~1oxm Case Document 54 Filed 08/10/17 Page PHILLIP A. TALBERT United States Attorney ROGER YANG Assistant United States Attorney 501 I Street, Suite 10?100 Sacramento, CA 95814 Telephone: (916) 554-2700 Facsimile: (916) 554-2900 Attorneys for Plaintiff United States of America AUG '1 2017 CLERK, us. coum' BY DEPUTY CLERK IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA OF AMERICA, Plaintiff, XIU PING LI, GUI WEN PAN, XIU RU LI, DAO ZHONG WEI, YONG I IE LIU, YOU AN LI, .SHUI PING ZHENG, KONG LIANG LI, GUANGZHAO LI, and HUANG CHEN, Defendants. CASENO.I 21 -U.S.C. 846, 841(a)(1) Conspiracy to Manufacture of Marijuana (9 Counts); 18 U. '853(a) Criminal Forfeiture mums: COUNT ONE: [21 U.S.C. 846, 841(a)(1) Conspiracy to Manufacture Marijuana] The Grand Jury charges: A INDICTMENT XIU PING LI, GUI WEN PAN, XIU RU LI, DAO ZHONG WEI, YONG I IE LIU, YOU AN LI, SHUI PING ZHENG, KONG LIANG LI, . 1956 Conspiracy to Launder Money; 18fU. 1956 Money Laundering (3 Counts); 21 U. EASTERN DISTRICT OF CALIFORNIA KJM Manufacture Marijuana; 21 U.S.C. 841(a)(1) s.c. s.c. 126' . 27 28 000510 Case Document 54 Filed 08/10/17 Page 2 of 13 GUANGZHAO LI, AND HUANG CHEN, defendants herein, between on or about January 14, 2016, and continuing through on or about July 26, A 2017, in the Counties of Sacramento and Placer, State and Eastern District of California, did knowingly . and intentionally conspire and agree-with each other and persons known and unknown to the Grand Jury to manufacture marijuana, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Sections 846 and 841(a)(1). . As to defendants XIU PING LI, and YOU AN LI, the conspiracy involved at least 1,000 marijuana plants. As to defendants XIU RU LI, GUI WEN PAN, YONG IE LIU, DAO ZHONG WEI, SHUI ZHENG, GUANG ZHAO LI, KONG LIANG LI, and HUANG CHEN, the conspiracy involved at least 100 marijuana plants. COUNT TWO: [21 U.S.C. ?841(a)(l) - Manufacture of VMarijuana] The Grand Jury further charges: A XIU PING LI, - XIU RU LI, and DAO ZHONG WEI, defendants herein, between on or about. February 22, 2016, and continuing through on or about July 26, 2017, at 7810 Elsie Avenue, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). COUNT THREE: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A XIU PING-LI YONG JIE LIU, and HUANG CHEN defendants herein, between On or about October 19, 2016, and continuing through on or about July 26, 2017, at' 8638 Bradshaw Road in the County of Sacramento, State and Eastern District of California, did INDICTMENT '.28 Case Document 54 Filed 08/10/17 Page 3 of 13 knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). COUNT FOUR: [2?1 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A YOU AN L1 and SHUI ZHENG, defendants herein, between on or about August 29, 2016, and Continuing through on or about July 26, 2017, at 2860 Central Avenue, Roseville, in the County of Placer, State and Eastern District of California, did knowingly and intentionally'manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in Violation of Title 21, United States Code, Section 841(a)(1). COUNT FIVE: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A YOU AN LI, and SHUI ZHENG, defendants herein, between on or about January 13,? 2017, and continuing through on or about July 26, 2017, at 10315 Baseline Road, Elverta, in the County of ?Placer, State and Eastern District of California, did knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). COUNT SIX: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury ?rrther charges: A XIU RU LI, defendant herein, between on or about March 22, 2017, and continuing through on or about July 26, 2017, at 8967 ISonoma Valley Way, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionally manufacture, at least 100 marijuana plants, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). INDICTMENT Case Document 54 Filed 08/10/17 Page 4 of 13 COUNT SEVEN: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A GUI WEN PAN, 7 defendant herein, between on or about February 16, 2017, and continuing through on or about July 26, 2017, at 4849 Armnolite Way, Elk Grove, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). COUNT EIGHT: U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A I .XIU PING LI, DAO ZHONG WEI, and GUANGZHAO LI, defendants herein, between on or about April 4, 2017, and continuing through on or about July 26, 2017, at 8114 Suarez Way, Elk Grove, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionallymanufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in Violation of Title 21, United States Code, Section 841(a)(1). COUNT NINE: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A YOU AN LI, and KONG LIANG LI, defendants herein, between on or about September 15, 2016, and continuing through on or about July 26,2017, at 3433 La Cadena Way, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled SubStance, in violation of Title 21, United States Code, Section 841(a)(1). - COUNT TEN: [21 U.S.C. 841(a)(1) Manufacture of Marijuana] The Grand Jury further charges: A INDICTMENT Case