doing things to “cross
3 the limit” which included talking too much. The CHS asked if BOPARAI brought the money, to which
4 BOPARAI responded, “Yeah.”
5 38. The CHS asked if BOPARAI had a picture of VICTIM 1’s girlfriend. BOPARAI
6 responded that he had a picture of everybody. I believe this shows that BOPARAI has intelligence on
7 VICTIM 1, as well as his/her associates, to assist with the assault of VICTIM 1. BOPARAI demonstrated
8 that he had information on VICTIM 1’s associates and was willing to provide the intelligence to the CHS
9 to help accomplish the assault.
10 39. The CHS later told BOPARAI that he and his crew were “ready for the other job.”
11 Immediately, BOPARAI responded, “That’s just a test.” I believe that when the CHS expressed a
12 willingness to conduct the next job, BOPARAI told the CHS that the current job was “just a test.” I
13 believe that although VICTIM 1 was the intended victim of the assault, the true purpose of BOPARAI
14 having the CHS assault VICTIM 1 was to test the CHS to see if the CHS was indeed a hitman who could
15 carry out an actual assault. I believe that BOPARAI intended to test the CHS in order to determine if the
16 CHS could follow through with the murder of VICTIM 2.

17 40. Later, BOPARAI asked, “When do you think like, as soon as.” The CHS believed
18 BOPARAI was asking when the CHS could complete the assault of VICTIM 1, and responded that he/she
19 could complete it within a week. The CHS asked BOPARAI to bring the other half of the payment the
20 next time they met.
21 41. BOPARAI again stated to the CHS that “This just a test. The other one is fucking good,
22 good job, easy one.” BOPARAI explained that VICTIM 1 was hiding and that VICTIM 2 was always out
23 in Stockton therefore the second job would be easy. The CHS asked “What’s up with [VICTIM 2]?”
24 BOPARAI responded, “That one, I tell you later. Has to do with this.” I believe this corroborates the
25 relation between VICTIM 1 and VICTIM 2 and how both were involved in a feud with BOPARAI which
26 is the motive for the assault of VICTIM 1 and the murder of VICTIM 2. BOPARAI again stated that
27 “[The assault of VICTIM 1 was] just a test. BOPARAI already had two jobs planned out: the first job for
28 the CHS involved VICTIM 1, who was hiding and did not go in public much; and the second job involved
AFFIDAVIT 16
1 VICTIM 2 and was actually the easier job because VICTIM 2 was out in Stockton often. I do not believe
2 the “test” for the first job was due to its difficulty level being lower than the second job, as BOPARAI
3 made clear that the second job was easier. In other words, the first job was not a test to see if the CHS
4 could accomplish a simpler task in order for BOPARAI to provide the second job, a more difficult job.
5 Based on BOPARAI’s statements, the second job was in fact easier. I believe the first job was a test
6 because BOPARAI intended to have VICTIM 2 murdered so the assault of VICTIM 1 was a test of the
7 CHS’ willingness to engage in a violent criminal act, and also to see whether the CHS was trying to scam
8 BOPARAI out of money, in which case the CHS would not complete the first job.
9 42. The CHS then spoke in a softer tone with BOPARAI asking, “Cause, cause, you, you,
10 really want me to fuckin’ beat [VICTIM 1’s] motherfuckin’ ass, right?” BOPARAI responded, “Yeah.”
11 BOPARAI moments later explained that “The next one, different.” I believe that when the CHS was
12 confirming with BOPARAI that he wanted VICTIM 1 to be assaulted, BOPARAI responded “Yeah”
13 indicating that he was intent on having the CHS harm VICTIM 1. BOPARAI again discussed “the next
14 one,” which is a reference to the next job which he had intended for the CHS. BOPARAI described it as
15 “different.” I believe BOPARAI explained the second job as “different” because it would not just be an
16 assault of an individual, but the killing of an individual.

17 43. BOPARAI then told the CHS, “If I tell you somebody have like $4 million sitting
18 somewhere, you think you can get ‘em?” The CHS responded, “Without a doubt, without a doubt.”
19 BOPARAI asked that the CHS to “share with me,” which I believe was BOPARAI wanting to have the
20 CHS rob a business and share the loot with BOPARAI. I believe this shows the scope of BOPARAI’s
21 criminal activity, which includes not just violent acts against individuals but also robberies for financial
22 gain.
23
24
25
26
27
Figure 1: From left to right: BIRLA, BOPARAI, and
28
AFFIDAVIT 17
1 44. BOPARAI would eventually leave the CHS and go to the bank to withdraw money for the
2 initial payment. Before departing, BOPARAI made a call in the presence of the CHS. Phone records
3 show that at that moment, BOPARAI placed a call to a phone believed to be used by
6
4 who was present during the first meet on February 16, 2023. After the call, BOPARAI left the
5 CHS to go to the bank to retrieve money to pay the CHS. Surveillance captured BOPARAI leaving
6 Starbucks with two other individuals (later identified as BIRLA and The three rode in ’s
7 vehicle.
8 45. Approximately 52 minutes later, BOPARAI returned and again met with the CHS.
9 BOPARAI provided the CHS $1,000. The CHS and BOPARAI had the following exchange:
10 CHS: I thought it was going to be $3,000.
11 JB: No, no, no, I said remember I said six, one and then five when we
done. Ok.
12
CHS: You said, you, came down six, then you said two, but then I told you I
13 need three.
14 JB: First one…come on, don’t worry about the money. I’ll give you one
extra. But just do this job for me. I’ll give you, but just do it quick,
15 please.
16 CHS: Ok on the next one, I need-
17 JB: Half.
18 CHS: No, the job is going to be done the next time I see you. So I’m going to
need everything.
19
JB: Everything. Plus, the next job, I give you half first.
20
CHS: Ok.
21
JB: The next job.
22
CHS: Ok.
23
JB: Yeah. But, I need that quick if you can. Trust me.
24
CHS: Yes, that’s the $2 million dollar one you’re talking about?
25
JB: No, that one is easy one. That one is like robbing, you know.
26
CHS: Ok.
27
28 6
I believe this number is used by based on database checks.
AFFIDAVIT 18
1 JB: That one, really, he’s in Stockton. I don’t know how you’re going to do it
but we talk.
2
CHS: Yeah, one thing at a time.
3
JB: That one is different. That one is different. The second job is
4 different. That’s also guy. But then, I don’t know what you’re going to
do between that, that’s $4 million, but share with me. Whatever I have.
5
CHS: That’s what I’m saying. I got people that I gotta take care of so I can get
6 shit done. You know what I mean?
7 JB: Yeah. He’s in Stockton, he’s an easy target. But I don’t know how you -
lonely. I’ll tell you everything.
8
CHS: Yeah. Do, do, do your research then-
9
JB: I already do research-
10
CHS: Be ready for the next one-
11
JB: I already do research. Yeah, I don’t want myself involved. Cause they
12 know me.
13 CHS: No one knows that we been talking, you know what I mean. We don’t
need to do much. You know what I mean?
14
JB: That’s good money. Try to, give me my share that’s all. Fuck the rest, you
15 know?
16 CHS: Ok, we’ll talk. We’ll definitely talk. You’re the, you’re the one with the-
17 JB: (UI) Trust me. You’ll be good.
18 CHS: Ok.
19 JB: Thank you brother, let’s do it, you know.
20 CHS: Alright.
21 JB: Tell me how it is.
22 CHS: Alright.
23 JB: Alright, brother.

