AO 91 (REV.5/85) Criminal Complaint AUSAs Stephen P.

Baker and Megan Cunniff Church (312) 353-5300

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

UNITED STATES OF AMERICA

CRIMINAL COMPLAINT
v.
CASE NUMBER:
ASKIA EUBANKS,
also known as “Bonifacio” and “Bon” UNDER SEAL

I, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to the best of my
knowledge and belief: From in or about February 2010 through April 2010, in the Northern District of Illinois, Eastern Division,
and elsewhere, ASKIA EUBANKS, also known as “Bonifacio” and “Bon,” defendant herein:

did conspire with others known and unknown to the United States to knowingly and intentionally possess with
intent to distribute and to distribute controlled substances, namely, five kilograms or more of mixtures and
substances containing a detectable amount of cocaine, a Schedule II Narcotic Drug Controlled Substance,
in violation of Title 21, United States Code, Section 841(a)(1),

in violation of Title 21, United States Code, Section 846. I further state that I am a Special Agent with the Drug Enforcement
Administration, and that this complaint is based on the facts contained in the Affidavit which is attached hereto and incorporated
herein.

Signature of Complainant
KEYUR PATEL
Special Agent, Drug Enforcement Administration

Sworn to before me and subscribed in my presence,

May 4, 2010 at Chicago, Illinois

Date City and State

MICHAEL T. MASON, U.S. Magistrate Judge

Name & Title of Judicial Officer Signature of Judicial Officer
 AFFIDAVIT

I, KEYUR PATEL, being duly sworn, deposes and states as follows:

1. I am a Special Agent with the United States Drug Enforcement

Administration (“DEA”), United States Department of Justice. I have been

employed by the DEA as a Special Agent for the last 6 months and I am currently

assigned to the DEA Chicago Field Division, Chicago, Illinois. Prior to that, I was

an Intelligence Officer with the Defense Intelligence Agency for approximately 5

years.

2. My official DEA duties include investigating criminal violations of the

federal narcotics laws, including but not limited to: possession with intent to

distribute and distribution of controlled substances, in violation of Title 21, United

States Code, Section 841(a)(1); conspiracy and attempt to possess with intent to

distribute and to distribute controlled substances, in violation of Title 21, United

States Code, Section 846; use of communication facilities to facilitate drug

trafficking offenses, in violation of Title 21, United States Code, Section 843(b); and

laundering of monetary instruments, in violation of Title 18, United States Code,

Section 1956. I have received special training in the enforcement of laws concerning

controlled substances as found in Title 21 of the United States Code. Some of the

specialized training I have received includes, but is not limited to, classroom

instruction concerning narcotics smuggling, money laundering investigations and

conspiracy and complex investigations. I have been involved in various types of

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electronic surveillance, including the interception of wire communications, the

debriefing of defendants, witnesses and informants, as well as others who have

knowledge of the distribution and transportation of controlled substances, the

laundering and concealing of proceeds from drug trafficking and the street gangs

who participate in these illegal activities.

3. As a result of these investigative activities, I have conducted and

participated in several investigations with DEA that have resulted in the seizure of

multiple kilograms of cocaine, heroin, and marihuana. I am familiar with and have

participated in all of the normal methods of investigation, including but not limited

to visual and video surveillance, questioning of witnesses, controlled deliveries, use

of search and arrest warrants, management and use of informants, and pen

registers. I know, based upon the above experience, that drug traffickers and

money launderers utilize telephones, pagers, and trapped vehicles to facilitate their

illegal activities.

4. The information contained in this Affidavit is based on my participation

in this investigation; my conversations with and review of reports prepared by

agents in the DEA, as well as other federal agencies and other law enforcement

agents and officers; the results of physical surveillance; agents’ review of

conversations intercepted pursuant to Court orders authorizing the interception of

wire communications; my training and experience; and the training and experience

of other law enforcement officers I have consulted. Since this Affidavit is being

submitted for the limited purpose of establishing probable cause as set forth herein,

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I have not included each and every fact known to me concerning this investigation.

I. PURPOSE OF AFFIDAVIT

5. This Affidavit is made for the purpose of establishing probable cause in

support of a complaint charging: ASKIA EUBANKS, aka “Bonifacio” and “Bon,”

with conspiring with Antonio Mendoza, aka “Tonio,” aka “Monster,” Roberto

Sandoval-Velazco, and Manuel Chavez, aka “Meno,” and with others known and

unknown to knowingly and intentionally possess with intent to distribute and to

distribute controlled substances, namely, five kilograms or more of mixtures and

substances containing a detectable amount of cocaine, a Schedule II Narcotic Drug

Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1),

all in violation of Title 21, United States Code, Section 846.

II. PROBABLE CAUSE

6. Based upon investigation and interceptions listed below, I believe that

Antonio Mendoza, aka “Tonio,” aka “Monster” (hereinafter “Mendoza”) is now

operating as the Chicago area cell head for a drug trafficking organization’s

(“DTO’s”) distribution efforts in this area. Mendoza is accepting narcotics from the

organization and distributing narcotics to various wholesale distributors in the

Chicago area. Roberto Sandoval-Velazco (hereinafter “Sandoval-Velazco”) and

Manuel Chavez, aka “Meno” (hereinafter “Chavez”) are workers for Mendoza and

the DTO in Chicago, Illinois, aiding in Mendoza’s distribution efforts. 1 ASKIA

1 On April 28, 2010, U.S. Magistrate Judge Susan E. Cox for the Northern District of
Illinois signed an amended complaint in case number 10 CR 333 that charged Mendoza,
Sandoval-Velazco, Chavez, and three others with conspiring with each other and others

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EUBANKS, aka “Bonifacio” and “Bon” (hereinafter “EUBANKS”) is a customer of

Mendoza’s who receives from Mendoza wholesale quantities of cocaine and heroin

on a fronted basis. INDIVIDUAL A is a Mexican-based source of supply for kilogram

quantities of cocaine who coordinates the distribution of cocaine from Mexico to the

United States, including Chicago, Illinois. As detailed below, one of the examples of

the conspiracy was the distribution of ten kilograms of cocaine to Mendoza,

Sandoval-Velazco, and Chavez from their supplier on a fronted basis, and which

they subsequently delivered, on a fronted basis, to EUBANKS.

