UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK


UNITED STATES OF AMERICA
V. SEALED
. SUPERSEDING
EFRAIN ANTONIO CAMPO FLORES and? INDICTMENT
FRANQUI FRANCISCO FLORES DE FREITAS, 3 
:3215Cr.7?1
Defendants.

COUNT ONE
The Grand Jury charges:
1. From at least in or about October 2015, up to and

including the date of this indictment, in Venezuela and
elsewhere, and in an offense begun and committed outside of the
jurisdiction of any particular State or district of the United
States, EFRAIN ANTONIO CAMPO FLORES and FRANQUI FRANCISCO FLORES
DE FREITAS, the defendants, at least one of whom will be first
brought to and arrested in the Southern District of New York and
whose point of entry into the United States will be in the
Southern District of New York, and others known and unknown,
intentionally and knowingly did combine, conspire, confederate
and agree together and with each other to violate the narcotics
laws of the United States.

2. It was a part and an object of the conspiracy that

EFRAIN ANTONEO CAMEO FLORES and FRANQUI FRANCISCO FLORES DE

 

FREITAS, the defendants, and others known and unknown, would and
did import into the United States and into the customs territory
of the United States from a place outside thereof a controlled
substance, in violation of Title 21, United States Code,
Sections 952(a) and 960(a)(1).

3. It was further a part and an object of the conspiracy
that EFRAIN ANTONIO CAMPO FLORES and FRANQUI FRANCISCO FLORES DE
the defendants, and others known and unknown, would and
did manufacture and distribute a controlled substance, intending
and knowing that such substance would be unlawfully imported
into the United States and into waters within a distance of 12
miles of the coast of the United States from a place outside
thereof, in violation of Title 21, United States Code, Sections
959(a) and 960(a)(3).

4. The controlled substance that EFRAIN ANTONIO CAMPO
FLORES and FRANQUI FRANCISCO FLORES DE FREITAS, the defendants,
Iconspired to import into the United States and into the
customs territory of the United States from a place outside
thereof and (ii) manufacture and distribute, intending and
knowing that such substance would be unlawfully imported into
the United States and into waters within a distance of 12 miles
of the coast of the United States from a place outside thereof,
was five kilograms and more of mixtures and substances

containing a detectable amount of cocaine, its salts, optical

 

and geometric isomers, and salts of isomers, in violation of
Title 21, United States Code, Section 
Overt Act

5. In furtherance of the conspiracy, and to effect the
illegal objects thereof, the following overt act was performed,
among others:

a. In or about October 2015, EFRAIN ANTONIO CAMPO

FLORES and FRANQUI FRANCISCO FLORES DE FREITAS, the defendants,
participated in meetings in Venezuela, regarding a shipment of
cocaine that was to be sent to the United States, via Honduras.

(Title 21, United States Code, Sections 959(c) 963;
Title 18, United States Code, Section 3238.)

FORFEITURE ALLEGATION

 

6. As a result of committing the controlled substance
offense charged in Count One of this Indictment, EFRAIN ANTONIO
CAMPO FLORES and FRANQUI FRANCISCO FLORES DE FREITAS, the
defendants, shall forfeit to the United States, pursuant to
Title 21, United States Code, Sections 853 and 970, any and all
property constituting or derived from any proceeds the
defendants obtained directly or indirectly as a result of the
offense and any and all property used or intended to be used in
any manner or part to commit and to facilitate the commission of

the offense charged in Count One of this Indictment.

 

Substitute Assets Provision

 

7. If any of the abovewdescribed forfeitable property, as
a result of any act or omission of EFRAIN ANTONIO CAMPO FLORES
and FRANQUI FRANCISCO FLORES DE FREITAS, the defendants,:
a. cannot be located upon the exercise of due
diligence;
b. has been transferred or sold to, or deposited
with, a third person;

C. has been plaCed beyond the jurisdiction of the

Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which

cannot be subdivided without difficulty,

it is the intent of the United States, pursuant to Title 21,
United States Code, Sections 853(p) and 970, to seek forfeiture
of any other property of the defendants up to the value of the
above forfeitable property.

(Title 21, United States Code, Sections 853 970.)

-W
PREET 

United States Attorney

 

 

 

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

 

UNITED STATES OF AMERICA
v. 

EFRAIN ANTONIO CAMPO FLORES and
FRANQUI FRANCISCO FLORES DE FREITAS,

Defandants.

SEALED
SUPERSEDING
INDICTMENT
82 15 Cr.

(21 U.S.C. 959(c) 963; and
18 U.S.C. 3238.)

PREET BHARARA
United States Attorneyt

A TRUE BILL

Foreperson.