Federal Search Warrant Affidavit For Biker Gang

Case 1:20-mr-00556-KBM Document 1 Filed 04/07/20 Page 1 of 61
AO I 06 (Rev. 04/10) Application for a Search Warrant

?ro*n&ED
i8rr
UNrrBn Srarss Drsrrucr Counr AP|. 7 zozo
-v
forthe .r ,* A/llTCHf,
District of New Mexico *i, .
. iilf,;a,FE&S
In the Marter of rhe search of l -?O -ffik-56
lq
be.sea.tched
bi;;i,,;;;i;;iA;;;;) i) Case No. {O - fflk '55 7
(Brie/ly cl.e;cribe the property to
';r'id;,i6 th; p;;;,;
The 3 persons and 3 Residences identified in )) 30- fflk- 55I
Attachments A-1 through A-3
(attached hereto) )
APPLICATION FOR A SEARCH WARRANT
-
I,-6 federal law enforcement officer or an attorney for the government, request a search wan'ant and state under
penalty of perjury that I have l€ason to believe that on thd following person or prdperty (identify the person or deslibe the
properly to be searched and give ils localion):
See Attachments A-1, A-2 and A-3
located in the District of New Mexico , there is now concealed 1dentif), tlte
person or desct'ibe the property lo be seized)',
See Attachment B
The basis for the search under Fed. R, Crim. P. 4l (c) is (eheck one or more)i
d evidence of a crime;
d.ontruburd, fruits of crime, or other items illegally possessed;
d property designed for use, intended for use, or used in committing a crime;
O a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
ritre 69d:3ffS$'tbozt"l, 1e5e(a), Rrco Act, vrcAR; Hobbs Act, uio&{€t3f&n{j1g65P68di, arnori use firearm in rurrherance of
1951, 931, 92aG),922(9),922tJ), violent crime or drug trafficking; felon possess firearm/ammoi possess stolen flrearm;
922(n),875,371, 2, and Title 21 indicted porson possess firearm/ammo; ihreatening communications; conspiracy; aid and
U.S.C. SS 846 and 8a1(a)(1), abet; conspiracy and possession with intent to distribute a controlled subslance.
^'
tG ipptiidtidn is based on these facts:
Refer to the attached 51-page Affidavit in Support of an Application for Search Warrants by FBI SA Bryan M. Acee.
d Continued on the attached sheet.

D Delayed notice of _
days (give exact ending date if more than 30 days: ) is requested
under l8 U.S.C. $ 3103a, the basis of which is set forth on the attached sheet.
Bryan Acee, FBI SpecialAgent

Prinled name and title
Electronicallv submitted and sworn before me.

M^^-e/q-|-
Date: _ Aprlli ?_Q?O_
Judge's signalure
City and sals; AlbuQuerque, New Mexico Karen B. M_o,lgen, 9!it{stgl". rvlug irtFte 4ggg
Prinled name and title
AFFTDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS
Table of Contents
INTRODUCTION 2
RELEVANT TRAIMNG AND EXPERIENCE 4
OVERVIEW OF THE INVESTIGATION 6
BACKGROIIND ALLEGATIONS REGARDING GANGS AND DRUG TRAFFICKERS 9
THE MONGOLS MC CRIMINAL ENTERPRISE 12
THE HISTORY OF THE MONGOLS MC t4

MONGOLS MC PATCHES AND INSIGNIA 19
PURPOSES OF THE ENTERPRISE 2A
MEANS AND METHODS OF THE ENTERPRISE 20
PUBLIC CORRUPTION: OUTLAW MOTORCYCLE GANGS AND LAW ENFORCEMENT 2l

THE CONFIDENTIAL HUMAN SOURCES 22
STATEMENT OF PROBABLE CAUSE 26
Coaspiracy to Commit Assault in Aid of Racketeering 27
Theft of Motorcycle Vests and Patches 29
Unlawful Firearms Possession and Use of Firearms in Furtherance of Violent Crime 30
Possession of Body Armor by a Violent Felon 34
Conspiracy to Distribute Controlled Substances 34
Evidence Sougtrt Pursuant to the Requested Search Warrants 36
THE TARGET SUBJECTS 37
THE SUBJECT PREMISES 4t

SEARCHING POR GANG TATTOOS 43
BIOMETRIC ACCESS TO DEVICES 45
MANNER IN WHICH THE SEARCH WARRANTS WILL BE SERVED 49
NIGHTIME SERVICE REQUEST 50
CONCLUSION 51
Page 1 of51
AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS
I, Bryan M. Acee, being duly sworn, do hereby depose and state as follows:
INTRODUCTION
1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and am recognized
as a "federal law enforcement officer" within the meaning of Rule 4l of the Federal Rules of
Criminal Procedure. I am submitting this affidavit in support of warrants to search the persons
and residences listed below:
a) CARLOS ALVARADO JR., aka: "CHUGGS," associated with Subject Premises
A-l: 1525 Larkin Road SW, Albuquerque, New Mexico;
b) WiLLIAM LEE WESTFALL, aka: *SHOTS," associated with Subject Premises
A-2: 3325 Montclaire Drive NE, Albuquetque, New Mexico; and
ooEK,"
c) ISAIAH MATTHEW CHAVEZ, aka: aka: "HARDON,'' associated with
Subject Premises A-3: 2844 John Street SE, Albuquerq:re, New Mexico.
Hereinafter I will refer to the aforementioned persons collectively as the "Target Subjects."
Based on the evidence obtained in this investigation, and as described herein, I believe there is
probable cause to believe the Subject Premises contain evidence fruits, and instrumentalities of
violations of
a) 18 U.S"C. $ 1962(c) Racketeer Inlluenced and Corupt Organizations (RICO);
b) 18 U.S.C. $ 1959(a) Violent Crimes in Aid of Racketeering (VICAR);
c) 18 U.S.C. $ 1951 Interference with commerce by threats or violence;
d) l8 U.S.C. $ 931 Possession of body arnor by a violent felon;
e) 18 U.S.C. $ 92a(c) Use of a firearm in furtherance of a crime of violence or drug
trafficking crime;
0- 18 U.S.C. $ 922(g) Prohibited person in possession of a firearm or ammunition;
Page 2 of51
AFFIDAVIT IN SUPPORT OF AN APPLICATION TOR SEARCH WARRANTS
g) 18 U.S.C. $ 922(i) Possession of a stolen firearm;
h) 18 U.S.C. g 922(n) Indicted person in possession of a firearm or ammunition;
i) 18 U.S.C. $ 875 Transmitting tlueatening communications;
j) 18 U.S.C. $ 371 Conspiracy;
k) l8 U.S.C. $2 Aiding and abetting;
l) 21 U.S.C. g 846 Conspiracy to distribute a controlled substance; and
m) 2l U.S.C. $ 8a1(aX1) Possession with intent to distribute a controlled substance.
Hereinafter I will refer to the aforementioned violations as the "Target Offenses."
2. The specific premises to be searched have been described in Attachments A-1 through A-
3, which have beea attached hereto and incorporated herein by reference and arc collectively
referred to as the "subject Premises." The particular evidence, fi'uits, and instrumentalities to be
seized by agents are set forth in Attachment B, which has been attached hereto and incorporated
herein.
3. This affidavit also seeks the Courl's permission to allow the law enforcement agents
executing the search warrants to search the bodies of the Target Subjects for tattoos evidencing
membership in or association with the MONGOLS MOTORCYCLE CLUB, and to photograph
those tattoos. I believe such tattoos may constitute a conspiratorial overt act and have utilized
such photographic evidence during gang-racketeering jury trials in the past.
4. I am submitting this affidavit based upon my experience and familiarity with the
investigation of the Target Subjects. This affrdavit does not set forth all of my knowledge or
summarize all of the fact-finding efforts in the overall investigation; rather, this affidavit sets
forth facts that support probable cause to search the requested locations and persons, as well as
relevant background information. During my investigation, I have developed information I
Page 3 of51
believe to be reliable from the following agencies and sources: information provided by the FBI,
Drug Enforcement Administration (DEA); Bureau of Alcohol, Tobacco, Firearms and
Explosives (ATF); United States Bureau of Prisons (BOP); United States Probation Office
(USPO); New Mexico Corrections Department (NMCD); New Mexico State Police (NMSP);
Albuquerque Police Department (APD); Bernalillo County Sheri{?s Office (BCSO); California
Highway Patrol (CHP); Califomia Department of Corrections and Rehabilitation (CDCR); Los
Angeles County Sheriffs Department (LASD); Los Angeles Police Department (LAPD); and
other law enforcement or corrections agencies; including oral and written reports perlaining to
physical surveillance; information provided by undercover agents and informants; information
provided by cooperating defendants and/or the defense attorneys representing those persons;
information derived from lawfully intercepted wire communications, to include telephone, text
aod email; and records from the FBI National Crime Information Center (NCIC), United States
District Couts, New Mexico Courts and the New Mexico Motor Vehicle Division.
5. Where I refer to conversalions herein, they are related in substance and, in-part, based on
conversations between fellow agents, task force oflicers, other law enforcement personnel, or
confidential human sources that assisted law enforcement. Any observations referenced herein
that I did not personally witness were relayed to me in oral and/or written reports by agents of
the FBI or other agencies. All figures, times, weights, and calculations herein arc approximate.
RELEVANT TRAINTNG AND EXPERIENCE
6. I have been a law enforcement offiser for 20 years, serving as a poiice offtcer, detective,
task force officer and Special Agent. I have been with the FBI since 2009 aad am currently
Page 4 of51
assigned to the Albuquerque Violent Crime Task Force (VCTF),I where I primarily investigate
violent repeat offenders and federal drug and firearm related crimes. Prior to my assignment to
the VCTF, I served on the FBI Safe Streets Gang Task Force in Albuquerque, New Mexico, and
the FBI-DEA Hybrid Cross Border Drug Violence Squad in Las Cruces, New Mexico. I was the
lead case agent in the government's 2010-2014 Continuing Criminal Enterprise Drug Kingpin
Act case against the Juarez Caftel, which resulted in extensive seizures of drugs, cuffency,
firearms, and the indictment of multiple cartel leaders
7. For the past five years, I have served as the lead case agent in the govemment's
zuCO/VICAR investigation into the illegal activities of the New Mexico Syndicate, more
commonly rcferred to as the "Syndicato de Nuevo Mexico" or "SNM." The investigation
remains active and has resulted in the closure of ten cold case homicides and the arrest of more
than 150 SNM members and associates.
8. Over the past 20-years, I have primarily worked investigations pertaining to gangs and
drug trafficking organizations (DTOs). I have interviewed hundreds of gang members and drug
traffickers about the various aspects of their criminal activities, I have developed and managed
numerous informants who have been members of gangs or DTOs and monitored dozens of
wiretaps and electronic surveillance recordings targeting gang members or drug distributors. I
have also worked in an undercover capacity to infiltrate such criminal organizations.
9. I have received hundreds of hours of formal training in the area of gang, drug, and
organized crime investigations from federal, state, and local law enforcement agencies. I've
participated in hundreds of investigations pertaining to drug distribution, money laundering,
I The Violent Crime Task Force is an FBl-sponsored task force comprised of investigators from
the FBI, NMSP, NMCD, APD and BCSO. The task force primarily focuses on Career Offenders
and persons suspected of violating the Armed Career Criminal Act (ACCA).
Page 5 of51
firearms trafficking, gangs and criminal enterprises. My investigative experience includes;
conducting surveillance; interviewing subjects, targets and witnesses; drafting and executing
search and arrest warrants; acting in an undercover capacity; supervising cooperating sources;
managing undercover agents; issuing subpoenas; analyzing phone records, financial rccords,
telephone tolls, and Title III and consensual wiretap investigations. Through my training and
experience, I am familiar with the methods used by individuals, DTOs, gilBs, and criminal
enterprises to distribute coatrolled substances. I am also familiar with how those individuals and
organirations hide the often substantial profits generated from their criminal activities.
10. I have qualified, in federal and state courts, as an expert witness on drug trafficking and
possession with intent to distribute. I have qualified in federal court as an expert witness on the
Juarez Cartel and am an FBI subject matter expert on the Juarez Cartel and SNM gang.
11. I have seryed as an adjunct professor; law enforcement instructor; and presenler on drug
and gang investigations at the California Highway Patrol, Los Angeles Police Department, New
Mexico State Police and Bernalillo County Sheriffs Office Academies; as well as at training
classes and seminars for the Organized Crime Drug Enforcement Task Force, lntemational
Outlaw Motorcycle Gang Investigator's Association, California Narcotic Officer's Association,
California Gang Investigator's Association, New Mexico Gaag Task Force, New Mexico State
University and University of New Mexico.
OVERVIEW OT THE INVESTIGATION
12, In February 2020, a detective with the BCSO Oang Recognition Intelligence Patrol
(GRIP) unit contacted me and requested assistance with the investigation of a potenlial "war"
between two rival motorcycle clubs in Albuquerque, New Mexico. BCSO intelligence
information indicated members of the MONGOLS MOTORCYCLE CLUB (hereinafter
Page 6 of5l
AFF]DAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS
'.MMC") were involved in an escalating conflict with the BANDIDOS MOTORCYCLE CLUB
(hereinafter *BMC") over the expansion of the MMC into New Mexico. By way of background,
the State of New Mexico has traditionally been dominated by the BMC. More specifically, law
enforcement investigators leamed members of the MMC were stockpiling firearms and
ammunilion, conducting surveillance on BMC members wi:h the intention of assaulting them,
and aggressively recruiting new MMC members.
13. Over the past year there have been several violent incidents between the MMC and BMC.
I believe more violent occurrences between the two gangs have occurred; however, were not
reported. A few of the recent incidents between the two organizatioas include:
a) In April 2019, in EI Paso, Texas, the president of the MMC El Paso chapter
assaulted a rival biker and caused great bodily harm to the victim.
b) In August 201,9, in Albuquerque, New Mexico, an MMC Southwest member
resisted arrest and assaulted a BCSO detective.
c) In September 2019, in Albuquerque, New Mexico, MMC members fi'om the
Southwest and Duke Ci6, chapters robbed a citiznn biker, at gunpoint, of his
leather vest and a pistol. The assailants also damaged the victim's motorcycle.
d) In January 2020, in downtown Albuquerque, New Mexico, several MMC and
BMC members got into a fight. A BMC prospective member shot and killed a
MMC prospective member during the brawl.
e) In February 2A2A, in Midland, Texas, BMC and MMC members got into a fight.
Four men were shot and one MMC member was killed.
Page 7 of5l
0 In March 2A2A, in Albuquerque, New Mexico, the MMC Duke City Chapter
Sergeant at Arms told other members of the MMC he had run a lone BMC
member offthe road and the BMC member subsequently died.
14. I am familiar with both motorcycle clubs and I believe they are similar in structure,
pulpose, and o'outlaw" ideology. The BMC and MMC have dozens of regional chapters around
the United States, as well as in several foreign countries. Both clubs have a large body of
members and a vast network of supporters, associates and recruits, Members of both
organizations are fiercely loyal to their respective clubs and to one another. The BMC and MMC
oomotorcycle I believe they may more accurately be

