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									NON-SEALED/PUBLIC

STATE OF MINNESOTA COUNTY OF RAMSEY

DISTRICT COURT SECONDWDICIAL DISTRICT
Court File No.: 62-CV -09-3113

TheCity of Saint Paul,Minnesota, and by through CityAttorney, its JOhFChfi, L

r::" c..

D
.AFFIDAVIT OF CRIMINAL

Plaintiff,

MAR 3 0 2009

GANG EXPERT SPPD

1y~~~..~ERGEANT
VS,

KEVIN MOORE

Sureno 13, a criminal gang, sued as an unincorporated association,

Defendant.

State of Minnesota
) SS.

Countyof Ramsey )
I, Kevin Moore, being first duly sworn, deposesand statesas follows: EXPERIENCE, EDUCATION, AND EXPERTISE REGARDING LATINO CRIMINAL GANGS AND THEIR MEMBERS

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I am employed as a Sergeantwith the City of Saint Paul Police Department ("SPPD"). I have been employed as a licensed, sworn peace officer for the SPPD for over 29
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I have been assignedto the SPPD's Gang Unit since its inception in 2005. I have been a gang investigator with the SPPDsince the mid 1990's. Within the Gang Unit, I overseeand am involved in the specialty area of Latino criminal gangs operating within Minnesota in general, and in Saint Paul in
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particular. I am a memberof the Midwest Gang Investigators Association. I have been a supervisor of the Gang ResistanceEducation and Training ("G.R.E.A.T"). G .R.E.A.T. is a nationally recognized gang prevention curriculum taught in elementaryand middle schools. I have also developedand presentednumerous training sessionsregarding Latino gangsto other law enforcementprofessionals, community groups, educatorsand professionalassociations.
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I am a court-qualified criminal gang expert, and I have testified in both Minnesota state and federal courts as a Latino criminal gang expert on numerousoccasions. My responsibilities as a police officer assignedto the SPPD's Gang Unit include investigating crimes committed in Saint Paul by criminal gangs suchas the Surefio 13 ("the Surefio"). My responsibilities as a police officer assignedto the SPPD's Gang Unit also Surefio. The intelligence I gather on thesecriminal gangs includes, but is not limited to, namesof the members of eachgang, methods of operationand communication, gang terminology, gang turf, gang rivalries, gang alliances, criminal histories of individual gangmembers,gang tattoos, gang graffiti, gang clothing and gang hand signs and symbols. c" c c'.,

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As part of my work as a Sergeantin the Criminal Gang Unit, I also identify and photograph active gang members,track gangmembers and their activities, carry my own caseloadof gang-relatedcrimes, work with other police officers in solving gang-related crimes, work with and assistthe probation and parole officers to ensure that gang members comply with their probation and parole conditions, and act as a liaison betweenthe SPPDand outside law enforcementagencieson gang related issues. I regularly come into contact with members,associates, affiliates, and rivals of the Sureiio criminal gang through traffic stops, pedestrianstops, consensual encounters,parole and probation compliance investigations, and during investigations of crimes involving gang membersas suspectsor victims. I obtain information about the Surefio and its activities by conducting custodial and non-custodial interviews with gang members,associates,and affiliates, rival gang members, members of the community, other SPPDofficers, other law enforcement representatives,and by reviewing police reports of gang-relatedand gang-involved incidents.
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SURENO 13 CRIMINAL 11
In the area known as

GANG STRUCTURE AND CRIMINAL ACTIVITIES
District del Sol located in Saint Paul's historic West Side , the

Surefio criminal gang maintain an active presence. 12. The Surefio is a nationally recognized, large criminal street ganghaving its origins in SouthernCalifornia. Sureno is a criminal gang organized for the primary purpose of enhancingand protecting its reputation as a formidable and dangerouscriminal gang through violence and intimidation.