46. Based on my training and experience, I believe this exchange shows that BOPARAI
24
intended to provide the CHS with a “next job” if the CHS completed the first job. The CHS discussed
25
how BOPARAI did not follow through with paying the $3,000, which was the agreed-upon initial
26
payment for a total of $6,000. BOPARAI offered to give the CHS an extra “one,” or $1,000, and asked
27
the CHS to “do it quick, please.” I believe BOPARAI was promising the CHS an extra $1,000, and asking
28
AFFIDAVIT 19
1 VICTIM 1 to be assaulted quickly. BOPARAI told the CHS he would pay the CHS “everything” the next
2 time they met, after the CHS completed the first job. BOPARAI said that for the “next job, [BOPARAI
3 would] give [the CHS] half first.” The CHS asked if the next job was the robbery for $2 million. 7
4 BOPARAI clarified that it was not the robbery job but the job that involved “[VICTIM 2] in Stockton.”
5 BOPARAI further clarified that “the second job is different. That’s also guy.” I believe BOPARAI was
6 clarifying that the next job involved a person also like the first job and not the robbery of a business. I
7 believe it involved the harm of another person, namely VICTIM 2. When the CHS told BOPARAI to “do
8 your research [on VICTIM 2], BOPARAI responded, “I already do research.” I believe that BOPARAI
9 was telling the CHS that he had already conducted the “research” which the CHS needed to conduct the
10 second job. I believe this also shows that BOPARAI intended to have the CHS kill VICTIM 2 even
11 before the assault of VICTIM 1. BOPARAI also stated, “Yeah, I don’t want myself involved.” I believe
12 this shows that BOPARAI knows the serious criminal implications of this second job, which was to kill
13 VICTIM 2, and therefore he did not want “[himself] involved. Cause they know me.”
14 4. March 8, 2023 – BOPARAI or His Associates send Two Surveillance Pictures to
15 VICTIM 1 in an Attempt to Intimidate VICTIM 1
16 47. On March 3, 2023, your affiant met with VICTIM 1, who told your affiant about his/her
17 relationship with BOPARAI. VICTIM 1 was originally a close associate of BOPARAI, BIRLA, the
18 Brothers, and other BOPARAI associates. VICTIM 1 told agents that he/she would be paid by the
19 Brothers for services which VICTIM 1 would perform. Over time, VICTIM 1 believed that
20 he/she was in a “cult,” as the group exerted more and more control over VICTIM 1. VICTIM 1 knew
21 about the details of how BOPARAI and his associates defrauded VICTIM 2 out of the property at
22 . In approximately November 2022, BOPARAI and others played a prank on VICTIM 1,
23 harassing VICTIM 1 at his/her residence. VICTIM 1 called the police, who responded and arrested
24 VICTIM 1 after discovering that VICTIM 1 had an outstanding warrant, which VICTIM 1 was not aware
25 of. After getting arrested, VICTIM 1 ended his/her relationship with BOPARAI and his associates.
26 VICTIM 1 then went to VICTIM 2 and disclosed to VICTIM 2 how BOPARAI and his associates had
27
28 7
This was a reference for the $4 million job but the CHS referred to it as $2 million believing he/she would keep half.
AFFIDAVIT 20
1 discussed plotting to kill VICTIM 2. Ever since then, VICTIM 1 had been harassed by BOPARAI and his
2 associates. 8 VICTIM 1 believed that BOPARAI was also attempting to harm or kill VICTIM 1.
3 48. On March 6, 2023, your affiant again spoke to VICTIM 1, who expressed a willingness to
4 cooperate with law enforcement in their investigation of BOPARAI. Agents worked with VICTIM 1 to
5 stage fake surveillance photographs. The photographs were intended to be props to further bolster the
6 CHS’ credibility by creating the appearance that the CHS was indeed conducting surveillance on VICTIM
7 1 for the purpose of assaulting VICTIM 1.
8 49. On March 8, 2023, the CHS was sent two photographs of VICTIM 1, which were obtained
9 by your affiant on March 6, 2023. The CHS was instructed to send those two photos to BOPARAI via
10 WhatsApp in an effort to show that the CHS was conducting surveillance on VICTIM 1 in order to carry-
11 out the assault, confirm BOPARAI’s intended victim, and BOPARAI’s intention for the CHS to carry-out
12 the assault. The CHS sent two photos to BOPARAI and asked, “is this the guy that needs he’s ass beat?
13 He was driving that .” The two photos which the CHS sent are depicted below.
14
15
16
17
18
19
20
21
22
23 50. Approximately nine minutes after sending the photos, the CHS received a call from
24 BOPARAI but was unable to answer. The CHS immediately called BOPARAI back via WhatsApp.
25 Almost immediately after answering the phone, BOPARAI asked, “Where you find [VICTIM 1]…where
26
27
8
Recorded meets between CHS and BOPARAI showed BOPARAI making similar statements that VICTIM 1 was harassing
28 BOPARAI and his associates.
AFFIDAVIT 21
1 this picture at?” The CHS provided a fabricated story that VICTIM 1 was followed to a Starbucks in
2 downtown Stockton, CA. BOPARAI responded, “Oh shit…yeah this is the guy.” The CHS asked for an
3 additional $2,000 for payment since BOPARAI had only provided $1,000 of the agreed $3,000 initial
4 payment. BOPARAI responded, “let’s do this, money is not an issue.” BOPARAI also elaborated that “I
5 already spent too much money people take and never done.” Based on the facts of this investigation, I
6 believe that BOPARAI had been scammed by an alleged hitman and was telling the CHS that he did not
7 want to provide any more money since he had paid someone who took his money and never followed
8 through. BOPARAI continued attempting to convince the CHS to finish the job by saying, “You do this
9 thing, I give you the money, right there. No questions asked.” BOPARAI wanted to speak to the CHS in-
10 person and stated, “we can postpone this.9” BOPARAI stated his “team” did not want to pay anything
11 more and that he did not want to talk on the phone anymore.
12 51. Approximately 73 minutes after the start of the above call between the CHS and
13 BOPARAI, VICTIM 1 received two photos and messages from an unknown number, (760) 537-3263.10
14 VICTIM 1 provided a screenshot (see below) of those two photos to your affiant, which your affiant
15 recognized as the very same photos which your affiant had sent to the CHS hours earlier and which the
16 CHS had sent to BOPARAI approximately 1:23 hour earlier. After the photos were sent, the sender also
17 sent four eye emojis and wrote, “How it going / What you doing.” It is important to note that your affiant
18 did not disseminate those photos to anyone outside of the FBI other than the CHS who only sent the
19
20 9
I believe that when BOPARAI stated, “we can postpone this,” he was not wanting to postpone the assault of VICTIM 1.
Throughout this investigation, BOPARAI has not wanted to discuss paying the CHS even after agreeing on a payment
21 amount. For example, the initial payment of $1,000 for the assault of VICTIM 1 was supposed to be $3,000. BOPARAI
later offered to pay the CHS an additional $1,000 to make a total of $7,000. However, after the CHS completed the assault of
22 VICTIM 1, BOPARAI only paid $5,000 of the remaining $6,000. After agreeing to pay $15,000 for the initial payment for
murder of VICTIM 2, BOPARAI only paid $10,000. In each instance, after the CHS was shorted and asked for the agreed
23 payment amount, BOPARAI cut off the CHS stating that the CHS would get paid and that money was not an issue. I believe
when BOPARAI stated, “postpone this,” he was actually wanting to stop talking about the extra $2,000 which the CHS was
24 asking for. In other words, BOPARAI was telling the CHS to talk about the money next time. BOPARAI cited a reason for
not wanting to pay more was because he had previously paid a hitman who did not follow-through with the job. BOPARAI
25 also suggested meeting to talk in person since he did not want to speak over the phone. I believe that for all these reasons,
BOPARAI was not expressing a desire to postpone the assault, but was instead trying to avoid having the conversation of
26 paying the CHS over the phone.
27 10
The FBI is currently working on identifying the registered user of this number, which appears to be a VOIP number.
Given the fact that these photos were only shared with BOPARAI, however, I suspect the user of this number is either
28 BOPARAI himself or one of his associates.
AFFIDAVIT 22
1 photos to BOPARAI. The photos were also not provided to VICTIM 1.
2
3
4
5
6
7
8
9
10
Figure 2: Screenshot of VICTIM 1’s phone which captured surveillance photos of VICTIM 1 which the FBI took and
11 provided to BOPARAI through the CHS.
12 52. Based on my training and experience, I believe that BOPARAI sent or had an associate
13 send those photos to VICTIM 1 to intimidate VICTIM 1 by showing VICTIM 1 that he/she was being
14 watched. Based on my training and experience, I believe that VICTIM 1’s receipt of these photos shows
15 a desire on the part of BOPARAI to instill fear into VICTIM 1. I believe this shows his intent to harm
16 VICTIM 1.
17 5. March 14, 2023 – BOPARAI’s Fourth Meeting with the CHS: Payment of Another
18 $5,000 for the Assault of VICTIM 1, and Discussion of Two Other Jobs, Including the
19 Murder-For-Hire Job of VICTIM 2