represeat themselves as clubs;" however,
described as outlaw motorcycle gangs (OMGs).2
15. I have spoken with members of both organizations and am aware both OMGs believe
themselves to be "at war" with the other. Bassd on my investigalion, I believe a select few BMC
and MMC members in New Mexico are instigating and fueling the conflict. Moreover, through
my conversations with members of both organizations, I believe the Target Subjects identified
herein have been the most aggressive proponents of violent conflict. Coupled with the fact those
2
The United States Department of Justice defines a gang as: (1) an association of tluee or more
individuals; (2) whose members collectively identi$ themselves by adopting a group identity
which they use to create an atmosphere of fear or intimidation frequently by employing one or'
more of the following: a common name, slogan, identifying sigrl symbol, tattoo or other physical
marking, style or color of clothing, hairstyle, hand sign or graffiti; (3) the association's purpose,
in part, is to engage in criminal activity and the association uses violence or intimidatioa to
fuither its criminal objectives; (4) its members engage in criminal activity, or acts of juvenile
delinquency that if committed by an adult would be crimes; (5) with the intent to enhance or
preserve the association's power, reputation, or ecoilomic resources; (6) the association may also
possess some of the following characteristics: (a) the members employ rules for joining and
operating within the association; (b) the members meet on a recurring basis; (c) the association
provides physical protection of its members from other criminals and gangs; (d) the association
seeks to exercise control over a particular location or region, or it may simply defend its
perceived interests against rivals; or (e) the association has an identifiable structure.
Source: https:/lwww.justice .gov/criminal-ocgs/gallery/outlaw-motorcycle-gangs-orngs
Page 8 of51
same Target Subjects are believed to be actively conducting reconnaissance on their rivals;
encouraging others to join them in assaulting and killing rivals; and in possession of firearms,
ammunition, and ballistic vests; I believe it imperative the requested search warrants be exscuted
to collect evidence and mitigate the threat, The facts and circumstances supporting my beliefs are
detailed herein.
16. The requested search wan'ants are based on three sets of criteria: (1) information from six
confidential human sources, all of whom are members or close associates of the MMC; (2)
information from law enforcement officers who have investigated the Target Subjects, and (3)
information derived from my knowledge about the MMC, and criminal enterprises in general.
17. I believe all six informants utilized in the present-day investigation to be reliable. I
recognize their cooperation with the FBI is a serious betrayal to the MMC, which could result in
their injury or death, should their identities be revealed.
BACKGROUND ALLEGATIONS REGARDING GANGS AND DRUG TRAFSICKERS
18. Based upon my training, experience, and participation in this investigation, as well as the
investigation of other gang/oiminal enterprises and DTOs, I am aware individuals engaged in
the type of uiminal conduct constituting the Target Offenses maintain documents, letters and
records relating to their illegal activities for long periods of time. This documentaly evidence is
usually secreted in their place of residence, or the residences of family members, friends or
associates, in their business locations, or in stash houses. This documentary evidence includes:
telephone numbers, address books, travel receipts, notes referencing aliases or coded names,
false identification, money order receipts, money orders, money remittance receipts, pre-paid
money cards such as, MoneyPak, Wal-Mart, Green Dot, or other debit cards, bulk U.S cutrency,
Page 9 of51
money collection logs, such as "tally" sheets, drug load sheets, shipping/mailing receipts,
detention facility inmate number lists or addresses for inmates or detention facilities.
19. I have leamed individuals engaged in the type of criminal conduct constituting the Target
Offenses maintain regular contact with one another. This contact does not terminate once an
individual is incarcerated. Members of gang/criminal enterprises routinely send and receive
letters from other members of the organization in which they discuss ongoing criminal activities
and request various forms of assistance, to ilclude financial help and/or witness intimidation or
elimination (as is the case in the instant investigation). Incarcerated members of gang/criminal
enterprises communicate via telephone calls, some of which are generated via third parlies. In
addition, incarcerated members often keep pholographs of themselves and other members of the
gang/criminal enterprise in order to impress or intimidate others.
20. I know that members and associates of gang/criminal entetprises and DTOs have access
to numerous cellular phones, often a1 the same time, in an effort to avoid 1aw enforcement
monitoring. I have observed gang members, who are involved in drug trafficking, routinely use
pre-paid phones requiring no subscriber information, or fictitious subscriber names, to advance
their unlawful activities. These cellular telephones oftea contain names and phone numbers of
other co-conspirators, text messages utilized to further their illicit activities, photographs and
videos of gang members, controlled substances, drug proceeds, or firearms. I have observed
incarcerated members of gang/criminal enterprises utilize non-gang members personal
identification number when making prison/jail telephone calls to mask their conversations and
decrease the likelihood institutional gang officers will monitor the call.
2L. In addition, I am also familiat with the use of text messaging, instant messaging, and
messaging applications, used by gang/criminal enterprises and DTOs to advance their unlawful
Page 10 of51
activities. Members of gang/criminal enterprises and DTOs often utilize the names of others to
mask their ownership of vehicles, real property, and utility services, in an effort to avoid
detection by law enforcement.
22. I have observed individuals involved in the distribution of controlled substances often
conceal evidence of their drug trafficking activities in their residences and businesses, or the
residences offriends or relatives, and in surrounding areas to which they have ready access, such
as garages, carports and outbuildings. They also conceal evidence in vehicles, including vehicles
outside oftheir residences, so that they have ready access to it and so that they can hide it from
law enforcement officers executing search warrants at their residences or businesses. I have also
observed individuals involved in drug tlafficking bury evidence underground il containers on
their property.
23. I believe members of gang/criminal enterprises and DTOs often maintain records of their
transactions in a manner similar to the record keeping procedures of legitimate businesses. Even
after the drugs are sold, documentary records often remain for long periods of lime, even yeals,
to memorialize past transactions, especially when debts remain open, I have located notes
documenting the status of accounts receivable and accounts payable, and the names and phone
numbers of sippliers, customers, and co-conspirators, and other associates who have assisted
drug traffickers in other ways, such as helping with the cleansing of otherwise "dirly" money. I
am aware such proceeds may be made to appear "clean" through a variety of means, including
investments into legitimate enterprises and structuring deposits of large amounts of U.S.
Currency into financial institutions in such a way so as to avoid the detection by law
enforcement, as well as reporting requirements of banking institutions. These records can be
maintained on paper, in the form of business and personal ledgers and diaries, calendars,
Page 11 of51
ATFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH V/ARRANTS
memoranda, pay-owe sheets, drug ledgers, IOUs, miscellaneous notes, money ordets, customer
lists, and phone address books, both in hard copy or electronic fotm.
24. I believe individuals involved in gang/criminal enterprises and DTOs possess items of
identification, including but not limited to, &iver's licenses, rent receipts, bills, and address
books. These items may be relevant to the identity of those involved in the criminal enteqprise,
the possessor of the items seized, and occupants of the premises searched.
25. I am aware that members of the MMC use and possess firearms and other weapons, such
as large knives, edged weapons, metal batVpipes, hammers and other weapons. These weapons
arc used and possessed by members of the gang to commit mutders, attempted murders, assaults,
robberies, to protect illicit drug supplies, to avoid arresl or escape from custody, to intimidate
rivals, victims, witnesses, and persons who have aggravated or disrespected the MMC. I know
that firearms are instrumentalities of the crime of violent crime in aid of racketeeting and drug
i'tools of the trade" for the MMC. I am aware members
tra{ficking, and that firearms are critical
and prospective members of the MMC are expected to possess and maintain weapons and
firearms.
26. It has been my experience that the items described above are ofte:r stored by members of
gang/criminal enterprises and DTOs on their person, in their businesses, residences and
sur:rounding garages, outbuildings, and yards, the residences of friends or relatives, and vehicles.
THE MMC CRIMINAL ENTERPRISE
27. The MMC is an outlaw motorcycle gang, whose primary purpose is the proliferation and
maintenance of the gang through criminal activity. Members of the MMC, to include the Target
Subjects, are believed to have violated federal statutes by engaging in criminal activities
including conspiracy to commit murder, assault with a deadly weapon, extortion, robbery, sale
Page 12 of51
and possession for sale of controlled substances, using firearms in connection with violent crimes
and drug trafficking, possession of stolen fitearms, and possession of fireatms by prohibited
persons.
28. The MMC is a highly organized criminal enterprise, with a defined multiJevel chain of
command. The MMC have established regional chapters around the world, with their
headquarlers being based in California. Each local chapter has a president, vice president,
secretary/treasuret and setgeant-at-arms. The gang has an estimated worldwide membership of
approximately 1,500 members.
29. Various federal and state jurisdictions around the country have prosecuted members of
the MMC in recent years.3 I am also aware the United States sought to seize the MMC trademark
insignia and patches after a federal jury found the MMC guilty of racketeering'a
3
Five media reports pertaining to the MMC have been listed below. The information contained
within the following reports should be incorporated herein,
a. Inside the world's deadliest biker gangs https://:rypost,com/2013/10130/i$ide-the:

world;:deadl iest-biker- gane sl
b. 54-Count Federal Indictment Charges 12 Members and Associates of Mongols

Motorcycle Gang with Racketeering Conspiracy and Three Others with Various Federal
Crimes Including Large Scale Drug Trafficking https://wwwjustice.gov,louabrlS4:qaln1[:
lbderal-indictment-charges- 1 2-members:arrd-a$oqiatcs:
c. Mongols biker gang found guilty of racketeering https://wvrw.lbqnews,com/news/us.

