OR\G\NAl

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
UNITED STATES OF AMERICA
. CLERK, u.s. DISTRICT COURT
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CRIMINAL COMPLAINT
v.
CASE NO. 4:11-MJ- cx3\



RIGOBERTO OROZCO, (2)
alk/a "Rigo"
. .

ERIC OROZCO, (4)
a/k/a "Eddie"

HECTOR RAMOS (6)
alk/a "John Gotti"
HAROLD GRUBBS (7)
alk/a "Big D"
JO ANN HENRY (8)
IVAN CANO (9)


SARAH REYES, (11)
alk/a "Sarah Murillo"

CRIMINAL COMPLAINT
I, Andrew D. Farrell, hereinafter Complainant, being duly sworn, state the
following is true and correct to the best of my knowledge and belief:
From on or about May 25,2005, and continuing until the date of this complaint, in
the Northern District of Texas and elsewhere, defendants
, Rigoberto
Orozco, also known as Rigo, also known as Eric
Orozco, also known as Eddie, Hector Ramos, also
Complaint Page 1
I :
known as John Gotti, Harold Grubbs, also known as Big D, Jo Ann Henry, Ivan
Cano, Sarah Reyes, also known as Sarah
Murillo, and and others known and unknown, did knowingly and
intentionally combine, conspire, confederate and agree together and with each
other, and with other persons known and unknown, to possess with intent to
distribute and to distribute more than 100 grams of a mixture or substance
containing a detectable amount of heroin, a Schedule I, Controlled Substance, in
violation of21 U.S.C. 84I(a)(1) and (b)(l)(B).
All in violation of21 U.S.C. 846.
1. Complainant is a Special Agent of the FBI. I have been so employed for
approximately twenty-six (26) years and am currently assigned to the Dallas Field
Division's Fort Worth Resident Agency on a Criminal Enterprise Squad working with a
Violent Crime/Gang Task Force (hereinafter referred to as the Task Force). The Task
Force is comprised of agents, investigators and police officers from the FBI, the Drug
Enforcement Administration (DEA), the Arlington, Texas Police Department (APD), and
the Fort Worth, Texas Police Department (FWPD).
2. The statements contained in this Complaint are based, in part, on Title III
interceptions, my personal observations and on information provided by other Special
Agents of the FBI and DEA and officers of the APD, the FWPD, and other law
enforcement agencies identified below. Statements herein are also based on information
provided by cooperating sources and cooperating defendants in other related cases, all of
whom are believed by me to be reliable and credible, as set out herein, officer's review of
telephone toll records and pen registers, physical surveillance, police reports, and on my
experience and training. In an effort to protect individuals not currently charged as a
result of this or other investigations, these uncharged individuals will be referred to by
their initials, rather than their full names. Additionally, in some instances, Confidential
Sources (CS), Cooperating Defendants (CD), and Cooperating Witnesses (CW) will
appear with a numerical designation which correspond to previous affidavits submitted in
support of the applications for the TIlls.
3. In 2007, CS5, a long established FBI source, who had consistently provided
truthful and accurate information and whose information has been used in both state and
federal affidavits, began providing information to the Complainant concerning the Fort
Worth area drug activity of CS5 reported that was
selling $20,000 worth of heroin a day in the North Fort Worth area and provided specific
details of activities, including the daily schedule of
couriers and the cars the. couriers were using. Due to the commitments of an ongoing
Complaint Page 2
investigation, the information regarding drug activity was initially
provided by the Complainant to the DEA, Fort Worth Resident Office and DEA
investigators initiated an investigation of criminal activities.
4. On November 9, 2008, Fort Worth Police Department officers and agents of
Immigration Customs and Enforcement (ICE) approached the business of
at 1399 Jacksboro Highway, Fort Worth, Texas. As the officers and agents
approached the business, ran to his vehicle and make a throwing motion
with is arm. A search of the area around where made the throwing motion
located a green zip lock baggie containing 1.8 grams of a black tar-like substance.
was arrested. Eric Orozco was also at the business with two other males.
was supposedly in the hospital. A search warrant was obtained for the
business. The search located $590 in cash in the glove compartment of Eric Orozco's
car, a 2001 Cadillac four door, Texas license 327TLF, registered to
wife Araceli Orozco. The search also located a clear plastic baggie containing six small
bags of heroin, located in the ceiling of the businesses' office, a green baggie containing
heroin, located on a shelf in the middle hall, a green baggie containing heroin, located on
the floor ofthe work area, and several blue and red "Apple" baggies in a Zip Lock box.
An examination by the Fort Worth Police Department Crime lab determined that the
baggie thrown by weighed 2.52 grams containing heroin and the baggie from the
ceiling weighed 0.20 grams containing heroin.
5. In January 2009, the Complainant began investigating the criminal activities
of the Orozco Drug Trafficking Organization (ODTO), focusing mainly on the
activities of Rigoberto Orozco. Based on a review of police reports and interviews with
cooperating informants, cooperating defendants and arrested individuals, investigators
determined that Rigoberto Orozco and were actively involved in various
criminal activities in the Fort Worth, Texas area. The criminal activities for Rigoberto
Orozco included the acquisition and sale of illegal narcotics, mainly cocaine, and the sale
of the cocaine to customers, including customers outside of the state of Texas. As
detailed above, the criminal activities for included the acquisition and
sale of illegal narcotics, mainly heroin, and the sale of the heroin mainly in the Fort Worth
area.