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The membershipof the Surefio has significantly increased,as the gang has continued to expand its reachbeyond California. The Surefio criminal gang has had a documentedpresencein Minnesota for approximately the past ten years.Totne-b-egt-ofrnymuW the Surenocriminal gang IS not Incorporated or similarly registered with the Office of the Minnesota Secretaryof State.There are hundreds of active members of the Surefio in the Twin Cities, including Saint Paul, Since arriving in the Twin Cities the Surefio gang has beeninvolved in numerous documented incidents of violence typically directed at their traditional criminal gang rivals, the Latin Kings, Brown Pride, and 18th Street. The Surefio utilize an organizational structure, which includes gang memberswho are incarceratedand gang members on the street. Streetlevel operatorsalso known as "street soldiers" or "homies," are the primary perpetratorsof street-level crime and work at the direction of the "shot callers." The tenD "shot caller" refers to those gang members who assumepositions of leadership, typically through the commission of violent acts. The Surefto are organized by many different "subsets" or "cliques". These subsets or cliques will fight with each other and Surefto affiliation does not guaranteeany alliances betweenits subsets. The Surefio entrusts "shot callers" in its subsetsto locally managestreet-level operations, overseeingthe distribution of weapons,the sale of narcotics, the protection of the turf, the recruitment of new members,and the physical violence against rival criminal gangs. Typically, the newest, youngestSureiio gang recruits are called "street soldiers". The street soldiers are the most visible members of the Sureiio, yet they represent 3

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the bottom tier of the gangstructure. Street soldiers must commit crimes to prove their loyalty to the gang, to gain respect,and to move up in the structure. Membership in the Surefio often transcendsgenerations.Thus it is not unusual for a juvenile member to succeedto Surefio membershipheld by his/her parents, or even grandparents.
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The Surefio measuresits successes a criminal gang based on severalfactors, the as most important of which are enhancingand protecting its reputation as being the most formidable and dangerousLatino criminal gang. Integral to the Surefio objective to enhanceits reputation is to assertclaims to "turf'. When a criminal street gang "claims turf," it means that the gang intends to exclusively occupy a given geographic area for its gang related activity. Unlike many other criminal gangs,the Surefios' claims to turf are not limited to specific geographic areas. Instead,the "turf' claimed by the Surefio is typically this reason,the criminal activities continuously and regularly engagedin by the Surefio encompassa wide geographic area that transcendsborders of neighborhoods and cities.

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Among the primary activities engagedin by the Surefio in order to define and defend "its turf' and protect its reputation, are the commissionof the types of predicate crimes described in Minn. Stat. §609.11, Subd. 9, including but not limited to: first, secondand third degreeassaults,aggravatedand simple robberies, riot, drive by shootings, possessionor other unlawful use of a firearm, and narcotics trafficking. It is typically the intent of a member of the Surefio that his or her individual crime, irrespective of its nature, serve to benefit the Surefio as an organization. In furtherance of these primary criminal activities, the Surefio are often armed with firearms, knives, baseballbats, and other dangerousweapons,so as to be prepared to engage in "war" with rival gang members or people they perceive are rivals.