A. Surveillance of the Delivery of 15 Kilograms of Cocaine from Mendoza

to EUBANKS at 60 Iliad Drive, Tinley Park, Illinois

7. Based on calls intercepted over Target Phone 1 and Target Phone 2

and prior surveillance, agents believed that Mendoza would deliver fifteen

kilograms of cocaine to ASKIA EUBANKS, aka “Bonifacio” and “Bon” 2 at 60 Iliad

known and unknown to the United States to possess with intent to distribute controlled
substances, namely, five kilograms or more of mixtures and substances containing a
detectable amount of cocaine, a Schedule II Narcotic Drug Controlled Substance, in
violation of Title 21, United States Code, Section 841(a)(1), all in violation of Title 21,
United States Code, Section 846. EUBANKS was identified in the amended complaint as
CUSTOMER 3. The amended complaint is incorporated herein by reference.
2 The identity of ASKIA EUBANKS, aka “Bonifacio” and “Bon,” was established by,
among other things, the following: according to a toll analysis of INDIVIDUAL A’s
telephones, a Chicago-area telephone number was in contact with INDIVIDUAL A’s
telephone on the same day that Mendoza delivered 15 kilograms of cocaine to “Bonifacio.”
After conducting surveillance of the transaction and subsequent transactions, agents
identified EUBANKS as “Bonifacio” and “Bon,” from an arrest photograph. According to
law enforcement database information, a known alias for EUBANKS is “Bone.”
Additionally, EUBANKS, aka “Bonifacio” and “Bon,“ was intercepted in conversations with
INDIVIDUAL A while using Target Phone 2, used by Mendoza, in Mendoza’s presence.
Specifically, on March 9, 2010, at approximately 3:21 p.m., Mendoza placed an outgoing call
on Target Phone 2 to INDIVIDUAL A. During the call, INDIVIDUAL A informed
EUBANKS, who was using Mendoza’s cellular telephone, that INDIVIDUAL A would have
kilograms of cocaine ready to distribute to EUBANKS. Specifically, INDIVIDUAL A asked,

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Drive, Tinley Park, Illinois, on February 23, 2010.

8. At approximately 10:00 a.m., agents established surveillance in the

area of 60 Iliad Drive in Tinley Park. During surveillance that morning, agents

observed Mendoza drive his car into the garage at 60 Iliad Drive and,

approximately two hours later, exit the garage driving his car after delivering 15

kilograms of cocaine to EUBANKS. Specifically, agents observed the following:

“Did Bon [EUBANKS] get there already?” Mendoza responded, “Yes. [Background: Bon . . .
Yes!] Here he is.” INDIVIDUAL A said, “I have good news.” Speaking in English,
EUBANKS responded, “Yeah, what’s up?” Speaking in English, INDIVIDUAL A said, “Uh,
maybe Friday or Saturday, 100 percent.” On March 9, 2010, at approximately 3:22 p.m.,
Mendoza placed an outgoing call from Target Phone 2 to Individual A. During the call,
EUBANKS used Target Phone 2 to speak with INDIVIDUAL A, who informed EUBANKS
that he was going to start receiving 50 kilograms of cocaine a week from a new cocaine
supplier. EUBANKS told INDIVIDUAL A to sell him the kilograms of cocaine for a good
price because he could sell all 50 kilograms of cocaine in 10 days. Specifically, using Target
Phone 2 and speaking in English, EUBANKS asked, “You talked to someone and they said
Saturday?” Speaking in English, INDIVIDUAL A said, “At the most, and this is a new
company. You remember that I told you that I was going to talk to the big fish today? They
say, at the most, Saturday.” EUBANKS then asked, “Do you believe it?” INDIVIDUAL A
said, “I believe in these guys. Just watch.” EUBANKS said, “You said the last one
[referring to INDIVIDUAL A’s prior cocaine supplier] was El Chapo.” INDIVIDUAL A
responded, “I know but just watch. Give me until Saturday and you’re going to see it.
These guys are saying that they will do it every 10 days. They are going to start lending me
5-0 [50 kilograms of cocaine] and see how we work. Then, they are going to try and send 100
[kilograms of cocaine]. They are saying that they can go every week if I want, you know?”
EUBANKS said, “Yeah. Just give me a good number and I’ll go through all of them. You
have to give me a good number [price] and I can go through all of them, 50 [kilograms of
cocaine], 100 [kilograms of cocaine]. I told you that I have some people that want a lot of
it.” INDIVIDUAL A said, “Yeah, that’s what I told these guys, but they want to start with
50 [kilograms of cocaine]. I’m telling you the truth. Believe in me.” EUBANKS then
asked, “What number?” INDIVIDUAL A said, “28 [$28,000 per kilogram of cocaine].”
EUBANKS then said, “27-5 [$27,500 per kilogram]. I’m doing 50 [kilograms of cocaine] in
ten days.” INDIVIDUAL A responded, “Yeah 28 [$28,000] my friend. They are telling me .
. . Damn, homie. I don’t want to lie to you but you or anything else but you will see.”
EUBANKS repeated, “27, 5 [$27,500], and I’ll do 50 [kilograms of cocaine] in 10 days.”
INDIVIDUAL A said, “Yeah. We’ll see when they lend them to me. I know it’s going to be
for sure with these guys. I called the other guys and they aren’t answering. Maybe they
don’t know what to tell me, you know.” EUBANKS said, “Okay, Homes. I gave him 8,700.”
INDIVIDUAL A said, “Okay.”

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 a. At approximately 10:17 a.m., agents observed a blue Dodge

Intrepid exit the garage at 60 Iliad Drive and park in a space across the street from

the residence. A white Buick SUV, bearing Illinois vehicle registration 3724133,

registered to PV Holding Cop., 10000 Bessie Coleman Drive, Chicago, Illinois, which

was parked in the driveway, pulled into the garage.

b. At approximately 10:31 a.m., agents observed the white Buick

SUV back out of the garage and park in the driveway of 60 Iliad Drive. An

unknown individual entered the blue Dodge Intrepid and drove away from the area.

c. At approximately 10:39 a.m., agents observed a white Chevrolet

Cobalt, bearing Illinois vehicle registration H865104 (“Cobalt”), registered to

Antonio Mendoza, 4002 West 63rd Street, Chicago, Illinois, drive into the garage at

60 Iliad Drive.

d. On February 23, 2010, at approximately 10:49 a.m., Mendoza

placed an outgoing call (Call #455) on Target Phone 2 to INDIVIDUAL A. During

the call, Mendoza informed INDIVIDUAL A that they were at EUBANKS’ house.

INDIVIDUAL A instructed Mendoza to leave 15 kilograms of cocaine with

EUBANKS. Specifically, Mendoza stated: “Hey, we’re here with Bon [EUBANKS]

already.” INDIVIDUAL A responded, “I was waiting for your call. So you’re there

already?” MENDOZA stated, “Yeah, we’re here. He’s very excited.” INDIVIDUAL

A then stated: “Good, leave him a ‘Quinceyera’ there. Just check them one by one.

How do they look?” [INDIVIDUAL A instructed MENDOZA to leave 15 kilograms of

cocaine for EUBANKS.] Mendoza stated, “He’s very happy. They look good.”