11
20 53. On March 14, 2023, the CHS met with BOPARAI, who brought along After
21 ordering drinks at Starbucks, BOPARAI and the CHS had the below exchange:
22 JB: We did good?
23 CHS: Yeah.
24 JB: You got anything to show me?
25 CHS: Yeah.
26 JB: That’s what I like to hear.
27
28 11
was present during the first meeting between the CHS and BOPARAI.
AFFIDAVIT 23
1 54. After the CHS explained how VICTIM 1 was followed from his/her residence, kidnapped,
2 taken to an orchard and assaulted, the CHS showed BOPARAI a photo from the CHS’s phone. The below
3 photo is the photo that agents had provided to the CHS to show BOPARAI. The photo was taken with the
4 cooperation of VICTIM 1.
5
6
7
8
9
10
11
12
13
14
15
Figure 3: Photo created by the FBI of VICTIM 1, with VICTIM 1’s consent, which was used to as proof to BOPARAI that
16 the CHS completed the task of assaulting VICTIM 1.
17 55. After seeing the photo, BOPARAI stated, “I like it.” Below is a photo of the CHS holding
18 his/her phone and showing BOPARAI the above photo of VICTIM 1 laying on the ground after being
19 assaulted.
20
21
22
23
24
25
26 Figure 4: Photo of the CHS’ hand holding the CHS’ phone to show BOPARAI the (staged) photo of VICTIM 1
beaten and laying on the ground
27
28 56. BOPARAI told the CHS that “we” had tried to pick up” VICTIM 1 four or five times
AFFIDAVIT 24
1 unsuccessfully. I believe this was BOPARAI telling the CHS that he and his associates had tried to find,
2 kidnap or “pick up,” and assault VICTIM 1 on four or five separate occasions, but were unsuccessful. I
3 believe this also demonstrates BOPARAI’s intent to harm VICTIM 1 was present long before the CHS
4 ever made contact with BOPARAI. I also believe this shows that multiple individuals associated with
5 BOPARAI also had the same intent to harm VICTIM 1, likely the same associates who attended meetings
6 with the CHS and BOPARAI, including BIRLA, SANDHU and
7 57. After seeing the photo of VICTIM 1, BOPARAI brought up the idea of the CHS helping
8 BOPARAI conduct two other “jobs.”12 One of the jobs BOPARAI brought up involved robbing a
9 business which he claimed had upwards of $4 million in cash stored at the business. The second job
10 involved making a person “disappear.” Below is an exchange between the CHS and BOPARAI regarding
11 the second job:
12 JB: I don’t want to see the body. The body (UI). Just tell me a number for how
much.
13
CHS: For, for what?
14
JB: For the guy to disappear.
15
CHS: To disappear?
16
JB: I don’t want to see him at all. Nobody could find him.
17
CHS: No one will find him.
18
JB: Tell me a number.
19
CHS: 30,000.
20
JB: I’ll give you 40.
21
(CHS and BOPARAI discussed details about half of the payment being needed upfront.)
22
JB: (UI) find the body, I’ll be fucked.
23
CHS: They won’t find the body.
24
58. Based on my training and experience, I believe this second job involved killing an
25
individual whom BOPARAI identified in the March 20, 2023 meeting as VICTIM 2. BOPARAI made it
26
clear that this job would require that the CHS dispose of the body so that “Nobody could find him.”
27
28 12
These two jobs were initially discussed with the CHS during BOPARAI’s meeting with the CHS on March 3, 2023.
AFFIDAVIT 25
1 Although BOPARAI did not say “kill” or “murder,” I believe that when BOPARAI stated he wanted the
2 “guy to disappear,” this was a coded phrase for having VICTIM 2 killed. It is my experience when
3 criminal subjects discuss their criminal activities, whether it is child pornography, narcotics trafficking, or
4 violent crime, the subjects often use coded or vague terms. In other words, “disappear” is a euphemism
5 for “murder.” I believe, based on the context of having a person “disappear” so “nobody could find him,”
6 BOPARAI was using coded terms to hire the CHS to murder VICTIM 2. BOPARAI also showed an
7 extreme desire to see this happen since the CHS asked for $30,000 to murder VICTIM 2 but BOPARAI,
8 without hesitation and without the CHS negotiating, offered “40,” or $40,000. Further, BOPARAI
9 showed that he knew what he was asking for was wrong when he stated that if the body of VICTIM 2 was
10 ever found, he would be “fucked.”

11 59. BOPARAI later told the CHS, “Give me one week, let cool down everything, restart. I’ll
12 give you 15 first.” I believe that BOPARAI was telling the CHS to wait one week in order to let things
13 “cool down” and “restart” because he believed VICTIM 1 was just assaulted and it would appear
14 suspicious if VICTIM 2 was murdered, since it was public knowledge that BOPARAI had a feud with
15 both VICTIM 1 and VICTIM 213 and both VICTIMS knew of each other. BOPARAI also confirmed that
16 he would provide “15” which would have been one-half of the total of $30,000 which the CHS
17 requested. 14
18 60. BOPARAI also instructed the CHS, “When we talk, just delete everything, please.” I
19 believe this shows not only BOPARAI’s intent to have VICTIM 2 killed, but also his awareness of the
20 seriousness of what BOPARAI was asking the CHS to do. As such, BOPARAI asked for the CHS to
21 delete their messages (referring to their WhatsApp messages), since it would be evidence that could
22 possibly incriminate BOPARAI.
23 61. When the CHS and BOPARAI left the Starbucks, BOPARAI gave the CHS an envelope
24 from Bank of the West. The CHS asked how much was in the envelope, to which BOPARAI responded,
25
13
Although VICTIM 2 was not identified by BOPARAI to the CHS until March 20, 2023 I believe BOPARAI already had
26 VICTIM 2 in mind and knew that VICTIM 1 and VICTIM 2 were associated. As such, an assault of one followed closely in
time by the murder of the second would cause suspicion.
27
14
The CHS asked for $30,000 originally. BOPARAI offered $40,000. However, the CHS expressed a desire for half of
28 $30,000 as a down payment and was willing to receive any extra if BOPARAI wanted to pay for the CHS’s service.
AFFIDAVIT 26
1 “5.” The CHS told BOPARAI that he (BOPARAI) had promised to pay an extra $1,000, making the total
2 payment $7,000, and so this payment should have been $6,000 since BOPARAI paid $1,000 in the first
3 payment. BOPARAI responded, “Don’t worry about anything now. Now we good, now we know, trust
4 me. You’ll be happy the next time you see me.” I believe that when BOPARAI stated, “Now we good,
5 now we know,” he was telling the CHS that the CHS and BOPARAI’s relationship was now at a different
6 stage. Previously, BOPARAI had been scammed by a hitman who took payment but never performed.
7 Now that the CHS had shown that the CHS could indeed carry-out what he/she promised, BOPARAI’s
8 relationship was now “good.” In other words, BOPARAI now trusted the CHS. BOPARAI also stated,
9 “now we know,” which I believe is an indication that BOPARAI and his associates, or “we,” know that
10 the CHS was indeed a legitimate hitman. I believe BOPARAI was telling the CHS “You’ll be happy the
11 next time you see me” because he intended to pay the CHS a much higher amount for the payment for the
12 next job, which was the murder of VICTIM 2.
13 6. March 20, 2023 – BOPARAI’S Fifth Meeting with the CHS: BOPARAI, and
14 SANDHU Gives the CHS Information on VICTIM 2 and BOPARAI pays the CHS a
15 $10,000 Down Payment for the Murder of VICTIM 2
16 62. On March 20, 2023, the CHS met with BOPARAI who brought along three associates, one
17 of whom was positively identified by your affiant as SANDHU. While waiting for their drinks at
18 Starbucks, BOPARAI told the CHS that he was carrying a firearm. BOPARAI allowed the CHS to touch
19 the firearm, which the CHS used his/her hand to touch.

