SUPREME COURT: COUNTY OF NASSAU

STATE OF NEW YORK

THE PEOPLE OF THE STATE OF NEW YORK

-against-
Indictment No. 33Nl8
a/k/a
a/k/a
VICTOR LOPEZ

a/k/a
KEVIN TORRES a/k1a INQUIETO
EVER MORALES LOPEZ a/k1a LENKY
AUGUSTINE BENITEZ a/k1a OLVIDADO
KEVIN CUEVAS DEL CID a/k/a CREEPER
MAURICIO MENDOZA a/k1a CYCLO
EDGAR a/k/a
a/k1a
a/k/a
a/k1a

Defendants

At all times relevant to this indictment, unless otherwise indicated:

INTRODUCTION

Members of the violent trans-national street gang Mara Salvatrucha, commonly referred to as MS-
13, agreed and conducted criminal activities such as murder, assault, and drug trafficking, here in
Nassau County, New York, and elsewhere in the United States and abroad. Specifically,
defendants in the instant case operated on Long Island, and the geographic scope of their
criminality extended on a national level from New York to New Jersey, Maryland, Virginia, and
Texas, and on an international level to EI Salvador. While Mara Salvatrucha was one large
organization, it was broken down regionally into sub-groups referred to as "cliques."
a/k/a and other similarly situated gang members, reported to
the gang's leaders in EI Salvador, who received the gang's profits and directed the cliques in EI
Salvador and in the United States in furtherance of their criminal enterprise. The leaders in EI
Salvador directed the regional clique leaders and their members, who participated in conference
calls referred to as "Ls" (Line). These conference calls included members ofthe gang in the United
States, Mexico, Colombia, Korea, France, Australia, Peru, Egypt, Ecuador, and Cuba. The
different cliques - including the Hollywood and Sailors cliques - reported on activities and events
occurring in their areas of responsibility and were directed in the gang's operations, including drug
trafficking, member movements, money transfers, murder, member punishment, and rival gang
retribution/movement/surveillance. a/k/a
orchestrated and participated in these conference calls, and was responsible for carrying out acts
of violence, including murder, as well as narcotics trafficking.

a/k/a also reported to the gang's leaders in EI Salvador, who

received the gang's profits and directed the cliques in EI Salvador and in the United States in
furtherance of their criminal enterprise. as head of the Hollywood
MS-13 clique on Long Island, interacted with the SAILORS Clique, communicating with
a/k/a and other local members of the SAILORS
Clique in Nassau County, New York. also orchestrated and
participated in conference calls, and was responsible for carrying out acts of violence, including
murder

THE PARTIES

a/k/a (hereinafter was the regional director

of the MS-13 SAILORS Clique for the East Coast of the United States. Local SAILORS Clique
members reported to who in tum reported to several heads of the gang in EI Salvador.
was responsible for carrying out acts of violence, including murder. was also
responsible for trafficking narcotics for delivery to customers to profit the gang. worked
with who brokered deals for kilograms of heroin with the Mexican Mafia. One of the
sources of supply operated in Bronx County, NY. Locally, distributors were believed
to be operating a heroin mill on Long Island, NY, and also sold to kilogram customers
in the vicinity of Baltimore, Maryland. In addition, obtained multiple pounds of cocaine
and marijuana from a Mexican supplier that was then redistributed by members ofthe gang.

Under operating on Long Island was KEVIN TORRES a/k/a INQUIETO (hereinafter
INQUIETO), who was identified as the head of the SAILORS clique in Long Island. INQUIETO
was based out of the Freeport/Roosevelt area in Nassau County, NY. INQUIETO controlled the
MS-13 SAILORS Clique throughout Long Island, including SAILORS Clique members in Central
Islip, and was responsible for the distribution of narcotics to members for resale purposes.

Additional SAILORS Clique members on Long Island were KEVIN CUEVA DEL CID a/k/a
CREEPER, EVER MORALES LOPEZ a/k/a LENKY, AUGUSTINE BENITEZ a/k/a
OLVIDADO, MAURICIO MENDOZA a/k/a CYCLO, JOSUE BONILLA SOTO a/k/a TONQUI,
DERWIN, MOSQUITO, and ASIA.

KEVIN CUEVA DEL CID a/k/a CREEPER (hereinafter CREEPER) was a close associate of
and INQUIETO. CREEPER assisted INQUIETO in distributing drugs for the SAILORS
Clique in Nassau and Suffolk counties.

EVER MORALES LOPEZ a/k/a LENKY (hereinafter LENKY) handled the SAILORS Clique's
money and accounts for New York, and the gang's narcotics operations. LENKY was also in
charge of enforcement, and overseeing the activities of the members of the SAILORS Clique in
the area of Elizabeth, New Jersey.

AUGUSTINE BENITEZ a/k/a OLVIDADO (hereinafter OLVIDADO) handled the SAILORS

Clique's money, and was in charge of enforcement, and overseeing the activities of the members
of the SAILORS Clique in Maryland.

MAURICIO MENDOZA a/k/a CYCLO, handled the SAILORS Clique's money and narcotics
dealing in Suffolk County, New York, and assisted INQUIETO in distributing drugs for the
SAILORS Clique in Nassau and Suffolk counties. CYCLO also harbored fugitives from justice
for the gang.

also directed the members ofthe Maryland SAILORS Clique. Under his supervision in
Maryland was MICHAEL CONTRERAS a/k/a CATRA (hereinafter CATRA). CATRA
distributed drugs for the Maryland Clique of the gang and managed the bank accounts. Other high
ranking, active members of the Maryland SAILORS Clique were JUNIOR NOE ALVARADO-
REQUENO a/k/a JUNIOR a/k/a INSOLENTE, MARTINEZ-MOZ a/k/a
FENIX, JEFFERY RODRIGUEZ a/k/a HYPER, and ROLANDO JUAREZ-VALAZQUEZ a/k/a
VIRUS.

while incarcerated in Mississippi, worked with trafficking narcotics

internationally to profit the gang. arranged for kilograms of heroin to be delivered to
members of their narcotics trafficking operation.

a/k/a CARNCIERO a/k/a (hereinafter was a

courier for the gang's narcotics operation. was related to Maryland SAILORS Clique
member JUNIOR NOE ALVARADO-REQUENO a/k/a JUNIOR a/k/a INSOLENTE, and acted
at the direction of and was responsible for delivering money and picking up narcotics.

LUIS EDGARDO LAZO MARTINEZ and JIMMY ANTHONY AVILA IGLESIAS were
members of the Maryland SAILORS Clique, and were couriers for the gang's narcotics operation.
They acted at the direction of and were responsible for delivering money and picking up
narcotics.

HECTOR ORTIZ, an associate of from Long Branch, NJ, was a courier for the gang's
narcotics operation. ORTIZ acted at the direction of REAPER, and was responsible for delivering
money and picking up narcotics.

an associate ofJD from Massachusetts, with connections to New York,

was a courier for the gang's narcotics operation. acted at the direction and
was responsible for delivering money and picking up narcotics.

an associate of and from the Baltimore, Maryland

area, purchased kilograms ofheroin on consignment from and that he would
in tum re-sell for profit.
 an associate of and from the Baltimore, Maryland area,
purchased kilograms of heroin on consignment from and that he would in
tum re-sell for profit.

a/k/a the head of the HOLLYWOOD Clique in Long Island,

associated withthe SAILORS Clique on Long Island in that he collaborated with SAILORS Clique
members in Nassau County, including KEVIN TORRES a/k/a INQUIETO and EVER MORALES
LOPEZ a/k/a LENKY. Like the SAILORS Clique, members of the MS-13 HOLLYWOOD
Clique, operated on Long Island, and the geographic scope of their criminality extended on a
national level from New York to Maryland, and on an international level to El Salvador.
a/k/a also reported to the gang's leaders in El Salvador, who also
received the gang's profits and direct the cliques in El Salvador and in the United States in
furtherance of their criminal enterprise.