news/mon gols-biker- gang:found- guilty-racketeering-!94?796
d. Mongols MC El Paso chapter president accused in biker assault arrested in raid

https:/lwww.elppsotimes.com/storylnqws/crimel?019/04/29lmotgols-mc-el-paso-chapter-
president-charles-andsrson-anested-biksr-assault-charge/3 622 I 79002i
e. Police raid new headquarters of Mongols MC gang

https://www.stg"ff.co.nzlnarionAl/crime/1 19841534/shl -closed:while-police-eearch-
ganterbury-propefty
Page l3 of5l
30. I believe the MMC, including its leadership, membership, prospects, and associates,
constitutes an enterprise as defined in 18 U.S,C. $ 1959(bX2), that is, a group of individuals
associated in fact that engaged in, and the activities of which, affect interstate commerce. The
enterprise constitutes an ongoiag organization whose members and associates functioned as a
continuing unit for a common pu{pose of achieving the objectives of the enterprise.
THA HISTORY OF THE MMC
31. The MMC was established ia 1969 in East Los Angeles, California, and identifies ilself
as an outlaw motorcycle gang. The MMC has established chapters in at least twenty states
around the country, to include New Mexico, and twelve foreign countries. The MMC is
governed by its "Mother Chapter," which many MMC members simply refer to as 'omother."
The Mother Chapter is headquartered in Montebello, California, and exercises authority over all
MMC members and chapters around the world. MMC members pay monthly dueso or fees, to the
Mother Chapter, which are utilized to promote the MMC and pay the legal fees for any MMC
members arrested while conducting club business. The Mother Chapter reviews al1 MMC
membership applications and has the final say in MMC politics, disputes, by-laws or any other
organizational decisions. The MMC members within the Mother Chapter are comidered
"national officers" and are generally heid in a higher regard among MMC members. New
Mexico euuently has two chapters (Duke City and Southwest), which are managed by a national
officer in Nevada. New Mexico is expected to get its own national officer, as more chapters are
created around the state.
a
Federal Jury Orders Mongols Motorcycle Gang to Forfeit Logos https://wwwiustice.gov/usao-
cdoa/prl&dqral-jury -orders -mon gols-motorc.v cl e- gan g-for&il- lo gos
Federal jury mles government can seize Mongols motorcycle club's trademark
https://]qww,dailynews.con 2019/0lll 1/federal-iury:tules-government-can-seize-rq9ryols-
motorcvclg:cl ubs-ttademark/
Page 14 of51
AFFIDAVIT IN SUPPORT OF AN APPLICAT1ON FOR SEARCH WARRANTS
32. Each MMC regional chapter is led by a chapter president, vice president, sergeant at
armso and secretary/treasurer. The sergeanls at arms are considered the "enforcers" among the
club mernbers and are responsible for enforcing club rules and administering consequences when
rules are broken. The secretary/treasurers perform the record keeping functions of the
organization and take notes during weekly chapter meetings. I am aware members of the New
Mexico's Duke City and Southwest chapters have discussed firearms acquisition, the targeting of
BMC members for violent acts, and the identities of suspected infornants with ties to the MMC.
Officers, such as &e chapter president, typically maiatain these documents in a secure location,
such as their residences. Those records include chapter meeting minutes, the chapter's bank
accounting details, the collection and receipt of dues and fines, and forwarding of funds to the
national secretary/treasurer in Califomia. These documents, including minutes from of meetings
and financial records, often reflect criminal activity.
33. The MMC have a well-documented history of criminal activity, to include murder,
battery, assault with a deadly weapon, robbery, firearms trafficking, unlawful possession and/or
use of firearms, drug distribution, extortion, motorcycle theft, and hate crimes directed at
African-Americans who run afoul of the MMC. Members of the gang often intimidate witnesses,
victims, and the general public in an effort to cause fear and minimize persons reporting MMC
related crime to law enforcement. As such, many MMC members believe they can commit their
crimes with impunity because the MMC is a large and powerful organization, with members
around the world. MMC members, prospective members, and associates often use the reputation
of the MMC as a meats to threaten and intimidate victims and witnesses, and protect MMC
members from prosecution.
Page 15 of51
34. MMC members, like most outlaw motorcycles gangs, direct attacks at their rivals, as well
as members of the general public who might unwittingly come into contact with tho Mongols in
a way that might be deemed disrespectful to the organization. Such circumstances often occur
when members of the motoring public do not move out of the way of MMC motorcycle riders,
follow them too closely, or otherwise show contempt in the eyes of the MMC members.
35. MMC members refer to one another as 'obrothers' and describe the MMC as a
"brothelhood." Law enforcement officers, suspected informants, witnesses who have cooperated
with the police, persons who have testified for the prosecution, homosexuals, and African-
Americans arc not allowed to join the MMC. Women cannot become members of the MMC, but
bear the distinction of being referred to as "Property of (insert member's name)," and wear
leather vests that denote the same.
36, ?rospective members of the MMC must submit a detailed written application and pass a
backgtound check. MMC attorneys and private investigators have been utilized to validate the
backgrounds of prospects and associates. MMC associates seeking to become full-fledged MMC
members are refened to as "prospects" and fiequently wear black and white flannel shirts,
jackets and t-shirts that bear "support Your Local Mongols" or "S.Y.L.M," Once a prospective
member passes a background check, they may be accepted into the MMC as a 'oprospect" and
wear patches identifying them as such. The prospect is then placed on a probationary period and
serves as an assistant to the MMC members.
37. The MMC are well organized and maintain an established structure and hierarchy. The
MMC uphold a written constitution and by-laws, which dictate the mles of membership and a
strict code of conduct for the group. The MMC by-laws also articulate the consequences and
penalties for noncompliance with MMC rules and traditions.
Page l6 of51
AFFIDAYIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS
38. MMC members identifu themselves with patches, tattoos and insignia, identifying their
connection to the MMC and status within the organization. MMC members signiff their
membership with the gang by wearing leather vests, tee-shirts, hats, jewelry demonstrating the
MMC trademark logo and specific patches (see examples on page 19). The most prominent
images are that of a Mongol motorcycle rider and a diamond shaped patch with "|o/oer MFFM'
inside the diamond. The 1%er image is a declaratioa used to distinguish MMC members from
the other u99yo" of "regular citizen" motorcycle clubs around the world. MMC members define
themselves as within the "1"0/ou who are not ordinary and do not adhere to the law or the rights of
ooMongols
others. The "MFFM" patch labels the wearer as Forever Forever Mongols." MMC
members also wear a patch that indicates which chapter they are from, for example: "Duke City"
or "SoutJrwest." MMC members can earn the 'oRespect Few Fear None," patch for "showing
heart" or committing violence on behalf of the gang. A skull and crossbones patch may be
awarded for killing on behalf of the gang. There are also specific patches for members who have
served time in prison for the club.
39. MMC members have unique patches to display sexual conquests of women, which must
be witnessed by ansther brother, or brothers. Winged patches in different colors represent
specific sex actsl golden wings represent participation in group sex involving more thaa six
brothers; purple wings for performing oral sex on a dead woman; green wings for performing
oral sex on a woman with a venereal disease; red wings for performing oral sex on a
menstruating woman; brown wings for performing oral-anal on a woman; white wings for
performing oral sex on a white woman; black wings for a black woman, yellow wings for an
Asian woman; and blue wings for a policewoman.
Page l7 of51
40. The MMC maintain a steady supply of firearms in order to enforce the authority of the
gang and protect its members, ptospects, associates and women. Some firearms are lawfully
owned and possessed by memberu, while other firearms are stolen or ultraceable. The later are
maintained to be utilized when confronting rivals or conducting shootings on behalf of the
MMC. Such weapcns are utilized so they may not be readily connected to the MMC member
who used it. Weapons are often discarded or destroyed after an insident.
41. MMC members also carry other weapons on their person and motorcycles, to include
knives, hammersn and metal chains. Melal chains are also affixed to member's motorcycle
handlebars so MMC riders can strike persons or vohicles while chasing or passing them on the
roadway.
42. MMC members are attentive to the presence of rival motorcycle gegs, law enforcement,
and suspected informants. Mongols are likely to identifr such persons, and in the instances
where rivals or infomants might be present, MMC members assault them. MMC members have
been known to confront law enforcement officsrs on patrol or during surveillance operations
targeting the MMC. MMC members frequently challenge persons wearing clothing supporting
rival OMGs and have threatened to assault them if they do not remove the indicia (such as red
and gold colored tee-shirts, hats, pins or patches).
43. MMC members who are "out bad," or thrown out of the gang, have to give up their
patches and MMC memorabilia. They are also subject to beatings by the MMC and may have to
give up their motorcycle(s), as such conveyances are considered properly of the MMC.
Page 18 of5l
AFFIDAVIT IN SUPPORT OF AN APPLTCATION FOR SEARCH WARRANTS
MMC PATCHES AND INSIGNIA
0 1l E 0 T
fil $
Patches worn on the front of an MMC member's vest:

1. MMC member, state and chapter designation.
2. One percenter patch with Mongols Forever Forever Mongols
3. Respect Few Fear None patch
4. Member who has done time for the MMC
5. Wings denoting sexual conquests
Patches worn on the back of an MMC member's vest:
6. Three-piece patch designating MMC, Mongol rider, and the
state the member is from.
Other MMC support insignia
Page 19 of5l
PURPOSES OT THE ENTERPRISE
44. The purposes of the MMC criminal enterprise, including its members and associates,
include, but are not limited to, the following:
a) Enriching the leaders, members, associates, and prospects of the MMC through,
among other things, establishing and distributing controlled substances in territory
controlled by the MMC.
b) Maintaining the control and authority of the MMC over the tenitory claimed by
the MMC.
c) Preseling, protecting, and expanding the power of the MMC through the use of
intimidation, violence, threats of violence, assault, kidnapping, and murder.
d) Promoting and enhancing the enterprise and the authority and activities of the
leaders, members, associates, and prospects of the MMC.
MEANS AND METHODS OT THE ENTERPRISE
45, The means and methods by which the defendants and their co-conspirators conduct and
participate in the conduct of the affairs of the MMC include:
a) Members of the MMC commit, attempt to commit, and tlreaten to commit acts of
violence to protect and expand the enterprise's criminal operation, which includes
murder, assaults, intimidation, robbery, extortion, money laundering, drug
trafficking, and threats of violence directed against rival gang members, law
enforcement, and potential witnesses to the crimes of the enterprise.
b) Members of the MMC and their associates promote a climate of fear through
intimidation, violence, and threals of violence intended to promote the authority
Page 20 of51
of the MMC and insulate its members from liability for drug-trafficking and
violent crimes committed on behalf oflhe organization.
c) Members of the MMC use the enterprise to murder, attempt to murder, kidnap,
assault, intimidate, and threaten those who pose a threat to the enterprise.
d) Members and associates of the MMC engage in the interstate and intrastate
trafficking of controlled substances as a means to generate income for themselves
and the organization.
?UBLIC CORRUPTION: OMGS AND LAW ENFORCEMfiNT
46. Over the past 20 years, I have observed individuals, whether sworn officers or law
enforcement support employees, maintain friendly relationships with OMG members. The biker
gang members sometimes refered to the law enforcement personnel as "inside sowces."
Additionally, my experience has confirmed that some law enforcement officials maintain
sociable and unprofessional relationships with members of OMGs. This is an unfoftunate

phenomenon that frequently compromises OMG investigations around the country. I have had
conversalions with OMG members who related concern and question as to why some law
enforcement and corrections officers establish motorcycle clubs akin to OMGs, to include the
wearing of three-piece patches on the back of their vests.
4'1. With the popularity of television programs and books that glamorize the OMG culture,
the desire for some law enforcement offrcials to maintain close, unprofessional and sometimes
criminal relationships with OMG members will not easily disappear. It is through these close and
unprofessional relalionships that OMG members often gain, information that is disruptive to law
enforcemeat investigations and dangerous to the safety of confidential humat sources.
Page 21 of51
TH3 CONT'IDENTIAL HUMAN SOURCES
48. During this investigation, FBI case agents utilized several Confidential Human Sources
(.'CHS" is used for both the singular and plural use of the term) to infiltrate and disrupt the MMC
in New Mexico. Agents encouraged the various CHS to maintain contact with MMC members
and associates who were engaged in ongoing criminal activity. Six CHS were utilized in the
instant investigation. By cooperating with the FBI, the CHS have exposed themselves to a
violent death by the MMC, should their identities become known. I have souglrt to provide the
Court with some of the underlying circumstances and background information I relied upon ia
determining the information from the various CHS was reliable. In the paragraphs that follow, I
have provided an overview of each CHS, to include:
a) their basis of knowledge concerning the criminal conduct;
b) motivation to assist the FBI;
c) criminal history;
d) any compensation received from the government; and
e) a statement concerning their reliability.
49. I tried to provide sufflcient information to the Court, while balancing the anonymity and
safety of &e CHS.
50. CHS-I is an FBI CHS and has been for the past few months. CHS-I previously worked
for the ATF as an informant, where CHS-I was regarded as a reliable source whose information
contributed to numerous federal search warrants, criminal complaints, indictments, and
convictions of MMC members. CHS-I provided me with background information on the Target
Subjects and the MMC, to include the gang's history, structure, goals, recruiting and intelligence
collection efforts on rival OMG members. CHS-1 is motivated to assist the FBI to help prevent
Page 22 of51
bloodshed between the MMC and BMC. CHS-I has not received monetary compensation from
the FBI, nor does CHS-1 have pending criminal charges. CHS-1 does not have any felony
convictions. I consider the information CHS-I provided to be reliable because much of it was
corroborated through law enforcement investigation, information from other CHS, social media
postings, and physical surveillance, To my knowledge, CHS-I's information has not been found
to be false or misleading.
51. CHS-2 is an FBI CHS and may best be desuibed as a "professional informant." CHS-2
seryed as an FBI CHS from 2012-2014.I reopened CHS-2 as an FBI informant in2020 because
CHS-2 had joined the MMC. CHS-2 has also worked as a professional CHS for several local law
enforcement agencies in New Mexico. Information provided by CHS-2 has resulted in several
arrests and the issuance of numerous search warrants, and the seizure of controlled substances,
U.S. cumency, firearms, and stolen vehicles. CHS-2 provided me with background information
on the Target Subjects and the MMC, to include the gang's history, structure, goals, recruiting
and intelligence collection efforts on rival OMG members. CHS-2 is motivated to assist the FBI
to rid the MMC of problematic members and create a peace treaty between the MMC and BMC.
CHS-2 has been paid approximately $7,800 for assisting the FBI over the years. CHS-2 does not
have any felony convictions or pending charges. I consider the information CHS-2 provided to
be reliable because much of it was couoborated through law enforcement investigation,

