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DETENTION AFFIDAVIT

I, Mark S. Karangekis, having been first duly do hereby depose and state as
follows:
1. I am a Special Agent of the Federal Bureau of Investigation (FBI). I have 'been a
Special Agent (SA) since April 5, 1992. I am currently assigned to the Boston Field Office,
Springfield Resident Agency. I am submitting this affidavit in support of the government's
motions that the following individuals be detained pending trial: Francisco Diaz, aka Franco,
Antonio Caraballo, aka Pote, William Rodriguez, aka Snoop,
Luzander Montoya, aka Zander, Miguel Medina, Miguel Alcaz ,
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gu a,
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FIaco, (hereinafter collectively referred to as lithe Targets"). I have not included each and every
fact developed from the investigation in this affidavit. Rather, this affidavit includes facts I
believe to be relevant to issues under 18 U.S.C. 3142 with respect to the Targets.
2. All of the Targets have been charged with various drug andlor flrearms violations
in indictments issued on March 28,2013. All of these individuals are alleged to be members
(including members of the local or regional leadership) or associates of La Familia, a violent
street gang operating in, among other places, Holyoke, Massachusetts. All of these individuals
have significant criminal histories involving drugs andlor firearms violations. As detailed more
fully below, the involvement by the Targets in La Familia heightens the likelihood that they
would commit further crimes, including violence directed at parties who have cooperated with .
the government, if they were released. The information provided below is submitted to show
. that there exists no conditions or combination of conditions under which the Targets can be
safely released to community.
3. Over the past three years, the Western Massachusetts Gang Task Force
(WMGTF) which includes members of the Federal Bureau of Investigation (FBI), Holyoke
Police Department (HPD), Massachusetts State Police (MSP), Springfleld Police Department,
. Hampden County Sheriff's Office (HCSO), Chicopee Police Department (CPD), Lee Police
Departinent (LPD), and the Drug Enforcement Administration (DEA), with assistance from the
United States Ma,rshal Service and the Bureau of Alcohol, Tobacco, Firearms and Explosives,
have conducted an investigation targeting the heroin distribution activities ofthe leaders,
members and associates of the LA FAMILIA street gang in Holyoke, Massachusetts and
surrounding communities.
4. One of the principal objectives of the above referenced in,:,estigation was to
develop current intelligence about the La Familia gang in Holyoke, to include, among other
things, the size of its membership, the identity of its current leadership, the scope of its members
and associates' illegal activities, and the manner in which they are organized and operate.
Toward this pursuit, investigators interviewed a large number of confldential human sources
(CHSs), reviewed law enforcement data base records, conferred with the Massachusetts
Department of Correction and Hampden County Sheriff's Department, examined documents
regarding telephones, automobiles, and real estate used by suspected gang members, and
conducted physical surveillance of individuals and locations in Holyoke and other surrounding
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coinmunities.
5. As stated above, investigators participating in the referenced
investigation interviewed numerous CHSs regarding the gang and its operations. These
individuals included current or former leaders, members and associates of La Familia who were
personally familiar with the gang, its operations, and its leaders. The information about La
Familia and its operations provided in the following paragraphs, represents a summary of
information provided by these individuals, by various CHSs, and information obtained from
other sources. The information provided by CHSs has been corroborated by comparing it to
information obtained from other sources, to include information provided by other law
enforcement sources, and from information developed from other sources during the course of
the investigation, to include consensually recorded conversations made during controlled
purchases of drug evidence. Information provided about La Familia described herein has also
been confIrmed through police records, by speaking with individuals who participated in the
events,' and by examirting prior gang intelligence.
6. In addition, the information provided by current and former members and
associates of La Familia was corroborated by subsequent developments in the investigation. As
an example, a CHS identified the Targets as La Familia members and associates involved in drug
and :f1rearms trafficking. The CHS, under the direction ofthe WMGTF, then made controlled
purchases of drugs and/or firearms from the Targets, who discussed other gang members and
gang activities during those purchases.