Under a/k/a direction were fellow HOLLYWOOD Clique members

VICTOR LOPEZ, a/k/a a/k/a
SOSPECHOS, RAMA, and LEON.

VICTOR LOPEZ was identified as a close associate of , and was in charge of enforcement,
and overseeing the activities ofthe members of the HOLLYWOOD Clique in Nassau and Suffolk
Counties, New York.

a/k/a a/k/a was a member of

the HOLLYWOOD Clique in Nassau County, New York, who carried out acts of violence, and
transported weapons on behalf ofthe gang. also moved the HOLLYWOOD Clique's
money and assisted in drug distribution in Nassau County, New York.

was a member of the HOLLYWOOD Clique who resided in ofNew Jersey

and participated in planned acts of violence on behalf of the gang in Nassau County.

Each of the conspiracies and substantive crimes set forth below were undertaken by MS-13
members in furtherance of the gang's overall objectives.

FIRST COUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendants
a/k/a KEVIN CUEVA DEL CID a/k/a CREEPER,
EVER MORALES LOPEZ a/k/a LENKY, AUGUSTINE BENITEZ a/k/a OLVIDADO, and
MAURICIO MENDOZA a/k/a CYCLO, of the crime of CONSPIRACY IN THE SECOND
DEGREE, a class B felony, in violation of Section 105.15 of the Penal Law of the State of New
York, committed as follows:
The defendants, on or about and between May 25, 2017, and January 8, 2018, in the County of
Nassau and elsewhere, with the intent that conduct constituting a class A felony be performed, -
to wit, Murder in the Second Degree - agreed with one or more persons to engage in or cause the
performance of such conduct.

THE AGREEMENT

MS-13 members undertook ruthless acts of violence to establish the gang's supremacy and further its
self-declared mission. The acts of violence, however, were to be sanctioned by the hierarchal
members. Members were not permitted to randomly attack people, but rather were required to report
to their leaders issues with specific individuals. In tum, the leaders, would determine the way in
which the group would proceed. In his capacity, as regional director for the east coast,
acting in concert with others, including TIEJERAS, determined when killing someone was
necessary to further the objectives of the gang. co-conspirators agreed to kill rival gang
members when local cliques reported issues with particular enemies that required their elimination.
The conspirators also agreed to kill their own members if there was evidence to suggest that the
member was disloyal to the gang by, for example, cooperating with law enforcement or attempting
to leave the gang. They even agreed to inflict punishment or death on those members who
overstated their position in the gang or whose actions compromised the gang's agendas, by failing
to perform required tasks or acting in a manner injurious to the gang.

In furtherance of their illicit agreement and in order to affect the object of the conspiracy, the
defendants, acting together and with other individuals, performed and caused to be performed the
following overt acts, among others in the conspiracy detailed in this count:

ON OR ABOUT MAY 27, 2017, a/k1a

INSTRUCTED FELLOW SAILORS CLIQUE MEMBERS MAFIOSO AND VIRUS THAT
PENNY WOULD BE KILLED IF HE DID NOT PERFORM HIS DUTIES.

ON OR ABOUT JULY 3, 2017, a/k1a

INSTRUCTED FELLOW SAILORS CLIQUE MEMBERS TO MOLD YOUNG GANG
MEMBERS TO BE THE EYES OF THE LEADERS, AND AS HOMEBOYS THEY MUST
WORK TO FULFILL THE GOALS OF THE CLIQUE, INCLUDING ENFORCEMENT AND
MURDER.

ON OR ABOUT JULY 7, 2017, a/k1a

INSTRUCTED FELLOW SAILORS CLIQUE MEMBERS, INCLUDING KEVIN TORRES
a/k1a INQUIETO AND MICHAEL CONTRERAS a/k1a CATRA, ON THE PROTOCOL FOR
REQUESTING PERMISSION TO KILL ANOTHER.

ON OR ABOUT SEPTEMBER 4, 2017, a/k1a

INSTRUCTED FELLOW SAILORS CLIQUE MEMBERS, INCLUDING KEVIN TORRES
a/k1a INQUIETO, EVER MORALES LOPEZ a/k1a LENKY, MAURICIO MENDOZA a/k1a
CYCLO, AUGUSTINE BENITEZ a/k/a OLVIDADO, ON THE PROTOCOL FOR THE
"PROGRAM" AND THE CLIQUE, REINFORCING THE RULES FOR KILLING OTHERS
AND THE PERMISSION THAT NEEDS TO BE RECEIVED FROM THE LEADERS.

ON OR ABOUT SEPTEMBER 4,2017, a/k/a

INSTRUCTED FELLOW SAILORS CLIQUE MEMBERS, INCLUDING KEVIN TORRES
a/k/a INQUIETO, EVER MORALES LOPEZ a/k/a LENKY, MAURICIO MENDOZA a/k/a
CYCLO, AUGUSTINE BENITEZ a/k/a OLVIDADO, ON THE CONSENQUNCES FOR THE
CLIQUE'S MEMBERS FAILURE TO FOLLOW THE RULES, RESULTING IN SEVERE
PUNISHMENT.

ON OR ABOUT SEPTEMBER 26, 2017, a/k/a

INSTRUCTED EVER MORALES LOPEZ a/k/a LENKY TO GO TO NEW JERSEY TO
MEET EDGAR a/k/a TO DO RECONNAISSANCE AND
PROVIDE MONEY IN ORDER TO EFFECTUATE THE MURDER OF ANOTHER
INDIVIDUAL.

ON OR ABOUT AND BETWEEN SEPTEMBER 29, 2017,

INSTRUCTED EVER MORALES LOPEZ a/k/a LENKY, KEVIN TORRES a/k/a INQUIETO,
AND AUGUSTINE BENITEZ a/k/a OLVIDADO, TO MURDER ANOTHER INDIVIDUAL IN
MARYLAND, WHOM THEY BELIEVED WAS COOPERATING WITH LAW
ENFORCEMENT.

ON OR ABOUT AND BETWEEN SEPTEMBER 29,2017,

INSTRUCTED AUGUSTINE BENITEZ a/k/a OLVIDADO TO RECRUIT YOUNGER
MEMBERS OF THE GANG TO COMMITT THE MURDER OF ANOTHER INDIVIDUAL
LOCATED IN MARYLAND, WHOM THEY BELIEVED WAS COOPERATING WITH LAW
ENFORCEMENT.

ON OR ABOUT SEPTEMBER 29, 2017, a/k/a

DIRECTED THAT HE WANTED THE COOPERATING WITNESS KILLED AS SOON AS
POSSIBLE.

ON OR ABOUT SEPTEMBER 29,2017, a/k/a

AUGUSTINE BENITEZ a/k/a OLVIDADO, AND ANOTHER INDIVIDUAL DETAILED THE
DIFFERENT WAYS TO COMMITT THE HOMICIDE; I.E., BY SHOOTING OR CHOKING
THE VICTIM.

