Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 1 of 45 United States Courts Southern District of Texas FILED November 3, 2017 David J. Bradley, Clerk of Court H CR 17-651 Case Document 1 Filed in TXSD on 11/03/17 Page 2 of 45 (10) JOSE RUBEN (11) DENIS AMAYA CABALLERO, a/k/a DENNIS CABALLERO, a/k/a CHRISTOPHER CABALLERO, a/k/a ARNOLD LOPEZ, a/k/a (12) GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA (I3) WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a (14) EDDIE ALEJANDRO TORRES, a/k/a (15) RAUL MORENO-REYNA, a/k/a (16) JOSE LUIS MORENO, a/k/a a/k/a (17) GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a (18) HECTOR REYNA, a/k/a a/k/a a/k/a (I9) ANADALIT DUARTE, a/k/a a/k/a ANN DALIT DUARTE (20) BIANCA STEPHANIE REYNA, a/k/a (21) CLAUDIA SORIANO-HERNANDEZ, a/k/a a/k/a CLAUDIA JACKELY Case Document 1 Filed in TXSD on 11/03/17 Page 3 of 45 (22) JIMMY MEJ IA CHAVEZ, a/k/a YIMMY MEJ IA CHAVEZ, a/k/a IMY OSUE MEJIA and - (23) JUAN CARLOS CONTRERAS CERVANTES, a/k/a Defendants. INDICTMENT THE GRAND JURY CHARGES THAT: INTRODUCTION At all times material to this indictment: l. The Southwest Cholos is a criminal organization based in Southwest Houston. In addition to its members, SWC also has associates operating throughout Texas, Mexico, and Central America who act in furtherance of its criminal scheme. 2. SWC members and associates are engaged in a variety of criminal conduct, including, but not limited to, sex traf?cking, the smuggling of illegal aliens into and within the United States, drug traf?cking, and the sale of illegal and stolen weapons. 3. Defendants (1) FREDDY MONTES, a/k/a KING MONO (2) GIOVANI ALEXANDER ALECIO, a/k/a WHITEBOY and (5) MARIA ANGELICA a/k/a PATTY are three leaders and members of SWC. KING MONO is one of sons. 4. Another SWC leader and member is (8) ERIK IVAN ALVAREZ-CHAVEZ IVAN is husband. 5. In addition to KING MONO, four of other sons are also SWC leaders and members. They are (6) WILLIAM ALBERTO LOPEZ (l3) WALTER 3 Case Document 1 Filed in TXSD on 11/03/17 Page 4 of 45 LOPEZ (l4) EDDIE ALEJANDRO TORRES, a/k/a MONTERREY and (16) JOSE LUIS MORENO, a/k/a LUCKY 6. SWC is using the Carriage Way Apartment Complex, located at 6011?6023 Dashwood, in Houston, Texas as one of its centers of operations for its criminal activities. SWC is also using other locations of operations in Houston, Texas, the Rio Grande Valley (Cameron, Hidalgo, Starr, and Webb Counties, Texas), and Cancun, Mexico. SEX TRAFFICKING AND PROSTITUTION SCHEME 7. One of criminal activities has been to operate brothels where girls and women work as prostitutes. 8. MAVM, EMR, AP, and ABP were adult females whom SWC members and associates forced, threatened, defrauded, and coerced into engaging in prostitution in Houston, Texas. Speci?cally, at all times material to this Indictment, MAVM, EMR, AP and ABP were individuals who were recruited, enticed, harbored, transported, provided, obtained and maintained in reckless disregard of the fact that means of force, threats of force, fraud, and coercion were used to cause them to engage in commercial sex acts that affected interstate and foreign commerce. They were also imported, transported and travelled in foreign commerce into the United States to engage in prostitution, and held, kept, maintained, controlled supported, employed and harbored in the Unite-d States in pursuance of such illegal importation, all of which were due to acts of inducement, enticement, and coercion by one or more of the defendants and their co?conSpirators known and. unknown to the Grand Jury,. 9. NGL was a girl who, beginning at age 14, SWC members and associates caused, recruited, enticed, harbored, transported, provided, obtained and maintained to engage in prostitution for their financial bene?t. SWC members and associates did so knowing and in 4 Case Document 1 Filed in TXSD on 11/03/17 Page 5 of 45 reckless disregard of the fact that means of force, threats of force, fraud, and coercion were used to cause her to engage in a commercial sex act that affected interstate and foreign commerce. 10. NGL, MAVM, EMR, AP, and ABP, are collectively referred to in this indictment as ?sex trafficking victims.? ll. BAS is an adult female that SWC members and associates imported and tranSported in foreign commerce into the United States to engage in prostitution and who SWC members and its associates held, kept, maintained, controlled, supported, employed and harbored in the United States as a prostitute in a brothel controlled by SWC and its associates. 