United States v. Alejandro Degante-Galeno, et al.

. I 

Before: THE HONORABLE ANDREW J. PECK 
United States Magistrate Judge 
Southern District of New York 

- - - - - - - - - - - - - - - - - - - - X 

UNITED STATES OF AMERICA 

- against -

ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," 

BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," 
a/k/a "Mota," 

JUANA LUCAS-SANCHEZ, 
DAVID VASQUEZ-MEDINA, 
CARLOS GARCIA-DE LA ROSA, 

a/k/a "Choqui," 
a/k/a "Pirulo," 
a/k/a "Miguel," 

ALEJANDRO DEGANTE-GALENO, 
a/k/a "Celestino Degante Galena," 
a/k/a "El Zorro," 

MARIA BAUTISTA-PENA, 
a/k/a "Maricruz," 

MIGUEL ANGEL CHE-VELIZ, 
a/k/a "Miguelon," 

ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," 
a/k/a "El Perro," 
a/k/a "Cachorro," 

MARGARITO DEGANTE, 
a/k/a "Chachalaco," 

PANFILO FLORES-MENDEZ, 
VALENTIN JIAMEZ-DOLORES, 
FNU LNU, 

a/k/a "Alberto Jesus 
Martinez-Miranda," 
a/k/a "Barbas," 
a/k/a "Barbitas," 

Defendants. 
- - - - - - - - - - - - - - - - - - - - X 

113 

SEALED COMPLAINT 

Violations of 
18 u.s.c. §§ 1512(c), 
1591 (a), 1591 (b) (1), 
1952, 2423 (d) , 
8 U.S.C. § 1326(a) 

COUNTY OF OFFENSE: 
BRONX 



COUNTY OF NEW YORK 
STATE OF NEW YORK ss.: 
SOUTHERN DISTRICT OF NEW YORK 

ELVIN HERNANDEZ, being duly sworn, deposes and says 
that he is a Special Agent with the Department of Homeland 
Security, Immigration and Customs Enforcement, Homeland Security 
Investigations ("HSI") charges as follows: 

COUNT ONE 
{Sex Trafficking) 

1. From at least in or about September 2006, up to 
and including in or about 2007, in the Southern District of New 
York and elsewhere, ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," and JUANA LUCAS­
SANCHEZ, the defendants, in and affecting interstate and foreign 
commerce, willfully and knowingly did recruit, entice, harbor, 
transport, provide, and obtain, by any means a person, and did 
benefit, financially and by receiving anything of value, from 
participation in a venture which has engaged in such acts, 
knowing that force, fraud, and coercion would be used to cause 
the person to engage in a commercial sex act, in violation of 
Title 18, United States Code, Section 1591(a) and (b) (1), to wit, 
ISAIAS FLORES-MENDEZ arranged for a woman ("Victim-1") to be 
smuggled to the United States from Mexico for the purpose of 
prostitution, and then ISAIAS FLORES-MENDEZ, BONIFACIO FLORES­
MENDEZ, and LUCAS-SANCHEZ, used force, threats of force, and 
other means of coercion to compel Victim-1 to engage in 
prostitution against her will for their own financial gain. 

(Title 18, United States Code, 
Sections 1591 (a) & (b) (1), and 2.) 

COUNT TWO 
{Sex Trafficking) 

2. From at least in or about 2006, up to and 
including in or about 2008, in the Southern District of New York 
and elsewhere, DAVID VASQUEZ-MEDINA, the defendant, in and 
affecting interstate and foreign commerce, willfully and 
knowingly did recruit, entice, harbor, transport, provide, and 
obtain, by any means a person, and did benefit, financially and 

2 



by receiving anything of value, from participation in a venture 
which has engaged in such acts, knowing that force, fraud, and 
coercion would be used to cause the person to engage in a 
commercial sex act, in violation of Title 18, United States Code, 
Section 1591(a) and (b) (1), to wit, VASQUEZ-MEDINA used force, 
threats of force, and other means of coercion to compel a woman 
("Victim-2") to engage in prostitution in several states against 
her will for his own financial gain. 

(Title 18, United States Code, 
Sections 1591 (a) & (b) (1), and 2.) 

COUNT THREE 
(Interstate Travel for Prostitution) 

3. In or about April 2013, in the Southern District 
of New York and elsewhere, BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant, willfully and knowingly, for the 
purpose of commercial advantage and private financial gain, 
arranged, induced, procured, and facilitated the travel of a 
person knowing that such a person was traveling in interstate 
commerce for the purpose of engaging in illicit sexual conduct, 
to wit, BONIFACIO FLORES-MENDEZ induced the travel of a person 
("Witness-1") to New York from out-of-state for the purpose of 
engaging in prostitution. 

(Title 18, United States Code, 
Sections 2423(d) and 2.) 

COUNT FOUR 
(Prostitution-Sex Trafficking Enterprise) 

4. From in or about October 2012, up to and including 
on or about the date of the filing of this Complaint, in the 
Southern District of New York and elsewhere, ISAIAS 
FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, together with others known and 

3 



unknown, willfully and knowingly did combine, conspire, 
confederate, and agree together and with each other to commit 
offenses against the United States of America, to wit, use of 
facilities in interstate commerce for the promotion, management, 
and facilitation of a prostitution enterprise, in violation of 
Title 18, United States Code, Section 1952. 

5. It was a part and an object of the conspiracy that 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and others known and unknown, 
knowingly would and did travel in interstate and foreign commerce 
and use the mail and a facility in interstate and foreign 
commerce, with intent to promote, manage, establish, carry on, 
and facilitate the promotion, management, establishment, and 
carrying on, of one or more unlawful activities, namely promoting 
prostitution and sex trafficking, in violation of New York Penal 
Law §§ 230.20 and 230.34, and thereafter would and did perform 
and attempt to perform an act to promote, manage, establish, 
carry on and facilitate the promotion, management, establishment, 
and carrying on of the unlawful activity. 

6. In furtherance of the conspiracy and to effect the 
illegal object thereof, ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," 
BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," CARLOS 
GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a 
"Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante-Galeno," a/k/a "El Zorro," MARIA BAUTISTA-PENA, a/k/a 
"Maricruz," ISIDRO DEGANTE GALENO, a/k/a "Marcos," a/k/a "El 
Perro," a/k/a "Cachorro," MARGARITO DEGANTE, a/k/a "Chachalaco," 
VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," the 
defendants, together with others known and unknown, committed the 
following overt acts, among others, in the Southern District of 
New York and elsewhere: 

a. On or about October 30, 2012, ISAIAS 

4 



FLORES-MENDEZ had a telephone conversation with BONIFACIO FLORES­
MENDEZ, during which they discussed which women were working in 
the Yonkers Brothel and the Poughkeepsie Brothel. 

b. On or about April 15, 2013, BONIFACIO 
FLORES-MENDEZ, had a telephone conversation with a woman working, 
or being forced to work, as a prostitute, in which BONIFACIO 
FLORES-MENDEZ and the woman discussed when she would arrive in 
Manhattan to meet BONIFACIO FLORES-MENDEZ to be taken to work at 
a brothel. 

c. On or about March 5, 2013, GARCIA-DE LA ROSA 
had a telephone conversation with BONIFACIO FLORES-MENDEZ about 
the fact that a customer interested in engaging in commercial sex 
with a woman working, or being forced to work, as a prostitute 
was waiting outside of a brothel. 

d. On or about April 15, 2013, ALEJANDRO 
DEGANTE-GALENO and ISIDRO DEGANTE-GALENO had a telephone 
conversation about the delivery to a customer's residence of a 
woman working, or being forced to work, as a prostitute. 

e. On or about April 21, 2013, BAUTISTA-PENA and 
ALEJANDRO DEGANTE-GALENO had a telephone conversation about the 
fact that a customer interested in engaging in commercial sex 
with a woman working, or being forced to work, as a prostitute 
was waiting at the door of his residence for the woman. 

f. On or about February 26, 2013, MARGARITO 
DEGANTE had a telephone conversation with ALEJANDRO DEGANTE­
GALENO about the fact that MARGARITO DEGANTE was on the corner 
distributing "chica cards" to solicit customers for women 
working, or being forced to work, as prostitutes. 

g. On or about March 5, 2013, JIAMEZ-DOLORES had 
a telephone conversation with BONIFACIO FLORES-MENDEZ in which 
JIAMEZ-DOLORES agreed to allow a customer to engage in commercial 
sex with one of the women working, or being forced to work, in a 
brothel in exchange for a $10 payment with the promise to pay the 
remaining $20 the next day, as long as JIAMEZ-DOLORES recognized 
the customer. 

h. On or about April 18, 2013, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," and BONIFACIO FLORES-MENDEZ had a telephone 

5 



conversation, in which FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," agreed to tell a 
woman working, or being forced to work, as a prostitute that 
there was one customer waiting to come in, and that three more 
were on their way. 

(Title 18, United States Code, Section 371.) 

COUNT FIVE 
(Possession of Child Pornography) 

7. From in or about February 2013, up to and 
including in or about March 2013, in the Southern District of New 
York, CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," 
a/k/a "Miguel," the defendant, knowingly did possess, and access 
with intent to view, a book, magazine, periodical, film, 
videotape, computer disk, and other material that contained an 
image of child pornography that had been mailed, and shipped and 
transported using a means and facility of interstate and foreign 
commerce and in and affecting interstate and foreign commerce by 
any means, including by computer, and that was produced using 
materials that had been mailed, and shipped and transported in 
and affecting interstate and foreign commerce by any means, 
including by computer, to wit, GARCIA-DE LA ROSA possessed on his 
cell phone photographs containing child pornography. 

(Title 18, United States Code, Section 2252A(a) (5) (B).) 

COUNT SIX 
(Obstruction of Justice) 

8. In or about October 2012, in the Southern District 
of New York and elsewhere, ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," and MIGUEL 
ANGEL CHE-VELIZ, a/k/a "Miguelon," the defendants, willfully and 
knowingly corruptly altered, destroyed, mutilated, and concealed 
a record, document, and other object, and attempted to do so, 
with the intent to impair the object's integrity and availability 
for use in an official proceeding, and otherwise obstructed, 
influenced, and impeded an official proceeding, and attempted to 
do so, to wit, working under the direction of ISAIAS FLORES­
MENDEZ, BONIFACIO FLORES-MENDEZ and CHE-VELIZ searched for, 
removed, and destroyed GPS tracking devices from vehicles used to 
commit the crimes charged in Counts Three and Four in order to 

6 



prevent the location tracking of several of the defendants and to 
make the evidence unavailable for use by law enforcement 
authorities in connection with a federal grand jury 
investigation. 

(Title 18, United States Code, Sections 1512(c) and 2.) 

COUNT SEVEN 
(Illegal Reentry} 

9. On or about November 18, 2012, in the Southern 
District of New York and elsewhere, PANFILO FLORES-MENDEZ, the 
defendant, being an alien, after having been denied admission, 
excluded, deported, and removed from the United States on or 
about November 29, 2010, unlawfully did enter and was found in 
the United States, without having obtained the express consent of 
the Attorney General of the United States or his successor, the 
Secretary for the Department of Homeland Security, to reapply for 
admission. 

(Title 8, United States Code, Section 1326(a) .) 

COUNT EIGHT 
(Illegal Reentry} 

10. On or about May 29, 2009, in the Southern District 
of New York and elsewhere, JUANA LUCAS-SANCHEZ, the defendant, 
being an alien, after having been denied admission, excluded, 
deported, and removed from the United States on or about June 8, 
2004, and on or about January 29, 2004, unlawfully did enter and 
was found in the United States, without having obtained the 
express consent of the Attorney General of the United States or 
his successor, the Secretary for the Department of Homeland 
Security, to reapply for admission. 

(Title 8, United States Code, Section 1326(a) .) 

The bases for my knowledge of the foregoing charges 
are, in part, as follows: 

11. I have been employed as a Special Agent with HSI 
(and its predecessor, the Bureau of Immigration and Customs 
Enforcement ("ICE")) for approximately three years. During my 
tenure as a Special Agent with HSI, I have conducted and 
participated in numerous investigations of criminal activity, 

7 



including but not limited to, sex trafficking, alien harboring, 
violations of the Mann Act, transportation in aid of racketeering 
activity, money laundering, and illegal reentry, in violation of 
Title 18, United States Code, Sections 1591, 2421, 2422, 2423, 
1952 and 1956, and Title 8, United States Code, Sections 1324 and 
1326. Through my training, education and experience, I have 
become familiar with the manner in which sex traffickers coerce 
women to engage in prostitution, the means and methods by which 
such prostitution occurs, the methods of exchange and transfer of 
the proceeds of such prostitution, and the coded language used by 
sex traffickers and others engaged in the prostitution business. 

12. The information contained in this affidavit is 
based upon my personal knowledge and my review of documents and 
records gathered during the course of this investigation, as well 
as information obtained, directly or indirectly, from other 
sources and agents, including information provided to me by 
witnesses who participated in conversations with the defendants. 
Because this affidavit is being submitted for the limited purpose 
of establishing probable cause, it does not include all of the 
facts that I have learned during the course of the 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. 

THE TENANCINGO-NEW YORK SEX TRAFFICKING NETWORK 

13. Many sex traffickers live in and around 
Tenancingo, Mexico and traffic women from rural areas in and 
around Tenancingo, Mexico to New York, among other places. The 
traffickers often lure women to the United States one at a time 
by engaging them in romantic relationships and promising a better 
life in New York. After the women are smuggled from Mexico to 
New York by their traffickers, they are forced by the traffickers 
to begin working as prostitutes against their will under 
abhorrent conditions. 

14. The victims are often beaten, threatened with 
physical harm to themselves and their family members, sexually 
assaulted, and verbally abused. In a typical day, a Mexican sex 
trafficking victim in New York will have sexual intercourse with 
20 to 30 customers. 

15. In some cases, the victims work in residential 
brothels - apartments or houses used as brothels for two to four 

8 



women, where a co-conspirator of the traffickers provides 
security. In such brothels, there is typically a public living 
room space, and a bedroom or bedrooms which are used for the 
actual commercial sex. Doormen or "steerers" typically collect 
the money from customers either at the entrance to the brothel or 
in the living room, after which the customers are directed to a 
bedroom to have sex with a woman working, or being forced to 
work, as a prostitute. In some cases, the steerers provide the 
customers with tickets or playing cards, which the customers the 
provide to the women as proof of payment. Steerers also provide 
security for the brothel, prevent victims from fleeing, and work 
outside the brothel directing customers to the brothel. Brothels 
often attract customers by distributing "chica cards" ("chica" 
means "girl" in Spanish) - business cards containing the phone 
number of a contact for the brothel. 

16. In other cases, the victims are forced to perform 
commercial sex at the customers' homes, which is referred to as a 
"delivery service." Drivers also attract customers by 
distributing chica cards. As a matter of course, in a delivery 
service the driver sets the appointments with customers or has a 
co-conspirator work as a dispatcher, receiving calls and 
directing the drivers to the customers' addresses. 

17. In order to provide customers with variety, 
traffickers typically move their victims from brothel to brothel, 
often on a weekly basis. Traffickers do not limit themselves to 
brothels within a small geographical range. It is not unusual 
for victims of New York-based traffickers to work in brothels as 
far away as Delaware or Massachusetts. 

18. Traffickers typically provide the victims with 
cell phones to contact brothels and drivers so that the 
traffickers themselves cannot be recorded committing the crime. 
Traffickers then monitor the victims' cell phone usage to ensure 
that the victims are not contacting family members or friends, 
because isolation is one tactic used by traffickers to maintain 
control over their victims. Nevertheless, and as described in 
further detail below, traffickers also use cell phones to 
communicate with brothels and with each other. 

19. Generally, each customer pays $30-$35 for 15 
minutes of sex. Of that $30-$35, $15 typically goes to the 
driver (in the case of a delivery service) or to the brothel. 
The other $15 goes to the victim, who is then typically forced to 

9 



give all of the proceeds to the trafficker. 

20. The trafficker then frequently sends, or has his 
victims send, some of those proceeds to family members and 
associates in Mexico by wire transfer. Such transfers provide 
financial assistance to the sex traffickers' families and provide 
financial support to the sex traffickers themselves if and when 
they return to Mexico. Such financial transfers are also a 
method of storing and hiding the significant profits of sex 
trafficking from law enforcement. In order to effect the wire 
transfer, the wire remitter businesses typically require the 
sender to provide his name, address, and phone number, and in 
some cases, they require official photo identification. The 
recipient of the wire transfer is required to provide a name, 
address, and phone number in order to pick up the wired funds. 
In my experience, traffickers and their relatives and associates 
typically provide their true names, addresses, and phone numbers 
to the wire remitter companies because they want to ensure that 
the wire transfer is completed or, if not, that they can be 
contacted to resolve any issues. 

21. In some instances, traffickers choose one of their 
respective victims to assist in the trafficking of other women. 
For example, some victims recruit, supervise, and direct new 
victims, and report to their respective traffickers on the 
activities and compliance of the new victims. These victims­
turned-accomplices effectively work as enforcers for their 
traffickers either because they are coerced to engage in such 
conduct or because doing so will better their position with their 
traffickers and thereby decrease the abuse they suffer. 

22. Traffickers typically provide their victims with 
condoms and birth control pills. If a victim is suspected of 
being pregnant, her trafficker will typically make the victim 
take the drug misoprostol, marketed as Cytotec. Cytotec is FDA­
approved to prevent gastric ulcers, but it also causes uterine 
contractions and induces miscarriage. Traffickers give victims 
Cytotec to induce miscarriage so that the victims can continue 
working as prostitutes. 

23. After periods of victimization- typically months 
or years - many victims manage to escape. Without legal status 
in the United States, without family or friends for support, 
without employment opportunities, and as a result of the trauma 
they have suffered, victims sometimes return to prostitution. In 

10 



those cases, the victims become effectively self-employed, 
keeping the $15 per customer they previously had to turn over to 
their traffickers. 

THE DEFENDANTS 

24. ISAIAS FLORES-MENDEZ: At various times relevant 
to this Complaint, ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
worked as a sex trafficker, using violence, threats of violence, 
and other means of coercion to force at least one woman - Victim-
1 - to engage in prostitution against her will. ISAIAS FLORES­
MENDEZ also operated at least four brothels located in the 
Southern and Eastern Districts of New York, at which women 
worked, and were forced to work, as prostitutes (the "Brothels") 
ISAIAS FLORES-MENDEZ sent by wire transfer some of the proceeds 
of these crimes to his family in Mexico. On or about October 19, 
2012, ISAIAS FLORES-MENDEZ was arrested by the New York City 
Police Department ("NYPD") under the name "Jesus Diaz," and 
charged with Possession of a Forged Instrument and ordered 
detained. A Mexican Consular ID seized from ISAIAS FLORES-MENDEZ 
at the time of his arrest bore the name "Jesus Diaz." On or 
about January 2, 2013, ISAIAS FLORES-MENDEZ was charged by 
complaint in this District with illegal reentry, in violation of 
Title 8, United States Code, Section 1326(a). (12 Mag 3262). On 
or about January 14, 2013, ISAIAS FLORES-MENDEZ was indicted on 
the same charge. (13 Cr. 31 (KBF)). ISAIAS FLORES-MENDEZ has 
been detained since in or about October 2012, and has been in the 
custody of the United States Marshals Service ("USMS") since in 
or about January 2013. 

25. BONIFACIO FLORES-MENDEZ: At various times 
relevant to this Complaint, BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendant, a brother of ISAIAS FLORES­
MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," the defendant, worked as a sex trafficker, using 
threats of violence and other means of coercion to force at least 
one woman - Victim-1 - to engage in prostitution against her 
will. BONIFACIO FLORES-MENDEZ also operated the Brothels -
scheduling women to work in the Brothels, transporting them to 
and from work, hiring drivers, doormen, and steerers for the 
Brothels, and taking calls from customers. 

26. JUANA LUCAS-SANCHEZ: At various times relevant to 
this Complaint, JUANA LUCAS-SANCHEZ, the defendant, has worked as 

11 



a sex trafficker, aiding ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," the 
defendant, and BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a 
"Mota," in their use force, threats of force, and other means of 
coercion to compel Victim-1 to engage in prostitution against her 
will. At other times, LUCAS-SANCHEZ has herself worked, or been 
forced to work, as a prostitute. LUCAS-SANCHEZ was deported 
twice in or about 2004, and subsequently reentered the United 
States without authorization. 

27. DAVID VASQUEZ-MEDINA: At various times relevant 
to this Complaint, DAVID VASQUEZ-MEDINA, the defendant, worked as 
a sex trafficker, using violence, threats of violence, and other 
means of coercion to force at least one woman - Victim-2 - to 
engage in prostitution against her will. On or about October 17, 
2012, VASQUEZ-MEDINA was arrested for Possession of a Forged 
Instrument and ordered detained. On or about January 7, 2013, 
VASQUEZ-MEDINA was charged with Illegal Reentry, in violation of 
Title 8, United States Code, Section 1326(a), and was 
subsequently indicted on the same charge (13 Cr. 128 (SAS)). 
VASQUEZ-MEDINA has been detained since in or about October 2012, 
and has been in the custody of the USMS since in or about January 
2013. 

28. CARLOS GARCIA-DE LA ROSA: At various times 
relevant to this Complaint, CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," the defendant, worked 
as a driver for ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and BONIFACIO 
FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the defendants, 
transporting women working, or being forced to work, as 
prostitutes to and from the Brothels, or to outside customers, 
and also transporting customers to and from the Brothels for the 
purpose of engaging in commercial sex. GARCIA-DE LA ROSA also 
enticed a minor girl with whom he was engaged in a sexual 
relationship ("Minor Victim-1") to take pornographic photographs 
of herself and send them to GARCIA-DE LA ROSA, which he then 
possessed in the Southern District of New York. 

29. ALEJANDRO DEGANTE-GALENO: At various times 
relevant to this Complaint, ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zarro," the defendant, 
worked as a driver, delivering to customers women working, or 
being forced to work, as prostitutes, for the purpose of engaging 
in commercial sex. 

12 



30. MARIA BAUTISTA-PENA: At various times relevant to 
this Complaint, MARIA BAUTISTA-PENA, a/k/a "Maricruz," the 
defendant, worked as a dispatcher, taking phone calls from people 
interested in having a woman delivered to them for the purpose of 
commercial sex, and then 'relaying the request and address to 
ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a 
"El Zorro," the defendant, who then delivered to the customers 
women working, or being forced to work, as prostitutes, for the 
purpose of engaging in commercial sex. 

31. MIGUEL ANGEL CHE-VELIZ: At various times relevant 
to this Complaint;, MIGUEL ANGEL CHE-VELIZ, a/k/a "Miguelon," the 
defendant, worked as a mechanic for ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chela," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants. In that capacity, CHE-VELIZ swept vehicles for 
tracking devices that had been placed by federal law enforcement 
agents in connection with a federal grand jury investigation, and 
aided in the destruction of some of those tracking devices. 

32. ISIDRO DEGANTE-GALENO: At various times relevant 
to this Complaint, ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a 
"El Perro," a/k/a "Cachorro," the defendant, a brother of 
ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a 
"El Zorro," the defendant, worked as a driver, delivering to 
customers women working, or being forced to work, as prostitutes 
for the purpose of engaging in commercial sex. 

33. MARGARITO DEGANTE: At various times relevant to 
this Complaint, MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, a nephew of ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante Galena," a/k/a "El Zorro," and ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," the 
defendants, worked as a driver, delivering to customers and/or 
brothels women working, or being forced to work, as prostitutes 
for the purpose of engaging in commercial sex. 

34. PANFILO FLORES-MENDEZ: At various times relevant 
to this Complaint, PANFILO FLORES-MENDEZ, the defendant, a 
brother of ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and BONIFACIO FLORES­
MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants, had illegally 
reentered the United States of America without authorization 
following his 2010 deportation. 

13 



35. VALENTIN JIAMEZ-DOLORES: At various times 
relevant to this Complaint, VALENTIN JIAMEZ-DOLORES, the 
defendant, worked as a doorman or steerer at a brothel run by 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendants, in Yonkers, New York. In 
that capacity, JIAMEZ-DOLORES manned the door at the brothel, 
collected payment from customers, and directed customers to 
bedrooms where the customers had commercial sex with women 
working, or being forced to work as prostitutes. 

36. FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas": At various times relevant to 
this Complaint, FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," the defendant, worked as a 
doorman or steerer at a brothel run by ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants, in Queens, New York. In that capacity, FNU LNU, 
a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," manned the door at the brothel, collected payment 
from customers, and directed customers to bedrooms where the 
customers had commercial sex with the women working, or being 
forced to work as prostitutes. 

THE BROTHELS 

37. ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
previously operated and utilized, and BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant, presently operates and 
utilizes numerous residential brothels - apartments and houses 
where women work, and are forced to work, as prostitutes -
throughout New York, including identified locations on Rose 
Street in Poughkeepsie, New York (the "Poughkeepsie Brothel"), on 
Seneca Avenue in Queens, New York (the "Queens Brothel"), on Elm 
Street in Yonkers, New York (the "Yonkers Brothel"), and on 1st 
Street in Newburgh, New York (the "Newburgh Brothel"). 

14 



The Poughkeepsie Brothel 

38. On or about January 24, 2013, a cooperating 
witness ( "CW-1") 1 made an audio and video recording of the inside 
of the Poughkeepsie Brothel. In the recording, CW-1 enters the 
Poughkeepsie Brothel and sees a woman wearing lingerie seated on 
a couch. CW-1 asks a Hispanic male working in the Poughkeepsie 
Brothel if there are women of any other nationality available and 
is told that there are not, at which time CW-1 leaves. 

39. During the course of this investigation, both 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chela," and BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendants, have been observed entering 
and leaving the Poughkeepsie Brothel, and BONIFACIO FLORES-MENDEZ 
has been observed delivering a woman to the Poughkeepsie Brothel. 

40. In connection with this investigation, in February 
2013 and April 2013, HSI obtained the following court orders 
authorizing interception of communications over cell phones used 
by various of the defendants charged herein: 

a. On or about February 21, 2013, the Honorable 
Kimba M. Wood, United States District Judge, Southern District of 
New York, signed an order (the "February 2013 Order") authorizing 
the interception of wire communications occurring over the 
following cellular telephones: (1) the cellular telephone 
assigned call number (917) 686-4929, subscribed to by "Josee D. 
Lopezzz," and used primarily by BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendant ("Intercepted Cellphone-1"); 
(2) the cellular telephone assigned call number (845) 764-7252, 
subscribed to by "Isabel Rodriguez" ("Intercepted Cellphone-2"); 
(3) the cellular telephone assigned call number (914) 619-7051, 
with no subscriber name provided, used primarily by BONIFACIO 

1 CW-1 pleaded guilty, pursuant to a cooperation agreement 
in this District, to charges including illegal reentry, social 
security fraud, narcotics distribution conspiracy, narcotics 
importation conspiracy, possessing a firearm in connection with a 
narcotic trafficking offense, and hostage-taking. CW-1 hopes to 
receive a reduced sentence as a result of his cooperation. To 
date, law enforcement agents dealing with CW-1 have found CW-1 to 
be credible and the information provided by CW-1 to be 
corroborated. 

15 



FLORES-MENDEZ ("Intercepted Cellphone-3"); (4) the cellular 
telephone assigned call number (718) 216-2596, subscribed to by 
"Marcos Degante" and used primarily by ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," the defendant 
("Intercepted Cellphone-4"); and (5) the cellular telephone 
assigned call number (347) 284-2648, subscribed to by "Alejandro 
Mendoza" and used primarily by ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zarro," the defendant 
("Intercepted Cellphone- 5") (collectively, the "Intercepted 
Cellphones"). 

b. On or about April 2, 2013, the Honorable 
Kimba M. Wood, United States District Judge, Southern District of 
New York, signed an order (the "April 2013 Order") authorizing 
the continued interception of wire communications occurring over 
Intercepted Cellphone-1, Intercepted Cellphone-3, and Intercepted 
Cellphone-5. 

41. In calls intercepted on Intercepted Cellphone-1 
and Intercepted Cellphone-3 pursuant to the February 2013 Order 
and the April 2013 Order, BONIFACIO FLORES-MENDEZ, a/k/a "Bani," 
a/k/a "Mota," the defendant, engaged in conversations in which he 
discussed arranging for women to work in the Poughkeepsie Brothel 
and in which he discussed the Poughkeepsie Brothel with customers 
or potential customers. For example, on or about April 22, 2013, 
at approximately 12:54 p.m., BONIFACIO FLORES-MENDEZ spoke to a 
woman identified during the call as "Karen," ("Karen") who asked 
if BONIFACIO had "a girl for Monday . . to the house in 
Newburgh." BONIFACIO responded that he did not have work in 
Newburgh, but that he had "the one for Poughkeepsie." Karen 
responded that she would take the week if BONIFACIO could give it 
to her. 