ON OR ABOUT SEPTEMBER 29, 2017, a/k/a

DIRECTED THAT HE WANTED THE BODY OF THE MURDER VICTIM TO BE BURIED.

SECOND COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the
defendants a/k/a and VICTOR LOPEZ, of the crime of
MURDER IN THE SECOND DEGREE, a class A felony, in violation of Section 125.25(1) of the
Penal Law of the State of New York, committed as follows:
The defendants a/k/a and VICTOR LOPEZ, acting in concert
with each other and others, on or about July 21, 2017, in the County of Nassau, with the intent to
cause the death of another, did cause the death of another, that being Soler a/k/a CHAPO.

THIRD COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the
defendants a/k/a and of the crime of
OPERATING AS A MAJOR TRAFFICKER, a class A-I felony, in violation of Section 220.77(1)
ofthe Penal Law of the State of New York, committed as follows:
The defendants a/k/a and on or about
and between May 25, 2017, and January 8, 2018, in the County of Nassau and elsewhere, as
directors of a controlled substance organization, did sell, on one or more occasions within twelve
months or less, a controlled substance, and the proceeds collected or due from such sale or sales
have a total aggregate value of seventy-five thousand dollars or more.

FOURTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the
defendant a/k/a of the crime of OPERATING AS A
MAJOR TRAFFICKER, a class A-I felony, in violation of Section 220.77(2) of the Penal Law of
the State of New York, committed as follows:
The defendant a/k/a on or about and between May
25, 2017, and October 9, 2017, in the County of Nassau, as a profiteer, did knowingly and
unlawfully sell, on one or more occasions within six months or less, a narcotic drug, and the
proceeds collected or due from such sale or sales have a total aggregate value of seventy-five
thousand dollars or more.

FIFTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the
defendant a/k/a of the crime of OPERATING AS A
MAJOR TRAFFICKER, a class A-I felony, in violation of Section 220.77(3) ofthe Penal Law of
the State of New York, committed as follows:
The defendant a/k/a on or about and between May
25, 2017, and October 9, 2017, in the County of Nassau, as a profiteer, did knowingly and
unlawfully possess, on one or more occasions within six months or less, a narcotic drug with intent
to sell the same, and such narcotic drugs have a total aggregate value of seventy-five thousand
dollars or more.
 SIXTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, further accuses
the defendant a1k/a ofthe crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21 (l)
ofthe Penal Law of the State of New York committed as follows:
The defendant, a1k/a on or about July 26, 2017, in the County
of Bronx, New York, did knowingly and unlawfully possess one or more preparations, compounds,
substances containing a narcotic drug, that being heroin, and the preparations, compounds, or
substances are of an aggregate weight of eight ounces or more.

SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, further accuses
the defendants a1k/a KEVIN TORRES
a1k/a INQUIETO, a1k/a HECTOR ORTIZ
and of the crime of
CONSPIRACY IN THE SECOND DEGREE, in violation of Section 105.15 of the Penal Law of
the State of New York, committed as follows:
The defendants a1k/a KEVIN TORRES
a1k/a INQUIETO, a1k/a HECTOR ORTIZ
and conspiring with others, on or
about and between May 25, 2017, and October 9,2017, in the County of Nassau, New York, and
elsewhere, with the intent that conduct constituting a class A felony be performed, agreed with one
or more persons to engage in or cause the performance of such conduct, to wit: the defendants did
conspire to commit the crime of Criminal Sale of a Controlled Substance in the Second Degree, a
class A-II felony:

In furtherance of their illicit agreement and in order to effect the object of the conspiracy, the
defendants, acting together and with other individuals, performed and caused to be performed the
following overt acts, among others:

ON OR ABOUT MAY 27,2017, a1k/a DIRECTED

PARCE TO TAKE POSSESSION OF A QUANTITY OF HEROIN IN BRONX COUNTY.

ON OR ABOUT MAY 27,2017, PARCE AND ANOTHER DROVE FROM NASSAU

COUNTY TO BRONX COUNTY TO OBTAIN A QUANTITY OF HEROIN.

ON OR ABOUT MAY 27, 2017, PARCE AND ANOTHER TOOK POSSESSION OF A

QUANTITY OF HEROIN IN BRONX COUNTY AND RETURNED TO NASSAU COUNTY.

ON OR ABOUT JULY 24,2017, a1k/a DIRECTED

a1k/a TO DROP OFF A SUM OF UNITED STATES
CURRENCY TO ANOTHER FOR PAYMENT FOR A HEROIN PURCHASE IN BRONX
COUNTY, NY.

ON OR ABOUT JULY 24,2017, TRANSFERRED POSSESSION OF A

SUM OF UNITED STATES CURRENCY TO a/k/a FOR
PAYMENT FOR HEROIN TO BE PICKED UP IN BRONX COUNTY, NY.

ON OR ABOUT JULY 24, 2017, a/k/a TRANSFERRED

POSSESSION OF A SUM OF UNITED STATES CURRENCY TO ANOTHER FOR
PAYMENT FOR A HEROIN PURCHASE IN BRONX COUNTY, NY.

ON OR ABOUT JULY 25, 2017, KEVIN TORRES a/k/a INQUIETO, IN NASSAU COUNTY,
Ask a/k/a TO CONTACT
a/k/a TO PICK UP OF A QUANTITY OF HEROIN IN BRONX COUNTY,
NY.

ON OR ABOUT JULY 25, 2017, a/k/a

INSTRUCTED KEVIN TORRES a/k/a INQUIETO, IN NASSAU COUNTY, TO CONTACT
a/k/a TO COORDINATE THE PICK UP OF A QUANTITY
OF HEROIN IN BRONX COUNTY, NY.

ON OR ABOUT JULY 25,2017, KEVIN TORRES a/k/a INQUIETO, IN NASSAU COUNTY,

CONTACTED a/k/a TO COORDINATE THE PICK UP OF
A QUANTITY OF HEROIN IN BRONX COUNTY, NY.

ON OR ABOUT JULY 26,2017, a/k/a DIRECTED

a/k/a TO PICK UP A QUANTITY OF HEROIN FOR HIM
IN BRONX COUNTY, NY.

ON OR ABOUT JULY 26, 2017, a/k/a AGREED TO

TRANSPORT A QUANTITY OF HEROIN FOR a/k/a

ON OR ABOUT JULY 26,2017, a/k/a DROVE FROM

MARYLAND TO BRONX COUNTY TO OBTAIN A QUANTITY OF HEROIN.

ON OR ABOUT JULY 26, 2017, a/k/a POSSESSED A

QUANTITY OF HEROIN IN EXCESS OF 4 OUNCES.

ON OR ABOUT AUGUST 20, 2017, ARRANGED FOR A QUANTITY OF HEROIN

TO BE PICKED UP BY ASSOCIATES OF a/k/a IN
THE VICINITY OF HOUSTON, TEXAS.
ON OR ABOUT AUGUST 20, 2017, a/k/a
DIRECTED JIMMY ANTHONY AVILA IGLESIAS AND LUIS EDGARDO LAZO
MARTINEZ TO PICK UP A QUANTITY OF HEROIN FOR
a/k/a IN THE VICINITY OF HOUSTON, TEXAS.

ON OR ABOUT AUGUST 20,2017, JIMMY ANTHONY AVILA IGLESIAS AND LUIS

EDGARDO LAZO MARTINEZ DROVE FROM MARYLAND TO THE VICINITY OF
HOUSTON, TEXAS.