20 63. After getting their drinks, the CHS and BOPARAI left Starbucks and sat inside the CHS’
21 vehicle. BOPARAI handed the CHS two Bank of America envelopes and stated that each envelope had
22 “5.” The CHS counted the cash in the envelopes which totaled $10,000. BOPARAI left the vehicle,
23 stating that he had to go and meet an associate. Surveillance observed BOPARAI walk to Starbucks,
24 where two other associates showed up. BOPARAI sat with the two associates outside and appeared to
25 count cash while concealing the cash under the table and between his legs. Based on my training and
26 experience, I believe that BOPARAI was supposed to provide the CHS $16,000, but had only provided
27 $10,000 up to that moment. BOPARAI likely received cash from one of the two associates whom he was
28 meeting with.
AFFIDAVIT 27
1 64. Shortly after, BOPARAI walked back to the CHS’ vehicle, sat in the vehicle, and asked the
2 CHS, “Do you still have that picture, that motherfucker?” The CHS understood BOPARAI to be referring
3 to the picture which the CHS had showed BOPARAI on March 14, 2023 of VICTIM 1 after VICTIM 1
4 was allegedly assaulted. BOPARAI then called two of his associates over. The two associates (who were
5 observed sitting at the table with BOPARAI minutes earlier) walked over and looked at the CHS’ phone.
6 One of the associates was positively identified by your affiant as After viewing the photo,
7 BOPARAI spoke to his associates in a foreign language and all the subjects laughed.
8 65. BOPARAI then handed the CHS a bundle of cash which amounted to $1,000. I believe
9 that this cash was obtained from one of the two associates while BOPARAI sat with those individuals.
10 BOPARAI told the CHS that he would provide a picture and that his other ‘buddy” was trying to get a
11 photo. I believe this was in reference to obtaining photos of VICTIM 2 so that the CHS would have the
12 intelligence necessary to identify, locate, and murder VICTIM 2.
13 66. The CHS asked BOPARAI if he could provide a gun. BOPARAI stated that he could
14 provide the CHS with a gun that was “no track” and ammunition that were “no track bullets” from Utah. I
15 believe BOPARAI was telling the CHS that he (BOPARAI) could provide the CHS with firearms that
16 could not be traced. During the conversation, the CHS also made it clear that he/she was a felon and did
17 not care about the firearm laws.
18 67. The CHS spoke with BOPARAI about the two “jobs” which they had discussed during the
19 last meeting. Since there were two “jobs,” the CHS wanted to clarify exactly what BOPARAI wanted
20 done. One of the jobs involved a robbery, for which the CHS proposed they use the term “paper” when
21 discussing this job. The second job involved killing and making a person disappear, which the CHS
22 proposed terms involving the “chop[ping] up” of a tree. Below is a transcript of this portion of the
23 conversation:
24 CHS: First, let’s establish something. When it has to do with the job of the money,
we’re going to say paper.
25
JB: Paper.
26
CHS: Ok? The paper job.
27
JB: Ok, Ok.
28
CHS: So, we won’t say anything, ok?
AFFIDAVIT 28
2 JB: Teach me something, yeah.
3 CHS: And about this one, “Did you already chop up the tree in the house?” That means
I already, I already killed him, disappear.
4
JB: Uh huh.
5
CHS: So when you say, “Did you already cut the, the, the tree, the trunk? That means
6 we’re talking about the guy you want disappeared. Ok? So we won’t talk about
single names or nothing, ok?
7
JB: I got you.
8
9 68. Based on my training and experience, I believe that BOPARAI understood that the CHS
10 was attempting to establish coded terms in order to facilitate their discussions about the different jobs that
11 BOPARAI wanted to hire the CHS to do. When BOPARAI stated, “Teach me something, yeah,” I believe
12 he was interested and wanted to learn from the CHS, who he believed was a hitman, so that he and the
13 CHS could better communicate while still concealing their criminal activity without incriminating
14 themselves.
15 69. BOPARAI showed the CHS a picture on his phone which showed two males. The CHS
16 asked, “That’s the one you want disappeared?” BOPARAI responded, “Yeah.” The CHS used his/her
17 phone and took a picture of the photo of the two males. The CHS later provided the photo to your affiant
18 who recognized the person who BOPARAI wanted “disappeared” as VICTIM 2. The CHS asked if
19 anyone else knew about the job and BOPARAI said, “no one except that mustache guy.” I believe that
20 “mustache guy” was a reference to SANDHU, who has a distinct handlebar mustache. 15
21 70. Later in the conversation, BOPARAI told the CHS that “After [the murder of VICTIM 2],
22 I’ll be happy, happy, happy, good, happy like normal. I’ll be like normal. Like, I don’t care, do other
23 things.” I believe BOPARAI was expressing to the CHS that he was looking forward to the CHS
24 murdering VICTIM 2. After the successful completion of the murder, BOPARAI would be very happy.
25
26
27
15
During a March 24, 2023, meeting with the CHS, BIRLA and SANDHU, SANDHU identified himself as “the mustache
28 guy.”
AFFIDAVIT 29
1 BOPARAI also told the CHS that SANDHU was scared and got a prepaid phone from AT&T16 because
2 he did not want his number associated with the plot to murder VICTIM 2.
3 71. Shortly after, SANDHU arrived and interacted with the CHS and BOPARAI through the
4 passenger side of the CHS’ vehicle. SANDHU was holding two phones, one of which I believe was the
5 prepaid phone that was just purchased. Just moments earlier, BOPARAI told the CHS that his associate,
6 who I believe was a reference to SANDHU, was scared. BOPARAI told the CHS that SANDHU had told
7 him, “I don’t want to give him that number” so he (SANDHU) went to purchase a prepay phone. I believe
8 that SANDHU purchased a prepay phone because he intended to use it in furtherance of the murder-for-
9 hire plot and did not want his personal phone to be associated in any way. Approximately three minutes
10 after SANDHU arrived at the CHS’ vehicle, the CHS observed SANDHU showing BOPARAI his phone.
11 BOPARAI used his phone and took a picture of SANDHU’s phone.
12
13
14
15
16
17
18
19
20 Figure 5: SANDHU (blue shirt) holding a phone while BIRLA (seated in the passenger seat) uses his phone to take a picture
of VICTIM 2’s address, which was moments later provided to the CHS.
21
22 72. BOPARAI immediately showed the CHS his phone with the photo of what BOPARAI had
23 captured from SANDHU’s phone. The CHS took a picture of BOPARAI’s phone and captured a street
24 address in a post which was timestamped “3:18 PM” which was the exact time in the recording of the
25 meet. Based on my training and experience, I believe that SANDHU purchased a phone for the sole
26 purpose of obtaining intelligence on VICTIM 2 in order to provide to the CHS. I also believe that
27
16
On March 24, 2023, SANDHU met with the CHS and told the CHS that he had a burner phone and to have the CHS
28 contact BOPARAI on the burner phone moving forward.
AFFIDAVIT 30
1 SANDHU did not show his phone to the CHS for the CHS to take a picture because SANDHU was scared
2 and did not want to provide the CHS with the intelligence directly. Therefore, he had BOPARAI take a
3 photo, which was then provided to the CHS. I believe this shows that SANDHU is knowledgeable that he
4 is participating in criminal activity that can have severe consequences. As such, he attempted to insulate
5 himself from other parties in the criminal conspiracy of murdering VICTIM 2 by attempting to insulate
6 himself from the CHS.
7 73. Later in the meeting, BOPARAI and the CHS had an exchange which clearly shows
8 BOPARAI’s nefarious intentions when he instructs the CHS not to leave any evidence. Below is an
9 excerpt of that exchange:
10 JB: No evidence.
11 CHS: Huh?
JB: No evidence at all. Disappear.
12
CHS: Ok, if you want him disappear cause if you say it come back to you he’s going to
13 disappear.
14 JB: Disappear.
CHS: Period.
15
JB: Period.
16
CHS: If it comes back to you, it comes back to me.
17 JB: You’re right. You’re right.
18 CHS: I take care of myself that’s how I take care of myself. That’s why I… (OV)
19 JB: Then you’re going to have to kill me, too. (BOPARAI laughs)
20 74. Based on my training and experience, I believe that BOPARAI was concerned about what
21 he was paying the CHS to do, that is, to murder VICTIM 2. As such, he wanted to emphasize to the CHS
22 not to leave any evidence. BOPARAI reiterated, “No evidence at all. Disappear.” BOPARAI wanted
23 VICTIM 2 to be murdered or disappear as to not leave any evidence. The CHS acknowledged BOPARAI
24 emphasizing that VICTIM 2 would disappear, “period.” BOPARAI responded, “Period,” showing that he
25 was emphatic about the CHS conducting the murder in a way which left absolutely no evidence. I believe
26 this shows BOPARAI’s intentions and also his knowledge of what he wanted the CHS to do.
27 75. The CHS then asked for VICTIM 2’s name. BOPARAI responded by telling SANDHU to
28
AFFIDAVIT 31
1 tell the CHS VICTIM 2’s name (this conversation was spoken in Punjabi). SANDHU stated VICTIM 2’s
2 first name twice and then both BOPARAI and SANDHU provided VICTIM 2’s nickname.
3 76. The CHS asked for VICTIM 2’s cell phone. BOPARAI began to share VICTIM 2’s phone
4 number to which the CHS asked to take a picture of that phone number. I believe BOPARAI provided
5 this phone number as the phone number could be used to call VICTIM 2 in an attempt to set up VICTIM 2
6 for the murder.
7 77. The CHS also asked for VICTIM 2’s social media accounts. BOPARAI placed a call to
8 (925) 549-8778, a phone used by BIRLA. In the call, BOPARAI spoke in PUNJABI, asking BIRLA to
9 take a picture of VICTIM 2’s Facebook profile photo to send to BOPARAI. BIRLA stated he was
10 blocked from VICTIM 2’s Facebook profile, but that he would get it and send it to BOPARAI.
11 Approximately two minutes later, the two had another phone call in which BOPARAI asked BIRLA to
12 send the photo. Moments later, BOPARAI showed the CHS a photo of VICTIM 2’s Facebook profile.
13 VICTIM 2 later confirmed this was his/her Facebook profile.