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The Sureiio criminal gang must, at all costs, enhanceits reputation as a formidable and dangerouscriminal gang (by engaging in such activities as loitering in public places in menacing numberswearing colors, gang symbols, and tattoos, act like they own the area, and commit graffiti vandalism againstpublic and private property) and defend it (by committing acts of violence againstrivals and perceived rivals within the turf area, carry weapons, and frighten and intimidate residents and merchants from interfering with or reporting their crimes).
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The Surefio criminal gang members regularly exerts its control to "its turf' by accostingpeople on the street, at MTC bus stops, on the bus, or wherever-and often demandingto know, "who do you claim?" (which means,"what gang do you belong to?") If the person accostedhappensto be wearing clothing or clothing reflecting a rival criminal gang's colors and/or symbols, the personwill likely be physically or verbally attacked or assaulted. 26. Beatings, assaultsand robberies committed by the Sureiio are frequently not reported to the police becausethe victims are too scaredto come forward -fear of retribution, fear of authorities. Suspectsare not identified, arrestsare not made, and the crimes are not punished, giving the Sureiio gang members an unjustified senseof invincibility, which tends to reinforce the notion in the community that the Sureiio criminal streetgang is in control of its territory. The Surefio often rob criminal gang rivals. The cashand other valuable taken by e ureno crimina gang mem ers uring esero eries a so ene 1 s e individual gang member and is used by the Surefio to buy narcotics and weapons, and to help out other gang members in need of cash. Commission of the robbery itself further gives the gang member a higher status within his own gang. In the Latino gang culture, including the Surefio criminal gang, committing an act of violence such as robbery or assault,is called "putting in work." In addition to being a source of income for the Surefio criminal gang, committing streetrobberies of criminal gang rivals also helps the Surefio gang createand perpetuatea climate of fear and intimidation among its gang rivals and the general public. The Surefio seekto perpetuatean environment of fear in an attempt to dominate and control "its turf." The Sureiio criminal gang memberswill usually commit their robberies as a gang, allowing some to shake down the victim, while others act as lookouts. Their "strength in numbers" also minimizes the likelihood that the victim will resist or fight back. Typically the Surefio criminal gang robbers will let the victim know that he is being robbed by members of the Surefio-showing tattoos, wearing colors, identifying themselvesby their local monikers. Many of the robberies that occur by the Surefio criminal gang membersare not reported becausethe victims are too afraid of retaliatory action by the gang and often becausethe victim was illegally trafficking in narcotics. In addition, many of the victims are recentimmigrants who are monolingual Spanishspeakersreluctant
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to come forward. It is for this reasonthat many of the crimes committed by the Sureiio are unreported. COMMON SIGNS, SYMBOLS, COLORS AND CLOTffiNG SURENO 13 CRIMINAL GANG USED BY THE

The Surefio criminal gang prominently use common signs, symbols, colors and clothing to overtly identify their criminal gang affiliation and allegiance. 33. The Surefio criminal gang use combinations of blue and gray or blue and white as their common gang "colors." The Surefio members identify themselvesto each other and to gang rivals when they wear blue and gray or blue and white colored clothing and accessorieslike belts, hats, shoesand bandannas. Additionally, baseball hats and clothing showcasingsports teams such asthe Los Angeles Dodgers are symbolically linked to the Surefio. It is common, within the District colored clothing and accessories as to publicly identify themselvesas members so of the Surefio. Other common gang identifying symbols and signs purposefully and overtly displayed by the Surefio include clothing, accessoriesand tattoos representingthe number "13". The Surefio criminal gang representswith the number 13 to show their allegiance to the Mexican Mafia (AKA: "La eMe"). The number 13 is very significant in Mexican Mafia lore. The letter "M" is the 13th letter of the English alphabetand there is documentedintelligence out of the California Department of Corrections that there were 13 original members that createdthe Mexican Mafia. The 13thmember was JosephRadisch Morgan (AKA: "Peg Leg" Morgan). Morgan is known as the Godfather of the Mexican Mafia. The Surefio criminal gang will represent"13" in various forms and ways, including, but not limited to Roman numerals (XII, X3), "Trece", Sur 13, Sur Trece, and a combination of Mayan bars and dots. It is common, within the District del Sol to seethe Surefio criminal gang members purposefully wearing colored clothing and accessories,or and overtly displaying tattoos, bearing such symbols and signs so as to publicly identify themselvesas membersof the Surefio.

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Attached hereto as Exhibit "A" are photographic examplesof the clothing, accessoriesand tattoos worn and displayed by the Surefio criminal gang members as described above. COMMON HAND SIGNS USED BY THE SURENO 13 CRIMINAL
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The Surefio criminal gang membersalso use hand signs to non-verbally identify themselvesto each other, to mark their turf vis-a-vis other gang rivals, and to communicate with eachother. When a criminal gang memberuseshand signs, it is often called "throwing" or "flashing" gang signs.
The hand signs used by the Surefio gang members often reflect the number "13", or variations thereon, including but not limited to forming by hand the 13thletter of the alphabet "M".

