Sergio Lopez Criminal Complaint

AO 91 (Rev. 02109) Criminal Complaint
United States District Court
United States of America
v.
SERGIO QUEZADA-LOPEZ,
Defendant.
for the
DISTRICT OF OREGON
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Case No.
CRIMINAL COMPLAINT
'12-MJ-068
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 of April 19,20 12, in the county ofMultnomah, in the District of Oregon, the defen ant violated
21 U.S.C. Section, 841 , (aXI), (b)(1 )(C) and an offense described as follows:
Distribution of Heroin Resulting in Death, 21 U.S.C. Section 841 (a)(I), (b)(I)(C), and Conspiracy to Distrib te Heroin in
violation of 21 U .S.C. Section 846.
This criminal complaint is based on these facts:
See Attached affidavit of Task Force Officer Gerrit Roelof.
Continued on the attached sheet.
T
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Prinled ?e_and lille
Sworn to before me and signed in my presence.
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Date: -t/2t{ (2-01 L
City and state: Portland, Oregon
Honorable Paul Papak. U.S. Magistrate udge
Printed name and title
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AFFIDAVIT OF DEA TASK FORCE OFFICER GERRIT C. ROELOF
I, TFO Gerrit C. Roelof, do hereby state as follows:
INTRODUCTION
I. The purpose of the affidavit is to set forth probable cause in support of an arrest warra t for
Sergio Quezada Lopez, DOB 11 / 1111978 for the charge of Distribution of Heroin Res ting
in Death and for the charge of Conspiracy to Distribute Heroin in a Quantity Greater T an
One Kilogram, in violation of; Title 21 , United States Code, Section 841 (a)(1)(b)(1)(c) and
846.
2. I am a Salem Police Department (SPD) Detective currently assigned as a Task Force 0 ficer
(TFO) to the Drug Enforcement Administration (DEA) Salem Resident Office (RO) a9d an
investigative or law enforcement officer of the United States within the meaning of Sedtion
2510(7) of Title 18 of the United States Code. I am empowered to conduct investigatij ns
and to make arrests for federal offenses enumerated in Title 18, United States Code, S tion
2516. I have been employed by the Salem Police Department as a police officer since une
2004. I have been assigned as a Task Force Officer with the DEA Salem RO since
February 2010. I have attended the DEA Basic Investigation School where I received
specialized training from the DEA. This training focused on methods of unlawful d r u ~
trafficking; the identification of controlled substances; the means by which drug trafficf ers
derive, launder, and conceal their profits from drug trafficking; the use of assets to facilitate
unlawful drug trafficking activity; and the laws relating to the forfeiture to the United I· tates
of assets purchased with drug proceeds or assets used or intended to be used to facilita e the
drug violations. As a TFO with the DEA, my duties have included investigating violat ons
of federal laws concerning the unlawful importation of controlled substances, the
distribution of controlled substances, and the possession with the intent to distribute
controlled substances, including heroin, cocaine, methamphetamine, and marijuana. rrring
my law enforcement career I have participated in investigations that have involved cOf -
authori zed access to latitude and longitude data for cellular telephones, as well as TitlellII
wiretap investigations. During this time I have attended specialized training provided fY
the DEA and other law enforcement agencies and I have become familiar with the types and
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amounts of profits made by narcotics smugglers and the methods, language and terms that
are used to disguise the source and nature of the profits from their illegal narcotic deali hgs.
I have also attended training on techniques and tools used to examine cellular telephon Is
and GPS devices. I have personally interviewed confidential sources and executed se ch
warrants for evidence of trafficking controlled substances.
SUMMARY OF THE INVESTIGATION
3. On April 16, 2012, the Keizer Police Department responded to the residence of21 ye old
Laurin Putnam, who was found deceased. The resulting investigation indicates that her
death was probably caused by a heroin overdose based on eyewitness accounts of LaurIn
Putnam buying heroin an hour before her death and evidence of heroin use found at thd
scene of her death. An autopsy on the deceased has been conducted and we are awaitiJ
r
toxicology reports. The medical examiner found an injection site on the body with no ther
apparent cause of death for such a young person. TFO Nelson interviewed Nicole
Liljequist, Putnam's roommate. Liljequist admitted to being a heroin user, and stated t ,
Nelson that both she and Putnam normally purchased their heroin from John Doe # I. I
Investigators determined that John Doe #1 had already attempted to reach Liljequist, t
meet and discuss Putnam's death. Liljequist, at the direction of investigators, agreed to meet
with John Doe # 1. During this subsequent meeting, John Doe # 1 admitted to supplyin
Putnam with heroin. John Doe #1 was subsequently arrested, and admitted to TFO's
Nelson and Roelof that he had arranged to sell Putnam 1 gram of heroin for $120
approximately one hour before she was found deceased.
