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8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 October 2016 Grand Jury

11 UNITED STATES OF AMERICA, CR No. 17-432(A)

12 Plaintiff, F I R S T
S U P E R S E D I N G
- ---------
I N D I C T ME N T
13 v.

14 ANGEL HUMBERTO CHAVEZ-GASTELUM, [21 U.S.C. § 846: Conspiracy to

aka "Don Angel," Distribute and to Possess with
15 aka "GTS," Intent to Distribute Cocaine; 21
aka "Borre," U.S.C. § 963: Conspiracy to Import
16 aka "Bose," Cocaine and to Distribute Cocaine
aka "Netflix," for the Purpose of Unlawful
17 aka "Madrid," Importation; 21 U.S.C. §§ 959(c),
aka "Rolex," 960(a) (3), (b) (1) (B): Possession
18 aka "Kuwait," With Intent to Distribute Cocaine
aka "Richard Milleo," on Board a United States-
19 aka "Huracan," Registered Aircraft; 21 U.S.C.
aka "Bally," §§ 841 (a) (1), (b) (1) (A) (ii) :
20 aka "Ricky Luis," Distribution and Possession with
aka "Perrier," Intent to Distribute Cocaine; 21
21 aka "Rosalba," U. S.C. §§ 841(a) (1),
aka "Nestea," (b) (1) (A) (viii) : Possession of
22 VICTOR HUGO CUELLAR-SILVA, Methamphetamine with Intent to
aka "Spartacus," Distribute; 21 U.S.C. §§ 959(a),
23 aka "Junior," 960 (a) (3), (b) (1) (B): Distribution
aka "Pitbull," of Cocaine for Purpose of Unlawful
24 aka "Black Sails," Importation; 18 U.S.C.
aka "A 45 AMG," § 924 (c) (1) (A) (i): Possession of a
25 aka "Wolverine," Firearm in Furtherance of Drug
aka "Sons of Anarchy," Trafficking Crime; 21 U.S.C.
26 DIEGO FERNANDO ANZOLA-GALINDO, §§ 848 (a), (b) : Continuing
aka "Aleman," Criminal Enterprise; 46 U.S . C.
27 aka "Aleman New," § 70506(b): Conspiracy to Possess
aka "Pastor Aleman," with Intent to Distribute Cocaine
28 aka "Lord of War," on Board a Vessel Subject to
 1 ALONSO JAIME GASTELUM-SALAZAR, United States Jurisdiction; 21
aka "Rito," U.S.C. § 846: Conspiracy to
2 aka "R2 5 , " Distribute and to Possess with
aka "R28," Intent to Distribute Heroin; 18
3 aka "Rito 114," U.S.C. § 1956(h): Conspiracy to
aka "R14," Launder Monetary Instruments; 21
4 aka "Rito 12," U.S.C. § 848 (e) (1) (A): Murder in
aka "Karate Kid," Connection with a Continuing
5 JESUS HERIBERTO PELAYO AGUILAR, Criminal Enterprise and a Drug
aka "Epa Chepa," Crime; 18 U.S.C. § 2(a): Aiding
6 aka "Luis XIII," and Abetting; 21 U.S.C. § 853; 18
aka "Ramon Ayala," u.s.c. § 924(d); 28 u.s.c.
7 aka "Pancho Barraza," § 2461(c); 46 U.S.C. § 70507(a);
JESUS ALBINO QUINTERO-MERAZ, 18 U.S.C. § 982(a) (1): Criminal
8 aka "Albi," Forfeiture]
aka "Emperador,"
9 aka "Don Beto,"
aka "Taewon,"
10 JULIAN ANDRES GONZALEZ-MORENO,
aka "Chiqui,"
11 aka "Enano,"
aka "Monstruo,"
12 aka "Goliath,"
aka "Braulio,"
13 aka "Gerente,"
aka "El Cabo,"
14 TULIO ALFONSO OCAMPO-GARCIA,
aka "Tulio Alfonso Ocampo,"
15 aka "El Flako,"
RICARDO GARCIA URQUIZA,
16 aka "El Doctor,"
aka "McK, "
17 aka "Javier,"
aka "Mike,"
18 aka "Mak,"
OMAR RICARDO TINAJERO-CORTES,
19 aka "Elvis,"
aka "Joel Tirado,"
20 FNU LNU,
aka "TNT,"
21 aka "TTE,"
aka "Teniente,"
22 aka "FX,"
FNU LNU,
23 aka "Profeta"
aka "Profeta Nuevo,"
24 aka "Jose,"
JOSE LUIS OJEDA AGUIRRE,
25 aka "Gerencia Tijuana,"
aka "Zona Noroeste,"
26 FNU LNU,
aka "Servi,"
27 RUPERT BAZIL DE LAS CASAS,
aka "Jagger,"
28 GERMAN DAVID HERNANDEZ DE LA

2
 1 TORRE,
aka "Camilo Espitia,"
2 MARVIN YANNICK HENDRICKS,
aka "Negrito,"
3 JORGE BAZUA BELTRAN,
aka "Don Taco,"
4 AURELIO VALENZUELA,
aka "Duende,"
5 aka "Casimiro,"
aka "Iraki,"
6 OSWALDO CAMACHO RUIZ,
aka "Oscar,"
7 YAMITH JAIMES-GUERRERO,
aka "Ingeniero,"
8 JEYSON FERLEY GALVIS-MONROY,
aka "Rodri Chaparito,"
9 JUAN CARLOS PRADO-ROMERO,
aka "Don Jose,"
10 aka "Mono,"
CARLOS EDUARDO GONZALEZ-BERRIO,
11 aka "Liche,"
FNU LNU,
12 aka "Miguel Lara,"
VERONICA BRAVO-PUERTA,
13 aka "Chikirukis,"
aka "Chaa,"
14 aka "CHPS,"
aka "La Tortu,"
15 aka "Cheetara,"
aka "La Chapis,"
16 YESENIA ISAMAR CHAIDEZ REYES,
aka "Bella,"
17 aka "Negrita,"
FNU LNU,
18 aka "Javonaso,"
aka "Perla,"
19 FNU LNU,
aka "Tio Fred,"
20 AMPARO YOKASTA MELO-PEGUERO,
aka "La Guera,"
21 aka "bani ban,"
aka "Black04,"
22 aka "Trinidad Sanchez,"
aka "Amparo Cornielle,"
23 aka "Amparo Y. Melo,"
aka "Amparo Y. Melo de
24 Cornielle,"
aka "la reina de la H,"
25 HUGO ATIENZO,
aka "Roberto Cazares,"
26 ERICK DURAN,
aka "Mechanico,"
27 JUAN ANTONIO BRIZUELA,
aka "El Osito,"
28 aka "Oso,"

