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Affidavit for Search Warrant
United States District Court
FOR THE
NORTHERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA
vs.
60 Plymouth Circle
Daly City, California
BEFORE U.S. MAGISTRATE OWEN E. WOODRUFF, 450 GOLDEN
GATE, SAN FRANCISCO, CA
The undersigned being duly sworn deposes and says:
That he has a reason to believe that (on the premises known as) 60 Plymouth Circle,
Daly City, California, a two story wood frame residence being light
grean in color with dark green trim and having the numerals 60
attached to the front of the residence to the left of the double
garage doors.
there is now being concealed certain property, namely
in the Northern District of California 1) Narcotics and narcotic para-
phernalia 2) Records and documents pertaining to narcotic transactions
3) All documents relating to cocaine trafficking 4) All proceeds includ-
ing monies, valuables and anything else believed to be the fruits of
narcotics trafficking.
which are the fruits and instruments of a violation
of 21 USC 841(a)(1)
And that the facts tending to establish the foregoing grounds for issurance of a Search Warrant
are as follows:
(SEE ATTACHED AFFIDAVIT)
AFFIDAVIT
I, Sandra C. Smith, having duly sworn, depose and state that I am a Special Agent
of the Drug Enforcement Administration, US Department of Justice, and have been
so employed for approximately 7 1/2 years. I am familiar with the facts as set
forth below due to my personal observations or the observations of other law
enforcement agents and officers who will have related
those circumstances to me.
1. The Drug Enforcement Administration has developed information over the
past several years that the MENESES Family has been involved in smuggling and
distribution of cocaine in the San Francisco Bay
area.
2. In April 1978, the FBI reported that Nowin and Ernest MENESES were smugg-
ling 20 kilos of cocaine at a time into the United States. The same report stated
that the cocaine was distributed in San Francisco
by Hymen MENESES.
3. In May of 1978, SR3780016 stated that Jaime MENESES received shipments of
cocaine approximately every two months.
4. In August 1978, Lauren LACAYO-VAISMAN was arrested in Panama City in
possession of one kilogram of cocaine. LACAYO stated that a Mr. MENESES financed
the smuggling venture.
5. New Orleans District Office of DEA in 1979 oonducted Operation Alligator in
which a number of persons were indicted for cocaine smuggling. "Operation
Alligator" resulted in the indicted of numerous persons for smuggling cocaine.
It was determined that Norwin MENESES was a source of supply for this group.
Manuel PORRO advised S/A Bill Cunningham that he had given Norwin MENESES money
for cocaine and that he had helped Norwin MENESES
smuggle cocaine.
6. In June 1980 the San Francisco District Office of DEA received a telephone
call from an identified individual who stated that cocaine seized from
Francisco LOBOS in Tampa, Florida, in February, 1980, was destined for Jaime
MENESES. This same caller stated that Jairo MENESES had gone to Costa Rica to
obtain approximately seven pounds of cocaine.
7. In June 1980, San Francisco Police Department arrested several individuals
including Omar Tony MENESES for the sale of cocaine in Donati's Bar, 5740 Mission
St., San Francisco. At that time, Donati's Bar was
owned by Jaime MENESES.
8. In July 1980, a search warrant was served on the residence occupied by
Roger MENESES at 171 Glenbrook Lane in San Bruno, which resulted in the seizure of
aproximately 20 pounds of cocaine and $8,817.00. Roger MENESES and Carolyn
CALDERA were arrested at that address. July 7, 1980, Omar Tony MENESES was
arrested by the San Bruno Police Department in possession of one-quarter pound of
cocaine which was found in his vehicle.
9. Carolyn CALDERA was arrested on May 5, 1977, at the Los Angeles Inter-
national Airport in possession of 3.6 pounds of cocaine that was being smuggled
into the United States from Peru. Roger MENESES was
on the same flight as CALDERA.
10. In August 1980, an anonymous caller telephoned the San Francisco District
office of DEA and advised that Norwin MENESES was the financier for the MENESES
Organization.
11. During the early part of June 1981, Detective Joseph Lee of the Baldwin
Park Police Department was contacted by a confidential informant who advised that
Julio BERMUDEZ of West Covina, California, is a large cocaine dealer that makes
two trips per month to the San Francisco Area where he contacts a large cocaine
smuggling organization headed by Norwin MENESES. The confidential informant
advised that BERMUDEZ picks up 14 to 20 pounds of
cocaine on each trip.
12. A second confidential informat corroborated the information supplied to
Detective Joseph Lee and stated that Julio BERMUDEZ places his order by telephone
prior to traveling to & San Francisco, California.
