United States v. JUAN MOISES PEREZ MENDEZ; and ODALIS EUSEBIO PERALTA BAUTISTA, Southern District of New York (Apr. 8, 2024) — Complaint

AUSAs: Maggie Lynaugh, Adam Sowlati 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
JUAN MOISES PEREZ MENDEZ, 
         a/k/a “Caballero,” and 
ODALIS EUSEBIO PERALTA BAUTISTA, 
         a/k/a “Luis Collazo Santos,” 
Defendants. 
      COMPLAINT 
      Violations of 21 U.S.C. §§ 841, 846; 18 
      U.S.C. § 2 
      COUNTY OF OFFENSE: 
      BRONX 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
STEPHANIE RICHMAN, being duly sworn, deposes and says that she is a Special Agent 
with Drug Enforcement Administration (“DEA”), and charges as follows: 
COUNT ONE 
(Conspiracy to Distribute Narcotics) 
1.From at least in or about September 2022 through at least in or about April 2024,
in  the  Southern  District  of  New  York  and  elsewhere,  JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  
“Caballero,” and ODALIS EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,”    the 
defendants,  and  others  known  and  unknown,  knowingly  and  intentionally  combined,  conspired, 
confederated, and agreed together and with each other to violate the narcotics laws of the United 
States. 
2.I
t  wa
s  a  part  and  an  object  of  the  conspiracy  that  JUAN  MOISES  PEREZ
MENDEZ,  a/k/a  “Caballero,” and ODALIS  EUSEBIO  PERALTA  BAUTISTA,  a/k/a “Luis 
Collazo  Santos,” the  defendants,  and  others  known  and  unknown,  would  and  did  distribute  and  
possess with intent to distribute controlled substances, in violation of Title 21, United States Code, 
Section 841(a)(1). 
3.The controlled substances involved in the offense were: (i) 400 grams and more of
mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United 
States  Code,  Section  841(b)(1)(A);  and  (ii)  500  grams  and  more  of  mixtures  and  substances  
containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in 
violation of Title 21, United States Code, Section 841(b)(1)(A).  
(Title 21, United States Code, Section 846.) 
24 MAG 1408

2 
COUNT TWO 
(Possession with Intent to Distribute Narcotics) 
4.On or about April 6, 2024, in the Southern District of New York and elsewhere,
JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  “Caballero,” and ODALIS  EUSEBIO  PERALTA  
BAUTISTA, a/k/a “Luis Collazo Santos,”    the defendants, knowingly and intentionally distributed 
and possessed with intent to distribute controlled substances, in violation of Title 21, United States 
Code, Section 841(a)(1), and aided and abetted the same. 
5.The controlled substances involved in the offense were: (i) 400 grams and more of
mixtures and substances containing a detectable amount of fentanyl, in violation of Title 21, United 
States  Code,  Section  841(b)(1)(A);  and  (ii)  500  grams  and  more  of  mixtures  and  substances  
containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, in 
violation of Title 21, United States Code, Section 841(b)(1)(A).  
(Title 21, United States Code, Sections 812, 841(a)(1) and 841(b)(1)(A); 
Title 18, United States Code, Section 2.) 
The bases for my knowledge and for the foregoing charges are, in part, as follows: 
6.I
 am a Special Agent with DEA, currently assigned to the El Dorado Task Force,
which focuses on combatting drug trafficking and money laundering.  I have been a Special Agent 
with DEA for approximately five  years.    I  have  been  personally  involved  in  this  investigation.  
This affidavit is based on my involvement in this investigation, my conversations with other law 
enforcement officers and other individuals, and my examination of reports and records.  Because 
this affidavit is being submitted for the limited purpose of establishing probable cause, it does not 
include all the facts that I have learned during the course of my investigation.  Where the contents 
of documents and the actions, statements, and conversations of others are reported herein, they are 
reported in substance and in part, except where otherwise indicated. 
Background 
7.This case concerns a network of drug traffickers operating industrial-scale illegal
narcotics pill  pressing  operations in  multiple  locations  throughout  New  York  City.    As  part  of  
those  operations,  the  traffickers  have  converted  spaces  in  residential  buildings  to  press  large  
quantities  of  powder  narcotics,  including  fentanyl  and  methamphetamine,  into  pill  form  for  
wholesale distribution.  At these locations, drug traffickers have manufactured millions of pills for 
further distribution, sometimes manufacturing hundreds of thousands of pills in a single session.   
8.On  or  about  April  6,  2024,  members  of  law  enforcement  searched  another  such
location: a storage room in the basement of a residential apartment building in the Bronx used by 
the drug traffickers to store powdered narcotics, combine the narcotics with other fillers, use dyes 
to  color  the  combined  powders,  and  then  use  large  industrial-scale  pill  presses,  which  press  
powdered material into tablets, to create hundreds of thousands of deadly pills.  Many of the pills 
appear to have been manufactured to be indistinguishable from prescription medications such as 