12. a. NGL, MAVM, EMR, AP, ABP, and BAS were all employed by SWC as prostitutes in brothels SWC and its associates controlled and MAVM, EMR, AP, ABP, and BAS were all smuggled illegally into the United States by SWC and its associates for that purpose. b. For MAVM, EMR, AP, ABP, and BAS, SWC members and associations would make arrangements for them to cross into the United States illegally for the purpose of working as a prostitute and engaging in commercial sex acts in a ?brothel? controlled by SWC members and associates. SWC members and associates would also provide a hotel, house or ?stash house? in the vicinity of the United States-Mexico border for them to reside at following their illegal entrance into the United States. SWC members and associates would also transport or make arrangements for their transportation from the United States?Mexico border region of Texas to the Houston, Texas Vicinity. 13. SWC members and associates used force, threats of force, fraud, and coercion in order to make their sex trafficking victims engage in prostitution. SWC members would often create a ?debt? on the part of the sex traf?cking victim, such as by smuggling them into the United States, harboring them here illegally, and by convincing them to live in ?safe residences? Case Document 1 Filed in TXSD on 11/03/17 Page 6 of 45 in the United States. In order to pay off that debt, SWC required these sex traf?cking victims to engage in commerical sex acts at brothels controlled and Operated by SWC members and associates. 14. As part of this sex traf?cking scheme, SWC members and associates would lie to their sex traf?cking Victims by falsely telling them they were going to work in a restaurant when, in fact, they would work in brothels controlled and operated by SWC members and associates. 15. As part of this sex traf?cking scheme, SWC members and associates would tattoo their names and nicknames on the body of their sex traf?cking Victims, including NGL, EMR, AP, ABP, and MAVM. 16. As part of this sex traf?cking scheme, SWC members and associates would assault, and threaten to assault, their sex traf?cking victims and family members of their sex traf?cking victims. As part of this sex traf?cking scheme, SWC members and associates would instruct their sex traf?cking victims how much to charge individuals for each commercial sex act, and then divide a portion of the proceeds from the commercial sex act amongst SWC members and associates. ALIEN SMUGGLING 18. Another of criminal activities was to smuggle aliens into, and transport and harbor them in, the United States in exchange for a fee. 19. BAS, EB, VRG, EEMH, AQF, HSB, JVM, AL, CC, and" WP (collectively referred to as ?aliens,?) are all individuals who do not have United States citizenship, but whom paid a fee to human smuggling organizations in order to be smuggled into the United States without permission and then transported to Speci?c locations in the United States. SWC was a Case Document 1 Filed in TXSD on 11/03/17 Page 7 of 45 part of and worked with these human smuggling organizations to smuggle, transport, and harbor the aliens. 20. As part of this human smuggling scheme, SWC members and associates would assist the aliens in crossing the United States-Mexico international border without inspection at a place other than a designated port of entry. 21. As part of this human smuggling scheme, SWC members and associates would transport the aliens to one of many ?stash houses? located in the Rio Grande Valley. 22. As part of this human smuggling scheme, SWC members and associates would conceal, harbor, and shield from detection the aliens at a stash house, and transport them between stash houses. 23. As part of this human smuggling scheme, SWC members and associates would transport the aliens through and past a United States Border Patrol checkpoint, including checkpoints located in Sarita, Texas and Falfurrias, Texas. 24. As part of this human smuggling scheme, SWC members and associates would transport the aliens to an area north of the United States Border Patrol checkpoint to another stash house located in or near Houston, Texas. 25. As part of this human smuggling scheme, SWC members and associates would conceal, harbor, and shield from detection the aliens at a stash house located in or near Houston, Texas. 26. In exchange for these illicit services, SWC members and associates would receive a fee from the aliens, directly or through the larger human smuggling organization. The fee varied by alien. Some aliens paid prior to passage into the United States. Some aliens paid a Case Document 1 Filed in TXSD on 11/03/17 Page 8 of 45 portion of their earnings in the United States after they illegally entered. SWC members and associates received a portion of the fee in exchange for their smuggling services. COUNT ONE Conspiracy to Engage in Sex Traf?cking by Means of Force, Threats, Fraud, and Coercion Paragraphs 1 through 26 of the Indictment, and Counts Two through Six of the Indictment, are re?alleged and incorporated herein by reference. Beginning on or about January 10, 2009, and continuing until on or about May 5, 2017, in the Southern District of Texas, I FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO LOPEZ-MORENO, a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA FLORES-GONZALES, a/k/a IELA GONZALES, WALTER LOPEZ, a/kfa WALTER BARRIOS MORENO, a/k/a and EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a 8 Case Document 1 Filed in TXSD on 11/03/17 Page 9 of 45 HECTOR REYNA, a/k/a a/k/a a/k/a ANADALIT DUARTE, a/k/a a/k/a ANN DALIT DUARTE GARCIA, and BIANCA STEPHANIE REYNA, a/k/a defendants herein, conSpired with one or more other persons to knowingly recruit, entice, harbor, transport, provide, obtain, and maintain by any means in and affecting interstate and foreign commerce, and to knowingly bene?t ?nancially and receive anything of value from participation in a venture which recruited, enticed, harbored, transported, provided, obtained and maintained in an affecting interstate and foreign commerce, NGL, MAVM, EMR, AP, and ABP, knowing and in reckless disregard of the fact that force, threats of force, fraud, and coercion would be used to cause NGL, MAVM, EMR, AP, and ABP to engage in commercial sex acts, and knowing and in reckless disregard of the fact that NGL had not attained the age of 18 years and that NGL would be caused to engage in a commercial sex act. In ViOlation of Title 18, United States Code, Section COUNT TWO Sex Trafficking of a Minor by Means of Force, Threats, Fraud, and Coercion Beginning on or before February, 2013, and continuing until on or about May 31, 2013, in the Southern District of Texas, MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a HECTOR REYNA, a/k/a a/k/a a/k/a ANADALIT DUARTE, a/k/a a/k/a ANN DALIT DUARTE GARCIA, and 9 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 10 of 45 BIANCA STEPHANIE REYNA, a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly, in an affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain, maintain, patronize, and solicit NGL, a person that had not attained the age of 18 years, and benefited financially and by receiving anything of value from participation in a venture which has engaged in recruiting, enticing, harboring, transporting, providing, obtaining, advertising, maintaining, patronizing and soliciting by any means NGL, knowing and in reckless disregard of the fact that (1) means of force, threats of force, fraud, and coercion, and any combination of such means, would be used to cause NGL to engage in a commercial sex act, and (2) NGL, whom defendants had a reasonable opportunity to observe, had not attained the age of 18 years and would be caused to engage in a commercial sex act. In Violation of Title 18, United States Code, Sections 1591 and and 2. COUNT THREE Sex Trafficking by Means of Force, Threats, Fraud, or Coercion Beginning on or before January 1, 2009, and continuing until on or about December 31, 2011, in the Southern District of Texas, MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA GONZALEZHFLORES, a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a and EDDIE ALEJANDRO TORRES, a/k/a 10 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 11 of 45 RAUL a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly, in an affecting interstate and foreign commerce, recruit, entice, harbor, transpOrt, provide, obtain and maintain knowing and in reckless disregard of the fact that means of force, threats of coerce, fraud, and coercion would be used to cause to engage in a commercial sex act. In Violation of Title 18, United States Code, Sections 1591(a) and 2. COUNT FOUR Sex Traf?ckingr by Means of Force, Threats, Fraud, or Coercion Beginning on or before April 20, 2012, and continuing until on or about July 18, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, aided and. abetted by each other, and by other persons, did knowingly, in an affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain and maintain knowing and in reckless disregard of the fact that means of force, threats of coerce fraud and coercion would be used to cause to en a in a commercial sex act. 3 5 ll Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 12 of 45 In Violation of Title 18, United States Code, Sections 1591(a) and 2. COUNT FIVE Sex Trafficking by Means of Force, Threats, Fraud, or Coercion Beginning on or before September 1, 2012, and continuing until on or about September 30, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARLA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILLIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a and. GABRIELA GONZALEZ-FLORES, a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, defendants herein, aided and abetted by each other, and by other persons, did knowingly, in an affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain and maintain knowing and in reckless disregard of the fact that means of force, threats of coece, fraud, and coercion would be used to cause to engage in a commercial sex act. In Violation of Title 18, United States Code, Sections 1591(a) and 2. COUNT SIX Sex Trafficking by Means of Force, Threats, Fraud, or Coercion Beginning on or before April 1, 2016, and continuing until on or about May 5, 2017, in the Southern District of Texas, GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a 12 