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Hand signs are used by the Surefio gang membersto discreetlycommunicate their gang affiliation to each other, and are also frequently and overtly used against criminal gang rivals, or perceived rivals. It is common to seethe Surefio gang members purposefully and overtly "throw" or '~flash" gang signs within the

Attached hereto as Exhibit "B" are photographic examplesof the Surefio gang members "throwing" and "flashing" gang signs as describedabove. COMMON GRAFFITI USED BY THE SURENO 13 CRIMINAL GANG

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The Surefio criminal gang further publicly identifies itself and "its turf' by committing graffiti vandalism againstpublic and private property. The Surefio criminal gang uses graffiti to literally mark its territory and demonstrateits claim thereto. It is intended to serve as constantand public reminder to both the neighborhood and criminal gang rivals, that the Surefio "claims" the area. In Latino criminal gang culture, gang graffiti is known as the "newspaperof the street." It is a way of communicating messagesfrom one gang memberto another, as well as to a gang's rivals. Gang graffiti is frequently used by criminal gangs, such as the Surefio, to communicate threats to rival gangs. Other criminal gang graffiti may be perpetratedby rival gangs,to show disrespect to the Surefio. For example, criminal gang rivals of the Surefio will often cross out the Surefio graffiti, and write their own graffiti over or above the Sureiio graffiti. "Cross outs" are purposeful and public act of disrespectagainsta criminal gang for which retribution by the "disrespected" gang is likely.
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Moreover, homeowners,merchantsand ordinary citizens are often afraid to paint over the graffiti becauseof fear that criminal gangs such as the Surefio,will retaliate againstthem. It is common to seethe Surefio graffiti within the District del Sol. Attached hereto as Exhibit "c" are photographic examples of Sureno gang graffiti as described above within the District del Sol. SURENO 13 CRIMINAL GANG RECRlliTING AND DISCIPLINE

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The Surefio criminal gang and enhancesand protects its reputation by steadfastly maintaining as large a membershipaspossible. Inevitably, becauseof its criminal activities, its membersare going to frequently cycle in and out of jail and prison. Thus, in order to survive, the gang must maintain its existing members,recruit new by exercising severepunishments and discipline for acting againstthe interestsof the gang. The more membersthe Surefio criminal gang has, the more territory it can cover. The more turf it can occupy and defend, the more powerful the gangbecomes. An individual canbecome a member of the Surefio criminal gang in one of three ways: (1) for male members, by being ')umped" into the gang, which meansbeing beaten up by existing members, for 13 seconds;(2) for female membersby being "sexed in" which requires being sexuallyassaultedby a group of male Surefio gang members; (3) by committing crimes in association, at the direction of, or for the benefit of the gang; or (4) by being sponsoredinto the gang by a family member who is already an active gang member. 51 Existing Surefio criminal gang members generally remain in the gang becauseit is difficult, if not impossible to get out of the gang without fear of violent reprisal. Thus, the Latino criminal gang motto -"blood in, blood out". The Surefio criminal gang benefits from recruiting at an early age. Having gang members enter the gang at a young age,helps promotes loyalty among the gang which in turn helps maintain the viability of the gang. Most of the recruiting undertaken by the Surefio criminal gang is directed towards middle and high school age persons. Members of the Surefio criminal gang will severely punish other Surefio criminal 8