6. On February 11,2009, an officer of the FWPD arrested Sarah Reyes, also
known as Sarah Murillo. Throughout the Fort Worth Police Department reports for this
arrest Reyes is referred to by her alias, Sarah Murillo. The officer stopped Reyes for a
traffic offense. The officer observed Reyes, the driver of a 1997 Buick, make multiple
furtive movements toward the floorboard of the Buick. When the officer made contact
with Reyes, she appeared nervous and fidgety. The officer removed Reyes from the
Complaint Page 3
Buick and searched the immediate area around where she had been seated. The officer
located a clear plastic baggie containing a black tar-like substance.
accompanied Reyes in the Buick. Reyes identified as her roommate
and asked that her children, who were also in the Buick, be released to
An examination of this evidence by the Fort Worth Police Department crime lab
determined that the evidence was .38 grams of a mixture or substance containing heroin.
7. On March 19,2009, an officer of the Fort Worth Police Department
conducted a traffic stop of a vehicle driven by an individual, who later agreed to
cooperate. A search of the vehicle located drug paraphernalia consisting of a black case
containing syringes. Since the cooperator did not want an arrest for possession of drug
paraphernalia on his record, he offered to order heroin from his supplier. The cooperator
placed a call to "Jo Ann" and order $60 worth of black tar heroin. When the supplier
came to meet the cooperator at the prearranged location, Jo Ann Henry was the driver of
the delivery car and was the passenger. told the
officers that she had one baggie of heroin under her phone in the door handle pocket of
the passenger door. Officers found an additional baggie containing three small bags of
heroin in the glove compartment. The officers arrested The
officers reviewed Henry's cell phone, which was located in the center console and
observed the calls from the cooperator to set up the heroin purchase in the phone's call
history. Henry was also arrested. The FWPD Crime Lab examined the evidence and
identified the substance in the baggie located with phone as .05 grams
containing heroin and the substance in the three baggies located in the glove box as 1.10
grams containing heroin.
8. On June 2, 2009, investigators from the DEA Fort Worth Resident Office
established surveillance of the known business of an auto body shop
located at 1399 Jacksboro Highway, Fort Worth, Texas. During the surveillance, several
vehicles were observed departing the business, including a vehicle being driven by AJ. A
traffic stop of AJ, who was driving a white Chevrolet, bearing Texas license MSW-I00,
led to the seizure of DE A Drug Exhibit 1, described as approximately 24.2 grams of
heroin.
9. On June 23,2009, DEA TFO Alicia Luna and a confidential source met
with FR and LR, who had been identified by multiple cooperating sources as heroin
couriers working for at the CVS pharmacy, 2706 Jacksboro Highway,
Fort Worth, Texas. FR and LR arrived in a black Chrysler two door. TFO Luna and the
source purchased black tar heroin, identified as DEA Drug Exhibits 2 and 3, from the FR
and LR for $120.00 in US currency. DEA Drug Exhibit 2 weighed 31.9 grams and DEA
Drug Exhibit 3 weighed 32 grams.
Complaint Page 4
--------------- -----------------_.-
10. On July 9,2009, TFO Alicia Luna placed a consensually monitored phone
call to LR, who was using telephone number 817-902-7061. During the phone
conversation TFO Luna and LR discussed amounts and prices for future heroin
transactions. TFO Luna told LR that she was sending the heroin to Atlanta, Georgia. In
response, LR told TFO Luna that he already had people in place in Atlanta, Georgia to
distribute heroin. The call was recorded on DEA Non-Drug Exhibit N-4.
11. On July 14,2009, TFO Luna, acting in an undercover capacity, met with FR
and LR at the CVS phannacy, 2706 Jacksboro Highway, Fort Worth, Texas. FR and LR
arrived in a green Toyota Camry, Texas license V73FYT, registered to LL, 2517 NW
28th Street, Fort Worth, Texas. TFO Luna purchased DEA Drug Exhibit 4,
approximately 44.8 grams of black tar heroin, from FR and LR for $1,500.00 in US
currency. An examination of DE A Drug Exhibit 4 by the South Central DEA Laboratory
in Dallas detennined that the exhibit contained heroin hydrochloride and the exhibit's
gross weight was 45.5 grams, net weight was 11.8 grams, purity of the exhibit was 30.3%
and the actual amount of the heroin was 3.5 grams.
12. On December 11,2009, members of the FBI Fort Worth Resident Agency
and DEA Fort Worth Resident Office seized DEA Drug Exhibit 7,871 grams black tar
heroin from a Confidential Source in Fort Worth, Texas. The source reported that
had given the source the heroin. had directed the source
to take the heroin back to Laredo, Texas, due to the poor quality of the heroin. After the
source returned the poor quality heroin, the source was supposed to pick up a new supply
of heroin. An examination of DE A Drug Exhibit 7 by the South Central DEA Laboratory
in Dallas detennined that the exhibit contained heroin hydrochloride and the exhibit's
gross weight was 870.2 grams, net weight was 649.2 grams, purity of the exhibit was
4.9% and the actual amount ofthe heroin was 31.8 grams.
13. In September 2009, FBI investigators were contacted by the DEA's Fort
Worth Resident Office regarding the Orozcos. After this contact, the Fort Worth DEA
and Fort Worth FBI began a joint investigation into the criminal and drug distribution
activities of the Orozcos and their associates.
14. On October 1,2009, a Fort Worth Police officer observed a narcotics
transaction as it occurred at 1500 Human, Fort Worth, Texas. The officer observed a
customer approach a white Toyota Camry, Texas license BB5W360, registered to LL
with a new license. The customer handed the driver, later identified as Hector Ray
Ramos, money and Ramos handed the customer a small baggie. The witnessing officer
requested that another Fort Worth Police Department marked unit conduct a traffic stop
of the white Toyota. After the marked unit had stopped the Toyota and as the officer
Complaint PageS
approached the car, the officer observed Ramos "messing" with the visor above the
driver's seat. When the officer made contact with Ramos, he was extremely nervous.