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 13 of 45 MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO LOPEZ-MORENO, a/k/a DAVID MALDONADO, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a and JOSE LUIS MORENO, a/k/a a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly, in an affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain and maintain knowing and in reckless disregard of the fact that means of force, threats of coerce, fraud, and coercion would be used to cause to engage in a commercial sex act. In Violation of Title 18, United States Code, Sections 1591(a) and 2. COUNT SEVEN Conspiracy to Conduct Transportation to Engage in Prostitution Beginning on or about January 10, 2009, and continuing until on or about May 5, 2017, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA MORENO-REYNA, a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a l3 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 14 of 45 WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, did knowingly and intentionally combine, conspire, confederate, and agree with each other, and others known and unknown to the Grand Jury, to knowingly transport and cause the transportation of individuals in foreign commerce with intent that such individuals engage in prostitution, in Violation of Title 18, United States Code, Section 371. MANNER AND MEANS The unlawful conspiracy was accomplished in the manner and means alleged in paragraphs 1 through 26 Of the Indictment, and Counts Eight through Twelve of this Indictment, which are re?alleged and incorporated herein by reference. OVERT ACTS In ?irtherance of this conspiracy, and in order to effect and accomplish its Objectives, one or more of the defendants committed in the Southern District of Texas the overt acts alleged in 14 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 15 of 45 paragraphs 1 through 26 of the Indictment, and Counts Eight through Twelve of this Indictment 3 which are re?alleged and incorporated herein by reference. COUNT EIGHT Transportation to Engage in Prostitution Beginning on or before January 1, 2009, and continuing until on or about December 31, 201 1, in the Southern District of Texas, MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and RAUL a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly transport and cause the transportation of an individual in interstate and foreign commerce with intent that such individual engage in prostitution. In Violation of Title 18, United States Code, Sections 2421(a) and 2. COUNT NINE Transportation to Engage in Prostitution Beginning on or before April 20, 2012, and continuing until on or about July 18, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a 15 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 16 of 45 MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA GONZALEZ-FLORES, a/k/a a/k/a a/k/a GABRIELA FLORES-GONZALES, a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly transport and cause the transportation of an individual in interstate and foreign commerce with intent that such individual engage in prostitution.- In Violation of Title 18, United States Code, Sections 2421 and 2. COUNT TEN Transportation to Engage in Prostitution Beginning on or before September 1, 2012, and continuing until on or about September 30, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILLIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a and GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, 16 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 17 of 45 defendants herein, aided and abetted by each other, and by other persons, did knowingly transport and cause the transportation of an individual in interstate and foreign commerce with intent that such individual engage in prostitution. In violation of Title 18, United States Code, Sections 2421(a) and 2. COUNT ELEVEN Transportation to Engage in Prostitution Beginning on or before April 1, 2016, and continuing until on or about May 5, 2017, in the Southern District of Texas, GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly transport and cause the transportation of an individual in interstate and foreign commerce with intent that such individual engage in prostitution. In Violation of Title 18, United States Code, Sections 2421(a) and 2. 