32
Case 3:18-cr-OOO22 *SEALED* Document L Filed in TXSD on L1-128118 Page 1 of 32 SEALED UNITED STATES OF AMERICA 1. CARLOS ALBERTO GUAJARDO AKA "VIEJON'' AKA "CHATO" 2. ERIKA CASTILLO-GUAJARDO 3. CRISTIAN ALEXIS GUAJARDO 4. ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA" AKA "BORRADO" 5. ELOY GONZALEZ 6. CAMILO ANTONIO CARIDAD 7. CESAR RAMON FLORES AKA "FAT BOY'' 8. CRISTIAN MACIEL REBOLLEDO AKA "TACO'' 9. WILLIE JAMES CRAIG AKA "BATMAN'' IO. NAVONTE KELTRONE WHITE 1 1. ALEJANDRO GUERRA-BALLEZA AKA "GORDO" 12. ELISEO GARZA-LOPEZ 13. CARLOS HERRERA -DTAZ AKA "JUAN CARLOS'' 14. JESUS GERARDO MARTINEZ I5. MARTA DELPILAR GOMEZ-RODRIGUEZ I 6. ROSWELL OZUNA-ANZALDUA 17. JUAN FRANCISCO MALDONADO 18. ODWIN DODANIM PENA 19. CARLOS OMAR PENA-VARGAS 20. RODRIGO CELIS-ALMADA AKA "CHELA" 2I. MARTTN GERARDO LOPEZ 22. VTCTOR HUGO GOMEZ 23. EMILIO RAMON TORRES 24. JOE ROY COCKERHAM AKA "JAY" UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION CRIMINAL NUMBER s*HHdm$Hi, iloy 2g 20,8 oavd J. Bradfqy, O*f orel8l v $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ I i ) i

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Case 3:18-cr-OOO22 *SEALED* Document L Filed in TXSD on L1-128118 Page 1 of 32

SEALED

UNITED STATES OF AMERICA

1. CARLOS ALBERTO GUAJARDOAKA "VIEJON''AKA "CHATO"

2. ERIKA CASTILLO-GUAJARDO3. CRISTIAN ALEXIS GUAJARDO4. ABEL LONGORRIA-PENA

AKA "GABRIEL LONGORIA"AKA "BORRADO"

5. ELOY GONZALEZ6. CAMILO ANTONIO CARIDAD7. CESAR RAMON FLORES

AKA "FAT BOY''8. CRISTIAN MACIEL REBOLLEDO

AKA "TACO''9. WILLIE JAMES CRAIG

AKA "BATMAN''IO. NAVONTE KELTRONE WHITE1 1. ALEJANDRO GUERRA-BALLEZA

AKA "GORDO"12. ELISEO GARZA-LOPEZ13. CARLOS HERRERA -DTAZ

AKA "JUAN CARLOS''14. JESUS GERARDO MARTINEZI5. MARTA DELPILAR

GOMEZ-RODRIGUEZI 6. ROSWELL OZUNA-ANZALDUA17. JUAN FRANCISCO MALDONADO18. ODWIN DODANIM PENA19. CARLOS OMAR PENA-VARGAS20. RODRIGO CELIS-ALMADA

AKA "CHELA"2I. MARTTN GERARDO LOPEZ22. VTCTOR HUGO GOMEZ23. EMILIO RAMON TORRES24. JOE ROY COCKERHAM

AKA "JAY"

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

GALVESTON DIVISION

CRIMINAL NUMBER

s*HHdm$Hi,

iloy 2g 20,8

oavd J. Bradfqy, O*f orel8l

v

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adodge
Text Box
Unsealed 3/20/19

25. TAVIS LAMAR MILLER26. LARRY JAMES WILLIAMS

AKA "BLACK''27. EDWIN MANUEL VIZCAINO28. AWNI MINAYA

AKA "CESAR"29. CARLOS JOVANNI PENA JR.

AKA "G[OVANNI''30. MARIA DELCARMEN HERNANDEZ-

MENDOZA3I. DEITHER OSVALDO TIJERINA-

SCHWUCHOW32. ANTHONY RAMONE COMPTON33. GERARDO GARCIA34. MTRiAM ALVAREZ AKA "MIA"35. MARI,A GUADALUPE GARCIA-

ALVAREZ36. CARLOS LIZARDI DEL VALLE

AKA "YORKIE"37. ALFONSO MARTTNEZ

AKA "MATRACA "AKA "LILO"AKA "FLACO''

38. FRANKLTN ERNESTO MARTINEZ-FERNANDEZ AKA "TILOS''

39 . ELIEZER CA STILLO-MARTINEZAKA "GALLO"

40. ALEX CASTILLO4I. MOISES CAMPOS-ESPINOSA

AKA "CHICHE''42. RICHARD DAVID ORTIZ

AKA "JESUS GUZMAN"AKA "EL CULON''

43. DANERI SAET MALDONADO-GUILLEN

44. RODRIGO RODRTGUEZ45. KEILA JOSEFINA PALOMO46. DIMITRIAUS PETERSON

AKA "MEECH''AKA "KING PHOENIX''

47. LOUIS YBARRAAKA "LOU''

48. RENE FRANCISCO PENA49. DARRELL BREEDLOVE50. KENNETH ROY JOHNSON

AKA "K9"