42. Based on my training and experience and my 
familiarity with this investigation, including the video obtained 
by CW-1, the surveillance of ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the 
defendants, and the intercepted telephone calls in which 
BONIFACIO FLORES-MENDEZ arranges for women to work in 
Poughkeepsie and/or provides information to men about the brothel 
in Poughkeepsie, I believe that the Poughkeepsie Brothel is, in 
fact, a brothel, and that BONIFACIO FLORES-MENDEZ runs the 
Poughkeepsie Brothel. 

16 



The Queens Brothel 

43. On or about December 6, 2012, law enforcement 
agents interviewed a customer of the Queens Brothel ("Customer-
1"). During the interview, Customer-1 stated, in substance and 
in part, that the Queens Brothel was a brothel, and that 
Customer-1 had frequented the Queens Brothel on three occasions, 
most recently that day. Customer-1 said that at the brothel, an 
apparent employee collected $30 from Customer-1, and directed him 
to a bedroom where he had sexual intercourse with a woman. 

44. During the course of this investigation, 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the 
defendant, has been observed delivering women to the Queens 
Brothel. 

45. In addition, in calls intercepted on Intercepted 
Cellphone-3 pursuant to the February 2013 Order and the April 
2013 Order, BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," 
the defendant, engaged in conversations in which he discussed 
customers of the Queens Brothel. For example, on or about April 
22, 2013, at approximately 1:22 p.m., BONIFACIO FLORES-MENDEZ had 
a conversation with an individual not charged herein in which 
BONIFACIO FLORES-MENDEZ said that he had spoken to a customer who 
asked if BONIFACIO FLORES-MENDEZ was open, and that BONIFACIO 
FLORES-MENDEZ had originally said he was closed, but because the 
customer said he had been to [the brothel] before and knew where 
it was located on Seneca Avenue, BONIFACIO FLORES-MENDEZ told the 
customer to come. 

46. Based on my training and experience, and my 
familiarity with this investigation, including the statements 
made by Customer-1, the surveillance of BONIFACIO FLORES-MENDEZ, 
a/k/a "Bani," a/k/a "Mota," the defendant, and my review of 
summaries of the intercepted calls described above, I believe 
that the Queens Brothel is, in fact, a brothel, and that it is 
run by BONIFACIO FLORES-MENDEZ. 

The Yonkers Brothel 

47. On or about December 20, 2012, law enforcement 
agents interviewed a customer of the Yonkers Brothel ("Customer-
2") and arrested VALENTIN JIAMEZ-DOLORES, the defendant, who 
waived his Miranda rights and provided a statement. Both 
Customer-2 and JIAMEZ-DOLORES stated, in substance and in part, 

17 



that the Yonkers Brothel was a brothel. JIAMEZ-DOLORES further 
explained that he manned the door of the Yonkers Brothel, and 
collected $30 from each customer in return for a playing card, 
which the customers then gave to the women working in the brothel 
as payment for sex. 

48. During the course of this investigation, BONIFACIO 
FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the defendant, has 
been surveilled driving women to and from the Yonkers Brothel. 

49. In addition, in calls intercepted on Intercepted 
Cellphone-1 and Intercepted Cellphone-3 pursuant to the February 
2013 Order and the April 2013 Order, BONIFACIO FLORES-MENDEZ, 
a/k/a "Bani," a/k/a "Mota," the defendant, engaged in 
conversations in which he discussed the Yonkers Brothel with 
customers or potential customers. For example, on or about April 
22, 2013, at approximately 9:59a.m., BONIFACIO FLORES-MENDEZ 
received a call on Intercepted Cellphone-3 from an unidentified 
male who asked, "what do you have in Yonkers," and BONIFACIO 
FLORES-MENDEZ responded, in substance and in part, that he had 
two Mexicans who were both good. 

50. Based on my training and experience, and my 
familiarity with this investigation, including the information 
provided by "Customer-2" and VALENTIN JIAMEZ-DOLORES, the 
defendant, the surveillance of BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendant, and my review of summaries 
of the intercepted telephone calls described above in which 
BONIFACIO FLORES-MENDEZ arranges for women to work in Yonkers 
and/or provides information to men who are coming to Yonkers, I 
believe that the Yonkers Brothel is, in fact, a brothel, that 
BONIFACIO FLORES-MENDEZ runs the Yonkers Brothel, and that 
JIAMEZ-DOLORES works at the Yonkers Brothel. 

The Newburgh Brothel 

51. On or about January 10, 2013, law enforcement 
agents interviewed a customer of the Newburgh Brothel ("Customer-
3"). During the interview, the customer stated, in substance and 
in part, that the Newburgh Brothel was a brothel, and that he had 
frequented the Newburgh Brothel approximately one to two times 
per month for the last four years. On or about January 17, 2013, 
Customer-3 made a consensual audio and video recording of the 
inside of the Newburgh Brothel. During the recording, Customer-3 
enters the Newburgh Brothel and sees a Hispanic female emerge 

18 



from a back bedroom wearing lingerie and high heels. Customer-3 
then tells the two men working in the Newburgh Brothel that he is 
not interested in the woman. Customer-3 then leaves the Newburgh 
Brothel. 

52. Based on my review of GPS tracking data for 
Intercepted Cellphone-1 and Intercepted Cellphone-3 (both of 
which are known to be used by BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendant, as set forth below), I know 
that in April 2013, Intercepted Cellphone-1 and Intercepted 
Cellphone-3 were frequently in the vicinity of the Newburgh 
Brothel on, among other days, Saturdays and Mondays. Based on my 
training and experience, and my familiarity with this 
investigation, I believe that women working, or being forced to 
work, at the Newburgh Brothel are dropped off for a week of work 
on Monday and are picked up on Saturday. I further believe, 
based on the GPS tracking data described above, that BONIFACIO 
FLORES-MENDEZ is the person driving the women to and from the 
Newburgh Brothel from his residence in Queens, New York, during 
which trips BONIFACIO FLORES-MENDEZ drives through Bronx, New 
York. 

53. In addition, in calls intercepted on Intercepted 
Cellphone-1 and Intercepted Cellphone-3 pursuant to the February 
2013 Order and the April 2013 Order, BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant, engaged in 
conversations in which he discussed arranging for women to work 
in the Newburgh Brothel. For example, on or about April 14, 
2013, at approximately 10:54 a.m., BONIFACIO FLORES-MENDEZ spoke 
to Karen who said that she was "calling about the week starting 
tomorrow" and asked where she had to go. BONIFACIO FLORES-MENDEZ 
responded that she had to go to "Newburgh." 

54. Based on my training and experience, and my 
familiarity with this investigation, including the recording 
obtained by Customer-3, the GPS tracking data, and my review of 
summaries of calls intercepted pursuant to the February 2013 
Order and the April 2013 Order, I believe that the Newburgh 
Brothel is, in fact, a brothel, and that it is run by BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant. 

19 



SEX TRAFFICKING OF VICTIM-1 

55. In 2012 and 2013 I interviewed Victim-1, 2 who, as 
set forth below, gave an account of her experience being forced 
to engage in prostitution as a result of force, threats of force, 
and coercion by an individual known to her as "Isaias Flores­
Mendez." Victim-1 was shown a known photograph of ISAIAS FLORES­
MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," the defendant, and identified the person depicted 
in that photograph as the "Isaias Flores-Mendez" who caused 
Victim-1 to engage in prostitution against her will. Victim-1 
also identified a known photograph of BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant. 

56. Based on my interviews of Victim-1, I know the 
following: 

a. ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," and BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants, are 
brothers. 

b. ISAIAS FLORES-MENDEZ and BONIFACIO FLORES­
MENDEZ arranged for Victim-1 to be smuggled across the border 
from Mexico into the United States, and then for Victim-1 and her 
young child to take a flight from California to Queens, New York. 
After Victim-1 arrived in New York, BONIFACIO FLORES-MENDEZ took 
her to a house on 112th Street in Queens, New York (the "Degante 
Residence"), where she was made to sleep on the floor under the 
kitchen table with her young child. In exchange for these 
accommodations, the matriarch of the Degante Residence, who 
Victim-1 knew as ISAIAS FLORES-MENDEZ's former mother-in-law, 
told Victim-1 that Victim-1 would be required to pay $200 per 
month in rent, and $50 per week for food. 

c. BONIFACIO FLORES-MENDEZ was in New York with 
Victim-1 at the time, awaiting the arrival from Mexico of ISAIAS 
FLORES-MENDEZ. BONIFACIO FLORES-MENDEZ attempted to recruit 
Victim-1 to work as a prostitute, and provided Victim-1 with a 
notebook containing contact information for brothels and drivers. 

Victim-1 has provided reliable information that has been 
independently corroborated. Victim-1 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

20BONIFACIO FLORES-MENDEZ took Victim-1 to a brothel in Yonkers, 
New York. 

d. Once ISAIAS FLORES-MENDEZ arrived in New 
York, he and BONIFACIO FLORES-MENDEZ worked together to use 
threats, verbal abuse, and violence to force Victim-1 to engage 
in commercial sex against her will in the New York City area and 
in Yonkers. On one occasion, when Victim-1 refused to work as a 
prostitute, ISAIAS FLORES-MENDEZ pushed Victim-1 and her young 
child outside into the cold winter night, locked the door, and 
refused to let her back in. Later that night, when BONIFACIO 
FLORES-MENDEZ returned home and let Victim-1 and her young child 
back inside, ISAIAS FLORES-MENDEZ said, in sum and substance, 
that Victim-1 needed to learn what would happen if she disobeyed 
him. 

e. Utilizing brothels located in Manhattan, 
Bronx, Yonkers, and Brooklyn, ISAIAS FLORES-MENDEZ directly 
caused Victim-1 to perform commercial sex against her will daily, 
often servicing more than 20 customers per day. ISAIAS FLORES­
MENDEZ also sent Victim-1 to engage in commercial sex against her 
will in Maryland, Connecticut, New Jersey, and Pennsylvania. 

f. Based on Victim-1's observations, both ISAIAS 
FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ each had several women 
working for them, or being forced to work for them, as 
prostitutes. 

g. JUANA LUCAS-SANCHEZ, the defendant, worked 
for BONIFACIO FLORES-MENDEZ as a prostitute and served as an 
"enforcer" for ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ 
with respect to Victim-1. 

h. For example, LUCAS-SANCHEZ went shopping for 
revealing clothes to be worn by Victim-1. LUCAS-SANCHEZ also 
directed Victim-1 to work as a prostitute, and dictated which 
sexual acts Victim-1 should perform. LUCAS-SANCHEZ also directed 
Victim-1 to continue to engage in prostitution while 
menstruating. 

i. At one point, suspicion arose that Victim-1 
had become pregnant. In response, ISAIAS FLORES-MENDEZ, 
BONIFACIO FLORES-MENDEZ, and LUCAS-SANCHEZ took Victim-1 to a 
doctor, and forced her to take several pills that were described 
to her as Cytotec, which she understood were intended to induce a 

21 



miscarriage if she were pregnant. 

j. ISAIAS FLORES-MENDEZ took the money earned by 
Victim-1. When Victim-1 did not provide ISAIAS FLORES-MENDEZ 
with all of her earnings in a given day, he beat her. 

k. ISAIAS FLORES-MENDEZ, BONIFACIO FLORES­
MENDEZ, and LUCAS-SANCHEZ used cell phones to perpetrate this 
crime by communicating with each other and Victim-1 during the 
commission of the crime, by using cell phones to contact the 
drivers and brothel workers to find out how many customers 
Victim-1 had serviced in a given day so that ISAIAS FLORES-MENDEZ 
could collect all of the earnings and ensure that Victim-1 was 
not holding back any money, and by providing Victim-1 with at 
least one cell phone that Victim-1 was then required to use to 
arrange with drivers or brothel workers to engage in commercial 
sex. 

57. Based on my review of airline records, I know that 
in or about September 2006, Victim-1 and her young child flew 
from California to Queens, New York. 

SEX TRAFFICKING OF VICTIM-2 

58. In 2012 and 2013, I interviewed Victim-2, 3 who, as 
set forth below, gave an account of her experience being forced 
to engage in prostitution as a result of force, threats of force, 
and coercion by an individual known to her as "David Vasquez­
Medina." Victim-2 was shown a known photograph of DAVID VASQUEZ­
MEDINA, the defendant, and identified the person depicted in that 
photograph as the "David Vasquez-Medina" who caused Victim-2 to 
engage in prostitution against her will. Victim-2 also 
identified known photographs of ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants. 

59. Based on my interviews of Victim-2, I know the 
following: 

Victim-2 has provided reliable information that has been 
independently corroborated. Victim-2 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

22 



a. In or about 2006 1 while living in the United 
States/ Victim-2 met DAVID VASQUEZ-MEDINA 1 the defendant/ and 
began a romantic relationship with him. A few months later 
Victim-2 returned to Mexico with her child. Shortly thereafter/ 
VASQUEZ-MEDINA also returned to Mexico/ where he met Victim-2 1 S 

parents and announced his intention to marry her. 

b. In or about later 2006 1 VASQUEZ-MEDINA and 
Victim-2 1 S brother were smuggled back into United States. 
VASQUEZ-MEDINA then made arrangements for Victim-2 and her child 
to be smuggled into the United States. 

c. When Victim-2 first joined VASQUEZ-MEDINA 1 

both Victim-2 and VASQUEZ-MEDINA had legitimate work. After 
VASQUEZ-MEDINA lost his legitimate job 1 however/ VASQUEZ-MEDINA 
began working as a driver/ delivering women working/ or being 
forced to work 1 as prostitutes/ to farms in New Jersey where the 
women had sex with the farm workers. 

d. VASQUEZ-MEDINA told Victim-2 that she should 
work as a prostitute and that the women he drove made 200 dollars 
or more a day. Victim-2 told VASQUEZ-MEDINA that she did not 
wish to do such work. 

e. Thereafter/ Victim-2 lost her legitimate job 1 

and her brother 1 who had been working in another state/ came to 
live with Victim-2 and VASQUEZ-MEDINA. VASQUEZ-MEDINA became 
angry and verbally abusive towards Victim-2 because neither 
Victim-2 nor her brother were working and because Victim-2 1 S 

child cost a lot of money. 

f. After suffering verbal abuse concerning 
Victim-2 1 S failure to make money/ and the expense of her child 1 

and repeated pressure from VASQUEZ-MEDINA 1 Victim-2 agreed to 
work as a prostitute. VASQUEZ-MEDINA purchased provocative 
clothing for Victim-2. 

g. VASQUEZ-MEDINA drove Victim-2 to various 
farms in New Jersey where Victim-2 had sex with approximately 25 
clients per day. VASQUEZ-MEDINA charged the clients $30 for 15 
minutes of sex with Victim-2. VASQUEZ-MEDINA kept all of the 
money Victim-2 had been paid. 

h. On another occasion/ VASQUEZ-MEDINA made 
arrangements for Victim-2 to work out-of-state for a week. 

23 



During that week, Victim-2 had sex with approximately 70 to 80 
clients. At the end of the week Victim-2 was given approximately 
$1,000. Victim-2 then returned to VASQUEZ-MEDINA by traveling 
through Manhattan, at which time VASQUEZ-MEDINA told Victim-2 
that he had spoken to the individual for whom Victim-2 had worked 
and knew how much she had earned. VASQUEZ-MEDINA forced Victim-2 
to give him all of the money she had been paid. 

i. After approximately two more weeks of working 
as a prostitute, Victim-2 pleaded with VASQUEZ-MEDINA to permit 
her to stop working as a prostitute. Victim-2 offered to work 
two jobs in order to earn more money. In response, 
VASQUEZ-MEDINA punched Victim-2, and told her, in sum and 
substance, that she had choice and must continue to work as a 
prostitute. VASQUEZ-MEDINA threatened to tell Victim-2's family 
that she was working as a prostitute, and that she would be 
responsible for her mother, who had a weak heart, dying from the 
shock. VASQUEZ-MEDINA also said that if Victim-2 did not comply 
he would take her child and she would never see her child again. 

j. Victim-2 was afraid of VASQUEZ-MEDINA and 
therefore did as he instructed. For approximately two years 
after this exchange, Victim-2 worked in prostitution against her 
will and under the control of VASQUEZ-MEDINA. Initially, 
VASQUEZ-MEDINA would set up work for Victim-2, but as time went 
on, he required Victim-2 to find her own work. 

k. In or around 2008, VASQUEZ-MEDINA was 
arrested and deported to Mexico. Once VASQUEZ-MEDINA was 
deported, Victim-2 stopped working as a prostitute. She began 
selling flowers and living in the Degante Residence. 

1. While living in the Degante Residence, 
Victim-2 observed that the Degante-Galeno family, including, but 
not limited to ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galeno," a/k/a "El Zorro," MARIA BAUTISTA-PENA, a/k/a "Maricruz," 
MIGUEL ANGEL CHE-VELIZ, a/k/a "Miguelon," and ISIDRO DEGANTE­
GALENO, a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," 
MARGARITO DEGANTE, a/k/a "Chachalaco," the defendants, were also 
engaged in the prostitution business. Victim-2 observed 
discussions between various members of the Degante-Galeno family 
concerning their work in prostitution, discuss women being forced 
to work as prostitutes, and meet in the Degante Residence to 
discuss the division of prostitution money among family members. 
Victim-2 learned that members of the Degante-Galeno family were 

24 



working with ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," and BONIFACIO FLORES­
MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants. 

m. In approximately 2010, VASQUEZ-MEDINA began 
calling Victim-2 from Mexico. VASQUEZ-MEDINA told Victim-2 that 
he had changed and wanted to be with her and that he wanted to 
return to the United States. After he returned to the United 
States, however, Victim-2 learned that while in Mexico, 
VASQUEZ-MEDINA had begun a romantic relationship with Victim-2's 
sister, and that VASQUEZ-MEDINA was forcing Victim-2's sister, 
who had also come to the United s,tates, to work in prostitution. 

INTERSTATE TRANSPORTATION FOR PURPOSE OF PROSTITUTION 

60. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, and of reports of 
surveillance written by other law enforcement officers, I know 
the following. I know the following: 

a. On or about April 14, 2013, at approximately 
10:54 a.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota" 
received a call on Intercepted Cellphone-1 from a woman 
identified in this and other calls as "Karen" ("Karen"). During 
the call, Karen said that she was "calling about the week 
starting tomorrow," and asked where she could wait for BONIFACIO 
FLORES-MENDEZ. BONIFACIO FLORES-MENDEZ responded that they could 
meet on "111th and Roosevelt" at 8:30. 

b. On or about April 15, 2013, at approximately 
8:26a.m., BONIFACIO FLORES-MENDEZ received a call on Intercepted 
Cellphone-1 from Karen. During the call, the following 
conversation, in substance and in part, took place: 

KAREN: 

BONIFACIO: 

KAREN: 

BONIFACIO: 

I'm on my way there, but there is too 
much traffic here and I have not been 
able to get to Manhattan. 
All right then, meanwhile I pick up the 
rest. 
All right, I will call you when I get 
out of the Lincoln [U/I] . 
All right. 

c. Based on my training and experience, and my 
familiarity with this investigation, I believe that Karen is a 

25 



woman working, or being forced to work as a prostitute and that 
in the above call Karen told BONIFACIO FLORES-MENDEZ that she 
there was a lot of traffic en route to Manhattan through the 
Lincoln Tunnel to New Jersey and that she would be late. I 
further believe that BONIFACIO FLORES-MENDEZ said he would first 
pick up the other women working, or being forced to work, as 
prostitutes. 

d. Shortly thereafter, at approximately 8:51 
a.m., BONIFACIO FLORES-MENDEZ again used Intercepted Cellphone-1 
to speak to Karen. During the call, Karen said that she was 
"almost there," and BONIFACIO FLORES-MENDEZ confirmed that they 
were meeting on "111th." At approximately 9:12a.m., BONIFACIO 
FLORES-MENDEZ and Karen again spoke on Intercepted Cellphone-1 
and Karen said that she had arrived and BONIFACIO FLORES-MENDEZ 
responded that he would "pass by now." 

e. At approximately 9:35a.m., law enforcement 
agents observed a Black Honda registered to "Isaias Flores 
Mendez," parked at the intersection of 112th Street and Roosevelt 
Avenue, in Queens, New York. Just before the Black Honda drove 
away, law enforcement agents observed to unidentified Hispanic 
females in the back seat. 

f. Based on my training and experience and my 
participation in this investigation, I believe that Karen is a 
woman working or being forced to work as a prostitute and that in 
the above calls, she and BONIFACIO FLORES-MENDEZ discussed the 
fact that she would travel from New Jersey to meet him in order 
to be transported to a brothel for a week of work. I further 
believe that on or about April 15, 2013, BONIFACIO FLORES-MENDEZ 
met Karen in the vicinity of 112th Street and Roosevelt Avenue, 
picked her up, and transported her, and at least one other woman, 
to work at a brothel. 

g. On or about April 22, 2013, at approximately 
10:10 a.m., BONIFACIO FLORES-MENDEZ received a call on 
Intercepted Cellphone-1 from a woman who identified herself 
during the call as "Violeta" ("VIOLETA"). During the call, the 
following conversation, in substance and in part, took place: 

VIOLETA: 
BONIFACIO: 
VIOLETA: 

. It's Violeta speaking. 
Yes, call me on Sunday. 
Yes I am checking in and on Sunday I 
will call you. 

26 



BONIFACIO: 

VIOLETA: 

Okay. Call me on Sunday to see where I 
pick you up. You are the one that lives 
in New Jersey, right? 
Yes, yes, I will call you on Sunday. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that Violeta is a 
woman working, or being forced to work as a prostitute, and that 
in the above call BONIFACIO FLORES-MENDEZ said that Violeta 
should call him on Sunday to confirm where he would pick her up 
to take her to work at a brothel, and confirmed that she lives in 
New Jersey .. 

THE PROSTITUTION-SEX TRAFFICKING ENTERPRISE 

61. Since at least in or about 2008, ISAIAS 
FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zor~o," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and others known and unknown, have 
been working in a criminal business enterprise, which profits 
from the sale of human beings for sex. 

62. Women who work, or are forced to work, as 
prostitutes for participants of the enterprise typically work 
under the abhorrent conditions described in more detail in 
paragraphs 13 through 23, above. The participants in this 
criminal business enterprise serve different functions, operating 
brothels, manning the brothels, driving victims to brothels and 
to customers' residences for the purpose of engaging in 
prostitution, dispatching drivers, passing out chica cards to 
advertise the enterprise, and recruiting and overseeing the women 
who work, or are forced to work, as prostitutes. In order to 
carry out their crimes, members of this criminal business 
enterprise rely heavily on the use of cell phones, communicating 
with each other, with victims and potential victims, and with 
customers by cell phone multiple times each day. 

63. Based on my review of GPS tracking data obtained 

27 



pursuant to court-authorized warrants, the February 2013 Order, 
and the April 2013 Order, I know that on a daily basis, members 
of this conspiracy travel-through Bronx, New York en route to the 
Yonkers Brothel, the Newburgh Brothel, and the Poughkeepsie 
Brothel. 

ISAIAS FLORES-MENDEZ 

64. On or October 16, 2012, law enforcement agents 
conducting surveillance observed an individual later identified 
as ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a 
"Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, exit the 
Poughkeepsie Brothel and get into a vehicle and drive away. 
Later that day, law enforcement agents observed ISAIAS FLORES­
MENDEZ in the vicinity of the Newburgh Brothel. Based on my 
review of GPS tracking data for Intercepted Cellphone-3, which 
ISAIAS FLORES-MENDEZ was using on or about October 16, 2012, I 
know that he traveled from Queens, New York to Poughkeepsie, New 
York, and from Newburgh, New York back to Queens, New York by 
traveling through Bronx, New York. 

65. Based on my review of summaries of consensually 
recorded telephone communications made by ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," the defendant, while incarcerated4 at the Vernon C. Bain 
Center at Rikers Island ("Rikers Island") 5

, I know the following: 

a. On or about October 22, 2012, at 
approximately 9:36a.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ, 

4 ISAIAS FLORES-MENDEZ was incarcerated at Rikers Island 
from the time of his October 19, 2012, arrest until January 2, 
2013, when he was transferred into federal custody in this 
District on the basis of a complaint charging him with illegal 
reentry in violation of Title 8, United States Code, Section 
1326(a) (12 Mag. 3262). On or about January 14, 2013, ISAIAS 
FLORES-MENDEZ was indicted on the same charge (13 Cr. 31 (KBF)) 

5 Based on my conversations with other law enforcement 
agents and my review of documents concerning Rikers Island inmate 
phone policies, I know that a sign is posted near all phones, in 
both English and Spanish, which informs inmates that, "Inmate 
telephone conversations are subject to electronic monitoring 
and/or recording in accordance with Department policy." 

28 



a/k/a "Bani," a/k/a "Mota," the defendant. During the call, 
ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ discussed the 
fact that BONIFACIO FLORES-MENDEZ had located a tracking device 
on a 1998 red Ford Expedition bearing Maryland license plate 
number 40484M7 (the "Red Expedition"), which is registered to 
"Bonifacio Flores-Mendez" (the "red one"), and that he had 
removed the tracking device. BONIFACIO FLORES-MENDEZ further 
said that the problem was that he "already [has] the women with 
[him]," and that he was going to drop them off far away. ISAIAS 
FLORES-MENDEZ directed BONIFACIO FLORES-MENDEZ to leave the women 
at the Family Dollar store. BONIFACIO FLORES-MENDEZ said he 
would use an individual he referred to as "Chachalaco," who I 
believe to be MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, to go up there (meaning, to the Family Dollar store to 
get the women and take them to the brothel) . 

b. On or about October 30, 2012, at 
approximately 7:36p.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ. 
During the call, ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ 
engaged in the following discussion, in substance and in part: 

ISAIAS: 
BONIFACIO: 
ISAIAS: 
BONIFACIO: 

ISAIAS: 

BONIFACIO: 

Did you get women reported for Monday? 
Yes, Chela, for Brooklyn she said. 
Ah-ha. 
And another one who says that she had a 
fight in Poughkeepsie, she also reported 
herself for outside. 
Oh, for outside? Yes, yes, yes, 
she is. 

I know who 

Ah-ha. And another one. 
one too many . then the 
skinned Angelica for . 

. there was even 
. dark 

Yonkers. 

c. Based on my training and experience, and my 
participation in this investigation, I believe that in the above 
conversation, ISAIAS and BONIFACIO FLORES-MENDEZ discussed which 
women would work at which brothels and that BONIFACIO FLORES­
MENDEZ said that "Chela" would work at the Queens Brothel, 6 

6 Based on my review of this and other calls that reference a 
Brooklyn brothel, and my review of reports documenting 
surveillance, I know that the brothel referred to in this and 
other calls as being in Brooklyn is, in fact, the Queens Brothel 

29 



"Angelica" would work at the Yonkers Brothel, and that another 
woman, who previously had a fight at the Poughkeepsie Brothel, 
would work elsewhere, possibly through a delivery service 
("outside") . 

d. On or about November 8, 2012, at 
approximately 9:39a.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ. 
During the call, ISAIAS FLORES-MENDEZ told BONIFACIO FLORES­
MENDEZ in substance and in part, that: 

ISAIAS: I found a tall guy . his last name is 
Mendoza, at the church I [asked] "why 
did they put you in here?" . . he said, 
"domestic violence." [I asked] "so where are 
you from, guy?" Then he told me "Tenancingo," 

. "From there come the pimps, guy," I 
said. He starts laughing. "And how do you 
know that, guy?" [he asked] . I said, 
"because I work on that too, guy" . oh, 
then he started telling me . . "I wooed a 
young girl who . was fifteen [and] 
later on, like six months after that I put 
her to work, guy . . and then they catch 
her over there in . . Florida" . . I told 
him, "no kidding." 

e. Based on my training and experience and my 
participation in this investigation, I believe that in the above 
conversation, ISAIAS FLORES-MENDEZ told BONIFACIO FLORES-MENDEZ 
about a conversation ISAIAS FLORES-MENDEZ had with another inmate 
at Rikers Island. In that conversation, ISAIAS FLORES-MENDEZ 
said that he was aware that "pimps" come from Tenancingo, Mexico 
because ISAIAS FLORES-MENDEZ works in the business of "pimping" -
that is, works facilitating, causing, and/or compelling women to 
engage in prostitution for his financial gain. 

f. On or about November 13, 2012, at 
approximately 9:47p.m., ISAIAS FLORES-MENDEZ placed a call to an 
individual identified in other calls as "Angelica." During the 
conversation, ISAIAS FLORES-MENDEZ and Angelica discussed the 
fact that she was filling out various forms in anticipation of 

(which is very close to the Brooklyn-Queens border) . 