After the officer told Ramos that an undercover officer had observed the sale, Ramos
told the officer where the drugs were located. The officer located a plastic sandwich bag
tucked into the Toyota's head liner above the driver's side visor. The sandwich bag
contained sixteen (16) smaller clear and green baggies which appeared to contain heroin.
The total weight ofthe evidence was 8.2 grams. Ramos admitted to the officer that he
had additional heroin hidden in his shoe. The officer found an additional baggie which
contained.2 grams of heroin. An examination by the Fort Worth Police Department
Crime lab determined that the small clear baggies contained 1.47 grams of heroin and the
green baggies contained 3.55 grams of heroin. The lab did not test the baggie from
Ramos' shoe.
15. Beginning in December 2009, investigators began to receive information
from a source, who had close access to The source provided
information which outlined heroin operation in the Fort Worth area.
After debriefing this source on a number of occasions over the course of this investigation
and verifying the information provided by this source through surveillance, review of
police reports, debriefings of other sources and cooperators and other means, the
investigators believe that this source is credible and reliable. The source reported that
was using a number of Fort Worth area women as heroin couriers.
would provide the couriers with a bus ticket to Laredo, Texas. Once in
Laredo, the couriers would walk across the border, meet a Mexican male, who would
provide the couriers with heroin, who would then walk back across the border into the
United States. The couriers would return to the DallaslFort Worth area on the bus, where
would meet the courier to obtain the heroin. would pay
the couriers for their trips. The source reported that had a number of
workers, who would sell the heroin around Fort Worth, Texas. These workers included
Harold Grubbs and as well as some of the female couriers. The source
knew Grubbs and to sell heroin from houses in West Fort Worth. The source
also reported that would use the couriers and other associates to send
payments to his heroin supplier in Mexico by Western Union. The courier provided the
names of some of the couriers and workers who were assisting This
source reported that after believed that one of his couriers was caught
with a large amount of heroin, fled to Mexico. While
was in Mexico, his brother, Eric Orozco took control of the heroin distribution activities
of the Orozco heroin DTO. returned to the U.S. and Fort Worth after
his son was killed in a car accident. father, MO, his wife, Araceli
Orozco, and a number of children were traveling through West Texas to visit ,
when the accident occurred.
Complaint Page 6
16. Based on the information from this source, the Complainant issued
subpoenas to Western Union seeking to verify whether the individuals identified by the
source had sent Western Union wires to Mexico. The Complainant checked border
crossing records to determine whether the individuals identified as couriers by the source
had re-entered the U.S. from Mexico. The Complainant contacted agents with the Bureau
of Immigration and Customs Enforcement ("ICE") and requested that the individuals
identified as couriers by the source and through the Western Union records be entered
into an ICE database, where the Complainant would be notified when the individuals
crossed the border into the U.S. from Mexico.
17. On February 5, 2010, DEA TFO Perry Moore and DEA SA Jim DeHass
seized DEA Drug Exhibit 8, several small zip lock type baggies, containing a brown
tar-like substance, weighing 33.40 grams, from a Confidential Source in Fort Worth,
Texas. The source reported that the source had taken the drugs from the residence of
2811 Wingate, Fort Worth, Texas. was selling heroin for
at that time.
18. On February 5, 2010, DEA TFO Perry Moore and DEA SA Jim DeHass
took custody of DE A Drug Exhibit 9, several small zip lock baggies containing a brown
tar like substance weighing 32.20 grams, and DEA Drug Exhibit 10, a small clear pipe, a
cigarette box, and several small plastic baggies, containing a brown tar-like substance
from the Fort Worth Police Property Room in Fort Worth, Texas. These exhibits were
seized by Fort Worth Police Department officers during a traffic stop of
and Jo Ann Henry in Fort Worth, Texas on March 19,2009, detailed in
Paragraph 7 above.
19. On February 25,2010, the U.S. Border Patrol at Laredo contacted the
Complainant and advised that based on her entry into the ICE database, Jo Ann Henry
was apprehended while crossing from Mexico into the U.S. Representatives of the U.S.
Border Patrol pulled Henry into a secondary search and searched her for heroin. The
Border Patrol located .75 kilos of heroin on Henry's person. An ICE duty agent
responded and conducted a short debriefing of Henry. The DEA, Laredo later
responded, took Henry into custody, and took custody of the heroin and the remaining
evidence.
20. On February 27,2010, investigators, including the Complainant,
interviewed Henry at the Webb County jail, Laredo, Texas. Henry, who had waived her
right to counsel and agreed to talk with the investigators, confirmed much of the
information the investigators had received previously from the sources listed above.
Complaint Page 7
Henry stated that in February 2007, she became a heroin customer of
who she also knew by the street name " Henry stated that
owned an auto body shop at 1399 Jacksboro Highway in Fort Worth. For a period of
time, Henry stayed at this shop. Henry then moved with into a
number of different houses owned by Henry recalled these houses to be
on Gould, 29th Street and 25th Street in North Fort Worth. Henry stated that
owned these houses, but the houses may be in the names of other people,
including wife, Araceli Orozco. While she was staying there, Henry
began to see "ounces and ounces" of heroin. Henry estimated that the most heroin she
saw was between 85 and 110 ounces. Henry only saw black tar heroin. Henry stated
that a Mexican male, known to her by the name would make the heroin and bring
it to Nuevo Laredo, Mexico, across from Laredo, Texas. couriers
would pick up the heroin from Henry estimated that her first trip to pick up
heroin was on June 1, 2008. Henry believed that she made trips to Nuevo Laredo,
Mexico on June 1,2009, June 20, 2009 and July 6,2009. Henry estimated that she
picked up a total of 100 grams of heroin on these three trips. Henry would cross into
Mexico and meet at a motel located just across the bridge, where would
rent a room. The packages of heroin were too big to carry inside of her. Henry would
hide the package on her body and walk back across the bridge. The heroin was in one big
piece and would be wrapped in silver packaging tape. Henry would travel to and from
Laredo, Texas on a Greyhound bus. would purchase the tickets for
Henry. They would take the heroin to one of "spots," where they
would break it down and package it for sale. Originally, they would take the heroin to the
shop on Jacksboro Highway in Fort Worth, Texas. They were not taking the heroin to the
shop any longer because believed the "feds" were watching the shop.