3
 1 aka "Ximena,"
aka "the Main Guy from LA,"
2 FNU LNU,
aka "El Semental,"
3 JUAN CARLOS BRIZUELA,
aka "Juan C,"
4 JONATHAN ZAMORA,
aka "JR,"
5 GERARDO MOJARRO,
JORGE CARBAJAL,
6 NIKOLA VLAHOVIC,
MARIA CLAUDIA PEREZ DE TAPIA,
7 aka "Maria Claudia Tapia,"
aka "the Nurse,"
8 ABRAHAM VIVANCO LEON,
JESUS MANUEL VASQUEZ MONRREAL,
9 aka "the Doctor,"
RICHARD FITZROY DENNIS,
10 aka "Rick,"
SALVADOR MURILLO MENDOZA,
11 FLOR RAQUEL DIAZ BARRANZA,
JOSE PONCE SEGURA,
12 aka "Guicho," and
ALEXANDRO GONZALEZ,
13 aka "Mulo, "

14 Defendants.

15

16 The Grand Jury charges:

17 COUNT ONE

18 [21 u.s.c. § 846]

19 Beginning on a date unknown, and continuing to on or around

20 October 25, 2017, in Los Angeles County, within in the Central

21 District of California, in the countries of Mexico and Colombia, and

22 elsewhere, defendants ANGEL HUMBERTO CHAVEZ-GASTELUM, also known as

23 ("aka") "Don Angel," aka "GTS," aka "Borre," aka "Bose," aka

24 "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait," aka "Richard

25 Millea," aka "Huracan," aka "Bally," aka "Ricky Luis," aka "Perrier,"

26 aka "Rosalba," aka "Nestea," VICTOR HUGO CUELLAR-SILVA, aka

27 "Spartacus," aka "Junior," aka "Pitbull," aka "Black Sails," aka "A

28 45 AMG," aka "Wolverine," aka "Sons of Anarchy," DIEGO FERNANDO

4
 1 ANZOLA-GALINDO, aka "Aleman," aka "Aleman New," aka "Pastor Aleman,"

2 aka "Lord of War," ALONSO JAIME GASTELUM-SALAZAR, aka "Rito," aka

3 "R25," aka "R28," aka "Rito 114," aka "R14," aka "Rito 12," aka

4 "Karate Kid," JESUS HERIBERTO PELAYO AGUILAR, aka "Epa Chepa," aka

5 "Luis XIII," aka "Ramon Ayala," aka "Pancho Barraza," JESUS ALBINO

6 QUINTERO-MERAZ, aka "Albi," aka "Emperador," aka "Don Beto," aka

7 "Taewon," JULIAN ANDRES GONZALEZ-MORENO, aka "Chiqui," aka "Enano,"

8 aka "Monstruo," aka "Goliath," aka "Braulio," aka "Gerente," aka "El

9 Cabo," TULIO ALFONSO OCAMPO-GARCIA, aka "Tulio Alfonso Ocampo," aka

10 "El Flako," RICARDO GARCIA URQUIZA, aka "El Doctor," aka "McK," aka

11 "Javier," aka "Mike," aka "Mak," OMAR RICARDO TINAJERO-CORTES, aka

12 "Elvis," aka "Joel Tirado," FIRST NAME UNKNOWN ("FNU") LAST NAME

13 UNKNOWN ("LNU"), aka "TNT," aka "TTE," aka "Teniente," aka "FX," FNU

14 LNU, aka "Profeta," aka "Profeta Nuevo," aka "Jose," JOSE LUIS OJEDA

15 AGUIRRE, aka "Gerencia Tijuana," aka "Zona Noroeste," FNU LNU, aka

16 "Servi," RUPERT BAZIL DE LAS CASAS, aka "Jagger," GERMAN DAVID

17 HERNANDEZ DE LA TORRE, aka "Camilo Espitia," MARVIN YANNICK

18 HENDRICKS, aka "Negrito," JORGE BAZUA BELTRAN, aka "Don Taco,"

19 AURELIO VALENZUELA, aka "Duende," aka "Casimiro," aka "Iraki,"

20 OSWALDO CAMACHO RUIZ, aka "Oscar," YAMITH JAIMES-GUERRERO, aka

21 "Ingeniero," JEYSON FERLEY GALVIS-MONROY, aka "Rodri Chaparito,"

22 VERONICA BRAVO-PUERTA, aka "Chikirukis," aka "Chaa," aka "CHPS," aka

23 "La Tortu," aka "Cheetara," aka "La Chapis," YESENIA ISAMAR CHAIDEZ

24 REYES, aka "Bella," aka "Negrita," FNU LNU, aka "Javonaso," aka

25 "Perla," FNU LNU, aka "Tio Fred," HUGO ATIENZO, aka "Roberto

26 Cazares," ERICK DURAN, aka "Mechanico," JUAN ANTONIO BRIZUELA, aka

27 "El Osito," aka "Oso," aka "'Ximena," aka "the Main Guy from LA," FNU

28 LNU, aka "El Semental," JUAN CARLOS BRIZUELA, aka "Juan C," JONATHAN

5
 1 ZAMORA, aka "JR," GERARDO MOJARRO, JORGE CARBAJAL, NIKOLA VLAHOVIC,

2 MARIA CLAUDIA PEREZ DE TAPIA, aka "Maria Claudia Tapia," aka "the

3 Nurse," ABRAHAM VIVANCO LEON, JESUS MANUEL VASQUEZ MONRREAL, aka "the

4 Doctor," RICHARD FITZROY DENNIS, aka "Rick," SALVADOR MURILLO

5 MENDOZA, FLOR RAQUEL DIAZ BARRANZA, JOSE PONCE SEGURA, aka "Guicho,"

6 and ALEXANDRO GONZALEZ, aka "Mulo," together with co-conspirators

7 Dicson Penagos-Casanova and Juan Gabriel Rios Sierra, and others

8 known and unknown to the Grand Jury, conspired and agreed with each

9 other to knowingly and intentionally distribute, and possess with

10 intent to distribute, at least five kilograms of a mixture and

11 substance containing a detectable amount of cocaine, a Schedule II

12 narcotic drug controlled substance, in violation of Title 21, United

13 States Code, Sections 841 (a) (1), (b) (1) (A) (ii).

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 1 COUNT TWO

2 [21 u.s.c. § 963]