30 



the birth of her and ISAIAS FLORES-MENDEZ's child. During that 
conversation, ISAIAS FLORES-MENDEZ and Angelica had the following 
exchange: 

ANGELICA: 

ISAIAS: 

ANGELICA: 
ISAIAS: 

ANGELICA: 
ISAIAS: 

ANGELICA: 
ISAIAS: 

And they don't ask anything - no name or 
anything? 
Well, of course. So give mine. Isaias 
Flores-Mendez. 
Should I give yours? 
Yeah. Isaias Flores-Mendez. Don't give 
another name . . yeah, because I have 
everything with that name, my passport and 
all . . and in any case, I'll have time to 
arrive, for the birth certificate, I can 
sign it and all. 
Oh, all right. 

.Yeah, you can say the num . 
father's number, give that one. 
Uh huh. 

. his 
686 4929. 

I'm also going to change my 686 number . 
and I'll start calling the women with that 
one . . because the 686 . . one is 
also really burnt . but that would be 
when I arrive . . and open other places 
and start working really hard for my son. 

g. Based on my training and experience, and my 
participation in this and other investigations, I believe that in 
the above call ISAIAS FLORES-MENDEZ told Angelica to list his 
phone number as Intercepted Cellphone-1 and told her that after 
he returned to the United States (following his likely 
deportation when the then pending state criminal charges were 
resolved) he intended to get a new phone with which to speak with 
women working, or being forced to work, as prostitutes ("I'll 
start calling the women with that one") because Intercepted 
Cellphone-1 ("the 686 one") was "burnt," meaning that law 
enforcement authorities had become aware of his use of that 
number. ISAIAS FLORES-MENDEZ further stated that he intended to 
open additional brothels ("open other places") upon his illegal 
reentry from Mexico in order to support his son. 

BONIFACIO FLORES-MENDEZ 

66. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 

31 



following: 

a. On or about April 14, 2013, at approximately 
12:21 p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendant, received a call on Intercepted Cellphone-1 from a 
woman who identified herself on the call as "Elizabeth" 
("Elizabeth"). During the call, the following conversation, in 
substance and in part, took place: 

ELIZABETH: 

BONIFACIO: 
ELIZABETH: 

BONIFACIO: 

I am calling to check in, I am with you 
next week in Brooklyn. 
Okay, call me on Sunday then. 
Listen, did you check for the 29th, to 
Newburgh . you told me you were going 
to check last night. 
No right now I am up here in Newburgh 
Call me tonight and we will check. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that Elizabeth is 
a woman working, or being forced to work, as a prostitute for 
BONIFACIO FLORES-MENDEZ and his co-conspirators. In this call, 
she asked BONIFACIO FLORES-MENDEZ for a week of work beginning on 
April 29, 2013, at the Newburgh Brothel. 

c. On or about April 15, 2013, at 
1:34 p.m., BONIFACIO FLORES-MENDEZ received a call 
Cellphone-3 from an unidentified male ("UM-8311"). 
call, the following conversation, in substance and 
place: 

UM-8311: 
BONIFACIO: 
UM-8311: 
BONIFACIO: 
UM-8311: 
BONIFACIO: 

How are the girls now? 
Good; --
Better than last week? 
A lot better. 
Where are they from? 
Dominican and Mexican. 

approximately 
on Intercepted 
During the 

in part, took 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that UM-8311 is a 
customer of a brothel run by BONIFACIO FLORES-MENDEZ. In this 
call, UM-8311 asked about the women working, or being forced to 
work, as prostitutes in the brothel, and BONIFACIO FLORES-MENDEZ 
provided their countries of origin and said they were a lot 
better than the women who had been working in the brothel last 

32 



week (alluding to the fact that the women work in the brothel in 
one-week shifts). 

e. On or about April 23, 2013, at approximately 
9:17p.m., BONIFACIO FLORES-MENDEZ placed a call on Intercepted 
Cellphone-1 to a woman who identified herself during the call as 
"Alejandra," ("Alejandra"). During the call, the following 
conversation, in substance and in part, took place: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRO: 

BONIFACIO: 

ALEJANDRA: 
BONIFACIO: 

· ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 
BONIFACIO: 

ALEJANDRA: 

Did you call me? 
Yeah, I call you yesterday. My name is 
Alejandra. 
For when? 
I don't know. Whenever you . well, 
whatever week is available sometime soon. 
For where do you want? 
Ummm . . one to stay and one for round 
trip. 
Okay for May . 
already have . 
one that I have is 
stay. 

hold on . April I 
Hmmm . the closest 
May 6th and May 13th to 

Okay well put me down for the 13th to stay. 
. Okay, for Yonkers Round trip . 

you want for . . May 20th . [to 
self:] ' Mayra, Diana, 27th, Wendy, Joanna, 
Dulce. ' Hmmm . . the 10th of June? 
No, for the 10th of June I already have 
that one . . do you have for the 24th? 
What about the first of July? 
Yes I the 1st yes. 
Put me down for that one round trip . 
because they told me that you have 3 . 
I don't know if 
I have 4. 
Oh, you have 4? 
Yeah, I have 2 to stay upstairs and I have 
2 round trip, one for Brooklyn and one for 
Yonkers . okay so I have you for May 
13th to stay over . . May 20th for 
Brooklyn and . let's see .. which 
one did you tell me? The 1st of July, 
right? 
Uh huh. For Yonkers. But the two that are 
to stay over are for the same location or 

33 



BONIFACIO: 

ALEJANDRA: 
BONIFACIO: 

in different places? 
No they are different. They are like 40 
minutes from each other. 
Oh, in Newburgh . 
One is in Newburgh and the other one is in 
Poughkeepsie. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that Alejandra is 
a woman working, or being forced to work, as a prostitute, and 
that in the above call she was making arrangements to work for a 
week at a time at various brothels run by BONIFACIO FLORES­
MENDEZ. In this call, BONIFACIO FLORES-MENDEZ describes the fact 
that he has four brothels, two at which the women working stay 
for the entire week, including sleeping at the brothel ("2 to 
stay") and two at which the women arrive each morning of the 
designated week and return home each evening of that week ("two 
round trip") . 

67. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-1 is used by BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant: 

a. Based on my conversations with Victim-2, I 
know that (i) ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
used Intercepted Cellphone-1 (ii) BONIFACIO FLORES-MENDEZ and 
ISAIAS FLORES-MENDEZ are brothers; and (iii) BONIFACIO 
FLORES-MENDEZ uses the nickname "Mota." 

b. Based on my review of wire remitter records 
from Casa De Cambio and Western Union, I know that both BONIFACIO 
FLORES-MENDEZ and ISAIAS FLORES-MENDEZ listed Intercepted 
Cellphone-1 as their phone number when sending wire transfers to 
Mexico. 

c. Based on my review of consensually recorded 
and intercepted calls over Intercepted Cellphone-1, I know that 
(i) Intercepted Cellphone-1 has continued to be in use since 
ISAIAS FLORES-MENDEZ's arrest in October 2012; (ii) the 
individual using Intercepted Cellphone-1 is referred to in calls 
as "Mota;" (iii) ISAIAS FLORES-MENDEZ has placed numerous calls 
to Cellphone-1 during which ISAIAS FLORES-MENDEZ has discussed 
the user of Intercepted Cellphone-1, the health of their mother 

34 



and the business of prostitution, among other topics. 

CARLOS GARCIA-DE LA ROSA 

68. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 23, 2013, at 
approximately 11:04 a.m., CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," the defendant, using 
Intercepted Cellphone-2, received an incoming call from an 
unknown male ("UM-1203"). During the intercepted call, the 
following conversation, in part, took place: 

UM-1203: Do you have something? 
DE LA ROSA: Yes . 
UM-1203: But where because I went to the other one, 

the one with the red door, and there was no 
one there. 

DE LA ROSA: No, I moved. I'm close by. Do you know 
where Pancho Villa is? 

UM-1203: Yeah. 
DE LA ROSA: Go over there and I'll pick you up. 
UM-1203: Oh. 
DE LA ROSA: Just tell me what you are wearing and I'll 

pick you up. 
UM-1203: No, listen, I'll call you during the week. I 

just want to know where it is. 
DE LA ROSA: Do you know where Rose Place is? Next to the 

gas station. It's house number [number 
provided] . 

UM-1203: Oh, house number [number provided]? 
DE LA ROSA: Yes, two bells on the right. It's on the 

second floor. 
UM-1203: So, I ring bell number 2? 
DE LA ROSA: Yes, both of the bells are working for 

upstairs or call me and I'll come down and 
pick you up. 

UM-1203: Cool. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that GARCIA-DE LA 
ROSA is a runner who works for BONIFACIO FLORES-MENDEZ and his 
co-conspirators. In his role as a runner, GARCIA-DE LA ROSA 

35 



transports women working, or being forced to work, as prostitutes 
to and from the brothels operated by BONIFACIO FLORES-MENDEZ, or 
to outside clients, and also transports customers to and from 
these brothels. Here, a prospective customer is speaking to 
GARCIA-DE LA ROSA about the location of the brothel in 
Poughkeepsie. GARCIA-DE LA ROSA offers to drive the customer to 
the brothel ("just tell me what you are wearing and I'll pick you 
up"), but the customer says he is simply trying to learn the 
location ("no, listen, I'll call you during the week. I just 
want to know where it is."). GARCIA-DE LA ROSA then identifies 
the location of the brothel in Poughkeepsie ("do you know where 
Rose Place is? Next to the gas station. It's house number 
[number provided]"). The address provided by GARCIA-DE LA ROSA 
on Rose Place is the address of the Poughkeepsie Brothel. 

c. On or about February 23, 2013, at 
approximately 10:10 p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant, using Intercepted Cellphone-2, 
received an incoming call from GARCIA-DE LA ROSA. During the 
intercepted call, the following conversation, in part, took 
place: 

DE LA ROSA: 

BONIFACIO: 
DE LA ROSA: 

BONIFACIO: 

DE LA ROSA: 

Don't take any money from there. I'll 
give you the envelope tomorrow. I have 
you today's envelope and tomorrow you 
give it to me. 
Cool. 
Yeah, because if not [U/I]. I didn't 
see when she called you. 
She said, "hey, tell Choqui to call me." 
Fucking flaca told her that my girl left 
already. 
No, I said, "I'm leaving, aunt." I 
didn't bother you anymore. I said, 
"maybe this guy doesn't want to." I'm 
going to pass by and give you the 
receipt. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that GARCIA-DE LA 
ROSA and BONIFACIO FLORES-MENDEZ are discussing the distribution 
of illegal prostitution/trafficking proceeds from the brothels 
operated by the criminal business enterprise. In this call, 
GARCIA-DE LA ROSA tells BONIFACIO FLORES-MENDEZ not to "take any 
money from there," which I believe is a reference to the 

36 



brothels. 

e. On or about February 26, 2013, at 
approximately 8:46a.m., BONIFACIO FLORES-MENDEZ, using 
Intercepted Cellphone-1, placed an outgoing call to a woman 
identified during other calls to the same number as "Mayra" 
("Mayra"). During the intercepted call, the following 
conversation, in part, took place: 

MAYRA: Hello. 
BONIFACIO: Choqui says he's at the corner on 108 

and 32. 
MAYRA: Okay. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that Mayra is 
working, or being forced to work, as a prostitute for BONIFACIO 
FLORES-MENDEZ and his co-conspirators. During this call, 
BONIFACIO FLORES-MENDEZ instructs Mayra to go to a corner where 
GARCIA-DE LA ROSA is waiting to drive Mayra to a brothel. 

g. On or about March 5, 2013, at approximately 
3:51p.m., GARCIA-DE LA ROSA, using Intercepted Cellphone-2, 
received an incoming call from an unknown male ("UM-7794"). 
During the intercepted call, the following conversation, in part, 
took place: 

UM-7794: The girls of Poughkeepsie. 
DE LA ROSA: Yes, come. 
UM-7794: From where? 
DE LA ROSA: Mexico. 
UM-7794: I'll be there later. 
DE LA ROSA: Okay, when you get here just knock. 
UM-7794: Okay. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
a prospective customer is speaking to GARCIA-DE LA ROSA about the 
women working, or being forced to work, as prostitutes at the 
Poughkeepsie Brothel. The customer wants to know where the women 
are from, and GARCIA-DE LA ROSA responds that they are from 
Mexico. The customer said he would arrive to the brothel later, 
and GARCIA-DE LA ROSA told the customer to knock when he arrives. 

i. On or about March 5, 2013, the following 

37 



calls were intercepted on Intercepted Cellphone-2: 

i) At approximately 3:55p.m., GARCIA-DE LA 
ROSA, using Intercepted Cellphone-2, received an incoming call 
from BONIFACIO FLORES-MENDEZ. During the intercepted call, the 
following conversation, in part, took place: 

DE LA ROSA: 
BONIFACIO: 
DE LA ROSA: 

Tell me chipotles. 
You have one downstairs. 
Okay, okay. 

ii) Approximately twenty-five minutes later, 
GARCIA-DE LA ROSA, using Intercepted Cellphone-2, received 
another call from BONIFACIO FLORES-MENDEZ, during which the 
following conversation, in part, took place: 

DE LA ROSA: Tell me, chipotles. 
BONIFACIO: You have one downstairs chiptudoi. 
DE LA ROSA: Okay, okay. 

iii) A few hours later, at approximately 7:06 
p.m., GARCIA-DE LA ROSA, using Intercepted Cellphone-2, received 
an incoming call from BONIFACIO FLORES-MENDEZ. During the 
intercepted call, the following conversation, in part, took 
place: 

DE LA ROSA: 
BONIFACIO: 
DE LA ROSA: 
BONIFACIO: 

Chipotles. 
The guy is downstairs. 
He is already inside dumbass. 
Okay, okay. 

iv) Based on my training and experience, and 
my familiarity with this investigation, I believe that in each of 
these calls, BONIFACIO FLORES-MENDEZ is alerting GARCIA-DE LA 
ROSA to calls BONIFACIO FLORES-MENDEZ has received from 
customers, indicating that there are customers coming to the 
brothel (e.g., "you have one downstairs"), and that GARCIA-DE LA 
ROSA, in his capacity as doorman or steerer, should let them 
inside. 

69. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-2 was used by CARLOS GARCIA-DE 
LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a "Miguel," the 
defendant: 

38 



a. As described in further detail above, on or 
about March 8, 2013, GARCIA-DE LA ROSA was administratively 
arrested. At the time of his arrest, GARCIA-DE LA ROSA was in 
possession of Intercepted Cellphone-2. GARCIA-DE LA ROSA 
admitted that Intercepted Cellphone-2 was his phone. 

ALEJANDRO DEGANTE-GALENO 

70. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order and the April 
2013 Order, I know the following: 

a. On or about February 26, 2013, at 
approximately 1:36 p.m., ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zorro," the defendant, 
using Intercepted Cellphone-5, placed an outgoing call to an 
unidentified female ("UF-3569"). During the intercepted call, 
the following conversation, in part, took place: 

UF-3569: 
ALEJANDRO: 

UF-3569: 
ALEJANDRO: 

UF-3569: 

Hello. 
This motherfucker didn't go in. He wanted to 
do it without a condom. Tell him no next 
time. Negro gave me one right now 89 and 
35th. I'm going to do that one and then I'm 
going to head up for yours, okay. 
Cool. 
Keep him there. Keep him there. Tell him 
that the girl is 17 years old. 
Okay. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that, during this 
call, ALEJANDRO DEGANTE-GALENO was driving a car that dropping 
off and picking up women working, or being forced to work, as 
prostitutes from addresses of customers. In this call, UF-3569 
was acting as a dispatcher, was directing ALEJANDRO DEGANTE­
GALENO to various pick-up and drop-off locations. ALEJANDRO 
DEGANTE-GALENO references a particular woman who refused to 
engage in commercial sex with a customer because the customer was 
unwilling to wear a condom. ALEJANDRO DEGANTE-GALENO told UF-
3569 to keep a particular customer interested by telling him that 
the woman working, or being forced to work, as a prostitute who 
was to be delivered to the customer is only 17 years old. 

39 



c. On or about April 15, 2013, at approximately 
12:36 p.m., ALEJANDRO DEGANTE-GALENO received a call on 
Intercepted Cellphone-5 from ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro". During the call, 
the following conversation, in substance and in part, took place: 

ISIDRO: 

ALEJANDRO: 
ISIDRO: 
ALEJANDRO: 

He said the door is open to go up to the 
second floor he'll open for her. 
Okay, 2nd Floor. 
Uh huh. 
It's [street number] 32nd right? 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
ISIDRO DEGANTE-GALENO was serving as a dispatcher for ALEJANDRO 
DEGANTE-GALENO, and was relaying information from a customer 
about customers' location. 

e. On or about April 15, 2013, at approximately 
9:29p.m., ALEJANDRO DEGANTE-GALENO received an incoming call on 
Intercepted Cellphone-5 from an individual identified on other 
calls as both "Sergio" and "Huesito" ("Huesito"). During the 
call, the following conversation, in substance and in part, took 
place: 

HUESITO: 
ALEJANDRO: 
HUESITO: 
ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

Where are you? 
I will be there real soon. 
Okay. 
There's nothing? 
No, the four that we had are already 
covered. 
Okay. 
Yeah, I already made you the favor for 
the day ones. 
Take the day and the night too. 
Yes, I stayed with her the weekend night 
time too . I thought I was going to 
be able to do okay with Chachalaco's but 
I have to give some time to Monica as 
well . . yeah, I called her [Monica] 
because I didn't have anyone else. 
Oh. 
I had Monica because I didn't have 
anyone else. But today I got that girl 
that was with Chachalaco. 

40ALEJANDRO: 
HUESITO: 
ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUES ITO: 
ALEJANDRO: 

HUESITO: 
ALEJANDRO: 

Yeah. 
I almost didn't get her 
Now until 4 am, right? 
Yeah, even if its early 
still fuck around 
day or night. 
Yeah. 

or late we'll 
they prostitute 

At what time is that girl getting there? 
Today she came in the day time. 
Tomorrow she comes in at three . 
yeah, I told you she came in today at 
eight in the morning. She finished 
around five. 
Oh, so she got to the house already? 
Yeah. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
Huesito and ALEJANDRO DEGANTE-GALENO are discussing their 
procurement of women working, or being forced to work, as 
prostitutes, including one who works for "Chachalaco," which I 
believe refers to MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, and the fact that the women will work day or night. 

g. On or about April 18, 2013, at approximately 
5:08p.m., ALEJANDRO DEGANTE-GALENO placed a call on Intercepted 
Cellphone-5 to an individual identified on other intercepted 
calls as "Juancho" ("Juancho"). During the call, the following 
conversation, in substance and in part, took place: 

ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 

JUANCHO: 

ALEJANDRO: 

JUANCHO: 
ALEJANDRO: 
JUANCHO: 

They said that new girl is good. 
Oh she's new. 
Yes, Nano said it's a girl. 
Oh, she's new? 
Yes. 
How old you think she is? 
She's only 17 and they're fucking her 
already. 
No kidding, she's young she looks 
good? 
Huesito, Chachalaco and Mario already 
had her. 
Damn! All of them! 
Yes. 
They're lucky. 

41 



ALEJANDRO: 

JUANCHO: 

ALEJANDRO: 

JUANCHO: 

It shows that she does it good. They 
said that she does it good. 

. Do you think she wants anything 
with you? 
I want to but the young guys got her 
already. 
There's nothing boss. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
ALEJANDRO DEGANTE-GALENO and Juancho are discussing a new female 
working, or being forced to work, as a prostitute, who was only 
17 years old ("Minor Victim-2"). ALEJANDRO DEGANTE-GALENO 
indicated that MARGARITO DEGANTE, a/k/a "Chachalaco," and men 
identified as Huesito and Mario, had each had Minor Victim-2 work 
as a prostitute for them already (or, alternatively, that they 
had each already had sex with Minor Victim-2) and that ALEJANDRO 
DEGANTE-GALENO would like to have Minor Victim-2 work for (or, 
alternatively, have sex with) him. 

71. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-5 is used by ALEJANDRO 
DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a "El 
Zorro," the defendant: 

a. Based on my review of subscriber information 
for Intercepted Cellphone-5, I know that Intercepted Cellphone-5 
is subscr;Lbed in the name "Alejandro Mendoza." 

b .. Based on my review of Western Union records, 
I know that in connection with wire transfers to Mexico, 
ALEJANDRO DEGANTE-GALENO listed Intercepted Cellphone-5 as his 
phone number on multiple wire transfers. 

c. Based on my interview of Victim-2, I know 
that ALEJANDRO DEGANTE-GALENO uses Intercepted Cellphone-5. 

MARIA BAUTISTA-PENA 

72. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 
following: 

a. On or about April 20, 2013, at approximately 

42 



2:49p.m., ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galeno," a/k/a "El Zorro," the defendant, placed a call from 
Intercepted Cellphone-5 to MARIA BAUTISTA-PENA, a/k/a "Maricruz," 
who was using a cell phone with a call numper ending in 3569 
"Cellphone-3569"). During the call, the following conversation, 
in substance and in part, took place: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 
ALEJANDRO: 
BAUTISTA-PENA: 

How many calls do you have? Tell me 
the ones you have done. 
Give me time . . Look [street 
address] 37~ passed one . 
Okay, [street address] on 45~ 

[street address] on 37~ 
there are three. 
What? There are three, right? 
three that are yours? 
Yes, plus this one that is [street 
address] 101th. There will be four. 
Four of yours and one from Barbas 
that I did now. 
Five. 
Five, right? 
Uh huh. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO delivers women working, or being forced to work, 
as prostitutes to customers' residences and that BAUTISTA-PENA 
works as a dispatcher, receiving calls from customers and 
relaying orders to ALEJANDRO DEGANTE-GALENO. In this call, 
BAUTISTA-PENA said that she had taken four orders for women from 
customers, and that another individual identified as "Barbas" had 
taken one. 

c. On or about April 21, 2013, at approximately 
3:52p.m., ALEJANDRO DEGANTE-GALENO received a call on 
Intercepted Cellphone-5 from BAUTISTA-PENA, using Cellphone-3569. 
During the call, the following conversation, in substance and in 
part, took place: 

BAUTISTA-PENA: He said he's at the door and no one is 
there. 

ALEJANDRO: Okay wait. Come over here. . There are 
some guys here. Tell him that she's at 
the door. 

43 



BAUTISTA-PENA: He's outside. I'll ask what he's 
wearing. 

ALEJANDRO: Don't hang up. Wait. I think she went 
in. I'm going to do it for 40. 

BAUTISTA-PENA: Okay, Bye. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
BAUTISTA-PENA said a customer - who was waiting for the delivery 
of a woman working, or being forced to work, as a prostitute -
said that he was at the door and no one was there. ALEJANDRO 
DEGANTE-GALENO said the woman had gone in (to the customer's 
residence) and that he was going to charge the customer $40 for 
the commercial sex. 

e. On or about April 22, 201·3, at approximately 
5:25p.m., ALEJANDRO DEGANTE-GALENO placed a call on Intercepted 
Cellphone-5 to BAUTISTA-PENA, using a cell phone with a call 
number ending in 2740 ("Cellphone-2740"). During the call, the 
following conversation, in substance and in part, took place: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 
ALEJANDRO: 

The girls is inside but the guy is 
not opening the door. 
The [] guy is calling, he says that 
he is there. 
But what the hell! What do you do? 
What do you do? She is there. It is 
[street address] . 
71! 71! I told you. 
Oh, 71, 71 okay, okay. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call ALEJANDRO DEGANTE-GALENO said that the woman working, or 
being forced to work as a prostitute, who ALEJANDRO DEGANTE­
GALENO was delivering to a customer's residence was inside the 
customer's building but the customer was not answering the door. 
BAUTISTA-PENA, working as a dispatcher, was on the phone with the 
customer at the same time, and told ALEJANDRO DEGANTE-GALENO that 
the customer was at the door. When it became clear that 
ALEJANDRO DEGANTE-GALENO had gone to the wrong address, BAUTISTA­
PENA directed him to the correct address. 

73. Based on my training and experience, my 
participation in this investigation, and the following facts, I 

44 



believe that Cellphone-3569 and Cellphone-2740 are used by MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," the defendant: 

a. Based on my review of subscriber information 
for the Cellphone-3569, I know that it is subscribed to "Maria 
Bautista" at the Degante Residence. 

b. Based on my conversations with Victim-2, I 
learned that (i) ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante Galena," a/k/a "El Zarro," the defendant, and his 
significant other, "Maria Bautista," live at the Degante 
Residencei (ii) that Celestino Degante uses the phone number of 
Intercepted Cellphone-5i and that "Maria Bautista" answers 
phones for the prostitution business. 

c. Based on the content of the numerous 
intercepted calls between Intercepted Cellphone-5 and the 
Cellphone-3569, I believe that (i) the user of Cellphone-3569 
goes by the name "Maricruz," (ii) the user of Intercepted 
CELLPHONE-5 and Cellphone-3569 are in a relationship and (iii) 
that the user of Cellphone-3569 works as a dispatcher for a 
prostitution delivery service. 

d. Based on a comparison of the voice of the 
individual using Cellphone-3569 and the voice of the individual 
using the Cellphone-2740, I believe that both phones are being 
used by the same person. 

ISIDRO DEGANTE-GALENO 

74. Based on my interviews of Victim-2, I know that 
ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El Perro," the 
defendant, has worked, at various times, as a driver, delivering 
women who work, or are forced to work, as prostitutes to brothels 
and/or to the residences of customers. 

75. Based on my interviews of a woman ("Victim-3") 7 

who was trafficked by an individual not named herein, I know that 
ISIDRO DEGANTE-GALENO a/k/a "Marcos," a/k/a "El Perro," the 
defendant, has worked, at various times, as a driver, delivering 

7 Victim-3 has provided reliable information that has been 
independently corroborated. Victim-3 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

45 



women to the residences of customers for the purposes of 
prostitution. ISIDRO DEGANTE-GALENO was one of the drivers who 
transported Victim-3 to customers for the purpose of engaging in 
prostitution. ISIDRO DEGANTE-GALENO is also known as "Marcos" 
and "El Perro." 

76. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order and the April 
2013 Order, I know the following: 

a. On or about February 22, 2013, at 
approximately 10:06 p.m., ISIDRO DEGANTE-GALENO, a/k/a "Marcos," 
a/k/a "El Perro," the defendant, using Intercepted Cellphone-4, 
received an incoming call from an unidentified male ("UM-1922"). 
During the intercepted call, the following conversation, in part, 
took place: 

UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 

UM-1922: 

ISIDRO: 

What girls do you have? 
From Salvador and Mexico. 
How do they look? 
They both look good. 
Can you bring me - how much do you charge? 
35. 
For how long? 
10-15 minutes. 
And half an hour? 
70. 
What's the least? 
70. 
Can you do it for 60? 
No, that's what they charge you. 35 for 
[u/ i] . 
Can you bring one to Astoria? To [street 
address] 30th Road? 
Give me 20 minutes. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that UM-1922 is a 
potential customer of ISIDRO DEGANTE-GALENO, who is working as a 
driver conducting deliveries of women working, or being forced to 
work, as prostitutes. The customer inquires about the 
availability of prostitutes, and ISIDRO DEGANTE-GALENO responds 
that he has women available who are El Salvadorean and Mexican. 
The customer then asks about pricing. ISIDRO DEGANTE-GALENO 
explains that the price is $35 for 10-15 minutes of sex, or $70 

46 



for a 30 minutes. Although the customer tries to negotiate a 
lower price, ISIDRO DEGANTE-GALENO says that it is not possible. 
The customer then asks for a woman to be delivered to a specific 
address, and ISIDRO DEGANTE-GALENO agrees. 

c. On or about March 10, 2013, at approximately 
10:06 p.m., ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El 
Perro," using Intercepted Cellphone-4, had a telephone 
conversation, direction unknown, with an unidentified male 
("UM"), using an unidentified/unregistered cell phone. During 
the intercepted call, the following conversation, in part, took 
place: 

UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 

Hey friend, are you working? 
Yes. 
What do you have? 
Salvador and Mexico. 
Which is better? 
They're both good. 
Okay, bring one. 
To where? 
[Street address] 39th Avenue on Roosevelt. 
Okay, give me 15 minutes. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that the UM is a 
customer who is asking ISIDRO DEGANTE-GALENO about the 
availability of women working, or being forced to work, as 
prostitutes ("What do you have . . . which is better") . The 
customer then asked ISIDRO DEGANTE-GALENO to deliver a woman to a 
specific address in Queens for sex ("bring one"), and ISIDRO 
DEGANTE-GALENO responded that he would have the woman at that 
address in "15 minutes." 

77. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-4 is used by ISIDRO DEGANTE­
GALENO, a/k/a "Marcos," a/k/a "El Perro," the defendant: 

a. Based on my review of subscriber records for 
Intercepted Cellphone-4, I know that it is subscribed in the name 
"Marcos Degante." 

b. Based on my conversations with Victim-2, I 
know that ISIDRO DEGANTE-GALENO uses Intercepted Cellphone-4 and 

47 



that ISIDRO DEGANTE-GALENO uses the nickname "Marcos," among 
others. 

c. Based on my conversations with a third 
victim, Victim-3, I know that Victim-3 called ISIDRO 
DEGANTE-GALENO on Intercepted Cellphone-4 to arrange for ISIDRO 
DEGANTE-GALENO to drive Victim-3 to brothels and/or to the 
residences of customers. 