Case 3:l-8-cr-00022 *SEALED* Document L Filed in TXSD on LLl28lLB Page 2 of 32

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on LLl28lLB Page 3 of 32

5 I. COREY EUGENE LOVELL52. JUAN GONZALEZ-CARDEBAS53. OSCAR HERNANDEZ-CERVANTES54. ROLINDO HERNANDEZ55. GUSTAVO JIMENEZ

AKA "JIMMY''56. ELMER ALEXANDER MACHADO

AKA "MEME''

Unlrcd lltrur CourBSarfrrn Ostrist of Ttxss

FII FD

Nov 28 Z0t8

.nvid J. Bradley, Clfikq(Couil

$

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INDICTMENT

THE GRAND ruRY CHARGES THAT:

INTRODUCTION

During the period between February I , 2ll6,and April lg, zllS,seven (7) groups of

persons identified as, but not limited to, the defendants named in this lndictunent operated in and

out of the Southern Judicial District of Texas to distribute cocaine and heroin which had been

smuggled into the United States from Colombia and Mexico. The leader of one of these groups,

CARLOS ALBERTO GUAJARDO AKA "VIEJON" AKA "CHATO", was the main source of

cocaine and heroin smuggled into the United States and subsequently dishibuted in the Southern

District of Texas and elsewhere throughout the United States by the seven (7) distribution cells

identified in this Indictment. The cocaine and heroin were distributed through Houston, Texas, to

Atlanta, Georgia; Buffalo and Manhattan, New York; Miami, Florida; New Orleans, Louisiana;

and Norfolk, Virginia. The allegations in this tndictment focus on the drug trafficking and money

laundering activities conducted by CARLOS ALBERTO GUAJARDO through the other

defendants. Most of the distribution cells identified in this Indictment were composed of persons

from Santo Domingo, Dominican Republic.

3

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on LLl28lLB Page 4 of 32

COUNT ONE

Between on or about February 1,2016, and on or about April 19, 2018, in the Southem

District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

[defendants 1,4-56)

1. CARLOS ALBERTO GUAJARDO AKA "VIEJON' AKA "CHATO",4. ABEL LONGORzuA-PENA AKA "GABRIEL LONGORIA'' AKA'OBORRADO",5. ELOY GONZALEZ,6. CAMILO ANTONIO CARIDAD,7. CESAR RAMON FLORES AKA "FAT BOY'"8. CRISTIAN MACIEL REBOLLEDO AKA "TACO",9. WILLIE JAMES CRAIG AKA "BATMAN'"10. NAVONTE KELTRONE WHITE,I I. ALEJANDRO GUERRA-BALLEZA AKA "GORDO'"1 2. ELISEO G ARZA-LOPEZ,13. CARLOS HERRERA-DIAZ AKA "JUAN CARLOS'"14. JESUS GERARDO MARTINEZ,1 5. MARIA DELPILAR GOMEZ-RODRIGUEZ,1 6. ROSWELL OZLTNA-ANZALDUA,17. JUAN FRANCISCO MALDONADO,18. ODWIN DODANIM PENA,19. CARLOS OMAR PENA-VARGAS,20. RODRIGO CELIS-ALMADA AKA "CHELA'"2I. MARTTN GERARDO LOPEZ,22. VICTOR HUGO GOMEZ,23. EMILIO RAMON TORRES,24, JOE ROY COCKERHAM AKA "JAY",25. TAVIS LAMAR MILLER,26. LARRY JAMES WILLTAMS AKA "BLACK'"27. EDWIN MANUEL VIZCATNO,28. AWNI MINAYA AKA "CESAR'"29. CARLOS JOVANNI PENA JR. AKA "GIOVANNI",30. MARIA DELCARMEN HERNANDEZ- MENDOZA,31. DEITHER OSVALDO TIJERINA- SCHWUCHOW,32. ANTHONY RAMONE COMPTON,33. GERARDO GARCIA,34. MIRIAM ALVAREZ AKA "MIA'"35. MARIA GUADALUPE GARCIA-ALVAREZ,36. CARLOS LIZARDI DEL VALLE AKA "YORKIE",37. ALFONSO MARTTNEZ-SOTO AKA "MATRACA'' AKA "LILO'' AKA "FLACO'"38. FRANKLTN ERNESTO MARTINEZ- FERNANDEZ AKA "TILOS'"39 . ELIEZER CASTILLO-MARTINEZ AKA "GALLO",40. ALEX CASTILLO,

4

Case 3:18-cr-OOO22 *SEALED" Document 1 Filed in TXSD on 7tl28l!8 Page 5 of 32

41. MOISES CAMPOS.ESPINOSA AKA "CHICHE'"42. RICHARD DAVID ORTIZ AKA "JESUS GUZMAN'' AKA "EL CULON'"43. DANERI SAET MALDONADO- GUILLEN,44. RODRIGO RODRIGUEZ,45. KEILA JOSEFINA PALOMO,46. DIMITRIAUS PETERSON AKA "MEECH" AKA "KING PHOENIX'"47. LOUIS YBARRA AKA "LOU",48. RENE FRANCISCO PENA,49. DARRELL BREEDLOVE,50. KENNETH ROY JOHNSON AKA "K9'',51. COREY EUGENE LOVELL,52. JUAN GONZALEZ-CARDEBAS,5 3. OSCAR HERNANDEZ-CERVANTES,54. ROLTNDO HERNANDEZ,55. GUSTAVO JTMENEZ AKA"JIMMY", ANd

56. ELMER ALEXANDER MACHADO AKA *MEME'"

did knowingly and intentionally conspire and agree together, with each other and with other

persons known and unknown to the Grand Jury, to possess with intent to distribute controlled

substances. This violation involved five (5) kilograms or more of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance, and one (l)

kilogram or more of a mixture or substance containing a detectable amount of heroin, a Schedule

I controlled substance.