3 Beginning on a date unknown, and continuing to on or around

4 October 25, 2017, in Los Angeles County, within the Central District

5 of California, and in the countries of Mexico and Colombia, and

6 elsewhere, defendants ANGEL HUMBERTO CHAVEZ-GASTELUM, also known as

7 ( "aka 11 ) "Don Angel, 11

aka "GTS, 11
aka "Borre, 11
aka "Bose, 11
aka

8 "Netf lix, 11
aka "Madrid, 11
aka "Rolex, 11
aka "Kuwait,,, aka "Richard

9 Milleo, 11
aka "Huracan, 11
aka "Bally, 11
aka "Ricky Luis, 11
aka "Perrier, 11

10 aka "Rosalba, 11 aka "Nestea, 11 VICTOR HUGO CUELLAR-SILVA, aka

11 "Spartacus, 11
aka "Junior, 11
aka "Pi tbull, 11
aka "Black Sails,'' aka "A

12 45 AMG, 11
aka "Wolverine, 11 aka "Sons of Anarchy, 11
DIEGO FERNANDO

13 ANZOLA-GALINDO, aka "Aleman, 11 aka "Aleman New, 11

aka "Pastor Aleman, 11

14 aka "Lord of War, 11

ALONSO JAIME GASTELUM-SALAZAR, aka "Rito,'1 aka

15 "R25, 11
aka "R28, 11
aka "Rito 114, 11 aka "R14, 11 aka "Rito 12, 11 aka

16 "Karate Kid, 11
JESUS HERIBERTO PELAYO AGUILAR, aka "Epa Chepa, ,, aka

17 "Luis XIII,'1 aka "Ramon Ayala,'1 aka "Pancho Barraza, 11 JESUS ALBINO

18 QUINTERO-MERAZ, aka "Albi, 11

aka "Emperador, 11
aka "Don Beto, 11
aka

19 "Taewon,'1 JULIAN ANDRES GONZALEZ-MORENO, aka "Chiqui, 11 aka "Enano, 1

'

20 aka "Monstruo, 11 aka "Goliath, 11 aka "Braulio, 11

aka "Gerente, 11
aka "El

21 Cabo, 11
TULIO ALFONSO OCAMPO-GARCIA, aka "Tulio Alfonso Ocampo, 11
aka

22 "El Flako, 11
RICARDO GARCIA URQUIZA, aka "El Doctor, 11
aka "McK, 11
aka

23 "Javier, 11 aka "Mike, 11

aka "Mak, 11
OMAR RICARDO TINAJERO-CORTES, aka

24 "El vis, 11
aka "Joel Tirado, 11
FIRST NAME UNKNOWN ( "FNU11 ) LAST NAME

25 UNKNOWN ("LNU 11 ) , aka "TNT, 11

aka "TTE, 11 aka "Teniente, 11 aka "FX, 11
FNU

26 LNU, aka "Profeta, 11

aka "Profeta New, 11
aka "Jose, 11 JOSE LUIS OJEDA

27 AGUIRRE, aka "Gerencia Tijuana, 11

aka "Zona Noroeste, 11
FNU LNU, aka

28 "Servi, 11
RUPERT BAZIL DE LAS CASAS, aka "Jagger, 11
GERMAN DAVID

7
 1 HERNANDEZ DE LA TORRE, aka "Camilo Espitia," MARVIN YANNICK

2 HENDRICKS, aka "Negrito," JORGE BAZUA BELTRAN, aka "Don Taco,"

3 AURELIO VALENZUELA, aka "Duende," aka "Casimiro," aka "Iraki,"

4 OSWALDO CAMACHO RUIZ, aka "Oscar," YAMITH JAIMES-GUERRERO, aka

5 "Ingeniero," JEYSON FERLEY GALVIS-MONROY, aka "Rodri Chaparito,"

6 VERONICA BRAVO-PUERTA, aka "Chikirukis," aka "Chaa," aka "CHPS," aka

7 "La Tortu," aka "Cheetara," aka "La Chapis," YESENIA ISAMAR CHAIDEZ

8 REYES, aka "Bella," aka "Negrita," FNU LNU, aka "Javonaso," aka

9 "Perla," FNU LNU, aka "Tio Fred," HUGO ATIENZO, aka "Roberto

10 Cazares," ERICK DURAN, aka "Mechanico," JUAN ANTONIO BRIZUELA, aka

11 "El Osito," aka "Oso," aka "Ximena," aka "the Main Guy from LA," FNU

12 LNU, aka "El Semental," JUAN CARLOS BRIZUELA, aka "Juan C," JONATHAN

13 ZAMORA, aka "JR," and MARIA CLAUDIA PEREZ DE TAPIA, aka "Maria

14 Claudia Tapia," aka "the Nurse," together with co-conspirators Dicson

15 Penagos-Casanova and Juan Gabriel Rios Sierra, and others known and

16 unknown to the Grand Jury, conspired and agreed with each other to

17 knowingly and intentionally import into the United States, and to

18 knowingly and intentionally distribute for the purpose of such

19 importation, at least five kilograms of a mixture and substance

20 containing a detectable amount of cocaine, a Schedule II narcotic

21 drug controlled substance, in violation of Title 21, United States

22 Code, Sections 952 (a), 959 (a), and 960 (a) (1), (a) (3), and

23 (b) (1) (B) (ii).

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 1 COUNT THREE

2 [21 U.S.C. §§ 959 (c) 1 960 (a) (3) 1 (b) (1) (B) (ii)]

3 On or about May 20 1 2015 1 in the country of Colombia 1 and

4 elsewhere 1 defendant YAMITH JAIMES-GUERRER0 1 also known as

5 "Ingeniero 1 11 who will be arrested and first brought to the Central

6 District of California 1 together with Dicson Penagos-Casanova and

7 others known and unknown to the Grand Jury 1 knowingly and

8 intentionally possessed with intent to distribute at least five

9 kilograms 1 that is, approximately 1,329 kilograms, of a mixture and

10 substance containing a detectable amount of cocaine, a Schedule II

11 narcotic drug controlled substance, while on board an aircraft

12 registered in the United States and owned by a United States citizen.

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 1 COUNT FOUR

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about May 14, 2015, in Los Angeles County, within the

4 Central District of California, and elsewhere, defendants ANGEL

5 HUMBERTO CHAVEZ-GASTELUM, also known as ("aka") "Don Angel," aka

6 "GTS," aka "Borre," aka "Bose," aka "Netflix," aka "Madrid," aka

7 "Rolex," aka "Kuwait," aka "Richard Millea," aka "Huracan," aka

8 "Bally," aka "Ricky Luis," aka "Perrier," aka "Rosalba," aka

9 "Nestea," and HUGO ATIENZO, aka "Roberto Cazares," knowingly and

10 intentionally possessed with intent to distribute at least five

11 kilograms, that is, approximately 50 kilograms, of a mixture and

12 substance containing a detectable amount of cocaine, a Schedule II

13 narcotic drug controlled substance.

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 1 COUNT FIVE

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about September 16, 2015, in Los A~geles County, within

4 the Central District of California, defendants ANGEL HUMBERTO CHAVEZ-

5 GASTELUM, also known as ("aka") "Don Angel," aka "GTS," aka "Borre,"

6 aka "Bose," aka "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait,"

7 aka "Richard Milleo," aka "Huracan," aka "Bally," aka "Ricky Luis,"

8 aka "Perrier," aka "Rosalba," aka "Nestea," ALONSO JAIME GASTELUM-

9 SALAZAR, aka "Rito," aka "R25," aka "R28," aka "Rito 114," aka "R14,"

10 aka "Rito 12," aka "Karate Kid," and JORGE CARBAJAL knowingly and

11 intentionally distributed at least five kilograms, that is,

12 approximately 29.04 kilograms, of a mixture and substance containing

13 a detectable amount of cocaine, a Schedule II narcotic drug

14 controlled substance.