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Xanax,  Adderall,  and  OxyContin,  though  in  fact  they  contain,  among  other  things,  varying  
quantities of fentanyl.   
9.As described in greater detail below, inside the Bronx storage room, investigators
found  two  industrial-scale  pill  presses,  approximately  130,000  pills,  the  vast  majority  of  which  
field tested positive for the presence of fentanyl (the remainder of which field tested positive for 
the presence of methamphetamine), approximately three kilograms of a powder in zip lock bags 
that tested positive for the presence of fentanyl, a bucket containing approximately 20 pounds of 
powdered  narcotics,  which  field  tested  positive  for  the  presence  of  methamphetamine,  and  
approximately 3.5 pounds of suspected crystalized methamphetamine.  
PEREZ MENDEZ Conspires to Operate Pill Mills Throughout the City 
The Washington Heights Pill Mill 
10.Based on my participation in this investigation and my review of court records, I
have learned the following: 
a.On or about May 31, 2023, law enforcement officers conducted a consent
search (the “May 31, 2023 Search”) of the basement in a particular building in Washington Heights 
(the “Washington Heights Building”), where they found large quantities of narcotics, as well as 
the  materials  and  equipment  necessary  to  press  narcotics  into  pill  form,  including  commercial-
grade pill presses.  A photograph of the narcotics recovered is below: 
b.I
n  c
onnection  with  the  May  31,  2023  Search,  law  enforcement  officers
arrested  Juan  Efren  Paulino  (“Paulino”),  who  was  found  in  the  basement  of  the  Washington  
Heights Building with the narcotics.   

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11.Based on my review of surveillance video footage from the Washington Heights
Building,  I  know  that  a  person  who  appears  to  be  JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  
“Caballero,” the defendant, appeared to enter the basement of the Washington Heights Building in 
the days leading up to the May 31, 2023 Search. 
12.Based on my personal involvement in this investigation and discussions with other
law  enforcement  officers  involved  in  this  investigation,  I  know  that  law  enforcement officers 
recovered Paulino’s phone (“Paulino Cellphone-1”) incident to his arrest and conducted a search 
of its contents.  From my participation in the   search of Paulino Cellphone-1 and discussions with 
other  law  enforcement  officers  involved  in searching  Paulino  Cellphone-1,  I  have  learned  the  
following: 
a.Paulino had a number of message exchanges with a phone number ending
in 9908.  That number (the “Perez Mendez Number”) is saved as a contact in Paulino Cellphone-
1 as “Caballero Ringo” and the WhatsApp user profile photograph associated with it appears to be 
JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant. 
b.The Perez Mendez Number exchanged a number of messages with Paulino
Cellphone-1 that are, based on my training and experience, indicative of narcotics trafficking.  For 
example: 
i.On or about September 5, 2022, the Perez Mendez Number sent a link to a
website to order a pill press machine.  
ii.On or about January 8, 2023, Paulino Cellphone-1 sent the Perez Mendez
Number the following photograph of a small bag of colorful pills: 

