IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS
COUNTY OF LOS SANTOS
LOS SANTOS COUNTY SHERIFF's DEPARTMENT,
Petitioner and Appellant,
v.
VARRIO SOUTH SIDE 38TH STREET GANG,
Respondent.
Superior Court Case No. 25-LSC-04113
PETITION FOR CIVIL GANG INJUNCTION
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LOS SANTOS COUNTY SHEIRFF'S DEPARTMENT
*Alexander C. Braithwaite IV, State Bar No. 00000
[email protected]
1886 Hopkins Ave, 2nd Floor
Los Santos, San Andreas
272-3544
Attorney for Plaintiff THE PEOPLE OF THE STATE OF SAN ANDREAS
Petitioner LOS SANTOS COUNTY SHERIFF'S DEPARTMENT
TABLE OF CONTENTS
I. INTRODUCTION.............................................................................................................
II. JURISDICTION................................................................................................................
III. GANG OVERVIEW.........................................................................................................
A. Summary of Facts...................................................................................................
1. Rise in Gang Activity.....................................................................................
2. Critical Incidents...........................................................................
IV. CRIMINAL PATTERN & PUBLIC SAFETY IMPACT .................................................
V. PRAYER FOR INJUNCTIVE RELIEF............................................................................
A. KNOWN MEMBERS (as documented in SanGang).............................................
B. SAFETY ZONE (Injunction Area)
VI. CONCLUSION..................................................................................................................
I. INTRODUCTION
ᅠᅠ I, JERMAINE LOVELL, being duly sworn, declare that I am a Captain and the Unit Commander of the Operation Safe Streets Bureau within the Los Santos County Sheriff's Department I have been with the Los Santos Police Department for over 30 years, with 25 of them being dedicated to the bureau.
ᅠᅠ I submit this affidavit in support of a Gang Injunction against Varrio Southside 38th Street Gang (38ST), a criminal street gang operating primarily in El Corona area of Los Santos, San Andreas. This affidavit is based on my personal knowledge, training, experience, and information provided to me by other law enforcement officers and investigators involved in this investigation.
ᅠᅠ The requested injunction is necessary to disrupt 38ST's criminal activities, prevent further violence, and restore safety to the affected neighborhoods. Without court intervention, 38ST will continue to terrorize the community, perpetuate violence, and expand their criminal operations.
ᅠᅠ This injunction is necessary to disrupt the gang's operations, prevent further violence, and restore safety to the affected neighborhoods.
II. JURISDICTION
ᅠᅠ This Court has jurisdiction over this matter pursuant to the laws of San Andreas governing public nuisance abatement and gang injunctions. The criminal activities of Varrio South Side 38th Street gang described in this affidavit have occurred within the City of Los Santos, San Andreas, placing this matter squarely within the Court's jurisdiction.
III. STATEMENT OF THE CASE
ᅠᅠ A. Summary of Facts.
ᅠᅠ Varrio South Side 38th Street Gang is a documented Sureno gang operating primarily in the El Corona area of Los Santos. 38ST has been operating for years within the area and has been infamous with it's criminal activities and overall disturbance and volatile response to whomever attempts to stop their tracks.
ᅠᅠ Intelligence gathered by multiple Law Enforcement agencies and shared on the SanGang suggests that the 38th Street Gang's been involved in a series of hostile interactions between multiple local street gangs around their areas, such as the 59 & Harlow Blood gang and law enforcement in general.
ᅠᅠ The 38ST gang maintains a strong presence in several key locations within El Corona, including:
28th Street Dead-End
El Corona Village Projects
38th Street
Kings Avenue
Newport Boulevard
Imperial Avenue
2. Critical Incidents
ᅠᅠ There were several critical incidents involving members of the 38ST gang that demonstrate the escalating danger posed by this criminal organization:
May 24th, 2025 - 28th Street Massacre
ᅠᅠ At approximately 16:00 hours, Detective Sergeant Ivan Moncada, of the Operation Safe Streets Detail, was conducting surveillance over the 28th Street Dead-End area where he came up with a conclusion of a slight altercation between 38ST members among themselves. While taking multiple photographs of the members and the altercation for documentation, 38th Street Member Alvaro Colon pulled out a Glock 17 and started opening fire on a male within the area. Upon seeing this, DET. SGT. Moncada called in for assistance to save what could be saved of the male. Sheriff Deputies rolled into the area with force, ordered the 38th Street Members to raise their hands and surrender, which they didn't do.
Instead of complying, an array of 38th Street Gang members brandished their handguns and open fire directly at the deputies, striking down three sworn deputies of the Los Santos County Sheriff's Department and proceeded to evade in separate ways from the crime scene. Detectives followed up on the killings and drew conclusions and submitted a series of warrants on the killers after reviewing dashcam footage and Sergeant Moncada's photographs. The deceased Hispanic male was later identified as a Carlos Barone and was pronounced dead at the hospital.