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 1 COUNT SIX

2 [21 U.S.C. §§ 841(a) (1), (b) (1) (A) (ii)]

3 On or about September 16, 2015, in Los Angeles County, within

4 the Central District of California, defendant NIKOLA VLAHOVIC

5 knowingly and intentionally possessed with intent to distribute at

6 least five kilograms, that is, approximately 29.04 kilograms, of a

7 mixture and substance containing a detectable amount of cocaine, a

8 Schedule II narcotic drug controlled substance.

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 1 COUNT SEVEN

2 [21 U.S.C. §§ 841(a) (1), (b) (1) (A) (viii)]

3 On or about December 8, 2015, in Los Angeles County, within the

4 Central District of California, defendants ANGEL HUMBERTO CHAVEZ-

5 GASTELUM, also known as ( "aka 11

) "Don Angel, 11
aka "GTS, 11
aka "Borre, 11

6 aka "Bose, 11
aka "Netflix, 11
aka "Madrid, 11
aka "Rolex, 11
aka "Kuwait, 11

7 aka "Richard Milleo, 11

aka "Huracan, 11
aka "Bally, 11
aka "Ricky Luis, 11

8 aka "Perrier, 11
aka "Rosalba, 11
aka "Nestea, 11
and ERICK DURAN, aka

9 "Mechanico, 11
knowingly and intentionally possessed with intent to

10 distribute at least 50 grams, that is, approximately 730 grams, of

11 methamphetamine, a Schedule II controlled substance.

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 1 COUNT EIGHT
2 [21 U.S.C. §§ 959 (a), 960 (a) (3), (b) (1) (B)] ·

3 On or about February 15, 2016, in the country of Mexico, and

4 elsewhere, defendants ANGEL HUMBERTO CHAVEZ-GASTELUM, also known as

5 ("aka") "Don Angel," aka "GTS," aka "Borre," aka "Bose," aka

6 "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait," aka "Richard

7 Millea," aka "Huracan," aka "Bally," aka "Ricky Luis," aka "Perrier,"

8 aka "Rosalba," aka "Nestea," and JESUS HERIBERTO PELAYO AGUILAR, aka

9 "Epa Chepa," aka "Luis XIII," aka "Ramon Ayala," aka "Pancho

10 Barraza," who will be arrested and first brought to the Central

11 District of California, together with others known and unknown to the

12 Grand Jury, knowingly and intentionally distributed at least five

13 kilograms, that is, approximately 17 kilograms, of a mixture and

14 substance containing a detectable amount of cocaine, a Schedule II

15 narcotic drug controlled substance, knowing and intending that such

16 substance would be unlawfully imported into the United States.

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 1 COUNT NINE

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about February 16, 2016, in Los Angeles County, within the

4 Central District of California, and elsewhere, defendants ANGEL

5 HUMBERTO CHAVEZ-GASTELUM, also known as ("aka") "Don Angel," aka

6 "GTS," aka "Borre," aka "Bose," aka "Netflix," aka "Madrid," aka

7 "Rolex," aka "Kuwait," aka "Richard Milleo," aka "Huracan," aka

8 "Bally," aka "Ricky Luis," aka "Perrier," aka "Rosalba," aka

9 "Nestea," JESUS HERIBERTO PELAYO AGUILAR, aka "Epa Chepa," aka "Luis

10 XIII," aka "Ramon Ayala," aka "Pancho Barraza," and JUAN ANTONIO

11 BRIZUELA, aka "El Osito," aka "Oso," aka "Ximena," aka "the Main Guy

12 from LA," knowingly and intentionally possessed with intent to

13 distribute at least five kilograms, that is, approximately 17

14 kilograms, of a mixture and substance containing a detectable amount

15 of cocaine, a Schedule II narcotic drug controlled substance.

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 1 COUNT TEN

2 [21 U.S.C. §§ 959(a), 960(a) (3), (b) (1) (B)]

3 On or about August 4, 2016, in the country of Mexico, and

4 elsewhere, defendants JOSE LUIS OJEDA AGUIRRE, also known as ("aka")

5 "Gerencia Tijuana," aka "Zona Noroeste," and FIRST NAME UNKNOWN, LAST

6 NAME UNKNOWN, aka "Servi," who will be arrested and first brought to

7 the Central District of California, together with others known and

8 unknown to the Grand Jury, knowingly and intentionally distributed at

9 least five kilograms, that is, approximately 14.01 kilograms, of a

10 mixture and substance containing a detectable amount of cocaine, a

11 Schedule II narcotic drug controlled substance, knowing, intending,

12 and having reasonable cause to believe that such substance would be

13 unlawfully imported into the United States.

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 1 COUNT ELEVEN

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about August 5, 2016, in Los Angeles County, within the

4 Central District of California, defendants JOSE LUIS OJEDA AGUIRRE,

5 also known as ("aka") "Gerencia Tijuana," aka "Zona Noroeste," FIRST

6 NAME UNKNOWN, LAST NAME UNKNOWN, aka "Servi," and MARIA CLAUDIA PEREZ

7 DE TAPIA, aka "Maria Claudia Tapia," aka "the Nurse," knowingly and

8 intentionally distributed at least five kilograms, that is,

9 approximately 14.01 kilograms, of a mixture and substance containing

10 a detectable amount of cocaine, a Schedule II narcotic drug

11 controlled substance.

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 1 COUNT TWELVE

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about August 5, 2016, in Los Angeles County, within the

4 Central District of California, defendant ABRAHAM VIVANCO LEON

5 knowingly and intentionally possessed with intent to distribute at

6 least five kilograms, that is, approximately 47.81 kilograms, of a

7 mixture and substance containing a detectable amount of cocaine, a

8 Schedule II narcotic drug controlled substance.

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18

19

20

21

22

23

24

25

26

27

28
18
 1 COUNT THIRTEEN

2 [21 U.S.C. §§ 841(a) (1), (b) (1) (A) (viii)]

3 On or about August 5, 2016, in Los Angeles County, within the

4 Central District of California, defendant ABRAHAM VIVANCO LEON

5 knowingly and intentionally possessed with intent to distribute at

6 least fifty grams, that is, approximately 209.8 grams, of

7 methamphetamine, a Schedule II controlled substance.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

19
 1 COUNT FOURTEEN

2 [21 U.S.C. §§ 84l(a) (1), (b) (1) (A) (ii)]

3 On or about February 2, 2017, in Los Angeles County, within the

4 Central District of California, defendants ANGEL HUMBERTO CHAVEZ-

5 GASTELUM, also known as ("aka") "Don Angel," aka "GTS," aka "Borre,"

6 aka "Bose," aka "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait,"

7 aka "Richard Millea," aka "Huracan," aka "Bally," aka "Ricky Luis,"

8 aka "Perrier," aka "Rosalba," aka "Nestea," JESUS HERIBERTO PELAYO

9 AGUILAR, aka "Epa Chepa," aka "Luis XIII," aka "Ramon Ayala," aka

10 "Pancho Barraza," FIRST NAME UNKNOWN, LAST NAME UNKNOWN, aka "El

11 Semental," and JESUS MANUEL VASQUEZ MONRREAL, aka "the Doctor,"

12 knowingly and intentionally distributed at least five kilograms, that

13 is, approximately 8.01 kilograms, of a mixture and substance

14 containing a detectable amount of cocaine, a Schedule II narcotic

15 drug controlled substance.