ON OR ABOUT AUGUST 21, 2017, JIMMY ANTHONY AVILA IGLESIAS AND LUIS
EDGARDO LAZO MARTINEZ POSSESSED A QUANTITY OF HEROIN IN EXCESS OF 4
OUNCES IN JEFFERSON COUNTY, TEXAS.

ON OR ABOUT AUGUST 31, 2017, ARRANGED FORA QUANTITY OF HEROIN

TO BE PICKED UP BY ASSOCIATES OF a/k/a IN
THE VICINITY OF LONG BRANCH, NEW JERSEY.

ON OR ABOUT AUGUST 31, 2017, a/k/a

DIRECTED TO ACCEPT POSSESSION OF A QUANTITY OF HEROIN FOR
a/k/a IN THE VICINITY OF LONG BRANCH,
NEW JERSEY.

ON OR ABOUT AUGUST 31, 2017, POSSESSED A QUANTITY OF HEROIN IN

EXCESS OF 4 OUNCES IN BALTIMORE COUNTY, MARYLAND.

ON OR ABOUT SEPTEMBER 1,2017, a/k/a

DIRECTED TO TRANSFER POSSESSION OF A QUANTITY OF HEROIN TO
ANOTHER THAT WEIGHED IN EXCESS OF Y2 AN OUNCE.

ON OR ABOUT SEPTEMBER 1, 2017, TRANSFERED POSSESSION OF A

QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN EXCESS OF Y2 AN OUNCE.

ON OR ABOUT SEPTEMBER 1,2017, TOOK POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y2 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT SEPTEMBER 1, 2017, TOOK POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y2 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT OCTOBER 9, 2017, a/k/a

AGREED TO SELL A QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN
EXCESS OF Y2 AN OUNCE.
ON OR ABOUT OCTOBER 9, 2017, a/k/a
POSSESSED A QUANTITY OF HEROIN IN EXCESS OF 4 OUNCES IN PRINCE GEORGE'S
COUNTY, MARYLAND.

ON OR ABOUT OCTOBER 18, 2017, ARRANGED FOR A QUANTITY OF

HEROIN TO BE PICKED UP BY IN THE VICINITY OF NEW YOK CITY,
NEW YORK.

ON OR ABOUT OCTOBER 18,2017, DID DIRECTED TO

TRANSFER POSSESSION OF A QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED
IN EXCESS OF Y:z AN OUNCE.

ON OR ABOUT OCTOBER 18,2017, TRANSFERED POSSESSION OF A

QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN EXCESS OF Y:z AN OUNCE.

ON OR ABOUT OCTOBER 18, 2017, DIRECTED TO TAKE

POSSESSION OF A QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y:z AN
OUNCE.

ON OR ABOUT OCTOBER 18,2017, TOOK POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y:z AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT OCTOBER 18,2017, DIRECTED STEVEN LIEVER TO TAKE

POSSESSION OF A QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y:z OUNCE.

ON OR ABOUT OCTOBER 18,2017, DID TAKE POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF Y:z AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

EIGHTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, further accuses
the defendants a/k/a KEVIN TORRES
a/k/a INQUIETO, a/k/a
and of the crime of CONSPIRACY IN THE
SECOND DEGREE, in violation of Section 105.15 of the Penal Law of the State of New York,
committed as follows:
The defendants a/k/a KEVIN TORRES
a/k/a INQUIETO, a/k/a
and conspiring with others, on or about and between
May 25, 2017, and October 9, 2017, in the County of Nassau, with the intent that conduct
constituting a class A felony be performed, agreed with one or more persons to engage in or cause
the performance of such conduct, to wit: the defendants did conspire to commit the crime of
Criminal Possession of a Controlled Substance in the Second Degree, a class A-II felony.
 In furtherance of their illicit agreement and in order to effect the object of the conspiracy,
the defendants, acting together and with other individuals, performed and caused to be performed
the following overt acts, among others:

ON OR ABOUT MAY 27, 2017, a1k/a DIRECTED

PARCE TO TAKE POSSESSION OF A QUANTITY OF HEROIN IN BRONX COUNTY.

ON OR ABOUT MAY 27, 2017, PARCE AND ANOTHER DROVE FROM NASSAU
COUNTY TO BRONX COUNTY TO OBTAIN A QUANTITY OF HEROIN.

ON OR ABOUT MAY 27, 2017, PARCE AND ANOTHER TOOK POSSESSION OF A

QUANTITY OF HEROIN IN BRONX COUNTY AND RETURNED TO NASSAU COUNTY.

ON OR ABOUT JULY 24, 2017, a1k/a DIRECTED

a1k/a TO DROP OFF A SUM OF UNITED STATES
CURRENCY TO ANOTHER FOR PAYMENT FOR A HEROIN PURCHASE IN BRONX
COUNTY, NY.

ON OR ABOUT JULY 24,2017, TRANSFERRED POSSESSION OF A

SUM OF UNITED STATES CURRENCY TO a1k/a FOR
PAYMENT FOR HEROIN TO BE PICKED UP IN BRONX COUNTY, NY.

ON OR ABOUT JULY 24, 2017, a1k/a TRANSFERRED

POSSESSION OF A SUM OF UNITED STATES CURRENCY TO ANOTHER FOR
PAYMENT FOR A HEROIN PURCHASE IN BRONX COUNTY, NY.

ON OR ABOUT JULY 25, 2017, KEVIN TORRES a1k/a INQUIETO, IN NASSAU COUNTY,
Ask a1k/a TO CONTACT
a1k1a TO PICK UP A QUANTITY OF HEROIN IN BRONX COUNTY, NY.

ON OR ABOUT JULY 25, 2017, a1k1a

INSTRUCTED KEVIN TORRES a1k1a INQUIETO, IN NASSAU COUNTY, TO CONTACT
a1k1a TO COORDINATE THE PICK UP OF A QUANTITY
OF HEROIN IN BRONX COUNTY, NY.

ON OR ABOUT JULY 25, 2017, KEVIN TORRES a1k/a INQUIETO, IN NASSAU COUNTY,
CONTACTED a1k/a TO COORDINATE THE PICK UP OF
A QUANTITY OF HEROIN IN BRONX COUNTY, NY.

ON OR ABOUT JULY 26,2017, a1k/a DIRECTED

a1k1a TO PICK UP A QUANTITY OF HEROIN FOR HIM
IN BRONX COUNTY, NY.
ON OR ABOUT JULY 26, 2017, a/k/a AGREED TO
TRANSPORT A QUANTITY OF HEROIN FOR a/k/a

ON OR ABOUT JULY 26, 2017, a/k/a DROVE FROM

MARYLAND TO BRONX COUNTY TO OBTAIN A QUANTITY OF HEROIN.

ON OR ABOUT JULY 26, 2017, a/k/a POSSESSED A

QUANTITY OF HEROIN IN EXCESS OF 4 OUNCES.

ON OR ABOUT AUGUST 20,2017, ARRANGED FORA QUANTITY OF HEROIN

TO BE PICKED UP BY ASSOCIATES OF a/k/a IN
THE VICINITY OF HOUSTON, TEXAS.

ON OR ABOUT AUGUST 20, 2017, a/k/a

DIRECTED JIMMY ANTHONY AVILA IGLESIAS AND LUIS EDGARDO LAZO
MARTINEZ TO PICK UP A QUANTITY OF HEROIN FOR
a/k/a IN THE VICINITY OF HOUSTON, TEXAS.