controlled drug buys, information from other CHS, social media postings, and physical
surveillaace. To my knowledge, CHS-2's information has not been found to be false or
misleading.
52. CHS-3 is an FBI CHS aad began cooperating with the FBI in November 2019. CHS-3 is
a member of aa OMG and provided me with background information on the Target Subjects,
Page 23 of51
with whom CHS-3 is closely associated. CHS-3 is motivated to assist the FBI to help prevent
bloodshed between the MMC and BMC. CHS-3 has a pending felony charge and hopes to
receive a positive recommendation from the FBI in that matter. CHS-3 has not received
monetary compensation from the FBI and has prior felony conviotions for larceny, possession
with intent to distribute a controlled substance, aggravated battery, and auto burglary. CHS-3 has
utilized a cellular telephone equipped with a consensual wiretap to converse with targets of FBI
investigations. I consider the information CHS-3 provided to be reliable because much of it was
corroborated through law enforcement investigation, information fiom other CHS, social media
postings, and physical and electronic surveillance. To my knowledge, CHS-3's infonnation has
not been found to be false or misleading.
53. CHS-4 is a citizen informaat and former MMC prospect. CHS-4 has known the Target
Subjects for about two years. While prospecting with the MMC in New Mexico, CHS-4 became
disillusioned with the MMC after CHS-4 discovered a couple of the full-patch members had
o'bad
charges."s CHS-4 didn't have a problem putting in work and committing crimes for the
MMC, but did not want to associate with certain members. CHS-4 codionted one such MMC
member who had been charged with six counts of criminal sexual penetration of a child under
the age of 13 and was "black-balled by the club" after that. CHS-4 is motivated to assist the FBI
to rid the MMC of problematic members and create a more peaceful motorcycle community.
CHS-4 has not been paid for assisting the FBI. I lend to view CHS-4 as a citizen informant, as
CHS-4 only came forward to prevent violent crime. Moreover, the information CHS-4 provided
5 CHS-4 provided me the names of two MMC New Mexico members who had been charged
with child sex srimes. I looked into the criminal history of both MMC members and discovered
both had prior aresls for criminal sexual penetration of a child under the age of 13. While
neilher MMC member was convicted of those crimes, CHS-4 believed the accusations were
well-founded and could not join the MMC and "call child molesters brothers."
Page 24 of5l
to the FBI could be a statement against iRterest, as CHS4 recently assisted MMC members spy
on BMC members, distlibuted stolen firearms to MMC members, and sold conlrolled substancss.
CHS-4 is not pending any charges and has prior felony convictions for aggravated battery with a
deadly weapon aad breaking and entering. CHS-4 provided me with background information on
the Tatget Subjects and the MMC, to include the gang's sxucture, goals, recruiting and
intelligence colleetion efflorts on rival OMG members. I consider the information CHS-4
provided to be reliable because much of it was corroborated through law enforcement
investigation, information from other CHS, social media postings, and physical surveillance. To
my knowledge, CHS-4's information has not been found to be false or misleading.
54, CHS-S is a cooperating defendant and member of the Duke City Wrecking Crew.6 CHS-
5 is a veteran street gang member and has known the Target Subjects for about two years. CHS-5
has committed uimes and assaulted people for the MMC. CHS-5 provided me with background
information on the Target Subjects and the MMC, to include the gang's structure, goals,
recruiting and intelligence collection efforts on rival OMG members. CHS-5 is motivated to
assist the FBI in hopes of receiving a positive recommendation on a pending felony charge.
CHS-5 has not been paid for assisting the FBI. The information CHS-5 provided to the FBI
could be a statement against interest, as CHS-5 recently assisted MMC members commit
assaults, intimidate witnesses/victims, and steal firearms and a motorcycle. CHS-5 has prior
felony convictions for shooting at or from a motor vehiele, false imprisonment, aggravated
assault with a deadly weapon, and possession of a controlled substance. I consider the
information CHS-S provided to be reliable because much of it was con'oborated through law
6
The Duke City Wrecking Crew is a support element of the MMC, which is comprised of MMC
associates who do not have motorcycies, but hang around with the MMC and are known for
"putting in work" when asked by the MMC.
Page 25 of51
enforcement investigation, information from other CHS, social media postings, and physical
surveillance. To my knowledge, CHS-S's information has not been found to be false or

misleading.
55' CHS-6 is a victim of a srime perpetrated by the Target Subjects and other members of
the MMC. In September 2019, five members of the MMC approached CHS-6 and demanded his
motorcycle vest, which bore the insignia of a citizen motorcycle club. Target Subject ISAIAH
MATTHEW CHAVEZ, aka: "EK," aka: "HARDON," stuck a firearm in CHS-6's lower back
when he demanded the vest. Target Subject WILLIAM LEE WESTFALL, aka: .,SHOTS,', stood
nearby during the robbery. CHS-6 sun'endered his vest because he feared he would be shot if he
did not. The MMC members then departed the location on their motorcycles. Before they left,
one of the MMC members pushed CIIS-6's motorcycle over and onto the ground. CHS-6
indicated the damage done to his motolcycle cost $2,000 to repair. The Target Subjects, or
another MMC member, stole a pistol from a saddlebag on CHS-6's motorcycle. CHS-6 provided
law enforcement with a written statement concerning the event. CHS-6 was motivated to
cooperate with law enforcement because he was a victim of a crime and suffered financial loss as
a result of the iacident. I am unaware of CHS-6 having a criminal history. CHS-5 was reluctant
to testi& against the MMC members because his motorcycle registration card was inside his vest
and contained his home address.
STATEMENT OT' PROBABLE CAUSE
56. This affidavit is being submitted for three search warrants to aid the FBI in stopping
several imminent threats made by the Target Subjects and other MMC members. The threats
have been directed at rival OMG members and their supporters, "citizen,' motorcycle riders,
witnesses, and the general public. Much of the threat information was corroborated by MMC
Page 26 of51
membsrs and well-placed assosiates of the gang, to include CHS-I thru CHS-6 (who were
introduced in paragraphs 50-55).
57. In or about March 2019, the Target Subjects were founding members of the Duke City
Chapter of the MMC, which was the first MMC chapter established in New Mexico. CARLOS
ALVARADO JR., aka: "CHUGGS," (ALYARADO) currently serves as the President of the
Duke City Chapter. WILLIAM LEE WESTFALL, aka: '.SHOTS," (WESTFALL) cunently
serYes as the Sergeant-at-Arms of the Duke City Chapter. ISAIAH MATTHEW CHAYEZ, aka:
"EK," aka: "HARDON,'(CHAYEZ) was a member of the Duke City Chapter, but transitioned
to the Southwest Chapter upon its creation in 2019.
58. The Target Subjects and others, known and unknown, are also suspected ofpossessing
firearms and conspiring to recruit new members into the MMC, in light of the war between the
MMC and BMC. Based on information provided by various CHS, the MMC are looking for
opportunities to kill or assault BMC members and supporters to make "sxamples" of them and
stlengthen the image and reputation of the MMC inNew Mexico.
Conspiracy to Commit Assault in Aid of Racketeering
59. CHS-I, CHS-2, CHS-4, and CHS-5 all reported the Target Subjects were actively
conducting physical surveillance on members of the BMC, and their support clubs, in and around
Albuquerque. The puqpose of the surveillance was to acquire the home and work addresses of the
intended targets so they could assault or kill them. Within the past three months, CHS-4 and
CHS-5 had been tasked with researching several BMC members and supporters, and reporting
their {indings back to ALVARADO or WESTFALL. CHS-4 and CHS-5 were told to note such
things as the existence of residential security systems, camera systems, dogs, children, and police
vehisles parked in nearby driveways. CHS-4 and CHS-S independently provided the results of
Page27 of51
some of their surveillance work to ALVARADO and WESTFALL, who they believed were
keeping files or notes on the intended targets.
60. CHS-I and CHS-2 reported the New Mexico MMC members, to include the Target
Subjects, were in communication with MMC members in Texas and Colorado who were
conducting similar research on BMC members for purposes of targeting the BMC. CHS-I and
CHS-2 attended several "card games" (MMC meetings) or other gatherings and witnessed the
Target Subjects discuss upcoming BMC motorcycle runs and events. During those meetings, the
Target Subjects discussed potential plans to shoot at BMC members from freeway overpasses or
the opea roadway. CHS-I knew ALYARADO and WESTFALL to be in cellular telephone
communication with MMC members in Nevada, Arizona, Colorado, Texas, and California
regarding the acquisition of firearms and the targeting of BMC members. CHS-I said MMC
national officem were giving ALVARADO contradictory information concenring what steps he
(ALVARADO) should take regarding the BMC. ALVARADO related to CHS-I that the mother
chapter (national officers) had told ALVARADO to "handle business" and 'tepresent" the
MMC, but o'not bring heat'; on the organization because the mother chapter was on probation
with the feds and being watched.
61. CHS-I, CHS-2, CHS-4, and CHS-5 all reported ALVARADO was in'charge of calling
the shots on what moves would be made against the BMC in New Mexico. The same sources
indicated ALVARADO passed orders down to WESTFALL, as the Sergeant at Arms.

WESTFALL regularly relied on CHAVEZ to help cany out the mission(s), because CHAVEZ
was"crazy" and a "good soldier."
62. CHS-I and CHS-2 reported WESTFALL has been claiming to have recently killed a
Texas BMC member, who was riding his motorcycle in Albuquerque. WESTFALL was in a car
Page 28 of51
and able to run the BMC member off the road, According to WESTFALL, the BMC member
crashed and was severely injured and subsequently died in the hospital.
63. CHS-3 and CHS-5 are associated with the SNM prison gang and independently reported
ALVARADO and WESTFALL discussed forming an alliance with the SNM to increase the
power and influence of the MMC in New Mexico. CHS-3 related the MMC, BMC, and other
OMGs try to establish formal relationships with influential prison gangs in order to advance the
OMG enterprise, as many members of the OMG end up being incarcerated. MMC members
involved in criminal activity within New Mexico are likely to end up in prison, where the SNM
thrive and maintain a power base. An alliance between the MMC and SNM would bolster the
standing and influence of both organizations.
Theft of Motorcycle Club Vests ald PaJches
64. CHS-I, CHS-2, CHS-3, CHS-4, CHS-S, and CHS-6 all reported MMC members in New
Moxico, to include the Target Subjects, were involved in the forcible removal of club "coLors" or
'ocuts" (vests bearing a particular club's patches and insignia) from people. The sources reported
the Target Subjects were using force and fear to induce other motorcycle riders to lemove their
colors. CHS-I, CHS-2, CHS-3, CHS-4, CHS-S and CHS-6 had all been present with one or more
of the Target Subjects when they produced firearms or other weapons and demanded a person
remove their colors. The Target Subjecls and other MMC members regularly boasted of such
conquests and hung the seized vests upside-down inside their residences or garages as trophies.
Last year, CHS-6 had his vest stolen from him in this manner by CHAVEZ, WESTFALL and
other MMC members.
65. CHS-I and CHS-4 helped the Target Subjects forcibly steal vests from BMC support
club members or multiple occasions in the past year. All of those robberies occurred within the
Page 29 of51
District of New Mexico and most went unreported to law enfurcement, as many citizen
motorcycle clubs (also known as 99Yoer clubs) are reluctant to report OMG members to the
police.
66. CHS-2 believed WESTFALL to thoroughly enjoy intimidating other motorcycle riders
with his large size and visible prcsence of a firearm in his waistband. WESTFALL often boasted
that he had "shot a cop" and "shot it out with a SWAT team,'o when in the presence of other
motorcycle club members.T
67. CHS-3 reported WESTFALL was instrumental in dismantlement of an entire VAGOS
MC support club in Albuquerque in recent years, to include the forcible collection of all of their
patches and insignia.s
68. I have spoken with sources inside the BMC and am aware many of their members in
Albuquerque recently began wearing ballistic vests under their cuts when riding arouad in public
or on organized runs. The BMC members with whom I have spoken are aware of the MMC
threat and indicated the BMC are prepared to defend themselves. It is worth noting the cunent
COVID-I9 pandemic has resulted in the MMC and BMC cancelling all large gatherings and runs
for a few weeks. Smaller meetings between chapter mernbers are still taking place.
Unlawful Possession and Use of Firearms in Furtherance of Yiolent Crime
69. CHS-I has known the Target Subjects for more than two years and reported they carry
firearms at all times, and they insist other MMC members do the same. CHS-I estimated he has
7
In 2010, WESTFALL shot a BCSO SWAT deputy through a closed door, as the swAT team
prepared to execute a drug search waffant on WESTFALLS's Albuquerque residence.
WESTFALL was subsequently convicted of aggravated battery on a peace offrcer in that rnatter.
Additional details conceming that incident may be found in the TARGET SUBJECTS section of
this affidavit.
8 Turf at center of biker gang conflict in N.M. https://www.abqiournal.com/245116/ty:f-at-