June 1, 2025 - LSPD Attempted Murder
LSSD deputies responded to a LSPD detective in distress on Artesia around midnight. Deputies came to see that the LSPD Detective was heavily wounded by multiple GSWs and his vehicle was riddled in shotgun shells and 9mm bullets. Deputies called the Fire Department which transported LSPD GND Detective Nathan Watts to the nearest hospital. OSS Detective Ivan Moncada picked up the case and reviewed the DCIV footage from the LSPD Unmarked vehicle. Coupled with the DICV footage, Detective Moncada picked up the statements detective Watts as well as bystanders whom observed the scene unfold. DCIV footage showed three well registered 38ST gang members chasing down detective Watts after he turned his sirens on when seeing them staging to hit a rival gang.
June 2, 2025 - Riot activities
On the first of June, 2025 morning, multiple 38 ST gang members torched up an array of LSSD Vehicles, flipped them over, and spray painted all over the vehicles leaving the morning shift deputies helpless. They also ganged up on Deputy Marcus Schafer and started to beat him up violently till he lost connection to reality. Deputy Schafer was treated by hospital staff at ASGH but 38ST's acts of terrorism remains unarmed.
June 2, 2025 - Warrant execution and shots fired.
On the second of June, 2025 around half past midnight. LSSD OSSB and SEB Personnel moved out to execute an array of search warrants within the area of El Corona. Upon their arrival they were met by a four door filled with 38ST affiliates, one of the passengers was suspected in the LSPD Attempted murder on a detective scene. SEB responded and extracted the male out of the vehicle, while doing so, one of the female passengers in 38ST Tattoos opened fire at deputies, striking one in his armored plate. The female dropped to the ground after deputies opened fire back, she was identified as a 38ST Gang member thanks to her tattoos.
June 5th, 2025 - HRAW Execution, shots fired and barricaded situation.
While SEB and OSSB move out in attempts to catch the suspects involved in the LSPD Detective case. The primary suspect was stopped at at felony stop, he proceeded to evade using his vehicle. The passenger leaned out and opened fire at deputies in the pursuit line using an automatic weapon. Deputies returned fire and later striking the shooter down, whom was confirmed to be a 38ST gang member. The primary suspect barricaded themselves inside an apartment in El Corona, to which SEB responded and extracted the subject from the apartments, he was found with a semi-automatic pistol on him.
A second suspect which was also an HRAW in the attempted murder of detective Watts was later stopped by SEB vehicles. The suspect evaded using his vehicle and he was later stopped by SEB once again. The suspect got out of the vehicle and surrendered to LSSD with a semi-automatic pistol on his body.
IV. CRIMINAL PATTER & PUBLIC SAFETY IMPACT
ᅠᅠ The Varrio South Side 38th Street Gang have established a clear pattern of criminal activity that poses a significant threat to public safety in the El Corona area and beyond. Their criminal enterprises include:
Narcotics Trafficking: Intelligence gathered by LSSD indicates 38ST is heavily involved in the distribution of controlled substances throughout their territory
Illegal Firearms Possession: Multiple incidents documented in this affidavit demonstrate 38ST members routinely carry and use firearms, ranging from Glock 17 handguns to fully automatic assault rifles and militarized weapons.
Homicide: In this affidavit multiple homicides were already mentioned that were ruled out by various members of the South Side 38th Street gang including
May 23th - Carlos Barone & 3 Sworn LSSD Deputies
Gang-Related Violence: LSSD Intelligence suggests heightened tension and multiple brawls and physical altercations and battery exchanged between the Varrio 38th Street Gang, Niners Function Street Gang, and the 59 & Harlow Bloods Street Gang
ᅠᅠ The presence of 38ST in El Corona has led to a surge in violent crime, with frequent shootings and armed confrontations that put both law enforcement and the public at serious risk. Residents in the affected areas live in fear, and legitimate businesses suffer as criminal activity drives away customers and discourages economic development.
ᅠᅠ
V. PRAYER FOR INJUNCTIVE RELIEF
A. KNOWN MEMBERS (as documented in SanGang).
1. ISAAC ILLESCAS / MEMBER
2. JADE COSTELLO / MEMBER
3. ALVARO COLON / MEMBER
4. LEONARDO RAMIEREZ / MEMBER
5. ALONSO VARGAS / MEMBER
6. ANTHONY CARVALO / MEMBER
5. MORGAN VAEZA / MEMBER
5. DENIS LINARES / MEMBER
5. EMMANUEL QUIJADA / MEMBER
5. JIGCY PECANA / MEMBER
B. B. SAFETY ZONE (Injunction Area)
ᅠᅠ The requested injunction would apply to the following areas of El Corona, where 38ST has established a strong presence:
28th Street Dead-End
El Corona Village Projects
38th Street
Kings Avenue
Newport Boulevard
ᅠᅠ Within this Safety Zone, I request that the Court prohibit the following activities by documented 38ST members:
ᅠᅠ [X] Denial of association: All subjects sitting, standing,walking, driving, gathering or appearing anywhere in public view or any place accessible to the public with any known member of the 59th & Harlow Bloods but not including: when all members are inside a school attending class, on school business or when inside of a church, providing that this prohibition against associating apply while travelling to said locations.