16

17

18

19

20

21

22

23

24

25

26

27

28

20
 1 COUNT FIFTEEN

2 [21 U.S.C. §§ 841 (a) (1), (b) (1) (A) (ii)]

3 On or about February 2, 2017, in Los Angeles County, within the

4 Central District of California, defendant RICHARD FITZROY DENNIS,

5 also known as "Rick," knowingly and intentionally possessed with

6 intent to distribute at least five kilograms, that is, approximately

7 8.01 kilograms, of a mixture and substance containing a detectable

8 amount of cocaine, a Schedule II narcotic drug controlled substance.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

21
 1 COUNT SIXTEEN

2 [18 U.S.C. § 924 (c) (1) (A) (i)]

3 On or about February 2, 2017, in Los Angeles County, within the

4 Central District of California, defendant RICHARD FITZROY DENNIS,

5 also known as "Rick," knowingly possessed a firearm, namely, a

6 Springfield Armory model 1911Al Micro Compact .45 ACP caliber pistol,

7 bearing serial number N448061, in furtherance of a drug trafficking

8 crime, namely:

9 (1) Conspiracy to Distribute Cocaine, in violation of Title 21,

10 United States Code, Section 846, as charged in Count One of this

11 First Superseding Indictment; and

12 (2) Possession with Intent to Distribute Cocaine, in violation

13 of Title 21, United States Code, Sections 841 (a) (1), (b) (1) (A) (ii),

14 as charged in Count Fifteen of this First Superseding Indictment.

15

16

17

18

19

20

21

22

23

24

25

26

27

28

22
 1 COUNT SEVENTEEN

2 [21 U.S.C. §§ 848 (a), (b)]

3 Beginning on an unknown date, and continuing to on or about

4 October 25, 2017, in Los Angeles County, within the Central District

5 of California, and elsewhere, defendants ANGEL HUMBERTO CHAVEZ-

6 GASTELUM, also known as ("aka") "Don Angel," aka "GTS," aka "Borre,"

7 aka "Bose," aka "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait,"

8 aka "Richard Millea," aka "Huracan," aka "Bally," aka "Ricky Luis,"

9 aka "Perrier," aka "Rosalba," aka "Nestea" ("CHAVEZ-GASTELUM"),

10 VICTOR HUGO CUELLAR-SILVA, aka "Spartacus," aka "Junior," aka

11 "Pitbull," aka "Black Sails," aka "A 45 AMG," aka "Wolverine," aka

12 "Sons of Anarchy" ("CUELLAR-SILVA"), DIEGO FERNANDO ANZOLA-GALINDO,

13 aka "Aleman," aka "Aleman New," aka "Pastor Aleman," aka "Lord of

14 War" ("ANZOLA-GALINDO"), ALONSO JAIME GASTELUM-SALAZAR, aka "Rito,"

15 aka "R25," aka "R28," aka "Rito 114," aka "R14," aka "Rito 12," aka

16 "Karate Kid" ("GASTELUM-SALAZAR"), and JESUS HERIBERTO PELAYO

17 AGUILAR, aka "Epa Chepa," aka "Luis XIII," aka "Ramon Ayala," aka

18 "Pancho Barraza" ("PELAYO"), engaged in a continuing criminal

19 enterprise in that defendants CHAVEZ-GASTELUM, CUELLAR-SILVA, ANZOLA-

20 GALINDO, GASTELUM-SALAZAR, and PELAYO knowingly and intentionally

21 violated Title 21, United States Code, Sections 84l(a) (1), 846, 959,

22 963, and 960(a) (2), (a) (3), by committing violations, including, but

23 not limited to, the felony violations alleged in Counts One, Two,

24 Four, Five, Seven, Eight, Nine, and Fourteen which Counts are re-

25 alleged and incorporated herein by reference as if fully set forth in

26 this Count, all of which violations were part of a continuing series

27 of felony violations of subchapters I and II of Title 21 of the

28 United States Code, undertaken by defendants CHAVEZ-GASTELUM,

23
 1 CUELLAR-SILVA, ANZOLA-GALINDO, GASTELUM-SALAZAR, and PELAYO in

2 concert with at least five other persons with respect to whom

3 defendants CHAVEZ-GASTELUM, CUELLAR-SILVA, ANZOLA-GALINDO, GASTELUM-

4 SALAZAR, and PELAYO occupied a position of organizer, supervisor, and

5 manager, and from which continuing series of violations defendants

6 CHAVEZ-GASTELUM, CUELLAR-SILVA, ANZOLA-GALINDO, GASTELUM-SALAZAR, and

7 PELAYO obtained substantial income and resources.

8 Furthermore, defendant CHAVEZ-GASTELUM was a principal

9 administrator, organizer, and leader of the criminal enterprise,

10 which involved the possession with intent to distribute and

11 distribution of at least 150 kilograms of a mixture and substance

12 containing a detectable amount of cocaine, a Schedule II narcotic

13 drug controlled substance.

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

24
 1 COUNT EIGHTEEN

2 [46 u.s.c. § 70506 (b)]

3 Beginning on a date unknown, and continuing to on or about

4 January 24, 2017, in the countries of Mexico, Colombia, and

5 elsewhere, defendants VICTOR HUGO CUELLAR-SILVA, also known as

6 ("aka") "Spartacus," aka "Junior," aka "Pi tbull," aka "Black Sails,"

7 aka "A 45 AMG," aka "Wolverine," aka "Sons of Anarchy," DIEGO

8 FERNANDO ANZOLA-GALINDO, aka "Aleman," aka "Aleman New," aka "Pastor

9 Aleman," aka "Lord of War," JUAN CARLOS PRADO-ROMERO, aka "Don Jose,"

10 aka "Mono," CARLOS EDUARDO GONZALEZ-BERRIO, aka "Liche," and FIRST

11 NAME UNKNOWN ("FNU") LAST NAME UNKNOWN ("LNU"), aka "Miguel Lara,"

12 each of whom will be arrested and first brought to the Central

13 District of California, and others known and unknown to the Grand

14 Jury, conspired and agreed with each other to knowingly and

15 intentionally possess with intent to distribute at least five

16 kilograms, that is, approximately 833 kilograms, of a mixture and

17 substance containing a detectable amount of cocaine, a Schedule II

18 narcotic drug controlled substance, on board a vessel subject to the

19 jurisdiction of the United States, in violation of Title 46, United

20 States Code, Section 70503(a) (1) and Title 21, United States Code,

21 Section 960 (b) (1) (B) .

22

23

24

25

26

27

28
25
 1 COUNT NINETEEN

2 [21 u.s.c. § 846]