MARGARITO DEGANTE 

78. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 26, 2013, the following 
conversations were intercepted on Intercepted Cellphone-5: 

i) At approximately 5:04p.m., ALEJANDRO 
DEGANTE-GALENO, a/k/a "Celestino Degante Galeno," a/k/a "El 
Zorro," the defendant, using Intercepted Cellphone-5, received an 
incoming call from an unidentified female working, or being 
forced to work, as a prostitute ("UF-4240") and MARGARITO 
DEGANTE, a/k/a "Chachalaco," the defendant, using a cell phone 
with a call number ending in 4240 ("Cellphone-4240"), during 
which the following conversation took place, in sum and 
substance: 

MARGARITO: 

ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 

UF-4240: 

ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 

Call him. [Street address] hasn't come 
out yet. 
29 
Oh, it's 29? 
Yes. Hold on. I have him on the line. 
Hello. 
He said to come to the door. He's there 
already. 
Okay. I have him on the other line. 
Chalaco? Chalaco? 
Yes. 
Hey. She said that he's at the door. 
Number 29. Send her. 
Okay, [street address]. 
Yes, I'll wait for you at [street name]. 
I'm going to leave. 
Okay, I saw him already. 

48 



ii) Based on my training and experience, and 
my familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO, UF-4240, and MARGARITO DEGANTE are discussing the 
delivery of a woman working, or being forced to work, as a 
prostitute to a customer for the purpose of engaging in 
commercial sex. In this call, while driving UF-4240 to a 
customer, MARGARITO DEGANTE is updating ALEJANDRO DEGANTE-GALENO 
about the customer's whereabouts, noting to ALEJANDRO DEGANTE­
GALENO that the customer is not yet in sight ("hasn't come out 
yet"). ALEJANDRO DEGANTE-GALENO gives MARGARITO the correct 
address, which MARGARITa acknowledges, and then proceeds with the 
transaction ("Okay, I saw him already.") . 

iii) A few minutes later, at approximately 
5:08p.m., MARGARITO DEGANTE, using Cellphone-4240, placed a call 
to ALEJANDRO DEGANTE-GALENO, using Intercepted Cellphone-5, 
during which the following conversation took place, in sum and 
substance: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 
MARGARITO: 

ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 

Where are you? 
Come right here to the other one. Come to . 

. what you call it? Come to seventy-first. 
Right? 
A ha, yeah. On [street name] . 
Yeah, is that where that bitch stays? 
Yes. She's stayed there. But they haven't 
passed yet. 
Yeah, why don't you come down the next one, 
dude? 
On seventy-second? 
71, 72, yes, 73. 
Seventy-third and what? 
Seventy-third and [street name], dude. 
Alright. I just passed seventy-second. 
Okay. 

iv) Based on my training and experience, and 
my familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO and MARGARITO DEGANTE are discussing meeting up in 
their cars on the street outside of a customer's address while 
they wait for a woman who is working, or being forced to work, as 
a prostitute to complete an appointment with a customer. 

v) Almost two hours later, at approximately 
6:54p.m., MARGARITa DEGANTE, using Cellphone-4240, placed a call 

49 



to ALEJANDRO DEGANTE-GALENO, using Intercepted Cellphone-5, 
during which the following conversation took place, in sum and 
substance: 

ALEJANDRO: 
MARGARITO: 

Where are you? In the car? 
I'm here. I came out to the corner here to 
pass some cards out. I'm going over there 
dude. 

vi) Based on my training and experience, and 
my familiarity with this investigation, I believe that in this 
call, MARGARITO DEGANTE indicates that he is on a corner passing 
out chica cards to advertise the prostitution enterprise. 

79. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-4240 is used by MARGARITO DEGANTE, a/k/a 
"Chachalaco," the defendant: 

a. Based on my conversations with Victim-2, I 
know that MARGARITO DEGANTE goes by the nickname Chachalaco. 

b. Based on my review of intercepted calls, I 
know that the user of the 4240 Cellphone uses the nickname 
Chachalaco and that the user of the 4240 Cellphone uses the 4240 
Cellphone to speak to members of the Degante-Galeno family, 
including ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galena," a/k/a "El Zarro," the defendant. 

VALENTIN JIAMEZ-DOLORES 

80. On or about November 21, 2012, law enforcement 
agents conducting surveillance of the Yonkers Brothel observed an 
individual later identified as VALENTIN JIAMEZ-DOLOREZ, the 
defendant, exit the Yonkers Brothel and get into the Red 
Expedition. During a stop of that vehicle by law enforcement 
agents, JIAMEZ-DOLORES claimed that he did not have any 
identification documents on him, but proffered that his name was 
"Valentine Jaimes," and provided a date of birth and a street 
address. 

81. As described above, on or about December 20, 2012, 
law enforcement agents interviewed VALENTIN JIAMEZ-DOLORES, the 
defendant, following his arrest at the Yonkers Brothel and 
execution of a written waiver of his Miranda rights. JIAMEZ-

so 



DOLORES then stated, in substance and in part, that the Yonkers 
Brothel is, in fact, a brothel, and that JIAMEZ-DOLORES mans the 
door of the Yonkers Brothel and collects $30 from each customer 
in return for a playing card, which the customers then gave to 
the women working in the brothel as payment for sex. Law 
enforcement agents seized from the person of JIAMEZ-DOLORES 17 
playing cards, $180 in cash, and a key ring. JIAMEZ-DOLORES was 
also in possession of an identification document which bore the 
name ~valentin Jiamez-Dolores" and the same date of birth and 
street address as that proffered by JIAMEZ-DOLORES on or about 
November 21, 2012. 

82. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about March 5, 2013, at approximately 
6:45p.m., BONIFACIO FLORES-MENDEZ, a/k/a ~Boni," a/k/a ~Mota," 
the defendant, using Intercepted Cellphone-3, made an outgoing 
call to VALENTIN JIAMEZ-DOLORES, the defendant, using a cell 
phone with a call number ending in 4158 (~cellphone-4158"). 

During the intercepted call, the following conversation, in 
substance and in part, took place: 

BONIFACIO: 

JIAMEZ-DOLORES: 
BONIFACIO: 

There is a guy that is going to be 
there. If it is a customer he says I 
will lend him . . that he will give me 
ten then tomorrow he will give the 
twenty. If you know him do it, if not 
no. 
Okay. 
He is going there now. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that BONIFACIO 
FLORES-MENDEZ was telling JIAMEZ-DOLORES that a customer was 
going to come to JIAMEZ-DOLORES and tell him that BONIFACIO 
FLORES-MENDEZ said it would be okay for him to patronize a woman 
working as a prostitute that evening and pay the next day ("a 
customer he says I will lend him . . that he will give me ten 
and then tomorrow he will give the twenty"). BONIFACIO FLORES­
MENDEZ told JIAMEZ-DOLORES that if he recognized this customer to 
allow it ("If you know him do it"), but that if JIAMEZ-DOLORES 
did not recognize the customer to not let him have sex with a 
woman without paying in full first ("if not no") 

51 



83. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-4158 is used by VALENTIN JIAMEZ-DOLORES, 
the defendant: 

a. As described in further detail above, on or 
about November 18, 2012, law enforcement officers conducted a 
traffic stop of the Red Expedition. In addition to BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant, law 
enforcement encountered an individual who claimed to be without 
identification but said his name was "Valentine Jaimes," and 
provided a date of birth and address. The same individual was 
later arrested and admitted that he was working at the Yonkers 
Brothel. At the time of his arrest, the individual was in 
possession of an identification document bearing the name 
"Valentin Jiamez-Dolores," which bore the same date of birth and 
address as "Valentine Jaimes" had provided to law enforcement. 

b. Based on my review of Western Union and Casa 
De Cambio records I know that an individual named "Valentin 
Jiamez-Dolores" has sent wire transfers to Mexico in connection 
with which he listed the cell phone number for Cellphone-4158. 

c. Based on my review of intercepted calls with 
Cellphone-4158, I know that during some intercepted calls the 
user of Cellphone-4158 is referred to as "Valentin." 

FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas" 

84. Based on my review of reports prepared other law 
enforcement agents, I know the following: 

a. On several occasions in November and December 
2012, and in April 2013, FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," the defendant, was 
seen escorting men into the Queens Brothel. Each man was seen 
leaving the Queens Brothel after spending approximately 10-15 
minutes inside. While conducting surveillance, law enforcement 
agents took video of FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," from which 
photographs were printed, some of which are attached hereto as 
Exhibit A. 

52 



b. On or about December 6, 2012, agents 
conducting surveillance of the Queens Brothel saw an individual 
later identified as FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," entering and exiting 
the Queens Brothel. That day, HSI agents encountered a man who 
had left the Queens Brothel ("Customer-1"), who said, in sum and 
substance, that FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," operated the Queens Brothel. 

c. On or about December 6, 2012, agents 
conducting surveillance followed FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," from the 
Queens Brothel to Latin Travel on Seneca Avenue, which provides a 
money remitter service. 

85. Based on my review of records provided by the 
money remitter service operated out of Latin Travel on Seneca 
Avenue, I know the following: 

a. On or about December 4, 2012, a wire transfer 
in the amount of approximately $500 was sent to "Alicia Miranda­
Flares" in Puebla, Mexico from an individual who identified 
himself as "Alberto Jesus Martinez-Miranda," living at the 
address of the Queens Brothel, with a contact phone number ending 
in 0431 ("Cellphone-0431"). 

b. On or about December 6, 2012, a wire transfer 
in the amount of approximately $200 was sent to "Luis Ramon 
Martinez-Miranda" in Puebla, Mexico from an individual who 
identified himself as "Alberto Jesus Martinez-Miranda," living at 
the address of the Queens Brothel, with Cellphone-0431 listed as 
the contact number. 

86. Based on my review of an ICE database, I know that 
on or about February 15, 1999, an individual identified as 
"Alberto Martinez-Miranda" was encountered along the United 
States-Mexico border, and stated that his mother's name is 
"Alicia." 

87. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 
following: 

a. On or about April 8, 2013, at approximately 
4:54p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 

53 



the defendant, placed a call from Intercepted Cellphone-3 to FNU 
LNU, a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," 
a/k/a "Barbitas," the defendant, who was using Cellphone-0431. 
During the call, the following conversation, in substance and in 
part, took place: 

FNU LNU: 
BONIFACIO: 

FNU LNU: 

Tell me, tell me. 
Check a guy for me with a black shirt 
and [U/I] Eight. Seneca and Grow. 
Okay, Okay. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call BONIFACIO told FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," to check on a male, 
possibly a client, who was near the Queens Brothel. 

c. On or about April 18, 2013, at approximately 
7:59p.m., BONIFACIO FLORES-MENDEZ placed a call on Intercepted 
Cellphone-3 to FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," using Cellphone-0431. During 
the call, the following conversation, in substance and in part, 
took place: 

BONIFACIO: 
FNU LNU: 
BONIFACIO: 

FNU LNU: 

You have one downstairs. 
Alright. 
Tell the girl that 3 guys are going to 
be waiting in five minutes. It's 3 
separate ones. 
Alright. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call, BONIFACIO FLORES-MENDEZ told FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," to tell the 
woman working, or being forced to work as a prostitute, that 
three separate customers were on their way and would arrive in 5 
minutes. 

88. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-0431 is being used by FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendant: (i) law enforcement agents' 
observation of FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 

54 



a/k/a "Barbas," a/k/a "Barbitas," working at the Queens Brothel, 
(ii) the intercepted calls concerning the Queens Brothel, and 
(iii) the use by FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," of Cellphone-0431 to send wire 
transfers to an individual with the same name as that of his 
mother. 

OBSTRUCTION OF JUSTICE 

89. Based on my review of records from the Virginia 
Department of Motor Vehicles and the Maryland Motor Vehicle 
Administration, I know the following: 

a. A 1999 black Honda Accord with Virginia 
license plate WXM 7063 (the "Black Honda") is registered to 
"Isaias Flores-Mendez." 

b. The Red Expedition (described above) is 
registered to "Bonifacio Flores-Mendez." 

c. A 2001 white Chevy Astra Van bearing Maryland 
license plate number 3AK2211 (the "Chevy Astra") is registered to 
"Bonifacio Flores-Mendez." 

90. On or about October 18, 2012, pursuant to a court­
authorized tracking warrant, GPS tracking devices were placed on 
the Red Expedition and on the Chevy Astra. The GPS tracking 
device placed on the Chevy Astra, however, was defective and 
never successfully transmitted GPS data. On or about October 22, 
2012, the GPS tracking device on the Red Expedition failed - that 
is, the GPS tracking device which had previously been 
transmitting GPS data, ceased to do so. Based on my experience 
working with GPS tracking devices, I know that a tracking device 
may "fail" for many reasons, including that the device itself may 
be defective, that the device may be inadvertently dislodged from 
the vehicle to which it is magnetically attached, or it may be 
intentionally removed. On or about October 23, 2012, replacement 
GPS devices were placed on the Red Expedition and the Chevy 
Astra. On or about October 25, 2012, the GPS tracking device on 
the Red Expedition failed again. On or about November 14, 2012, 
a replacement GPS tracking device was placed on the Red 
Expedition. On or about November 15, 2012, the GPS tracking 
device on the Chevy Astra failed. On or about November 19, 2012, 
the GPS tracking device on the Red Expedition failed again. 
Shortly thereafter, law enforcement agents approached the Red 

55 



Expedition and the Chevy Astro to look for the GPS tracking 
devices but were unable to locate them. 

91. Based on my review of consensually recorded 
telephone communications made by ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," the defendant, while incarcerated at Rikers Island, I 
know the following: 

a. On or about October 22, 2012, at 
approximately 9:36a.m., ISAIAS FLORES-MENDEZ placed a c~ll to 
Intercepted Cellphone-1 and spoke to an individual later j 

identified as BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a 
"Mota," the defendant. During the call, BONIFACIO FLORES-MENDEZ 
stated, in substance and in part, "listen carefully . . I found 
a tracker in the red one . . I put gas in it a while ago and it 
started spilling so I went to Miguelon's . [and] he said, ] 
'listen dude, you have something weird on the fuel tank . so 
we took it out . . it's a tracking device dude but the 
problem is that I already have the women with me . . I am going 
to drop them off far away." 

b. On or about October 25, 2012, at 
approximately 6:36p.m., ISAIAS FLORES-MENDEZ again placed a call 
to Intercepted Cellphone-1 and again spoke to BONIFACIO FLORES­
MENDEZ. During the call, BONIFACIO FLORES-MENDEZ stated in 
substance and in part, "I found another tracking device in the 
red one . . last night Choqui went to get it and Miguelon said, 
'we have to check it out every two or three days,' . so I 
called him and told him 'let's check it out . . we 
removed the spare tire and now they placed it on top of the spare 
tire. . he [Miguelon] said 'take it apart . take half of it, 
I'll dispose of half of it, and you leave . . and go throw the 
other half in the ocean.' I pulled over by Whitestone and dropped 
it there." 

c. On or about October 31, 2012, at 
approximately 7:39p.m., ISAIAS FLORES-MENDEZ placed another call 
to Intercepted Cellphone-1 and again spoke to BONIFACIO 
FLORES-MENDEZ. During the call, ISAIAS FLORES-MENDEZ asked, in 
substance and in part, if everything was fine in Yonkers and 
whether BONIFACIO FLORES-MENDEZ, had "seen anything else weird?" 
BONIFACIO FLORES-MENDEZ replied, in substance and in part, that 
everything was fine and that he had not seen anything weird. 
ISAIAS FLORES-MENDEZ then asked, in substance and in part, if 

56 



"you guys not check the black car 
FLORES-MENDEZ responded "yes, but 
That's the one I am driving now." 
further, "did you guys open up the 
BONIFACIO FLORES-MENDEZ said yes. 

or anything," and BONIFACIO 
it doesn't have anything. 

ISAIAS FLORES-MENDEZ inquired 
engine and everything," and 

92. Based on my review of telephone calls intercepted 
pursuant to the April 2013 Order, I know the following: 

a. On or about February 23, 2013, at 
approximately 10:40 a.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant,' received an incoming call on 
Intercepted Cellphone-3 from a man identified during the call as 
"Miguelon," who was using a cellular telephone assigned a call 
number ending in 0765 ("CELLPHONE-0765"), during which the 
following conversation took place, in substance and in part: 

BONIFACIO: Tell me, Miguelon. 
MIGUELON: The black one is ready. 
BONIFACIO: Okay. I will pass by in a little while. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that BONIFACIO 
FLORES-MENDEZ and "Miguelon" were discussing the Black Honda that 
BONIFACIO FLORES-MENDEZ and his co-conspirators use to transport 
women who work, and are forced to work, as prostitutes, and I 
believe that "Miguelon" is a mechanic. 

93. Based on my review of subscriber records for 
CELLPHONE-0765, I know that CELLPHONE-0765 is subscribed in the 
name "Miguel Ang Che." 

94. Based on my review of a Customs and Border Patrol 
database, I know that on or about February 2, 2013, an airline 
ticket for a child (the "Child Passenger") was booked with 
CELLPHONE-0765 listed as the contact telephone number for the 
Child Passenger) . 

95. Based on my review of United States Department of 
State records, I know that United States Passport issued for the 
Child Passenger states that the Child Passenger's father is 
"Miguel Angel Che Veliz," with an address on 53rd Avenue in 
Queens, New York, and a contact phone number that is the same as 
CELLPHONE-0765. 

57 



96. Based on my review of GPS tracking data obtained 
pursuant to a court-authorized warrant, I know that CELLPHONE-
0765 is frequently in the vicinity of the address on 53rct Avenue 
in Queens, New York, that was provided for "Miguel Angel Che 
Veliz" in the Passport for the Child Passenger. 

97. Based on my training and experience, and my 
familiarity with this investigation, and my review of the 
records, phone calls, and data described above, I believe that 
the "Miguelon" referred to by BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," in calls with ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," is the same person as MIGUEL ANGEL CHE-VELIZ, a/k/a 
"Miguelon," the defendant. I further believe that as discussed 
in the intercepted calls described above, MIGUEL ANGEL CHE-VELI.Z 
located the tracking devices that law enforcement had placed on 
the Red Expedition and the Chevy Astro and destroyed and/or 
directed that the tracking devices be destroyed. I further 
believe that MIGUEL ANGEL CHE-VELIZ then continued to check 
various cars used by BONIFACIO FLORES-MENDEZ and others for new 
tracking devices and removed any additional tracking devices that 
he found. 

POSSESSION OF CHILD PORNOGRAPHY 

98. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 22, 2013, at 
approximately 10:31 p.m., CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," spoke to Minor Victim-1 
on Intercepted Cellphone-2. During the call, the following 
conversation, in substance and in part, took place: 

DE LA ROSA: 

MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 

What are you doing? Send me a picture 
[pause] of you, naked. 

Ah? 
Send me a picture of you, naked. 
I will take a shower. 
Are you going to take a shower? 
Yes. 
Send me a picture, no? 
I will think about it. 
Please? 

58 



MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 

MINOR VICTIM-1: 

Okay then. 
Of you taking a shower, very open. 
Uh? 
When you are in the bathroom, standing, 
very open . I'll never ask you 
anything else. Only that . send it 
to me this number, uh? 
Okay then. 

99. On or about March 8, 2013, CARLOS GARCIA-DE LA 
ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a "Miguel," the 
defendant, was administratively arrested by the Department of 
Homeland Security, waived his Miranda rights, and was 
interviewed. During the interview, GARCIA-DE LA ROSA stated, in 
substance and in part: 

a. He had been talking to Minor Victim-1 for 
approximately 6-7 months. 

b. He knows Minor Victim-1 to be approximately 
14 years old. 

c. He asked Minor Victim-1 to send him naked 
photos of herself, including photos of her breasts and photos of 
Minor Victim-1 with her legs spread open. Minor Victim-1 texted 
GARCIA-DE LA ROSA the requested photos. Shortly after receiving 
the requested photos he deleted them from his phone. 

100. Law enforcement agents recovered Intercepted 
Cellphone-2 from CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a 
"Pirulo," a/k/a "Miguel," determined that it was manufactured 
outside of New York, and conducted a forensic review of 
Intercepted Cellphone-2. During the forensic review, law 
enforcement agents were able to recover previously deleted 
photos, one of which depicted a girls breasts and one of which 
depicted a girls genitalia (the "Photographs"). 

101. On or about March 11, 2013, Minor Victim-1 was 
interviewed by law enforcement. Minor Victim-1 stated, in 
substance and in part, that approximately two weeks prior, she 
had, at the request of a man with whom she had a sexual 
relationship, taken picturers of herself and texted them to him. 
Minor Victim-1 was shown the Photographs and identified one of 
the images as the picture she took of her genitalia. 

59 



102. Based on my review of GPS tracking data for 
Intercepted Cellphone-2, I know that after February 22, 2013, and 
prior to his arrest, CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," was present in the Southern 
District of New York. 

103. Based on (i) the intercepted call described abovei 
(ii) the statements of CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo" a/k/a "Miguel," and Minor Victim-1, and the 
recovered Photographs, I believe that Minor Victim-1 is a minor 
and that she texted photographs depicting her genitalia to 
GARCIA-DE LA ROSA, who possessed the images on his cellular 
telephone, Intercepted Cellphone-2, in the Southern District of 
New York. 

ILLEGAL REENTRY BY PANFILO FLORES-MENDEZ 

104. Based on my review of the file maintained by ICE 
(the "Alien File") regarding PANFILO FLORES-MENDEZ, the 
defendant, I have learned the following: 

a. PANFILO FLORES-MENDEZ is a citizen of Mexico 
and has never been a citizen of the United States. 

b. On or about November 29, 2010, PANFILO 
FLORES-MENDEZ was removed and deported from the United States to 
Mexico. On that date, a photograph of PANFILO FLORES-MENDEZ was 
taken and added to his Alien File. 

c. Following his removal and deportation to 
Mexico, PANFILO FLORES-MENDEZ never obtained the express consent 
of the Attorney General of the United States, or the Secretary 
for the Department of Homeland Security, to reapply for admission 
to the United States. 

105. Based on my review of a report prepared by another 
HSI agent, I know the following: 

a. On or about November 18, 2012, a Detective 
with the Yonkers Police Department (the "Yonkers Detective") saw 
PANFILO FLORES-MENDEZ, the defendant, walk out of the Yonkers 
Brothel and get into the Red Expedition. Shortly thereafter, the 
Yonkers Detective stopped the Red Expedition, which was occupied 
by PANFILO FLORES-MENDEZ, BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," VALENTIN JIAMEZ-DOLORES, and two women. PANFILO 

60FLORES-MENDEZ produced a Mexican identification document bearing 
the name "Panfilo Flores-Mendez" and a date of birth. 

b. The Yonkers Detective looked at the 
photograph in the Alien File for PANFILO FLORES-MENDEZ and 
confirmed that it depicted the same person as the PANFILO FLORES­
MENDEZ stopped in Yonkers, New York, on or about November 18, 
2012. 

106. Based on my review of the Alien File and the 
report documenting the car stop of by the Yonkers Detective on or 
about November 18, 2012, I know that the date of birth for 
PANFILO FLORES-MENDEZ that is in the Alien File, and the date of 
birth on the identification produced by PANFILO FLORES-MENDEZ on 
or about November 18, 2012, are the same. 

ILLEGAL REENTRY BY JUANA LUCAS-SANCHEZ 

107. Based on my review of the Alien File regarding 
JUANA LUCAS-SANCHEZ, the defendant, I have learned the following: 

a. LUCAS-SANCHEZ is a citizen of Mexico and has 
never been a citizen of the United States. 

b. On or about January 29, 2004, LUCAS-SANCHEZ 
was removed and deported from the United States to Mexico. On 
that date, LUCAS-SANCHEZ was fingerprinted and her fingerprint 
was placed on an executed warrant of removal. On that date, a 
photograph of LUCAS-SANCHEZ was taken and added to her Alien 
File. 

c. On or about June 8, 2004, LUCAS-SANCHEZ was 
removed and deported from the United States to Mexico. On that 
date, LUCAS-SANCHEZ was fingerprinted and her fingerprint was 
placed on an executed notice to alien ordered removed/departure 
verification. On that date, a photograph of LUCAS-SANCHEZ was 
taken and added to her Alien File. 

d. Following her removal and deportation to 
Mexico, LUCAS-SANCHEZ never obtained the express consent of the 
Attorney General of the United States, or the Secretary for the 
Department of Homeland Security, to reapply for admission to the 
United States. 

108. On or about May 29, 2009, JUANA LUCAS-SANCHEZ, the 

61 



defendant, was arrested by the NYPD in Bronx, New York. On or 
about August 31, 2009, LUCAS-SANCHEZ was convicted upon of a plea 
of guilty, in Bronx County Supreme Court, to Prostitution, a 
class B misdemeanor, in violation of New York Penal Code Section 
230.00, and sentenced to conditional discharge. 

109. Upon her arrest on or about May 29, 2009, JUANA 
LUCAS-SANCHEZ's fingerprints were uploaded to a law enforcement 
database. The law enforcement database matched the fingerprints 
taken from LUCAS-SANCHEZ in connection with the May 29, 2009 
arrest to the fingerprints taken by ICE in connection with LUCAS­
SANCHEZ's removal on or about January 29, 2004, and on or about 
June 8, 2004. 

WHEREFORE, deponent respectfully requests that warrants 
issue for the arrests of ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," 
BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," JUANA LUCAS­
SANCHEZ, DAVID VASQUEZ-MEDINA, CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE­
GALENO, a/k/a "Celestino Degante Galena," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," MIGUEL ANGEL CHE-VELIZ, a/k/a 
"Miguelon," ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El 
Perro," a/k/a "Cachorro," MARGARITO DEGANTE, a/k/a "Chachalaco," 
PANFILO FLORES-MENDEZ, VALENTIN JIAMEZ-DOLORES, and FNU LNU, 
a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and that they each be arrested and 
imprisoned, or bailed, as the case may be. 

APR Z 9 2013 
Sworn to before me this 
J=_:2th day of April 2013 

· ONOIUlliLE 
UNITED STATES MAGISTRATE JUDGE 
SOUTHERN DISTRICT OF NEW YORK 

/ 

i£t~ . ('. 
EL~IN HERNJ\NDEi 
SPECIAL AGENT 
DEPARTMENT OF HOMELAND SECURITY 

62 



EXHIBIT A

. I 

Before: THE HONORABLE ANDREW J. PECK 
United States Magistrate Judge 
Southern District of New York 

- - - - - - - - - - - - - - - - - - - - X 

UNITED STATES OF AMERICA 

- against -

ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," 

BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," 
a/k/a "Mota," 

JUANA LUCAS-SANCHEZ, 
DAVID VASQUEZ-MEDINA, 
CARLOS GARCIA-DE LA ROSA, 

a/k/a "Choqui," 
a/k/a "Pirulo," 
a/k/a "Miguel," 

ALEJANDRO DEGANTE-GALENO, 
a/k/a "Celestino Degante Galena," 
a/k/a "El Zorro," 

MARIA BAUTISTA-PENA, 
a/k/a "Maricruz," 

MIGUEL ANGEL CHE-VELIZ, 
a/k/a "Miguelon," 

ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," 
a/k/a "El Perro," 
a/k/a "Cachorro," 

MARGARITO DEGANTE, 
a/k/a "Chachalaco," 

PANFILO FLORES-MENDEZ, 
VALENTIN JIAMEZ-DOLORES, 
FNU LNU, 

a/k/a "Alberto Jesus 
Martinez-Miranda," 
a/k/a "Barbas," 
a/k/a "Barbitas," 

Defendants. 
- - - - - - - - - - - - - - - - - - - - X 

113 

SEALED COMPLAINT 

Violations of 
18 u.s.c. §§ 1512(c), 
1591 (a), 1591 (b) (1), 
1952, 2423 (d) , 
8 U.S.C. § 1326(a) 

COUNTY OF OFFENSE: 
BRONX 



COUNTY OF NEW YORK 
STATE OF NEW YORK ss.: 
SOUTHERN DISTRICT OF NEW YORK 

ELVIN HERNANDEZ, being duly sworn, deposes and says 
that he is a Special Agent with the Department of Homeland 
Security, Immigration and Customs Enforcement, Homeland Security 
Investigations ("HSI") charges as follows: 

COUNT ONE 
{Sex Trafficking) 

1. From at least in or about September 2006, up to 
and including in or about 2007, in the Southern District of New 
York and elsewhere, ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," and JUANA LUCAS­
SANCHEZ, the defendants, in and affecting interstate and foreign 
commerce, willfully and knowingly did recruit, entice, harbor, 
transport, provide, and obtain, by any means a person, and did 
benefit, financially and by receiving anything of value, from 
participation in a venture which has engaged in such acts, 
knowing that force, fraud, and coercion would be used to cause 
the person to engage in a commercial sex act, in violation of 
Title 18, United States Code, Section 1591(a) and (b) (1), to wit, 
ISAIAS FLORES-MENDEZ arranged for a woman ("Victim-1") to be 
smuggled to the United States from Mexico for the purpose of 
prostitution, and then ISAIAS FLORES-MENDEZ, BONIFACIO FLORES­
MENDEZ, and LUCAS-SANCHEZ, used force, threats of force, and 
other means of coercion to compel Victim-1 to engage in 
prostitution against her will for their own financial gain. 