7. Investigations conducted by the WMGTF over the past decade have revealed that
the Massachusetts Chapter of La Familia, which includes Springfield and Holyoke Chapters, is a
street gang with dozens of members in Springfield, Holyoke, and other cities. La Familia
operates local chapters tbroughout the state and the Northeast region, including chapters inside
many correctional facilities. Many members of the gang are involved in a broad range of illegal
activities including drug trafficking and crimes of violence undertaken in furtherance of
protecting interests of the gang and its members.
8. La Familia is an organized Hispanic gang whose membership is primarily made up
of individuals of Puerto Rican descent. During the early 1970s, a loose-knit gang of teenagers
from Brooklyn, New York determined that in orderto protect themselves from gangs
operating in the same area, they would create a larger gang. The gang was named La Familia to
reflect their feeling of family. Over time other Hispanic groups were granted membership into
La Familia. The gang adopted the colors of the Puerto Rican Flag and the Five pointed star on
the flag to represent the gang. During the late 1970s and early 1980s, due to relocations, the
incarceration of members, and criminal activities which expanded territory, La Familia spread to
other areas of New York, Connecticut, and western Massachusetts. By the end of the 1980s, La
Familia had chapters throughout the Northeast.
9. During the 1990s, many members ofLa Familia who had served prison sentences
were being released from jail with a newfound appreciation for the need for organization to
ensure protection. The older members, or "godfathers" organized and recruited younger
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members frOIT). small neighborhood gangs into La Familia This included juveniles, called
"Mafilia," who were recruited by La Familia to conduct its illegal activities as a condition for
membership. As a result, the Holyoke and Springfield Chapters grew rapidly. Intelligence
indicated that the relationship between these Chapters was tepid but peaceful, with Holyoke
members of La Familia trafficking narcotics and firearms in Springfield, and vice versa. As time
passed, the two chapters merged into one and have co-existed peacefully.
1O. La Familia criminal activities included drug trafficking and the violence
associated with that activity, typicaily involving assaults with firearms. La Familia have often
fought the Massachusetts chapter of the Latin Kings over drug turf and perceived acts of
disrespect. Over the past ten years, numerous assaults and homicides have been connected to
this ongoing conflict, with members of each gang being indicted, arrested and convicted for such
offenses against the other gang.
11. During the past decade, the organizational structure of La Familia has changed
several times, due in large part to internal power struggles and the incarceration of significant
leaders and members. Notwithstanding changes in leadership over the years, the power has
remained centered on a small group of people who have promoted between La Familia
and the Latin Kings in Holyoke to further their own interests. La Familia leadership, known as
the "Overseer Table" has historically utilized gang members and associates in furtherance of
their criminal activities, particularly drug trafficking.
12. During the past decade, leaders and members of La Familia have been indicted
and arrested, and have served significant prison sentences. Prior to their incarceration, these
individuals capitalized on the ongoing conflict between La Familia and the Latin Kings, favoring
members who were the most violent, using them to instill fear in the gang, and in doing so,
supported their,own drug distribution. Subsequent to these indictments and arrests, lower ranking
La Familia members have taken leadership positions, and have continued in this activity,
including Target Francisco Diaz, AKA Franco.
13. The current leadership and senior members remain heavily involved in drug
distribution, supplying lower-ranking La Familia members and associates with drugs, to include
heroin. The territory, or "stronghold, II for La Familia, remains the south end of Holyoke.
14. During the first phase of the current investigation, the Holyoke Police Narcotics
Unit, supported by .the WMGTF, identified and targeted several heroin distribution points in
south Holyoke, to include 556 South Bridge Street, a four story multi-unit tenement building.