Henry knew couriers or individuals who sold the heroin around Fort
Worth to be Miguel Last Name Unknown (known to the investigators to be
Harold Grubbs, "Big D," Sarah Reyes (also known as Sarah Murillo), and
John Gotti (known to the investigators to be Hector Ramos). Henry stated that Grubbs
had been working with seIling heroin for 10 years and
described Grubbs as his "oldest soldier." Henry stated that formerly
kept military weapons, including M-16s with lasers and scopes, and body armor at the
shop. Henry further described the guns being in a green and a silver case. One of the
rifles may have been a 30.06. These items were moved in either November or December
2008. Henry stated that Harold Grubbs took the guns from the shop. Henry does not
know where Grubbs took the guns. Henry was selling between $3,000 and $4,000 worth
of heroin a day for from a Fort Worth motel. Henry stated that the
heroin sales would begin at 9:00 am and continue until 10:30 pm when the sellers would
tum in the money from the day's sales. The sellers would either pick up four (4) $600
packs of heroin at the start of the day or they would already have it from the previous
Complaint Page 8
night. Henry stated that at the direction of a number of people used
Western Union to wire money to pay for the heroin. Henry believed that
Eric Orozco, Sarah Reyes, JH, a former girlfriend of
and FR wired money. Henry stated that each person wired $2,000 each time
from various Western Union locations. Henry stated that four (4) or five (5) people
would go at one time to wire the money. Henry stated that all of the money would be
wired to possibly using the name Ramon Garcia or Garza. Henry stated that she
had recently gathered and burned all of the Western Union wire transfer receipts she
could find at the Jacksboro Highway shop. Henry estimated that she had made six (6)
trips to Nuevo Laredo to pick up heroin for the Orozcos. Each time, Henry would pick
up between fifteen (15) and eighteen (18) ounces of heroin from Henry heard
that in December 2009, one of heroin couriers was caught with 30
ounces of heroin at the bus station in Dallas. After the heroin was found,
fled to Mexico. Henry did not know the courier and had never met her. Henry believed
that one of the courier's daughters was married to and the other, possibly
named D, was married to Eric Orozco. Henry stated that during the time that
was in Mexico, Eric Orozco ran the heroin business from the shop. Henry knew
Araceli Orozco to live in a creme colored house, known to the investigators to be 5336
Lovell, Fort Worth, Texas. Henry knew that kept between $70,000 and
$100,000 at this house. Henry stated that 11 year old son, EO, was
killed in an accident involving a Chevrolet Tahoe, which would drive.
Henry stated that there was $72,000 in the front doors of the Tahoe. MO,
father, was taking the money to in Chihuahua when the
accident occurred. Henry believed that had been staying in a small town
two hours South of Juarez, Mexico. Henry believed that had a residence
in the town of Cuahtemoc, Mexico. Henry knew about the money in the doors of the
Tahoe, because she helped count the money and put in the doors. The money was
counted, put into $5,000 stacks, put into bread bags and placed into the front doors ofthe
Tahoe. They counted the money and removed the door panels at the Jacksboro shop.
Henry stated that the money came from the sale of heroin. Eric Orozco brought the
Tahoe to the shop. They also put new tires on the Tahoe and MO and Araceli Orozco
thought that the Tahoe was at the shop to get new tires. Henry alleged that neither MO
nor Araceli Orozco knew about the cash in the doors of the Tahoe.
21. After interviewing Henry, investigators learned from recorded calls at the
Webb County jail that Henry had warned that investigators had
interviewed her about Henry provided details about questions the
investigators had asked.
22. A review of ICE records for Henry located crossings under the name Jo
Complaint Page 9
Ann Henry, true Date of Birth , on July 8, 2009, at Laredo, Texas and
under the name Jo Ann Henry, Date of Birth , on February 4,2010,
January 26,2010, January 21,2010, and March 3, 2009, at the Progresso Point of Entry.
23. An examination of the heroin seized from Henry, Laredo DEA Drug
Exhibit 1, by the South Central DEA Laboratory in Dallas determined that the exhibit
contained heroin hydrochloride and the exhibit's gross weight was 816.8 grams, net
weight was 681.0 grams, purity of the exhibit was 43.3% and the actual amount of the
heroin was 294.8 grams.
24. On February 19,2010, the Complainant obtained a copy of the Texas
Department of Public Safety accident report for the February 11,2010 Ward County
automobile accident involving a 2007 tan Chevrolet Tahoe, bearing Texas license
92TJL9, registered to AO, 5336 Lovell Avenue, Fort Worth, Texas. The report indicates
that the Tahoe, driven by MO, was traveling westbound on Interstate 20 as it entered a
curve at an unsafe speed. The report also indicates that the driver, possibly fatigued or
asleep, veered left and struck a guardrail with the vehicle's left front. The vehicle slid
along the top of the guardrail where it "tripped" and flipped several times. The vehicle
was occupied by MO, AD and eight (8) children. EO, the twelve (12) year old son of
was killed as a result of the accident. The Complainant talked with
Texas Department of Safety (DPS) investigators to determine whether any cash was
discovered at the crash site. DPS investigators advised that no cash was located at the
scene and all occupants of the Tahoe had been transported to local hospitals. The
Complainant learned that the Tahoe had remained in an impound lot after the crash and
DPS investigators did not believe that any family members had been back to the Tahoe.