csnter-o,f-bikqr:ggns-confl i ct-il:am. hlml
Page 30 of51
been with each of the Target Subjects on at least fifty occasions, wi&in the past two years, and
indicated they were armed with pistols every time. In fact, CHS-I said he had never seen any of
the Target Subjects without a firearm. CHS-I said the Target Subjects kept guns on their person,
when riding their motorcycles, when in cars, and in their residences.
70. CHS-I knows ALVARADO and WESTFALL to be in cellular telephone communication
with MMC members in Nevada, Arizona, Colorado, Texas, and California regarding the
acquisition of "ghost gunso' (firearms without serial numbers), o'long guns" (rifles), and higher
caliber hunting rifles with scopes. CHS-1 said MMC members in the aforementioned states, to
include ALVARADO and WESTFALL, discussed "saiping," or shooting BMC members from a
distance. I am aware hunting rifles with scopes could easily accomplish such a task.
71. CHS-2 has known the Target Subjects for approximately two years and knows them to
cany fireatms at all times. CHS-2 estimated he had hung out with the Target Subjects dozens of
times over the past year and said they were armed each time CHS-2 was with them. Accor.ding to
CHS-2, ALVARADO frequently commented on how lax New Mexico laws were, compared to
Colorado and Arizona. ALVARADO seemed to opine that slack New Mexico laws would boost
the growth and goals of the MMC.
72. CHS-2 described the speci{ic firearms he had observed the Target Subjects cany with
them at all times: WESTFALL usually carried a black Glock model 27, .4A caliber pistol and
ALVARADO cartied a black Springfield XD semi-auto pistol or a Ruger single stack pistol.
CHAVEZ owned mulliple firearms and normally caried a Springfield XD pistol on his waist
and a snub nose .38 revolver in an ankle holster.
73. CHS-3 is a longtime associate of WESTFALL and described him as being "big,
aggressive, and always armed." CHS-3 added, "He (WESTFALL) ain't afraid to pull the trigger
Page 31 of51
either." CHS-3 told me FBI agents should be very careful when dealing with WESTFALL
because he was very proud of the fact, he had shot a police of{icer and would not hesitate to do it
again. CHS-3 knew WESTFALL to be a former BMC member and said he had been given a raw
deal by the BMC after several BMC members had disrespected WESFALL's "old lady."
WESTFALL challenged the BMC members who had disrespected his girlfriend, which led to
WESTFALL's ouster from the BMC. CHS-3 said the incident soured WESTFALL to the BMC
and he readily joined the rival MMC. CHS-3 described WESTF'ALL as having a deep hatred for
the BMC and WESTFALL frequently talked about shooting and killing as many BMC as he
could.
74. CHS-3 reported MMC member RANDY GARCIA, aka: "SMOKE" got into a {istfight
with a BMC member in late March 2020, in the parking lot of a local business. The BMC
member beat GARCIA up and then departed the location. GARCIA also departed, but returned
the following day with a gun and WUSTFALL, who was also armed. GARCIA and WESTFALL
asked employees of the business questions about the BMC member 1o see when he might retum.
75. CHS-4 admitted to having provided stolen flrearms to several MMC members and
prospects, to include the Target Subjects. Within the past year, CHS-4 obtained fircarms from
some of his drug clients who had obtained the guns during residential and auto burglaries. CHS-4
o'missions" or *difiy work." CHS-4

knew the MMC required stolen or uatraceable firearms for
said he would still be providing firearms to the MMC members in Albuquerque; however, he
became disillusioned with the MMC after he witnessed them bring in Mongols who had "bad
oharges" (sex offenses).
76. CHS-4 related MMC member RANDY GARCIA, aka: "SMOKE," kept getting stopped
by BCSO and charged with being a felon in possession of a fireatm. MMC members initially
Page 32 of51
suspected GARCIA might be an informant because his charges kept getting dismissed. I have
reviewed GARCIA's criminal history and noted he had prior felony convictions, to include
traflicking a controlled substance and possession of a stolen firearm; however, the New Mexico
District Court enabled OARCIA to have his felony convictions removed upon completion of his
term of probation. As such, I believe GARCIA is able to lawfully possess fireanns and
ammunition.
77. CHS-2 reported GARCIA is always armed and caried coufi paperwork wilh him
showing his felony convictions were removed from his record.
78. CHS-4 reported the Target Subjects were always armed with pistols and they encouraged
other MMC members and prospects to "be armed and ready."
79. CHS-5 has known the Target Subjects for about ayeff and a half. During that period of
time, CHS-5 has socialized with the Target Subjects on at least twenty occasions and said the
Target Subjects were armed with pistols every time. CHS-5 said CHAVEZ cxiedtwo guns, one
of which he wore on his ankle. CHAYEZ also sometimes strapped a pistol to the front of his
motorcycle where he could easily access it while riding on the roadway. CHS-5 said
ALVARADO and WESTFALL carried black semi-automatic pistols that were either Smith &
Wesson's or Glock's. CHS-5 said all of the MMC members carried guns everywhere they went
because they were paranoid about being afiacked by a rival OMG.
80. CHS-6 reported CHAVEZ and WESTFALL robbed him at gunpoint in late 2019, and
CHAVEZ or another MMC member stole a pistol from a saddlebag attached to his motorcycle.
81. Within the past 36-hours, CHS-2 attended a meeting with the Target Subjects and
reported all three were armed with pistols and discussed their suspicions that they being followed
around by BMC members. I should point out that the Target Subjects have been under law
Page 33 of51
enforcement surveillanco in recent weeks by members of the VCTF and FBI Safe Streets Gang
Task Force, which includes detectives from the APD Gang Unit.
Possession of Body Armor by a Violent Felon
82, CHS-I reported ALVARADO and WESTFALL possessed ballistic vests that had been
stolen from law enforcement vehicles, and had encouraged other MMC members to acquire
similar vests. CHS-I said ALVARADO and WESTFALL would loan their vests to other MMC
members, to include members visiting New Mexico from other states. CHS-I believed the Target
Subjects and other MMC members would wear the vests when they perceived a threat or when
"on a mission" for the MMC.
83. CHS-3 said all of the Target Subjects possessed body armor, bearing the MMC insignia.
CHS-3 had borrowed body armor from WESTFALL in the past, but had returned it. CHS-3 said
all of the MMC members were encouraged to possess body arnor and OMG members had told
CHS'3 that most states, to include New Mexico, did not have restrictions in place conceming the
possession of body armor.
84. CHS-4 reported that withinthe past few months, WESTFALL told him to keep an eye
out for ballistic vests because the MMC was expanding its membership alound New Mexico.
Conspiracy to Distribute Controlled Substances
85. CHS-I reported ALVARADO and WESTFALL regularly provided cocaine to other
MMC members and associates during MMC related parties. CHS-I did not know who
ALVARADO's and WESTFALL's source of supply was. CHS-I had observed ALVARADO
and WESTFALL dish'ibute small bags of cocaine to other people on at least twenty-five
occasions over the past year. CHS-I knew CHAYEZ ta sometimes sell fentanyl tablets to MMC
Page 34 of51
associatos and other people. Within the past month, CHS-I observed CHAVEZ to possess 20-25
small blue pil1s, several of which he sold to persons inside an Albuquerque bar.
86. CHS-2 reported the Talget Subjects consume cocaine when pafiying, and sometimes used
fentanyl. CHS-2 said CHAVEZ recently tested positive on a urinalysis tests with county prehial
services; however, he was not arrested. CHAVEZ then resumed using cocaine and consuming
alcoholic beverages.
87. CHS-3 related MMC members had established a partnership with a specific street gang in
Albuquerquee to distribute controlled substanc.es. A known MMC member, who had hailed from
that particular street gang, connected the MMC members with street gang leaders. CHS-3 said
ALVARADO and WESTFALT appreciated the rclationship with the street gang, but were
having on-going discussions about establishing a relationship with the SNM or the Burqueflos
gangr0 in hopes of expanding their drug hafficking network. WESTFALL also discussed the
impoftance of having better liaison with the SNM and Burqueflos because of their ability to
"make money" and "call shots on the inside" (ait/prison).
88. CHS-5 reported the Target Subjects regularly consumed cocaine and sold small amounts
to other MMC members or associates, as well as other petsons. CHS-5 described the Target
Subjects as'osmall" cocaine dealers and identified an Albuquerque street gang that was sourcing
the MMC with drugs.rl
e
I am withholding the specific name of the gang and any members associated with the gang, as
they are the subjects of a related VCTF investigation.
l0 The Burquefros have

not been designated a prisons gang; however, New Mexico prison and
jail officials consider them a security threat group (STC). The Burqueflos STG are comprised of
street gang members from Albuquerque, who band together for protection in prison and jail.
1l
It was the same street gang named by CHS-3.
Page 35 of51
AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH V/ARRANTS
f,vidence Sought Pursuant to the Requested Search Warrants
89. Based on the information contained herein, I believe there is probable cause to believe
evidence, fruits, and instrumentalities of violations of 18 U.S.C, $$ 1962(c), 1959(a), 1957,931,
924(c), 922(9), 922(j) 922(n), 875, 377,2, and 21 U.S.C. $$ 846 and 8a1(a)(l), will be found
within the Subject Premises when the requested warrants are executed. The specific items being
sought pursuant to the requested search warrants include:
a) Evidence of membership or affrliation with the Mongols Motorcycle Club (MMC): to
include any documents, photographs, patches, drawings, writings, or objects depicting
MMC rnember's names, initials, monikers, officer role, chapter assignment, or any other
item depicting potential gang membership, affiliation, activity or identity;
b) Rival motorcyole club lists or photographs, "gleen light" lists, murder/assault lists,
witness or confidential informant tists, inmate lists, address and telephone number lists,
letters, law enforcement repofis, judgments, pre-sentencing repofis, newspaper afiicles,
computer generated reports or printouts, legal documents, detention facility inmate
number lists or addresses for rival motorcycle clubs;
c) Vests, patches, shirts, hats, or similar items bearing the name, moniker, logo, or insignia
of a potenlial rival motorcycle club, that may have been acquired through thteats or
violence;
d) Firearms, magazines, and ammunition;
e) Body armor and ballistic vests;
0 Controlled substances, drug packaging material, paraphernalia and scales;
g) United States curency;
h) Documentary evidence of drug trafficking, to include records, reoeipts, notes, ledgers,
money orders money order receipts, pre-paid money cards such as MoneyPak, Gleen
Page 36 of 5 I
Dot, lVal-Mart, or othel debit cards and any documents relating to transpofting, ordering,
purchasiag or distributing drugs;
i) Cellular telephones and other digital devices, such as computers, laptops, tablets, PDAs
or similar electronic storago devices;
90, In the paragraphs that follow, I have identified the Target Subjeets in greater detail, noted
their position within the MMC aad whether they were part of any other gangs prior to joining the .
MMC. I have also included the arrest history of the Target Subjects, and where possible, noted l
the felony offenses for which they were convicted.l2
91. CARLOS ALVARADO JR., aka: "CHUGGS," is a former MMC member from Arizona
:
and is currentlty the President of the Duke City, New Mexico, Chapler. ALVARADO has prior ,.
arrests in New Mexico and Arizona for shooting at or from a motor vehicle and receiving stolen
properly Q002); possess dangerous drugs (2004); unlawfi.rl taking of a motor vehicle (2010);
,
theft of transportation (2010); and theft by extortion where the victim is a vulnerable adult
(2010). ALVARADO has a prior felony conviction for attempted theft of a means of
transporlation (2011) in Navajo County, Arizona, Case No, S0900CR201000454.
92. ALVARADO is currently being sought on a misdemeanor Valencia County, New