5 
 
iii. On  or  about  January  14,  2023,  the  Perez  Mendez  Number  sent  Paulino  
Cellphone-1  an  audio
1
  note  stating,  in  sum  and  substance,  that  only  “one”  came  in.    The  Perez 
Mendez Number  followed  up  with  the  following  photographs  of  what  I  know  to  be,  from  my  
training and experience, a die mold and two rings, which are materials used in connection with 
shaping powder narcotics into pill form on pill press machines.  The die mold photograph is below: 
 
iv. On  or  about  March  8,  2023,  Paulino  Cellphone-1  sent  the  Perez  Mendez  
Number an audio note stating, in sum and substance, that he was currently working “down here 
using the new one.”  In the background can be heard what I believe to be, from my training and 
experience, an active pill press machine. 
v. On  or  about  May  30,  2023,  the  Perez  Mendez  Number  sent  Paulino  
Cellphone-1  an  audio  note  stating,  in  sum  and  substance,  that  someone’s  location  had  been  
“ransacked”  resulting  in  the  user  of  the  Perez  Mendez  Number having  lost  one  of  his  bags  of  
“medicine.” 
The Beaumont Pill Mill 
13. Based on my participation in this investigation and my review of court records, I 
have learned the following: 
a. On or  about  October  5,  2023,  law  enforcement  officers  searched  the  
basement  of  a  building  located  on  Beaumont  Avenue  in  the  Bronx (the “Beaumont  Building”), 
pursuant to a search warrant.  In that basement, law enforcement officers encountered a large-scale 
pill  pressing  operation.    In  particular,  during  the  course  of  the  search,  law  enforcement  officers  
found hundreds of thousands of pills and over 20 kilograms of narcotics, along with three industrial 
pill  press  machines,  one  disassembled  pill  press,  a  kilogram  press, and  narcotics  mixing  and  
repackaging  materials  including  blenders,  dyes,  jars  of  calcium  citrate  (frequently  used  as  a  
narcotics  cutting  agent),  and  industrial-grade gas  masks  (used  for  protection  when  handling 
narcotic powders intended for pill pressing).  A photograph of the narcotics recovered is below: 
 
1
 These and other voice notes and messages were in Spanish.  I do not speak Spanish, but had the 
notes and messages translated to me by members of law enforcement fluent in the Spanish 
language.  These translations are drafts and remain subject to change. 

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b.In  connection  with  that  search,  law  enforcement  officers  arrested  four
individuals, all of whom were present in the Beaumont Building at the time of the search. 
14.Based   on   my participation   in   surveillance   of   the   Beaumont   Building,   and
discussions I have had with other law enforcement officers who participated in surveillance of the 
Beaumont Building, I know that, in or about August 2023 law enforcement officers observed an 
individual  who  appeared  to  be JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  “Caballero,”  the  
defendant, enter and exit the Beaumont Building. 
The Calcium Purchases 
15.Based  on  information  provided  to  law  enforcement  officers by a  particular  retail
chain  of  consumer  products  (the  “Retailer”)  and my discussions  with  other  law  enforcement  
officers, I have learned the following: 
a.From  on  or  about  June  10,  2023,  to  on  or  about  March  3,  2024,  JUAN
MOISES  PEREZ  MENDEZ,  a/k/a  “Caballero,”  the  defendant,  and  his  girlfriend  purchased 
approximately  1,274  bottles  of  calcium  pills  from  the  Retailer.    This  amounts  to  approximately  
356,720 calcium pills. 
b.Based on my training and experience as a law enforcement officer, I know
that  narcotics  traffickers  often  use  pulverized  calcium  pills  as  a  mixing  agent  to  combine  with  
illegal narcotics.  Narcotics traffickers do this both to dilute the narcotics and to generate a greater 
volume  of  mixtures  and  substances  containing  narcotics—thus  creating  a  greater  volume  of  
product to sell—before packaging the narcotics for further distribution.   
Surveillance of the Storage Room 
16.In light of JUAN MOISES PEREZ MENDEZ’s, a/k/a “Caballero,” the defendant’s,
involvement in  the  above-described  pill  mills at  the  Washington  Heights  Building  and the 
Beaumont   Building, law   enforcement   officers   began   conducting   surveillance   of   PEREZ   
MENDEZ.  During the course of that surveillance, law enforcement officers identified a storage 