Later, the Tahoe was released to the insurance company and was moved to Insurance
Auto Auctions, 701 W. 81st Street, Odessa, Texas. On March 1,2010, the Complainant
requested that agents from the Midland locate and search the Tahoe at this impound lot.
The agents responded to the Insurance Auto Auctions impound lot, searched the Tahoe
and found no indication that cash had been hidden in the doors of the Tahoe, as described
by Henry. The agents described locating the factory installed plastic barriers intact on
each door of the Tahoe.
25. On March 1,2010, the Complainant reviewed an initial group of records
received from Western Union pursuant to a subpoena. The Western Union records
showed wire transfers from AO, the wife of totaling $17,300; Eric
Orozco, the brother of totaling $2,000; MG, a female associate of
totaling $4,000; and totaling $37,000. The records
reflected that these wire transfers from associates were received by ten
(10) named recipients in Nuevo Laredo or Tlacotepec, Mexico.
Complaint Page 10
26. Based on the records detailed above, the Complainant requested Western
Union records for a wider time frame. On April 12, 2010, the Complainant reviewed
records received from Western Union pursuant to the additional subpoena. The Western
Union records showed wire transfers from AO, totaling $18,200; Jo Ann Henry, a
courier for totaling $2,100; MG, an associate of
totaling $4000; totaling $38,070; and Rigoberto Orozco totaling
$1,000. A second file received from Western Union showed wire transfers from AF, a
female associate of totaling $750;
a female associate of and the mother of a child by
totaling $50,325; AO totaling $16,200; Cric (Sic Eric) Orozco totaling $2,000; DR, a
male associate of totaling $2,000; DB, a male associate of
totaling $2,000; FRA, one of workers, totaling $2,000; FR,
one of workers, described above regarding undercover purchases of
heroin, totaling $2,000; Harold Grubbs, one of workers, totaling
$1,500; Hector Ramos, one of workers, totaling $6,000; JR, a female
associate of totaling $5,000; LL, a female associate of
totaling $19,000; MG, a female associate of totaling $4000;
totaling $37,100; Sarah Murillo (also known as Sarah Reyes), a female
associate of totaling $7,000; and VBDR, a possible relative of
totaling $7,000. The Complainant noted that these records included
some of the same previously received documents. The records reflected that these wire
transfers from associates werereceived by the same ten (10) recipients
listed above in Paragraph 25 and some additional recipients in Nuevo Laredo, Acuna or
Tlacotepec, Mexico.
27. After reviewing these records from Western Union, the Complainant again
contacted agents with the Bureau of Immigration and Customs Enforcement ("ICE") and
requested that the additional individuals identified through the Western Union records be
entered into an ICE database, where the Complainant would be notified when the
individuals crossed the border into the U.S. from Mexico.
28. On April 14,2010, at the direction of members of the FBI Fort Worth
Resident Agency and DEA Fort Worth Resident Office, a Confidential Source placed a
consensually monitored phone call to a member of the Drug Trafficking
Organization to purchase a small quantity of black tar heroin. The source was able to
purchase DEA Drug Exhibit 11,23.3 grams black tar heroin, from Ivan Cano. The drug
transaction was completed at the residence located at 2012 Prairie Ave, Fort Worth,
Texas, an address located next door to 2016 Prairie, Fort Worth, an address associated by
records to Cano.
Complaint Page 11
29. On June 15,2010, IvanCano, who had been identified by a cooperating
defendant as a heroin courier for was arrested by the Fort Worth Police
Department. Two officers of the FWPD observed a 2002 Chevrolet pick up truck,
bearing Texas license 76XSP6, registered to a DG in EI Paso, Texas, and conducted a
traffic stop on this truck for an offense. While the officers followed the truck and
attempted to stop it, one of the officers observed a small brown object being thrown from
the truck. While one officer detained the driver, Cano, the second officer retrieved the
object which had been thrown from the truck. The officer retrieved a small round metal
box which contained four (4) blue baggies and five (5) white baggies. All of the baggies
contained a brown substance believed by the officers to be heroin. The officers noted that
Cano had three (3) cell phones, all of which were constantly ringing during the traffic
stop. An examination of the drugs seized during this traffic stop, which were identified as
DEA Drug Exhibit 13, by the South Central DEA Laboratory in Dallas determined that
the exhibit contained heroin, calculated as hydrochloride, and the exhibit's gross weight
was 78.6 grams, net weight was 2.0 grams, purity of the exhibit was 34.0 % and the actual
amount of the heroin was 0.68 grams.
30. In September 2010, the investigation proceeded to the court authorized
interception of cell phones used by some of the subjects. In November, investigators
conducted court ordered interceptions of two (2) cell phones, identified as Target
Telephone 2 (TT2) and Target Telephone 3 (TT3), used by Rigoberto Orozco, the
brother of The interception of these phones determined that Rigoberto
Orozco would talk to his worker, William Glenn Jones, and one of his suppliers,
using TT2 and would talk to using TT3. The
interceptions showed ,that had sold a quantity of heroin to
during the time that had borrowed TT2 from Rigoberto Orozco. After
returned TT2 to Rigoberto Orozco, would talk with
Rigoberto Orozco about and would ask Rigoberto
Orozco to have call him or visit him. Rigoberto Orozco would use
TT3 to relay these messages to Later in November 2010, when
investigators began to intercept cell phone, TT4, they learned that
and his heroin supplier, were discussing efforts to
get to pay for the heroin. had provided the heroin to
and had sold it to and
discuss that is one of the few customers who would sell
heroin. These calls are detailed below in Paragraphs 31, 32, 34 through 40.