14 78. In all, BOPARAI provided the CHS with four photos for the purpose of intelligence in the
15 murder-for-hire investigation:
16 a. Photo of VICTIM 2 with another male subject in the background.
17 b. Photo of VICTIM 2’s home address which was provided by BOPARAI after he took a
18 photo of the address from SANDHU’s phone.
19 c. Photo of VICTIM 2’s cell phone number.
20 d. Photo of VICTIM 2’s Facebook profile photo.
21 79. At the end of the meeting, BOPARAI told the CHS, “Give me good news as soon as you
22 can.” I believe that BOPARAI was telling the CHS that he wanted “good news” of the CHS successfully
23 killing VICTIM 2 and that he wanted this “job” completed soon. I believe this shows that BOPARAI is
24 intent on having VICTIM 2 killed.
25 7. March 24, 2023 – Meeting between BIRLA, SANDHU, and the CHS (Monitored by
26 BOPARAI) to discuss how to kill VICTIM 2
27 80. On March 23, 2023 the CHS contacted BOPARAI to arrange a meeting for March 24,
28 2023. The purpose of the meeting was to provide a photo of VICTIM 2 and his/her vehicle and present
AFFIDAVIT 32
1 the photo to BOPARAI to confirm the victim for the murder-for-hire plot and confirm his/her desire to
2 have VICTIM 2 murdered. BOPARAI did not respond to the CHS’ calls or texts, either through
3 WhatsApp or regular phone calls/texts. BOPARAI eventually responded via WhatsApp asking the CHS,
4 “Answer my cousin phone”. A WhatsApp message came through from (925) 664-8315, an AT&T
5 serviced phone which I believe was the phone BOPARAI stated SANDHU had purchased during the
6 March 20, 2024 meeting. The CHS contacted that number with the user of that number confirming they
7 were “mustache guy” (SANDHU). SANDHU arranged to meet the CHS. The meeting occurred in the
8 CHS’ vehicle, in the parking lot by Starbucks.

9 81. During the meeting, SANDHU and BIRLA entered the CHS’ vehicle. SANDHU
10 explained that BOPARAI was out-of-town. However, surveillance was able to confirm that BOPARAI
11 was sitting in his vehicle nearby. I believe SANDHU lied because BOPARAI was trying to insulate
12 himself. SANDHU instructed the CHS that the TARGET SUBJECTS had a “burner phone,” which was a
13 reference to the phone that had contacted the CHS, (925) 664-8315. BIRLA elaborated that it was for the
14 purpose of “being cautious.” SANDHU instructed the CHS to only contact BOPARAI through the burner
15 phone.
16 82. During the meeting, the CHS reiterated the coded terms that the CHS had discussed with
17 BOPARAI during the March 20, 2023 meeting. Below is an excerpt:

18 CHS: For sure cause [OV] cause you understood [OV] when I told them about chopping
up the tree.
19
SS: Yeah.
20
RB: Yeah.
21
CHS: You know that’s what we talk about our guy so we wouldn’t have to say [OV].
22
SS: He understand that.
23
24 83. I believe that SANDHU and BIRLA both confirmed their understanding that the coded
25 terms involving “chopping up the tree” were for the purpose of disguising their conversations about the
26 murder of VICTIM 2. SANDHU instructed the CHS, “Another thing is we don’t want any evidence.”
27 BIRLA and then SANDHU again emphasized, “No evidence.” I believe this shows that both BIRLA and
28 SANDHU know that the purpose of their conversation was in regard to the murder of VICTIM 2.
AFFIDAVIT 33
1 SANDHU again emphasized, “Yeah no. Another thing is if we don’t want don’t kill him until its hundred
2 percent take him away to Mexico.” I believe SANDHU was telling the CHS that the TARGET
3 SUBJECTS did not want the CHS to “kill” VICTIM 2 unless the CHS was a “hundred percent” confident
4 that it could be accomplished without any evidence by taking VICTIM 2’s body to Mexico. It is
5 important to note that SANDHU wanted to emphasize to the CHS that the CHS should not proceed with
6 killing VICTIM 2 unless it was a certainty that there would be no evidence left behind. SANDHU stated
7 on six separate occasions that the CHS should proceed only if it was “hundred percent” certain there
8 would be no evidence. Both BIRLA and SANDHU used the word “suitcase,” which the CHS understood
9 to mean for the CHS to take the body of VICTIM 2 away to Mexico in a suitcase where it can be disposed
10 of, further evading U.S. law enforcement from being able to identify the body of VICTIM 2. SANDHU
11 continued stating, “cut, burn, and then no evidence.” I believe SANDHU was trying to emphasize to the
12 CHS that absolutely no evidence could remain for the murder for VICTIM 2 even if it meant having to cut
13 and burn VICTIM 2’s body. BIRLA added, “We don’t even want dental records.” I believe this shows
14 that BIRLA is aware that dental records are a common way of identifying remains even after
15 decomposition since a person’s teeth can remain intact for a long period of time allowing law enforcement
16 to compare those teeth with dental records.

17 84. The CHS showed SANDHU and BIRLA two photos which agents had obtained of
18 VICTIM 2 and VICTIM 2’s vehicle. Both BIRLA and SANDHU confirmed these were pictures of
19 VICTIM 2 and his/her vehicle. SANDHU then asked the CHS to show BIRLA the photo of VICTIM 1
20 beaten on the ground. BIRLA saw the photo and exclaimed, “Oh shit, yeah that’s him, yeah.” Below is a
21 photo of SANDHU which was captured at this moment.
22
23
24
25
26
27
28
AFFIDAVIT 34
2
3
4
5
6
7
8
9 Figure 6: SANDHU looking back into a recording device while sitting in the CHS’ front passenger seat.
10 85. SANDHU again emphasized to the CHS, “Till it’s hundred percent full proof, don’t do it.”
11 I believe SANDHU was concerned about the murder leaving evidence, which was why he again
12 emphasized that the CHS needed to ensure that the murder was “hundred percent full proof.” BIRLA also
13 agreed, “Don’t do it till you are 100 percent.”

14 86. SANDHU later told the CHS, “You don’t know the mustache guy.” I believe SANDHU
15 was telling the CHS that the CHS could never disclose his knowledge of SANDHU, who called himself
16 the “mustache guy.” SANDHU did not want his involvement with the CHS to ever be known.
17 87. BIRLA also showed his participation and knowledge of the murder-for-hire plot when he
18 used the CHS’ coded terms to tell the CHS, “The physical tree needs to be a few hundred miles away.”
19 The CHS had just moments earlier reiterated that terms involving the cutting of trees was a way to
20 disguise their conversation about the murder of VICTIM 2. I believe that BIRLA was using the coded
21 terms previously discussed by telling the CHS that VICTIM 2’s body, or “the physical tree,” had to be far
22 away so that there would be no evidence.
23 88. SANDHU told the CHS about how the CHS needed to break VICTIM 2’s phone right
24 away when the CHS killed VICTIM 2 because VICTIM 2’s phone might be wiretapped by the “Feds.”
25 SANDHU and BIRLA explained their conspiracy to cover their tracks by providing “the Feds” fake
26 complaints against VICTIM 2. Below is an excerpt:

27 SS: His phone might be [OV] his phone might be cause he’s into this shit.
28 RB: He’s tapped.
AFFIDAVIT 35
1 SS: His phone might be getting tapped so break the phone right away.
2 RB: Break it right away.
3 SS: The phone.
4 RB: The feds might be onto him.
5 CHS: Okay okay what is he on what us what does he do.
6 SS: No, he’s not like a, we, we just complaining like cause he hired someone to
eliminate us.
7
CHS: Oh, okay, okay.
8
SS: So we were trying give a complaint to feds that he is trying to eliminate us.
9
CHS: Okay, okay.
10
RB : Just to protect ourselves.
11
SS: Just to protect ourselves.
12
13 89. I believe the TARGET SUBJECTS instructed the CHS to immediately break the CHS’
14 phone because the TARGET SUBJECTS were planning on contacting the “Feds,” which would likely be
15 the FBI, to make a complaint that VICTIM 2 was hiring hitmen to “eliminate,” or kill them. The purpose
16 of this accusation was so that when VICTIM 2 was killed by the CHS, the TARGET SUBJECTS could
17 use their previously filed complaint to show that they were not hiding anything but were in fact targeted
18 victims themselves of VICTIM 2. Further, with VICTIM 2 killed, the TARGET SUBJECTS could
19 explain to law enforcement and members of the community that VICTIM 2 had fled because he/she was
20 under investigation by the FBI for trying to hire hitmen to kill the TARGET SUBJECTS. I believe the
21 purpose of this scheme was to protect the TARGET SUBJECTS when VICTIM 2 was murdered. Your
22 affiant learned on March 28, 2023, that SANDHU had indeed filed a police report alleging these same
23 accusations with the Lathrop Police Department. 17