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gang members for acting againstthe interests of the gang, including dropping out of the gang. 54. Punishment for such actions may take the form of shooting, stabbing, beating the gang member or a member of his family, or destructionof the member's property. In criminal gangvernacular, this is called "being violated". CINCO DE MAYO AND THE SAFETY ZONE 55 The Cinco De Mayo Festival ("Cinco") is a celebration-inthe Latino community with rich cultural significance and is annually celebratedduring the first weekend of May. Cinco is held in the District del Sol, and attracts a very large and culturally diverse crowd. The actual sanctione v
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north; Ohio Streetto the west; Barge Channel Road to the eastand Sidney Streetto the south. 57 BecauseCinco is such a heavily attendedevent, and the neighborhoods surrounding the event are also denselypopulated, the effective event areaof Cinco must extend many blocks in all directions from the actual site of Cinco events as parking and traffic congestion directly related to Cinco affect the entire District del Sol. This areais more particularly depicted on Exhibit "D" attachedhereto, and hereinafter referred to as the "Safety Zone." My experienceduring past Cincos, has shown that the Surefio criminal gang uses the event as on opportunity to increasethe quantity of its violent gang activities including shootings and assaults,throughout the SafetyZone. The Sureiio is among the most actively aggressiveand violent criminal gangs in the SafetyZone during Cinco. During the 2008 Cinco, the Sureiio were responsible for a shooting in which an individual was seriously wounded and numerous incidents of assaultand disorderly conduct. Based on past personalexperience, I know that the Surefio criminal gang has attended Cinco in large groups, prominently and purposefully wearing clothing that displays Surefio gang colors and gang symbols throughout the SafetyZone. Additionally, I have also observedmembersof the Surefio criminal gang "throwing" or "flashing" criminal gang signs throughout the Safety Zone during 9

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past Cincos.

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Based on my past personalexperience,I also know that the Surefio criminal gang has been involved in assaultsat past Cincos that were startedas a consequenceof the Surefio gang membersencounteringrival gang members. Based on my past personalexperience,I also know that during pastCincos, Surefio gang membershave been in possessionof a variety of dangerousweapons, including firearms and knives, while attending the festival, and somehave also reported having accessto weaponsin vehicles parked well beyond the areaswhere the actual event is held. TheseSurefio criminal gangmembersare armed to defend themselves againstrivals that they anticipate encountering at Cinco. While Surefio gang memberscommit their above-described criminal gang activities both within, and outside of the Safety Zone throughoutthe year, such actIvItIes ecome partIcu ar y pro ematIc unng InCO ecause0 t e IncreaseIn the volume and severity of suchcriminal gang activities and the heightened risk to innocent bystandersbecauseof the large number of visitors attending Cinco. The Surefio criminal gang does not limit its commission of Cinco-related criminal gang activities to the event itself. The Surefio uses the weeks and days preceding Cinco to threaten its criminal gang rivals. The Surefio also uses the weeks and days following Cinco to settle scores with its criminal gang rivals arising from incidents that occurred during the event. Based on my personal pastexperiencewith the Surefio criminal gang, the Surefios' use of Cinco as an eventto brazenlyand violently displayits strengthis purposeful. First and foremost, suchdisplaysby the Surefio during Cinco are intendedto enhanceits violent and powerful reputationto both the generalpublic and its criminal gangrivals. Additionally, such behavior by the Surefioduring Cinco also servesas strongcriminal gangrecruiting tool as it seeksto increaseits ranks among impressionableyouth who are in attendance. Strong showingsof force and criminal activities by the Surefio at Cinco also has the chilling effect of reminding existing gang memberswhat typesof reprisals await thosewho may wish to leave the gang. The criminal activities engagedin by the Surefio both outsideof, and within the SafetyZone during the pasttwelve months are predictive as to how the Surefio is likely to behaveduring the upcomingCinco. There is every reason believe that to the Surefio will attemptto similarly taint the upcoming 2009 Cinco with its criminal activities. 10