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INDIVIDUAL A asked: “Okay, what was I going to tell you? Do they look like if we

could play them or not?” Mendoza responded, “Let me check the rest, and I will let

you know.” INDIVIDUAL A stated: “Alright.”

e. At approximately 11:20 a.m., agents observed the blue Dodge

Intrepid, which was occupied by an unknown African-American female driver,

return to 60 Iliad Drive. The unknown female parked the car and entered the

residence.

f. At approximately 11:21 a.m., a surveillance agent saw a red

Mitsubishi, bearing Illinois vehicle registration 6933140, registered to Hertz Rental

Car, 2170 Mannheim Road, Des Plaines, Illinois, arrive at 60 Iliad Drive and park

in the drive. An unknown African-American male got out of the Mitsubishi and

went inside the residence.

g. At approximately 11:25 a.m., a surveillance agent saw the

unknown African-American female return to the Dodge and drive away from the

area. At approximately 11:58 a.m., a surveillance agent observed the unknown

African-American male return to the Mitsubishi, get inside, and drive away from

the area.

h. At approximately 12:18 p.m., a surveillance agent observed the

Cobalt exit the garage and depart the area.

B. The Delivery of Cocaine from Adolfo Lopez-Garcia to Mendoza,

Sandoval-Velazco, and Chavez

9. On April 11, 2010, at approximately 5:26 p.m., Mendoza received an

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incoming call (call #4588) on Target Phone 1 from Adolfo Lopez-Garcia (hereinafter

“Adolfo”) utilizing Target Phone 8. During the conversation, Adolfo stated that he

received a load of cocaine and asked Mendoza if he would want it. Specifically,

Adolfo stated: “I wanted to talk to [INDIVIDUAL A], but it’s out of service. The

‘guys’ arrived, the lazy ones. We’ll see if they go back to work.” [Adolfo told

Mendoza that he could not reach INDIVIDUAL A and that Adolfo had received

kilograms of cocaine.] Mendoza stated: “I was just praying to St. Jude right now. I

think he is going to be at the movies or mass. Maybe that’s why it doesn’t go

through.” (Call continues in call #4589.) Adolfo stated: “The guy from the ‘office’

called right now and told me to take care of it. He told me to pick up the vehicle

from you. He told me to resolve it right now. Are you going to bring it to me so I

can let them know?” [Adolfo told Mendoza that Adolfo heard from the stash house

and that Adolfo was to pick up a vehicle from Mendoza to deliver cocaine.] Mendoza

stated: “Yes, I’ll bring it to you. Let me talk to him [INDIVIDUAL A]. I’ll call you

back.” Adolfo stated, “Tell him to resolve something. Otherwise I’m going to move

forward another way.” [Adolfo told Mendoza to tell INDIVIDUAL A to decide

whether they wanted the cocaine, because if not, Adolfo would go with another

customer.] Mendoza advised, “Hold on a bit. I will call you back.”

10. On April 11, 2010, at approximately 5:33 p.m., Mendoza received an

incoming call (call #4601) on Target Phone 1 from INDIVIDUAL A. During the call,

Mendoza advised INDIVIDUAL A that he had spoken to Adolfo and that Adolfo had

cocaine for them to sell. Specifically, Mendoza stated: “Look, Flaco [Adolfo] called

8
me and told me he has work and wants you to call him.” INDIVIDUAL A stated:

“Alright, I was taking a shower let me call him.” Mendoza stated: “He said for to

call to him right away or else he’ll go elsewhere.” INDIVIDUAL A stated: “Tell that

guy I will call him in ten minutes. Tell him I do want some and to put aside a

‘toston’ for me. Tell him I’ll talk to him right now in ten minutes. Just tell him to

give me a minute.” [INDIVIDUAL A told Mendoza to tell Adolfo that INDIVIDUAL

A would call Adolfo in 10 minutes and that INDIVIDUAL A wanted 50 kilograms of

cocaine (a “toston”).] Mendoza stated, “Alright, I’ll call him.”

11. On April 11, 2010, at approximately 8:45 p.m., based upon the calls

summarized above and other calls intercepted over Target Phone 1, agents

established surveillance at two locations: Sneakers Sports Bar located at 9721

Grand Ave, Franklin Park, Illinois; and a stash location known to be utilized by

Adolfo, in the area of 2127 Louis Ave, Melrose Park, Illinois. During surveillance

that evening, agents observed Mendoza and Chavez drop off their car at the Sports

Bar in Franklin Park and Adolfo and his associates retrieve the car and relocate it

to the Melrose Park address. 3

12. On April 12, 2010, at approximately 6:00 a.m., based upon the calls

summarized above and other calls intercepted over Target Phone 1 and the

surveillance of the previous day, agents established surveillance in the area of 2127

Louis Street, Melrose Park, Illinois. During surveillance that morning, agents

3 For a complete description of what agents observed, see paragraphs 18(a) through (j)
of the amended complaint.

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observed Adolfo and his associates deliver the Cobalt to Mendoza and Sandoval-

Velazco at a Dunkin Donuts after Adolfo had stocked it with 30 kilograms of

cocaine. 4

13. On April 12, 2010, at approximately 12:05 p.m., Sandoval-Velazco

placed on outgoing call (call #207) on Target Phone 9 to INDIVIDUAL A. During

the conversation, INDIVIDUAL A advised Sandoval-Velazco to get 10 kilograms of

cocaine ready to take to EUBANKS, a narcotics customer of the drug trafficking

organization. Specifically, INDIVIDUAL A stated: “What’s up? How do those ‘kids’

look? Do they look like they could work or no?” [INDIVIDUAL A asked Sandoval-

Velazco about the quality of the cocaine and whether or not the cocaine could be

sold.] Sandoval-Velazco stated: “Some can, but there are some that can’t because

that’s really white.” INDIVIDUAL A responded: “Alright, when you guys are done

checking, at least, a “dientito” (10) to take to Bon, let me know leave the other guy

checking the rest.” [INDIVIDUAL A advised Sandoval-Velazco to get 10 kilograms

of cocaine ready to deliver to EUBANKS, aka “Bonifacio” and “Bon”.] Sandoval-

Velazco responded: “Alright, so then I’ll call you, ten are done.” INDIVIDUAL A

responded, “Alright then.”

14. On April 12, 2010, at approximately 8:51 a.m., Mendoza received an

incoming call (call #4866) on Target Phone 1 from Adolfo utilizing Target Phone 8.

During the conversation, Adolfo advised Mendoza that his workers put 30 kilograms

4 For a complete description of what agents observed, see paragraphs 19(a) through
(g) of the amended complaint.

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of cocaine in Mendoza’s vehicle. Specifically, Adolfo stated: “Just wanted to let you

know they put 30 dollars of gas.” Mendoza responded: “Alright, I’ll call you once I

arrive to the office.” Adolfo responded: “Fine, cousin, call me when you arrive.”

Mendoza responded: “It cut off.” Adolfo stated: “I said, call me once you get to

work.”