31. On November 2, 2010 at 1 :06 p.m., Rigoberto Orozco, using TT2, placed
a PTT call to TT4 and spoke to in Spanish. The call was translated. After
greeting and discussing the weather, Rigoberto Orozco said, "Yeah, that's true, that's
Complaint Page 12
true. Hey, my friend just called me again. It's because I just got my telephone because
my brother still had it. .. " (Rigoberto Orozco is telling that his brother,
had borrowed his cell phone.)
32. On November 4,2010 at 6:50 p.m., Rigoberto Orozco, over TT2, received
a PTT call from TT4 and spoke to in Spanish. The call was translated.
After discussion about a number of other matters, asked Rigoberto
Orozco, "The radio of this, of has he gotten one. " ( asks
Rigoberto Orozco whether has gotten PTT cell phone, because
had not called As described above, had borrowed
Rigoberto Orozco's TT2, because felt his PTT cell phone could have
been compromised by law enforcement after Eric Orozco's arrest.) Rigoberto Orozco
told "I don't know, I don't know, he hasn't called. I haven't talked to him,
maybe I will talk to him tonight because my wife had a boy and I am going to the hospital
shortly. Do you want me to tell him to call you?" replied, "Yes, ifhe has,
ifhe has the radio, yes, let him know. Because he said he was going to get a radio and
that he was going to call me. Give him a holler to see what he tells you, to see if he gives
me a holler." Rigoberto Orozco answered, "Ok, it's done, I will tell him to call you."
replied, "Ok, good." ( is asking Rigoberto Orozco to tell
to call him if has obtained a PTT cell phone. Based on
this part of the conversation, investigators believe that also knows
and has had previous contact with over a previous PIT cell
phone.)
33. On November 15, 201O,investigators sought court authorization to conduct
electronic surveillance of the cell phone number used by
TT4. On November 15,2010, U.S. District Judge Terry R. Means of the Northern
District of Texas, Fort Worth, Texas, signed an Order authorizing the interceptions for a
30-day period. Interceptions began on November 15, 2010 and ended on November 28,
2010, when dropped this cell phone after observing surveillance units.
34. On November 16, 2010 at 5:31 p.m., over TT4, placed a call
to on PTT number 143*902*7775. asked
if he saw that man. affirmed and said that he went to see third party very
early and he talked with a worker he has there. said that the worker told
him not to worry and told him that the dude was there and that he didn't know why he
( had not answered ( tells
that he went to see at his shop. Initially, was not there
and talked to a worker, who told that was
around and he did not know why had not called
Complaint Page 13
said that came in shortly after that. said that
he told that he had very worried. said he
asked what was going on with him, that he ( wasn't
answering. ( got to the shop. asked why
he had not been returning his calls.) told that
told him that he would bring the check to business at seven the
following day. ( told that he will bring the payment for the
heroin to shop the next day.) says that told
him to bring his friend ( to his ( business to see it.
asked why would his friend ( want to see
business adding that all that friend wants is his check.
( asked to bring to his shop.
replied, asking why would want to see
shop. added that all wanted was payment for the heroin.)
said he told that he should have answered his phone or
called or something. said that he told not to take too long
because needed his money, he needed his check. asked if
he said it would be tomorrow. affirmed and said that third party told him
not to worry, just to give him a chance. asked, "What did he say. Did he
tell you yes? Tomorrow?" said, "Yes, that's what he said. 'No, really,
dude,' he told me 'it got .. .! got a little behind on it,' he said, 'It calmed down,' he said, 'I
don't even know why.''' ( confirmed to that
told him he would bring the payment the next day. also tells
that told him he had gotten behind on collecting for the heroin.)
said that told him that had asked his
cousin (code for Rigoberto Orozco) to tell to give him a couple more days
and that said that cousin did not tell him anything, that
all cousin said was that he hasn't seen the third party. (
had told that he had asked Rigoberto Orozco to tell that he
needed a few more days. tells that the only thing the
brother told him was that he had not seen
35. In response to this conversation, the investigators reviewed the recorded
electronic surveillance covering Jacksboro shop for November 16,
2010. The review of the recording showed a white Ford van with a distinctive roofrack,
associated to at shop on November 16,2010. The
investigators observed utilizing a white Ford van, bearing Texas license
98SVW3, registered to RT, 838 Forest Oaks, Grand Prairie, Texas.
36. On November 17,2010 at 10:4Ip.m., over TT4, placed a
Complaint Page 14
call to on PTT number 143*902*7775. told
that the guy ( came there just now. said that the
guy ( left him part of it and the guy said he would bring the rest of the
money tomorrow. ( is telling that had
given him a partial payment for the heroin had provided to
also promised to pay the remaining amount to
the following day.) asked, "How much did he give you?"
said, "He gave me nine (9 or $9,000) because he says he is also waiting on a friend to
bring another check." ( tells that paid him
$9,000 and that was waiting on the rest of the money from another
customer.) said that he didn't know if wanted
to give him what had then or tomorrow after the guy comes and
gives them the rest. said that tomorrow, because they need all of it.