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The Surefio also attempts to further its objectives during Cinco by publicly and brazenly engaging in the following activities within the Safety Zone: 1) wearing gang colors; 2) flashing gang signs; 3) accosting people, often demanding to know "who do you claim?" or "what gang are you with?"; 4) obstructing free passage of public streets and sidewalks; 5) exercising verbal and physical harassment of criminal gang rivals and innocent bystanders; 6) trespassing on private property; 7) committing graffiti vandalism to mark territory; and 8) increasing their membership by recruiting youth from the

neighborhood.
69. The paramount objective of the SPPDis to ensurethe security and safety of every one 0 e tens 0 t ousan 0 personsW 0 WI e In e a ety one unng Cinco. Becauseof the large numberof people attending Cinco, anyundertakingby the Surefio of criminal activities in the SafetyZone of the type they have previously committed in the past 12 months,will pose a significant risk to personsand property. Abating the public nuisancecausedby the Surefio within the SafetyZone during Cinco is a necessary stepto allow the SPPDto fulfill its objective. The Safety Zone is reasonablein scopeand size. The SafetyZone representsthe area of the District del Sol that has been hit the hardestand has beenthe most negatively affected by the public nuisancecausedby the Surenocriminal gang's criminal activities during Cinco. Although the Surefio criminal gang continuously and regularly conducts its criminal gang activities beyond the SafetyZone, into other areasof Saint Paul, the Safety Zone does not seekto impose injunctive provisions to everyplace the Surefio criminal gang operates,only the specific area that has beenhit the hardest during Cinco. The scope and size of the SafetyZone is reasonablein size and scope in that it lies entirely within the SPPD Central District, allowing the SPPDto enforce the injunctive provisions with unifonnity and continuity. The scope and size of the SafetyZone is made even more reasonable becausenone of the ten criminal gang membersof the Surefio who will be subjectto the proposed injunctive relief soughtby the City, actually reside within the boundaries of the Safety Zone.

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According to the organizers ofCinco, the duration of the event is between 5:00 P.M. (C.D.T.) on May 1, 2009 to 6:00 P.M. (C.D.T.) on May 2,2009. The duration of the proposed injunctive relief sought by the City is between4:00 P.M. (C.D.T.) on May 1,2009 to 6:00 A.M. (C.D.T.) on May 3,2009. This period is intended to only cover the event itself and the period of time it takes for all of the attendees,including members of Surefio to reasonablyand safelydispersefrom the Safety Zone. My personal past experiencewith the Surefio criminal gang at Cinco, is that even though the event itself is completed,the Surefio will remain in the SafetyZone either on public streetsand sidewalks, private housesor taverns for many hours after the event seeking opportunities to confront its criminal gang rivals. The Surefio will also often use thesehours following the conclusion of Cinco to conduct its criminal activities, including seeking physical confrontation with its criminal gang rivals.

quality of life, health and safety of the residents,merchantsand visitors within the SafetyZone. It is my opinion, that enjoining the Surefio and its below named members from engaging in the conduct set forth in the proposed Order filed with the Court by the City is the only civil law remedy that can effectively abate this nuisance. INDIVIDUAL 76. SURENO 13 CRIMINAL GANG MEMBERS

