UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK.

- I 
UNITED STATES OF AMERICA
.. 
ALFRED RAMIREZ, 16 Cr.
Defendant.
- - I 
COUNT ONE
The Grand Jury charges:
1. From at least in or about 2012, up to and including in or

about September 2015, in the Southern District of New York and

,elsewhere, ALFRED RAMIREZ, the defendant, 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 ALFRED
RAMIREZ, the defendant, andmothers known and unknown, would and did
distribute and possess with intent to distribute a controlled
substance, in violation of Title 2T, United States Code, Section

841(a)(l).

3. The controlled substance involved in the offense was

mixtures and.substances containirmya.detectable amount.of oxycodone,?

commonly known as ?Oxycontin,? a Schedule II controlled substance,

in violation of 21 U.S.C. 

u,

 

 

(Title 21, United States Code, Sections 846, 841(a)(1),
841(b) (C) .)
COUNT TWO

The Grand Jury further charges:

4. From at least in or about 2012, up to and including in or
about September 2015, in the Southern District of New York and
elsewhere, ALFRED RAMIREZ, the defendant, intentionally and
knowingly did distribute and possess with intent to distribute a
controlled.substance, in'violation of Title 21, United States Code,
Section 841(a)(1).

5. The controlled substance involved in the offense was
mixtures and.substances contair?inga.detectable amount of oxycodone,
commonly known as ?OxyContin,? a Schedule II controlled substance,
in violation of 21 6.8.0.



(Title 21, United States Code, Sections 841(a)(1)

Title 18, Suited States Code, Section 2.)

FORFEITURE ALLEGATION
6. lnsa.result.of committing the controlled.substance.offense
alleged in Counts One and Two of this Indictment, ALFRED RAMIREZ,
the defendant, shall forfeit to the United States, pursuant to 21
S.C. 853, any and.all property constituting or derived from any
proceeds said defendant obtained directly'or indirectly as a result

of the violation and any'and.all property used.or intended.to be used

 

 

in any manner or part to commit or to facilitate the commission of
the violation alleged in Counts One and Two of this Indictment,
including but not limited toga sum in United States currency
representing the amount of proceeds obtained as a result of the
offense,

Substitute Assets Provision

 

7. If any of the property described above as being subject

to forfeiture, as a result of any act or omission of the defendant:

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 beerxplaced 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 intention of the United States, pursuant to Title 21, United
States Code, tc)seek forfeiturec?fany'other property
of the defendant up to the value of the above

forfeitable property.

(Title 21, United States Code, Sections 841(a)(1) and 853.)


a

BHARARA
United States Attorney

//FOREs@hso

1.1

 

 

 

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

 

UNITED STATES OF AMERICA

V. 

ALFRED RAMIREZ,

Defendant.

 

INDICTMENT
16 Cr.

(21 U.S.C. 841(a) 841(b) (C), 846,
853; 18 U.S.C. 2)

PREET BHARARA

 

United States Attorney.

A TRUE 

 

oreperson.


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