:
Mexico, amest warrant for failure to appear on tra{Iic offenses, warrant no. M45TR2ADUA27,
issued December 28,2079, with statewide extradition.
g3.WILLIAMLEEwESTFALL,aka:..SHoTS,',isaformerBMCmemberandcurrently
serves as the Sergeant-at-Arms of the Duke City Chapter of the MMC. WESTFALL has several :
12
Criminal history records were obtained &om the FBI's National Criminal Information Center
(NCIC). I believe the records accurately reflect the subject's arrest record; however, conviction
data is often not listed, or listed as "disposillon unknown," because aot all arresting agencies
enter post-anest data. In order to compile conviction data I also consulted NM Courts online and
o&er state court databases, Where possible, I have listed the subject's arrests and convictions.
Page 37 of5l
prior arrests in New Mexico for unlawful taking of a motor vehicle (1999); auto burglary {1999);
conspiracy (1999); aggravated assault with a deadly weapon (2000); tampering with evidence
(2000); criminal damage over $1000 (2000); on a police officer (2001); contributing to
lattery
the delinqueney of a minor Q\A\; eluding an officer (2002); obstructing an officer (2002);
aggravated assault upon a peace officer with a deadly weapon, 3-counts, (2010); lrafficking a
controlled substance (2010); felon in possession of a firearm (2010); abuse of a child, 3-counts,
(2010); and felon in possession of a firearm Q0l9} WESTFALL has been convicted of
unauthorized use of vehicle (2002),383'd Judicial District Court El Paso Cornql, Texas, Case
No. 2AA20DA6263; and aggravated battery with a deadly weapon, aggravated assault with a
deadly weapon, and aggravated assault with a deadly weapon (2011), Second Judicial District
Court, Bernalillo County, New Mexico, Case No. D-202-CR-2010-04434. The 2011 conviction
related to his having shot a BCSO SWAT deputy as the sheriffs department executed a drug
search warrant on his residence in Albuquerque, NM.
94, On March 25, 2020, VCTF Task Force Officer Paul Montoya (BCSO) obtained a
criminal complaint and arest warrant charging WESTFALL with a violation of 18 U.S.C. g
92?($(l) being a felon in possession of a firearm and ammunition, The complaint and wanant
were authorized by U,S. Magistrate Judge Steven C. Yarbrough, Case No, 20-MJ-986.
95. FBI agents plan to anest WESTFALL at his residence during the execution of the
requested search warants. It is worth noting; the instant firearm charge against WESTFALL
involved WESTFALL, CHAYEZ and 1wo other MMC members possessing six loaded firearms
inside a vehicle they were preparing to travel in. BCSO deputies contacted the men and
subsequently seized the firearms. There were MMC vests inside the truck, as well. CHAVEZ
claimed two of the loaded guns belonged to him and they were subsequently retumed to him.
Page 38 of51
Laboratory testing confirmed WESTFALL's DNA was on one of the loaded firearms. I am
aware the Court can readily access the referenced complaint aad hereby request that it be
incotporated herein by this rcference (20-MJ-986, filed March 25,2020 within the District of
New Mexico).
96. ISAIAH MATTHEW CHAVEZ, aka: "EK," aka: "HARDoN,,'is a former member of
the Bandoleros MC, which is a BMC support club. CHAVEZ was recruited by the MMC
sometime in late 2018 or early 2019. CHAVEZ is currently an MMC member in the Southwest
Chapter and has pr{or arrests in New Mexico for possession of drug paraphernalia (2010);
aggravated assault upon a peace officer with a deadly weapon

QAi_9); and resisting, evading or
obstructing an officer (2019). CHAYEZ has no prior felony convictions; however, he was
indicted on or about December 2,2079, within the Second Judicial District, County of Bemalillo,
State of New Mexico, on (Count 1) Aggravated assault upon a peace officer with a deadly
weapon, (Count 2) Resisting, evading or obstructing an officer, and (Count 3) Reckless driving,
Case No. D-202-CR-193218. As such, I am aware CHAVEZ may not possess a firearm or
ammunition pursuant to l8 U.S.C. g 922(n).
97, I understand CHAVEZ recently tested positive for use of a prohibited substaace, but was
not detained by Bernalillo County pretrial services. Through my conversations with BCSO
detectives, I am aware probable cause exists to charge CHAVEZ with armed robbery based on
the September 2019 incident involving CHS-6.
98. CHAVEZ seems to be intentionally misleading county pretrial services officers
concerning his address, as he has lived at Subject Premises A-3 for the dwation of the instant
investigation. CHAVEZ' Bernalillo County couft records Iist his residence as that of his parent's
home in the South Valley area of Albuquerque.
Page 39 of5 I
99. Case agents have collected several photos and videos from MMC member's social media
posts. I have included a few such photographs to further demonstrate the association between the
Target Subjects (all photos below are from Facebook postings):
From Ieftto righn CHAVEZ, ALVARADO and WESTFALL
From Ieftto right: cHAVEZ, WESTFALL and ALVARADO
From left to right: ALVARADO and CHAVEZ From left to right: CHAVEZ, ALVARADO, unnamed member,
Page 40 of51
THf, SUBJECT PREMISES
100. Subiect Premises A-1: I believe CARLOS ALVARADO JR., aka: "CHUGGS,'lives at
Subject Premises A-1, Iocated at 1525 Larkin Road SW, Albuquerque, New Mexico. Subject
Premises A-1 may be described as a single-story residence with rose-colored siding and white
trim. A rose-colored stucco wall and white rod iron gate sncompasses the front of the property.
The numbers "1525" are posted on a large stucco post in front of the residence. There appear.to
be cameras attached to the western roofline of the Subject Premises. Metal security scrsen doors
cover the front and side entry doors. A color photograph of the Subject Premises has been
attached and incorporated in Attachment A-1,
lndicia of Residence:
a) ALVARADO was initially difficult to pin down to a residence, as his driver's
license is expired, his vehicle is registered under a different name and address, his
cellular telephone is still registered to an address in Arizona, and during his most
recent contact with law enforcement he provided his gather's address in Belen,
New Mexico. I caused Valencia County Sheriffs Office perconnel 1o visit
ALVARADO's father's house under a ruse visit, and ALVARADO's falher said
he only lived there for 2-weeks when he first moved to New Mexico from
Arizona. ALVARADO's father said ALVARADO was now living in
Albuquerque.
b) On April 1, 2020, VCTF agents followed ALVARADO from an MMC meeting to
Subject Premises A-1. Since April 1, 2020, VCTF agents begaa conducting daily
surveillance on ALVARADO.
Page4l of51
c) VCTF surveillance agents have been monitoring ALVARADO for the past 7-days
and have observed him to reside at Subject Premises A-1.
d) The vehicle VCTF agents have observed ALVARADO drive has been parked in
the driveway of the location at night and eally in the moming for the past 7-days.
e) A neighbor identified AVARADO as living at the Subject Premises and usually
entering and exiting from the westem most door of the Subject Premises.
101. Subiect Premises A-2: I believe WILLIAM LEE WESTFALL, aka: "SHOTS," lives at
Subject Premises A-2, located at3325 Montclaire Drive NE, Albuquetque, New Mexico. Subject
Premises A-2 may be described as a single-story resideace with tan stucco and tanlbrown rock
siding. The attached garage has a white door and the trim on the house is white and maroon. The
numbers *3325" are posted on the curb in front of the residence. There are multiple cameras
affixed the exterior of the residence. A color photograph of the Subject Premises has been
attached and incorporated in Attachment A-2.
Indicla of Residence:
a) The Subject Premises is listed as WESTFALL's residence on his valid New
Mexico driver's license.
b) The vehicle VCTF agents have observed WESTFALL drive is parksd in the
driveway of the location on a regular basis.
c) Official police records list the Subject Premises as his residence.
d) Multiple CHS have visited WESTFALL at the Subject Premises in recent weeks.
I o'EK," aka:
102. Subiegt Premises A-3: believe ISAIAH MATTHEW CHAVEZ, aka:
"HARDON," lives at Subject Premises A-3, located at2844 John Street SE, Albuquerque, New
Mexico. Subject Premises A-3 may be described as a single-story residence with red brick siding
?age 42 of 5l
AFFIDAVIT IN SUPPORT OF AN APPLICAT]ON FOR SEARCH WARRANTS
and tan trim. There is a tan security door over the front door. The driveway is enclosed with a
black and white gate/fence, which bears a Keep Out sign. The numbers 2844 arc posted on the
fiont porch and on the mailbox in front of the residence. A color photograph of the Subject
Premises has been attached and incorporated in Attachmeat A-3.
Indicia of Residence:
a) VCTF surveillance agents observed CHAVEZ come and go from the location on
multiple occasions over the past l0-days.
b) The vehicle VCTF agents have observed CHAVEZ drive has been parked in the
driveway of the location every night and early in the moming over the past 10-
days.
c) A CHS visited CHAVEZ at the Subject Premises on multiple occasions in recent
weeks, to include while VCTF agents had the location under surveillance.
d) CHS-2 knows CHAVEZ to reside at Subject Premises A-3 with his wife and tluee
children.
SEARCHING FOR GANG TATTOOS:
i03. rffhen the search warrants are executed, agents will attempt to interview the Target
Subjects about their affiliation with the MMC and any other gangs. I believe gang tattoos to be
significart evidence of gang affiliation and such tattoos may constitute an overt act, in-so-much-
as gang-specific tattoos enable a person to maintain or increase their position within the gang. I
have successfully charged several gang members with overt acts, within the context of a RICO
conspiracy, for having one or more gang specific tattoos.
104. lt has been my experience that many people lie when speaking with law enforcement and
will sometimes go to great lengths to conceal their gang ties. Furlhermore, the Target Subjects
Page 43 of51
may exercise their constitutional right to refrain from speaking with FBI agents. In au effort to
discern and document the Target Subject's gang affiliation, I am requesting agents be permitted
to search the Target Subject's bodies, above the waist and below the thighs, for tattoos.
105. I am aware MMC members have distinct tattoos that represent their dedication to the
MMC criminal enterprise. The members display these tattoos to gain respect within the
entetprise and to intimidate non-members. I am seeking the courl's permission to utilize law
enforcement photographers to photograph and document the Target Subject's tattoos. Such photo
documentation would help positively identi& tlre Target Subjects and better document and
determine their gang affiliation.
106. Law enforcement records, jail photographs, and social media photos that I have rcviewed
in this case indicate that all of the Target Subjects have ons or more tattoos on their bodies. I
believe the male Targel Subjects may have gang related tattoos.
107, I am aware that some of the tattoos evidencing membership in or association with the
MMC include, but are not limited to: the letters *MFFM,'' *RFFN," the words 'oMongol,"
or "Mongols MC," the symbols "IYo" ot "lo/oer," chapter names, and other imagery
that may signify the MMC. Some example MMC tattoos have been included on the
following page.
Page 44 of5l
AFFIDAVIT IN SI.'PPORT OF AN APPLICATION FOR SEARCH WARRANTS
108. Example MMC gang tattoos:
BIOMETRIC ACCESS TO DEVICES
109. I know from my training and experience, as well as from information found in publicly
available materials published by device manufacturers, that many elecfronic devices, particularly
newer mobile devices and laptops, offer their users the ability to unlock the devise through
biometric features in lieu of a numeric or alphauumeric passcode or password. These biometric
features include fingerprint scanners, facial recognition features and iris recognition features.
Some devices offer a combination of these biometric features, and the user of such devices can
select which features they would like to utilize.
a) If a device is equipped with a fingerprint scanner, a user may enable the ability to
unlock the device through his or her fingerprints. For example, Apple offers a
feature called "Touch [D," which allows a user to register up to five fingerprints
that can unlock a device. Once a fingerprint is registered, a user can unlock the
device by pressing the relevant finger to the device's Touch ID sensor, which is
Page 45 of5l
found in the rnund button (often referred to as the "home" button) located at the
bottom center of the front of the device. The fingerprint sensors found on devices
produced by other manufacturers have different names but operate similarly to
Touch ID.
b) If a device is equipped with a facial-recognition feature, a user may enable the
ability to unlock the device through his or her face, For example, this feature is
available on certain Andloid devices and is called "Trusted Face." During the
Trusted Face registration process, the user holds the device in front ofhis or her
face. The device's front-facing camera then analyzes and records data based on
the user's facial characteristics. The device can then be unlocked if the fiont-
facing camera detects a face with characteristics that match those of the registered
face. Facial recognition features found on devices produced by other

manufacturers have different names but operate similarly to Trusted Face.
c) If a device is equipped with an iris-recognition feature, a user may enable the