ON OR ABOUT AUGUST 20,2017, JIMMY ANTHONY AVILA IGLESIAS AND LUIS

EDGARDO LAZO MARTINEZ DROVE FROM MARYLAND TO THE VICINITY OF
HOUSTON, TEXAS.

ON OR ABOUT AUGUST 21, 2017, JIMMY ANTHONY AVILA IGLESIAS AND LUIS
EDGARDO LAZO MARTINEZ POSSESSED A QUANTITY OF HEROIN IN EXCESS OF 4
OUNCES IN JEFFERSON COUNTY, TEXAS.

ON OR ABOUT AUGUST 31,2017, ARRANGED FOR A QUANTITY OF HEROIN

TO BE PICKED UP BY ASSOCIATES OF a/k/a IN
THE VICINITY OF LONG BRANCH, NEW JERSEY.

ON OR ABOUT AUGUST 31, 2017, a/k/a

DIRECTED TO ACCEPT POSSESSION OF A QUANTITY OF HEROIN FOR
a/k/a IN THE VICINITY OF LONG BRANCH,
NEW JERSEY.

ON OR ABOUT AUGUST 31, 2017, POSSESSED A QUANTITY OF HEROIN IN

EXCESS OF 4 OUNCES IN BALTIMORE COUNTY, MARYLAND.

ON OR ABOUT SEPTEMBER 1,2017, a/k/a

DIRECTED TO TRANSFER POSSESSION OF A QUANTITY OF HEROIN TO
ANOTHER THAT WEIGHED IN EXCESS OF Yz AN OUNCE.

ON OR ABOUT SEPTEMBER 1,2017, TRANSFERED POSSESSION OF A

QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN EXCESS OF Yz AN OUNCE.
ON OR ABOUT SEPTEMBER 1,2017, TOOK POSSESSION OF A
QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT SEPTEMBER 1, 2017, TOOK POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT OCTOBER 9, 2017, a/k/a

AGREED TO SELL A QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN
EXCESS OF Yz AN OUNCE.

ON OR ABOUT OCTOBER 9, 2017, a/k/a

POSSESSED A QUANTITY OF HEROIN IN EXCESS OF 4 OUNCES IN PRINCE GEORGE'S
COUNTY, MARYLAND.

ON OR ABOUT OCTOBER 18,2017, ARRANGED FOR A QUANTITY OF

HEROIN TO BE PICKED UP BY IN THE VICINITY OF NEW YOK CITY,
NEW YORK.

ON OR ABOUT OCTOBER 18, 2017, DIRECTED TO

TRANSFER POSSESSION OF A QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED
IN EXCESS OF Yz AN OUNCE.

ON OR ABOUT OCTOBER 18,2017, TRANSFERED POSSESSION OF A

QUANTITY OF HEROIN TO ANOTHER THAT WEIGHED IN EXCESS OF 12 AN OUNCE.

ON OR ABOUT OCTOBER 18, 2017, DIRECTED TO TAKE

POSSESSION OF A QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 AN
OUNCE.

ON OR ABOUT OCTOBER 18, 2017, TOOK POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

ON OR ABOUT OCTOBER 18,2017, DIRECTED STEVEN LIEVER TO TAKE

POSSESSION OF A QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 OUNCE.

ON OR ABOUT OCTOBER 18, 2017, DID TAKE POSSESSION OF A

QUANTITY OF HEROIN THAT WEIGHED IN EXCESS OF 12 AN OUNCE, WITH THE
INTENT TO SELL IT TO ANOTHER.

NINTH COUNT
THE GRAND JURY OF THE COUNTY OF NAS SAU, by this indictment, accuses the defendants
a/k/a KEVIN TORRES a/k/a INQUIETO, EVER
MORALES LOPEZ a/k/a LENKY, AUGUSTINE BENITEZ a/k/a OLVIDADO, of the crime of
CONSPIRACY IN THE SECOND DEGREE, a class B felony, in violation of Section 105.15 of
the Penal Law of the State of New York, committed as follows:

The defendants a/k/a KEVIN TORRES a/k/a

INQUIETO, EVER MORALES LOPEZ a/k/a LENKY, AUGUSTINE BENITEZ a/k/a
OLVIDADO, on or about and between September 29, 2017, and September 30, 2017, in the
County of Nassau, with the intent that conduct constituting a class A felony be performed, agreed
with one or more persons to engage in or cause the performance of such conduct, to wit: the
defendants did conspire to commit the crime of Murder in the Second Degree, a class A felony.

In furtherance of their illicit agreement and in order to effect the object of the conspiracy,
the defendants, acting together and with other individuals, performed and caused to be performed
the following overt acts, among others:

ON OR ABOUT AND BETWEEN SEPTEMBER 29 AND SEPTEMBER 30, 2017,

INSTRUCTED EVER MORALES LOPEZ a/k/a LENKY, KEVIN
TORRES a/k/a INQUIETO, and AUGUSTINE BENITEZ a/k/a OLVIDADO, TO MURDER
ANOTHER INDIVIDUAL WITHIN THE VICINITY OF PRINCE GEORGE'S COUNTY,
MARYLAND, WHOM THEY BELIEVED WAS COOPERATING WITH LAW
ENFORCEMENT.

ON OR ABOUT AND BETWEEN SEPTEMBER 29,2017, AND SEPTEMBER 30,2017,

INSTRUCTED AUGUSTINE BENITEZ a/k/a OLVIDADO
TO RECRUIT YOUNGER MEMBERS OF THE GANG TO COMMITT THE MURDER OF
ANOTHER INDIVIDUAL LOCATED IN THE VICINITY OF PRINCE GEORGE'S COUNTY,
MARYLAND, WHOM THEY BELIEVED WAS COOPERATING WITH LAW
ENFORCEMENT.

ON OR ABOUT SEPTEMBER 29,2017, a/k/a

DIRECTED AUGUSTINE BENITEZ a/k/a OLVIDADO, AND ANOTHER INDIVIDUAL
THAT HE WANTED THE COOPERATING WITNESS KILLED AS SOON AS POSSIBLE.

ON OR ABOUT SEPTEMBER 29, 2017, a/k/a

AUGUSTINE BENITEZ a/k/a OLVIDADO, AND ANOTHER INDIVIDUAL DETAILED THE
DIFFERENT WAYS TO COMMITT THE HOMICIDE; I.E., BY SHOOTING OR CHOKING
THE VICTIM.

ON OR ABOUT SEPTEMBER 29,2017, a/k/a

DIRECTED THAT HE WANTED THE BODY OF THE MURDER VICTIM TO BE BURIED.

ON OR ABOUT SEPTEMBER 29,2017, KEVIN TORRES a/k/a INQUIETO DIRECTED EVER

MORALES LOPEZ a/k/a LENKY TO DRIVE MEMBERS OF THE MS-13 TO A KNOWN
LOCATION TO COMMIT THE MURDER OF THE COOPERATOR IN MARYLAND.
ON OR ABOUT SEPTEMBER 30, 2017, AUGUSTINE BENITEZ a1k/a OLVIDADO
CONTACTED MOSQUITO AND DERWIN IN ORDER TO ENLIST THEM IN
COMMITING THE MURDER OF THE COOPERATOR IN MARYLAND.
TENTH COUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, further accuses the
defendants a1k/a EVER MORALES LOPEZ a1k/a
LENKY, and EDGAR a1k/a of the crime of CONSPIRACY IN
THE SECOND DEGREE, a class B felony, in violation of Section 105.15 ofthe Penal Law of the
State of New York, committed as follows:

The defendants a1k/a EVER MORALES LOPEZ

a1k/a LENKY, and EDGAR a1k/a on or about and between
September 24,2017, and September 30,2017, in the County ofNassau, with the intent that conduct
constituting a class A felony be performed, agreed with one or more persons to engage in or cause
the performance of such conduct, to wit: the defendants did conspire to commit the crime of
Murder in the Second Degree, a class A felony.