3 Beginning on a date unknown 1 and continuing to on or about

4 October 25 1 2017 1 in Los Angeles County 1 within the Central District

5 of California 1 and elsewhere 1 defendants JESUS HERIBERTO PELAYO

6 AGUILAR 1 also known as ( "aka 11

) "Epa Chepa 1
11
aka "Luis XIII, 11
aka

7 "Ramon Ayala 1 11
aka "Pancho Barraza, 11
and AMPARO YOKASTA MELO-PEGUER0 1

8 aka "La Guera, 11

aka "bani ban 1
11
aka "Black04 1 11
aka "Trinidad

9 Sanchez 1 11
aka "Amparo Corniel le," aka "Amparo Y. Melo 1 11
aka "Amparo

10 Y. Melo de Cornielle, 11
aka "la reina de la H1 11
and others known and

11 unknown to the Grand Jury, conspired and agreed with each other to

12 knowingly and intentionally distribute 1 and to possess with intent to

13 distribute 1 at least one kilogram of a mixture and substance

14 containing a detectable amount of heroin 1 a Schedule I controlled

15 substance, in violation of Title 21, United States Code 1 Sections

16 841 (a) (1), (b) (1) (A) (i).

17

18

19

20

21

22

23

24

25

26

27

28

26
 1 COUNT TWENTY

2 [18 u.s.c. § 1956(h)]

3 Beginning on a date unknown, and continuing to at least on or

4 about October 25, 2017, in Los Angeles County, within the Central

5 District of California, and elsewhere, defendants ANGEL HUMBERTO

6 CHAVEZ-GASTELUM, also known as ("aka") "Don Angel," aka "GTS," aka

7 "Borre," aka "Bose," aka "Netflix," aka "Madrid," aka "Rolex," aka

8 "Kuwait," aka "Richard Milleo," aka "Huracan," aka "Bally," aka

9 "Ricky Luis," aka "Perrier," aka "Rosalba," aka "Nestea," VICTOR HUGO

10 CUELLAR-SILVA, aka "Spartacus," aka "Junior," aka "Pitbull," aka

11 "Black Sails," aka "A 45 AMG," aka "Wolverine," aka "Sons of

12 Anarchy," and JULIAN ANDRES GONZALEZ-MORENO, aka "Chiqui," aka

13 "Enano," aka "Monstruo," aka "Goliath," aka "Braulio," aka "Gerente,"

14 aka "El Cabo," and others known and unknown to the Grand Jury,

15 conspired and agreed with each other to knowingly and intentionally

16 commit the following offenses against the United States:

17 a. To knowingly conduct and attempt to conduct financial

18 transactions, affecting interstate and foreign commerce, knowing and

19 believing that the property involved in the financial transactions

20 represented the proceeds of some form of unlawful activity, and

21 knowing that the transactions were designed in whole and in part to

22 conceal and disguise the nature, location, source, ownership, and

23 control of the proceeds of specified unlawful activity, in violation

24 of Title 18, United States Code, Section 1956 (a) ( 1) (B) ( i) ; and

25 b. To knowingly and intentionally transport, transmit,

26 and transfer funds to a place in the United States from a place

27 outside of the United States, knowing and believing that the funds

28 involved in the transportation, transmission, and transfer

27
 1 represented some form of unlawful activity, and knowing that such

2 transportation, transmission, and transfer was designed in whole and

3 in part to conceal and disguise the nature, location, source,

4 ownership, and control of the proceeds of said specified unlawful

5 activity, in violation of Title 18, United States Code, Section

6 1956 (a) (2) (B) (i).

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

28
 1 COUNT TWENTY-ONE

2 [21 U.S.C. § 848 (e) (1) (A)]

3 On or about July 7, 2017, in Los Angeles County, within the

4 Central District of California, and elsewhere, defendants ANGEL

5 HUMBERTO CHAVEZ-GASTELUM, also known as ("aka") "Don Angel," aka

6 "GTS," aka "Borre," aka "Bose," aka "Netflix," aka "Madrid," aka

7 "Rolex," aka "Kuwait," aka "Richard Milleo," aka "Huracan," aka

8 "Bally," aka "Ricky Luis," aka "Perrier," aka "Rosalba," aka

9 "Nestea," and ALONSO JAIME GASTELUM-SALAZAR, aka "Rito," aka "R25,"

10 aka "R28," aka "Rito 114," aka "R14," aka "Rito 12," aka "Karate

11 Kid," and others known and unknown to the Grand Jury, while engaging

12 in and working in furtherance of a continuing criminal enterprise, as

13 charged in Count Seventeen of this First Superseding Indictment, and

14 while engaged in an offense punishable under Title 21, United States

15 Code, Section 841 (b) (1) (A) or 960 (b) (1),. namely:

16 (1) Conspiracy to distribute, and to possess with intent to

17 distribute, at least five kilograms of cocaine, in violation of Title

18 21, United States Code, Sections 846 and 841 (a) (1), (b) (1) (A) (ii), as

19 charged in Count One of this First Superseding Indictment; and

20 (2) Conspiracy to import, and to distribute for the purpose of

21 importation, at least five kilograms of cocaine, in violation of

22 Title 21, United States Code, Sections 963, 952(a), and 960(a) (1),

23 (a) (3), (b) (1) (B) (ii), as charged in Count Two of this First

24 Superseding Indictment;

25 intentionally killed and counseled, commanded, induced, procured, and

26 caused the intentional killing of another person, namely, Victim A,

27 and such killing did result.