(Title 18, United States Code, 
Sections 1591 (a) & (b) (1), and 2.) 

COUNT TWO 
{Sex Trafficking) 

2. From at least in or about 2006, up to and 
including in or about 2008, in the Southern District of New York 
and elsewhere, DAVID VASQUEZ-MEDINA, the defendant, in and 
affecting interstate and foreign commerce, willfully and 
knowingly did recruit, entice, harbor, transport, provide, and 
obtain, by any means a person, and did benefit, financially and 

2 



by receiving anything of value, from participation in a venture 
which has engaged in such acts, knowing that force, fraud, and 
coercion would be used to cause the person to engage in a 
commercial sex act, in violation of Title 18, United States Code, 
Section 1591(a) and (b) (1), to wit, VASQUEZ-MEDINA used force, 
threats of force, and other means of coercion to compel a woman 
("Victim-2") to engage in prostitution in several states against 
her will for his own financial gain. 

(Title 18, United States Code, 
Sections 1591 (a) & (b) (1), and 2.) 

COUNT THREE 
(Interstate Travel for Prostitution) 

3. In or about April 2013, in the Southern District 
of New York and elsewhere, BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant, willfully and knowingly, for the 
purpose of commercial advantage and private financial gain, 
arranged, induced, procured, and facilitated the travel of a 
person knowing that such a person was traveling in interstate 
commerce for the purpose of engaging in illicit sexual conduct, 
to wit, BONIFACIO FLORES-MENDEZ induced the travel of a person 
("Witness-1") to New York from out-of-state for the purpose of 
engaging in prostitution. 

(Title 18, United States Code, 
Sections 2423(d) and 2.) 

COUNT FOUR 
(Prostitution-Sex Trafficking Enterprise) 

4. From in or about October 2012, up to and including 
on or about the date of the filing of this Complaint, in the 
Southern District of New York and elsewhere, ISAIAS 
FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, together with others known and 

3 



unknown, willfully and knowingly did combine, conspire, 
confederate, and agree together and with each other to commit 
offenses against the United States of America, to wit, use of 
facilities in interstate commerce for the promotion, management, 
and facilitation of a prostitution enterprise, in violation of 
Title 18, United States Code, Section 1952. 

5. It was a part and an object of the conspiracy that 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and others known and unknown, 
knowingly would and did travel in interstate and foreign commerce 
and use the mail and a facility in interstate and foreign 
commerce, with intent to promote, manage, establish, carry on, 
and facilitate the promotion, management, establishment, and 
carrying on, of one or more unlawful activities, namely promoting 
prostitution and sex trafficking, in violation of New York Penal 
Law §§ 230.20 and 230.34, and thereafter would and did perform 
and attempt to perform an act to promote, manage, establish, 
carry on and facilitate the promotion, management, establishment, 
and carrying on of the unlawful activity. 

6. In furtherance of the conspiracy and to effect the 
illegal object thereof, ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," 
BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," CARLOS 
GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a 
"Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante-Galeno," a/k/a "El Zorro," MARIA BAUTISTA-PENA, a/k/a 
"Maricruz," ISIDRO DEGANTE GALENO, a/k/a "Marcos," a/k/a "El 
Perro," a/k/a "Cachorro," MARGARITO DEGANTE, a/k/a "Chachalaco," 
VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," the 
defendants, together with others known and unknown, committed the 
following overt acts, among others, in the Southern District of 
New York and elsewhere: 

a. On or about October 30, 2012, ISAIAS 

4 



FLORES-MENDEZ had a telephone conversation with BONIFACIO FLORES­
MENDEZ, during which they discussed which women were working in 
the Yonkers Brothel and the Poughkeepsie Brothel. 

b. On or about April 15, 2013, BONIFACIO 
FLORES-MENDEZ, had a telephone conversation with a woman working, 
or being forced to work, as a prostitute, in which BONIFACIO 
FLORES-MENDEZ and the woman discussed when she would arrive in 
Manhattan to meet BONIFACIO FLORES-MENDEZ to be taken to work at 
a brothel. 

c. On or about March 5, 2013, GARCIA-DE LA ROSA 
had a telephone conversation with BONIFACIO FLORES-MENDEZ about 
the fact that a customer interested in engaging in commercial sex 
with a woman working, or being forced to work, as a prostitute 
was waiting outside of a brothel. 

d. On or about April 15, 2013, ALEJANDRO 
DEGANTE-GALENO and ISIDRO DEGANTE-GALENO had a telephone 
conversation about the delivery to a customer's residence of a 
woman working, or being forced to work, as a prostitute. 

e. On or about April 21, 2013, BAUTISTA-PENA and 
ALEJANDRO DEGANTE-GALENO had a telephone conversation about the 
fact that a customer interested in engaging in commercial sex 
with a woman working, or being forced to work, as a prostitute 
was waiting at the door of his residence for the woman. 

f. On or about February 26, 2013, MARGARITO 
DEGANTE had a telephone conversation with ALEJANDRO DEGANTE­
GALENO about the fact that MARGARITO DEGANTE was on the corner 
distributing "chica cards" to solicit customers for women 
working, or being forced to work, as prostitutes. 

g. On or about March 5, 2013, JIAMEZ-DOLORES had 
a telephone conversation with BONIFACIO FLORES-MENDEZ in which 
JIAMEZ-DOLORES agreed to allow a customer to engage in commercial 
sex with one of the women working, or being forced to work, in a 
brothel in exchange for a $10 payment with the promise to pay the 
remaining $20 the next day, as long as JIAMEZ-DOLORES recognized 
the customer. 

h. On or about April 18, 2013, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," and BONIFACIO FLORES-MENDEZ had a telephone 

5 



conversation, in which FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," agreed to tell a 
woman working, or being forced to work, as a prostitute that 
there was one customer waiting to come in, and that three more 
were on their way. 

(Title 18, United States Code, Section 371.) 

COUNT FIVE 
(Possession of Child Pornography) 

7. From in or about February 2013, up to and 
including in or about March 2013, in the Southern District of New 
York, CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," 
a/k/a "Miguel," the defendant, knowingly did possess, and access 
with intent to view, a book, magazine, periodical, film, 
videotape, computer disk, and other material that contained an 
image of child pornography that had been mailed, and shipped and 
transported using a means and facility of interstate and foreign 
commerce and in and affecting interstate and foreign commerce by 
any means, including by computer, and that was produced using 
materials that had been mailed, and shipped and transported in 
and affecting interstate and foreign commerce by any means, 
including by computer, to wit, GARCIA-DE LA ROSA possessed on his 
cell phone photographs containing child pornography. 

(Title 18, United States Code, Section 2252A(a) (5) (B).) 

COUNT SIX 
(Obstruction of Justice) 

8. In or about October 2012, in the Southern District 
of New York and elsewhere, ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," and MIGUEL 
ANGEL CHE-VELIZ, a/k/a "Miguelon," the defendants, willfully and 
knowingly corruptly altered, destroyed, mutilated, and concealed 
a record, document, and other object, and attempted to do so, 
with the intent to impair the object's integrity and availability 
for use in an official proceeding, and otherwise obstructed, 
influenced, and impeded an official proceeding, and attempted to 
do so, to wit, working under the direction of ISAIAS FLORES­
MENDEZ, BONIFACIO FLORES-MENDEZ and CHE-VELIZ searched for, 
removed, and destroyed GPS tracking devices from vehicles used to 
commit the crimes charged in Counts Three and Four in order to 

6 



prevent the location tracking of several of the defendants and to 
make the evidence unavailable for use by law enforcement 
authorities in connection with a federal grand jury 
investigation. 

(Title 18, United States Code, Sections 1512(c) and 2.) 

COUNT SEVEN 
(Illegal Reentry} 

9. On or about November 18, 2012, in the Southern 
District of New York and elsewhere, PANFILO FLORES-MENDEZ, the 
defendant, being an alien, after having been denied admission, 
excluded, deported, and removed from the United States on or 
about November 29, 2010, unlawfully did enter and was found in 
the United States, without having obtained the express consent of 
the Attorney General of the United States or his successor, the 
Secretary for the Department of Homeland Security, to reapply for 
admission. 

(Title 8, United States Code, Section 1326(a) .) 

COUNT EIGHT 
(Illegal Reentry} 

10. On or about May 29, 2009, in the Southern District 
of New York and elsewhere, JUANA LUCAS-SANCHEZ, the defendant, 
being an alien, after having been denied admission, excluded, 
deported, and removed from the United States on or about June 8, 
2004, and on or about January 29, 2004, unlawfully did enter and 
was found in the United States, without having obtained the 
express consent of the Attorney General of the United States or 
his successor, the Secretary for the Department of Homeland 
Security, to reapply for admission. 

(Title 8, United States Code, Section 1326(a) .) 

The bases for my knowledge of the foregoing charges 
are, in part, as follows: 

11. I have been employed as a Special Agent with HSI 
(and its predecessor, the Bureau of Immigration and Customs 
Enforcement ("ICE")) for approximately three years. During my 
tenure as a Special Agent with HSI, I have conducted and 
participated in numerous investigations of criminal activity, 

7 



including but not limited to, sex trafficking, alien harboring, 
violations of the Mann Act, transportation in aid of racketeering 
activity, money laundering, and illegal reentry, in violation of 
Title 18, United States Code, Sections 1591, 2421, 2422, 2423, 
1952 and 1956, and Title 8, United States Code, Sections 1324 and 
1326. Through my training, education and experience, I have 
become familiar with the manner in which sex traffickers coerce 
women to engage in prostitution, the means and methods by which 
such prostitution occurs, the methods of exchange and transfer of 
the proceeds of such prostitution, and the coded language used by 
sex traffickers and others engaged in the prostitution business. 

12. The information contained in this affidavit is 
based upon my personal knowledge and my review of documents and 
records gathered during the course of this investigation, as well 
as information obtained, directly or indirectly, from other 
sources and agents, including information provided to me by 
witnesses who participated in conversations with the defendants. 
Because this affidavit is being submitted for the limited purpose 
of establishing probable cause, it does not include all of the 
facts that I have learned during the course of the 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. 

THE TENANCINGO-NEW YORK SEX TRAFFICKING NETWORK 

13. Many sex traffickers live in and around 
Tenancingo, Mexico and traffic women from rural areas in and 
around Tenancingo, Mexico to New York, among other places. The 
traffickers often lure women to the United States one at a time 
by engaging them in romantic relationships and promising a better 
life in New York. After the women are smuggled from Mexico to 
New York by their traffickers, they are forced by the traffickers 
to begin working as prostitutes against their will under 
abhorrent conditions. 

14. The victims are often beaten, threatened with 
physical harm to themselves and their family members, sexually 
assaulted, and verbally abused. In a typical day, a Mexican sex 
trafficking victim in New York will have sexual intercourse with 
20 to 30 customers. 

15. In some cases, the victims work in residential 
brothels - apartments or houses used as brothels for two to four 

8 



women, where a co-conspirator of the traffickers provides 
security. In such brothels, there is typically a public living 
room space, and a bedroom or bedrooms which are used for the 
actual commercial sex. Doormen or "steerers" typically collect 
the money from customers either at the entrance to the brothel or 
in the living room, after which the customers are directed to a 
bedroom to have sex with a woman working, or being forced to 
work, as a prostitute. In some cases, the steerers provide the 
customers with tickets or playing cards, which the customers the 
provide to the women as proof of payment. Steerers also provide 
security for the brothel, prevent victims from fleeing, and work 
outside the brothel directing customers to the brothel. Brothels 
often attract customers by distributing "chica cards" ("chica" 
means "girl" in Spanish) - business cards containing the phone 
number of a contact for the brothel. 

16. In other cases, the victims are forced to perform 
commercial sex at the customers' homes, which is referred to as a 
"delivery service." Drivers also attract customers by 
distributing chica cards. As a matter of course, in a delivery 
service the driver sets the appointments with customers or has a 
co-conspirator work as a dispatcher, receiving calls and 
directing the drivers to the customers' addresses. 

17. In order to provide customers with variety, 
traffickers typically move their victims from brothel to brothel, 
often on a weekly basis. Traffickers do not limit themselves to 
brothels within a small geographical range. It is not unusual 
for victims of New York-based traffickers to work in brothels as 
far away as Delaware or Massachusetts. 

18. Traffickers typically provide the victims with 
cell phones to contact brothels and drivers so that the 
traffickers themselves cannot be recorded committing the crime. 
Traffickers then monitor the victims' cell phone usage to ensure 
that the victims are not contacting family members or friends, 
because isolation is one tactic used by traffickers to maintain 
control over their victims. Nevertheless, and as described in 
further detail below, traffickers also use cell phones to 
communicate with brothels and with each other. 

19. Generally, each customer pays $30-$35 for 15 
minutes of sex. Of that $30-$35, $15 typically goes to the 
driver (in the case of a delivery service) or to the brothel. 
The other $15 goes to the victim, who is then typically forced to 

9 



give all of the proceeds to the trafficker. 

20. The trafficker then frequently sends, or has his 
victims send, some of those proceeds to family members and 
associates in Mexico by wire transfer. Such transfers provide 
financial assistance to the sex traffickers' families and provide 
financial support to the sex traffickers themselves if and when 
they return to Mexico. Such financial transfers are also a 
method of storing and hiding the significant profits of sex 
trafficking from law enforcement. In order to effect the wire 
transfer, the wire remitter businesses typically require the 
sender to provide his name, address, and phone number, and in 
some cases, they require official photo identification. The 
recipient of the wire transfer is required to provide a name, 
address, and phone number in order to pick up the wired funds. 
In my experience, traffickers and their relatives and associates 
typically provide their true names, addresses, and phone numbers 
to the wire remitter companies because they want to ensure that 
the wire transfer is completed or, if not, that they can be 
contacted to resolve any issues. 

21. In some instances, traffickers choose one of their 
respective victims to assist in the trafficking of other women. 
For example, some victims recruit, supervise, and direct new 
victims, and report to their respective traffickers on the 
activities and compliance of the new victims. These victims­
turned-accomplices effectively work as enforcers for their 
traffickers either because they are coerced to engage in such 
conduct or because doing so will better their position with their 
traffickers and thereby decrease the abuse they suffer. 

22. Traffickers typically provide their victims with 
condoms and birth control pills. If a victim is suspected of 
being pregnant, her trafficker will typically make the victim 
take the drug misoprostol, marketed as Cytotec. Cytotec is FDA­
approved to prevent gastric ulcers, but it also causes uterine 
contractions and induces miscarriage. Traffickers give victims 
Cytotec to induce miscarriage so that the victims can continue 
working as prostitutes. 

23. After periods of victimization- typically months 
or years - many victims manage to escape. Without legal status 
in the United States, without family or friends for support, 
without employment opportunities, and as a result of the trauma 
they have suffered, victims sometimes return to prostitution. In 

10 



those cases, the victims become effectively self-employed, 
keeping the $15 per customer they previously had to turn over to 
their traffickers. 

THE DEFENDANTS 

24. ISAIAS FLORES-MENDEZ: At various times relevant 
to this Complaint, ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
worked as a sex trafficker, using violence, threats of violence, 
and other means of coercion to force at least one woman - Victim-
1 - to engage in prostitution against her will. ISAIAS FLORES­
MENDEZ also operated at least four brothels located in the 
Southern and Eastern Districts of New York, at which women 
worked, and were forced to work, as prostitutes (the "Brothels") 
ISAIAS FLORES-MENDEZ sent by wire transfer some of the proceeds 
of these crimes to his family in Mexico. On or about October 19, 
2012, ISAIAS FLORES-MENDEZ was arrested by the New York City 
Police Department ("NYPD") under the name "Jesus Diaz," and 
charged with Possession of a Forged Instrument and ordered 
detained. A Mexican Consular ID seized from ISAIAS FLORES-MENDEZ 
at the time of his arrest bore the name "Jesus Diaz." On or 
about January 2, 2013, ISAIAS FLORES-MENDEZ was charged by 
complaint in this District with illegal reentry, in violation of 
Title 8, United States Code, Section 1326(a). (12 Mag 3262). On 
or about January 14, 2013, ISAIAS FLORES-MENDEZ was indicted on 
the same charge. (13 Cr. 31 (KBF)). ISAIAS FLORES-MENDEZ has 
been detained since in or about October 2012, and has been in the 
custody of the United States Marshals Service ("USMS") since in 
or about January 2013. 

25. BONIFACIO FLORES-MENDEZ: At various times 
relevant to this Complaint, BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendant, a brother of ISAIAS FLORES­
MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," the defendant, worked as a sex trafficker, using 
threats of violence and other means of coercion to force at least 
one woman - Victim-1 - to engage in prostitution against her 
will. BONIFACIO FLORES-MENDEZ also operated the Brothels -
scheduling women to work in the Brothels, transporting them to 
and from work, hiring drivers, doormen, and steerers for the 
Brothels, and taking calls from customers. 

26. JUANA LUCAS-SANCHEZ: At various times relevant to 
this Complaint, JUANA LUCAS-SANCHEZ, the defendant, has worked as 

11 



a sex trafficker, aiding ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," the 
defendant, and BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a 
"Mota," in their use force, threats of force, and other means of 
coercion to compel Victim-1 to engage in prostitution against her 
will. At other times, LUCAS-SANCHEZ has herself worked, or been 
forced to work, as a prostitute. LUCAS-SANCHEZ was deported 
twice in or about 2004, and subsequently reentered the United 
States without authorization. 

27. DAVID VASQUEZ-MEDINA: At various times relevant 
to this Complaint, DAVID VASQUEZ-MEDINA, the defendant, worked as 
a sex trafficker, using violence, threats of violence, and other 
means of coercion to force at least one woman - Victim-2 - to 
engage in prostitution against her will. On or about October 17, 
2012, VASQUEZ-MEDINA was arrested for Possession of a Forged 
Instrument and ordered detained. On or about January 7, 2013, 
VASQUEZ-MEDINA was charged with Illegal Reentry, in violation of 
Title 8, United States Code, Section 1326(a), and was 
subsequently indicted on the same charge (13 Cr. 128 (SAS)). 
VASQUEZ-MEDINA has been detained since in or about October 2012, 
and has been in the custody of the USMS since in or about January 
2013. 

28. CARLOS GARCIA-DE LA ROSA: At various times 
relevant to this Complaint, CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," the defendant, worked 
as a driver for ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and BONIFACIO 
FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the defendants, 
transporting women working, or being forced to work, as 
prostitutes to and from the Brothels, or to outside customers, 
and also transporting customers to and from the Brothels for the 
purpose of engaging in commercial sex. GARCIA-DE LA ROSA also 
enticed a minor girl with whom he was engaged in a sexual 
relationship ("Minor Victim-1") to take pornographic photographs 
of herself and send them to GARCIA-DE LA ROSA, which he then 
possessed in the Southern District of New York. 

29. ALEJANDRO DEGANTE-GALENO: At various times 
relevant to this Complaint, ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zarro," the defendant, 
worked as a driver, delivering to customers women working, or 
being forced to work, as prostitutes, for the purpose of engaging 
in commercial sex. 

12 



30. MARIA BAUTISTA-PENA: At various times relevant to 
this Complaint, MARIA BAUTISTA-PENA, a/k/a "Maricruz," the 
defendant, worked as a dispatcher, taking phone calls from people 
interested in having a woman delivered to them for the purpose of 
commercial sex, and then 'relaying the request and address to 
ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a 
"El Zorro," the defendant, who then delivered to the customers 
women working, or being forced to work, as prostitutes, for the 
purpose of engaging in commercial sex. 

31. MIGUEL ANGEL CHE-VELIZ: At various times relevant 
to this Complaint;, MIGUEL ANGEL CHE-VELIZ, a/k/a "Miguelon," the 
defendant, worked as a mechanic for ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chela," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants. In that capacity, CHE-VELIZ swept vehicles for 
tracking devices that had been placed by federal law enforcement 
agents in connection with a federal grand jury investigation, and 
aided in the destruction of some of those tracking devices. 

32. ISIDRO DEGANTE-GALENO: At various times relevant 
to this Complaint, ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a 
"El Perro," a/k/a "Cachorro," the defendant, a brother of 
ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a 
"El Zorro," the defendant, worked as a driver, delivering to 
customers women working, or being forced to work, as prostitutes 
for the purpose of engaging in commercial sex. 

33. MARGARITO DEGANTE: At various times relevant to 
this Complaint, MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, a nephew of ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante Galena," a/k/a "El Zorro," and ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," the 
defendants, worked as a driver, delivering to customers and/or 
brothels women working, or being forced to work, as prostitutes 
for the purpose of engaging in commercial sex. 

34. PANFILO FLORES-MENDEZ: At various times relevant 
to this Complaint, PANFILO FLORES-MENDEZ, the defendant, a 
brother of ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and BONIFACIO FLORES­
MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants, had illegally 
reentered the United States of America without authorization 
following his 2010 deportation. 

13 



35. VALENTIN JIAMEZ-DOLORES: At various times 
relevant to this Complaint, VALENTIN JIAMEZ-DOLORES, the 
defendant, worked as a doorman or steerer at a brothel run by 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendants, in Yonkers, New York. In 
that capacity, JIAMEZ-DOLORES manned the door at the brothel, 
collected payment from customers, and directed customers to 
bedrooms where the customers had commercial sex with women 
working, or being forced to work as prostitutes. 

36. FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas": At various times relevant to 
this Complaint, FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," the defendant, worked as a 
doorman or steerer at a brothel run by ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants, in Queens, New York. In that capacity, FNU LNU, 
a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," manned the door at the brothel, collected payment 
from customers, and directed customers to bedrooms where the 
customers had commercial sex with the women working, or being 
forced to work as prostitutes. 

THE BROTHELS 

37. ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
previously operated and utilized, and BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant, presently operates and 
utilizes numerous residential brothels - apartments and houses 
where women work, and are forced to work, as prostitutes -
throughout New York, including identified locations on Rose 
Street in Poughkeepsie, New York (the "Poughkeepsie Brothel"), on 
Seneca Avenue in Queens, New York (the "Queens Brothel"), on Elm 
Street in Yonkers, New York (the "Yonkers Brothel"), and on 1st 
Street in Newburgh, New York (the "Newburgh Brothel"). 

14 



The Poughkeepsie Brothel 

38. On or about January 24, 2013, a cooperating 
witness ( "CW-1") 1 made an audio and video recording of the inside 
of the Poughkeepsie Brothel. In the recording, CW-1 enters the 
Poughkeepsie Brothel and sees a woman wearing lingerie seated on 
a couch. CW-1 asks a Hispanic male working in the Poughkeepsie 
Brothel if there are women of any other nationality available and 
is told that there are not, at which time CW-1 leaves. 

39. During the course of this investigation, both 
ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chela," and BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendants, have been observed entering 
and leaving the Poughkeepsie Brothel, and BONIFACIO FLORES-MENDEZ 
has been observed delivering a woman to the Poughkeepsie Brothel. 

40. In connection with this investigation, in February 
2013 and April 2013, HSI obtained the following court orders 
authorizing interception of communications over cell phones used 
by various of the defendants charged herein: 

a. On or about February 21, 2013, the Honorable 
Kimba M. Wood, United States District Judge, Southern District of 
New York, signed an order (the "February 2013 Order") authorizing 
the interception of wire communications occurring over the 
following cellular telephones: (1) the cellular telephone 
assigned call number (917) 686-4929, subscribed to by "Josee D. 
Lopezzz," and used primarily by BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendant ("Intercepted Cellphone-1"); 
(2) the cellular telephone assigned call number (845) 764-7252, 
subscribed to by "Isabel Rodriguez" ("Intercepted Cellphone-2"); 
(3) the cellular telephone assigned call number (914) 619-7051, 
with no subscriber name provided, used primarily by BONIFACIO 

1 CW-1 pleaded guilty, pursuant to a cooperation agreement 
in this District, to charges including illegal reentry, social 
security fraud, narcotics distribution conspiracy, narcotics 
importation conspiracy, possessing a firearm in connection with a 
narcotic trafficking offense, and hostage-taking. CW-1 hopes to 
receive a reduced sentence as a result of his cooperation. To 
date, law enforcement agents dealing with CW-1 have found CW-1 to 
be credible and the information provided by CW-1 to be 
corroborated. 

15 



FLORES-MENDEZ ("Intercepted Cellphone-3"); (4) the cellular 
telephone assigned call number (718) 216-2596, subscribed to by 
"Marcos Degante" and used primarily by ISIDRO DEGANTE-GALENO, 
a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," the defendant 
("Intercepted Cellphone-4"); and (5) the cellular telephone 
assigned call number (347) 284-2648, subscribed to by "Alejandro 
Mendoza" and used primarily by ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zarro," the defendant 
("Intercepted Cellphone- 5") (collectively, the "Intercepted 
Cellphones"). 

b. On or about April 2, 2013, the Honorable 
Kimba M. Wood, United States District Judge, Southern District of 
New York, signed an order (the "April 2013 Order") authorizing 
the continued interception of wire communications occurring over 
Intercepted Cellphone-1, Intercepted Cellphone-3, and Intercepted 
Cellphone-5. 

41. In calls intercepted on Intercepted Cellphone-1 
and Intercepted Cellphone-3 pursuant to the February 2013 Order 
and the April 2013 Order, BONIFACIO FLORES-MENDEZ, a/k/a "Bani," 
a/k/a "Mota," the defendant, engaged in conversations in which he 
discussed arranging for women to work in the Poughkeepsie Brothel 
and in which he discussed the Poughkeepsie Brothel with customers 
or potential customers. For example, on or about April 22, 2013, 
at approximately 12:54 p.m., BONIFACIO FLORES-MENDEZ spoke to a 
woman identified during the call as "Karen," ("Karen") who asked 
if BONIFACIO had "a girl for Monday . . to the house in 
Newburgh." BONIFACIO responded that he did not have work in 
Newburgh, but that he had "the one for Poughkeepsie." Karen 
responded that she would take the week if BONIFACIO could give it 
to her. 

42. Based on my training and experience and my 
familiarity with this investigation, including the video obtained 
by CW-1, the surveillance of ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chela," and 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the 
defendants, and the intercepted telephone calls in which 
BONIFACIO FLORES-MENDEZ arranges for women to work in 
Poughkeepsie and/or provides information to men about the brothel 
in Poughkeepsie, I believe that the Poughkeepsie Brothel is, in 
fact, a brothel, and that BONIFACIO FLORES-MENDEZ runs the 
Poughkeepsie Brothel. 

16 



The Queens Brothel 

43. On or about December 6, 2012, law enforcement 
agents interviewed a customer of the Queens Brothel ("Customer-
1"). During the interview, Customer-1 stated, in substance and 
in part, that the Queens Brothel was a brothel, and that 
Customer-1 had frequented the Queens Brothel on three occasions, 
most recently that day. Customer-1 said that at the brothel, an 
apparent employee collected $30 from Customer-1, and directed him 
to a bedroom where he had sexual intercourse with a woman. 

44. During the course of this investigation, 
BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the 
defendant, has been observed delivering women to the Queens 
Brothel. 

45. In addition, in calls intercepted on Intercepted 
Cellphone-3 pursuant to the February 2013 Order and the April 
2013 Order, BONIFACIO FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," 
the defendant, engaged in conversations in which he discussed 
customers of the Queens Brothel. For example, on or about April 
22, 2013, at approximately 1:22 p.m., BONIFACIO FLORES-MENDEZ had 
a conversation with an individual not charged herein in which 
BONIFACIO FLORES-MENDEZ said that he had spoken to a customer who 
asked if BONIFACIO FLORES-MENDEZ was open, and that BONIFACIO 
FLORES-MENDEZ had originally said he was closed, but because the 
customer said he had been to [the brothel] before and knew where 
it was located on Seneca Avenue, BONIFACIO FLORES-MENDEZ told the 
customer to come. 

46. Based on my training and experience, and my 
familiarity with this investigation, including the statements 
made by Customer-1, the surveillance of BONIFACIO FLORES-MENDEZ, 
a/k/a "Bani," a/k/a "Mota," the defendant, and my review of 
summaries of the intercepted calls described above, I believe 
that the Queens Brothel is, in fact, a brothel, and that it is 
run by BONIFACIO FLORES-MENDEZ. 