I Due to my ongoing concerns that the suspects who cooperated in this matter may face retalia
l
ion
for their cooperation from members of the high-level drug organization that distributed the s U I ~ e c t
heroin, I have elected to refer to them as John Does rather than disclose their true name at this early
juncture in the case. All of the individuals listed as John Doe in this affidavit have been positi ely
identified and have been arrested. They are currently either in state or federal custody at this tIme or
on a controlled release status pending adjudication of their own charges stemming from their
invol vement in the supply chain of heroin believed to have resulted in the death Laurin Putna . I
do not believe that listing the actual names of these cooperating defendants is necessary for a I
determination of probable cause at this stage in the investigation. I have detailed an abundance of
evidence in this affidavit that corroborates the statements of the John Does.
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4. John Doe # I agreed to cooperate with law enforcement, and provide information on his
heroin supplier. He stated that he had brokered the one gram deal with John Doe #2. Jdhn
Doe #1 placed several recorded phone calls to John Doe #2, ordering another gram of
heroin while being monitored by law enforcement. John Doe #2 responded to deliver t IS
heroin, and was arrested. One gram of heroin was subsequently found on John Doe #2's
person. John Doe #2 was interviewed by TFO's Roelof and Nelson, and admitted to se ling
the one gram of heroin to John Doe # I the night before. John Doe #2 also identified a
photograph of Putnam, stating that she had purchased heroin from him, through John Doe
# I, in the past.
5. John Doe #2 agreed to cooperate with law enforcement, and provide information on his
heroin supplier. He stated that he was supplied solely by John Doe #3. While being
monitored and directed by law enforcement, John Doe #2 made several recorded calls 0
John Doe #3, and ordered two "pieces" of heroin. I know that among heroin purchaSerj and
sellers, a "piece" refers to 25 grams of heroin. John Doe #3 was arrested when he arriv d at
the agreed location of the deal. During a search of his person, John Doe #3 was found 0
have two "pieces" of heroin in his front jacket pocket. John Doe #3 was arrested, and
refused to cooperate with law enforcement.
6. On the next day, Apri l 17, 2012, after speaking to his attorney, John Doe #3 and hi s
attorney advised law enforcement that John Doe #3 was willing to cooperate with this
investigation, and provide information on his heroin supplier. John Doe #3 stated that e
purchased heroin solely from John Doe #4. John Doe #3 placed several recorded call s [0
John Doe #4, ordering 5 pieces of heroin. John Doe #4 subsequently responded to the eet
location and was arrested. During the search of his person and vehicle, approximately 69
grams of heroin (gross weight), 21 grams of cocaine (gross weight) and $800 in US
currency was located and seized. John Does #4 refused to cooperate with law enforce ent.
7. On the next day, April 18,2012, after speaking to his attorney, John Doe #4 re-contac d
law enforcement and advised that he was wi lling to cooperate with this investigation, Jnd
provide information on his heroin supplier that supplied the heroin that John Doe #4 st ld to
John Doe #3. This is some ofthe same heroin that John Doe #3 had earl ier told law I
enforcement that he had sold to John Doe #2 who told officers that he had sold to Jo Doe
# I who told officers that he had sold to Laurin Putnam, an hour before her death. Jo Doe
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#4 stated that he had recently purchased heroin from John Doe #5. John Doe #4 furthe
stated that he had initially contacted "Cheche" (later identified as Sergio Quezada-Lop z),
and that "Pariente" or John Doe #5 was "Cheche's" worker, and would normally be th one
to deliver the heroin for Sergio Quezada Lopez. John Doe #4 placed several recorded ails
to John Doe #5, ordering 20 pieces of heroin. John Doe #5 was arrested upon his arriv II at
the agreed location for the deal and was arrested. During the search of his vehicle,
approximately 1.42 pounds (gross weight) of heroin was seized.