ability to unlock the device with his or her irises. For example, on certain
Microsofl devices, this feature is called o'Windows Hello." During the Windows
Hello registration, a user registers his or her irises by holding the device in front
of his or her face. The device then directs an infrared light toward the user's face
and activates an infrared-sensitive camera to record data based on patterns within
the user's irises. The device can then be unlocked if the intared'sensitive camera
detects the registered irises. Iris-recognition features found on devices produced
by other manufacturers have different names but operate similarly to Windows
Hello.
Page 46 of51
d) In my training and experience, users of electronic devices often enable the
aforcmentioned biometric features because they are considered to be a more
convenient way to unlock a device than by entering a numeric or alphanumeric
passcode or password. Moreover, in some instances, biometric features are
considered to be a more secure way to protect a device's contents. This is
particularly true when the users of a device are engaged in criminal activities and
thus have a heightened concern about securing the contents ofa device.
e) As discussed in this Affidavit, I have reason to believe thal one or more digital
devices will be found during the search. The passcode or password that would
unlock the devices subject to search under this wan'ant currently is not known to
law enforcement. Thus, law enforcement personnel may not otherwise be able to
access the data contained within the devices, making the use of biomelric featurcs
necessary to the execution of the searrh authorized by this warrant.
0 I also know from my training and experience, as well as from information found
in publicly available materials including those published by device manufacturers,
that biometric features will not unlock a device in some circumstances even if
such features are enabled. This can occur when a device has been restafied,
inactive, or has not been unlocked for a cefiain period of time. For example,
Apple devices cannot be unlocked using Touch ID when: (1) more than 48 hours
has elapsed since the device was last unlocked; or, (2) when the device has not
been unlocked using a fingerprint for 8 hours and the passcode or password has
not been entered in the last 6 days. Similarly, certaia Android devices cannot be
unlocked with Trusted Face if the device has remained inactive for four hours.
Page 47 of51
Biometric features from other brands carry similar restrictions. Thus, in the event
law enforcement personnel encounter a locked device equipped with biometric
features, the opportunity to unlock the device through a biometric feature may
exist for only a short time.
110. Due to the foregoing, if law enforcement personnel encounter any devices that are subject
to seizure pursuant to this warart and may be unlocked using one of the aforementioned
biometric features, I request permission to: (1) press or swipe the fingers (including thumbs) of
the Target Subject to ths fingerprint scanner of the devices found at the Subject Premises; (2)
hold the devices found at the Subject Premises in front of the face of the Target Subject and
activate the facial recognition feature; and/or (3) hold the devices found at the Subject Premises
in front of the face of the Target Subject and activate the iris recognition feature, for the purpose
of attempting to unlock the devices in order to search the contents as authorizedby this warrant.
The proposed warrant does not authorize law enforcement to request that the Target Subject state
or otherwise provide the password or any other means that may be used to unlock or access the
devices. Moreover, the ploposed warrant does not authorize law enforcement to ask the Target
Subject to identiS the specific biomelric characteristics (including the unique finger(s) or other
physical features) that may be used to ualock or access the devices.
Page 48 of51
MANNER IN WHICH SEARCH WARRANTS WILL BE SERVED
1ll. I am requesting authority be granted to execute the search warrants on the Subject
Premises without the requirement of delayed entry ("NO DELAY") in the interest of personal
safety of the participating agents.13
ll2. Based oa the violent nature of the MMC, uiminal histories of the Target Subjects,
alleged violent crirnes, and firearm related evidence being sought; I have requested FBI and
BCSO Special Weapons and Tactics (SWAT) teams execute the requested search warrants.
Multiple CHS have reported the Target Subjects are always armed and each has histories of
firearms related crimes and/or aggravated assault on police offrcers. I believe all three Subject
Premises have suryeillance cameras on the exterior of the houses, to include on the front of the
residence. I believe that if agents delay their entry into the residence for more than a few
seconds, the Target Subjects may arm themselves and shoot at agents. Moreover, delayed entry
into the Subject Premises may enable the Target Subjects or another oecupant to destroy
evidence, particularly drug evidence, which is easily disposable.
113. During the knock and announce process, the SWAT teams will utilize specially
coashucted equipmenl to forcibly breech some exterior doors and windows. This tactic will be
employed to more quickly address persons inside the residence and limit their movements.l4
SWAT agents will repeatedly announce their presence during entry into the Subject Premises.
13
Such search walrant requests have traditionally been referred to as "No Knock" authorizations.
To be clear, I am not requesting permission to enter the premises without knocking our
announcing. Rather, I am requesting the Cout's preapproved authorization for agents to knock,
announce, and then immediately begin breaching locked en@ points.
la This SWAT
techaique is often referred to as "breech and hold" and enables agents to better
control and detain occupants within a structure. Through the utilization of this technique, I have
been able to prevent subjects from moving about the structure and/or flushing controlled
substances down the toilet.
Page 49 of51
AFFIDAVIT IN SUPPORT OF AN APPLICATION ['OR SEARCH WARRANTS
Several law enforcement vehicles will be parked in front of the Subject Premises with red and
blue emelgency lights flashing and law enforcement personnel will repeatedly make
announcements over a loud speaker advising that the FBI (or Sheri{Ps Department) is serving a
search warrant on the Subject Premises. The public address system will be mounted on a SWAT
vehicle at the front ofthe Subject Premises.
I14. Based on the foregoing, I believe that there is probable cause to believe that evidence of
violations of 18 U.S.C. $$ 1962(c), 1959(a), 1951, 931, 924(c),922(9),922(j,) 922(n),875,371,
2 and 21 U.S.C. $$ 846 and 841(a)(1), as more particularly described in Attachment B, will be
found at Subject Premises. Furthermore, based upon the foregoing, 1 believe there is reasonable
suspicion to believe that compliance with the *knock and announce" rule, pursuant to 18 U.S.C,
$ 3109, would be dangerous, futile, and destructive to the investigation. Therefore, I am
requesting authorization for the SWAT teams to make a forcible entry into the Subject Premises
immediately after knocking and announcing their presence (i.e. "FBI with a seatch warrant").
NIGHTIME SERYICE REOUEST
115. I have learned Target Subjects work for one or more local businesses performing
plumbing, heating, ventilation, and air conditioning (HVAC) work. I confirmed this information
via CHS reporting on the Target Subjects and state employment records. I am also aware tluough
CHS information and physical surveillance that the Target Subjects frequently depart their
residences as early as 5:30 a.m. to travel to a centrally located warehouse in northern

Albuquerque, or various other job sites around the region.
116. It is essential to the investigation that agents execute the requested search warants at a
time when the Target Subjects are home, as their psrsons will be searched for gang-related
tattoos. Furthermore, I anticipate firearms will be present at the Subject Premises and/or on the
Page 50 of51
Target Subjects. I would like to recover those fircrums and collect appropriate evidence to
mitigate future violence perpetrated by the Target Subjects. Therefore, I am requesting
authorization to serve this search wamant as early as 4:30 a.m,
CONCLUSION
ll7. Based on the information set forth above, there is probable cause to believe that items
more fully described in Attachment B and consisting of evidence, contraband, instrumentalities
and/or fruits of violations of 18 U.S.C. $$ 1962(c), 1959(a), 1951,931, 924(c),922(9),922A)
922(n),875,371,2 and 2l U.S.C. $$ 846 and 841(a)(1), will be found atthe locations more
fully described in Attachments A-1, A-2, and A-3. Further, based upon the foregoing paragraphs,
judicial authority is specifically requested to allow the FBI and BCSO SWAT teams to execute
the requested search wan'ants as early at 4:30 a.m., and immediately after knocking and
announcing their presence.
118. This application was reviewed and approved by Supervisory Assistant United States
Attorney Jack Burkhead of the District of New Mexico.
Respectfully submitted,
Bryary&I. Acee
FBI Special Agent
Electronically submitted and telephonically sworn before me. Aprll7,202O
ffi^^,er4.5-
THE HONORABLE KAREN B. MOLZEN
UNITED STATES MAGISTRATE JUDGE
DISTRICT OF NEW MEXICO
Page 51 of51
ATTACHMENT A-1
Person and Premises to be Searched
Person to be Searched: CARLOS J. ALVARADO JR., aka: ..CHUGGS,,, who appears in the
photographs below. The Defendant will be searched for tattoos evidencing membership in oi association
with the Mongols Motorcycle Club, or any other gang.
Premises to be Searched: Subject Premises A-1, located at 1525 Larkin Road SW, Albuquerque, New
Mexico. Subject Premises A-l may be described as a single-story residence with rose-colored siding and
white trim. A similar colored stucco wall and white rod iron gate encompass the front of the property.
The numbers "1525" are posted on a large stucco post in front of the residence. There appiar to be
cameras attached to the western roofline. Metal security screen doors cover the front and side entry
doors. color photographs of subject Premises A-l have been attached hereto.
The search of the Subject Premises shall include the entire residence and all outbuildings, trash cans,
storage containers, and vehicles parked at, or in front of, the Subject premises.l
t Only vehicles parked at,

or in fircnt of, the Subject Premises and having an apparent connection to the Subject
Premises will be seached. Connection to the Subject Premises may be eiiablished by way of prior iaw
-
enforcement observation, vehicle registration, subject admission or possession of an ignition key.
{,{rN\ Attachment A-l

ATTACHMENT A.1
Cellular Telephone Biometric Features: During the execution of the search of the premises described
herein, law enforcement are also specifically authorized to compel CARLOS J. ALVARADO JR., aka:
*CHUGGS," provide
to biometric features, including pressing fingers (including thumbs) against and/or
putting a face before the sensor, or any other security feature requiring biometric recognition, of:
a. Any devices found at the premises, and

b. Where the devices are limited to those which are capable of containing and reasonably could
contain fruits, evidence, information, contraband, or instrumentalities of the offense(s) as
described in the search warrant affidavit and warrant attachments
for the purpose of attempting to unlock the devices' security features in order to search the contents as
authorized by this warrant.
This warrant does not authorize law enforcement personnel to compel any other individuals found at the
premises to provide biometric features, as described in the preceding paragraph, to access or otherwise
unlock any device. Further, this warrant does not authorize law enfoicement personnel to request that
CARLOS J. ALVARADO JR., aka: "CHUGGS," state or otherwise provide the password or any other
means that may be used to unlock or access the devices, including by identifting the specific biometric
characteristics (including the unique finger(s) or other physical features) that may be used to unlock or
access the devices.
fif/v\ AttachmentA-r
,Tffi#f#."
Items to be Seized: All evidence, fruits, and instrumentalities of violations of: 18 U.S.C.
$
1962(c) Racketeer Influenced and CorruptOrganizations (RICO); 18 U,S.C. g 1959(a) Violeni
Crimes In Aid of Racketeering (VICAR); 18 U.S.C. g 1951 Interference *ith comrnerce by
threats orviolence; 18 U.S.C. $ 931 Possessionof body armorby aviolentfelon; l8 U.S.C.
b
924(c) Use of a firearm in furtherance of a crime of violence; 18 U.S.C. g 922(9) prohibited
person in possession of a fireatm or ammunition; 18 U.S.C. g 922((} Possession'of a stolen
fitearm; 18 U.S.C. $ 922(n) Indicted person in possession of a firearm or ammunition; l8 U.S.C,
$ 875 Transmitting threatening communications; 18 U.S.C. g 371 Conspiracy; 18 U.S.C. $ 2
Aiding and abetting; and 21 U,S.C. $$ 846 Conspiracy to distribute a controlied substance and
841(a)(1) possession with intent to distribute a controlled substance; to include:
1' Evidence of membership or affiliation with the Mongols Motorcycle Club (MMC): to include
any documents, photographs, patches, dlawings, writings, or objects depicting MMC
membet's names, initials, monikers, officer roie, chapter assignment, or any other item
depicting potential gang membership, affiliation, activity or identity;
2, Rival motorcycle club lists or photographs, "gleen light" lists, murder/assault lists, witness or
confidential informant lists, inmate lists, address and telephone number lists, letters, law
enforcement reports, judgments, pre-sentencing reports, newspaper articles, computer
generated reports or printouts, legal documents, detention facility inmate number lists or
addresses for rival motorcycle clubs;
3. Vests, patches, shirts, hats, or similar items bearing the name, moniker, Iogo, or insignia of a
potential rival motorcycle club, that may have been acquired through threais or violence;
4. Firearms, magazines, and ammunition;
5. Body armor, to include: ballistic vests, plates, panels or plate caniers;
6. controlled substances, drug packaging material, paraphemalia and scales;
7. United States cumency;
8. Documentaty evidence of drug trafficking, to include records, receipts, notes, ledgers, money
orders, pre-paid money cards such as MoneyPak, Green Dot, Wal-Mart, or other:debit cardi
and any documents relating to transporting, ordering, purchasing or distributing drugs;
9. Cellular telephones and other digital devices, such as computers, laptops, tablets, pDAs or
similar electronic storage devices;
10. Articles of property tending to establish the identity of persons in control of premises,
vehicles, storage Eueas, and containers being searched, inciuding utility companf receipts,
rent receipts, addressed envelopes, and keys; and
11. Safes, combination or key-lock strong boxes or other secure storage containers, and types of
-
locked or containers, and hidden compafiments that may contain any of the foregoing.-
Attachment B
1[,[*Tv\
ATTACHMENT A-2
Person to be searched: WILLTAM LEE WESTFALL, aka: ,,SHoTSr', who appears in the
photographs below. The Defendant will be searched for tattoos evidencing membirship in or
association with the Mongols Motorcycle CIub or any other gang.
Premises to be searched: Subject Premises A-2, Iocated at 3325 Montclaire Drive NE,
Albuquerque, New Mexico. Subject Premises A-2 may be desoibed as a single-story residence
with tan stucco and tanlbrown rock siding. The attached garage has a white door and the trim on
the house is white and maroon. The numbers "3325" are posted on the sidewalk/curb in front of
the residence. There are multiple cameras affixed the exterior of the residence. Color
photographs of Subject Premises A-2 have been attached hereto.
The search of the Subject Premises shall include the entire residence and all outbuildings, trash
cans, storage containers, and vehicles parked at, or in front of, the Subject Premises.l
I OltV vehicles parked at, or in front of the Subject Premises and having an apparent connection to the
Subject Premises will be searched. Connection to the Subject Premiseshay bi established by way of
prior law enforcement observation, vehicle registration, subject admission or possession of an ignition
key.
{,{r/Y\ Attachment A-2