When determining whether an individual is a member, affiliate, or associateof the Sur.efiocriminal gang, I look at the totality of several factors, including selfadmission, criminal history, associationwith known members of the Surefio criminal gang, gang clothing or symbols, gang tattoos, photographs,monikers, location where individual has been contacted by law enforcement(i.e. home turf, or rival turt), gang writings or letters sent or received, graffiti, information from other law enforcementagencies,confidential informants, school personneland records, parentsand other relatives, etc. These standardsare also used by law enforcementagenciesthroughout Minnesota. One of the most important factors I consider when determining whether someone is a member, affiliate, or associateof the Surefio criminal gang is self-admission during a police investigation where the individual is a suspect,victim or witness. However, it is not uncommon for an individual who is suspectedof being an active member of the Sureno,to deny his/her membership when so askedby law enforcementprofessionals. For this reason, an individual who meets many of the other indicia of gang membership, does not warrant being deemedto not be a
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member of the Surefio, based solely on his/her denial of suchmembership. 78. Another factor I consider when determining if someoneis a member, affiliate, or associateof the Surefio criminal gang, is the person's prior criminal history records. I review the record to seewhat type of crimes he or she was arrestedfor, where the crime was committed, and who else, if anyone,was arrested with him or her. I also considerthe person's associationwith other known gang members. Association is a considerable factor becausegang memberswill associatewith other gang membersbecausethey trust the other gang members. If a personis seenhanging around with known Surefio gang members in territory claimed by the Surefio gang, that is a factor in determining if they are also a member, affiliate or associateof the Surefio gang. If the personalso doesn't live in the neighborhood, that only makesthe associationmore compelling. When police officers seea
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contact to document that the personwas seen,who they were seenwith, where they were seen,and what they were doing when they were seen. 80. I also consider whether the personhas any Sureno gang tattoos. A Sureno gang tattoo is a life commitment to the Sureiio criminal gang, and is very strong evidence of membership,affiliation, or association. Even if the tattoo is removed, the scarremains. I also consider whether the personwears gang-associated clothing or accessories. Obviously, wearing clothing bearing the Surefios' colors and symbols doesn't automatically mean that they are a member of the Surefio. However, such clothing when coupled with some of the other factors discussedherein, such as association with other known members of the Surefio,is often very compelling evidence of gang membership. I also consider whether the personis depicted in any gang or "party" photos, with other known members of the Surefio gang, flashing Surefio gang signs, showing gang tattoos, and/orbrandishing weapons. It is very common for members of the Surefio gang to pose for, keep, and display "party" photos, evidencing pride in their gang membership,affiliation, or association. 83. I also consider any writings, suchas written communications exchangedbetween the person and known gang members. Additionally, the Minnesota Gang Strike Force ("MGSF") was created in 1997 by
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the State of Minnesota to do among other things, assistlocal law enforcement agencies in identifying active criminal gang members. The MGSF and the Minnesota Bureau of Criminal Apprehensionmaintain a Minnesota State Pointer Systemthat identifies and tracks confirmed criminal gang members.In addition to meeting other requirements,a personmust meet at leastthree (3) often (10) specific criteria (the "MGSF criteria") before he/shecan be enteredinto the State Pointer systemas a confinned criminal gang member. 85. I have been askedto offer an opinion as to whether certain namedindividuals are members, of the Surefio, as discussedbelow. The below namedindividuals represent the members of the Surefio who are among the most active and influential members in the Surefio criminal gang activities within Saint Paul. Because of their influence within the Surefio organization, these individuals pose the greatest threat of organizing and/or leading the Surefio's collective criminal gang activities during Cinco. Accompanying my opinion for each of and documents I have relied on to form my opinions.

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Salatiel Nicolas Hernandez-Patino (DOB: 01/26/1991 or 01/20/1991); A\K\A: "Chucky": Based on my professional experienceworking in the SPPD Gang Unit investigating Latino gangs in general, and the Surefio in particular, including my consideration of the above-describedfactors, my review of any data maintained pursuant to Minn. Stat. §299C.091 on the Minnesota Criminal Gang Investigative Data System,including Mr. Hernandez-Patinohaving met at least six (6) of the ten (10) point MGSF criteria, and my review of the below-referencedComplaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I use and rely upon in the regular and ordinary course of my assignment as a Sergeantwith the SPPDGang Unit; it is my opinion that Mr. HernandezPatino ("Hernandez-Patino") is an active memberof the Surefio criminal gang. A

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Heriberto Lopez (DOB: 12/23/1990); A\K\A: "Lil' Cuete": Based on my professional experienceworking in the SPPD Gang Unit investigating Latino gangs in general, and the Surefio in particular, including my considerationof the above-describedfactors, my review of any data maintained pursuantto Minn. Stat.
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§299C.091 on the Minnesota Criminal Gang Investigative Data System,including Mr. Lopez having met at least six (6) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I use and rely upon in the regular and ordinary course of my assignmentas a Sergeantwith the SPPD Gang Unit; it is my opinion that Mr. Lopez ("Lopez") is an active member of the Sureno criminal gang.

