Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 1 of 11 UNITED STATES DISTRICT COURT musoumcmm SOUTHERN DISTRICT OF TEXAS Waugd?fw UNSEALED CORPUS CHRISTI DIVISION JUN 2 2 2015 UNITED STATES OF AMERICA V. r?A . RAMON VALENCIA-MORFIN . SILVESTRE VALENCIA-VEGA AKA 3. MARIN MEDINA-MENDOZA JR. 4. MARIO ALBERTO MEDINA-MENDOZA 5. BRYAN MENDOZA 6 7 (3-16-5441 CRIMINAL NUMBER . VALENCIA . ISMAEL SILVA-CORTEZ AKA 8. ALAN CASTILLO AKA INDICTMENT THE GRAND JURY CHARGES THAT: Between on or about February 2009, and up to and including the date of this indictment, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants, RAMON VALENCIA-MORFIN, MARIN MEDINA-MENDOZA R., BRYAN MENDOZA, ISMAEL SILVA-CORTEZ AKA and ALAN CASTILLO AKA 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 more than one thousand (1,000) kilograms of marihuana, a Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 2 of 11 Schedule I controlled substance, and more than ?ve (5) kilograms of cocaine, a Schedule II controlled substance. In violation of Title 21, United States Code, Sections 846, 841(a)(1), and COUNT TWO Between on or about February 2009, and up to and including the date of this indictment, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants, RAMON VALENCIA-MORFIN, - SILVESTRE AKA MARIN MEDINA-MENDOZA JR., MARIO ALBERTO MEDINA-MENDOZA, BRYAN MENDOZA, VALENCIA, ISMAEL SILVA-CORTEZ AKA and ALAN CASTILLO AKA did knowingly and intentionally conspire and agree, with each other and with other persons known and unknown to the Grand Jury, to conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial 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 speci?ed unlawful possession of controlled substances with intent to distribute and 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 and Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 3 of 11 COUNT THREE On or about March 1, 2012, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, BRYAN MENDOZA, did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute. and 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)(B)(i) and On or about August 31, 2012, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, SILVESTRE VALENCIA-VEGA AKA did knowingly engage and attempt to engage in a monetary transaction by, through, and to a ?nancial institution, affecting interstate and foreigncommerce, in criminally derived property of a value greater than $10,000, that is, the purchase of a motor vehicle with US. Currency, such property having been derived from a speci?ed unlawful activity, that is, the distribution and possession with intent to distribute of controlled substances. 3 Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 4 of 11 In violation of Title 18, United States Code, Section 1957. COUNT FIVE On or about September 12, 2012, in the SOuthern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, VALENCIA, did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute and 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)(B)(i) and COUNT SIX On or about November 26, 2012, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, BRYAN MENDOZA, did knowingly engage and attempt to engage in a monetary transaction by, through, and to a ?nancial institution, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, that is, the purchase of a motor vehicle with U.S. Currency, such Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 5 of 11 property having been derived from a speci?ed unlawful activity, that is, the distribution and possession with intent to distribute of controlled substances. In violation of Title 18, United States Code, Section 1957. COUNT SEVEN On or about January 7, 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, MARIO ALBERTO MEDINA-MENDOZA, did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute and 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 l956(a)(l)(B)(i) and COUNT EIGHT On or about April 11, 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, BRYAN MENDOZA, did knowingly engage and attempt to engage in a monetary transaction by, through, and to a ?nancial institution, affecting interstate and foreign commerce, in criminally derived property of a Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 6 of 11 value greater than $10,000, that is, the purchase of a motor vehicle with U.S. currency, such property having been derived from a speci?ed unlawful activity, that is, the distribution and possession with intent to distribute of controlled substances. In violation of Title 18, United States Code, Section 1957. COUNT NINE On or about August 25, 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, VALENCIA, did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, tor/wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute and 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)(B)(i) and COUNT TEN On or about October 13, 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, ISMAEL SILVA-CORTEZ AKA Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 7 of 11 did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful activities of unlawful possession of controlled substances with intent to distribute and 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)(B)(i) and COUNT ELEVEN On or about October 15, 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, ISMAEL SILVA-CORTEZ AKA did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute and unlawful operation of an unlicensed money transmitting business, and to avoid a transaction reporting requirement under State or Federal law. Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 8 of 11 In violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and COUNT TWELVE On or about June 26, 2015, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendant, SILVESTRE VALENCIA-VEGA AKA did knowingly and intentionally conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, then well knowing that the ?nancial transactions involved the proceeds of some form of unlawful activity, to wit: the unlawful possession of controlled substances with intent to distribute and 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 speci?ed unlawful possession of controlled substances with intent to distribute and 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)(B)(i) and NOTICE OF CRIMINAL FORFEITURE (21 U.S.C. 853(a)) Pursuant to Title 21, UnitedStates Code, Section 853(a), the United States of America gives notice to the defendants, RAMON VALENCIA-MORFIN, MARIN MEDINA-MENDOZA JR., BRYAN MENDOZA, ISMAEL SILVA-CORTEZ AKA and ALAN CASTILLO AKA Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 9 of 11 that upon conviction of conspiracy as charged in Count One of the Indictment, the following property, whether real or personal, is subject to forfeiture: 1) all property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such conspiracy; and 2) all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, such conspiracy. NOTICE OF CRIMINAL FORFEITURE (18 U.S.C. 982(a)(1)) Pursuant to Title 18, United States Code, Section 982(a)(1), the United States of America gives notice to the defendants, RAMON VALENCIA-MORFIN, . SILVESTRE VALENCIA-VEGA AKA MARIN JR., MARIO ALBERTO MEDINA-MENDOZA, BRYAN MENDOZA, VALENCIA, ISMAEL SILVA-CORTEZ AKA and ALANCASTILLO AKA that, upon conviction of a conspiracy in violation of Title 18, United States Code, Section 1956(h), or of a violation of Title 18, United States Code, Sections 1956(a0(1)(B)(i), 1956(a)(1)(B)(ii), or 1957, as charged in Counts Two through Twelve 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. Case Document 1 Filed in TXSD on 06/22/16 Page 10 of 11 PROPERTY SUBJECT TO FORFEITURE The property to be forfeited includes, but is not limited to, the following: a. Approximately $1.5 million in United States currency; and b. The following real property, with improvements and appurtenances: - 1. Located in Mission, Texas, and legally described as: THE SOUTH 22 ACRES OF LOT 35-10, WEST ADDITION TO SHARYLAND SUBDIVISION, HIDALGO COUNTY, TEXAS, ACCORDING TO THE MAP RECORDED IN VOLUME 1, PAGE 56, MAP RECORDS IN THE OFFICE OF THE COUNTY CLERK OF HIDALGO - COUNTY, SAVE AND EXCEPT A 1.00 ACRE TRACT OUT THE . SOUTHEAST CORNER. 2. Located in Mission, Texas, and legally described as: 1.0 ACRE MORE OR LESS, OUT OF THE SOUTH 22.0 ACRES OF LOT 35-10, WEST ADDITION TO SHARYLAND SUBDIVISION, HIDALGO COUNTY, TEXAS, ACCORDING TO THE MAP OR PLAT THEREOF RECORDED IN VOLUME 1, PAGE 56, MAP RECORDS IN THE OFFICE OD THE COUNTY CLERK OF HIDALGO COUNTY, TEXAS. 3. Located in Mission, Texas, and legally described as: LOT TEN (10), MALMAISON LUXE AT TRINITY SUBDIVISION, A SUBDIVISION IN THE CITY OF MISSION, HIDALGO COUNTY, TEXAS, AS PER MAP OR PLAT RECORDED IN VOLUME 53, PAGES 4-5, MAP RECORDS OF HIDALGO COUNTY, TEXAS, TO WHICH REFERENCE IS HEREBY MADE FOR ALL PERTINENT PURPOSES. 4. Located in Pharr, Texas, and legally described as: LOT 181 LA QUINTA SUBDIVISION, AN ADDITION TO THE CITY OF PHARR, HIDALGO COUNTY, TEXAS AS PER MAP OR PLAT THEREOF RECORDED IN VOLUME 23, PAGE 114, AND MAP RECORDS, HIDALGO COUNTY, TEXAS. MONEY JUDGMENT Defendants are noti?ed that, upon conviction, a money judgment may be imposed equal to 10 Case 2:16-cr-00544 Document 1 Filed in TXSD on 06/22/16 Page 11 of 11' the value of the 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) (2) (3) (4) (5) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without dif?culty, the United States to seek forfeiture of any other property of the defendants up to the total value of property subject to forfeiture, pursuant to Title 21, United States Code, Section 853(p), and Title 18, United State Code, Section 982(b). A TRUE BILL: ORIGINAL SIGNATURE ON FILE OREPERSON OF THE GRAND JURY KENNETH MAGIDSON UNITED STATES TTORNEY Maw KENNETH A. CUSICK Assistant United States Attorney 11