In violation of Title 2 I , United States Code, Sections 846, 841 (a)( I ), and 841 (bX I XA)

COUNT TWO

Between on or about February 1,2016, and on or about April 19, 2018, in the Southern

District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

I defendants 1,3,4,8, I 1,12,1 6,17,18, 36,3 7,4 1,56]

I. CARLOS ALBERTO GUAJARDO AKA "VIEJON' AKA "CHATO'"3. CRISTIAN ALEXIS GUAJARDO,4. ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA'' AKA "BORRADO'"8. CRISTIAN MACIEL REBOLLEDO AKA "TACO'"I I. ALEJANDRO GUERRA-BALLEZA AKA "GORDO'"I 2. ELISEO G ARZA-LOPEZ,

5

Case 3:18-cr-00022 *SEALED* Document 1 Filed in TXSD on 77128118 Page 6 of 32

I 6. ROSWELL OZUNA-ANZALDUA,17. JUAN FRANCISCO MALDONADO,18. ODWIN DODANIM PENA,36. CARLOS LIZARDI DEL VALLE AKA "YORKIE",37. ALFONSO MARTINEZ-SOTO AKA *MATRACA'' AKA'LILO" AKA 'FLACO",41. MOISES CAMPOS-ESPINOSA AKA *CHICHE", and

56. ELMER ALEXANDER MACHADO AKA "MEME",

did knowingly and intentionally conspire and agree, with each other and with other persons known

and unknown to the Grand Jury, to transport, transmit, and transfer monetary instruments and

funds, that is, United States currency, which the defendants then well knew represented the

proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled

substances with intent to distribute and the unlawful operation ofan unlicensed money transmitting

business, and knowing that the transactions were designed in whole or in part to conceal and

disguise the nature, location, source, ownership, and control ofthe proceeds of the said specified

unlawful activities, and to avoid a transaction reporting requirement under State or Federal Law.

In violation of Title 18, United States Code, Sections 1956(a)(2XBXD, 1956 (a)(2)(B)(ii),

and 1956(h).

COUNT THREE

Between on or about February l, 2016, and on or about April 19, 2018, in the Southern

District of Texas and elsewhere within the judsdiction ofthe Court, the defendants,

I defendants 1,2]

L CARLOS ALBERTO GUAJARDO AKA *VIEJON" AKA "CHATO", and

2. ERIKACASTILLO.GUAJARDO,

did klowingty and intentionally conspire and agree, with each other and with otherpersons known

and unknown to the Grand Jury, to conduct and attempt to conduct financial transactions affecting

interstate and foreign commence, then well knowing that the financial transactions involved the

6

Case 3:18-cr-OOOZ2 *SEALED* Document 1 Filed in TXSD on L1,128118 Page 7 of 32

proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled

substances with intent to distribute and the unlawful operation of an unlicensed money transmitting

business, knowing that the transactions were designed in whole or in part to conceal and disguise

the nature, location, source, ownership, and control of the proceeds of the said specified unlawful

possession of controlled substances with intent to distribute and the unlawful operation of an

unlicensed money transmitting business, and to avoid a transaction reporting requirement under

State or Federal Law.

In violation of Title 18, United States Code, Sections 1956(a)(1)(BXi), (aXl)(B)(ii), and

1es6(h).

COUNT FOUR

Between on or about February 1, 2016, and on or about April 19, 2018, in the Southern

District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

I defendants 19,22,331

19. CARLOS OMAR PENA-VARGAS,22. VICTOR HUGO GOMEZ, and33. GERARDO GARCIA,

did knowingly and intentionally conspire and agree, with each other and with otherpersons known

and unknown to the Grand Jury, to conduct and attempt to conduct financial transactions affecting

interstate and foreign commence, then well knowing that the {inancial transactions involved the

proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled

substances with intent to distribute and the unlawful operation of an unlicensed money transmitting

business, knowing that the transactions were designed in whole or in part to conceal and disguise

the nature, location, source, ownership, and control of the proceeds of the said specified unlawful

possession of controlled substances with intent to distribute and the unlawful operation of an

7

t

Case 3:L8-cr-00022 *SEALED* Document L Filed in TXSD on LLl28l18 Page 8 of 32

unlicensed money transmitting business, and to avoid a transaction reporting requirement under

State or Federal Law.

In violation of Title 18, United States Code, Sections 1956(a)(1)(BXi), (aXl)(B)(ii), and

res6(h).

COUNT FIYE

On or about Febru^ry 4,2016, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

DIMTTRIAUS PETERSON AKA "MEECH" AKA "KING PHOENIX",KENNETH ROY JOHNSON AKA "K9", ANd

DARRELL BREEDLOVE,

did knowingly and intentionally possess with intent to distribute controlled substances. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately eleven (l l) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance; and 100 grams or

more of a mixture or substance containing a detectable amount of heroin, that is, approximately

500 grams of a mixture or substance containing a detectable amount of heroin, a Schedule I

controlled substance.

In violation of Title 21, United States Code, Sections Sal(a)(l) , 841(bXlXA),

841(bXlXB), and Title 18, United States Code, Section 2.