C. Mendoza and Sandoval-Velazco Take the Drugs to 3016 W. Fargo

15. On April 12, 2010, agents continued their surveillance of the Cobalt

and observed the following:

a. At approximately 9:47 a.m., agents observed the Cobalt park in

front of the driveway that pertained to the 3016 West Fargo Avenue, Chicago,

Illinois residence, the residence previously identified as a house used by Antonio

Mendoza, aka “Monster.”

b. At approximately 9:48 a.m., agents observed Sandoval-Velazco

exit the Cobalt and enter a blue Grand Cherokee Jeep bearing Illinois temporary

registration 557L442. A check with the Secretary of State revealed 557L442 is a

2001 Jeep, registered to Manuel Chavez-Garcia. Shortly thereafter, agents

observed Sandoval-Velazco move the Jeep from the driveway of 3016 West Fargo

and park it on the street. Agents then observed Mendoza drive the Cobalt into the

garage that pertained to the 3016 West Fargo residence. Sandoval-Velazco entered

the 3016 West Fargo residence.

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 D. Mendoza and Sandoval-Velazco Deliver 10 Kilograms of Cocaine to
EUBANKS

16. On April 12, 2010, at approximately 5:00 p.m., based upon the calls

summarized above and other calls intercepted over Target Phone 1 and Target

Phone 8 and prior surveillance, agents initiated surveillance in the area of an

apartment complex located at 5930 Lake Bluff Drive in Tinley Park, Illinois.

During surveillance that evening, agents observed Mendoza and Sandoval-Velazco

meet and deliver 10 kilograms of cocaine to EUBANKS. Specifically, agents

observed the following:

a. At approximately 5:05 p.m., agents observed a red Lincoln MKS,

bearing Illinois license plate Y9993, registered to P.V. Holding Corp., 10000 Bessie

Coleman Drive, Chicago, Illinois (the “MKS”), driving on the access road adjacent to

the garages located near the apartment complex at 5930 Lake Bluff Drive in Tinley

Park. At approximately 5:09 p.m., agents observed the same red Lincoln MKS park

in an apartment complex parking lot located near 5930 Lake Bluff Drive.

b. At approximately 5:21 p.m., agents observed the same MKS

driving through the parking lot. Agents observed EUBANKS, aka “Bonifacio,” who

was wearing a white t-shirt, as the driver of the MKS.

c. At approximately 5:30 p.m., agents observed the Cobalt arrive in

the parking lot near 5930 Lake Bluff, Tinley Park Illinois, and park. Agents

observed Sandoval-Velazco driving the Cobalt, with Mendoza as his passenger.

Agents observed that Sandoval-Velazco was wearing a dark-colored t-shirt. Agents

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also observed Mendoza move to the rear passenger seat of the Cobalt while

remaining inside the vehicle.

d. Shortly thereafter, agents observed the MKS drive over and

park next to the Cobalt. After the MKS parked next to the Cobalt, agents observed

both vehicles move to a smaller parking lot to the east of their initial location.

Agents observed both vehicles parked next to each other on the south side of the

smaller parking lot. Agents then observed the trunk of the MKS open, a male

wearing a white t-shirt place an unknown object in the trunk of the MKS, the same

male closed the trunk of the MKS, and then the same male entered the passenger

side seat of the Cobalt. 5

e. At approximately 5:35 p.m., agents observed the Cobalt and

MKS drive away from 5930 Lake Bluff Drive. Agents observed EUBANKS as the

driver of the MKS; Sandoval-Velazco was the driver of the Cobalt; and Mendoza was

the passenger in the Cobalt.

f. At approximately 5:50 p.m., agents received cellular location

information for the telephone 6 used by EUBANKS and determined that he was in

the area of 60 Iliad Drive, Tinley Park, Illinois. At approximately 6:14 p.m., agents

observed EUBANKS leaving the area of 60 Iliad Drive while driving a grey Dodge

5 Surveillance agents were unable to see the individual who placed the unknown
object in the MKS. Based on the prior observation of Sandoval-Velazco driving the Cobalt
with Mendoza as his passenger, agents believe that Mendoza was the male who placed the
object in the trunk of the MKS.
6 On April 9, 2010, Acting Chief Judge Wayne R. Anderson for the Northern District
of Illinois, authorized the use of Error! Main Document Only.a pen register and trap and
trace device, including a pen register device in the form of a digital analyzer, on the cellular
telephone believed to be used by EUBANKS.

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Charger. 7

g. At approximately 7:25 p.m., agents observed a white Ford pull

into the driveway of 60 Iliad Drive. At the same time, agents observed the garage

door of 60 Iliad Drive open. Agents then observed the same red Lincoln MKS

parked inside the garage.

E. Mendoza Delivers an Additional 5 Kilograms of Cocaine to EUBANKS

and Receives Payment from EUBANKS for Prior Delivery of Fronted
Cocaine

17. On April 13, 2010, at approximately 11:56 a.m., Mendoza placed an

outgoing call (call #5022) on Target Phone 1 to INDIVIDUAL A. During the

conversation, INDIVIDUAL A told Mendoza to take 5 kilograms of cocaine to

EUBANKS, a narcotics customer of the organization. Specifically, INDIVIDUAL A

stated: “Did you call him?” Mendoza responded: “It rings as if it were out of area.”

INDIVIDUAL A stated: “Alright, how long will it take you to get to Bon

[EUBANKS]?” Mendoza responded: “About an hour.” INDIVIDUAL A stated:

“Alright, take him a ‘hand’ and he is going to give you a receipt.” [INDIVIDUAL A

told Mendoza to take EUBANKS 5 kilograms of cocaine (a “hand”) and that

Mendoza should pick up cash from EUBANKS for a previous drug delivery.]

Mendoza responded, “Alright, I’ll take Bon [EUBANKS] another hand. What is

CUSTOMER 2 telling you? He’s not going to take responsibility for it?” [Mendoza

asked INDIVIDUAL A what CUSTOMER 2 was going to do about the previous

evening when officers seized 3 kilograms of heroin and 8 kilograms of cocaine from

7 Agents were unable to observe the license plate on the grey Dodge Charger.

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CUSTOMER 2’s worker, Corey Scott.] 8 INDIVIDUAL A responded: “I told him

we’re going to check and if it’s true what you said and the police got him, I need the

report so I could show it over here...to see if they could give me a discount. They’re

still not going to give me a break though, I need to pay.” Mendoza stated: “What

does he say?” INDIVIDUAL A responded: “That they’re going to have to get lawyers

involved and shit. We’re going to have to spend money. I told him, ‘Yeah but it’s

more money over here.’” Mendoza stated: “Too bad, why did he send his guy? He

needs to take responsibility.” INDIVIDUAL A stated: “He hasn’t answered me.”

Mendoza responded: “Alright, I told Walas [Sandoval-Velazco] we should take a ride

later by the restaurant where we’ve seen the guy before. If we see him there, I don’t

know...follow him or something, right?” INDIVIDUAL A responded: “Hopefully,

hopefully...let me call Bon [EUBANKS] and tell him in one hour.” Mendoza stated,

“Alright, it’s set.”