The Yonkers Brothel 

47. On or about December 20, 2012, law enforcement 
agents interviewed a customer of the Yonkers Brothel ("Customer-
2") and arrested VALENTIN JIAMEZ-DOLORES, the defendant, who 
waived his Miranda rights and provided a statement. Both 
Customer-2 and JIAMEZ-DOLORES stated, in substance and in part, 

17 



that the Yonkers Brothel was a brothel. JIAMEZ-DOLORES further 
explained that he manned the door of the Yonkers Brothel, and 
collected $30 from each customer in return for a playing card, 
which the customers then gave to the women working in the brothel 
as payment for sex. 

48. During the course of this investigation, BONIFACIO 
FLORES-MENDEZ, a/k/a "Bani," a/k/a "Mota," the defendant, has 
been surveilled driving women to and from the Yonkers Brothel. 

49. In addition, in calls intercepted on Intercepted 
Cellphone-1 and Intercepted Cellphone-3 pursuant to the February 
2013 Order and the April 2013 Order, BONIFACIO FLORES-MENDEZ, 
a/k/a "Bani," a/k/a "Mota," the defendant, engaged in 
conversations in which he discussed the Yonkers Brothel with 
customers or potential customers. For example, on or about April 
22, 2013, at approximately 9:59a.m., BONIFACIO FLORES-MENDEZ 
received a call on Intercepted Cellphone-3 from an unidentified 
male who asked, "what do you have in Yonkers," and BONIFACIO 
FLORES-MENDEZ responded, in substance and in part, that he had 
two Mexicans who were both good. 

50. Based on my training and experience, and my 
familiarity with this investigation, including the information 
provided by "Customer-2" and VALENTIN JIAMEZ-DOLORES, the 
defendant, the surveillance of BONIFACIO FLORES-MENDEZ, a/k/a 
"Bani," a/k/a "Mota," the defendant, and my review of summaries 
of the intercepted telephone calls described above in which 
BONIFACIO FLORES-MENDEZ arranges for women to work in Yonkers 
and/or provides information to men who are coming to Yonkers, I 
believe that the Yonkers Brothel is, in fact, a brothel, that 
BONIFACIO FLORES-MENDEZ runs the Yonkers Brothel, and that 
JIAMEZ-DOLORES works at the Yonkers Brothel. 

The Newburgh Brothel 

51. On or about January 10, 2013, law enforcement 
agents interviewed a customer of the Newburgh Brothel ("Customer-
3"). During the interview, the customer stated, in substance and 
in part, that the Newburgh Brothel was a brothel, and that he had 
frequented the Newburgh Brothel approximately one to two times 
per month for the last four years. On or about January 17, 2013, 
Customer-3 made a consensual audio and video recording of the 
inside of the Newburgh Brothel. During the recording, Customer-3 
enters the Newburgh Brothel and sees a Hispanic female emerge 

18 



from a back bedroom wearing lingerie and high heels. Customer-3 
then tells the two men working in the Newburgh Brothel that he is 
not interested in the woman. Customer-3 then leaves the Newburgh 
Brothel. 

52. Based on my review of GPS tracking data for 
Intercepted Cellphone-1 and Intercepted Cellphone-3 (both of 
which are known to be used by BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," the defendant, as set forth below), I know 
that in April 2013, Intercepted Cellphone-1 and Intercepted 
Cellphone-3 were frequently in the vicinity of the Newburgh 
Brothel on, among other days, Saturdays and Mondays. Based on my 
training and experience, and my familiarity with this 
investigation, I believe that women working, or being forced to 
work, at the Newburgh Brothel are dropped off for a week of work 
on Monday and are picked up on Saturday. I further believe, 
based on the GPS tracking data described above, that BONIFACIO 
FLORES-MENDEZ is the person driving the women to and from the 
Newburgh Brothel from his residence in Queens, New York, during 
which trips BONIFACIO FLORES-MENDEZ drives through Bronx, New 
York. 

53. In addition, in calls intercepted on Intercepted 
Cellphone-1 and Intercepted Cellphone-3 pursuant to the February 
2013 Order and the April 2013 Order, BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant, engaged in 
conversations in which he discussed arranging for women to work 
in the Newburgh Brothel. For example, on or about April 14, 
2013, at approximately 10:54 a.m., BONIFACIO FLORES-MENDEZ spoke 
to Karen who said that she was "calling about the week starting 
tomorrow" and asked where she had to go. BONIFACIO FLORES-MENDEZ 
responded that she had to go to "Newburgh." 

54. Based on my training and experience, and my 
familiarity with this investigation, including the recording 
obtained by Customer-3, the GPS tracking data, and my review of 
summaries of calls intercepted pursuant to the February 2013 
Order and the April 2013 Order, I believe that the Newburgh 
Brothel is, in fact, a brothel, and that it is run by BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant. 

19 



SEX TRAFFICKING OF VICTIM-1 

55. In 2012 and 2013 I interviewed Victim-1, 2 who, as 
set forth below, gave an account of her experience being forced 
to engage in prostitution as a result of force, threats of force, 
and coercion by an individual known to her as "Isaias Flores­
Mendez." Victim-1 was shown a known photograph of ISAIAS FLORES­
MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," 
a/k/a "Chelo," the defendant, and identified the person depicted 
in that photograph as the "Isaias Flores-Mendez" who caused 
Victim-1 to engage in prostitution against her will. Victim-1 
also identified a known photograph of BONIFACIO FLORES-MENDEZ, 
a/k/a "Boni," a/k/a "Mota," the defendant. 

56. Based on my interviews of Victim-1, I know the 
following: 

a. ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," and BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants, are 
brothers. 

b. ISAIAS FLORES-MENDEZ and BONIFACIO FLORES­
MENDEZ arranged for Victim-1 to be smuggled across the border 
from Mexico into the United States, and then for Victim-1 and her 
young child to take a flight from California to Queens, New York. 
After Victim-1 arrived in New York, BONIFACIO FLORES-MENDEZ took 
her to a house on 112th Street in Queens, New York (the "Degante 
Residence"), where she was made to sleep on the floor under the 
kitchen table with her young child. In exchange for these 
accommodations, the matriarch of the Degante Residence, who 
Victim-1 knew as ISAIAS FLORES-MENDEZ's former mother-in-law, 
told Victim-1 that Victim-1 would be required to pay $200 per 
month in rent, and $50 per week for food. 

c. BONIFACIO FLORES-MENDEZ was in New York with 
Victim-1 at the time, awaiting the arrival from Mexico of ISAIAS 
FLORES-MENDEZ. BONIFACIO FLORES-MENDEZ attempted to recruit 
Victim-1 to work as a prostitute, and provided Victim-1 with a 
notebook containing contact information for brothels and drivers. 

Victim-1 has provided reliable information that has been 
independently corroborated. Victim-1 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

20BONIFACIO FLORES-MENDEZ took Victim-1 to a brothel in Yonkers, 
New York. 

d. Once ISAIAS FLORES-MENDEZ arrived in New 
York, he and BONIFACIO FLORES-MENDEZ worked together to use 
threats, verbal abuse, and violence to force Victim-1 to engage 
in commercial sex against her will in the New York City area and 
in Yonkers. On one occasion, when Victim-1 refused to work as a 
prostitute, ISAIAS FLORES-MENDEZ pushed Victim-1 and her young 
child outside into the cold winter night, locked the door, and 
refused to let her back in. Later that night, when BONIFACIO 
FLORES-MENDEZ returned home and let Victim-1 and her young child 
back inside, ISAIAS FLORES-MENDEZ said, in sum and substance, 
that Victim-1 needed to learn what would happen if she disobeyed 
him. 

e. Utilizing brothels located in Manhattan, 
Bronx, Yonkers, and Brooklyn, ISAIAS FLORES-MENDEZ directly 
caused Victim-1 to perform commercial sex against her will daily, 
often servicing more than 20 customers per day. ISAIAS FLORES­
MENDEZ also sent Victim-1 to engage in commercial sex against her 
will in Maryland, Connecticut, New Jersey, and Pennsylvania. 

f. Based on Victim-1's observations, both ISAIAS 
FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ each had several women 
working for them, or being forced to work for them, as 
prostitutes. 

g. JUANA LUCAS-SANCHEZ, the defendant, worked 
for BONIFACIO FLORES-MENDEZ as a prostitute and served as an 
"enforcer" for ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ 
with respect to Victim-1. 

h. For example, LUCAS-SANCHEZ went shopping for 
revealing clothes to be worn by Victim-1. LUCAS-SANCHEZ also 
directed Victim-1 to work as a prostitute, and dictated which 
sexual acts Victim-1 should perform. LUCAS-SANCHEZ also directed 
Victim-1 to continue to engage in prostitution while 
menstruating. 

i. At one point, suspicion arose that Victim-1 
had become pregnant. In response, ISAIAS FLORES-MENDEZ, 
BONIFACIO FLORES-MENDEZ, and LUCAS-SANCHEZ took Victim-1 to a 
doctor, and forced her to take several pills that were described 
to her as Cytotec, which she understood were intended to induce a 

21 



miscarriage if she were pregnant. 

j. ISAIAS FLORES-MENDEZ took the money earned by 
Victim-1. When Victim-1 did not provide ISAIAS FLORES-MENDEZ 
with all of her earnings in a given day, he beat her. 

k. ISAIAS FLORES-MENDEZ, BONIFACIO FLORES­
MENDEZ, and LUCAS-SANCHEZ used cell phones to perpetrate this 
crime by communicating with each other and Victim-1 during the 
commission of the crime, by using cell phones to contact the 
drivers and brothel workers to find out how many customers 
Victim-1 had serviced in a given day so that ISAIAS FLORES-MENDEZ 
could collect all of the earnings and ensure that Victim-1 was 
not holding back any money, and by providing Victim-1 with at 
least one cell phone that Victim-1 was then required to use to 
arrange with drivers or brothel workers to engage in commercial 
sex. 

57. Based on my review of airline records, I know that 
in or about September 2006, Victim-1 and her young child flew 
from California to Queens, New York. 

SEX TRAFFICKING OF VICTIM-2 

58. In 2012 and 2013, I interviewed Victim-2, 3 who, as 
set forth below, gave an account of her experience being forced 
to engage in prostitution as a result of force, threats of force, 
and coercion by an individual known to her as "David Vasquez­
Medina." Victim-2 was shown a known photograph of DAVID VASQUEZ­
MEDINA, the defendant, and identified the person depicted in that 
photograph as the "David Vasquez-Medina" who caused Victim-2 to 
engage in prostitution against her will. Victim-2 also 
identified known photographs of ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," and BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendants. 

59. Based on my interviews of Victim-2, I know the 
following: 

Victim-2 has provided reliable information that has been 
independently corroborated. Victim-2 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

22 



a. In or about 2006 1 while living in the United 
States/ Victim-2 met DAVID VASQUEZ-MEDINA 1 the defendant/ and 
began a romantic relationship with him. A few months later 
Victim-2 returned to Mexico with her child. Shortly thereafter/ 
VASQUEZ-MEDINA also returned to Mexico/ where he met Victim-2 1 S 

parents and announced his intention to marry her. 

b. In or about later 2006 1 VASQUEZ-MEDINA and 
Victim-2 1 S brother were smuggled back into United States. 
VASQUEZ-MEDINA then made arrangements for Victim-2 and her child 
to be smuggled into the United States. 

c. When Victim-2 first joined VASQUEZ-MEDINA 1 

both Victim-2 and VASQUEZ-MEDINA had legitimate work. After 
VASQUEZ-MEDINA lost his legitimate job 1 however/ VASQUEZ-MEDINA 
began working as a driver/ delivering women working/ or being 
forced to work 1 as prostitutes/ to farms in New Jersey where the 
women had sex with the farm workers. 

d. VASQUEZ-MEDINA told Victim-2 that she should 
work as a prostitute and that the women he drove made 200 dollars 
or more a day. Victim-2 told VASQUEZ-MEDINA that she did not 
wish to do such work. 

e. Thereafter/ Victim-2 lost her legitimate job 1 

and her brother 1 who had been working in another state/ came to 
live with Victim-2 and VASQUEZ-MEDINA. VASQUEZ-MEDINA became 
angry and verbally abusive towards Victim-2 because neither 
Victim-2 nor her brother were working and because Victim-2 1 S 

child cost a lot of money. 

f. After suffering verbal abuse concerning 
Victim-2 1 S failure to make money/ and the expense of her child 1 

and repeated pressure from VASQUEZ-MEDINA 1 Victim-2 agreed to 
work as a prostitute. VASQUEZ-MEDINA purchased provocative 
clothing for Victim-2. 

g. VASQUEZ-MEDINA drove Victim-2 to various 
farms in New Jersey where Victim-2 had sex with approximately 25 
clients per day. VASQUEZ-MEDINA charged the clients $30 for 15 
minutes of sex with Victim-2. VASQUEZ-MEDINA kept all of the 
money Victim-2 had been paid. 

h. On another occasion/ VASQUEZ-MEDINA made 
arrangements for Victim-2 to work out-of-state for a week. 

23 



During that week, Victim-2 had sex with approximately 70 to 80 
clients. At the end of the week Victim-2 was given approximately 
$1,000. Victim-2 then returned to VASQUEZ-MEDINA by traveling 
through Manhattan, at which time VASQUEZ-MEDINA told Victim-2 
that he had spoken to the individual for whom Victim-2 had worked 
and knew how much she had earned. VASQUEZ-MEDINA forced Victim-2 
to give him all of the money she had been paid. 

i. After approximately two more weeks of working 
as a prostitute, Victim-2 pleaded with VASQUEZ-MEDINA to permit 
her to stop working as a prostitute. Victim-2 offered to work 
two jobs in order to earn more money. In response, 
VASQUEZ-MEDINA punched Victim-2, and told her, in sum and 
substance, that she had choice and must continue to work as a 
prostitute. VASQUEZ-MEDINA threatened to tell Victim-2's family 
that she was working as a prostitute, and that she would be 
responsible for her mother, who had a weak heart, dying from the 
shock. VASQUEZ-MEDINA also said that if Victim-2 did not comply 
he would take her child and she would never see her child again. 

j. Victim-2 was afraid of VASQUEZ-MEDINA and 
therefore did as he instructed. For approximately two years 
after this exchange, Victim-2 worked in prostitution against her 
will and under the control of VASQUEZ-MEDINA. Initially, 
VASQUEZ-MEDINA would set up work for Victim-2, but as time went 
on, he required Victim-2 to find her own work. 

k. In or around 2008, VASQUEZ-MEDINA was 
arrested and deported to Mexico. Once VASQUEZ-MEDINA was 
deported, Victim-2 stopped working as a prostitute. She began 
selling flowers and living in the Degante Residence. 

1. While living in the Degante Residence, 
Victim-2 observed that the Degante-Galeno family, including, but 
not limited to ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galeno," a/k/a "El Zorro," MARIA BAUTISTA-PENA, a/k/a "Maricruz," 
MIGUEL ANGEL CHE-VELIZ, a/k/a "Miguelon," and ISIDRO DEGANTE­
GALENO, a/k/a "Marcos," a/k/a "El Perro," a/k/a "Cachorro," 
MARGARITO DEGANTE, a/k/a "Chachalaco," the defendants, were also 
engaged in the prostitution business. Victim-2 observed 
discussions between various members of the Degante-Galeno family 
concerning their work in prostitution, discuss women being forced 
to work as prostitutes, and meet in the Degante Residence to 
discuss the division of prostitution money among family members. 
Victim-2 learned that members of the Degante-Galeno family were 

24 



working with ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," 
a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," and BONIFACIO FLORES­
MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendants. 

m. In approximately 2010, VASQUEZ-MEDINA began 
calling Victim-2 from Mexico. VASQUEZ-MEDINA told Victim-2 that 
he had changed and wanted to be with her and that he wanted to 
return to the United States. After he returned to the United 
States, however, Victim-2 learned that while in Mexico, 
VASQUEZ-MEDINA had begun a romantic relationship with Victim-2's 
sister, and that VASQUEZ-MEDINA was forcing Victim-2's sister, 
who had also come to the United s,tates, to work in prostitution. 

INTERSTATE TRANSPORTATION FOR PURPOSE OF PROSTITUTION 

60. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, and of reports of 
surveillance written by other law enforcement officers, I know 
the following. I know the following: 

a. On or about April 14, 2013, at approximately 
10:54 a.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota" 
received a call on Intercepted Cellphone-1 from a woman 
identified in this and other calls as "Karen" ("Karen"). During 
the call, Karen said that she was "calling about the week 
starting tomorrow," and asked where she could wait for BONIFACIO 
FLORES-MENDEZ. BONIFACIO FLORES-MENDEZ responded that they could 
meet on "111th and Roosevelt" at 8:30. 

b. On or about April 15, 2013, at approximately 
8:26a.m., BONIFACIO FLORES-MENDEZ received a call on Intercepted 
Cellphone-1 from Karen. During the call, the following 
conversation, in substance and in part, took place: 

KAREN: 

BONIFACIO: 

KAREN: 

BONIFACIO: 

I'm on my way there, but there is too 
much traffic here and I have not been 
able to get to Manhattan. 
All right then, meanwhile I pick up the 
rest. 
All right, I will call you when I get 
out of the Lincoln [U/I] . 
All right. 

c. Based on my training and experience, and my 
familiarity with this investigation, I believe that Karen is a 

25 



woman working, or being forced to work as a prostitute and that 
in the above call Karen told BONIFACIO FLORES-MENDEZ that she 
there was a lot of traffic en route to Manhattan through the 
Lincoln Tunnel to New Jersey and that she would be late. I 
further believe that BONIFACIO FLORES-MENDEZ said he would first 
pick up the other women working, or being forced to work, as 
prostitutes. 

d. Shortly thereafter, at approximately 8:51 
a.m., BONIFACIO FLORES-MENDEZ again used Intercepted Cellphone-1 
to speak to Karen. During the call, Karen said that she was 
"almost there," and BONIFACIO FLORES-MENDEZ confirmed that they 
were meeting on "111th." At approximately 9:12a.m., BONIFACIO 
FLORES-MENDEZ and Karen again spoke on Intercepted Cellphone-1 
and Karen said that she had arrived and BONIFACIO FLORES-MENDEZ 
responded that he would "pass by now." 

e. At approximately 9:35a.m., law enforcement 
agents observed a Black Honda registered to "Isaias Flores 
Mendez," parked at the intersection of 112th Street and Roosevelt 
Avenue, in Queens, New York. Just before the Black Honda drove 
away, law enforcement agents observed to unidentified Hispanic 
females in the back seat. 

f. Based on my training and experience and my 
participation in this investigation, I believe that Karen is a 
woman working or being forced to work as a prostitute and that in 
the above calls, she and BONIFACIO FLORES-MENDEZ discussed the 
fact that she would travel from New Jersey to meet him in order 
to be transported to a brothel for a week of work. I further 
believe that on or about April 15, 2013, BONIFACIO FLORES-MENDEZ 
met Karen in the vicinity of 112th Street and Roosevelt Avenue, 
picked her up, and transported her, and at least one other woman, 
to work at a brothel. 

g. On or about April 22, 2013, at approximately 
10:10 a.m., BONIFACIO FLORES-MENDEZ received a call on 
Intercepted Cellphone-1 from a woman who identified herself 
during the call as "Violeta" ("VIOLETA"). During the call, the 
following conversation, in substance and in part, took place: 

VIOLETA: 
BONIFACIO: 
VIOLETA: 

. It's Violeta speaking. 
Yes, call me on Sunday. 
Yes I am checking in and on Sunday I 
will call you. 

26 



BONIFACIO: 

VIOLETA: 

Okay. Call me on Sunday to see where I 
pick you up. You are the one that lives 
in New Jersey, right? 
Yes, yes, I will call you on Sunday. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that Violeta is a 
woman working, or being forced to work as a prostitute, and that 
in the above call BONIFACIO FLORES-MENDEZ said that Violeta 
should call him on Sunday to confirm where he would pick her up 
to take her to work at a brothel, and confirmed that she lives in 
New Jersey .. 

THE PROSTITUTION-SEX TRAFFICKING ENTERPRISE 

61. Since at least in or about 2008, ISAIAS 
FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus 
Diaz-Rincon," a/k/a "Chelo," BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante-Galeno," a/k/a "El Zor~o," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro," MARGARITO DEGANTE, 
a/k/a "Chachalaco," VALENTIN JIAMEZ-DOLORES, FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and others known and unknown, have 
been working in a criminal business enterprise, which profits 
from the sale of human beings for sex. 

62. Women who work, or are forced to work, as 
prostitutes for participants of the enterprise typically work 
under the abhorrent conditions described in more detail in 
paragraphs 13 through 23, above. The participants in this 
criminal business enterprise serve different functions, operating 
brothels, manning the brothels, driving victims to brothels and 
to customers' residences for the purpose of engaging in 
prostitution, dispatching drivers, passing out chica cards to 
advertise the enterprise, and recruiting and overseeing the women 
who work, or are forced to work, as prostitutes. In order to 
carry out their crimes, members of this criminal business 
enterprise rely heavily on the use of cell phones, communicating 
with each other, with victims and potential victims, and with 
customers by cell phone multiple times each day. 

63. Based on my review of GPS tracking data obtained 

27 



pursuant to court-authorized warrants, the February 2013 Order, 
and the April 2013 Order, I know that on a daily basis, members 
of this conspiracy travel-through Bronx, New York en route to the 
Yonkers Brothel, the Newburgh Brothel, and the Poughkeepsie 
Brothel. 

ISAIAS FLORES-MENDEZ 

64. On or October 16, 2012, law enforcement agents 
conducting surveillance observed an individual later identified 
as ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez Mendez," a/k/a 
"Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, exit the 
Poughkeepsie Brothel and get into a vehicle and drive away. 
Later that day, law enforcement agents observed ISAIAS FLORES­
MENDEZ in the vicinity of the Newburgh Brothel. Based on my 
review of GPS tracking data for Intercepted Cellphone-3, which 
ISAIAS FLORES-MENDEZ was using on or about October 16, 2012, I 
know that he traveled from Queens, New York to Poughkeepsie, New 
York, and from Newburgh, New York back to Queens, New York by 
traveling through Bronx, New York. 

65. Based on my review of summaries of consensually 
recorded telephone communications made by ISAIAS FLORES-MENDEZ, 
a/k/a "Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," the defendant, while incarcerated4 at the Vernon C. Bain 
Center at Rikers Island ("Rikers Island") 5

, I know the following: 

a. On or about October 22, 2012, at 
approximately 9:36a.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ, 

4 ISAIAS FLORES-MENDEZ was incarcerated at Rikers Island 
from the time of his October 19, 2012, arrest until January 2, 
2013, when he was transferred into federal custody in this 
District on the basis of a complaint charging him with illegal 
reentry in violation of Title 8, United States Code, Section 
1326(a) (12 Mag. 3262). On or about January 14, 2013, ISAIAS 
FLORES-MENDEZ was indicted on the same charge (13 Cr. 31 (KBF)) 

5 Based on my conversations with other law enforcement 
agents and my review of documents concerning Rikers Island inmate 
phone policies, I know that a sign is posted near all phones, in 
both English and Spanish, which informs inmates that, "Inmate 
telephone conversations are subject to electronic monitoring 
and/or recording in accordance with Department policy." 

28 



a/k/a "Bani," a/k/a "Mota," the defendant. During the call, 
ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ discussed the 
fact that BONIFACIO FLORES-MENDEZ had located a tracking device 
on a 1998 red Ford Expedition bearing Maryland license plate 
number 40484M7 (the "Red Expedition"), which is registered to 
"Bonifacio Flores-Mendez" (the "red one"), and that he had 
removed the tracking device. BONIFACIO FLORES-MENDEZ further 
said that the problem was that he "already [has] the women with 
[him]," and that he was going to drop them off far away. ISAIAS 
FLORES-MENDEZ directed BONIFACIO FLORES-MENDEZ to leave the women 
at the Family Dollar store. BONIFACIO FLORES-MENDEZ said he 
would use an individual he referred to as "Chachalaco," who I 
believe to be MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, to go up there (meaning, to the Family Dollar store to 
get the women and take them to the brothel) . 

b. On or about October 30, 2012, at 
approximately 7:36p.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ. 
During the call, ISAIAS FLORES-MENDEZ and BONIFACIO FLORES-MENDEZ 
engaged in the following discussion, in substance and in part: 

ISAIAS: 
BONIFACIO: 
ISAIAS: 
BONIFACIO: 

ISAIAS: 

BONIFACIO: 

Did you get women reported for Monday? 
Yes, Chela, for Brooklyn she said. 
Ah-ha. 
And another one who says that she had a 
fight in Poughkeepsie, she also reported 
herself for outside. 
Oh, for outside? Yes, yes, yes, 
she is. 

I know who 

Ah-ha. And another one. 
one too many . then the 
skinned Angelica for . 

. there was even 
. dark 

Yonkers. 

c. Based on my training and experience, and my 
participation in this investigation, I believe that in the above 
conversation, ISAIAS and BONIFACIO FLORES-MENDEZ discussed which 
women would work at which brothels and that BONIFACIO FLORES­
MENDEZ said that "Chela" would work at the Queens Brothel, 6 

6 Based on my review of this and other calls that reference a 
Brooklyn brothel, and my review of reports documenting 
surveillance, I know that the brothel referred to in this and 
other calls as being in Brooklyn is, in fact, the Queens Brothel 

29 



"Angelica" would work at the Yonkers Brothel, and that another 
woman, who previously had a fight at the Poughkeepsie Brothel, 
would work elsewhere, possibly through a delivery service 
("outside") . 

d. On or about November 8, 2012, at 
approximately 9:39a.m., ISAIAS FLORES-MENDEZ placed a call to 
Intercepted Cellphone-1 and spoke to BONIFACIO FLORES-MENDEZ. 
During the call, ISAIAS FLORES-MENDEZ told BONIFACIO FLORES­
MENDEZ in substance and in part, that: 

ISAIAS: I found a tall guy . his last name is 
Mendoza, at the church I [asked] "why 
did they put you in here?" . . he said, 
"domestic violence." [I asked] "so where are 
you from, guy?" Then he told me "Tenancingo," 

. "From there come the pimps, guy," I 
said. He starts laughing. "And how do you 
know that, guy?" [he asked] . I said, 
"because I work on that too, guy" . oh, 
then he started telling me . . "I wooed a 
young girl who . was fifteen [and] 
later on, like six months after that I put 
her to work, guy . . and then they catch 
her over there in . . Florida" . . I told 
him, "no kidding." 

e. Based on my training and experience and my 
participation in this investigation, I believe that in the above 
conversation, ISAIAS FLORES-MENDEZ told BONIFACIO FLORES-MENDEZ 
about a conversation ISAIAS FLORES-MENDEZ had with another inmate 
at Rikers Island. In that conversation, ISAIAS FLORES-MENDEZ 
said that he was aware that "pimps" come from Tenancingo, Mexico 
because ISAIAS FLORES-MENDEZ works in the business of "pimping" -
that is, works facilitating, causing, and/or compelling women to 
engage in prostitution for his financial gain. 

f. On or about November 13, 2012, at 
approximately 9:47p.m., ISAIAS FLORES-MENDEZ placed a call to an 
individual identified in other calls as "Angelica." During the 
conversation, ISAIAS FLORES-MENDEZ and Angelica discussed the 
fact that she was filling out various forms in anticipation of 

(which is very close to the Brooklyn-Queens border) . 

30 



the birth of her and ISAIAS FLORES-MENDEZ's child. During that 
conversation, ISAIAS FLORES-MENDEZ and Angelica had the following 
exchange: 

ANGELICA: 

ISAIAS: 

ANGELICA: 
ISAIAS: 

ANGELICA: 
ISAIAS: 

ANGELICA: 
ISAIAS: 

And they don't ask anything - no name or 
anything? 
Well, of course. So give mine. Isaias 
Flores-Mendez. 
Should I give yours? 
Yeah. Isaias Flores-Mendez. Don't give 
another name . . yeah, because I have 
everything with that name, my passport and 
all . . and in any case, I'll have time to 
arrive, for the birth certificate, I can 
sign it and all. 
Oh, all right. 

.Yeah, you can say the num . 
father's number, give that one. 
Uh huh. 

. his 
686 4929. 

I'm also going to change my 686 number . 
and I'll start calling the women with that 
one . . because the 686 . . one is 
also really burnt . but that would be 
when I arrive . . and open other places 
and start working really hard for my son. 

g. Based on my training and experience, and my 
participation in this and other investigations, I believe that in 
the above call ISAIAS FLORES-MENDEZ told Angelica to list his 
phone number as Intercepted Cellphone-1 and told her that after 
he returned to the United States (following his likely 
deportation when the then pending state criminal charges were 
resolved) he intended to get a new phone with which to speak with 
women working, or being forced to work, as prostitutes ("I'll 
start calling the women with that one") because Intercepted 
Cellphone-1 ("the 686 one") was "burnt," meaning that law 
enforcement authorities had become aware of his use of that 
number. ISAIAS FLORES-MENDEZ further stated that he intended to 
open additional brothels ("open other places") upon his illegal 
reentry from Mexico in order to support his son. 