COUNT SIX

On or about July 14,2016, in the Southem District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ABEL LONGORRIA-PENA AKA "GABRTEL LONGORIA'' AKA "BORRADO",DIMITRIAUS PETERSON AKA "MEECH" AKA "zuNG PHOENIX", ANd

KENNETH ROY JOHNSON AKA "K9'"

8

Case 3:18-cr00022 *SEALED* Document 1 Filed in TXSD on tll28l18 Page I of 32

did knowingly and intentionally possess with intent to distribute controlled substances. This

violation involved five (5) kilograms or more ofa mixture or substance containing a detectable

amount ofcocaine, that is, approximately five (5) kilo$ams ofa mixture or substance containing

a detectable amount ofcocaine, a Schedule ll controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(1) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNTSEVEN

On or about August 15, 2016, in the Southem District ofTexas and elsewhere within the

jurisdiction ofthe Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA *VIEJO].I,' AKA ..CHATO'',

and ELISEO G ARZA-LOPEZ,

did knowingly and intentionally transport, transmit, and transfer, and attempt to transport, transmit,

and transfer monetary instruments and funds, that is, $340,890.00 in United States currency, which

involved the proceeds of specified unlawful activity, to wit: possession with intent to distribute

controlled substances and operating an unlicensed money transmitting business, from a place in

the United States to or through a place outside the United States, knowing that the monetary

instruments and funds involved in the transportation, transmission, and transfer represented the

proceeds of some form of unlawful activity, and knowing that such transportation, transmission,

and transfer was desigrred in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of specified unlawful activity, and to avoid a transaction

reporting requirement under State or Federal law.

In violation of Title 18, United States Code, Sections 1956(a)(2)@)(i), 1956(aX2XBXii),

and 2.

9

Case 3:L8-cr-00O22 *SEALED* Document 1 Filed in TXSD on tLl2SlLB Page 10 of 32

COUNT EIGHT

On or about February 14,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA "VIEJON" AKA "CHATO'"ELOY GONZALEZ,

and CARLOS LIZARDI DEL VALLE AKA "YORKIE",

did knowingly and inteniionally possess with intent to distribute controlled substances. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately three (3) kilograms of a mixture or

substance containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 84l(a)(l) , 841(bxlXB), and Title

18, United States Code, Section 2.

COUNT NINE

Between on or about February 15, 20l7,andon or about February 23,2017, in the Southern

District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

CARLOS ALBERTO GUAJARDO,ELOY GONZALEZ,

ALEJANDRO GUERRA -B ALLEZ A AKA "GORDO",ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA'' AKA "BORRADO",

CARLOS LIZARDI DEI. VALLE AKA "YORKIE'"MOISES CAMPOS.ESPTNOSA,

ELIEZER CASTILLO-MARTINEZ AKA "GALLO'"and ALEX CASTILLO,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately thirteen (13) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

i0

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on 1,Ll28lLB Page 1L of 32

In violation of Title 21, United States Code, Sections 8al(a)(1) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT TEN

On or about March 2, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ELMER ALEXANDER MACHADO AKA "MEME'"and GUSTAVO JIMENEZ AKA "JIMMY",

did knowingly and intentionally possess with intent to dishibute controlled substances. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately fourteen (14) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II conrolled substance.

. In violation of Title 21, United States Code, Sections 8al(a)(1), 841(bXlXA), and Title

18, United States Code, Section 2.

pouNT ELEVEN

Between on or about March 6, 2017, and on or about March 10, 2017, in the Southern

District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA "VIEJON" AKA "CHATO'"ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA" AKA "BORRADO'"

CARLOS LIZARDI DEL VALLE AKA "YORKIE",ALFONSO MARTINEZ-SOTO AKA "MATRACA'' AKA "L[LO'' AKA "FLACO'"

FRANKLIN ERNESTO MARTINEZ-FERNANDEZ AKA "TILOS'"MOISES CAMPOS-ESPINOSA AKA "CHICHE",

and, ELIEZER CASTILLO-MARTINEZ AKA "GALLO",

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately seventeen (17) kilograms of a mixture or substance

11

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on LLI2S1LB Page 12 ol32

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(b)(lXA), and Title

18, United States Code, Section 2.

COUNT TWELVE

On or about May 22, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CESAR RAMON FLORES AKA "FAT BOY'"ALEJANDRO GUERRA -B ALLEZA AKA "G ORDO",

and JESUS GERARDO MARTINEZ,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately twenty (20) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violaiion of Title 21, United States Code, Sections S I(aXl),841(b)(lXA), and Title

18, United States Code, Section 2.

COUNT THIRTEEN

Between on or about June 2, 2017, and on or about June 4, 2017, in the Southern District

of Texas and elsewhere within the jurisdiction of the Court, the defendants,

RICHARD DAVID ORTIZ AKA "JESUS GUZMAN" AKA "EL CULON",DANERT SAET MALDONADO-GUILLEN,

and RODRIGO RODRIGUEZ,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately ten (10) kilograms of a mixture or substance

12

Case 3:18-cr-O0022 *SEALED* Document 1 Filed in TXSD on 1L128118 Page 13 of 32

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(l) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT FOURTEEN

On orabout June 28, 2017,inthe Southem District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ALEJANDRO GUERRA -B ALLEZ A AKA "GORDO'"CRISTTAN MACIEL REBOLLEDO AKA "TACO'"

WILLIE JAMES CRATG AKA "BATMAN'"and NAVONTE KELTRON WHITE,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately ten (10) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule [I controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bXl)(A), and Title

18, United States Code, Section 2.