The HPD Narcotics Unit targeted the drug trafficking activity in those locations, employing
various investigative techniques, including physical and electronic surveillance, controlled
purchases of drug evidence, data base checks, field interviews and post arrest interrogations of
suspected drug customers, and search warrant execution. These techniques not only resulted in
numerous arrests, but they also resulted in the identification of an organized heroin distribution
operation directed by the current leaders and significant members of La Familia.
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,,15, During the second phase of the investigation, the WMGTF and HPD Narcotics
Unit, tasked sources in a position to make controlled purchases of drug evidence from mid-level
La Familia heroin dealers to make controlled purchases of heroin from those subjects. Sources
were also developed and tasked with making controlled purchases of drug evidence from certain
gang leaders. These controlled purchases of drug evidence resulted ill evidence of each subject's
individual drug distribution. Moreover, they assisted in identifying the modes of communication
utilized by the organization and drug trafficking organizations inside of Massachusetts and in
New York who supplied the gang with heroin.
16. Law enforcement documents from a previous investigation I have reviewed
demonstrated that Francisco Diaz, aka Franco, is the leader of La Familia. That iIivestigation
revealed an organized distribution operation directed by Diaz. That investigation confIrmed that
the distribution operation was centered in south Holyoke and supplied various points of
distribution throughout the city. These points of distribution were operated by La Familia
members and associates, including 556 South Bridge Street. The investigation revealed that
Diaz directed the operation, but kept an arm's length from day to day operations, leaving that
to trusted associates. .
17. During the course of this prior stage of the investigation, a source was able to
purchase a firearm from Diaz, and Diaz was arrested while in possession of two other firearms,
but sources were unable to make a controlled purchase of drug evidence directly from Diaz.
18. In February of2012, state indictments were sought and arrest warrants were
issued for 18 subjects for distribution of narcotics in violation of Massachusetts General Laws
Chapter 94 C. These individuals were identilled through the investigation asDiaz's inner circle
and most trusted associates. These arrests were based on controlled of drug evidence
from those subjects. Diaz was arrested for the above referenced controlled purchase of a frrearm,
, but was released on baiL '
19. The prosecution ofthese subjects (referenced immediately above) led to further
leads, to include cooperating witnesses who had admitted intimate knowledge of La Familia
Evidence obtained at this point corroborated evidence developed to that point which had
identified Diaz as not only the leader ofthe gang, but the leader and manager of the heroin
distribution operation. Additionally, information was developed which assisted in the
development of additional sources with access to Diaz' s newly established inner circle, which
included Antonio Caraballo, aka Pote, William Rodriguez, , aka Snoop, and
..
20. Information was developed which revealed that Diaz moved from outside of,
Holyoke to 556 South Bridge Street, Holyoke in order to take a more direct role in the heroin
distribution operation. It was at this time that 556 South Bridge Street doubled as the most
active distribution point for the organization and the organization's "headquarters".
21. The third phase of the investigation was'initiated after investigators developed a
source in a position to make controlled purchases' of drug evidence from various La Familia
members and associates who, were working for Diaz, to include the Targets, many of whom were
distributing heroin from 556 South Bridge Street Numerous controlled purchases were made
from the Targets. Over time, the source was able to make contact with Diaz and make controlled
purchases of larger quantities of heroin from Diaz. During controlled purchases with the
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Targets, it became clear to the CHS through hlslher conversation with Targets and observations
that Diaz ran the operation at 556 South Bridge Street, providing heroin to the other Targets, who
would distribute that heroin throughout the building. During these meetings the source observed
the same workers from whom he/she had made controlled purchases of drug evidence meet with
Diaz to deliver money from sales and obtain additional amounts ofheroin.
22. Between July 6f20l2 and March of 2013, a CHS was used to make controlled
purchase heroin and cocaine from members and associates of La Familia in Holyoke and
Springfield. The resulting federal indictments allege the following:
23. Francisco Diaz distributed heroin on five occasions. Diaz was charged twice in
2012 with separate state frrearms offenses, pled guilty to both of them on February 5, 2013, and
received concurrent three year state prison sentences on the same day which were stayed until
April 4, 2013.