BONIFACIO FLORES-MENDEZ 

66. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 

31 



following: 

a. On or about April 14, 2013, at approximately 
12:21 p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 
the defendant, received a call on Intercepted Cellphone-1 from a 
woman who identified herself on the call as "Elizabeth" 
("Elizabeth"). During the call, the following conversation, in 
substance and in part, took place: 

ELIZABETH: 

BONIFACIO: 
ELIZABETH: 

BONIFACIO: 

I am calling to check in, I am with you 
next week in Brooklyn. 
Okay, call me on Sunday then. 
Listen, did you check for the 29th, to 
Newburgh . you told me you were going 
to check last night. 
No right now I am up here in Newburgh 
Call me tonight and we will check. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that Elizabeth is 
a woman working, or being forced to work, as a prostitute for 
BONIFACIO FLORES-MENDEZ and his co-conspirators. In this call, 
she asked BONIFACIO FLORES-MENDEZ for a week of work beginning on 
April 29, 2013, at the Newburgh Brothel. 

c. On or about April 15, 2013, at 
1:34 p.m., BONIFACIO FLORES-MENDEZ received a call 
Cellphone-3 from an unidentified male ("UM-8311"). 
call, the following conversation, in substance and 
place: 

UM-8311: 
BONIFACIO: 
UM-8311: 
BONIFACIO: 
UM-8311: 
BONIFACIO: 

How are the girls now? 
Good; --
Better than last week? 
A lot better. 
Where are they from? 
Dominican and Mexican. 

approximately 
on Intercepted 
During the 

in part, took 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that UM-8311 is a 
customer of a brothel run by BONIFACIO FLORES-MENDEZ. In this 
call, UM-8311 asked about the women working, or being forced to 
work, as prostitutes in the brothel, and BONIFACIO FLORES-MENDEZ 
provided their countries of origin and said they were a lot 
better than the women who had been working in the brothel last 

32 



week (alluding to the fact that the women work in the brothel in 
one-week shifts). 

e. On or about April 23, 2013, at approximately 
9:17p.m., BONIFACIO FLORES-MENDEZ placed a call on Intercepted 
Cellphone-1 to a woman who identified herself during the call as 
"Alejandra," ("Alejandra"). During the call, the following 
conversation, in substance and in part, took place: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRO: 

BONIFACIO: 

ALEJANDRA: 
BONIFACIO: 

· ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 

BONIFACIO: 
ALEJANDRA: 
BONIFACIO: 

ALEJANDRA: 

Did you call me? 
Yeah, I call you yesterday. My name is 
Alejandra. 
For when? 
I don't know. Whenever you . well, 
whatever week is available sometime soon. 
For where do you want? 
Ummm . . one to stay and one for round 
trip. 
Okay for May . 
already have . 
one that I have is 
stay. 

hold on . April I 
Hmmm . the closest 
May 6th and May 13th to 

Okay well put me down for the 13th to stay. 
. Okay, for Yonkers Round trip . 

you want for . . May 20th . [to 
self:] ' Mayra, Diana, 27th, Wendy, Joanna, 
Dulce. ' Hmmm . . the 10th of June? 
No, for the 10th of June I already have 
that one . . do you have for the 24th? 
What about the first of July? 
Yes I the 1st yes. 
Put me down for that one round trip . 
because they told me that you have 3 . 
I don't know if 
I have 4. 
Oh, you have 4? 
Yeah, I have 2 to stay upstairs and I have 
2 round trip, one for Brooklyn and one for 
Yonkers . okay so I have you for May 
13th to stay over . . May 20th for 
Brooklyn and . let's see .. which 
one did you tell me? The 1st of July, 
right? 
Uh huh. For Yonkers. But the two that are 
to stay over are for the same location or 

33 



BONIFACIO: 

ALEJANDRA: 
BONIFACIO: 

in different places? 
No they are different. They are like 40 
minutes from each other. 
Oh, in Newburgh . 
One is in Newburgh and the other one is in 
Poughkeepsie. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that Alejandra is 
a woman working, or being forced to work, as a prostitute, and 
that in the above call she was making arrangements to work for a 
week at a time at various brothels run by BONIFACIO FLORES­
MENDEZ. In this call, BONIFACIO FLORES-MENDEZ describes the fact 
that he has four brothels, two at which the women working stay 
for the entire week, including sleeping at the brothel ("2 to 
stay") and two at which the women arrive each morning of the 
designated week and return home each evening of that week ("two 
round trip") . 

67. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-1 is used by BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant: 

a. Based on my conversations with Victim-2, I 
know that (i) ISAIAS FLORES-MENDEZ, a/k/a "Adrian Sanchez 
Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," the defendant, 
used Intercepted Cellphone-1 (ii) BONIFACIO FLORES-MENDEZ and 
ISAIAS FLORES-MENDEZ are brothers; and (iii) BONIFACIO 
FLORES-MENDEZ uses the nickname "Mota." 

b. Based on my review of wire remitter records 
from Casa De Cambio and Western Union, I know that both BONIFACIO 
FLORES-MENDEZ and ISAIAS FLORES-MENDEZ listed Intercepted 
Cellphone-1 as their phone number when sending wire transfers to 
Mexico. 

c. Based on my review of consensually recorded 
and intercepted calls over Intercepted Cellphone-1, I know that 
(i) Intercepted Cellphone-1 has continued to be in use since 
ISAIAS FLORES-MENDEZ's arrest in October 2012; (ii) the 
individual using Intercepted Cellphone-1 is referred to in calls 
as "Mota;" (iii) ISAIAS FLORES-MENDEZ has placed numerous calls 
to Cellphone-1 during which ISAIAS FLORES-MENDEZ has discussed 
the user of Intercepted Cellphone-1, the health of their mother 

34 



and the business of prostitution, among other topics. 

CARLOS GARCIA-DE LA ROSA 

68. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 23, 2013, at 
approximately 11:04 a.m., CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," the defendant, using 
Intercepted Cellphone-2, received an incoming call from an 
unknown male ("UM-1203"). During the intercepted call, the 
following conversation, in part, took place: 

UM-1203: Do you have something? 
DE LA ROSA: Yes . 
UM-1203: But where because I went to the other one, 

the one with the red door, and there was no 
one there. 

DE LA ROSA: No, I moved. I'm close by. Do you know 
where Pancho Villa is? 

UM-1203: Yeah. 
DE LA ROSA: Go over there and I'll pick you up. 
UM-1203: Oh. 
DE LA ROSA: Just tell me what you are wearing and I'll 

pick you up. 
UM-1203: No, listen, I'll call you during the week. I 

just want to know where it is. 
DE LA ROSA: Do you know where Rose Place is? Next to the 

gas station. It's house number [number 
provided] . 

UM-1203: Oh, house number [number provided]? 
DE LA ROSA: Yes, two bells on the right. It's on the 

second floor. 
UM-1203: So, I ring bell number 2? 
DE LA ROSA: Yes, both of the bells are working for 

upstairs or call me and I'll come down and 
pick you up. 

UM-1203: Cool. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that GARCIA-DE LA 
ROSA is a runner who works for BONIFACIO FLORES-MENDEZ and his 
co-conspirators. In his role as a runner, GARCIA-DE LA ROSA 

35 



transports women working, or being forced to work, as prostitutes 
to and from the brothels operated by BONIFACIO FLORES-MENDEZ, or 
to outside clients, and also transports customers to and from 
these brothels. Here, a prospective customer is speaking to 
GARCIA-DE LA ROSA about the location of the brothel in 
Poughkeepsie. GARCIA-DE LA ROSA offers to drive the customer to 
the brothel ("just tell me what you are wearing and I'll pick you 
up"), but the customer says he is simply trying to learn the 
location ("no, listen, I'll call you during the week. I just 
want to know where it is."). GARCIA-DE LA ROSA then identifies 
the location of the brothel in Poughkeepsie ("do you know where 
Rose Place is? Next to the gas station. It's house number 
[number provided]"). The address provided by GARCIA-DE LA ROSA 
on Rose Place is the address of the Poughkeepsie Brothel. 

c. On or about February 23, 2013, at 
approximately 10:10 p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant, using Intercepted Cellphone-2, 
received an incoming call from GARCIA-DE LA ROSA. During the 
intercepted call, the following conversation, in part, took 
place: 

DE LA ROSA: 

BONIFACIO: 
DE LA ROSA: 

BONIFACIO: 

DE LA ROSA: 

Don't take any money from there. I'll 
give you the envelope tomorrow. I have 
you today's envelope and tomorrow you 
give it to me. 
Cool. 
Yeah, because if not [U/I]. I didn't 
see when she called you. 
She said, "hey, tell Choqui to call me." 
Fucking flaca told her that my girl left 
already. 
No, I said, "I'm leaving, aunt." I 
didn't bother you anymore. I said, 
"maybe this guy doesn't want to." I'm 
going to pass by and give you the 
receipt. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that GARCIA-DE LA 
ROSA and BONIFACIO FLORES-MENDEZ are discussing the distribution 
of illegal prostitution/trafficking proceeds from the brothels 
operated by the criminal business enterprise. In this call, 
GARCIA-DE LA ROSA tells BONIFACIO FLORES-MENDEZ not to "take any 
money from there," which I believe is a reference to the 

36 



brothels. 

e. On or about February 26, 2013, at 
approximately 8:46a.m., BONIFACIO FLORES-MENDEZ, using 
Intercepted Cellphone-1, placed an outgoing call to a woman 
identified during other calls to the same number as "Mayra" 
("Mayra"). During the intercepted call, the following 
conversation, in part, took place: 

MAYRA: Hello. 
BONIFACIO: Choqui says he's at the corner on 108 

and 32. 
MAYRA: Okay. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that Mayra is 
working, or being forced to work, as a prostitute for BONIFACIO 
FLORES-MENDEZ and his co-conspirators. During this call, 
BONIFACIO FLORES-MENDEZ instructs Mayra to go to a corner where 
GARCIA-DE LA ROSA is waiting to drive Mayra to a brothel. 

g. On or about March 5, 2013, at approximately 
3:51p.m., GARCIA-DE LA ROSA, using Intercepted Cellphone-2, 
received an incoming call from an unknown male ("UM-7794"). 
During the intercepted call, the following conversation, in part, 
took place: 

UM-7794: The girls of Poughkeepsie. 
DE LA ROSA: Yes, come. 
UM-7794: From where? 
DE LA ROSA: Mexico. 
UM-7794: I'll be there later. 
DE LA ROSA: Okay, when you get here just knock. 
UM-7794: Okay. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
a prospective customer is speaking to GARCIA-DE LA ROSA about the 
women working, or being forced to work, as prostitutes at the 
Poughkeepsie Brothel. The customer wants to know where the women 
are from, and GARCIA-DE LA ROSA responds that they are from 
Mexico. The customer said he would arrive to the brothel later, 
and GARCIA-DE LA ROSA told the customer to knock when he arrives. 

i. On or about March 5, 2013, the following 

37 



calls were intercepted on Intercepted Cellphone-2: 

i) At approximately 3:55p.m., GARCIA-DE LA 
ROSA, using Intercepted Cellphone-2, received an incoming call 
from BONIFACIO FLORES-MENDEZ. During the intercepted call, the 
following conversation, in part, took place: 

DE LA ROSA: 
BONIFACIO: 
DE LA ROSA: 

Tell me chipotles. 
You have one downstairs. 
Okay, okay. 

ii) Approximately twenty-five minutes later, 
GARCIA-DE LA ROSA, using Intercepted Cellphone-2, received 
another call from BONIFACIO FLORES-MENDEZ, during which the 
following conversation, in part, took place: 

DE LA ROSA: Tell me, chipotles. 
BONIFACIO: You have one downstairs chiptudoi. 
DE LA ROSA: Okay, okay. 

iii) A few hours later, at approximately 7:06 
p.m., GARCIA-DE LA ROSA, using Intercepted Cellphone-2, received 
an incoming call from BONIFACIO FLORES-MENDEZ. During the 
intercepted call, the following conversation, in part, took 
place: 

DE LA ROSA: 
BONIFACIO: 
DE LA ROSA: 
BONIFACIO: 

Chipotles. 
The guy is downstairs. 
He is already inside dumbass. 
Okay, okay. 

iv) Based on my training and experience, and 
my familiarity with this investigation, I believe that in each of 
these calls, BONIFACIO FLORES-MENDEZ is alerting GARCIA-DE LA 
ROSA to calls BONIFACIO FLORES-MENDEZ has received from 
customers, indicating that there are customers coming to the 
brothel (e.g., "you have one downstairs"), and that GARCIA-DE LA 
ROSA, in his capacity as doorman or steerer, should let them 
inside. 

69. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-2 was used by CARLOS GARCIA-DE 
LA ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a "Miguel," the 
defendant: 

38 



a. As described in further detail above, on or 
about March 8, 2013, GARCIA-DE LA ROSA was administratively 
arrested. At the time of his arrest, GARCIA-DE LA ROSA was in 
possession of Intercepted Cellphone-2. GARCIA-DE LA ROSA 
admitted that Intercepted Cellphone-2 was his phone. 

ALEJANDRO DEGANTE-GALENO 

70. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order and the April 
2013 Order, I know the following: 

a. On or about February 26, 2013, at 
approximately 1:36 p.m., ALEJANDRO DEGANTE-GALENO, a/k/a 
"Celestino Degante Galena," a/k/a "El Zorro," the defendant, 
using Intercepted Cellphone-5, placed an outgoing call to an 
unidentified female ("UF-3569"). During the intercepted call, 
the following conversation, in part, took place: 

UF-3569: 
ALEJANDRO: 

UF-3569: 
ALEJANDRO: 

UF-3569: 

Hello. 
This motherfucker didn't go in. He wanted to 
do it without a condom. Tell him no next 
time. Negro gave me one right now 89 and 
35th. I'm going to do that one and then I'm 
going to head up for yours, okay. 
Cool. 
Keep him there. Keep him there. Tell him 
that the girl is 17 years old. 
Okay. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that, during this 
call, ALEJANDRO DEGANTE-GALENO was driving a car that dropping 
off and picking up women working, or being forced to work, as 
prostitutes from addresses of customers. In this call, UF-3569 
was acting as a dispatcher, was directing ALEJANDRO DEGANTE­
GALENO to various pick-up and drop-off locations. ALEJANDRO 
DEGANTE-GALENO references a particular woman who refused to 
engage in commercial sex with a customer because the customer was 
unwilling to wear a condom. ALEJANDRO DEGANTE-GALENO told UF-
3569 to keep a particular customer interested by telling him that 
the woman working, or being forced to work, as a prostitute who 
was to be delivered to the customer is only 17 years old. 

39 



c. On or about April 15, 2013, at approximately 
12:36 p.m., ALEJANDRO DEGANTE-GALENO received a call on 
Intercepted Cellphone-5 from ISIDRO DEGANTE-GALENO, a/k/a 
"Marcos," a/k/a "El Perro," a/k/a "Cachorro". During the call, 
the following conversation, in substance and in part, took place: 

ISIDRO: 

ALEJANDRO: 
ISIDRO: 
ALEJANDRO: 

He said the door is open to go up to the 
second floor he'll open for her. 
Okay, 2nd Floor. 
Uh huh. 
It's [street number] 32nd right? 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
ISIDRO DEGANTE-GALENO was serving as a dispatcher for ALEJANDRO 
DEGANTE-GALENO, and was relaying information from a customer 
about customers' location. 

e. On or about April 15, 2013, at approximately 
9:29p.m., ALEJANDRO DEGANTE-GALENO received an incoming call on 
Intercepted Cellphone-5 from an individual identified on other 
calls as both "Sergio" and "Huesito" ("Huesito"). During the 
call, the following conversation, in substance and in part, took 
place: 

HUESITO: 
ALEJANDRO: 
HUESITO: 
ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUESITO: 

Where are you? 
I will be there real soon. 
Okay. 
There's nothing? 
No, the four that we had are already 
covered. 
Okay. 
Yeah, I already made you the favor for 
the day ones. 
Take the day and the night too. 
Yes, I stayed with her the weekend night 
time too . I thought I was going to 
be able to do okay with Chachalaco's but 
I have to give some time to Monica as 
well . . yeah, I called her [Monica] 
because I didn't have anyone else. 
Oh. 
I had Monica because I didn't have 
anyone else. But today I got that girl 
that was with Chachalaco. 

40ALEJANDRO: 
HUESITO: 
ALEJANDRO: 
HUESITO: 

ALEJANDRO: 
HUES ITO: 
ALEJANDRO: 

HUESITO: 
ALEJANDRO: 

Yeah. 
I almost didn't get her 
Now until 4 am, right? 
Yeah, even if its early 
still fuck around 
day or night. 
Yeah. 

or late we'll 
they prostitute 

At what time is that girl getting there? 
Today she came in the day time. 
Tomorrow she comes in at three . 
yeah, I told you she came in today at 
eight in the morning. She finished 
around five. 
Oh, so she got to the house already? 
Yeah. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
Huesito and ALEJANDRO DEGANTE-GALENO are discussing their 
procurement of women working, or being forced to work, as 
prostitutes, including one who works for "Chachalaco," which I 
believe refers to MARGARITO DEGANTE, a/k/a "Chachalaco," the 
defendant, and the fact that the women will work day or night. 

g. On or about April 18, 2013, at approximately 
5:08p.m., ALEJANDRO DEGANTE-GALENO placed a call on Intercepted 
Cellphone-5 to an individual identified on other intercepted 
calls as "Juancho" ("Juancho"). During the call, the following 
conversation, in substance and in part, took place: 

ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 
JUANCHO: 
ALEJANDRO: 

JUANCHO: 

ALEJANDRO: 

JUANCHO: 
ALEJANDRO: 
JUANCHO: 

They said that new girl is good. 
Oh she's new. 
Yes, Nano said it's a girl. 
Oh, she's new? 
Yes. 
How old you think she is? 
She's only 17 and they're fucking her 
already. 
No kidding, she's young she looks 
good? 
Huesito, Chachalaco and Mario already 
had her. 
Damn! All of them! 
Yes. 
They're lucky. 

41 



ALEJANDRO: 

JUANCHO: 

ALEJANDRO: 

JUANCHO: 

It shows that she does it good. They 
said that she does it good. 

. Do you think she wants anything 
with you? 
I want to but the young guys got her 
already. 
There's nothing boss. 

h. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
ALEJANDRO DEGANTE-GALENO and Juancho are discussing a new female 
working, or being forced to work, as a prostitute, who was only 
17 years old ("Minor Victim-2"). ALEJANDRO DEGANTE-GALENO 
indicated that MARGARITO DEGANTE, a/k/a "Chachalaco," and men 
identified as Huesito and Mario, had each had Minor Victim-2 work 
as a prostitute for them already (or, alternatively, that they 
had each already had sex with Minor Victim-2) and that ALEJANDRO 
DEGANTE-GALENO would like to have Minor Victim-2 work for (or, 
alternatively, have sex with) him. 

71. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-5 is used by ALEJANDRO 
DEGANTE-GALENO, a/k/a "Celestino Degante Galena," a/k/a "El 
Zorro," the defendant: 

a. Based on my review of subscriber information 
for Intercepted Cellphone-5, I know that Intercepted Cellphone-5 
is subscr;Lbed in the name "Alejandro Mendoza." 

b .. Based on my review of Western Union records, 
I know that in connection with wire transfers to Mexico, 
ALEJANDRO DEGANTE-GALENO listed Intercepted Cellphone-5 as his 
phone number on multiple wire transfers. 

c. Based on my interview of Victim-2, I know 
that ALEJANDRO DEGANTE-GALENO uses Intercepted Cellphone-5. 

MARIA BAUTISTA-PENA 

72. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 
following: 

a. On or about April 20, 2013, at approximately 

42 



2:49p.m., ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galeno," a/k/a "El Zorro," the defendant, placed a call from 
Intercepted Cellphone-5 to MARIA BAUTISTA-PENA, a/k/a "Maricruz," 
who was using a cell phone with a call numper ending in 3569 
"Cellphone-3569"). During the call, the following conversation, 
in substance and in part, took place: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 
ALEJANDRO: 
BAUTISTA-PENA: 

How many calls do you have? Tell me 
the ones you have done. 
Give me time . . Look [street 
address] 37~ passed one . 
Okay, [street address] on 45~ 

[street address] on 37~ 
there are three. 
What? There are three, right? 
three that are yours? 
Yes, plus this one that is [street 
address] 101th. There will be four. 
Four of yours and one from Barbas 
that I did now. 
Five. 
Five, right? 
Uh huh. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO delivers women working, or being forced to work, 
as prostitutes to customers' residences and that BAUTISTA-PENA 
works as a dispatcher, receiving calls from customers and 
relaying orders to ALEJANDRO DEGANTE-GALENO. In this call, 
BAUTISTA-PENA said that she had taken four orders for women from 
customers, and that another individual identified as "Barbas" had 
taken one. 

c. On or about April 21, 2013, at approximately 
3:52p.m., ALEJANDRO DEGANTE-GALENO received a call on 
Intercepted Cellphone-5 from BAUTISTA-PENA, using Cellphone-3569. 
During the call, the following conversation, in substance and in 
part, took place: 

BAUTISTA-PENA: He said he's at the door and no one is 
there. 

ALEJANDRO: Okay wait. Come over here. . There are 
some guys here. Tell him that she's at 
the door. 

43 



BAUTISTA-PENA: He's outside. I'll ask what he's 
wearing. 

ALEJANDRO: Don't hang up. Wait. I think she went 
in. I'm going to do it for 40. 

BAUTISTA-PENA: Okay, Bye. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in this call, 
BAUTISTA-PENA said a customer - who was waiting for the delivery 
of a woman working, or being forced to work, as a prostitute -
said that he was at the door and no one was there. ALEJANDRO 
DEGANTE-GALENO said the woman had gone in (to the customer's 
residence) and that he was going to charge the customer $40 for 
the commercial sex. 

e. On or about April 22, 201·3, at approximately 
5:25p.m., ALEJANDRO DEGANTE-GALENO placed a call on Intercepted 
Cellphone-5 to BAUTISTA-PENA, using a cell phone with a call 
number ending in 2740 ("Cellphone-2740"). During the call, the 
following conversation, in substance and in part, took place: 

ALEJANDRO: 

BAUTISTA-PENA: 

ALEJANDRO: 

BAUTISTA-PENA: 
ALEJANDRO: 

The girls is inside but the guy is 
not opening the door. 
The [] guy is calling, he says that 
he is there. 
But what the hell! What do you do? 
What do you do? She is there. It is 
[street address] . 
71! 71! I told you. 
Oh, 71, 71 okay, okay. 

f. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call ALEJANDRO DEGANTE-GALENO said that the woman working, or 
being forced to work as a prostitute, who ALEJANDRO DEGANTE­
GALENO was delivering to a customer's residence was inside the 
customer's building but the customer was not answering the door. 
BAUTISTA-PENA, working as a dispatcher, was on the phone with the 
customer at the same time, and told ALEJANDRO DEGANTE-GALENO that 
the customer was at the door. When it became clear that 
ALEJANDRO DEGANTE-GALENO had gone to the wrong address, BAUTISTA­
PENA directed him to the correct address. 

73. Based on my training and experience, my 
participation in this investigation, and the following facts, I 

44 



believe that Cellphone-3569 and Cellphone-2740 are used by MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," the defendant: 

a. Based on my review of subscriber information 
for the Cellphone-3569, I know that it is subscribed to "Maria 
Bautista" at the Degante Residence. 

b. Based on my conversations with Victim-2, I 
learned that (i) ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino 
Degante Galena," a/k/a "El Zarro," the defendant, and his 
significant other, "Maria Bautista," live at the Degante 
Residencei (ii) that Celestino Degante uses the phone number of 
Intercepted Cellphone-5i and that "Maria Bautista" answers 
phones for the prostitution business. 

c. Based on the content of the numerous 
intercepted calls between Intercepted Cellphone-5 and the 
Cellphone-3569, I believe that (i) the user of Cellphone-3569 
goes by the name "Maricruz," (ii) the user of Intercepted 
CELLPHONE-5 and Cellphone-3569 are in a relationship and (iii) 
that the user of Cellphone-3569 works as a dispatcher for a 
prostitution delivery service. 

d. Based on a comparison of the voice of the 
individual using Cellphone-3569 and the voice of the individual 
using the Cellphone-2740, I believe that both phones are being 
used by the same person. 

ISIDRO DEGANTE-GALENO 

74. Based on my interviews of Victim-2, I know that 
ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El Perro," the 
defendant, has worked, at various times, as a driver, delivering 
women who work, or are forced to work, as prostitutes to brothels 
and/or to the residences of customers. 

75. Based on my interviews of a woman ("Victim-3") 7 

who was trafficked by an individual not named herein, I know that 
ISIDRO DEGANTE-GALENO a/k/a "Marcos," a/k/a "El Perro," the 
defendant, has worked, at various times, as a driver, delivering 

7 Victim-3 has provided reliable information that has been 
independently corroborated. Victim-3 may obtain immigration relief, 
pursuant to the Trafficking Victims Protection Reauthorization Act, as 
a result of her victimization and her cooperation with the Government. 

45 



women to the residences of customers for the purposes of 
prostitution. ISIDRO DEGANTE-GALENO was one of the drivers who 
transported Victim-3 to customers for the purpose of engaging in 
prostitution. ISIDRO DEGANTE-GALENO is also known as "Marcos" 
and "El Perro." 

76. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order and the April 
2013 Order, I know the following: 

a. On or about February 22, 2013, at 
approximately 10:06 p.m., ISIDRO DEGANTE-GALENO, a/k/a "Marcos," 
a/k/a "El Perro," the defendant, using Intercepted Cellphone-4, 
received an incoming call from an unidentified male ("UM-1922"). 
During the intercepted call, the following conversation, in part, 
took place: 

UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 
UM-1922: 
ISIDRO: 

UM-1922: 

ISIDRO: 

What girls do you have? 
From Salvador and Mexico. 
How do they look? 
They both look good. 
Can you bring me - how much do you charge? 
35. 
For how long? 
10-15 minutes. 
And half an hour? 
70. 
What's the least? 
70. 
Can you do it for 60? 
No, that's what they charge you. 35 for 
[u/ i] . 
Can you bring one to Astoria? To [street 
address] 30th Road? 
Give me 20 minutes. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that UM-1922 is a 
potential customer of ISIDRO DEGANTE-GALENO, who is working as a 
driver conducting deliveries of women working, or being forced to 
work, as prostitutes. The customer inquires about the 
availability of prostitutes, and ISIDRO DEGANTE-GALENO responds 
that he has women available who are El Salvadorean and Mexican. 
The customer then asks about pricing. ISIDRO DEGANTE-GALENO 
explains that the price is $35 for 10-15 minutes of sex, or $70 

46 



for a 30 minutes. Although the customer tries to negotiate a 
lower price, ISIDRO DEGANTE-GALENO says that it is not possible. 
The customer then asks for a woman to be delivered to a specific 
address, and ISIDRO DEGANTE-GALENO agrees. 

c. On or about March 10, 2013, at approximately 
10:06 p.m., ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El 
Perro," using Intercepted Cellphone-4, had a telephone 
conversation, direction unknown, with an unidentified male 
("UM"), using an unidentified/unregistered cell phone. During 
the intercepted call, the following conversation, in part, took 
place: 

UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 
UM: 
ISIDRO: 

Hey friend, are you working? 
Yes. 
What do you have? 
Salvador and Mexico. 
Which is better? 
They're both good. 
Okay, bring one. 
To where? 
[Street address] 39th Avenue on Roosevelt. 
Okay, give me 15 minutes. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that the UM is a 
customer who is asking ISIDRO DEGANTE-GALENO about the 
availability of women working, or being forced to work, as 
prostitutes ("What do you have . . . which is better") . The 
customer then asked ISIDRO DEGANTE-GALENO to deliver a woman to a 
specific address in Queens for sex ("bring one"), and ISIDRO 
DEGANTE-GALENO responded that he would have the woman at that 
address in "15 minutes." 

77. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Intercepted Cellphone-4 is used by ISIDRO DEGANTE­
GALENO, a/k/a "Marcos," a/k/a "El Perro," the defendant: 

a. Based on my review of subscriber records for 
Intercepted Cellphone-4, I know that it is subscribed in the name 
"Marcos Degante." 

b. Based on my conversations with Victim-2, I 
know that ISIDRO DEGANTE-GALENO uses Intercepted Cellphone-4 and 

47 



that ISIDRO DEGANTE-GALENO uses the nickname "Marcos," among 
others. 

c. Based on my conversations with a third 
victim, Victim-3, I know that Victim-3 called ISIDRO 
DEGANTE-GALENO on Intercepted Cellphone-4 to arrange for ISIDRO 
DEGANTE-GALENO to drive Victim-3 to brothels and/or to the 
residences of customers. 