COUNT FIFTEEN

On or about June 28,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,MARTIN GERARDO LOPEZ,JOE ROY COCKERHAM AKA "JAY'"

and MARIA DELCARMEN HERNANDEZ-MENDOZA,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately twelve (12) kilograms of a mixture or substance

13

I

I

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on t1,l28lL9 Page L4 of 32

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT SIXTEEN

Between on or about June 28, 2017 , and on or about July l, 2A17, in the Southern District

of Texas and elsewhere within the jurisdiction of the Court, the defendants,

A,LEJANDRO GUERRA -B ALLEZA AKA "GORDO'"and ROSWELL OZUNA-ANZALDUA,

did knowingly and intentionally transport, transmit, and transfer, and attempt to transport, transmit,

and transfer monetary instruments and funds, that is, $664,933.00 in United States currency, which

involved the proceeds of specified unlawful activity, to wit: possession with intent to distribute

controlled substances and operating an unlicensed money transmitting business, from a place in

the United States to or through a place outside the United States, knowing that the monetary

instruments and funds involved in the transportation, transmission, and transfer represented the

proceeds of some form of unlawful activity, and knowing that such transportation, transmission,

and transfer was designed in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of specified unlawful activity, and to avoid a transaction

reporting requirement under State or Federal law.

In violation of Title 18, United States Code, Sections 1956(aX2XBXi), 1956(aX2XBXii),

and2.

COUNT SEVENTEEN

Between on or about June 29,2017, and on or about July 6, 2017, in the Southern District

of Texas and elsewhere within the jurisdiction of the Court, the defendants,

14

Case 3:18-cr-OOO22 *SEALED* Document 1 Filed in TXSD on lLl2&lLB Page 15 of 32

CARLOS OMAR PENA-VARGAS,and VICTOR HUGO GOMEZ,

did knowingly and intentionally possess with intent to diskibute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately ten (10) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bXlXA), and Title

18, United States Code, Section 2.

COUNT EIGHTEEN

Between on or about July l, 2017 , and on or about July 2,2017, in the Southern District of

Texas and elsewhere within the jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,MIRIAM ALVAREZ AKA "MIA",

LARRY JAMES WILLIAMS AKA "BLACK'"ANd TAVIS LAMAR MILLER,

did knowingly and intentionally possess with intent to distribute a conholled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately ten (10) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(1) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT NINETEEN

On or about July 2, 20L7, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendant,

LARRY JAMES WILLIAMS AKA "BLACK'"

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did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved more than five hundred (500) grams or more of a mixture or substance

containing a detectable amount of cocaine, that is, approximately two (2) kilograms of a mixture

or substance containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) and 8al@)(1)B).

COUNT TWENTY

On or about July 2, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Coufi, the defendant,

TAVIS LAMAR MILLER,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved more than five hundred (500) grams or more of a mixture or substance

containing a detectable amount of cocaine, that is, approximately three (3) kilograms of a

mixture or substance containing a detectable amount of cocaine, a Schedule II controlled

substance.

In violation of Title 21, United States Code, Sections 8 l(a)(l) and 8al@)(l)B).

COUNT TWENTY.ONE

On or about July 6, 2017, in the Southem District of Texas and elsewhere within the

jurisdiction of the Courl, the defendants,

CARLOS OMAR PENA-VARGAS,EMILIO RAMON TORRES,

aNd TAVIS LAMAR MILLER,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

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violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately sixteen (16) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l), 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT TWENTY.TWO

On or about July 8,2017, in the Southem District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,RODRIGO CELIS.ALMADA AKA "CHELA'"

and DEITHER TIJERINA-SCHWUCHOW,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately twenty-wo (22) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(aXl) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT TWENTY-THREE

On or about July 15,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ALEJANDRO GUERRA -B ALLEZ AKA "GORDO",and CRISTIAN MACIEL REBOLLEDO AKA .,TACO',,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

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violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately five (5) kilograms of a mixture or substance containing

a detectable amount of cocaine, a Schedule tt conholled substance.

In violation of Title 21, United States Code, Sections Sal(a)(1) , 841(bXlXA), and Title

18, United States Code, Section 2.

COUNT TWENTY.FOUR

On or about July 16, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ALEJANDRO GUERRA -B ALLEZA AKA "GORDO",and CARLOS HERRERA-DIAZ AKA "JUAN CARLOS':,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately twenty-three (23) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(aXl) , 841(bXlXA), and Title

18, United States Code, Section 2.

COUNT TWENTY-FIYE

On or about July 16,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

ALEJANDRO GUERRA -B ALLEZA AKA "GORDO'"and CRISTIAN MACIEL REBOLLEDO AKA .,TACO',,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

18

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violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately ten (10) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 84l(a)(l) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT TWENTY.SX

On or about July 22, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

, ALEJANDRO GUERRA-BALLEZAAKA "GORDO'"CRISTIAN MACIEL REBOLLEDO AKA "TACO",

JUAN FRANCISCO MALDONADO,and ODWIN DODANIM PENA,

did knowingly and intentionally transport, transmit, and transfer, and attempt to transport, transmit,

and transfer monetary instruments and funds, that is, $194,734.00 in United Stat.s curency, which

involved the proceeds of specified unlawful activity, to wit: possession with intent to distribute

conffolled substances and operating an unlicensed money transmitting business, from a place in

the United States to or through a place outside the United States, knowing that the monetary

instruments and funds involved in the transportation, transmission, and transfer represented the

proceeds of some form of unlawful activity, and knowing that such transportation, transmission,

and transfer was designed in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of specified unlawful activity, and to avoid a transaction

reporting requirement under State or Federal law.

