Case 2:17-cr-00304-JLL Document 1 Filed 12/09/16 Page 1 of 4 PageID: 1

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon. Leda Dunn Wettre

v. : Mag. No. 16-8199

LUIS CALDERON,
a/k/a “Lagrima” : CRIMINAL COMPLAINT

I, Philip Castrogiovanni, being duly sworn, state the following is true and
correct to the best of my knowledge and belief:

SEE ATTACHMENT A

I further state that I am a Special Agent with the Department of

Homeland Security, Homeland Security Investigations, and that this complaint
is based on the following facts:

SEE ATTACHMENT B

continued on the attached page and made a part hereof.

Special A nt Philip Castrogiovanni

Depart nt of Homeland Security
Homeland Security Investigations

Sworn to before me and subscribed in my presence,

December 9, 2016 at Newark, New Jersey

HONORABLE LEDA DUNN WERE L

UNITED STATES MAGISTRATE JUDGE ignature of Judicial Officer
 Case 2:17-cr-00304-JLL Document 1 Filed 12/09/16 Page 2 of 4 PageID: 2

ATTACHMENT A

Count One
(Conspiracy to Distribute Methamphetamine)

From in or around October 2015 through in or around November 2015,

in Middlesex County, in the District of New Jersey, and elsewhere, defendant

LUIS CALDERON,
a/k/a ccLagrima

did knowingly and intentionally conspire and agree with others to distribute
and to possess with intent to distribute 50 grams or more of
methamphetamine, a Schedule II controlled substance, contrary to Title 21,
United States Code, Sections 841(a)(1) and 841(b)(1)(A).

In violation of Title 21, United States Code, Section 846.

Count Two
(Conspiracy to Distribute Heroin and Cocaine)

From in or around October 2015 through in or around November 2015,

in Middlesex County, in the District of New Jersey, and elsewhere, defendant

LUIS CALDERON,
a/k/a “Lagrima”

did knowingly and intentionally conspire and agree with others to distribute
and to possess with intent to distribute (1) a quantity of a mixture and
substance containing a detectable amount of heroin, a Schedule I controlled
substance, and (ii) a quantity of a mixture and substance containing a
detectable amount of cocaine, a Schedule II controlled substance, both
contrary to Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C).

In violation of Title 21, United States Code, Section 846.

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ATTACHMENT B

I, Philip Castrogiovanni, am a Special Agent with the Department of

Homeland Security, Homeland Security Investigations (“HSF). I am fully
familiar with the facts set forth herein based on my own investigation, my
conversations with law enforcement officers and others, and my review of
reports, documents, and items of evidence. Because this complaint is being
submitted for a limited purpose, I have not set forth each and every fact that I
know concerning this investigation. Where I assert that an event took place on
a particular date, I am asserting that it took place on or about the date alleged.
Where statements of others are related herein, they are related in substance
and in part.

1. As part of an ongoing investigation into a drug trafficking

organization, HSI has lawfully obtained recorded telephone conversations and
text messages involving targets of the investigation.

2. One of the targets of the investigation is defendant Luis Calderon,

a/k/a “Lagrima” (“Calderon”). Calderon is a member of the violent
international street gang MS- 13.

3. At all times relevant to this complaint, Calderon was incarcerated

at the Calipatria State Prison in Calipatria, California (the “Calipatria State
Prison”). During this conspiracy, Calderon had access to, and used, a
contraband cellular telephone assigned a telephone number ending in 2884
(the “Contraband Cell Phone”).

4. Between on or about October 27, 2015 and on or about November

4, 2015, Calderon, using the Contraband Cell Phone, participated in a number
of recorded telephone conversations and exchanged a series of text messages
with an MS-13 member in Middlesex County, New Jersey (“Individual-i”).

5. For example, during one of the recorded telephone calls, Calderon

told Individual-i that he wanted Individual-i to distribute controlled
substances supplied by a third-party, including crystal methamphetamine and
heroin, and then split the narcotics proceeds with Calderon. Later, an MS-13
member from Los Angeles, California (“Individual-2”) participated in the
recorded telephone call using the three-way-calling feature. After Individual-2
joined the call, the three discussed distributing multiple kilograms of controlled
substances, among other topics.

6. Over the course of several telephone calls and text messages,

Calderon and Individual-i arranged for a package containing controlled
substances to be sent to a package and shipping business center in Edison,
New Jersey (the “Business Center”), where Individual-i would retrieve the
narcotic s-laden package.
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7. Shortly before the package arrived, Calderon called Individual-i

using the Contraband Cell Phone. After introducing himself as “Lagrima,”
Calderon informed Individual-i that he was sending Individual-i a package
containing four ounces each of “heroin” and “coke” [cocaine]. Calderon stated
that the package would also likely contain “two [ouncesJ or more of crystal
[methamphetaminej.” Calderon told Individual-i that the total cost for the
heroin, cocaine, and crystal methamphetamine was $9,000. Calderon stated
that Individual-i could keep the proceeds Individual-i made from selling the
illegal substances once Individual-i paid Calderon the $9,000 for the
shipment. Individual-i agreed. Calderon told Individual- i that the package
would be arriving in the near future, and that the sender listed on the package
was “Jairo Ruiz from Los Angeles.”

8. A couple of days later, Calderon, using the Contraband Cell Phone,

sent a text message to Individual- i containing a tracking number ending in
8615US for the package.

9. On or about November 4, 2015, HSI agents lawfully intercepted

and seized a Priority Mail Express package bearing a tracking number ending
in 8615US that had been sent to the Business Center (the “Package”). The
Package was addressed to “Jairo Ruiz”; the sender of the package was listed as
“Maria Rodriguez” of Los Angeles, California.

10. HSI agents lawfully searched the Package and recovered the
following controlled substances from inside a box of Little Debbie Swiss Rolls:
approximately 95.5 grams of heroin; approximately 54.7 grams of cocaine; and
approximately 52.4 grams of methamphetamine. Subsequent laboratory
analysis confirmed the composition and weight of the controlled substances.

ii. On or about the morning of November 4, 2015, officers at the

Calipatria State Prison conducted a search of the prison cell occupied by
Calderon and another individual. During the search, officers confiscated a
black Samsung cellular telephone from Calderon’s cell. Records indicate that
the Contraband Cell Phone is a Samsung Galaxy cellular telephone.

12. Cell-site records associated with the Contraband Cell Phone

indicate that the Contraband Cell Phone was in the vicinity of the Calipatria
State Prison around the times the calls and text messages described above
were made and/or received.