18. At approximately 12:07 p.m., Mendoza placed an outgoing call on

Target Phone 1 (Call #5023) to Sandoval-Velazco, who was using Target Phone 8.

During the call, Mendoza informed Sandoval-Velazco that he was going to meet

EUBANKS. Specifically, Mendoza stated: “I’m going to see Bon [EUBANKS], man.”

Sandoval-Velazco stated: “What time?” Mendoza stated: “He doesn’t want me to

meet him anymore.” Sandoval-Velazco stated: “You’re going to meet him on the

8 As described in greater detail in the amended complaint, on April 12, 2010, law
enforcement officers seized from Corey Scott eight kilograms of cocaine and three kilograms
of heroin that were contained in a brown paper bag after observing Mendoza and Sandoval-
Velazco deliver a brown paper bag to Scott. For a complete description, see paragraphs 23
through 25 of the amended complaint.

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street, right?” Mendoza stated: “Yeah.” Sandoval-Velazco stated: “I’ll go help you

right now.” Mendoza stated: “Thank you.” Sandoval-Velazco then asked, “Has

[INDIVIDUAL A] told you anything else?” Mendoza stated; “No, man.”

19. At approximately 1:00 p.m., based upon the calls summarized above,

agents set up surveillance in the area of Edgewater Walk Apartment Complex,

located at 16703 Lakewood Drive, Tinley Park, Illinois, and 60 Iliad Drive, Tinley

Park, Illinois. Based on prior surveillance, agents had identified both locations as

being used by EUBANKS for money and narcotics pick-ups and as stash houses.

During surveillance that afternoon, agents observed the following:

a. At approximately 1:44 p.m., surveillance agents observed the Cobalt,

driven by Mendoza, drive to the rear of the apartment complex located at 16703

Lakewood Drive. Agents then observed the Cobalt drive back and forth from the

parking lot, to the front of the apartment complex, and back to the parking lot. At

approximately 1:49 p.m., agents observed the Cobalt park near 167th street.

b. On April 13, 2010, at approximately 1:49 p.m., Mendoza received an

incoming call (Call #5046) on Target Phone 1 from INDIVIDUAL A. During that

conversation, Mendoza informed INDIVIDUAL A that he was waiting for

EUBANKS. Specifically, Mendoza stated: “I circled around and he’s not there.”

INDIVIDUAL A stated: “Let me call him. Either way, go to the back.”

c. On April 13, 2010, at approximately 1:50 p.m., Mendoza received an

incoming call (Call #5047) on Target Phone 1 from Sandoval-Velazco, using Target

Phone 8. During the call, Mendoza informed Sandoval-Velazco that he was waiting

16
for EUBANKS. Specifically, Sandoval-Velazco asked: “Where are you?” Mendoza

stated: “Waiting for Bonifacio [EUBANKS].” Sandoval-Velazco then asked: “You

haven’t seen him yet?” Mendoza stated: “Hold on, [INDIVIDUAL A] is going to call

me. I’ll call you back.”

d. At approximately 1:56 p.m., surveillance agents observed a

small red sedan and a silver/light blue Cadillac Escalade, with Illinois registration

H897286, registered to ASKIA-JAMES EUBANKS, 643 Saratoga Drive, Chicago

Heights, Illinois (the “Escalade”), leave the residence at 60 Iliad Drive in Tinley

Park.

e. At approximately 2:14 p.m., surveillance agents observed

EUBANKS sitting in the front driver seat of the Escalade at 60 Iliad Drive.

Surveillance agents observed the front door to the Escalade open and saw

EUBANKS sitting with a blue shopping bag on his lap.

20. On April 13, 2010, at approximately 2:22 p.m., Mendoza placed an

outgoing call (Call #5084) on Target Phone 1 to Sandoval-Velazco. During the call,

Mendoza told Sandoval-Velazco that he was on his way back from meeting

EUBANKS. Specifically, Mendoza stated: “I’m on my way back.” Sandoval-Velazco

stated: “The guy [EUBANKS] took a long time, right?” Mendoza stated: “Yeah, he’s

always on some bullshit.” Sandoval-Velazco stated: “[unintelligible] . . . half?”

Mendoza stated: “More or less.” Sandoval-Velazco stated: “I’m heading to the

office.” Mendoza stated: “Alright then.” Sandoval-Velazco stated: “You haven’t

heard anything from [Customer 2’s] guy? Mendoza stated: “No, we haven’t heard

17
anything yet.”

21. At approximately 2:25 p.m., surveillance agents observed the Escalade,

parked in front of the residence at 60 Iliad Drive.

22. On April 13, 2010, at approximately 6:22 p.m., Mendoza received an

incoming call (Call #5142) on Target Phone 1 from INDIVIDUAL A. During the

call, Mendoza informed INDIVIDUAL A that he had received a payment of more

than $200,000 from EUBANKS for the fronted cocaine. Specifically, Mendoza

stated: “We checked BONIFACIO’s [EUBANKS] already.” INDIVIDUAL A stated:

“All right. How much did he give you?” Mendoza stated: “He gave me two bags. It

was 46. But, in that one, it was 50 with 450 in it.” INDIVIDUAL A stated, “All

right. You mean, that he said he had taken 46 and there was actually 50?”

Mendoza stated: “Well, it was on a little paper there. In one, we counted a hundred

fifty-four [154], and in the other one. . . the ones I’m telling you . . . It was fifty [50]

four [4], fifty [50].” Individual A stated, “I think that is correct. Either way, I’ll call

you when I get to the house right now so we can write it down. What’s the total?

Two hundred [200]? What?” Mendoza stated: “Hold on.”

23. On April 13, 2010, at approximately 6:23 p.m., Mendoza placed an

outgoing call (#5143) on Target Phone 1 to INDIVIDUAL A. During the call,

Mendoza informed INDIVIDUAL A that he had $205,450 in U.S. Currency, which

INDIVIDUAL A directed Mendoza to give to Adolfo, aka “Flaco.” Specifically,

Mendoza stated: “I come up with two hundred [200], five [5], four [4], fifty [50].”

INDIVIDUAL A stated: “Yeah.” Mendoza stated: “All right. Let me know what to

18
do with that. Should I give them to Flaco [Adolfo] or see if he answers me right

now?” INDIVIDUAL A stated: “He hasn’t answered you yet?” Mendoza stated: “No.

He has it off. I’m going to call him right now.” INDIVIDUAL A stated: “All right.

Call the guy.” Mendoza stated: “All right. Am I going to give him a ‘ticket’ from

here or what? So I can tell him?” INDIVIDUAL A stated; “Yes, I’ll tell you right

now how much. Just call him and tell him that. And tell him that I’ll call him right

now.” Mendoza stated: “All right.”