In furtherance of their illicit agreement and in order to effect the object of the conspiracy,
the defendants, acting together and with other individuals, performed and caused to be performed
the following overt acts, among others:

ON OR ABOUT SEPTEMBER 24,2017, EVER MORALES LOPEZ a1k/a LENKY,

USING MOBILE TELEPHONE NUMBER 516-324-9262, CONTACTED EDGAR
a1k/a ON MOBILE TELEPHONE NUMBER 908-937-0381
AND THE PARTIES CONFERRED ABOUT DIFFERENT LOCATIONS TO COMMIT THE
MURDER OF ANOTHER INDIVIDUAL KNOWN TO THE GANG.

ON OR ABOUT SEPTEMBER 24,2017, EVER MORALES LOPEZ a1k/a LENKY,

USING MOBILE TELEPHONE NUMBER 516-324-9262, CONTACTED EDGAR
a1k/a ON MOBILE TELEPHONE NUMBER 908-937-0381,
AND EVER MORALES LOPEZ a1k/a LENKY DIRECTED THE SIZE OF THE HOLE TO BE
DUG TO DISPOSE OF THE BODY.

ON OR ABOUT SEPTEMBER 26,2017, EDGAR a1k/a

TOOK PICTURES OF DIFFERENT LOCATIONS TO COMMIT A MURDER.

ON OR ABOUT SEPTEMBER 26,2017, a1k/a

INSTRUCTED EVER MORALES LOPEZ a1k/a LENKY TO GO TO NEW JERSEY TO
MEET EDGAR a1k/a TO DO RECONNAISSANCE AND
PROVIDE MONEY IN ORDER TO EFFECTUATE THE MURDER OF SAID INDIVIDUAL.

ON OR ABOUT SEPTEMBER 30, 2017, EVER MORALES LOPEZ a1k/a LENKY DROVE
FROM NASSAU COUNTY, NY TO THE VICNITY OF ELIZABETH, NJ TO MEET
a1k/a TO DO RECONNAISSANCE AND PROVIDE
MONEY IN ORDER TO EFFECTUATE THE MURDER OF SAID INDIVIDUAL.
 ELEVENTH COUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendants
KEVIN CUEVAS DEL CID, a/k1a CREEPER and AUGUSTINE BENITEZ a/k1a OLVIDADO,
of the crime of CONSPIRACY IN THE SECOND DEGREE, a class A felony, in violation of
Section 105.15 of the Penal Law of the State of New York, committed as follows:

The defendants KEVIN CUEVAS DEL CID, a/k1a CREEPER and AUGUSTINE BENITEZ a/k1a
OLVIDADO, on or about July 19, 2017, in the County of Nassau, with the intent that conduct
constituting a class A felony be performed, agreed with one or more persons to engage in or cause
the performance of such conduct, to wit: the defendants did conspire to commit the crime of
Murder in the Second Degree, a class A felony, and did commit the following overt acts in
furtherance of said conspiracy:

ON OR ABOUT JULY 19,2017, KEVIN CUEVAS DEL CID a/k1a CREEPER ENCOUNTERED
ANOTHER INDIVIDUAL WHOM HE PLANNED TO MURDER IN NASSAU COUNTY,
AND ATTEMPTED TO LURE HIM INTO THE WOODS BY OFFEREING MARIJUANA.

ON OR ABOUT JULY 19,2017, KEVIN CUEVA DEL CID a/k1a CREEPER, USING
MOBILE TELEPHONE NUMBER 516-787-6320, CONTACTED AUGUSTINE BENITEZ
a/k1a OLVIDADO ON MOBILE TELEPHONE NUMBER 516-808-6228, AND AUGUSTINE
BENITEZ a/k1a OLVIDADO PROPOSED THE LOCATION FOR SAID MURDER AND
STATED HE WOULD DO RECONNAISSANCE ON THE AREA WHERE THE MURDER
WAS TO TAKE PLACE AND CHECK FOR CAMERAS.

ON OR ABOUT JULY 19,2017, AUGUSTINE BENITEZ a/k1a OLVIDADO, STATED HE

WOULD OBTAIN SHOVELS FOR PREPARATION OF THE HOMICIDE.

ON OR ABOUT JULY 19,2017, KEVIN CUEVA DEL CID a/k1a CREEPER, STATED HE
WOULD DIRECT THE GANGS' MEMBERS TO OBTAIN THE NECESSARY TOOLS.

TWELTHCOUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendants
KEVIN TORRES a/k1a INQUIETO, EVER MORALES LOPEZ a/k1a LENKY, AUGUSTINE
BENITEZ a/k1a OLVIDADO, KEVIN CUEVAS DEL CID a/k1a CREEPER, and MAURICIO
MENDOZA a/k1a CYCLO of the crime of CONSPIRACY IN THE SECOND DEGREE, a class
B felony, in violation of Section 105.15 of the Penal Law of the State of New York, committed as
follows:
The defendants KEVIN TORRES a/k1a INQUIETO, EVER MORALES LOPEZ a/k1a LENKY,
AUGUSTINE BENITEZ a/k1a OLVIDADO, KEVIN CUEVAS DEL CID a/k/a CREEPER and
MAURICIO MENDOZA, a/k1a CYCLO, on or about and May 25, 2017, and October 12,2017,
in the County of Nassau and elsewhere, with the intent that conduct constituting a class A felony
be performed, agreed with one or more persons to engage in or cause the performance of such
conduct, to wit: the defendants did conspire to commit the crime of Criminal Possession of a
Controlled Substance in the Second Degree, a class A-II felony, and did commit the following
overt acts in furtherance of said conspiracy:

ON OR ABOUT JULY 11,2017, MAURICIO MENDOZA a/k1a CYCLO DID TRANSFER

POSSESSION OF A QUANTITY OF COCAINE TO ANOTHER WITHIN THE VICINITY OF
SUFFOLK COUNTY.

ON OR ABOUT JULY 21, 2017, KEVIN TORRES a/k/a INQUIETO AND EVER MORALES
LOPEZ a/k1a LENKY, AGREED TO TRANSPORT A QUANTITY OF COCAINE TO
ANOTHER.

ON OR ABOUT JULY 21, 2017, KEVIN TORRES a/k/a INQUIETO AND EVER MORALES
LOPEZ a/k1a LENKY, DROVE FROM NASSAU COUNTY TO QUEENS COUNTY TO
OBTAIN A QUANTITY OF COCAINE.

ON OR ABOUT JULY 21, 2017, KEVIN TORRES a/k/a INQUIETO AND EVER MORALES
LOPEZ a/k/a LENKY, POSSESSED A QUANTITY OF COCAINE IN EXCESS OF 8 OUNCES.

ON OR ABOUT JULY 27, 2017, MAURICIO MENDOZA a/k1a CYCLO DID TRANSFER
POSSESSION OF A QUANTITY OF COCAINE TO ANOTHER.