ATTACHMENT A.2
Qellular Telephone Biometric Features: During the execution of the search of the premises
described herein, law enforcement are also specifically authorized to compel MLLIAM LEE
WESTFALL, aka: *SHOTS," to provide biometric features, including pressing fingers
(including thumbs) against and/or putting a face before the sensor, or any ofuei securily feal,e
requiring biometric recognition, of:

b. Where the devices are limited to those which are capable of containing and
reasonably could contain fmits, evidence, information, contrabandl or
instrumentalities of the offense(s) as described in the search warrant affrdavit and
warant attachments
for the purpose of attempting to unlock the devices' security features in order to search the
contents as authorizcd by this warraot.
This wartant does not authorize law enforcement personnel to compel any other individuals
found at the premises to provide biometric features, as described in the prr."dirrg paragraph, to
access or otherwise unlock any device. Further, this warrant does not authorize law enforciment
personnel to request that WILLIAM LEE WESTFALL, aka: *SHOTS,' state or othenrise
prwide the password or any other means that may be used to unlock or access the devices,
including
!r i{entifying the specific biometric characteristics (including the unique finger(s) or
other physical features) that may be used to unlock or access the devices.
/a/'f/v\ Attachment A-2

ATTACHMENT B
Items to be Seized
Items to be Seized: Al1 evidence, fruits, and instrumentalities of violations ofl 18 U.S.C.
$
1962(c) Racketeer Influenced and Comrpt Orgarnzatrons (RICO); 18 U.S.C. g 1959(a) Violeni
Crimes In Aid of Racketeering (VICAR); 13 U.S.C. ilsr Interference witt
5 by
-$
threats or violence; 18 U.S.C. $ 931 Possession of body armor by a violent felon;"ommerce
18 U.S.C.
924(c) Use of a firearm in fuilherance of a crime of violence; ia U.s.C. g 922(9) prohibite;
person in possession of a firearm or ammunition; 18 U.S.C. 922(j) Possession of a stolen
S
firearm; 18 U.S.C. $ 922(n) Indicted person in possession of a firlearm or ammunition; 18 U.S.C.
$ 875 Transmitting threatening communications; 18 U.S.C. g 371 Conspiracy; 18 U.S.C. $ 2
Aiding and abetting; and 21 U.S.C. $$ 846 Conspiracy to distribute u rontotird substance and
841(a)(1) possession with intent to distribute a controlled substance; to include:
1. Evidence of membership or affiliation with the Mongols Motorcycle Club (MMC): to include
any documents, photographs, patches, dmwings, writings, or objects' depicting MMC
member's names, initials, monikers, officer role, chaptei assignment, or any other item
depicting potential gang membership, affiliation, activity or identity;
2. Rival motolcycle club lists or photographs, "green light" lists, murder/assault lists, witness or
confidential informant lists, inmate lists, address and telephone number lists, letters, law
enforcement reports, judgments, pre-sentencing reports, newspaper articles, computer
gelterated repofis or printouts, legal docurnents, detention facility lnmate number lisis
or
3. Vests, patches, shirts, hats, or similar items bearing the name, moniker, logo, or insignia of a
potential lival motorcycle club, that may have been acquired thr.ough threats or violence;
4. Firearms, magazines, and amrnunition;
5. Body armor, to include: ballistic vests, plates, paners or plate caniers;
6, controlled substances, drug packaging material, paraphemalia and scales;
7. United States crurency;
8. Documentaty evidence of drug trafficking, to include records, receipts, notes, ledgers, money
orders, pre-paid money cards such as MoneyPak, Green Dot, Wal-Mart, or other debit cards
and any documents relating to h'ansporting, ordering, pulchasing or distributing drugs;
9. Ceilular telephones and other digital devices, such as computers, laptops, tablets, pDAs or
similar electronic storage devices;
vehicles, storage &reas, and containers being searched, inciuding utility company .eceipts,
rentreceipts, addressed envelopes, and keys; and
11. Safes, combination or key-Iock strong boxes or other secure storage containers, and types
of
loclced or containers, and hidden compafiments that may contain any of the foregoing.- -
Attachment B
ATTACHMENT A.3
Person and Premises to be Sear.ched
Person to be searched: ISAIAH MATTHEW CHAVEZ, akaz *EK,,, aka: ,.HARI)ONr,,

who
appears in the photographs below. The Defendant will be searched for tattoos evidencing
membership in or association with the Mongols Motorcycle Club or any other gang.
Premises to be searched: Subject Premises A-3, located, at2844 John Street SE,
Albuquerque,
New Mexico. Subject Premises A-3 may be described as a single-story residencl with red brick
siding and tan trim. There is a tan security door over the front door. The numbers 2844 are
posted on the front porch and on the mailbox in front of the residence. Color photographs
of
Subject Premises A-3 have been attached hereto.
The search of the Subject Premises shall include the entire residence and all outbuildings,
trash
cans, storage containers, and vehicles parked at, or in front of, the Subject premises.l
'- Oltv vehicles parked at, or in front of, the Subject Premises and having an apparent connection to the
Subject Premises will be searched. Connection to the Subject Plemises-may be established by
way of
prior law enforcement observation, vehicle registration, subject admission or possession of
an ignition
key.
Y{f/Y\ Attachment A-3

ATTACHMENT A.3
Cellular Telephone Biometric Features: During the execution of the search of the premises
described herein, law enforcement are also specifically authorized to compel fsAfaft
MATTHEW CHAVEZ, aka: "EK," aka: "HARDON," to provide biometric features, including
pressing fingers (including thumbs) against and/or putting a face before the sensor, or any othei
security feature requiring biometric recognition, of:

b. Where the devices are limited to those which are capableof containing and
reasonably could contain fruits, evidence, information, contraband, or
instrumentalities of the offense(s) as described in the search warrant affidavit and
warrant attachments
for the purpose of attempting to unlock the devices' security feafures in order to search the
contents as authorized by this warrant.
This wanant does not authorize law enforcement personnel to compel any other individuals
found at the premises to provide biometric features, as described in the p.""lding paragraph, to
access or otherwise unlock any device. Further, this warrant does not authorize lawenforciment
pelsonnel to request that ISAIAH MATTHEW CHAyEZ,aka: ..EK,', aka: .,HARDQN,,'state or
otherwise provide the password or any other means that may be used to unlock or access the
devices, including by identifiing the specific biometric characteristics (including the unique
finger(s) or other physical features) that may be used to unlock or access the devices.
firtv\ Attachment A-3

ATTACHMBNT B
Items to be Seized
Items to be Seized: All evidence, fruits, and instrumentalities of violations of; 18 U.S.C.
$
1962(c) Racketeer Influenced and Comrpt Organizations (RICO); 18 U.S.C. g i959(a) Violent
Crimes In Aid of Racketeering (VICAR); 18 U.S.C. $ 1951 Interference with commerce by
threats or violence; 18 U.S.C. $ 931 Possession of body armor by a violent felon; 18 U.S.C.
b
924(c) Use of a firearnr in furtherance of a crime of violence; ig U.S.C. g 922(9) prohibite;
person in possession of a firearm or ammunition; 18 U.S.C. g2Z0 Possession of a stolen
S
firearm; 18 U.S.C. fi 922(rL) Indicted person in possession of a filearm or ammunition; 18 U.S.C.
$ 875 Transmitting threatening communications; 18 U.S.C, g 371 Conspbacy;18 U.S.C. $ 2
Aiding and abetting; and 21U,S.C. $$ 346 Conspiracy to distribute u .orrtroti"O substance and
841(a)(1) possession with intent to dishibute a conirolled substance; to include:
1. Evidence of membership or affiliation with the Mongols Motorcycle Club (MMC): to include
any documents, photographs, patches, drawings, writings, or objects' depicting MMC
member's nslmes, initials, monikers, ofEcer role, chapter assignment, or any otf,er item
depicting potential gang membership, affiriation, wtivity or identity;
2' Rival motorcycle club lists or photographs, "green light" lists, murd.erlassault lists, witness or
confidential informant lists, inmate lists, addless and telephone number lists, letters, law
enforcement reports, judgments, prc-sentencing repofis, newspaper articles, computer
gerrerated reports or printouts, legal documents, detention facility inmate'number ]ists or
3, Vests, patches, shirts, hats, or similar items bearing the name, moniker, logo, or insignia of a
potential rival motorcycle club, that may have been acquired through threais or vioience;
4. Firearms, magazines, and ammunition;
5. Body armor, to include: ballistic vests, plates, paoels or prate caniers;
6. controlled substances, drug packaging material, paraphernalia and scales;
7. United States curency;
8. Documentary evidence of drug trafficking, to include recoLds, receipts, notes, ledgers, money
orders, pre-paid money cards such as MoneyPak, Green Dot, Wal-Mart, or other debit car.ds
and any documents relating to transporling, ordeling, purchasing or distributing drugs;
9. Cellular telephones and othel digital devices, such as computers, laptops, tablets, pDAs or
similar elechonic storage devices;
vehicles, storage areas, and containers being searched, including utility receipts,
rent receipts, addressed envelopes, and keys; and "o*puny
I 1. Safes, combination or key-lock strong boxes or other secure storage containers, and types of
locked or containers, and hidden compartments that may contain any of the foregoing.'-
Attachment B

Federal Search Warrant Affidavit For Biker Gang

Hochgeladen von

Dokumentinformationen

Originaltitel

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Federal Search Warrant Affidavit For Biker Gang

Hochgeladen von

Copyright:

Verfügbare Formate

Case 1:20-mr-00556-KBM Document 1 Filed 04/07/20 Page 1 of 61

AO I 06 (Rev. 04/10) Application for a Search Warrant

APPLICATION FOR A SEARCH WARRANT

d Continued on the attached sheet.

Bryan Acee, FBI SpecialAgent

Electronicallv submitted and sworn before me.

AFFTDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS

RELEVANT TRAIMNG AND EXPERIENCE 4

OVERVIEW OF THE INVESTIGATION 6

BACKGROIIND ALLEGATIONS REGARDING GANGS AND DRUG TRAFFICKERS 9

THE MONGOLS MC CRIMINAL ENTERPRISE 12

THE HISTORY OF THE MONGOLS MC t4

PURPOSES OF THE ENTERPRISE 2A

MEANS AND METHODS OF THE ENTERPRISE 20

PUBLIC CORRUPTION: OUTLAW MOTORCYCLE GANGS AND LAW ENFORCEMENT 2l

STATEMENT OF PROBABLE CAUSE 26

Coaspiracy to Commit Assault in Aid of Racketeering 27

Theft of Motorcycle Vests and Patches 29

Unlawful Firearms Possession and Use of Firearms in Furtherance of Violent Crime 30

Possession of Body Armor by a Violent Felon 34

Conspiracy to Distribute Controlled Substances 34

Evidence Sougtrt Pursuant to the Requested Search Warrants 36

THE TARGET SUBJECTS 37

THE SUBJECT PREMISES 4t

BIOMETRIC ACCESS TO DEVICES 45

MANNER IN WHICH THE SEARCH WARRANTS WILL BE SERVED 49

NIGHTIME SERVICE REQUEST 50

AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS

and residences listed below:

a) CARLOS ALVARADO JR., aka: "CHUGGS," associated with Subject Premises

A-l: 1525 Larkin Road SW, Albuquerque, New Mexico;

b) WiLLIAM LEE WESTFALL, aka: *SHOTS," associated with Subject Premises

A-2: 3325 Montclaire Drive NE, Albuquetque, New Mexico; and

b) 18 U.S.C. $ 1959(a) Violent Crimes in Aid of Racketeering (VICAR);

c) 18 U.S.C. $ 1951 Interference with commerce by threats or violence;

d) l8 U.S.C. $ 931 Possession of body arnor by a violent felon;

e) 18 U.S.C. $ 92a(c) Use of a firearm in furtherance of a crime of violence or drug

0- 18 U.S.C. $ 922(g) Prohibited person in possession of a firearm or ammunition;

AFFIDAVIT IN SUPPORT OF AN APPLICATION TOR SEARCH WARRANTS

g) 18 U.S.C. $ 922(i) Possession of a stolen firearm;

h) 18 U.S.C. g 922(n) Indicted person in possession of a firearm or ammunition;

i) 18 U.S.C. $ 875 Transmitting tlueatening communications;

j) 18 U.S.C. $ 371 Conspiracy;

k) l8 U.S.C. $2 Aiding and abetting;

l) 21 U.S.C. g 846 Conspiracy to distribute a controlled substance; and

m) 2l U.S.C. $ 8a1(aX1) Possession with intent to distribute a controlled substance.

Hereinafter I will refer to the aforementioned violations as the "Target Offenses."

membership in or association with the MONGOLS MOTORCYCLE CLUB, and to photograph

such photographic evidence during gang-racketeering jury trials in the past.

relevant background information. During my investigation, I have developed information I

AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS

Drug Enforcement Administration (DEA); Bureau of Alcohol, Tobacco, Firearms and

physical surveillance; information provided by undercover agents and informants; information

RELEVANT TRAINTNG AND EXPERIENCE

AFFTDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS

firearms, and the indictment of multiple cartel leaders

commonly rcferred to as the "Syndicato de Nuevo Mexico" or "SNM." The investigation

than 150 SNM members and associates.

have also worked in an undercover capacity to infiltrate such criminal organizations.

participated in hundreds of investigations pertaining to drug distribution, money laundering,

AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR SEARCH WARRANTS

firearms trafficking, gangs and criminal enterprises. My investigative experience includes;

Outlaw Motorcycle Gang Investigator's Association, California Narcotic Officer's Association,