28

29
 1 COUNT TWENTY-TWO

2 [21 U.S.C. § 848 (e) (1) (A)]

3 On or about July 7, 2017, in Los Angeles County, within the

4 Central District of California, and elsewhere, defendants ANGEL

5 HUMBERTO CHAVEZ-GASTELUM, also known as ("aka") "Don Angel," aka

6 "GTS," aka "Borre," aka "Bose," aka "Netflix," aka "Madrid," aka

7 "Rolex," aka "Kuwait," aka "Richard Millea," aka "Huracan," aka

8 "Bally," aka "Ricky Luis," aka "Perrier," aka "Rosalba," aka

9 "Nestea," and ALONSO JAIME GASTELUM-SALAZAR, aka "Rito," aka "R25,"

10 aka "R28," aka "Rito 114," aka "Rl4," aka "Rito 12," aka "Karate

11 Kid," and others known and unknown to the Grand Jury, while engaging

12 in and working in furtherance of a continuing criminal enterprise, as

13 charged in Count Seventeen of this First Superseding Indfctment, and

14 while engaged in an offense punishable under Title 21, United States

15 Code, Section 841 (b) (1) (A) or 960 (b) (1), namely:

16 (1) Conspiracy to distribute, and to possess with intent to

17 distribute, at least five kilograms of cocaine, in violation of Title

18 21, United States Code, Sections 846 and 841 (a) (1), (b) (1) (A) (ii), as

19 charged in Count One of this First Superseding Indictment; and

20 (2) Conspiracy to import, and to distribute for the purpose of

21 importation, at least five kilograms of cocaine, in violation of

22 Title 21, United States Code, Sections 963, 952(a), and 960(a) (1),

23 (a) (3), (b) (1) (B) (ii), as charged in Count Two of this First

24 Superseding Indictment;

25 intentionally killed and counseled, commanded, induced, procured, and

26 caused the intentional killing of another person, namely, Victim B,

27 and such killing did result.

28

30
 1 FORFEITURE ALLEGATION ONE

2 [21 u.s.c. § 853]

3 1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice

4 is hereby given to defendants ANGEL HUMBERTO CHAVEZ-GASTELUM, also

5 known as ("aka") "Don Angel, 1

' aka "GTS," aka "Borre," aka "Bose," aka

6 "Netflix, 11
aka "Madrid, 11
aka "Rolex, 11 aka "Kuwait," aka "Richard

7 Millea, 11
aka "Huracan, 11 aka "Bally, 11 aka "Ricky Luis, 11
aka "Perrier, 11

8 aka "Rosalba, 11
aka "Nestea," VICTOR HUGO CUELLAR-SILVA, aka

9 "Spartacus," aka "Junior, 11 aka "Pitbull," aka "Black Sails," aka "A

10 45 AMG, 11
aka "Wolverine," aka "Sons of Anarchy, 11
DIEGO FERNANDO

11 ANZOLA-GALINDO, aka "Aleman, 11

aka "Aleman New," aka "Pastor Aleman,"

12 aka "Lord of War, 11

ALONSO JAIME GASTELUM-SALAZAR, aka "Rito," aka

13 "R2_5," aka "R2 8," aka "Ri to 114, ,, aka "R14," aka "Ri to 12, 11
aka

14 "Karate Kid, 11
JESUS HERIBERTO PELAYO AGUILAR, aka "Epa Chepa, 11
aka

15 "Luis XIII," aka "Ramon Ayala," aka "Pancho Barraza, 11

JESUS ALBINO

16 QUINTERO-MERAZ, aka "Albi, 11

aka "Emperador, 11 aka "Don Beto," aka

17 "Taewon," JULIAN ANDRES GONZALEZ-MORENO, aka "Chiqui, 11

aka "Enano,"

18 aka "Monstruo, 11
aka "Goliath," aka "Braulio," aka "Gerente," aka "El

19 Cabo," TULIO ALFONSO OCAMPO-GARCIA, aka "Tulia Alfonso Ocampo, 11

aka

20 "El Flako," RICARDO GARCIA URQUIZA, aka "El Doctor, 11

aka "McK," aka

21 "Javier, 11 aka "Mike, 11

aka "Mak," OMAR RICARDO TINAJERO-CORTES, aka

22 "Elvis," aka "Joel Tirado," FIRST NAME UNKNOWN ("FNU 11 ) , LAST NAME

23 UNKNOWN ("LNU 11 ) , aka "TNT," aka "TTE, 11

aka "Teniente, 11 aka "FX, 11
FNU

24 LNU, aka "Profeta, 11

aka "Profeta New," aka "Jose, 11
JOSE LUIS OJEDA

25 AGUIRRE, aka "Gerencia Tijuana, 11

aka "Zona Noroeste," FNU LNU, aka

26 "Servi, 11
RUPERT BAZIL DE LAS CASAS, aka "Jagger 1 11 GERMAN DAVID

27 HERNANDEZ DE LA TORRE, aka "Camilo Espitia," MARVIN YANNICK

28 HENDRICKS, aka "Negrito," JORGE BAZUA BELTRAN, aka "Don Taco,"

31
 1 AURELIO VALENZUELA, aka "Duende," aka "Casimiro," aka "Iraki,"

2 OSWALDO CAMACHO RUIZ, aka "Oscar," YAMITH JAIMES-GUERRERO, aka

3 "Ingeniero," JEYSON FERLEY GALVIS-MONROY, aka "Rodri Chaparito,"

4 VERONICA BRAVO-PUERTA, aka "Chikirukis," aka "Chaa," aka "CHPS," aka

5 "La Tortu," aka "Cheetara," aka "La Chapis," YESENIA ISAMAR CHAIDEZ

6 REYES, aka "Bella," aka "Negrita," FNU LNU, aka "Javonaso," aka

7 "Perla," FNU LNU, aka "Tio Fred," AMPARO YOKASTA MELO-PEGUERO, aka

8 "La Guera," aka "bani ban," aka "Black04," aka "Trinidad Sanchez,"

9 aka "Amparo Cornielle," aka "Amparo Y. Melo," aka "Amparo Y. Melo de

10 Cornielle," aka "la reina de la H," HUGO ATIENZO, aka "Roberto

11 Cazares," ERICK DURAN, aka "Mechanico," JUAN ANTONIO BRIZUELA, aka

12 "El Osito," aka "Oso," aka "Ximena," aka "the Main Guy from LA," FNU

13 LNU, aka "El Semental," JUAN CARLOS BRIZUELA, aka "Juan C," JONATHAN

14 ZAMORA, aka "JR," GERARDO MOJARRO, JORGE CARBAJAL, NIKOLA VLAHOVIC,

15 MARIA CLAUDIA PEREZ DE TAPIA, aka "Maria Claudia Tapia," aka "the

16 Nurse," ABRAHAM VIVANCO LEON, JESUS MANUEL VASQUEZ MONRREAL, aka "the

17 Doctor," RICHARD FITZROY DENNIS, aka "Rick," SALVADOR MURILLO

18 MENDOZA, FLOR RAQUEL DIAZ BARRANZA, JOSE PONCE SEGURA, aka "Guicho,"

19 and ALEXANDRO GONZALEZ, aka "Mulo," that the United States will seek

20 forfeiture as part of any sentence in accordance with Title 21,

21 United States Code, Section 853, in the event of any defendant's

22 conviction under any of Counts One through Fifteen, Seventeen,

23 Nineteen, Twenty-One, or Twenty-Two of this First Superseding

24 Indictment.

25 2. Each defendant so convicted shall forfeit to the United

26 States the following:

27 a. All right, title, and interest in any and all

28 property, real or personal (i) constituting, or derived from, any

32
 1 proceeds obtained, directly or indirectly, as a result of any such

2 offense; or (ii) used, or intended to be used, in any manner or part,

3 to commit, or to facilitate the commission of, any such offense; and

4 b. To the extent any such property is not available for

5 forfeiture, a sum of money equal to the total value of the property

6 described in paragraph 2.a.