ᅠᅠ [X] No guns or dangerous weapons: Anywhere in public view or anywhere accessible to the public. Carrying any gun or illegal weapon as defined in penal code sections (9)01, (9)02,(9)04,(9)05, (9)07 and (9)09. Knowingly remaining in the presence of such a weapon or gun or a person possessing such a weapon or gun.
ᅠᅠ [X] No intimidation: Confronting, intimidating, harassing, annoying, threatening, challenging, provoking, assaulting or committing battery against any person engaged in lawful or peaceful business within the safety zone without due cause or reason.
ᅠᅠ [X]No Graffiti or Graffiti tools: Damaging, defacing or marking any public or private property of another or possessing any graffiti capable device, including spray paint and markers.
ᅠᅠ [X] Stay away from drugs: Without a prescription, selling, possessing or using any controlled substance or related paraphernalia, including but not limited to rolling paper and pipes for drug use. Knowingly remaining in the presence of any controlled substance or related paraphernalia or knowingly remaining in the presence of anyone possessing controlled substances or paraphernalia.
ᅠᅠ [X] No drug sales activities: Loiter anywhere in public view or anyplace accessible to the public in a manner and under circumstances manifesting the purpose and with the intent to commit an offense specified in penal code sections (6)03 and (6)04. Circumstances that may be considered in determining whether a person has the requisite intent to engage in such drug sales activity include: Acting as a "Lookout", transferring small objects or packages for currency in a furtive manner, trying to conceal him or herself or any object that reasonably could be involved in an unlawful drug-related activity, uses signals or language indicative of summoning purchasers of illegal drugs, repeatedly beckons to, stops, attempts to stop, or engages in conversations with passersby, whether on foot or in a motor vehicle, indicative of summoning purchasers of illegal drugs. Repeatedly passes to or receives from a passerby, whether on foot or in a motor vehicle, money or small objects. Has been convicted of any offense within this State within five months prior to a violation of this provision, of any violation of penal code sections(6)03 and (6)04. and is currently subject to any order prohibiting his or her presence in any high drug activity geographic area.
ᅠᅠ [X] Stay away from alcohol: Anywhere in public view or any place accessible by the public, except on properly licensed premises the possession of an open alcohol container of an alcoholic beverage or knowingly remaining in the presence of such a container and substance or knowingly remaining in the presence of someone in possession of such a container or substance.
ᅠᅠ [X] No Trespassing: Being present on or in any property not open to the general public except: with the prior written consent of the owner or person who is in lawful possession of the property or in the presence of the owner of the person who is in lawful possession of the property.
ᅠᅠ [X] No loitering: Loitering in public view or any place accessible to the general public for the purpose of engaging in graffiti, drug-related or other illegal activities.
ᅠᅠ [X] No lookouts: Acting as a lookout by whistling, yelling, or otherwise signaling, by any means, to warn another person engaged in unlawful or nuisance activity of the approach of law enforcement officers or soliciting, employing or coercing another person to act as such lookout.
ᅠᅠ [X] No Obstructing Traffic: Obstructing, impeding or blocking the passage of any vehicle or person on any street, walkway, sidewalk, alleyway, driveway, parking lot or other areas of public access.
ᅠᅠ [X] No recruiting children: Soliciting or recruiting anyone under the age of 18 to join, actively participate in, or associate with the intent to join the 59th & Harlow Bloods.
ᅠᅠ [X] Varrio South Side 38th Street members and affiliates are to stay away from 28th Street Dead-End, El Corona Village Projects, 38th Street, Kings Avenue, Newport Boulevard: Being present on or in 28th Street Dead-End, El Corona Village Projects, 38th Street, Kings Avenue, Newport Boulevard. For purposes of this provision, LOCATION includes properties, sidewalks and adjacent parking lots to LOCATION.
ᅠᅠ [X] Do not Obstruct, resist or Delay any Peace Officer: Knowingly obstructing, resisting or delaying any peace officer when that peace officer is effectuating or attempting to effectuate lawful detention or arrest. This includes but is not limited to: Running from a peace officer in an attempt to evade lawful detention or arrest and providing false identifying information to any peace officer in an attempt to evade proper identification by the peace officer.
ᅠᅠ [X] Obey all laws: Obey all laws and sections of the penal code.
V. CONCLUSION
ᅠᅠ Based on my training, experience, and the facts set forth in this affidavit, I believe that the Southside 38ST Gang constitute a public nuisance that significantly threatens the safety and welfare of the Los Santos community, particularly in the El Corona area. The gang's involvement in narcotics trafficking, illegal firearms possession, violent assaults, and the murder of three sworn deputies demonstrates their ongoing criminal enterprise and complete disregard for public safety and the law.
ᅠᅠ The requested injunction is necessary to disrupt 38ST's criminal activities, prevent further violence, and restore safety to the affected neighborhoods. Without court intervention, 38ST will continue to terrorize the community, perpetuate violence, and expand their criminal operations.
ᅠᅠ
DATED: June 5th, 2025 By: /s/ Alexander C. Braithwaite IV
Alexander C. Braithwaite IV
Chief Prosecutor
LOS SANTOS COUNTY SHERIFF'S DEPARTMENT
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