MARGARITO DEGANTE 

78. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 26, 2013, the following 
conversations were intercepted on Intercepted Cellphone-5: 

i) At approximately 5:04p.m., ALEJANDRO 
DEGANTE-GALENO, a/k/a "Celestino Degante Galeno," a/k/a "El 
Zorro," the defendant, using Intercepted Cellphone-5, received an 
incoming call from an unidentified female working, or being 
forced to work, as a prostitute ("UF-4240") and MARGARITO 
DEGANTE, a/k/a "Chachalaco," the defendant, using a cell phone 
with a call number ending in 4240 ("Cellphone-4240"), during 
which the following conversation took place, in sum and 
substance: 

MARGARITO: 

ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 

UF-4240: 

ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 

Call him. [Street address] hasn't come 
out yet. 
29 
Oh, it's 29? 
Yes. Hold on. I have him on the line. 
Hello. 
He said to come to the door. He's there 
already. 
Okay. I have him on the other line. 
Chalaco? Chalaco? 
Yes. 
Hey. She said that he's at the door. 
Number 29. Send her. 
Okay, [street address]. 
Yes, I'll wait for you at [street name]. 
I'm going to leave. 
Okay, I saw him already. 

48 



ii) Based on my training and experience, and 
my familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO, UF-4240, and MARGARITO DEGANTE are discussing the 
delivery of a woman working, or being forced to work, as a 
prostitute to a customer for the purpose of engaging in 
commercial sex. In this call, while driving UF-4240 to a 
customer, MARGARITO DEGANTE is updating ALEJANDRO DEGANTE-GALENO 
about the customer's whereabouts, noting to ALEJANDRO DEGANTE­
GALENO that the customer is not yet in sight ("hasn't come out 
yet"). ALEJANDRO DEGANTE-GALENO gives MARGARITO the correct 
address, which MARGARITa acknowledges, and then proceeds with the 
transaction ("Okay, I saw him already.") . 

iii) A few minutes later, at approximately 
5:08p.m., MARGARITO DEGANTE, using Cellphone-4240, placed a call 
to ALEJANDRO DEGANTE-GALENO, using Intercepted Cellphone-5, 
during which the following conversation took place, in sum and 
substance: 

MARGARITO: 
ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 
MARGARITO: 

ALEJANDRO: 

MARGARITO: 
ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 
MARGARITO: 
ALEJANDRO: 

Where are you? 
Come right here to the other one. Come to . 

. what you call it? Come to seventy-first. 
Right? 
A ha, yeah. On [street name] . 
Yeah, is that where that bitch stays? 
Yes. She's stayed there. But they haven't 
passed yet. 
Yeah, why don't you come down the next one, 
dude? 
On seventy-second? 
71, 72, yes, 73. 
Seventy-third and what? 
Seventy-third and [street name], dude. 
Alright. I just passed seventy-second. 
Okay. 

iv) Based on my training and experience, and 
my familiarity with this investigation, I believe that ALEJANDRO 
DEGANTE-GALENO and MARGARITO DEGANTE are discussing meeting up in 
their cars on the street outside of a customer's address while 
they wait for a woman who is working, or being forced to work, as 
a prostitute to complete an appointment with a customer. 

v) Almost two hours later, at approximately 
6:54p.m., MARGARITa DEGANTE, using Cellphone-4240, placed a call 

49 



to ALEJANDRO DEGANTE-GALENO, using Intercepted Cellphone-5, 
during which the following conversation took place, in sum and 
substance: 

ALEJANDRO: 
MARGARITO: 

Where are you? In the car? 
I'm here. I came out to the corner here to 
pass some cards out. I'm going over there 
dude. 

vi) Based on my training and experience, and 
my familiarity with this investigation, I believe that in this 
call, MARGARITO DEGANTE indicates that he is on a corner passing 
out chica cards to advertise the prostitution enterprise. 

79. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-4240 is used by MARGARITO DEGANTE, a/k/a 
"Chachalaco," the defendant: 

a. Based on my conversations with Victim-2, I 
know that MARGARITO DEGANTE goes by the nickname Chachalaco. 

b. Based on my review of intercepted calls, I 
know that the user of the 4240 Cellphone uses the nickname 
Chachalaco and that the user of the 4240 Cellphone uses the 4240 
Cellphone to speak to members of the Degante-Galeno family, 
including ALEJANDRO DEGANTE-GALENO, a/k/a "Celestino Degante 
Galena," a/k/a "El Zarro," the defendant. 

VALENTIN JIAMEZ-DOLORES 

80. On or about November 21, 2012, law enforcement 
agents conducting surveillance of the Yonkers Brothel observed an 
individual later identified as VALENTIN JIAMEZ-DOLOREZ, the 
defendant, exit the Yonkers Brothel and get into the Red 
Expedition. During a stop of that vehicle by law enforcement 
agents, JIAMEZ-DOLORES claimed that he did not have any 
identification documents on him, but proffered that his name was 
"Valentine Jaimes," and provided a date of birth and a street 
address. 

81. As described above, on or about December 20, 2012, 
law enforcement agents interviewed VALENTIN JIAMEZ-DOLORES, the 
defendant, following his arrest at the Yonkers Brothel and 
execution of a written waiver of his Miranda rights. JIAMEZ-

so 



DOLORES then stated, in substance and in part, that the Yonkers 
Brothel is, in fact, a brothel, and that JIAMEZ-DOLORES mans the 
door of the Yonkers Brothel and collects $30 from each customer 
in return for a playing card, which the customers then gave to 
the women working in the brothel as payment for sex. Law 
enforcement agents seized from the person of JIAMEZ-DOLORES 17 
playing cards, $180 in cash, and a key ring. JIAMEZ-DOLORES was 
also in possession of an identification document which bore the 
name ~valentin Jiamez-Dolores" and the same date of birth and 
street address as that proffered by JIAMEZ-DOLORES on or about 
November 21, 2012. 

82. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about March 5, 2013, at approximately 
6:45p.m., BONIFACIO FLORES-MENDEZ, a/k/a ~Boni," a/k/a ~Mota," 
the defendant, using Intercepted Cellphone-3, made an outgoing 
call to VALENTIN JIAMEZ-DOLORES, the defendant, using a cell 
phone with a call number ending in 4158 (~cellphone-4158"). 

During the intercepted call, the following conversation, in 
substance and in part, took place: 

BONIFACIO: 

JIAMEZ-DOLORES: 
BONIFACIO: 

There is a guy that is going to be 
there. If it is a customer he says I 
will lend him . . that he will give me 
ten then tomorrow he will give the 
twenty. If you know him do it, if not 
no. 
Okay. 
He is going there now. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that BONIFACIO 
FLORES-MENDEZ was telling JIAMEZ-DOLORES that a customer was 
going to come to JIAMEZ-DOLORES and tell him that BONIFACIO 
FLORES-MENDEZ said it would be okay for him to patronize a woman 
working as a prostitute that evening and pay the next day ("a 
customer he says I will lend him . . that he will give me ten 
and then tomorrow he will give the twenty"). BONIFACIO FLORES­
MENDEZ told JIAMEZ-DOLORES that if he recognized this customer to 
allow it ("If you know him do it"), but that if JIAMEZ-DOLORES 
did not recognize the customer to not let him have sex with a 
woman without paying in full first ("if not no") 

51 



83. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-4158 is used by VALENTIN JIAMEZ-DOLORES, 
the defendant: 

a. As described in further detail above, on or 
about November 18, 2012, law enforcement officers conducted a 
traffic stop of the Red Expedition. In addition to BONIFACIO 
FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," the defendant, law 
enforcement encountered an individual who claimed to be without 
identification but said his name was "Valentine Jaimes," and 
provided a date of birth and address. The same individual was 
later arrested and admitted that he was working at the Yonkers 
Brothel. At the time of his arrest, the individual was in 
possession of an identification document bearing the name 
"Valentin Jiamez-Dolores," which bore the same date of birth and 
address as "Valentine Jaimes" had provided to law enforcement. 

b. Based on my review of Western Union and Casa 
De Cambio records I know that an individual named "Valentin 
Jiamez-Dolores" has sent wire transfers to Mexico in connection 
with which he listed the cell phone number for Cellphone-4158. 

c. Based on my review of intercepted calls with 
Cellphone-4158, I know that during some intercepted calls the 
user of Cellphone-4158 is referred to as "Valentin." 

FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas" 

84. Based on my review of reports prepared other law 
enforcement agents, I know the following: 

a. On several occasions in November and December 
2012, and in April 2013, FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," the defendant, was 
seen escorting men into the Queens Brothel. Each man was seen 
leaving the Queens Brothel after spending approximately 10-15 
minutes inside. While conducting surveillance, law enforcement 
agents took video of FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," from which 
photographs were printed, some of which are attached hereto as 
Exhibit A. 

52 



b. On or about December 6, 2012, agents 
conducting surveillance of the Queens Brothel saw an individual 
later identified as FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," entering and exiting 
the Queens Brothel. That day, HSI agents encountered a man who 
had left the Queens Brothel ("Customer-1"), who said, in sum and 
substance, that FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," operated the Queens Brothel. 

c. On or about December 6, 2012, agents 
conducting surveillance followed FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," from the 
Queens Brothel to Latin Travel on Seneca Avenue, which provides a 
money remitter service. 

85. Based on my review of records provided by the 
money remitter service operated out of Latin Travel on Seneca 
Avenue, I know the following: 

a. On or about December 4, 2012, a wire transfer 
in the amount of approximately $500 was sent to "Alicia Miranda­
Flares" in Puebla, Mexico from an individual who identified 
himself as "Alberto Jesus Martinez-Miranda," living at the 
address of the Queens Brothel, with a contact phone number ending 
in 0431 ("Cellphone-0431"). 

b. On or about December 6, 2012, a wire transfer 
in the amount of approximately $200 was sent to "Luis Ramon 
Martinez-Miranda" in Puebla, Mexico from an individual who 
identified himself as "Alberto Jesus Martinez-Miranda," living at 
the address of the Queens Brothel, with Cellphone-0431 listed as 
the contact number. 

86. Based on my review of an ICE database, I know that 
on or about February 15, 1999, an individual identified as 
"Alberto Martinez-Miranda" was encountered along the United 
States-Mexico border, and stated that his mother's name is 
"Alicia." 

87. Based on my review of summaries of calls 
intercepted pursuant to the April 2013 Order, I know the 
following: 

a. On or about April 8, 2013, at approximately 
4:54p.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," 

53 



the defendant, placed a call from Intercepted Cellphone-3 to FNU 
LNU, a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," 
a/k/a "Barbitas," the defendant, who was using Cellphone-0431. 
During the call, the following conversation, in substance and in 
part, took place: 

FNU LNU: 
BONIFACIO: 

FNU LNU: 

Tell me, tell me. 
Check a guy for me with a black shirt 
and [U/I] Eight. Seneca and Grow. 
Okay, Okay. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call BONIFACIO told FNU LNU, a/k/a "Alberto Jesus Martinez­
Miranda," a/k/a "Barbas," a/k/a "Barbitas," to check on a male, 
possibly a client, who was near the Queens Brothel. 

c. On or about April 18, 2013, at approximately 
7:59p.m., BONIFACIO FLORES-MENDEZ placed a call on Intercepted 
Cellphone-3 to FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," using Cellphone-0431. During 
the call, the following conversation, in substance and in part, 
took place: 

BONIFACIO: 
FNU LNU: 
BONIFACIO: 

FNU LNU: 

You have one downstairs. 
Alright. 
Tell the girl that 3 guys are going to 
be waiting in five minutes. It's 3 
separate ones. 
Alright. 

d. Based on my training and experience, and my 
familiarity with this investigation, I believe that in the above 
call, BONIFACIO FLORES-MENDEZ told FNU LNU, a/k/a "Alberto Jesus 
Martinez-Miranda," a/k/a "Barbas," a/k/a "Barbitas," to tell the 
woman working, or being forced to work as a prostitute, that 
three separate customers were on their way and would arrive in 5 
minutes. 

88. Based on my training and experience, my 
participation in this investigation, and the following facts, I 
believe that Cellphone-0431 is being used by FNU LNU, a/k/a 
"Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendant: (i) law enforcement agents' 
observation of FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 

54 



a/k/a "Barbas," a/k/a "Barbitas," working at the Queens Brothel, 
(ii) the intercepted calls concerning the Queens Brothel, and 
(iii) the use by FNU LNU, a/k/a "Alberto Jesus Martinez-Miranda," 
a/k/a "Barbas," a/k/a "Barbitas," of Cellphone-0431 to send wire 
transfers to an individual with the same name as that of his 
mother. 

OBSTRUCTION OF JUSTICE 

89. Based on my review of records from the Virginia 
Department of Motor Vehicles and the Maryland Motor Vehicle 
Administration, I know the following: 

a. A 1999 black Honda Accord with Virginia 
license plate WXM 7063 (the "Black Honda") is registered to 
"Isaias Flores-Mendez." 

b. The Red Expedition (described above) is 
registered to "Bonifacio Flores-Mendez." 

c. A 2001 white Chevy Astra Van bearing Maryland 
license plate number 3AK2211 (the "Chevy Astra") is registered to 
"Bonifacio Flores-Mendez." 

90. On or about October 18, 2012, pursuant to a court­
authorized tracking warrant, GPS tracking devices were placed on 
the Red Expedition and on the Chevy Astra. The GPS tracking 
device placed on the Chevy Astra, however, was defective and 
never successfully transmitted GPS data. On or about October 22, 
2012, the GPS tracking device on the Red Expedition failed - that 
is, the GPS tracking device which had previously been 
transmitting GPS data, ceased to do so. Based on my experience 
working with GPS tracking devices, I know that a tracking device 
may "fail" for many reasons, including that the device itself may 
be defective, that the device may be inadvertently dislodged from 
the vehicle to which it is magnetically attached, or it may be 
intentionally removed. On or about October 23, 2012, replacement 
GPS devices were placed on the Red Expedition and the Chevy 
Astra. On or about October 25, 2012, the GPS tracking device on 
the Red Expedition failed again. On or about November 14, 2012, 
a replacement GPS tracking device was placed on the Red 
Expedition. On or about November 15, 2012, the GPS tracking 
device on the Chevy Astra failed. On or about November 19, 2012, 
the GPS tracking device on the Red Expedition failed again. 
Shortly thereafter, law enforcement agents approached the Red 

55 



Expedition and the Chevy Astro to look for the GPS tracking 
devices but were unable to locate them. 

91. Based on my review of consensually recorded 
telephone communications made by ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," the defendant, while incarcerated at Rikers Island, I 
know the following: 

a. On or about October 22, 2012, at 
approximately 9:36a.m., ISAIAS FLORES-MENDEZ placed a c~ll to 
Intercepted Cellphone-1 and spoke to an individual later j 

identified as BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a 
"Mota," the defendant. During the call, BONIFACIO FLORES-MENDEZ 
stated, in substance and in part, "listen carefully . . I found 
a tracker in the red one . . I put gas in it a while ago and it 
started spilling so I went to Miguelon's . [and] he said, ] 
'listen dude, you have something weird on the fuel tank . so 
we took it out . . it's a tracking device dude but the 
problem is that I already have the women with me . . I am going 
to drop them off far away." 

b. On or about October 25, 2012, at 
approximately 6:36p.m., ISAIAS FLORES-MENDEZ again placed a call 
to Intercepted Cellphone-1 and again spoke to BONIFACIO FLORES­
MENDEZ. During the call, BONIFACIO FLORES-MENDEZ stated in 
substance and in part, "I found another tracking device in the 
red one . . last night Choqui went to get it and Miguelon said, 
'we have to check it out every two or three days,' . so I 
called him and told him 'let's check it out . . we 
removed the spare tire and now they placed it on top of the spare 
tire. . he [Miguelon] said 'take it apart . take half of it, 
I'll dispose of half of it, and you leave . . and go throw the 
other half in the ocean.' I pulled over by Whitestone and dropped 
it there." 

c. On or about October 31, 2012, at 
approximately 7:39p.m., ISAIAS FLORES-MENDEZ placed another call 
to Intercepted Cellphone-1 and again spoke to BONIFACIO 
FLORES-MENDEZ. During the call, ISAIAS FLORES-MENDEZ asked, in 
substance and in part, if everything was fine in Yonkers and 
whether BONIFACIO FLORES-MENDEZ, had "seen anything else weird?" 
BONIFACIO FLORES-MENDEZ replied, in substance and in part, that 
everything was fine and that he had not seen anything weird. 
ISAIAS FLORES-MENDEZ then asked, in substance and in part, if 

56 



"you guys not check the black car 
FLORES-MENDEZ responded "yes, but 
That's the one I am driving now." 
further, "did you guys open up the 
BONIFACIO FLORES-MENDEZ said yes. 

or anything," and BONIFACIO 
it doesn't have anything. 

ISAIAS FLORES-MENDEZ inquired 
engine and everything," and 

92. Based on my review of telephone calls intercepted 
pursuant to the April 2013 Order, I know the following: 

a. On or about February 23, 2013, at 
approximately 10:40 a.m., BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," the defendant,' received an incoming call on 
Intercepted Cellphone-3 from a man identified during the call as 
"Miguelon," who was using a cellular telephone assigned a call 
number ending in 0765 ("CELLPHONE-0765"), during which the 
following conversation took place, in substance and in part: 

BONIFACIO: Tell me, Miguelon. 
MIGUELON: The black one is ready. 
BONIFACIO: Okay. I will pass by in a little while. 

b. Based on my training and experience, and my 
familiarity with this investigation, I believe that BONIFACIO 
FLORES-MENDEZ and "Miguelon" were discussing the Black Honda that 
BONIFACIO FLORES-MENDEZ and his co-conspirators use to transport 
women who work, and are forced to work, as prostitutes, and I 
believe that "Miguelon" is a mechanic. 

93. Based on my review of subscriber records for 
CELLPHONE-0765, I know that CELLPHONE-0765 is subscribed in the 
name "Miguel Ang Che." 

94. Based on my review of a Customs and Border Patrol 
database, I know that on or about February 2, 2013, an airline 
ticket for a child (the "Child Passenger") was booked with 
CELLPHONE-0765 listed as the contact telephone number for the 
Child Passenger) . 

95. Based on my review of United States Department of 
State records, I know that United States Passport issued for the 
Child Passenger states that the Child Passenger's father is 
"Miguel Angel Che Veliz," with an address on 53rd Avenue in 
Queens, New York, and a contact phone number that is the same as 
CELLPHONE-0765. 

57 



96. Based on my review of GPS tracking data obtained 
pursuant to a court-authorized warrant, I know that CELLPHONE-
0765 is frequently in the vicinity of the address on 53rct Avenue 
in Queens, New York, that was provided for "Miguel Angel Che 
Veliz" in the Passport for the Child Passenger. 

97. Based on my training and experience, and my 
familiarity with this investigation, and my review of the 
records, phone calls, and data described above, I believe that 
the "Miguelon" referred to by BONIFACIO FLORES-MENDEZ, a/k/a 
"Boni," a/k/a "Mota," in calls with ISAIAS FLORES-MENDEZ, a/k/a 
"Adrian Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a 
"Chelo," is the same person as MIGUEL ANGEL CHE-VELIZ, a/k/a 
"Miguelon," the defendant. I further believe that as discussed 
in the intercepted calls described above, MIGUEL ANGEL CHE-VELI.Z 
located the tracking devices that law enforcement had placed on 
the Red Expedition and the Chevy Astro and destroyed and/or 
directed that the tracking devices be destroyed. I further 
believe that MIGUEL ANGEL CHE-VELIZ then continued to check 
various cars used by BONIFACIO FLORES-MENDEZ and others for new 
tracking devices and removed any additional tracking devices that 
he found. 

POSSESSION OF CHILD PORNOGRAPHY 

98. Based on my review of summaries of calls 
intercepted pursuant to the February 2013 Order, I know the 
following: 

a. On or about February 22, 2013, at 
approximately 10:31 p.m., CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," spoke to Minor Victim-1 
on Intercepted Cellphone-2. During the call, the following 
conversation, in substance and in part, took place: 

DE LA ROSA: 

MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 

What are you doing? Send me a picture 
[pause] of you, naked. 

Ah? 
Send me a picture of you, naked. 
I will take a shower. 
Are you going to take a shower? 
Yes. 
Send me a picture, no? 
I will think about it. 
Please? 

58 



MINOR VICTIM-1: 
DE LA ROSA: 
MINOR VICTIM-1: 
DE LA ROSA: 

MINOR VICTIM-1: 

Okay then. 
Of you taking a shower, very open. 
Uh? 
When you are in the bathroom, standing, 
very open . I'll never ask you 
anything else. Only that . send it 
to me this number, uh? 
Okay then. 

99. On or about March 8, 2013, CARLOS GARCIA-DE LA 
ROSA, a/k/a "Choqui," a/k/a "Pirulo," a/k/a "Miguel," the 
defendant, was administratively arrested by the Department of 
Homeland Security, waived his Miranda rights, and was 
interviewed. During the interview, GARCIA-DE LA ROSA stated, in 
substance and in part: 

a. He had been talking to Minor Victim-1 for 
approximately 6-7 months. 

b. He knows Minor Victim-1 to be approximately 
14 years old. 

c. He asked Minor Victim-1 to send him naked 
photos of herself, including photos of her breasts and photos of 
Minor Victim-1 with her legs spread open. Minor Victim-1 texted 
GARCIA-DE LA ROSA the requested photos. Shortly after receiving 
the requested photos he deleted them from his phone. 

100. Law enforcement agents recovered Intercepted 
Cellphone-2 from CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," a/k/a 
"Pirulo," a/k/a "Miguel," determined that it was manufactured 
outside of New York, and conducted a forensic review of 
Intercepted Cellphone-2. During the forensic review, law 
enforcement agents were able to recover previously deleted 
photos, one of which depicted a girls breasts and one of which 
depicted a girls genitalia (the "Photographs"). 

101. On or about March 11, 2013, Minor Victim-1 was 
interviewed by law enforcement. Minor Victim-1 stated, in 
substance and in part, that approximately two weeks prior, she 
had, at the request of a man with whom she had a sexual 
relationship, taken picturers of herself and texted them to him. 
Minor Victim-1 was shown the Photographs and identified one of 
the images as the picture she took of her genitalia. 

59 



102. Based on my review of GPS tracking data for 
Intercepted Cellphone-2, I know that after February 22, 2013, and 
prior to his arrest, CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo," a/k/a "Miguel," was present in the Southern 
District of New York. 

103. Based on (i) the intercepted call described abovei 
(ii) the statements of CARLOS GARCIA-DE LA ROSA, a/k/a "Choqui," 
a/k/a "Pirulo" a/k/a "Miguel," and Minor Victim-1, and the 
recovered Photographs, I believe that Minor Victim-1 is a minor 
and that she texted photographs depicting her genitalia to 
GARCIA-DE LA ROSA, who possessed the images on his cellular 
telephone, Intercepted Cellphone-2, in the Southern District of 
New York. 

ILLEGAL REENTRY BY PANFILO FLORES-MENDEZ 

104. Based on my review of the file maintained by ICE 
(the "Alien File") regarding PANFILO FLORES-MENDEZ, the 
defendant, I have learned the following: 

a. PANFILO FLORES-MENDEZ is a citizen of Mexico 
and has never been a citizen of the United States. 

b. On or about November 29, 2010, PANFILO 
FLORES-MENDEZ was removed and deported from the United States to 
Mexico. On that date, a photograph of PANFILO FLORES-MENDEZ was 
taken and added to his Alien File. 

c. Following his removal and deportation to 
Mexico, PANFILO FLORES-MENDEZ never obtained the express consent 
of the Attorney General of the United States, or the Secretary 
for the Department of Homeland Security, to reapply for admission 
to the United States. 

105. Based on my review of a report prepared by another 
HSI agent, I know the following: 

a. On or about November 18, 2012, a Detective 
with the Yonkers Police Department (the "Yonkers Detective") saw 
PANFILO FLORES-MENDEZ, the defendant, walk out of the Yonkers 
Brothel and get into the Red Expedition. Shortly thereafter, the 
Yonkers Detective stopped the Red Expedition, which was occupied 
by PANFILO FLORES-MENDEZ, BONIFACIO FLORES-MENDEZ, a/k/a "Boni," 
a/k/a "Mota," VALENTIN JIAMEZ-DOLORES, and two women. PANFILO 

60FLORES-MENDEZ produced a Mexican identification document bearing 
the name "Panfilo Flores-Mendez" and a date of birth. 

b. The Yonkers Detective looked at the 
photograph in the Alien File for PANFILO FLORES-MENDEZ and 
confirmed that it depicted the same person as the PANFILO FLORES­
MENDEZ stopped in Yonkers, New York, on or about November 18, 
2012. 

106. Based on my review of the Alien File and the 
report documenting the car stop of by the Yonkers Detective on or 
about November 18, 2012, I know that the date of birth for 
PANFILO FLORES-MENDEZ that is in the Alien File, and the date of 
birth on the identification produced by PANFILO FLORES-MENDEZ on 
or about November 18, 2012, are the same. 

ILLEGAL REENTRY BY JUANA LUCAS-SANCHEZ 

107. Based on my review of the Alien File regarding 
JUANA LUCAS-SANCHEZ, the defendant, I have learned the following: 

a. LUCAS-SANCHEZ is a citizen of Mexico and has 
never been a citizen of the United States. 

b. On or about January 29, 2004, LUCAS-SANCHEZ 
was removed and deported from the United States to Mexico. On 
that date, LUCAS-SANCHEZ was fingerprinted and her fingerprint 
was placed on an executed warrant of removal. On that date, a 
photograph of LUCAS-SANCHEZ was taken and added to her Alien 
File. 

c. On or about June 8, 2004, LUCAS-SANCHEZ was 
removed and deported from the United States to Mexico. On that 
date, LUCAS-SANCHEZ was fingerprinted and her fingerprint was 
placed on an executed notice to alien ordered removed/departure 
verification. On that date, a photograph of LUCAS-SANCHEZ was 
taken and added to her Alien File. 

d. Following her removal and deportation to 
Mexico, LUCAS-SANCHEZ never obtained the express consent of the 
Attorney General of the United States, or the Secretary for the 
Department of Homeland Security, to reapply for admission to the 
United States. 

108. On or about May 29, 2009, JUANA LUCAS-SANCHEZ, the 

61 



defendant, was arrested by the NYPD in Bronx, New York. On or 
about August 31, 2009, LUCAS-SANCHEZ was convicted upon of a plea 
of guilty, in Bronx County Supreme Court, to Prostitution, a 
class B misdemeanor, in violation of New York Penal Code Section 
230.00, and sentenced to conditional discharge. 

109. Upon her arrest on or about May 29, 2009, JUANA 
LUCAS-SANCHEZ's fingerprints were uploaded to a law enforcement 
database. The law enforcement database matched the fingerprints 
taken from LUCAS-SANCHEZ in connection with the May 29, 2009 
arrest to the fingerprints taken by ICE in connection with LUCAS­
SANCHEZ's removal on or about January 29, 2004, and on or about 
June 8, 2004. 

WHEREFORE, deponent respectfully requests that warrants 
issue for the arrests of ISAIAS FLORES-MENDEZ, a/k/a "Adrian 
Sanchez Mendez," a/k/a "Jesus Diaz-Rincon," a/k/a "Chelo," 
BONIFACIO FLORES-MENDEZ, a/k/a "Boni," a/k/a "Mota," JUANA LUCAS­
SANCHEZ, DAVID VASQUEZ-MEDINA, CARLOS GARCIA-DE LA ROSA, a/k/a 
"Choqui," a/k/a "Pirulo," a/k/a "Miguel," ALEJANDRO DEGANTE­
GALENO, a/k/a "Celestino Degante Galena," a/k/a "El Zorro," MARIA 
BAUTISTA-PENA, a/k/a "Maricruz," MIGUEL ANGEL CHE-VELIZ, a/k/a 
"Miguelon," ISIDRO DEGANTE-GALENO, a/k/a "Marcos," a/k/a "El 
Perro," a/k/a "Cachorro," MARGARITO DEGANTE, a/k/a "Chachalaco," 
PANFILO FLORES-MENDEZ, VALENTIN JIAMEZ-DOLORES, and FNU LNU, 
a/k/a "Alberto Jesus Martinez-Miranda," a/k/a "Barbas," a/k/a 
"Barbitas," the defendants, and that they each be arrested and 
imprisoned, or bailed, as the case may be. 

APR Z 9 2013 
Sworn to before me this 
J=_:2th day of April 2013 

· ONOIUlliLE 
UNITED STATES MAGISTRATE JUDGE 
SOUTHERN DISTRICT OF NEW YORK 

/ 

i£t~ . ('. 
EL~IN HERNJ\NDEi 
SPECIAL AGENT 
DEPARTMENT OF HOMELAND SECURITY 

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