8. John Doe #5 subsequently agreed to cooperate with law enforcement. John Doe #5 sta d to
investigators that he worked for a male named "Cheche" (later identified as Sergio
Quezada-Lopez). He stated that Quezada-Lopez would receive orders for heroin, and then
direct John Doe #5 to deliver the heroin to the buyer, collect the money, and return the l
money to Quezada-Lopez. John Doe #5 further stated that Quezada-Lopez was out oft wn,
and would be returning the next day on April 19,2012.
COOPERATION OF JOHN DOE #5 AND CONSENT SEARCH OF 1809 W 24T11 ST ET,
VANCOUVER, WASHINGTON I
9. On April 18,2012, after John Doe #5 was arrested and advised of his Miranda Rights . y
TFO Jose Salas, John Doe #5 agreed to speak with investigators. I know this informati n, as
well as information articulated below regarding this interview, from speaking directly 0
TFO Jose Salas and from being present during portions of these interviews. John Doe 5
stated to TFO Salas that he lived at 1809 W 24th Street in Vancouver, Washington. He
explained that he lived there with "Checho" (heretofore referred to as Quezada-Lopez) and
that he worked for Quezada-Lopez, selling heroin. John Doe #5 stated that Quezada-L pez
would instruct him to deliver heroin to certain persons. John Doe #5 would then pick up the
heroin and place it behind the stereo in the silver Ford Focus which he used to deliver
heroin on this date to John Doe #4. He would then receive money from the customer, r d
place that behind the same stereo, and deliver it back to Quezada-Lopez. John Doe #5 jtated
to TFO Salas that there was approximately $17,000 in US currency stored at their resi1ence,
at 1809 W 24th Street, Vancouver, Washington. John Doe #5 stated that Quezada-Lop, z had
been in Las Vegas for the past couple of months, and that he had left John Doe #5 in charge
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of this residence while Sergio Quezada-Lopez frequently called John Doe #5 on phones
with instructions on how to keep the drug operation running with specific directions a+ ut
multiple deliveries of large quantities of heroin to various customers. John Doe #5 furtr er
stated that the only two keys for this residence were retained by John Doe #5, as Quezada-
Lopez had given his key to John Doe #5 before departing to Las Vegas. John Doe #5 j ave
written consent to investigators, authorizing them to search this residence.
10. Investigators searched the residence on W 24th St. As a result of this search, a still-to-Ile
counted amount of US currency, drug ledgers and drug packaging materials were seizdd
from the residence. A Mexican Photo Identification card was also seized. This card wl in
the name Carlos Arias-Castillo. John Doe #5 was later shown a photograph of this 1
Identification card taken by TFO Salas during the search, and John Doe #5 identified t e
person in the photograph as "Checho" (Sergio Quezada-Lopez).
RECORDED CALLS BETWEEN JOHN DOE #5 AND SERGIO UEZADA-LOPElZ
II. On April 19
th
, 2012, TFO Salas, TFO Chris Nelson and I met again with John Doe #5, and hi s
attorney. John Doe #5 reiterated his intent to cooperate with law enforcement, and stated that 1e
would attempt to communicate with Quezada-Lopez and assist in our attempts to locate and ar est
him. John Doe #5 then made a series of recorded phone calls to Quezada-Lopez. John Doe #5ised
telephone number (4 I 4-215-1685) to make these calls, and Quezada-Lopez was contacted at pr one
number (702-235-1117). The recorded conversations between John Doe #5 and Quezada-Lopez
primarily concerned Quezada-Lopez's plan to return to Oregon on a bus, the direction of John Doe
#5 to pick him up, and the direction of John Doe #5 as to the distribution of heroin to customers,
Sergio Quezada- Lopez was not aware that John Doe #5 was in the custody of police officers when
Quezada-Lopez spoke freely to John Doe #5 about their heroin business, thereby providing an
incriminating recording of hi s own voice discussing the distribution of heroin. TFO Salas
translated these Spanish conversations to English. TFO Salas compared the voice talking to Jo n
Doe #5 with a recording of Quezada-Lopez's voice after he was later arrested and concluded tr at the
voice talking to John Doe #5 was Quezada Lopez. TFO Salas stated to me that some of the
conversations discussed selling heroin to persons named "TJ", "Buki" and John Doe #6. John r oe
#5 stated to me that "TJ" (identified as John Doe #4), "Buki", and John Doe #6 are heroin
customers. In these conversations, Quezada-Lopez instructed John Doe #5 to sell portions oft eir
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remaining heroin to these customers. Quezada-Lopez further instructed John Doe #5 to contact
"Buki" and John Doe #6 to arrange these deliveries.