24
25 17
Throughout this investigation, there has been no indication to your affiant that there were any confirmed threats against the
TARGET SUBJECTS.
26
On March 26 and 28, 2023, VICTIM 2 advised that he/she was solicited by a subject identified as , who offered to help
27 protect VICTIM 2 with his/her troubles, which VICTIM 2 understood to mean problems with the TARGET SUBJECTS.
VICTIM 2 further explained that he/she was approached by about three weeks earlier. VICTIM 2 stated he/she did not
28 take up ’s offer for assistance. VICTIM 2 said that he/she later learned, through an associate, that went to SANDHU,
telling him that VICTIM 2 had offered kill SANDHU. VICTIM 2 believed that approached both VICTIM 2
AFFIDAVIT 36
1 90. SANDHU also told the CHS, “So, we have to, I have to send all emails ready.” SANDHU
2 also planned on preparing emails so he could “send um sending to feds this and this guy is hired to
3 eliminate us.” BIRLA told the CHS that VICTIM 2 had sent four people over to BIRLA’s home,
4 presumably to harm BIRLA. 18 I believe SANDHU was laying out their plan to cover their involvement in
5 VICTIM 2’s murder by sending the FBI emails accusing VICTIM 2 of wanting to kill the TARGET
6 SUBJECTS. SANDHU knew that once VICTIM 2 was killed, law enforcement would focus on the
7 TARGET SUBJECTS. As such, SANDHU instructed the CHS not to contact the TARGET SUBJECTS
8 on any phones because they would be under investigation by law enforcement.

9 91. During the meeting, SANDHU also referenced BOPARAI as “Homie Boy,” who was the
10 one in charge. BOPARAI had a reputation of being a “bad ass,” and so he would be scrutinized by law
11 enforcement once VICTIM 2 went missing.
12 92. After the meeting, SANDHU called the CHS on the burner phone to tell the CHS not to
13 take any action in killing VICTIM 2, but to give the TARGET SUBJECTS a few days in order for them to
14 prepare their complaints against VICTIM 2 and send them to law enforcement. I believe SANDHU
15 wanted to pre-emptively make his complaints so it would seem that his complaints arose out of a
16 legitimate threat from VICTIM 2 while VICTIM 2 was alive rather than for it to appear that the
17 complaints were made as a reaction to VICTIM 2’s death.
18 93. I believe this meeting showed not only that SANDHU and BIRLA were participants in the
19 conspiracy to hire the CHS for the murder of VICTIM 2, but also showed that they had already planned
20
and SANDHU in an effort to pit the two against each other in order to get them to pay them for their information and/or
21 protection.
22 On March 27, 2023, SANDHU filed a police report with the Lathrop Police Department alleging that,
“[VICTIM 2] was soliciting for a hitman to kill [SANDHU]. [SANDHU] received one call where the caller
23 stated [VICTIM 2] offered him to kill [SANDHU]. [SANDHU] refused to identify who the caller
was because he believed it would result in that individual retaliating. With the amount of calls he received,
24 along with the statements made, [SANDHU] feared for his life and believed that [VICTIM 2] put a hit on
him to have him killed. [SANDHU] did not receive a direct or specific threat, but found the information
25 regarding the hit to be credible.”
The report does not note whether SANDHU provided a specific date or time of that call. This is consistent SANDHU’s
26 recorded statements to the CHS on March 24, 2023, that he was going to file a police report regarding an alleged threat by
VICTIM 2. Notably, although this report was made to the Lanthrop Police Department, SANDHU also provided an email
27 with this report. That email including several law enforcement entities, including the FBI.
18
On March 26, 2023, during an interview with VICTIM 2, VICTIM 2 stated emphatically that he/she had never sent anyone
28 to BIRLA’s home nor has he/she hired anyone to harm or kill the TARGET SUBJECTS.
AFFIDAVIT 37
1 out how they would cover their tracks by having false complaints sent to the FBI.
2 D. Interview of VICTIM 2 / Potential Motive for Murder-For-Hire Plot
3 94. On February 13, 2023, your affiant spoke with Amo VIRK, a private investigator who had
4 interviewed VICTIM 2 on February 11, 2023. VIRK advised that VICTIM 2 obtained information that he
5 and VICTIM 1 were targets for a murder-for-hire plot.

6 95. On February 14, 2023, your affiant met VICTIM 2 in-person to obtain information directly
7 from VICTIM 2. VICTIM 2 advised that he/she had obtained information from VICTIM 1 and others that
8 BOPARAI had been inquiring with associates about hiring a hitman to assault and/or kill both VICTIM 1
9 and VICTIM 2.
10 96. During this and subsequent meetings, VICTIM 2 provided background which provided a
11 motive for the TARGET SUBJECTS to want to kill VICTIM 2.19 In October 2021, VICTIM 2 closed on
12 the property at Stockton, CA, purchasing the property for $2.6 million under VICTIM 2’s
13 business, , INC, which he/she had sole ownership and control. The property was purchased
14 with $1 million in funding from three subjects who are identified as the “ Brothers.” 20 The three
15 brothers are hereafter designated as , and . The agreement was that after
16 purchasing the property, it would get developed by VICTIM 2 into a truck parking yard which would then
17 be resold to the Brothers. The property value appreciated much higher than expected. As such,
18 the Brothers were not able to obtain a loan for the higher purchase amount.
19 97. The Brothers advised VICTIM 2 to sell it to other buyers. VICTIM 2 advised the
20 Brothers to file a lien on the property to ensure that their funds that they had provided VICTIM 2
21 to purchase the property would be guaranteed in case anything happened to VICTIM 2. In January 2022,
22 VICTIM 2 signed documents allowing the Brothers to file a lien on the property. The paperwork
23 provided VICTIM 2 with six months to pay $2.184 million from the original purchase date of the property
24 in October 2021. However, VICTIM 2 was under the impression that he/she had to pay off approximately
25
19
The following information is meant to provide background as to VICTIM 2’s belief regarding the motives for why the
26 TARGET SUBJECTS want VICTIM 2 killed. These facts were obtained from VICTIM 2 and have not been fully
corroborated but are being provided as background. Further, this background will provide facts pertaining items listed in
27 Attachment B which can further corroborate the motive for the investigation into 18 U.S.C. § 1958.
28 20
There was also funding from one other source but for the purpose of this affidavit that source is not being detailed.
AFFIDAVIT 38
1 $1.6 million (including interest) to cover the lien. VICTIM 2 acknowledged not reading the documents in
2 their entirety at signing.