In violation of Title 18, United States Code, Sections 1956(aX2XBXi), 1956(a)(2)(B)(ii),

and2.

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COUNT TWENTY-SEVEN

On or about July 24,2O17, in the Southem District of Texas and elsewhere within the

jurisdiction ofthe Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA "VIEJON'' AKA'CHATO",and ALEJANDRO GUERRA-BALLEZA AKA "GORDO",

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved more than five hundred (500) grams or more ofa mixture or substance

containing a detectable amount ofcocaine, that is, approximately three (3) kilograms ofa

mixture or substance containing a detectable amount ofcocaine, a Schedule II controlled

substance.

In violation of Title 21, United States Code, Sections 841(a)(l) and 8alGXl)B), and Title

18, United States Code, Section 2.

COUNT TWENTY-EIGHT

On or about September 7,2017 , in the Southem District ofTexas and elsewhere within the

jurisdiction ofthe Cout, the defendants,

ALEJANDRO GUERRA-BALLEZ AKA "GORDO'"and MARIA DELPILAR GOMEZ-RODRIGUEZ,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more ofa mixture or substance containing a detectable

amount ofcocaine, that is, approximately fourteen (14) kilograms ofa mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 84t(bXlXA), and Title

18, United States Code, Section 2.

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COUNT TWENTY-NINE

On or about September 7,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendant,

CRISTIAN MACIEL REBOLLEDO AKA "TACO'',

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately five (5) kilograms of a mixture or substance containing

a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(1) , 841(bXl)(A), and Title

18, United States Code, Section 2.

COUNT THIRTY

On or about September 10, 2017,in the Southern District of Texas and elsewhere within

the jurisdiction of the Court, the defendants,

RICHARD DAVID ORTIZ AKA "JESUS GUZMAN" AKA "EL CULON'"and DANERI SAET MALDONADO-GUILLEN,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately six (6) kilograms of a mixture or substance containing

a detectable amount of cocaine, a Schedule II controlled substance.

ln violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bxlXA), and Title

18, United States Code, Section 2.

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COUNT THIRTY-ONE

On or about September I l,2Ol7,in the Southern District of Texas and elsewhere within

the jurisdiction of the Court, the defendants,

ALEJANDRO GUERRA -B ALLEZ A AKA "GORDO'"and MARIA DELPILAR GOMEZ-RODRIGUEZ,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately sixteen (16) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(l) , 841(bXlXA), and Title

18, United States Code, Section 2.

COUNT THIRTY.TWO

On or about September 13, 2017,in the Southem District of Texas and elsewhere within

the jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,and MARTIN GERARDO LOPEZ,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately two (2) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bX1XB), and Title

18, United States Code, Section 2.

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COUNT THIRTY.THREE

On or about September 19, 2017, in the Southern District of Texas and elsewhere within

the jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,LARRY JAMES WILLIAMS AKA "BLACK'"

and ANTHONY RAMONE COMPTON,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately three (3) kilograms of a mixture or

substance containing a detectable amount of cocaine, a Schedule II conholled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(l) , 841(bxlXB), and Title

18, United States Code, Section 2.

COUNT THIRTY.FOUR

On or about September 19, 2017, in the Southern District of Texas and elsewhere within

the jurisdiction ofthe Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA "VIEJON" AKA "CHATO'"ALEJANDRO GUERRA -B ALLEZA AKA "GORDO",

and CAMILO ANTONIO CARIDAD,

did knowingly and intentionally possess with intent to distribute a conholled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately seven (7) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections S I(a)(l), 841(bXlXA), and Title

18, United States Code, Section 2.

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COUNT THIRTY.FIVE

Between on or about September 15,2017, and on or about September 20,2017, in the

Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

DIMITRIAUS PETERSON AKA "MEECH'' AKA "KING PHOENIX'"RENE FRANCISCO PENA,LOUIS YBARRA AKA "LOU'"

JUAN GONZALEZ-CARDEBAS,OSCAR HERNANDEZ-CERVANTES,

ROLTNDO HERNANDEZ,and COREY EUGENE LOVELL,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

arnount of cocaine, that is, approximately eighteen (18) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(1) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT THIRTY-SIX

On or about Octob er 31, 2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS OMAR PENA.VARGAS,and LARRY JAMES WILLIAMS AKA "BLACK",

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately two and five-tenths (2.5) kilograms of a

mixture or substance containing a detectable amount of cocaine, a Schedule II controlled

24

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substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(b)(lXB), and Title

18, United States Code, Section 2.

COUNT THIRTY.SEVEN

On or about November 3, 2017,inthe Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,CARLOS JOVANNI PENA JR. AKA "GIOVANNI",

and EDWIN MANUEL VIZCAINO,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately two (2) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8a1(a)(1) , 841(bxlXB), and Title

18, United States Code, Section 2.

COUNT THIRTY.EIGHT

Between on or about November 5, 2017, and on or about November 6, 2017, in the

Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

CARLOS OMAR PENA-VARGAS,And TAVIS LAMAR MILLER,

did knowingly and intentionally possess with intent to distribute a conholled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately eight (8) kilograms of a mixture or substance

25

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containing a detectable amount of cocaine, a Schedule II controlled substance.

ln violation of Title 21, United States Code, Sections 8al(a)(1), 846, 841(b)(l)(A), and

Title 18, United States Code, Section 2.