F. Mendoza Delivers Cobalt to Adolfo and Gonzalo Lopez-Garcia

Following Calls Concerning Payment for the Previously Fronted
Cocaine on April 14, 2010 in the Amount of $205,000

24. On April 13, 2010, at approximately 6:30 p.m., Mendoza, using Target

Phone 1, placed an outgoing call (Call #5144) to Adolfo, who was using Target

Phone 8. During that conversation, Mendoza told Adolfo that he, Mendoza, wanted

to pay Adolfo U.S. Currency. Specifically, Mendoza stated: “Hey, can I see you

later?” Adolfo stated: “Uh, what’s up?” Mendoza stated: “I wanted to give you a

‘ticket.’” [Mendoza told Adolfo that he wanted to deliver U.S. Currency as payment

for a prior delivery of cocaine.] Adolfo asked, “Like at what time?” Mendoza stated:

“Well, I’m just waiting for [Individual A] to arrive there to Uruapan so he can tell

me how much I’m going to give you in a little while.” Adolfo said, “All right. I’ll call

you later. Don’t come without calling me.” Mendoza said, “All right. I’ll call you in

a little bit and see what’s up.”

25. On April 13, 2010, at approximately 6:51 p.m., Adolfo, using Target

Phone 8, placed an outgoing call (Call #5148) to Mendoza, who was using Target

19
Phone 1. During that conversation, Adolfo informed Mendoza that he had spoken

with his source of supply and that he had informed his source that Mendoza had

payment for a prior delivery of cocaine for him. Specifically, Adolfo stated: “I called

the ‘office’ right now and I told him that you had a ‘check’ for me, and they told me

for you to get together the most that you can and bring it, and that way, if you want,

you could leave us ‘Mueble’ [vehicle] so that you can take it to ‘work’ tomorrow. But,

I need you to get together the most you can.” [Adolfo told Mendoza to get together

as much money as possible for payment for the prior delivery of cocaine and that

Mendoza could put the money in a ‘Mueble’ [vehicle] so that cocaine could later be

placed in the same vehicle.] Mendoza stated: “Yeah, that’s fine. What was I going

to tell you? Listen, yesterday I gave eight (8) to a guy and he’s not answering

[Individual A], man. [Individual A] told me he was going to call you right now so

you won’t be worried.” [Mendoza told Adolfo that he had delivered eight kilograms

of cocaine to Customer 2, who was no longer answering his phone.] Adolfo said,

“What do you mean? I didn’t understand you?” Mendoza stated: “What’s happening

is that I took some to a ‘morenito’ [black guy] yesterday. But, he says that his guy is

not answering him. [Individual A] told me right now to tell you that he’s going to

call you right now to talk to you. See if this fucker answers him.” Adolfo stated:

“No, let’s not start with mishaps.” Mendoza stated: “That’s what I told [Individual

A]. If not, we have to pay them, right? But he will call you so you can talk with

him.”

26. On April 13, 2010, at approximately 6:52 p.m., Mendoza placed an

20
outgoing call (Call #5151) from Target Phone 1 to Individual A. During the

conversation, Mendoza told Individual A that he had told Adolfo that he had money

in payment for kilograms of cocaine and that Mendoza had told him to bring the

money in a vehicle so that Adolfo could also provide Mendoza with more kilograms

of cocaine. Specifically, Mendoza stated: “I already told Flaco [Adolfo] before I told

him I had a ‘ticket’ and then he said for me to get together the most that I could and

that maybe by tomorrow I could let him borrow the ‘mueble’ [vehicle] so he could

lend us more. But then I told him that eight of them are . . . , well, that this guy

doesn’t answer you and that we can’t find the guy. And he says, “Oh man, let’s not

start with that. Because if we start with that, we are going to stop.” Individual A

stated: “Uh-huh. Yeah. No, well, we’ll see what happens later. This guy still hasn’t

answered me. Well, just tell him the truth. That’s the only way we can advance

more quickly. Because if we stop just like that, it’ll be harder to pay them. Either

way, we pay over here. But, who knows if they will want to.” Mendoza stated:

“Yeah. Call that damned [Customer 2] and hopefully the fucker answers. Why

don’t you have someone call him from over here in English and see if he answers or

not?” Individual A stated: “He doesn’t answer anymore, man. The guy from

Atlanta called me and told me that he had changed numbers because the number he

would call me on, that was the number he called the guy on and that he is really

scared. That because the car was under [Customer 2’s] name and that he is really

scared. That [Customer 2] doesn’t know what to do. So, I told my buddy, ‘Well, tell

me what his name is so I can investigate’ and about the plates, too.” Mendoza

21
stated: “No, well I have the plates. Once he gives you the name, we can investigate

to see if it’s true. Individual A stated: “Yeah, I’m going to call the guy again now so

he can tell me what his name is.” Mendoza stated: “All right. All right. Well, see if

you could call Flaco [Adolfo] later and see what he tells you.” Individual A stated:

“All right. I’m going to call him and I’m going to tell him and see what he says.”

Mendoza stated: “All right. Right now, I’m going to tell Walas [Sandoval-Velazco]

that we go to the fucking restaurant to see if we see him. Hopefully, we see him and

see where he goes.” Individual A stated: “Yeah, that’s fine. And he didn’t tell you

anything about the payment? That if you should take it to him today or tomorrow?”

Mendoza stated: “No. He told me he talked to the ones at the ‘office’ and he said to

get together the most for tomorrow in other words, for tomorrow. This way

tomorrow, you can leave me the ‘mueble’ [vehicle] and I can lend you more. And

then I told him that and that’s when he said he didn’t want us to fail him. He said,

“There’s going to be a lot of work and hopefully this is not a reason to stop.”

[Mendoza informed Individual A that Adolfo had instructed Mendoza to get together

money for the following day as payment for an earlier delivery of cocaine and to

leave the vehicle with Adolfo so that Adolfo could provide additional kilograms of

cocaine to Mendoza.] Individual A stated: “Yeah. No. Well, we’ll see what happens,

right? We have to wait.” Mendoza stated, “Yeah, hopefully, that fucker answers.

Well, we’ll see if Flaco [Adolfo] calls me back or maybe tomorrow. I don’t know. I

told him I had a payment. I’m going to wait and see what he tells me.” Individual A

stated; “All right. All set.”

22
 27. On April 13, 2010, at approximately 8:48 p.m., Adolfo placed an

outgoing call (Call #5195) using Target Phone 8 to Mendoza, who was using Target

Phone 1. During the call, Mendoza agreed to meet Adolfo by McDonald’s at

approximately 7:00 a.m. the next morning to make the payment. Specifically,

Adolfo stated, “I think if you are going to have something, let’s do it early tomorrow

morning.” Mendoza stated, “That’s fine. You tell me what time.” Adolfo stated:

“Try to be over there, by the ‘M’ at 7:00.” Mendoza stated: “That’s fine. You see

that I will go by myself. So then I’ll see you by the ‘M’ at 7:00.” Adolfo stated:

“That’s fine. We will meet there, God willing.” Mendoza stated: “All right. Thanks.

Take care.”