Document 54 Filed 08/10/17 Page 5?of 13 GUI WEN PAN, and DAO ZHONG WEI, defendants herein, between on or about antu 23, 2017, and continuing through on or about July 26, 2017 at 2725 52d Avenue, in the County of Sacramento, State and Eastern District of California, did knowingly and intentionally manufacture at least 100 marijuana plants, a Schedule I Controlled Substance, in Violation of Title 21 United States Code, Section 841(a)(l). COUNT [18 U.S.C. l956(a)(2)(A) and Conspiracy to Launder Money] The Grand Jury further charges: A XIU PING LI defendant herein, from on or about January 14, 2016 to on or about July 26, 2017, in the County of Sacramento, State and Eastern District of California, and elsewhere, did knowingly combine, conspire, and agree with other persons known and unknown to the Grand Jury to commit offenses against the United States in violation of Title 18, United States Code, Section 1956, to wit: to transport, transmit and transfer and attempt to transport,transmit and transfer a monetary instrument and funds to the United States from and through a place outside the United States with the intent to promote the carrying on of speci?ed unlawful activity, that is, violations .of Title 21, United States Code, Sections 841 and 846, Conspiracy to Manufacture Marijuana and Manufacture of Marijuana, all in violation of Title 18, United States Code, Section 1956(a)(2)(A) and and 18 U.S.C. 2. MANNER AND MEANS: On or about January 22, 2016, XIU PING LI received a wire transfer of $48,985.00 from account number 18.7 at China Construction Bank in Fujian, China to XIU PING LI ?s Bank of America account number XIU PING LI used this wire transfer as part of her down payment to buy 7810 Elsie Avenue, Sacramento, California, for the purpose of converting the residence into an indoor marijuana grow site. On or about January 25, 2016, XIU PING LI received a wire transfer of $48,985.00 from account INDICTMENT Case Document 54 Filed 08/10/17 Page 6 of 13 number at China Construction Bank in Fujian, China to XIU PING LI ?s Bank of America account number XIU PING LI used this wire transfer as part of her down payment to buy 7810 Elsie Avenue, Sacramento, California, for the purpose of converting the residence into an indoor marijuana grow site. On or-about May 10, 2016, XIU PING LI received a wire transfer of $49,985.00 from account number at China Construction Bank in Fujian, China to XIU PING Bank of America account number XIU PING LI used this wire transfer as part of her down payment to buy 13734 Montfort Road, Herald, California, for the purpose of converting the residence into an indoor marijuana grow site. COUNTS TWELVE THROUGH [18 U.S.C. 195 - Money'Laundering] The Grand Jury ?irther charges: A XIU PING LI, defendant herein, on or about the dates set forth below, in-the County of Sacramento, State and Eastern . District 'of California, and elsewhere, did knowingly and intentionally transport, transmit, and transfer funds and aid and abet others to transport, transmit, and transfer funds to the United States from and through a place outside the United States with the intent to promote the carrying on of speci?ed unlawful activity: to wit, the manufacture of marijuana in violation of Title 21, United States Code, Section 841(a)(1), as follows: INDICTMENT Case Document 54 Filed 08/10/17 Page 7 of 13 Count Date Amount 12 January 22,2016 $48,985.00 13 January 25, 2016 - 1 $48,985.00 14 May 10, 2016 . $49,985.00 all in violation of Title 18, United States Code, Section and 18 U.S.C. 2. FORFEITURE U.S.C. 853(a) and 18 U.S.C. 982(a)(1) Criminal Forfeiture] 1. Upon conviction of one or more of the offenses alleged in Counts One through Ten of this Indictment, defendants XIU PING LI, GUI WEN PAN, XIU RU LI, DAO ZHONG WELYONG IE LIU, YOU AN LI, SHUI PING ZHENG, KONG LIANG LI, GUANGZHAO LI, AND HUANG CHEN, shall forfeit to the United States pursuant to Title 21, United States Code, Section 853(a), the following pr0perty: I All right, title, and interest in any and all property involved 1n violations of Title 21, U. S. C. 841(a)(1), or conspiracy to commit such offenses, for which defendant IS convicted, and all property traceable to such property, including the following: all real or personal property, which constitutes or is derived from proceeds obtained, directly or indirectly, as a result of such' offenses; and all property used, or intended to be used, in any manner or part to commit or to facilitate the commission of the offenses. b. . A sum of money equal to the total amount of proceeds obtained as a result of the . offenses, orconspiracy to commit such offenses, for which defendants are convicted. 2. Upon conviction of one or more of the offenses alleged in Counts Eleven through Fourteen of this Indictment, defendant XIU PING LI shall forfeitto the United States, pursuant to 18 U.S.C. 982(a)(1), all property, real and personal, which constitutes or is derived from proceeds traceable to such violations, and! or any property used or intended to be used, in any manner or part, to commit, orto facilitate the commission of such violations, including but not limited to: I a. A sum of money equal to the total amount of proceeds obtained as a result of the INDICTMENT '23 Case Document 54 Filed 08/10/17 Page 8 of 13 offenses, or conspiracyto commit such offenses, for which defendant is convicted. 