COUNT THTRTY-NINE

On or about November 8,2017, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendants,

CARLOS ALBERTO GUAJARDO AKA "VIEJON" AKA "CHATO'"ELOY GONZALEZ,

and DIMITRIAUS PETERSON AKA "MEECH" AKA "KING PHOENIX",

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five hundred (500) grams or more of a mixture or substance containing a

detectable amount of cocaine, that is, approximately four (4) kilograms of a mixture or substance

containing a detectable amount of cocaine, a Schedule II conholled substance.

In violation of Title 21, United States Code, Sections 8al(a)(1),841(bxlXB), and Title

18, United States Code, Section 2.

COUNT FORTY

Between on or about November 8, 2017, and on or about November 12, 2017, inthe

Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants,

DIMITRIAUS PETERSON AKA "MEECH" AKA "KING HOENIX'"and LOUIS YBARRA AKA "LOIJ",

did knowingly and intentionally possess with intent to distribute a conholled substance. This

violation involved five (5) kilograms or more of a mixture or substance containing a detectable

amount of cocaine, that is, approximately eleven (11) kilograms of a mixture or substance

26

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containing a detectable amount ofcocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l) , 841(bxlXA), and Title

i8, United States Code, Section 2.

UNT FORTY-ONE

Between on or about November 5,2017, and on or about November 13, 2017, in the

Southem District of Texas and elsewhere within the jurisdiction of the Cou(, the defendants,

CARLOS OMAR PENA.VARGAS,VICTOR HUGO GOMEZ,

and GERARDO GARCIA,

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved five (5) kilograms or more ofa mixture or substance containing a detectable

amount ofcocaine, that is, approximately fwenty (20) kilograms ofa mixture or substance

containing a detectable amount ofcocaine, a Schedule II controlled substance.

In violation of Title 21, United States Code, Sections 8al(a)(l),841(bX1XA), and Title

18, United States Code, Section 2.

COUNTFORTY-TWO

On or about November 11,2017, in the Southom District of Texas and elsewhere within

thejurisdiction ofthe Court, the defendants,

CARLOS OMAR PENA-VARGAS,MARIA GUADALUPE GARCIA.ALVAREZ,ANd RODRIGO CELIS-ALMADA AKA *CHELA'"

did knowingly and intentionally possess with intent to distribute a controlled substance. This

violation involved one (l) kilogram or more ofa mixture or substance containing a detectable

27

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amount of heroin, that is, approximately three (3) kilograms of a mixture or substance containing

a detectable amount of heroin, a Schedule I controlled substance.

In violation of Title 21, United States Code, Sections 841(a)(1) , 841(bxlXA), and Title

18, United States Code, Section 2.

COUNT FORTY.THREE

On or about April 19, 2018, in the Southern District of Texas and elsewhere within the

jurisdiction of the Court, the defendant,

ELISEO GARZA.LOPEZ,

did knowingly and intentionally transport, transmit, and transfer, and attempt to transport, transmit,

and transfer monetary instruments and funds, that is, $225,640.00 in United States currency, which

involved the proceeds of specified unlawful activity, to wit: possession with intent to distribute

conholled substances and operating an unlicensed money hansmitting business, from a place in

the United States to or through a place outside the United States, knowing that the monetary

instruments and funds involved in the transportation, transmission, and transfer represented the

proceeds of some form of unlawful activity, and knowing that such transportation, transmission,

and transfer was designed in whole or in part to conceal and disguise the nature, Iocation, source,

ownership, and control of the proceeds of specified unlawful activity, and to avoid a transaction

reporting requirement under State or Federal law.

In violation of Title 18, United States Code, Sections 1956(a)(2)(BXi), 1956(a)(2)(B)(ii),

and2.

(21 U.s.C. g 8s3(a))

Pursuant to Title 21, United States Code, Section 853(a), the United States of America

28

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gives notice to the defendants,

I defendants 1,4-56]

1. CARLOS ALBERTO GUAJARDO AKA "VIEJON' AKA "CHATO",4. ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA'' AKA "BORRADO'"5. ELOY GONZALEZ,6. CAMILO ANTONIO CARIDAD,7. CESAR RAMON FLORES AKA "FAT BOY'"8, CRISTIAN MACIEL REBOLLEDO AKA "TACO'"9. WILLIE JAMES CRAIG AKA "BATMAN'"10. NAVONTE KELTRONE WHITE,1I. ALEJANDRO GUERRA-BALLEZA AKA "GORDO'"I 2. ELTSEO G ARZA.LOPEZ,13. CARLOS HERRERA-DIAZ AKA "JUAN CARLOS'"14. JESUS GERARDO MARTINEZ,1 5. MARIA DELPILAR GOMEZ-RODRIGUEZ,1 6. ROSWELL OZI.INA-ANZALDUA,17. JUAN FRANCISCO MALDONADO,18. ODWIN DODANIM PENA,19. CARLOS OMAR PENA-VARGAS,20. RODRIGO CELIS-ALMADA AKA "CHELA",2I. MARTIN GERARDO LOPEZ,22. VICTOR HUGO GOMEZ,23. EMILIO RAMON TORRES,24, JOE ROY COCKERHAM AKA "JAY",25. TAVIS LAMAR MILLER,26. LARRY JAMES WILLIAMS AKA "BLACK",27. EDWIN MANUEL VIZCATNO,28. AWNI MINAYA AKA "CESAR'"29. CARLOS JOVANNI PENA JR. AKA "GIOVANNI'"30. MARI,A DELCARMEN HERNANDEZ- MENDOZA,3I. DEITHER OSVALDO TIJERINA- SCHWUCHOW,32. ANTHONY RAMONE COMPTON,33. GERARDO GARCIA,34. MIRIAM ALVAREZ AKA "MIA'"35. MARIA GUADALUPE GARCTA-ALVAREZ,36. CARLOS LIZARDI DEL VALLE AKA "YORKIE'"37. ALFONSO MARTINEZ-SOTO AKA "MATRACA" AKA "LILO'' AKA "FLACO'"38. FRANKLIN ERNESTO MARTINEZ- FERNANDEZ AKA "TILOS'"39. ELTEZER CASTTLLO-MARTINEZ AKA "GALLO'"40. ALEX CASTILLO,4I. MOISES CAMPOS-ESPTNOSA AKA "CHICHE",42. RICHARD DAVID ORTIZ AKA"'JESUS GUZMAN'' AKA "EL CULON'"43. DANERI SAET MALDONADO- GUILLEN,44. RODRIGO RODRTGUEZ,