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Ivann Alexander Valencia (DOB: 03/09/1991); A\K\A: "Sniper"; "111 Sniper": Based on my professional experience working in the SPPDGang Unit investigating Latino gangs in general, and the Surefio in particular, including my consideration of the above-describedfactors, my review of any data maintained pursuant to Minn. Stat. §299C.09l on the Minnesota Criminal Gang Investigative Data System,including Mr. Valencia having met at least seven(7) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I use and rely upon in the regular and ordinary course of my assignmentas a Sergeantwith the SPPD Gang Unit; it is my opinion that Mr. Valencia ("Valencia") is an active member of the Surefio criminal gang.

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Juan Quintero Jr. (DOB: 06/11/1989); A\K\A "Big Happy": Based on my professional experienceworking in the SPPDGang Unit investigating Latino gangs in general, and the Surefio in particular, including my considerationof the above-describedfactors, my review of any data maintained pursuantto Minn. Stat. §299C.091 on the Minnesota Criminal Gang Investigative Data System,including Mr. Quintero having met at least six (6) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I useand rely upon in the regular and ordinary courseof my assignmentas a Sergeantwith the SPPD Gang Unit; it is my opinion that Mr. Quintero ("Quintero") is an active member of the Surefio criminal gang.

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Luis Fernando Gaytan (DOH: 04/04/1990) A\K\A "Chukklez"; "Lg": Based on my professional experienceworking in the SPPDGang Unit investigating Latino gangs in general, and the Surefio in particular, including my consideration of the above-describedfactors, my review of any data maintained pursuantto Minn. Stat. §299C.091 on the Minnesota Criminal Gang Investigative Data System,including Mr. Gaytan having met at least three (3) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers "CN" and other olice contact information maintained b the SPPD; all of which I use and rely upon in the regular and ordinary course of my assignmentas a Sergeantwith the SPPDGang Unit; it is my opinion that Mr. Gaytan ("Gaytan") is an active member of the Surefio criminal gang.

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Jesus Jacobo (DOB: 10/21/1989)A\K\A: "Jesse": Based on my professional experienceworking in the SPPDGang Unit investigating Latino gangs in general, and the Surefio in particular, including my considerationof the above-described factors, my review of any datamaintained pursuantto Minn. Stat. §299C.O91on the Minnesota Criminal Gang Investigative Data System,including Mr. Jacobo
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having met at least six (6) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I use and rely upon in the regular and ordinary courseof my assignmentas a Sergeantwith the SPPDGang Unit; it is my opinion that Mr. Jacobo ("Jacobo") is an active member of the Sureno criminal gang.

94

Jorge Luis Vargas (DOB: 03/11/1988); A\K\A :"Loner": Based on my professional experienceworking in the SPPDGang Unit investigating Latino gangs in general, and the Surefio in particular, including my considerationof the above-describedfactors, my review of any data maintained pursuantto Minn. Stat. §299C.091 on the Minnesota Criminal Gang Investigative Data System,including Mr. Vargas having met at least six (6) of the ten (10) point MGSF criteria, and my review of the below-referenced Complaint Numbers ("CN") and other police contact information maintained by the SPPD; all of which I use and rely upon in the regular and ordinary course of my assignmentas a Sergeantwith the SPPD Gang Unit; it is my opinion that Mr. Vargas ("Vargas") is anactive member of the Surefio criminal gang.

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FURTHER YOUR AFFIANT SAYETH NOT.

.",::~/ 9:'"~--Kevin Moore Sergeant,Saint Paul Police Department Subscribedand sworn to before me on this 23rd day of March, 2009.

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"

Cj{,.;:~ '1 ~~:-.. -c-

II 81~~~.5

,)

I

EXHIBIT C


								
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