ON OR ABOUT AUGUST 22, 2017, MAURICIO MENDOZA a/k1a CYCLO POSSESSED A

QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

ON OR ABOUT AUGUST 22, 2017, EVER MORALES LOPEZ a/k1a LENKY POSSESSED A
QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

ON OR ABOUT OCTOBER 12,2017, EVER MORALES LOPEZ a/k1a LENKY POSSESSED

A QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

THIRTEENTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, further accuses
the defendants KEVIN TORRES a/kIa INQUIETO, EVER MORALES LOPEZ a/k1a LENKY,
AUGUSTINE BENITEZ a/k1a OLVIDADO, KEVIN CUEVAS DEL CID a/k/a CREEPER, and
MAURICIO MENDOZA, a/k1a CYCLO of the crime of CONSPIRACY IN THE FOURTH
DEGREE, a class E felony, in violation of Section 105.10(1) ofthe Penal Law of the State of New
York, committed as follows:
The defendants KEVIN TORRES a/k1a INQUIETO, EVER MORALES LOPEZ a/k1a LENKY,
AUGUSTINE BENITEZ a/k1a OLVIDADO,KEVIN CUEVAS DEL CID a/k1a CREEPER, and
MAURICIO MENDOZA, a/k1a CYCLO on or about and between May 25, 2017, and October 12,
2017, in the County of Nassau, with the intent that conduct constituting a class B felony be
performed, agreed with one or more persons to engage in or cause the performance of such
conduct, to wit: the defendants did conspire to commit the crime of Criminal Sale of a Controlled
Substance in the Third Degree, a class B felony, and did commit the following overt acts in
furtherance of said conspiracy:

ON OR ABOUT JULY 11, 2017, MAURICIO MENDOZA a/k1a CYCLO DID TRANSFER
POSSESSION OF A QUANTITY OF COCAINE TO ANOTHER WITHIN THE VICINITY OF
SUFFOLK COUNTY.

ON OR ABOUT JULY 21, 2017, KEVIN TORRES a/k1a INQUIETO AND EVER MORALES
LOPEZ a/k1a LENKY, AGREED TO TRANSPORT A QUANTITY OF COCAINE TO
ANOTHER.

ON OR ABOUT JULY 21,2017, KEVIN TORRES a/k1a INQUIETO AND EVER MORALES
LOPEZ a/k1a LENKY, DROVE FROM NASSAU COUNTY TO QUEENS COUNTY TO
OBTAIN A QUANTITY OF COCAINE.

ON OR ABOUT JULY 21, 2017, KEVIN TORRES a/k1a INQUIETO AND EVER MORALES
LOPEZ a/k1a LENKY, POSSESSED A QUANTITY OF COCAINE IN EXCESS OF 8 OUNCES.

ON OR ABOUT JULY 27, 2017, MAURICIO MENDOZA A/KIA CYCLO DID TRANSFER
POSSESSION OF A QUANTITY OF COCAINE TO ANOTHER.

ON OR ABOUT AUGUST 22, 2017, MAURICIO MENDOZA a/k1a CYCLO POSSESSED A

QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

ON OR ABOUT AUGUST 22, 2017, EVER MORALES LOPEZ a/k1a LENKY POSSESSED A
QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

ON OR ABOUT OCTOBER 12,2017, EVER MORALES LOPEZ a/k1a LENKY POSSESSED

A QUANTITY OF COCAINE WITH THE INTENT TO SELL IT.

FOURTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendants
a/k1a VICTOR LOPEZ, a/k1a
and a/k1a a/k1a
of the crime of CONSPIRACY IN THE SECOND DEGREE, a class B felony, in
violation of Section 105.15 of the Penal Law of the State of New York, committed as follows:

The defendants a/k1a VICTOR LOPEZ, ELVIN

RODRIGUEZ a1k/a and a1k/a
a1k/a , on or about and between July 1,2017, and January 8,2017,
in the County of Nassau, with the intent that conduct constituting a class A felony be performed,
agreed with one or more persons to engage in or cause the performance of such conduct, to wit:
the defendants did conspire to commit the crime of Murder in the Second Degree, a class A felony.

MS-13 members undertook ruthless acts of violence to establish the gang's supremacy and further its
self-declared mission. The acts of violence, however, were to be sanctioned by the hierarchal
members. Members were not permitted to randomly attack people, but rather were required to report
to their leaders issues with specific individuals. In turn, the leaders, would determine the way in
which the group would proceed. The conspirators also agreed to kill their own members if there
was evidence to suggest that the member was disloyal to the gang by, for example, cooperating
with law enforcement or attempting to leave the gang. They even agreed to inflict punishment or·
death on those members who overstated their position in the gang or whose actions compromised
the gang's agendas, by failing to perform required tasks or acting in a manner injurious to the gang.

In furtherance of their illicit agreement and in order to affect the object of the conspiracy, the
defendants, acting together and with other individuals, performed and caused to be performed the
following overt acts, among others in the conspiracy detailed in this count:

ON OR ABOUT JULY 21, 2017, VICTOR LOPEZ AND a1k/a

AND OTHERS, LURED SOLER a1k/a CHAPO, TO A REMOTE WOODED
AREA IN ROOSEVELT, NASSAU COUNTY, WITH THE INTENT TO KILL HIM.

ON OR ABOUT AUGUST 4,2017, VICTOR LOPEZ, USING MOBILE TELEPHONE

NUMBER 516-503-3115, COMMUNICATED WITH a1k/a
OVER MOBILE TELEPHONE NUMBER 516-528-5957, DURING WHICH
CONVERSAnON a1k/a INSTRUCTED VICTOR LOPEZ
TO HAVE GUNS AVAILABLE IN CASE THEY HAD TO BE USED TO MURDER
.

ON OR ABOUT AUGUST 4, 2017, VICTOR LOPEZ, USING MOBILE TELEPHONE

NUMBER 516-503-3115 COMMUNICATED, WITH a1k/a
OVER MOBILE TELEPHONE NUMBER 516-528-5957, DURING WHICH
CONVERSAnON, a1k/a DIRECTED VICTOR LOPEZ
TO CONTACT THEIR CLIQUE'S LEADER ( ) TO GET
PERMISSION TO COMPLETE THE ATTACK ON .

ON OR ABOUT AUGUST 4,2017, a1k/a OVER MOBILE

TELEPHONE NUMBER 516-528-5957 SENT A TEXT MESSAGE TO VICTOR LOPEZ ON
MOBILE TELEPHONE NUMBER 516-503-3115, PROVIDING THE TELEPHONE
NUMBER FOR VICTOR LOPEZ TO CALL IN ORDER TO ARRANGE PERMISSION TO
KILL .

ON OR ABOUT AUGUST 4, 2017, VICTOR LOPEZ CONTACTED

IN ORDER TO OBTAIN PERMISSION TO COMPLETE THE ATTACK ON , AND
WAS INSTRUCTED TO CONTACT HIM ( ) ONCE THEY HAD
IN THEIR CUSTODY.

ON OR ABOUT OCTOBER 28,2017, VICTOR LOPEZ, USING MOBILE TELEPHONE

NUMBER 516-503-3115 COMMUNICATED, WITH a/k/a
OVER MOBILE TELEPHONE NUMBER 516-528-5957, DURING WHICH
CONVERSATION, a/k/a DIRECTED
a/k/a a/k/a TO TRANSPORT HIS LOADED
FIREARM FROM NASSAU COUNTY TO MARYLAND.

ON OR ABOUT OCTOBER 28, 2017, a/k/a

a/k/a POSSESSED A LOADED FIREARM.