7 3. Pursuant to Title 21, United States Code, Section 853(p),

8 each defendant convicted of any of Counts One through Fifteen,

9 Seventeen, Nineteen, Twenty-One, or Twenty-Two of this First

10 Superseding Indictment shall forfeit substitute property, up to the

11 total value of the property described in paragraph 2 if, as the

12 result of any act or omission of said defendant, the property

13 described in paragraph 2, or any portion thereof: (a) cannot be

14 located upon the exercise of due diligence; (b) has been transferred,

15 sold to, or deposited with a third party; (c) has been placed beyond

16 the jurisdiction of the court; (d) has been substantially diminished

17 in value; or (e) has been commingled with other property that cannot

18 be divided without difficulty.

19

20

21

22

23

24

25

26

27

28
33
 1 FORFEITURE ALLEGATION TWO

2 [18 U.S.C. § 924(d); 28 U.S.C. § 2461(c)]

3 1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice

4 is hereby given to defendant RICHARD FITZROY DENNIS, aka "Rick," that

5 the United States will seek forfeiture as part of any sentence in

6 accordance with Title 18, United States Code, Section 924(d), and

7 Title 28, United States Code, Section 2461(c), in the event of

8 defendant's conviction under Count Sixteen of this First Superseding

9 Indictment.

10 2. Upon defendant's conviction under Count Sixteen of this

11 First Superseding Indictment, the defendant shall forfeit to the

12 United States any firearms and ammunition involved in the commission

13 of the offense, including, but not limited to:

14 a. a Springfield Armory model 1911Al Micro Compact .45

15 caliber pistol, bearing serial number N448061.

16

17

18

19

20

21

22

23

24

25

26

27

28

34
 1 FORFEITURE ALLEGATION THREE

2 [46 U.S.C. § 70507 (a)]

3 1. Pursuant to Federal Rule of Criminal Procedure 32.2 1 notice

4 is hereby given to defendants VICTOR HUGO CUELLAR-SILVA 1 aka

5 "Spartacus 1
11
aka "Junior 1
11
aka "Pi tbull 1
1
' aka "Black Sails, 11
aka "A

6 45 AMG, 11
aka "Wolverine, 11 aka "Sons of Anarchy 1 11
DIEGO FERNANDO

7 ANZOLA-GALIND0 1 aka "Aleman 1 11

aka "Aleman New, 11 aka "Pastor Aleman, 11

8 aka "Lord of War, 11

JUAN CARLOS PRADO-ROMER0 1 aka "Don Jose, 11
aka

9 "Mono, 11
CARLOS EDUARDO GONZALEZ-BERRI0 1 aka "Liche 1 11
and FIRST NAME

10 UNKNOWN ("FNU 11 ) LAST NAME UNKNOWN ("LNU11 ) , aka "Miguel Lara, 11 that

11 the United States will seek forfeiture as part of any sentence in

12 accordance with Title 46 1 United States Code, Section 70507(a), in

13 the event of any defendant 1 s conviction under Count Eighteen of this

14 First Superseding Indictment.

15 2. Each defendant so convicted shall forfeit to the United

16 States any property, real or personal, that was used or intended to

17 be used to commit or to facilitate the commission of such offense,

18 and any property traceable to such property.

19 3. Pursuant to Title 21, United States Code, Section 853(p) 1

20 each defendant convicted of Count Eighteen of this First Superseding

21 Indictment shall forfeit substitute property 1 up to the total value

22 of the property described in paragraph 2 if, as the result of any act

23 or omission of said defendant 1 the property described in paragraph 2,

24 or any portion thereof: (a) cannot be located upon the exercise of

25 due diligence; (b) has been transferred, sold to, or deposited with a

26 third party; (c) has been placed beyond the jurisdiction of the

27 court; (d) has been substantially diminished in value; or (e) has

28 been commingled with other property that cannot be divided without

35
 1 difficulty.

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

36
 1 FORFEITURE ALLEGATION FOUR

2 [18 U.S.C. § 982 (a) (1)]

3 1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice

4 is hereby given to defendants ANGEL HUMBERTO CHAVEZ-GASTELUM, also

5 known as ("aka") "Don Angel," aka "GTS," aka "Borre," aka "Bose," aka

6 "Netflix," aka "Madrid," aka "Rolex," aka "Kuwait," aka "Richard

7 Milleo," aka "Huracan," aka "Bally," aka "Ricky Luis," aka "Perrier,"

8 aka "Rosalba," aka "Nestea," VICTOR HUGO CUELLAR-SILVA, aka

9 "Spartacus," aka "Junior," aka "Pitbull," aka "Black Sails," aka "A

10 45 AMG," aka "Wolverine," aka "Sons of Anarchy," and JULIAN ANDRES

11 GONZALEZ-MORENO, aka "Chiqui," aka "Enano," aka "Monstruo," aka

12 "Goliath," aka "Braulio," aka "Gerente," aka "El Cabo," that the

13 United States will seek forfeiture as part of any sentence in

14 accordance with Title 18, United States Code, Section 982, in the

15 event of said defendant's conviction under Count Twenty of this First

16 Superseding Indictment.

17 2. Upon such conviction, the defendant shall forfeit to the

18 United States any property, real or personal, involved in such

19 offense, and any property traceable to such property.

20 3. Pursuant to Title 21, United States Code, Section 853(p),

21 each defendant convicted of Count Twenty of this First Superseding

22 Indictment shall forfeit substitute property, up to the total value

23 of the property described in paragraph 2 if, as the result of any act

24 or omission of a defendant, the property described in paragraph 2, or

25 any portion thereof: (a) cannot be located upon the exercise of due

26 diligence; (b) has been transferred, sold to, or deposited with a

27 third party; (c) has been placed beyond the jurisdiction of the

28 court; (d) has been substantially diminished in value; or (e) has

37
 1 been commingled with other property that cannot be divided without

2 difficulty.

4 A TRUE BILL

6 /5/
Foreperson
7

8 SANDRA R. BROWN
Acting United States Attorney
9

10~~

11 LAWRENCE S. MIDDLETON
Assistant United States Attorney
12 Chief, Criminal Division

13 KEVIN M. LALLY
Assistant United States Attorney
14 Chief, Organized Crime Drug
Enforcement Task Force Section
15
CAROL ALEXIS CHEN
16 BENJAMIN R. BARRON
RYAN H. WEINSTEIN
17 ALEXANDER B. SCHWAB
Assistant United States Attorneys
18 Organized Crime Drug Enforcement
Task Force Section
19

20

21

22

23

24

25

26

27

28

38