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45, KEILA JOSEFINA PALOMO,46. DIMITRIAUS PETERSON AKA *MEECH'' AKA "KING PHOENIX'"47. LOUIS YBARRA AKA "LOIJ",48. RENE FRANCISCO PENA,49. DARRELL BREEDLOVE,50. KENNETH ROY JOHNSON AKA "K9",5 I. COREY EUGENE LOVELL,52. JUAN GONZALEZ-CARDEBAS,53. OSCAR HERNANDEZ-CERVANTES,54. ROLINDO HERNANDEZ,55. GUSTAVO JIMENEZ AKA "JIMMY", and56. ELMER ALEXANDER MACHADO AKA "MEME",

that upon conviction of conspiracy as charged in Count ONE of the Indictment, the following

property, whether real or personal, is subject to forfeiture:

I ) all property constituting, or derived from, any proceeds obtained,directly or indirectly, as the result of such conspiracy; and

all property used, or intended to be used, in any manner or part, tocommit; or to facilitate the commission of, such conspiracy.

NOTICE OF CRIMINAL FORFEITURE(18 u.s.c. $ e82(a)(1))

Pursuant to Title I 8, United States Code, Section 982(a)( I ), the United States of America

gives notice to the defendants,

I defendants I 4, 8, 1 1,1 2,1 6- I 9,22,33,3 6,37,4 1,5 6]

I.CARLOS ALBERTO GUAJARDO AKA "V[EJON'' AKA "CHATO'"2. ERIKA CASTILLO-GUAJARDO,3. CRISTIAN ALEXIS GUAJARDO,4. ABEL LONGORRIA-PENA AKA "GABRIEL LONGORIA'' AKA "BORRADO",8. CRISTIAN MACIEL REBOLLEDO AKA "TACO",I I. ALEJANDRO GUERRA-BALLEZA AKA "GORDO",I 2. ELISEO G ARZA-LOPEZ,I 6. ROSWELL OZUNA-ANZALDUA,17. JUAN FRANCISCO MALDONADO,18. ODWIN DODANIM PENA,19. CARLOS OMAR PENA-VARGAS,22. VICTOR HUGO GOMEZ,33. GERARDO GARCIA,

2)

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36. CARLOS LIZARDI DEL VALLE AKA "YORKJE'"37. ALFONSO MARTINEZ-SOTO AKA "MATRACA" AKA "LILO" AKA "FLACO'"41. MOISES CAMPOS-ESPINOSA AKA "CHICHE", and56. ELMER ALEXANDER MACHADO AKA "MEME'"

that, upon conviction of a conspiracy in violation of Title 18, United States Code, Section 1956(h),

a violation of Title I8, United States Code, Sections 1956(aXlXBXi) or (ii), or of a violation of

Title 18, United States Code, Sections 1956(a)(2)(B)(i) or (ii), as charged in Counts TWO,

THREE, FOUR, SEVEN, SXTEEN, TWENTY-SIX, and FORTY-THREE of the Indictment, all

property, real or personal, involved in such money laundering offenses or traceable to such

property, is subject to forfeiture to the United States.

PROPERTY SUBJECT TO FORFEITURE

The property to be forfeited includes, but is not limited to, approximately $10 million in

United States currency.

MONEY JUDGMENT

Defendants are notified that upon conviction, a money judgment may be imposed equal to

the value ofthe property subject to forfeiture, for which the defendants may be jointly and severally

liable.

SUBSTITUTE ASSETS

In the event the property that is subject to forfeiture, as a result of any act of omission of

the defendants

(1) cannot be located upon the exercise ofdue diligence;

(2) has been transferred or sold to, or deposited with, a third party;

(3) has been placed beyond the jurisdiction of the court;

(4) has been substantially diminished in value; or

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(5) has been commingled with other property which cannot be divided without

difficulty,

the United States will seek to forfeiture any other property of the defendants up to the total value

of the property subject to forfeiture, pursuant to Title 21, United States Code, Section 853(p), and

Title 18, United States Code, Section 982(b).

A TRUE BILL:

ORIGINAL SIGNATURE ON FILE

FOEEPERSON OF THE GRAND JURY

RYAN K. PATRICKUMTED STATES

By: /,A. CUSICK

Assistant United States Attorney

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