12. John Doe #5 subsequently identified to officers Quezada-Lopez as he exited a bus later that ev ning
in Portland near 148
1h
Street and Stark Street, and Quezada-Lopez was arrested.
COOPERATION OF JOHN DOE #S AND CONSENT SEARCH OF 4701 72"d A VENUE,
APARTMENT #84, VANCOUVER, WASHINGTON
I. On April 23, 2012, investigators again interviewed John Doe #5. During this interview, John 9 0e #5
stated to TFO Salas that there was still some information for which he was afraid to speak about.
TFO Salas and TFO Nelson reminded John Doe #5 of the agreement discussed with his attorn11y on
April 19th, 2012, and that his total disclosure of relevant facts during this investigation was
important. John Doe #5 then disclosed that he and Quezada-Lopez maintained a second "stash
house" location, where additional drugs and money were being kept. John Doe #5 stated that hi had
not wanted to talk about this location earlier, for fear that he would be charged for these additi t nal
drugs. John Doe #5 then led me to 4701 72"d Avenue, which is the Camden Place Apartments. ohn
Doe #5 showed me the front door of apartment #84, and stated that this was the location wherJ. he
and Quezada-Lopez stored additional drugs. John Doe #5 stated that Quezada-Lopez stored thJ
drugs here, and that he would instruct John Doe #5 to pick up the heroin from there, in order t
subsequently deliver it to the customers of Quezada-Lopez .. John Doe #5 gave written consent to
search thi s location, and also identified a key from hi s key ring which opened the door at this
location. A subsequent search of this apartment resulted in the seizure of approximately two to three
pounds of heroin, a still-to-be counted amount of US Currency, documents with Sergio Queza a-
Lopez's name on them, multiple discarded wrappers likely used to contain drugs and drug
packaging materials. In my experience, the two stash houses and the amount of drugs being
di stri buted by Sergio Quezada-Lopez together with the statements about him from John Does 4, #5
and #6 (see below) to his customers in Oregon and Washington was on a very high level both r
terms of sophistication and great quantities far exceeding on a regular basis more than one kilor ram
of heroin. The operation was likely yielding a yearly gross profit of over one-hundred thousan1
dollars. The investigation is ongoing and it is unknown at this time if Sergio Quezada-Lopez was
operating a similar scheme in Las Vegas. A review of Sergio Quezada-Lopez's criminal
history indicates he has been convicted of Delivery of Heroin in Multnomah County i
2000, Illegal Reentry in 2002 in Tucson Arizona, Conspiracy to Violate the Uniform
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Controlled Substances Act in Las Vegas, Nevada, in 2005, and Dangerous Drugs in 2007 in
Colorado.
COOPERATION OF JOHN DOE #5 RESULTING IN THE ARREST OF JOHN DOE #6.
2 0" A p';' 23, 2012, d ,,;"' <h, w;<h 30h" Doo #5, h' ;d,"';fiod ",<Om" o"jdO
as a nickname for John Doe #6. John Doe #5 subsequently made recorded phone calls to John Doe
I
#6, who ordered 8-9 pieces of heroin /Tom John Doe #5. John Doe #6 used telephone number 360-
600-094 I) during these conversations. John Doe #6 was arrested upon his arrival at the agreed
location for the deal. Approximately $9,200 in US Currency was seized from his vehicle. John Doe
was subsequently read hi s Miranda Rights in Spanish by TFO Salas. John Doe #6 agreed to spr ak
with investigators. He stated that he had been contacted earlier by a male he knew as "Hijo". Jf hn
Doe #6 stated that "Hijo" worked for a man known as "Loca", and that " Loca" and "Hijo" sold him
heroin regularly. John Doe #6 stated that he ordered 8-9 pieces of heroin from " Hijo". John Ode #6
was shown a photo lineup, and identified a photo of Sergio Quezada-Lopez as "Loca". John Dbe #6
also identified three phone numbers which he had saved in his phone, which he had used to c+ tact
Quezada-Lopez in the past. These numbers were; (559-45 I -580 I), (559-2 I 7-0734) and (702-2B5-
I I 17). John Doe #6 also identified a phone number he stated that he used to contact " Hijo" to order
the heroin that evening, as (414-215-1685). As note
, Task Force Officer
Drug Enforcement Administration
Sworn to before me, and subscribed to in this (L!; day of April 2012
dktfi irA
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U.S. Magistrate Judge Paul Papak
United States District Court
District of Oregon
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