3 98. After January 2021, VICTIM 2 obtained offers for the property and received offers
4 upwards of $10 to $14 million. VICTIM 2 entered into a contract with a buyer for $14 million. This
5 amount would have covered the lien which VICTIM 2 owed the Brothers. Although the buyer
6 appeared eager, the buyer backed out. Later, VICTIM 2 learned from an associate who had heard that one
7 of the Brothers, M.M., had met up with the potential buyer and told the potential buyer not to
8 purchase the property since the property would default. M.M. told that buyer that the Brothers
9 would sell the property to the buyer for $8 million. VICTIM 2 believes that MM was thwarting his ability
10 to sell the property in hopes that VICTIM 2 could not pay the $2.184 million balloon payment which was
11 due April 27, 2022.
12 99. In March 2022, VICTIM 2 attempted to obtain a loan to cover the lien amount which
13 he/she still believed to be approximately $1.6 million. VICTIM 2 was approved for the loan but found out
14 three days before the balloon payment deadline that the amount owed was $2.184 million. VICTIM 2
15 agreed to pay the extra funds through an escrow account created by BIRLA. BIRLA worked with a
16 finance entity which had already approved VICTIM 2 for $1.6 million. BIRLA opened an escrow account
17 with Chicago Title Insurance Company. VICTIM 2 contacted Chicago Title which advised that there
18 were no wire instructions detailed in the escrow account. VICTIM 2 then believed that the escrow
19 account was a ploy which was created but was never intended to allow him/her to cover the $2.184 million
20 lien. By not making the payment on the balloon payment, the Brothers would be able to have
21 VICTIM 2 default. Prior to the deadline, an attorney working with VICTIM 2 and the Brothers
22 provided a cashier’s check to cover the full lien amount but for some reason the funds were not transferred
23 to the Brothers.
24 100. The Brothers attempted to foreclose on the property but had difficulties since they
25 could not provide proof of the source of the $2.184 million. The Brothers utilized another way to
26 take ownership of the property by selling the $2.184 note to an associate of the Brothers under the
27 business Wild Hawk LLC. Wild Hawk LLC attempted to foreclose on the property but was unsuccessful.
28 101. On December 7, 2022, SANDHU and BIRLA Jr. created fictitious corporate meeting
AFFIDAVIT 39
1 minutes that essentially ousted VICTIM 2 from his/her corporation, INC. and placed
2 SANDHU as the president. The next day, the property at was transferred to Church Street
3 Equity Trust, which is owned by Jagninder Singh BOPARAI. The following day, the property was
4 transferred to Wild Hawk LLC. Wild Hawk LLC contacted a business that was leasing the property at
5 , , instructing them to pay future lease payments to Wild Hawk LLC. and
6 no longer to INC. Lastly, in February 2023, Wild Hawk LLC transferred the property at
7 to Royal Eagle Properties LLC.
8 102. VICTIM 2 also has heard through associates that the TARGET SUBJECTS have identified
9 multiple properties (further identified in Attachment B) which belong or belonged to VICTIM 2. Their
10 plan is to have VICTIM 2 killed and then for the properties to be fraudulently transferred to entities in
11 their control. When asked how they were going to accomplish the transfer, BOPARAI told an associate
12 that BIRLA would take care of it. BIRLA has been reported to backdate notary records in order to
13 fraudulently create legal documents to help transfer property. VICTIM 2 is also the plaintiff in a lawsuit
14 against BOPARAI, BIRLA,21 SANDHU, and the Brothers. VICTIM 2 believes that the
15 TARGET SUBJECTS want to kill him/her in order to end the civil lawsuit involving as
16 well as provide an opportunity for the TARGET SUBJECTS to take ownership of his other properties.
17 103. Your affiant is providing these facts, which were relayed by VICTIM 2, not for the purpose
18 of providing probable cause for this fraud but for the purpose of providing background and a possible
19 motive for the following facts which I believe provide probable cause that BOPARAI, BIRLA, and
20 SANDHU have conspired to violate 18 U.S.C. §1958, conspiracy to use interstate commerce facilities in
21 the commission of murder-for-hire.
22
23
21
VICTIM 2 also alleged that BIRLA had defrauded VICTIM 2 in the sale of a property which VICTIM 2 held under the
24 entity DKSB Investment LLC, BIRLA had a fictitious business SKY 9 Commercial, which was supposed to be filed by
BIRLA for VICTIM 2. It was later discovered that the business was filed under BIRLA’s wife who received approximately
25 $400,000 from the escrow account which was supposed to go to VICTIM 2 from the sale of the property.
26 BIRLA also created SB Property INC. as a joint entity that VICTIM 2 and BIRLA would utilize in business investments.
However, the corporation was filed under RS. VICTIM 2 provided 100% of funds which were used to pay for the purchase
27 of two properties which were then controlled by RS through SB Property INC.
28
AFFIDAVIT 40
1 E. Probable Cause for Locations and Vehicles
2 1. BOPARAI’s Residence - 2235 Capistrano St, Manteca, CA.
3 104. BOPARAI’s DMV address of record for his California driver’s license shows an address of
4 2235 Capistrano St, Manteca, CA 95337. BOPARAI has been observed driving a black Subaru Forester,
5 CA, bearing license plate MEHAR07. That vehicle has been observed parked on the driveway of
6 BOPARAI’s residence at 2235 Capistrano St on multiple occasions during this investigation.
7 105. Further, on March 23, 2023, BOPARAI reported to the Manteca Police Department that
8 there had been two suspicious vehicles in his neighborhood in the last day. BOPARAI provided his
9 address to the officer as 2235 Capistrano St, Manteca, CA.
10 2. ’S RESIDENCE - Manteca, CA 95337
11 106. DMV address of record for his California driver’s license shows an address of
12 Manteca, CA 95337. His DMV records also shows a July 10, 2022, citation
13 while driving a vehicle with CA license plate . DMV registration records for that vehicle
14 showed it registered to a ., who I know is the brother of out of
15 Manteca, CA 95337.
16 107. It is important to note that the mailbox outside of has the street
17 address designated as , Manteca, CA on the mailbox. The adjacent properties have
18 address numbers in the 200’s. I believe that the address is an error and that the
19 actual address is indeed Manteca, CA 95337.
20 108. During the March 3, 2023, meeting between the CHS and BOPARAI, BOPARAI called
21 ’s phone number, asking for money. Moments later, BOPARAI left with
22 BIRLA in ’s black Tesla SUV driven by The vehicle did not have license plates.
23 109. On March 23, 2023, surveillance observed a similar black Tesla SUV parked at
24 Manteca, CA. The Tesla resembled a Tesla without license plates driven by on
25 March 3, 2023. Again, on March 28, 2023, a similar black Tesla SUV was again observed at the
26 location. The lot occupied by Manteca, CA is over large.
27 The property also has in the front. There is no street parking on the road in
28 front of the front driveway. The only way to see the residence is through the open metal driveway gate,
AFFIDAVIT 41
1 which is approximately 22’ wide. The residence is also approximately feet away from the road. As
2 such, it is extremely difficult for agents to conduct surveillance on the location or obtain license plates of
3 vehicles parked inside the property. However, based on database checks and the observation of a similar
4 black Tesla SUV at the location, I believe this is ’s residence.
5 110. Based on my training and experience, I know that subjects involved in white collar crimes
6 such as real estate fraud often have residences and businesses in which they store their records. I also
7 know that BIRLA is a licensed real estate agent in California with a restricted license. Although this
8 affidavit is not intended to provide probable cause for a white collar crime violations, I believe that the
9 real estate fraud alleged by VICTIM 1 provides a possible motive for the murder-for-hire plot. As such,
10 because VICTIM 1 and VICTIM 2 have both alleged BIRLA is involved in real estate fraud, and because
11 VICTIM 2 alleged that such fraud may be a motive for the murder-for-hire plot, I believe there is a
12 likelihood that records detailed in Attachment B could be present at the TARGET LOCATIONS.
13 3. BOPARAI’S FORESTER
14 111. On February 16, 2023, during the meeting with the CHS, BOPARAI was observed driving
15 his black Subaru Forester bearing CA Lic. MEHARO7. The same Forester has been observed parked on
16 the driveway of BOPARAI’s residence at 2235 Capistrano St. on multiple occasions during this
17 investigation including, as recently as on March 22, 2023. I believe that BOPARAI is regularly driving
18 this vehicle and that there is probable cause to believe that items from Attachment B are located in the
19 vehicle.
20 4. BOPARAI’S RAM
21 112. On March 14, and 24, 2023, BOPARAI’s pickup truck was observed at the meets with the
22 CHS. The vehicle was identified as a grey Dodge pick-up bearing CA license plate PBOOOO4. I believe
23 that BOPARAI is regularly driving this vehicle and that there is probable cause to believe that items from
24 Attachment B are located in the vehicle.
25 5. SANDHU’S ACCORD
26 113. On March 20, 2023, SANDHU drove to the meeting with the CHS and BOPARAI. At this
27 meeting, SANDHU used his newly purchased AT&T phone to show BOPARAI VICTIM 2’s address. A
28 photo of the address was taken by BOPARAI, who then allowed the CHS to take a photo. I believe that
AFFIDAVIT 42
1 SANDHU is regularly driving this vehicle and that there is probable cause to believe that items from
2 Attachment B are located in the vehicle.

3 F. Training and Experience Regarding Murder-For-Hire Offenses
4 114. Based on my training and experience, and the training and experience of other agents with
5 greater prior involvement in murder-for-hire investigations, I know the following:

6 a. Individuals who seek the assistance of others to murder someone often maintain materials
7 about their intended victims in their residences, in their vehicles, on their persons, and on
8 their digital devices. Murder-for-hire suspects often maintain information about their
9 intended victims in order to provide it to their chosen “hitman” to ensure that the “hitman”
10 kills the correct target. This information could include photographs of the intended
11 victims, their home address, their business address, information about other places they
12 frequent or their habits generally, information about the victims’ family members, and
13 other information that could be used by a hitman to carry out the murder for which he or
14 she is hired.
15 b. Individuals who seek out the assistance of others to murder someone often do so because
16 the individual believes that the intended victim has wronged him/her or poses some threat
17 or risk to the individual’s business, personal, or other interests. Murder-for-hire suspects
18 often maintain information about their intended victims and the origins of the perceived or
19 actual dispute with, or threat or risk posed by, the victims. Suspects often maintain this
20 information in their residences, vehicles, on their persons, and on their digital devices.
21 c. Individuals who seek out the assistance of others to murder someone utilize cellular
22 phones to communicate, as detailed above in this affidavit. I also know that these subjects
23 will often utilize cameras to obtain photographs or “intelligence” on their intended
24 victims. These photographs are often transferred through hard drives, thumb drives,
25 optical discs and are viewed through tablets, laptops, and desktop computers.
26 VI. AUTHORIZATION REQUEST REGARDING APPLICATION FOR WARRANTS
27 TO OBTAIN PRECISE LOCATION DATA FROM A CELLULAR TELEPHONE
28 115. In my training and experience, I have learned that T-Mobile, AT&T, and Verizon are
AFFIDAVIT 43
1 companies that provides cellular telephone access to the general public. I also know that providers of
2 cellular telephone service have technical capabilities that allow them to collect and generate information
3 about the locations of the cellular telephones to which they provide service, including E-911 Phase II data,
4 also known as GPS data or latitude-longitude data and cell-site data, also known as “tower/face
5 information” or cell tower/sector records. E-911 Phase II data provides relatively precise location
6 information about the cellular telephone itself, either via GPS tracking technology built into the phone or
7 by triangulating on the device’s signal using data from several of the provider’s cell towers. Cell-site data
8 identifies the “cell towers” (i.e., antenna towers covering specific geographic areas) that received a radio
9 signal from the cellular telephone and, in some cases, the “sector” (i.e., faces of the towers) to which the
10 telephone connected. These towers are often a half-mile or more apart, even in urban areas, and can be 10
11 or more miles apart in rural areas. Furthermore, the tower closest to a wireless device does not necessarily
12 serve every call made to or from that device. Accordingly, cell-site data is typically less precise that E-
13 911 Phase II data.

14 116. Based on my training and experience, I know that carriers such as AT&T, Verizon
15 Wireless, and T-Mobile can collect E-911 Phase II data about the location of the Target Cell Phone,
16 including by initiating a signal to determine the location of the Target Cell Phone on their network or with
17 such other reference points as may be reasonably available.
18 117. Based on my training and experience, I know that T-Mobile, AT&T, and Verizon can
19 collect cell-site data about the Target Cell Phone. Based on my training and experience, I know that for
20 each communication a cellular device makes, its wireless service provider can typically determine: (1) the
21 date and time of the communication; (2) the telephone numbers involved, if any; (3) the cell tower to
22 which the customer connected at the beginning of the communication; (4) the cell tower to which the
23 customer connected at the end of the communication; and (5) the duration of the communication. I also
24 know that wireless providers such as T-Mobile, AT&T, and Verizon typically collect and retain cell-site
25 data pertaining to cellular devices to which they provide service in their normal course of business in order
26 to use this information for various business-related purposes.

27 118. Based on the foregoing, I request that the Court issue the proposed search warrants,
28 pursuant to Federal Rule of Criminal Procedure 41 and 18 U.S.C. § 2703(c).
AFFIDAVIT 44
1 119. I further request that the Court direct the respective carriers to disclose to the government
2 any information described in Attachment B that is within the possession, custody, or control of the
3 respective carriers. I also request that the Court direct the respective carriers to furnish the government all
4 information, facilities, and technical assistance necessary to accomplish the collection of the information
5 described in Attachment B unobtrusively and with a minimum of interference with the respective
6 carriers’ services, including by initiating a signal to determine the location of the Target Cell Phone on
7 the respective carriers’ network or with such other reference points as may be reasonably available, and
8 at such intervals and times directed by the government. The government shall reasonably compensate the
9 respective carriers for reasonable expenses incurred in furnishing such facilities or assistance.
10 VII. REQUEST FOR SEALING
11 120. I further request that the Court order that all papers in support of this application, including
12 the affidavit, arrest warrants, and this complaint, be sealed until further order of the Court. These
13 documents discuss an ongoing criminal investigation that is neither public nor known to all of the targets
14 of the investigation. Accordingly, there is good cause to seal these documents because their premature
15 disclosure may seriously jeopardize that investigation.
16
17
18
19
20
21
22
23
24
25
26
27
28
AFFIDAVIT 45
1 VIII. CONCLUSION
2 121. Based on my training, experience, and the information contained within this affidavit, I
3 believe that probable cause exists to believe the TARGET SUBJECTS committed the TARGET
4 OFFENSE. Also based on the foregoing, I submit there is probable cause to search the subject and
5 locations described in ATTACHMENTS A-1 through A-15 for the items described in ATTACHMENTS
6 B-1 through B-15. I also submit that there is probable cause to arrest the TARGET SUBJECTS for
7 violations of the TARGET OFFENSE.
8
Respectfully submitted,
9
10 /s/
11 BRIAN TOY
Special Agent
12 FBI
13
14 Subscribed and sworn to before me on: 03/29/2023 @ 3:45 p.m.
15
16 Hon. Kendall J. Newman

17 U.S. MAGISTRATE JUDGE
18
19
/s/ Adrian T. Kinsella
20 Approved as to form by AUSA ADRIAN T. KINSELLA
21
In addition, with regard to the request for warrants to obtain precise location data from the target cellular
22 telephones, to ensure technical compliance with 18 U.S.C. §§ 3121-3127, I also request that this warrant
shall also function as a pen register order. I thus certify that the information, under oath, that likely to be
23 obtained is relevant to an ongoing criminal investigation conducted by the FBI, based on the agent’s
affidavit herein. See 18 U.S.C. §§ 3122(b), 3123(b).
24
25
26
27
28
AFFIDAVIT 46

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Case 2:23-mj-00050-KJN Document 7 Filed 04/03/23 Page 1 of 46

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

United States of America )

Code Section Offense Description

18 U.S.C. § 1958 Conspiracy to Commit Murder for Hire

This criminal complaint is based on these facts:

Please see attached affidavit of FBI Special Agent Brian Toy

☒ Continued on the attached sheet.

Special Agent Brian Toy, FBI

Sworn to me and signed via telephone.

Date: 03/29/2023 @ 3:45 p.m.

10 Attachment Person/Property Process Sought

1 III. AGENT BACKGROUND

10 knowledge about this matter.

13 murder-for-hire. Subsection (a) of this statute provides:

19 A “facility in interstate or foreign commerce” includes means of transportation and communication. 18

24 A. The Confidential Source

1 the killing of VICTIM 2. BOPARAI is described as an Indian male born in 1976;

6 number as (209) 740-6740 (“BOPARAI’S PHONE”) (serviced by Verizon Wireless) and

10 murder of VICTIM 2. BIRLA is described as an Indian male, born in 1978;

16 (BURLA’S PHONE”)(serviced by AT&T Wireless). BIRLA’s criminal history includes a

17 2002 conviction for annoying phone calls: obscene/threat.

18 c. Shaminderjit Singh SANDHU has been identified as an associate of BOPARAI. He

20 conduct the murder of VICTIM 2. SANDHU is described as an Indian male born in

27 C. Overt Acts Committed by TARGET SUBJECTS

1 CHS He Wants to Hire Him/Her to Assault VICTIM 1

24 BOPARAI wanted of the CHS:

26 you can say, “Take care of him.”

1 JB: I don’t want, I don’t want to-

7 happy, you know what I mean?

9 is burning. He’s just saying shit and staying home.

1 Another “Big Job” After

5 1 assaulted. Below is an excerpt of that conversation ( BIRLA is identified as “RB”):

11 JB: But this one, let’s start with this.

5 1 assaulted. Below is an excerpt of that conversation:

15 RB: Yeah, he’s out in open air.

18 JB: He’s just motherfucker, faggot, big mouth.

6 CHS: Ok, yeah.

16 CHS could follow through with the murder of VICTIM 2.

16 assault of an individual, but the killing of an individual.

10 CHS: I thought it was going to be $3,000.

16 CHS: Ok on the next one, I need-

17 JB: (UI) Trust me. You’ll be good.

19 JB: Thank you brother, let’s do it, you know.

21 JB: Tell me how it is.

23 JB: Alright, brother.

15 VICTIM 1 in an Attempt to Intimidate VICTIM 1

22 . In approximately November 2022, BOPARAI and others played a prank on VICTIM 1,

1 photos to BOPARAI. The photos were also not provided to VICTIM 1.

19 Murder-For-Hire Job of VICTIM 2

22 JB: We did good?

24 JB: You got anything to show me?

26 JB: That’s what I like to hear.

10 ever found, he would be “fucked.”

22 possibly incriminate BOPARAI.

15 $10,000 Down Payment for the Murder of VICTIM 2

19 the firearm, which the CHS used his/her hand to touch.

2 JB: Teach me something, yeah.

13 VICTIM 2 later confirmed this was his/her Facebook profile.

16 a. Photo of VICTIM 2 with another male subject in the background.

18 photo of the address from SANDHU’s phone.

19 c. Photo of VICTIM 2’s cell phone number.