said that third parties have been calling and want all of it. (When
asked whether wanted the partial payment, tells
to wait until he had the full payment, because his suppliers had been asking
for the full amount.) said that maybe tomorrow or the day after tomorrow,
with check in hand, would give the guy the other little half that was over
there. said that the guy needs to pay that one first. said
that, that is what he is saying that once the guy pays that, the guy said that he will come
with check in hand to get the other little half. ( tells that if
paid him, he would give the rest of the heroin
had on hand. tells that needed to
pay for what he already had before gives him any additional heroin.
agreed.) said that the good thing is that the guy brought
something. said that is proof that the guy is really doing work.
tells that the fact that brought him some money
at least proves that is working to sell the heroin.) said,
"Yes, right? Besides I don't think that just anyone sells that shit, dude. [UI] It's not like
the other stuff, right. The white. " agreed, saying, "You see that's the
problem. That's the problem. Not just anybody ... well know what I mean ... notjust
anyone ... " ( tells that not everyone sells heroin and it is
different than the sales of cocaine,the white stuff.) said that he has gone
around other guys and nobody wants to do anything with that. They have told
to go somewhere else. ( has offered the heroin to other customers,
but they do not want anything to do with the heroin. The customers tell him to go
somewhere else.) said that it is not like the other stuff that is more
natural. ( tells that heroin is not like cocaine, which is
easier to sell.) said that at least if the guy pays. said he
hopes that he brings everything tomorrow and takes the other, the other piece, they will be
Complaint Page 15
done with that. ( wants to pay for the heroin, even though
he is one of the few customers who sells heroin. hopes that
will bring the rest of the money for the heroin he already has. If
brings the money, will give him the rest of the heroin and
and will be done with the supply of heroin they have.) and
agreed to see each other the next day so can go get that
and third party can order the other one from said the guy
agreed to call him tomorrow. ( will pick up the money
'received from will then be able to pick up the
remaining heroin. tells that agreed to call
him the next day.)
37. On November 19,2010 at 12:20 p.m., over TT4, placed a
call to on PTT number 143*902*7775. greets
saying, "What's up, my (a nickname uses for
and said, "Ifhe gives everything to me at one time, [unintelligible]."
asked, "But do you think he will give all of that to you today?" added that
if not, will wait. Otherwise will pick that up to take it to
the guys. (Again, is hoping that will fully repay him for
the heroin he received. asks whether he thinks
will pay him the full amount. If thinks will pay,
will wait to come and get the money. If thinks
will not pay the money, will pick up what already
has from
38. On November 19,2010 at 2:22 p.m., over TT4, placed a call
to on PTT number 143*902*7775. said, "What, ? Well
no, I went by, I went by there to that fool's shop, his worker told me ( that
he hadn't gotten there." said that he waited there about 30 minutes and then
returned to his place with (Based on other calls, is an individual who helped
tend to his fighting cocks at a Fort Worth residence.) said,
" .. .I told his ... his worker there, I told him to have him call me as soon as he got there or to
come here where I am, the roosters." said he would be waiting for him.
( is telling that he went to see at his shop.
worker told that was not there.
told the worker to call him or to visit him. told the worker to tell
that was waiting for him.)
39. On November 20,2010 at 1 :44 p.m., overTT4, placed a call
to on PTT number 143*902*7775. asked, "The one with
Complaint
Page 16
the little black one ... anything? " said, "Call the guy with the little black
one, okay, so we can do ... we can get something." ( is asking
whether he has heard anything from
40. On November 20,2010 at 9:48 p.m., over TT4, placed a call
to on PIT number 143*902*7775. asked, "Did the one
with the little black one ever call you after all?" said, "The fool said he'll
come by tomorrow to see me." said he hoped so. said that
he hoped tomorrow, Sunday, becomes a happy day. asked
what did third party ( tell and if third party (
told tomorrow. ( again asks
whether he had heard from concerning the money he owed them for
heroin. replies that told him he would come by the next
day. Both and hope that does come by
and pay.) affirmed and said, "'I'm here collecting everything' he said, 'but
tomorrow I will come by to see you over there'" ( quoted
saying that told that he was collecting from his customers
for the heroin and he would be by the next day to see
41. On December 8,2010, the Complainant and other investigators debriefed a
cooperating defendant (identified in previous affidavits in support of the T III
applications as CD13), who was attempting to reduce his sentence for criminal activities.
This CD13 reported that Eric Orozco had been arrested in Houston while trying to sell
one kilo of cocaine. When asked how he learned about this arrest, CD13 stated that a
relative ofRigoberto Orozco's wife, Margarita Monrreal had told CD13 about the arrest.
The relative told CD13 that Eric Orozco had called and asked the relative to accompany
him to Houston for the sale of the kilo of Cocaine. Eric Orozco offered the relative
$1,000 to go with him to Houston. The relative declined to go with Eric Orozco. After
the relative refused, Eric Orozco called some others to go with him to Houston. CD13
did not know who had accompanied Eric Orozco. CD13 knew Eric Orozco. CD13 met
Eric Orozco through Sarah Reyes. When asked how Eric Orozco knew Sarah Reyes,
CD13 advised that Eric Orozco was supplying Reyes with Ice/methamphetamine. Reyes
had told CD13 that someone owed Eric Orozco's brother, money and
instead of paying in cash, the person had paid with ten (10) pounds of
Ice. and Eric Orozco were trying to sell the Ice and Eric Orozco would bring
some of the Ice to Reyes, who is an Ice user. CD13 also knew Eric Orozco to sell
heroin. Occasionally, Eric Orozco would buy heroin from CD13. Eric Orozco would
buy a quarter ounce of heroin at a time from CD13. CD13 knew to also
sell heroin. CD13 believed that was getting his heroin from across the
Mexican border. CD13 had heard that the last girl that had sent to the
Complaint Page 17
border to pick up heroin, had been arrested. CD13 was not sure if
changed the way he got his heroin after this arrest. CD13 had heard that the courier was
allowed to cross into the U.S. with the heroin and she was then arrested. CD13 believed
that may have been at the border when this arrest happened. CD13 knew
that Reyes had made a run to the border to pick up heroin for CD13
believed that this trip may have occurred in April or May of201O. CD13 also believed
that and Reyes flew to Laredo, Texas. CD13 did not know whether they
flew using their real names. accompanied Reyes to the border.