7 
room  (the  “Storage  Room”)  located  in  the  basement  of  a  particular  building located  on  Gerard  
Avenue in the Bronx (the “Gerard Avenue Building”) that was frequented by PEREZ MENDEZ. 
17.Based on my review of surveillance footage obtained from cameras located in and
around the Gerard  Avenue  Building,  I  have  learned,  among  other  things,  the  following  about  
events that occurred there between on or about April 3, 2024, and on or about April 6, 2024: 
a.On  or  about  April  3,  2024,  at  approximately  5:00  p.m.,  JUAN  MOISES
PEREZ MENDEZ, a/k/a “Caballero,” the defendant, appeared to enter the Storage Room, pushing 
a cart containing what appeared to be a case of water, a case of soup, and a case of juice or soda.  
Approximately  10  minutes  later,  a  person  that  appeared  to  be  ODALIS  EUSEBIO  PERALTA  
BAUTISTA, a/k/a “Luis Collazo Santos,” the defendant, joined PEREZ MENDEZ in the Storage 
Room. 
b.PEREZ  MENDEZ  and  PERALTA  BAUTISTA remained  in  the  Storage
Room until early in the morning on or about April 4, 2024.  At approximately 1:30 a.m., as depicted 
in part below, PEREZ MENDEZ left the Storage Room wearing a dark colored short sleeved shirt. 
A white, powdery residue appears to be on his shirt.   
c.Later, on or
 about April 4, 2024, PEREZ MENDEZ returned to the Storage
Room.    At  approximately  3:20  a.m.,  PEREZ  MENDEZ again  left  the  Storage  Room.    He  then  
appeared to look at the floor outside of the Storage Room, and then returned to the Storage Room 
to retrieve a mop, which he then used to clean the floor outside of the Storage Room before leaving 
the Gerard Avenue Building.  Based on my training and experience, I know that individuals who 
run  pill  mills  will  often  attempt  to  clean  the  areas  where  they  manufacture  pills,  as  the  
manufacturing of tens of thousands of pills creates a large amount of powdered, airborne detritus.  
d.On or about April 5, 2024, at approximately 6:30 p.m., PEREZ MENDEZ
appeared  to  enter  the  Storage  Room  accompanied  by  another  individual  who  appeared  to  be 
PERALTA BAUTISTA.  PEREZ MENDEZ appeared to be rolling a large suitcase and PERALTA 
BAUTISTA appeared to be carrying a large blue plastic bag. Over the next several hours, PEREZ 
MENDEZ and PERALTA BAUTISTA appeared to enter and exit the Storage Room on several 
occasions.   

8 
 
e. Later,  on  or  about  April  5,  2024,  at  approximately  10:00  p.m.,  PEREZ 
MENDEZ appeared to enter Storage Room with a shopping bag, a handful of cash, and keys.  He 
again entered the Storage Room, this time empty-handed, at approximately 12:15 a.m. on April 6, 
2024.  At approximately 3:05 a.m. on April 6, 2024, PEREZ MENDEZ exited the Storage Room.  
As depicted in part below, at that time, PEREZ MENDEZ appeared to mop the floor outside of 
the Storage  Room  wearing  a  protective  mask.     Based  on  my  training  and  experience  as  a  law  
enforcement  officer,  I  know  that  operators  of  pill  mills  often  use  protective  masks  to  protect  
themselves from the powdered narcotics that they are pressing into pills. 
 