28. On April 13, 2010, at approximately 8:58 p.m., Adolfo placed an

outgoing call (Call #5198) using Target Phone 8 to Mendoza, who was using Target

Phone 1. During the call, Mendoza estimated to Adolfo that he was bringing

$150,000 the next day as payment for the prior delivery of cocaine. Specifically,

Adolfo stated: “What number is the ‘ticket’ you are bringing?” Mendoza stated:

“Look, I’m not sure yet, but it’s going to be like a hundred fifty (150) dollars, I

think.” [Mendoza was bringing $150,000.] Adolfo stated: “All right. I’ll wait for you

here then.” Mendoza stated: “Alright.”

29. On April 13, 2010, at approximately 9:37 p.m., Mendoza received an

incoming call (Call #5207) on Target Phone 1 from Individual A. During the call,

Mendoza and Individual A discussed the amount of money owed to Adolfo and

payment of $205,000 to Adolfo the next day. Specifically, Individual A stated: “915.”

23
Mendoza stated: “Yeah, that’s what I have, 18,915.” Individual A stated: “All right.

I still own 50,000 pesos for the contribution that was made over here. No fucking

[Customer 2], man. He doesn’t answer me.” Mendoza stated: “Well, hopefully, he

regrets it, or if his guy left . . . .He should know where his guy is or his relatives or

something.” Individual A stated: “The guy who hooked me up with him told me that

he was really scared because that car is in his name [Customer 2’s name]. That’s

why he is really scared. So that’s why I don’t know if it’s true. You know what I

mean? I don’t know. I had a good conversation with [Individual F], the person who

hooked me up with him, and he said, ‘You know that’s how things happen

sometimes.’ I said, ‘I know it can, but what I want is for him to answer me, move

forward and make the report, and if it’s true, well, maybe they will forgive me for

something over here. But either way, we have to report something.” Mendoza

stated: “For sure. Hopefully, this guy talks to him and he calls you. If he hides,

then he’s guilty.” Individual A stated: “For sure. If he doesn’t want to use the

phone, then just get rid of them and get a new one within that time.” Mendoza

stated: “Hopefully, he finds the guy because he should know where he lives. Don’t

you think one knows what happens over there in Uruapan? Any guy could give you

answers.” Individual A stated: “Yeah. Let me write down [Customer 1’s] payment

because I hadn’t counted it. He’s given 13 pesos, right?” [Individual A asked if

Customer 1 had paid $13,000.] Mendoza stated: “Yeah, 13 pesos.” Individual A

stated: “The last payment that I have written down from him was 51. So then after

the 51 is the one for 13 pesos, right?” Mendoza stated, “Um, where did I leave the

24
sheet? I’ll look for it right now. It’s because I rip everything now. I’ll check right

now.” [Mendoza informed Individual A that he would look on his drug ledger to

determine what payments Customer 1 had made.] Individual A stated: “Alright.”

Mendoza stated: “The last time was 51 . . .because he had given me . . .I’ll remember

right now and will let you know.” Individual A stated: “Alright.” Mendoza stated:

“Yeah, you just have that now and what Bon [EUBANKS] gave right now. How

much am I going to give Flaco [Adolfo] because he already called me. He set up the

meeting for tomorrow at 7:00.” Individual A stated: “Yeah, just leave . . . .Take out

54 to give the other guy for the other “food” and take him the rest.” Mendoza

stated: “Alright. So then, take out 54 . . . .I told you there was a bag that said 46. It

turned out to be 50 with 450. I told you, no?” INDIVIDUAL A stated: “Yeah, what

he was missing was 50 bucks, so then it’s right. Look, take him all of it because

[Customer 3] told me he was going to give another payment tomorrow. So then

we’ll give the other payment to the other guy. Take him all of it. Just complete

205. Leave the 450 out.” [INDIVIDUAL A instructed Mendoza to bring $205,000 to

Adolfo.] Mendoza stated: “Alright. I’m going to take him 205, right?” INDIVIDUAL

A stated: “Well, give him the 205 even.” Mendoza stated: “Alright, so I could call

him right now and tell him I will meet him at 7:00.” INDIVIDUAL A stated:

“Alright. Call him and tell him tomorrow. Tell him you might give him another

payment, but until later on, tell him you don’t know exactly how much. Hopefully,

this guy [U/I]. I’m going to have a good talk with him and tell him.”

30. On April 14, 2010, at approximately 6:45 a.m., based upon the calls

25
summarized above, agents set up surveillance in the area of the McDonald’s, located

at 8800 West Grand, River Grove, Illinois, and at 9132 West Grand Avenue,

Franklin Park, Illinois. During surveillance that morning, agents observed Adolfo

and Gonzalo Lopez-Garcia (hereinafter “Gonzalo”) collect proceeds from Mendoza

and take them to the 9132 West Grand Avenue location. 9

III. SITE FOR SEARCH

31. As set forth in this affidavit, it is believed the facts establish probable

cause that the records, documents, and items constitute fruits, instrumentalities

and/or evidence of violations of Title 21, United States Code, Section 846, and

further that a search of 60 Iliad Drive, Tinley Park, Illinois and its garage will

result in the discovery of such records, documents, and items.

32. As a result of my law enforcement experience and this investigation, I

am familiar with the ways in which the members of the narcotics and money

laundering organization conduct their business, including, but not limited to, their

methods of importing and distributing cocaine, their use of numerical codes and

code words to conduct their transactions in secret, and their methods of laundering

the proceeds of their narcotics trafficking. Through my experience and my

discussions with other experienced law enforcement officers, I am familiar with the

methods, schemes, and operations used by major heroin traffickers and know:

9 For a complete description of what agents observed, see paragraphs 18(a) through (j)
of the amended complaint.

26
 a. It is common practice for drug traffickers, including persons

trafficking in cocaine, to conceal in their residences and/or places of business, secure

places to store the contraband, including but not limited to safes, and that once a

sizeable load of contraband has been delivered, to repackage and break-down larger

quantities of illegal drugs into smaller more easily handled and concealed

quantities for distribution; and that paraphernalia related to the packaging,

cutting, weighing and distribution of contraband is usually secreted or stored in

their residences and/or places of business.

b. Drug traffickers, including persons trafficking in substances

such as cocaine, maintain books, records, receipts, notes, ledgers, airline tickets,

money orders, and other papers relating to the purchase, packaging, sale,

distribution, and transportation of their product.

c. Drug traffickers, including persons trafficking in substances

such as cocaine, commonly maintain books, papers, and cellular telephones which

reflect the names, addresses and/or telephone numbers of their suppliers, couriers,

customers, and other associates in the illegal drug trade.

d. Drug traffickers, including persons trafficking in substances

such as cocaine, conceal in their residences and/or places of business the proceeds of

their illegal activity, including large amounts of United States currency, financial

instruments, precious metals, jewelry, rare coins, works of art, and other items of

value, as well as books and records regarding the acquisition, use, and disposition of

such items of value.