FIFTEENTH COUNT
THE GRAND JURY OF THE COUNTY OF NASSAU, by this indictment, accuses the defendants
a/k/a VICTOR LOPEZ, a/k/a
and a/k/a a/k/a
of the crime of CONSPIRACY IN THE FOURTH DEGREE, a class E felony, in
violation of Section 105.10(1) of the Penal Law of the State of New York, committed as follows:

The defendants a/k/a VICTOR LOPEZ,

a/k/a and a/k/a
a/k/a on or about and between August 2,2017, and August 6,
2017, in the County of Nassau, with the intent that conduct constituting a class B felony be
performed, agreed with one or more persons to engage in or cause the performance of such
conduct, to wit: the defendants did conspire to commit the crime of Assault in the First Degree, a
class B felony, and did commit the following overt acts in furtherance of said conspiracy:

ON OR ABOUT AUGUST 2, 2017, VICTOR LOPEZ CONTACTED USING MOBILE

TELEPHONE NUMBER 516-503-3115, CALLED LEON, THE INDIVIDUAL HE
PLANNED ON ATTACKING, AND TOLD HIM TO MEET HIM THAT WEEKEND.

ON OR ABOUT AUGUST 5, 2017, VICTOR LOPEZ USING MOBILE TELEPHONE

NUMBER 516-503-3115 DIRECTED OTHER CO-CONSPIRATORS TO BRING WEAPONS
AND GUNS TO THE LOCATION WHERE THEY PLANNED TO ATTACK .

ON OR ABOUT AUGUST 6, 2017, VICTOR LOPEZ, USING MOBILE TELEPHONE

NUMBER 516-503-3115, COMMUNICATED WITH OVER MOBILE
TELEPHONE NUMBER 201-456-4419, AND AGREED TO PROVIDE
TRANSPORTATION FOR MEMBERS OF THE CONSPIRACY TO THE LOCATION IN
GLEN COVE, NASSAU COUNTY, WHERE THEY PLANNED TO ATTACK .
ON OR ABOUT AUGUST 6, 2017, DROVE FROM NEW JERSEY TO
NASSAU COUNTY TO MEET VICTOR LOPEZ IN ORDER TO PROVIDE
TRANSPORTATION TO THEIR CO-CONSPIRATORS.

ON OR ABOUT AUGUST 6,2017, VICTOR LOPEZ, AND

a/k/a a/k/a MET IN THE VICINITY
OF 420 NASSAU ROAD, ROOSEVELT, NASSAU COUNTY TO OBTAIN
TRANSPORTATION TO THE LOCATION FOR THE AGREED UPON ATTACK ON

ON OR ABOUT AUGUST 6, 2017, VICTOR LOPEZ, AND

a/k/a a/k/a WERE IN POSSESSION
OF 2 MASKS, A LARGE HUNTING KNIFE, AND RUBBER GLOVES.

AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendants
VICTOR LOPEZ, a/k/a and
a/k/a a/k/a of the crime of CRIMINAL
POSSESSION OF A WEAPON IN THE FOURTH DEGREE, in violation of Section 265.01(2)
of the Penal Law of the State of New York committed as follows:
The defendants VICTOR LOPEZ, a/k/a
and a/k/a a/k/a on or about
August 6, 2017, in the County of Nassau, State of New York, did knowingly and unlawfully
possess a deadly weapon, that being a large knife, with the intent to use it unlawfully against
another.

SEVENTEENTH COUNT
AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendant
a/k/a a/k/a of the crime of
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE, in violation of Section
265.03(3) of the Penal Law of the State of New York committed as follows:
The defendant, a/k/a a/k/a
on or about the October 27,2017, in the County of Nassau, State of New York, and
elsewhere, did knowingly and unlawfully possess a loaded AND OPERABLE firearm, that being
a .32 caliber pistol (Walther 7.65 mm).

EIGHTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendant EVER
MORALES LOPEZ a/k/a LENKY of the crime of CRIMINAL POSSESSION OF A
CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1) of
the Penal Law of the State of New York committed as follows:
The defendant, EVER MORALES LOPEZ a1k/a LENKY on or about October 12, 2017,
in the County of Nassau, State of New York, did knowingly possess a narcotic drug, that being
cocaine, with the intent to sell it.
NINETEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendant EVER
MORALES LOPEZ a1k/a LENKY of the crime of CRIMINALLY USING DRUG
PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(2) of the Penal
Law of the State of New York committed as follows:
The defendant, EVER MORALES LOPEZ a1k/a LENKY on or about October 12, 2017, in the
County of Nassau, State of New York, did knowingly possesses gelatin capsules, glassine
envelopes, vials, capsules or any other material suitable for the packaging of individual quantities
of narcotic drugs or stimulants under circumstances evincing an intent to use or under
circumstances evincing knowledge that some person intends to use the same for the purpose of
unlawfully manufacturing, packaging or dispensing of any narcotic drug or stimulant, to wit:
packaging material.

TWENTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendant EVER
MORALES LOPEZ a1k/a LENKY of the crime of CRIMINALLY USING DRUG
PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(3) of the Penal
Law of the State of New York committed as follows:
The defendant, EVER MORALES LOPEZ a1k/a LENKY on or about October 12,2017,
in the County of Nassau, State of New York, did knowingly possesses scales and balances used
or designed for the purpose of weighing or measuring controlled substances, under circumstances
evincing an intent to use or under circumstances evincing knowledge that some person intends to
use the same for the purpose of unlawfully manufacturing, packaging or dispensing of any narcotic
drug or stimulant, to wit: digital scale.

TWENTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF NASSAU further accuses the defendant
KEVIN TORRES a1k/a INQUIETO of the crime of CRIMINAL POSSESSION OF A WEAPON
IN THE FOURTH DEGREE, in violation of Section 265.01(2) of the Penal Law of the State of
New York committed as follows:
The defendant, KEVIN TORRES a1k/a INQUIETO on or about October 12,2017, in the
County of Nassau, State of New York, did knowingly and unlawfully possess a weapon with the
intent to use unlawfully against another, that being a machete.
All of the acts and transactions alleged in each of the several counts of this Indictment are
connected together and form a common scheme and plan.

Dated: January 8, 2018

Mineola, New York

MADELINE SINGAS
District Attorney
IND NO. 33N18

SUPREME COURT: COUNTy OF NASSAU

THE PEOPLE OF THE STATE OF NEW YORK

-against-

a/k/a
a/k/a
VICTOR LOPEZ
JDPRIMO
a/k/a
KEVIN TORRES a/k/a INQUIETO
EVER MORALES LOPEZ a/k/a LENKY
AUGUSTINE BENITEZ a/k/a OLVIDADO
KEVIN CUEVAS DEL CID a/k/a CREEPER
MAURICIO MENDOZA a/k/a CYCLO
EDGAR a/k/a
a/k/a
a/k/a a/k/a
JDGORDO

MADELINE SINGAS
District Attorney

INDICTMENT FOR:

MURDER IN THE SECOND DEGREE

OPERATING AS A MAJOR TRAFFICKER (3 COUNTS)
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE
CONSPIRACY IN THE SECOND DEGREE ( 8 COUNTS)
CRIMINAL POSSESSION OF A WEAPON IN THE SECOND DEGREE
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE
CONSPIRACY IN THE FOURTH DEGREE ( 2 COUNTS)
CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE (2 COUNTS)
CRIMINAL POSSESSION OF A WEAPON IN THE FOURTH DEGREE (2 COUNTS)

A TRUE BILL

Foreperson