 
f. At approximately 4:35 a.m. on or about April 6, 2024, PEREZ MENDEZ 
and PERALTA BAUTISTA left the Storage Room. 
g. Later  that  day,  on  or  about  April  6,  2024,  at  approximately  6:00  p.m.,  
PERALTA BAUTISTA returned to and reentered the Storage Room.  Approximately five to ten 
minutes  later,  PEREZ  MENDEZ  returned  to  and  reentered  the  Storage  Room,  and  then  left  the  
Storage Room one hour later, at approximately 7:10 p.m. 
The Arrest of the Defendants 
18. Based  on  my  participation  in  this  investigation  and  discussions  with  other  law  
enforcement  officers,  I  know  that,  on  or  about  April  6,  2024,  at  approximately  7:15  p.m.,  law  
enforcement  officers  arrested  JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  “Caballero,”  as  he  was  
exiting  the  Gerard  Avenue  Building,  only  minutes  after  leaving  the  Storage  Room.    Law  
enforcement officers found a key to the Storage Room on his person. 
19. Based on my discussions with other law enforcement officers and review of a video 
taken by law enforcement officers of the door to the Storage Room, I have learned that, after the 
arrest of JUAN MOISES PEREZ MENDEZ, a/k/a “Caballero,” the defendant, law enforcement 
officers  approached  the  door  to  the  Storage  Room.    A  loud  pounding  sound  could be  heard  
emanating from within the Storage Room, which I know, from my training and experience, to be 
consistent with the operation of a pill press. 
20. Based on my personal involvement in this investigation and discussions with other 
law enforcement officers, I have learned the following: 

9 
 
a. On or about April 6, 2024, at approximately 7:50 p.m., the loud pounding 
sound  emanating  from  the  Storage  Room  stopped.    Shortly  thereafter,  ODALIS  EUSEBIO  
PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,” the defendant, exited the Storage Room.  At 
the time, PERALTA BAUTISTA’s shirt appears to have had white powder on it. 
b. As PERALTA BAUTISTA exited the Storage Room, he was placed under 
arrest.   
The Search of the Storage Room  
21. Based  on  my  participation  in  this  investigation  and  discussions I  have  had  with  
other law enforcement agents,  I have learned, among other things, the following: 
a. On or about April 6, 2024, law enforcement officers conducted a search of 
the Storage Room pursuant to a search warrant authorized by the Honorable Robyn F. Tarnofsky, 
United  States  Magistrate  Judge.    In  the Storage  Room,  law  enforcement  officers  found  two  
industrial-scale pill presses, approximately 130,000 pills, the vast majority of which field tested 
positive for the presence of fentanyl (the remainder of which field tested positive for the presence 
of  methamphetamine),  approximately  three  kilograms  of  a  powder  in  zip  lock  bags  that  tested  
positive for the presence of fentanyl, a bucket containing approximately 20 pounds of powdered 
narcotics, which field tested positive for the presence of methamphetamine, and approximately 3.5 
pounds of suspected crystalized methamphetamine.  The suspected narcotics and pill presses are 
depicted, in part, below:    
 

10 
 
      
b. Additionally,   law   enforcement   officers   found   materials   used   to   mix   
powdered narcotics with fillers as well as packaging materials used to package narcotics for further 
distribution.    Those  items  included  mixing  bowls, a  blender,  strainers,  dyes,  empty  bottles  of  
calcium citrate, which appear to be the type of calcium purchased from the Retailer, and thousands 
of glassine envelopes.  Some of those materials and tools are pictured below.   
  

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WHEREFORE,  I  respectfully  request  that  JUAN  MOISES  PEREZ  MENDEZ,  a/k/a  
“Caballero,” and ODALIS EUSEBIO PERALTA BAUTISTA, a/k/a “Luis Collazo Santos,”    the 
defendants, be imprisoned or bailed, as the case may be. 
______________________________ 
STEPHANIE RICHMAN 
Special Agent 
Drug Enforcement Administration 
Sworn to before me by reliable electronic means 
this 8th day of April, 2024 
___________________________________ 
THE HONORABLE SARAH NETBURN 
United States Magistrate Judge 
Southern District of New York