24. Antonio Caraballo distributed heroin on five occasions. Caraballo was convicted
for distribution of heroin in Hamden County Superior Court on April 6, 2011 for which he
received a sentence of 2 years, 1 year committed with the balance suspended for two years and
he is on parole until January 31, 2014. He was released from jail only a few months prior to the
frrst deal with the CHS.
25. Miguel Alcazar distributed heroin on two occasions. Alcazar's criminal history
includes prior convictions for drug distribution.
26. _distributedheroin on one occasion. record
includes and assault and battery weapon. .
27. Miguel Medina distributed heroin on one occasion. Medina has been convicted,
in Springfield Federal Court, of a drug trafficking offense as well as the use of a frrearm in
furtheranc of a drug trafficking offense.
28. William Rodriguez distributed heroin on one occasion. Rodriguez's criminal
history includes. a state-court conviction for assault with a frrearm, for which he received a state
prison term.
29. Reynaldo Figueroa distributed cocaine base on one occasion, and possessed and
sold a firearm on another date. Figueroa's criminal history includes a conviction for
distribution of heroin for which he was .sentenced to four years in prison. During the course of
the investigation, the WMGTF received reliable information from multiple sources that
Reynaldo Figueroa, was involved in a drug related robbery of300 grams of cocaine. A CHS
was able to have conversation with Figueroa, during which Figueroa confrrmed that he was
involved in the robbery.
30. Luzander Montoya distributed heroin on three occasions. Montoya's criminal
history includes assault with a dangerous weapon and distribution of cocaine.
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31. During the above referenced meetings with Diaz, he [Diaz] boasted to the CHS
about running the heroin distribution operation, setting prices and determining which members
and associates of La Familia would be involved. During these meetings Diaz discussed with the
source an individual who owed him money, and his intent to collect on that debt, utilizing
violence if necessary. Diaz told the CHS about how he and other La Familia Gang members shot
at a Latin King Gang Member known as Killg Gambo. Diaz informed the CHS that Antonio
Caraballo had been arrested and how Diaz was paying for Caraballo's lawyer. Diaz informed the
CHS that the police were trying to put 15 guns on Caraballo and that the guns actually belonged
to Diaz. Near the end of the investigation, Diaz advised that he was going to jail for gun charges,
and went on to identify William Rodriguez, aka Snoop, as the person who would take over the
operation when he went to jail.
32. During the course of the above referenced prior investigation, investigators
learned that four La Familia members planned on fInding a member of the Latin Kings to shoot
him in retaliation for the shooting of a La Familia several months earlier. Investigators located
the vehicle in which the subjects were riding, conducted a motor vehicle stop and detained
known members of La Fanillia, one of whom was in possession ofa firearm. That subject was
arrested. On a separate occasion, investigators learned that members of La Familia associated
with Francisco Diazwere on their way to shoot a competing heroin distributor who was selling
heroin in La Familia territory, and undercutting the prices. Investigators were able to intercede
outside the residence ofthe competing heroin distributer. Several La Familia members were
detained. One such member ran, and during the course of the pursuit, his gun discharged. Two
subjects were arrested, one for possession of heroin, and the other for the possession of the
firearm.
33. Most recently, multiple CHSs. and law enforcement intelligence have corroborated
the ongoing and open war between La Familia and the Latin Killgs. Open-air shootings and
assaults between the rival gangs have been reported on a regular basis. Investigation of this
violence has been hampered by a lack of cooperation from witnesses, who are routinely
intimidated by the rival' gangs and who fear disclosure of cooperation with law enforcement.
During the course of the current investigation, there have been documented incidents of violence.
34. This concludes a summary of information I believe to be relevant to the pre-trial
detention of the Targets.
Mark S. Kaiangekis
Special Agent
Federal Bureau of Investigation
Dated: March 29, 2013
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