sent Reyes across the border to a motel on the Mexican side. While Reyes was
in the room, the heroin courier came to the room and dropped off the heroin. Once the
heroin was delivered, Reyes became afraid and refused to smuggle the heroin across the
border. Reyes called and told him that she would not carry the heroin
across. Reyes told that he needed to get someone else to carry the heroin
across. CD13 does not know what happened to the heroin or whether
was able to get someone else to carry the drugs across. CD13 stated that while she was in
Mexico, Reyes called him crying and asking what she should do. CD13 supposedly told
her that he could not tell her what to do. CD13 knew of one other trip, where
wanted Reyes to carry heroin across the border. CD13 stated that
picked Reyes up and began driving South on Interstate 35. When they arrived in
Austin, Reyes told that she did not want to carry the drugs. Reyes exited
the car along the highway and called CD13. CD13 wired Reyes money and she returned
to Fort Worth. CD13 estimated that this occurred in June 2010. At the same time Reyes
would hold heroin for CD13, Reyes was holding heroin and Ice for and
Eric Orozco. CD13 believed that couriers were picking up between
one and one and a half pounds of heroin on each trip. CD13 believed that
had other women helping him as couriers. CD13 also knew that
was using his couriers to send money to his heroin suppliers by Western Union. CD13
had heard through a friend that her cousin had been sending money to Mexico for
CD13 thought that may have had a baby with this girl.
42. On March 25,2011, the Complainant received a call indicating that
was crossing at the Eagle Pass Point of Entry #1, Eagle Pass, Texas.
was accompanied by Rachel Rae Skidmore, who was unknown to the
investigators at this point. The two women were pulled into a secondary search which
located .56 kilograms of heroin on Skidmore. refused to cooperate
during an interview. Skidmore did cooperate.
43. Following her arrest, Skidmore was interviewed by investigators. Skidmore
reported that she first met when she was 12 years old in Fort Worth,
Texas. Skidmore knew that supplied heroin to numerous people who
Complaint Page 18
worked for him and resold the heroin to users. opened a paint and body
shop in Fort Worth in was selling large quantities of heroin
during this period of time. Skidmore knew that would pay for a house
and put people in it to sell heroin to users. Skidmore did not know how many houses
had set up, but believed there were several houses in operation at the
same time. Skidmore saw with at this paint and body
shop. The paint and body shop had recently closed because had triple
bypass heart surgery. Skidmore believed that heroin business had
declined since the shutdown of the paint and body shop. approached
Skidmore and asked if she would be interested in transporting heroin on a bus from
Weatherford, Texas to Fort Worth, Texas. Skidmore decided that she would pick up the
heroin in order to make some money. girlfriend,
two children, and , identified by
investigators as traveled to San Antonio, Texas. Skidmore was told
that needed heroin transported from Piedras Negras across the border
into the US and then to San Antonio, Texas. told Skidmore that she was
going to pick up 20 ounces of heroin. Skidmore was to be paid $2,000 for smuggling the
heroin into the US. Skidmore and traveled by bus to Eagle Pass, Texas.
After arriving in Eagle Pass, Skidmore and walked across the bridge into
Piedras Negras, Coahuila, Mexico. They met a Hispanic female and walked to a hotel
where the Hispanic female had rented a room. The Hispanic female and Skidmore went
into the bathroom to conceal the heroin on the body of Skidmore. The heroin was
packaged as one large bundle which made concealment very difficult. Skidmore was
unable to adequately conceal the heroin in the short period of time that they were able to
stay in the hotel room. Skidmore, and the Hispanic female left the hotel
and walked approximately three blocks to another hotel. rented a hotel
room at the Luxury Inn Hotel so that the heroin could be sufficiently concealed for
crossing into the US. Skidmore and then left the hotel for the Point of
Entry (POE). Skidmore explained that the heroin did not conceal very well because of its
bulk. Skidmore and were placed into secondary inspection at the POE
and the heroin was discovered. Orozco's brother, Eric Orozco, sold methamphetamine
to Skidmore during May, June, and July of2010. Skidmore purchased one quarter to one
half ounce of crystal methamphetamine every day during this period oftime.
Based on the foregoing, the Complainant believes that probable cause exists that
Complaint Page 19
also known as
Rigoberto Orozco, also known as Rigo, also known as
Eric Orozco, also known as Eddie, Hector Ramos, also
known as John Gotti, Harold Grubbs, also known as Big D, Jo Ann Henry, Ivan Cano,
also known as M, Sarah Reyes, also known as Sarah Murillo, and
have committed offenses involving violations of Title 21, United States
Code, Section 84 1 (a)(I)(Possession ofa Controlled Substance with the Intent to
Distribute); United States Code, Section 846 (Conspiracy to Possess with Intent to
Distribute a Controlled Substance); and Title 18, United States Code, Section 2 (Aidi _
and Abetting the above-described offense . i)
drew D. Farrell, Special Agent,
Federal Bureau of Investigation
Sworn to before me and subscribed in my presence, July ~ 2011, at Fort Worth,
Texas, at 3:/0 o'clock, p.m.
Complaint
~ l L ... , ..... EJEFFREYL. CURETON
TATES MAGISTRATE JUDGE
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