13. In October 1981, a search warrant was obtained for telephone toll calls
for telephone number (213) 338-5208, the residence of Julio BERMUDEZ. Telephone
number (213) 338-5208 is listed to Patricia BARRETO. These toll records indiciated
that during the months of August, September, and October 1981, 22 telephone calls,
15 telephone calls, and 14 telephone calls, respectively, were made to telephone
number (415) 992-5631, listed to Jairo MENESES at
60 Plymouth Circle, Daly City, CA.
14. In October 1981, surveillance was initiatad at 1128 Greendale St. in West
Covina, CA, by Baldwin Park Police, Los Angeles County Sheriff's Department and
United States Customs. On November 12, 1981, surveilling officers observed Julio
BERMUDEZ leave his residence at 1128 Greendale St. in West Covina, CA, with a small
beige suitcase, and enter a 1972 Buick, California license #389FAI. BERMUDEZ
subsequently picked up a passenger, Jose HERRERA, and the two individuals proceeded
to Los Angeles International Airport.
15. BERMUDEZ, carrying the above described suitcase, accompanied by HERRERA,
purchased two one-way tickets to San Francisco, CA on PSA Flight #425.
and HERRERA subsequently boarded Flight #425 and arrived at San Francisco Inter-
national Airport at approximately 3:40pm. They were observed by your affiant to
enter a 1979 gold Toyota bearing California license. #1AOA407 registered to Jose
HERRERA, 9303 Elm Vista Drive in Downey, CA. The Toyota driven by a Latin male
adult, proceeded to 8 Bellevue St. in Daly City,
CA.
16. At 4:10pm, Deputy John Austin observed BERMUDEZ exit 8 Bellevue in Daly
City and remove the small beige sitcase from the trunk of the Toyota and place
it behind the driver's seat. BERMUDEZ slowly drove the vehicle away from the
location, driving in a definite counter surveillance manner; i.e., recessive
speed, rapid lane changing, exiting and returning to the freeway, and U-Turns.
The vehicle was lost in the area of Freeway 280 and
Sneath Lane.
17. At approximately 4:45pm, your affiant located the vehicle parked in the
driveway at 60 Plymouth Circle, Daly City. This is the address of Jairo MENESES,
a known member of of the MENESES Organization and
known cocaine trafficker.
18. At approximately 6:35pm, BERMUDEZ, driving the gold Toyota, left 60
Plymouth Circle, in Daly City, and was surveilled back to 8 Bellevue in Daly City.
The gold Toyota was subsequently lost from view.
19. On November 16, 1981, your affiant was advised by Detective Joseph Lee that
Julio BERMUDEZ returned to his residence at 1128 Greendale St. in West Covina, CA,
at approximately 7:00pm, November 14, 1981. Shortly thereafter, a search warrant
was served on 1128 Greendale St. in West Covina, resulting in the seizure of
approximately three pounds of cocaine and $17,000. A ledger was also seized which
bore the entry "11-11-81 $90,000 to Jairo."
Sworn to and subscribed to by me on November 16,
1981, at San Francisco, CA.
Sandra Smith, Special Agent
11-16-81
Owen Woodruff
United States Magistrate
Northern District of California
11-16-81
5:00pm
United States District Court
FOR THE
NORTHERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA
vs.
60 Plymouth Circle
Daly City, Calif.
To Any Special Agent of the Drug Enforcement Administration or other
authorized person
Affidavit(s) having been made before me by S/A Sandra Smith
that he has reason to believe that on the premises known as 60 Plymouth Circle,
Daly City, California, a two story wood frame residence being light
green in color with dark green trim and having the numerals 60 attached
to the front of the residence to the left of the
double garage doors.
there is now being concealed certain property, namely
in the Northern District of California
1) Narcotics and narcotic para-
phernalia 2) Records and documents pertaining to narcotic transactions
3) All documents relating to cocaine trafficking 4) All proceeds
including monies, valuables and anything else believed to be the
fruits of narcotics trafficking.
and as I am satisfied that there is probable cause to believe that the property so described is being
concealed on the person or premises above described and that grounds for application for issuance of the
search warrant exist as stated in the supporting
affidavit(s).
You are hereby commanded to search within a period of 10 days
(not to exceed 10 days) the person or place named for the property specified, serving this warrant
and making the search [INFORMATION BLACKED OUT] and if the property be found
there to seize it, leaving a copy of this warrant and receipt for the property taken, and prepare a written
inventory of the property seized and promptly return this warrant and bring the property before
OWEN WOODRUFF as required by law.
Owen Woodruff
United States Magistrate
I received the attached search warrant November 16, 1981, and have executed it as
follows:
On November 16, 1981 at 6:45 o'clock PM, I searched the person or premises de-
scribed in the warrant and
I left a copy of the warrant with at the place of search
together with a receipt for the items seized.
The following is an inventory of property taken pursuant
to the warrant:
Miscellaneous papers, address books and photographs and passports
Smith & Wesson .22-cal. pistol, Serial #31827
Remington 12-guage shotgun, Serial #N404653V and ammunition
OHaus Triple Beam Balance
Plastic bag containg Thai sticks
Envelope containing $9,000.00
This inventory was made in the presence of
Saverio Weidl and Clark Edwards
I swear that this Inventory is a true and detailed account of all the property taken by me on the
warrant.
SANDRA C. SMITH
Subscribed and sworn to and returned before me this
24th day of November, 1981.
OWEN E. WOODRUFF