3. If any property subject to forfeiture, as a result of the offenses alleged in One through Fourteen of this Indictment, for which defendants are convicted: a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party; 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 divided without dif?culty; it is the intent of the United States, pursuant to 18 982(b)(1), incorporating 21 U.S.C. 853(p), to seek forfeiture of any other property of defendant, up to the value of the property subject to forfeiture. A TRUE BIL-L.- Isl Signature on file - . FOREPERSON PHILLIP TALBERT United States Attorney 24" 25 26 27 '28 INDICTMENT Case Document 54 Filed 08/10/17 Page 9 of 13 UNITED STATES DISTRICT COURT Eastern District of California Criminal Division THE UNITED STATES OF AMERICA VS. XIU PING DAO ZHONG WEI YONG JIE LIU YOU AN LI SHUI PING ZHENG KONG LIANG LI GUANGZHAO LI HUANG CHEN INDICTMENT 21 U.S.C. 846, 841(a)(1) Conspiracy to Manufacture and to Possess with'Intent to Distribute Marijuana; 21 U. S. C. 841(a)(1) Manufacture of Marijuana (9 Counts); 18 U. S. C. 1956 Conspiracy to Commit Money Laundering; 18 U. S. C. 1956? Money Laundering (3 Counts); 21 U. S. C. 853(a)? Criminal Forfeiture A may, Isl Signature on file Baa, MLBAILWARRANT an @547? 24196 ?75 GPO 863 525 Document 54 Filed 08/10/17 Page 10 of 13 United States v. Xiu Ping Li, et al. Penalties for Indictment Defendants XIU PING LI, GUI WEN PAN, XIU RU LI, DAO ZHONG WEI, YONG JIE LIU, YOU AN LI, SHUI PING ZHENG, KONG LIANG LI, GUANGZHAO LI, AND HUANG CHEN COUNT 1: XIU PING LI, YONG IE LIU, YOU AN LI, VIOLATION: 21 U.S.C. 846, 841(a)(1) - Conspiracy to Manufacture Over 1,000 Plants of Marijuana PENALTIES: Mandatory minimum of 10 years in prison and a maximum of up to life in prison; or Fine of up to $10,000,000; or both ?ne and imprisonment 1 Supervised release of at least 5 years up to life 1 SPECIAL ASSESSMENT: $100 (mandatory on each count) GUI WEN PAN, XIU RU LI, DAO ZHONG WEI, SHUI PING ZHENG, KONG LIANG LI, GUANGZHAO LI, AND HUANG CHEN VIOLATION: 21 U.S.C. 846, - Conspiracy to Manufacture Over 100 Plants of Marijuana PENALTIES: Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or I Fine of up to $5,000,000; orboth ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 2: XIU PING LI, XIU RU LI, and DAO ZHONG WEI VIOLATION: 21 U.S.C. 84l(a)(1) Manufacture more than 100 plants of Marijuana PENALTIES: Mandatory minimum of .5 years in prison and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 3: XIU PING LI, YONG JIE LIU, and HUANG CHEN VIOLATION: 21 U.S.C. 841 Manufacture more than 100 plants of Marijuana Case Document ?54 Filed 08/10/17 Page 11 of 13 PENALTIES: Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 4: VIOLATION: PENALTIES: YOUAN LI, and SHUI ZHENG, 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 5: VIOLATION: . PENALTIES: YOU AN LI, and SHUI ZHENG, 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prisOn and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 6: VIOLATION: PENALTIESU.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine of up to 000, 000; or both ?ne and imprisonment supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 7: VIOLATION: GUI WEN PAN, 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Case Document 54 Filed 08/10/17 Page 12 of 13 Fine of up to $5,000,000; Or both ?ne and imprisonment I Supervised release of at least 4 years up tollife SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNT 8: VIOLATION: PENALTIES XIU PING LI, DAO ZHONG WEI, and GUANGZHAO LI 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) - COUNT 9: VIOLATION: PENALT IE YOU AN LI and KONG LIAN LI 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine ofup to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIALASSESSMENT: $100 (mandatory on each count) COUNT 10: VIOLATION: PENALTIES: GUI WEN PAN, and DAO ZHONG WEI 21 U.S.C. 841(a)(1) Manufacture more than 100 plants of Marijuana Mandatory minimum of 5 years in prison and a maximum of 40 years in prison; or Fine of up to $5,000,000; or both ?ne and imprisonment Supervised release of at least 4 years up to life SPECIAL ASSESSMENT: $100 (mandatory on each count) COUNTS 11-14: VIOLATION: XIU PING LI 18 U.S.C. 1956(a)(2)(A), 1956(h) International Money Laundering and Conspiracy to Commit International Money Laundering Up to 20 years in prison; Fine of up to $500,000 or twice the value of the monetary instrument or funds involved, whichever is greater; Case 2:17-crd-00136-KJM Do?Cument 54 Filed 08/10/17 Page 13 of 13 Supervised release Of up to 3 years SPECLAL ASSESSMENT: $100 (mandatory on each count) ORFEITURE ALLEGATION: all Defendants VIOLATION: 21 U.S.C. 853(a) - Criminal Forfeiture PENALTIES: As stated in the charging document