27
 e. When drug traffickers, including persons trafficking in

substances such as cocaine, amass large proceeds from the sale of controlled

substances, they attempt to legitimize these profits through money laundering

activities, often accomplishing this goal by using the services of banks, securities

brokers, professionals such as attorneys and accountants, casinos, real estate

brokers and other financial professionals, shell corporations and business fronts,

and otherwise legitimate businesses which generate large quantities of currency.

f. It is common for drug traffickers, including persons trafficking

in substances such as cocaine, to maintain the aforementioned books, papers, and

documents in secure places within their residences and/or places of business so that

the drug traffickers have ready access to such information.

g. Drug traffickers, including persons trafficking in substances

such as cocaine, often places assets, including real and personal property, such as

vehicles, in names other than their own to avoid the detection and forfeiture of such

assets by government agencies; and that the drug traffickers continue to use these

assets and to exercise dominion and control over them even though the assets are

nominally owned by others.

h. Drug traffickers, including persons trafficking in substances

such as cocaine, frequently possess firearms and ammunition to protect their illegal

product.

i. Drug traffickers frequently take, or cause to be taken,

photographs of themselves, their associates in the drug trade, property acquired

28
from the distribution of drugs, and their product, and such photographs are often

kept in their residences and/or places of business.

j. In addition, during the course of residential searches, I and

other agents have also found items of personal property that tend to identify the

person or persons in residence, occupancy, control, or ownership of the subject

premises, including such items as canceled mail, deeds, leases, rental agreements,

photographs, personal telephone books, diaries, utility and telephone bills, or other

mail, statements, identification documents and keys.

33. For the foregoing reasons, and for the reasons set forth below in the

discussion of probable cause to search 60 Iliad Drive, Tinley Park, Illinois and its

garage, there is probable cause to believe that 60 Iliad Drive, Tinley Park, Illinois

and its attached garage will contain the items requested to be seized as set forth

below in paragraph 37.

A. 60 Iliad Drive, Tinley Park, Illinois and Attached Garage

34. During this investigation, agents learned that 60 Iliad Drive, Tinley

Park, Illinois is one of the residences used by EUBANKS. Agents have observed

EUBANKS arriving at and leaving from this location approximately three times

since agents identified him as “Bonifacio” and “Bon.” Based on cellular telephone

location information, agents determined that EUBANKS was at that location as

recently as April 16, 2010. According to information received from Nicor Gas,

utilities for 60 Iliad Drive, Tinley Park, Illinois are billed to ASKIA EUBANKS, 60

Iliad Drive, Tinley Park, Illinois. 60 Iliad Drive, Tinley Park, Illinois, consists of a

29
single family residence with brown brick and vinyl siding. The numerals “60” are

affixed to the right of the garage door on the front of the residence. The residence

faces south on Iliad Drive with a garage door to the right of the main door entrance.

This residence is attached to another residence to the west of 60 Iliad Drive.

35. Additionally, as discussed above in greater detail, on February 23,

2010, Mendoza delivered 15 kilograms of cocaine to EUBANKS at 60 Iliad Drive in

Tinley Park, Illinois. As discussed above, agents observed Mendoza’s Cobalt drive

into the attached garage at 60 Iliad Drive. While the Cobalt was inside the garage,

at approximately 10:49 a.m., Mendoza placed an outgoing call (Call #455) on Target

Phone 2 to INDIVIDUAL A. During the call, Mendoza informed INDIVIDUAL A

that they were at EUBANKS’ house. INDIVIDUAL A instructed Mendoza to leave

15 kilograms of cocaine with EUBANKS.

36. As also discussed above in greater detail, on April 12, 2010, agents

observed Sandoval-Velazco and Mendoza deliver 10 kilograms of cocaine to

EUBANKS, who was driving a red Lincoln MKS, in a parking lot. As discussed

above, agents subsequently observed the same red Lincoln MKS parked in the

garage at 60 Iliad Drive, Tinley Park, Illinois.

B. Items Requested to be Seized at 60 Iliad Drive, Tinley Park, Illinois

and its Attached Garage

37. Based on the foregoing it appears that there is probable cause to seize

from the foregoing locations the following items:

a. Paraphernalia for packaging, processing, diluting, weighing, and

30
distributing controlled substances, such as scales, funnels, sifters, grinders, glass

panes and mirrors, razor blades, plastic bags, heat-sealing devices, and dilutants;

and paraphernalia for packaging cash drug proceeds including heat sealing devices,

plastic packaging for cash, rubber bands, and money-counting devices;

b. Personal books and papers reflecting names, addresses,

telephone numbers, and other contact or identification data relating to distribution

of controlled substances;

c. Books, records, receipts, notes, ledgers, airline tickets, money

orders, wire transfer or money remittance records, and other records related to the

receipt, expenditure and concealment or other disposition of income;

d. Cash, currency, financial instruments, and records relating to

controlled substances income and expenditures of proceeds of drug transactions,

and evidence of financial transactions relating to obtaining, transferring, secreting,

or spending of large sums of money made from engaging, in drug trafficking

activities;

e. Pagers, cellular phones, electronic organizers, caller

identification, answering machine tapes, and other communication devices and the

contents thereof, including names, addresses, telephone numbers and other contact

or identification information of participants in drug trafficking activities;

f. Photographs of individuals, associates, their property and their

drugs;

g. Records reflecting names, nicknames, addresses, and telephone

31
numbers of both current and past drug associates;

h. Safes, safety-deposit boxes, keys for safety-deposit boxes, hidden

compartments and other secure locations, which often contain the proceeds of

narcotics-trafficking activity, including large amounts of United States currency,

financial instruments, precious metals, jewelry, and other items of value, as well as

books and records regarding the acquisition, use, and disposition of such items of

value;

i. Canceled mail, deeds, leases, rental agreements, photographs,

personal telephone books, diaries, utility and telephone bills, statements,

identification documents and keys; and,

j. Documents related to rental, lease, or ownership of the search

sites identified herein.

32
IV. CONCLUSION

WHEREFORE, I submit that there is probable cause to support a complaint

charging: ASKIA EUBANKS, aka “Bonifacio,” and “Bon,” with conspiring with

others known and unknown to the United States to knowingly and intentionally

possess with intent to distribute and to distribute controlled substances, namely,

five kilograms or more of mixtures and substances containing a detectable amount

of cocaine, a Schedule II Narcotic Drug Controlled Substance, in violation of Title

21, United States Code, Section 841(a)(1), all in violation of Title 21, United States

Code, Section 846. FURTHER, I submit that there is probable cause to support the

search of 60 Iliad Drive, Tinley Park, Illinois and its attached garage.

_______________________________
Keyur Patel
Special Agent
Drug Enforcement Administration

SUBSCRIBED and SWORN before me on May 4, 2010.

_________________________________________
HONORABLE MICHAEL T. MASON
Magistrate Judge, United States District Court
Northern District of Illinois

33