17 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 18 of 45 COUNT TWELVE Transportation to Engage in Prostitution Beginning on or before April 12, 2017, and continuing until on or about April 19, 2017, in the Southern District of Texas, MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a and ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly transport and cause the transportation of an individual in interstate and foreign commerce with intent that such individual engage in prostitution. In Violation of Title 18, United States Code, Sections 2421(a) and 2. COUNT THIRTEEN Conspiracy to Entice and Coerce Another to Travel in Interstate or Foreign Commerce for Prostitution Beginning on or about January 1, 2009, and continuing until on or about May 5, 2017, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, l8 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 19 of 45 a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO LOPEZ-MORENO, a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, did knowingly and intentionally combine, conspire, confederate, and agree with each other, and others known and unknown to the Grand Jury, to induce, entice and coerce others travel in foreign commerce with intent that those individuals engage in prostitution and sexual activity for which a person can be charged with a criminal offense, in Violation of Title 18, United States Code, Section 371. MANNER AND MEANS The unlawful conspiracy was accomplished in the manner and means alleged in paragraphs 1 through 26 of the Indictment, and Counts Fourteen through Seventeen of this Indictment, which are re?alleged and incorporated herein by reference. 19 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 20 of 45 OVERT ACTS In furtherance of this conspiracy, and in order to effect and accomplish its objectives, one or more of the defendants committed in the Southern District of Texas the overt acts alleged in paragraphs 1 through 26 of the Indictment, and Counts Fourteen through Seventeen of this- Indictment which are re-alleged and incorporated herein by reference. COUNT FOURTEEN Enticing and Coercing Another to Travel in Interstate or Foreign Commerce for Prostitution Beginning on or before January 1, 2009, and continuing until on or about December 31, 2011, in the Southern District of Texas, MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and RAUL a/k/a defendants herein, aided and abetted by each other, did knowingly induce, entice and coerce to travel in foreign commerce, from Mexico to Texas, with intent that engage in prostitution and sexual activity for which a person can be charged with a criminal offense. In Violation of Title 18, United States Code, Sections 2422(a) and 2. 20 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 21 of 45 COUNT FIFTEEN Enticing and Coercing Another to Travel in Interstate or Foreign Commerce for Prostitution Beginning on or before April 20, 2012, and continuing until on or about July 18, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARIA ANGELICA MORENO-REYNA, a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO LOPEZ-MORENO, a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA GONZALEZ-FLORES, a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly induce, entice, and coerce to travel in foreign commerce, from Mexico to Texas, with intent that engage in prostitution and sexual activity for which a person can be charged with a criminal offense. In Violation of Title 18, United States Code, Sections 2422(a) and 2. COUNT SIXTEEN Enticing and Coercing Another to Travel in Interstate or Foreign Commerce for Prostitution Beginning on or before September 1, 2012, and continuing until on or about September 30, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a 2l Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 22 of 45 MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILLIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a and GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, defendants herein, aided and abetted by each other, and by other persons, did knowingly induce, entice and coerce to travel in foreign commerce, from Mexico to Texas, with intent that engage in prostitution and sexual activity for which a person can be charged with a criminal offense. In violation of Title 18, United States Code, Sections 2422(3) and 2. COUNT SEVENTEEN Enticing and Coercing Another to Travel in Interstate or Foreign Commerce for Prostitution Beginning on or before April 1, 2016, and continuing until on or about May 5, 2017 in the Southern District of Texas, GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and 22 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 23 of 45 JOSE LUIS MORENO, a/k/a a/k/a and RAUL a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly induce, entice, and coerce to travel in foreign commerce, from Mexico to Texas, with intent that engage in prostitution and sexual activity for which a person can be charged with a criminal offense. In Violation of Title 18, United States Code, Sections 2422(a) and 2. COUNT EIGHTEEN Conspiracy to Bring In, Transport, Move, Conceal, Harbor, and Shield From Detection Illegal Aliens Beginning on or about April 17, 2017, and continuing until on or about July 24, 2017, in the Southern District of Texas, MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a and ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GRISEL SALAS, a/k/a and JOSE RUBEN and DENIS AMAYA CABALLERO, a/k/a DENNIS CABALLERO, a/k/a CHRISTOPHER CABALLERO, a/k/a ARNOLD LOPEZ, a/k/a 23 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 24 of 45 defendants herein, did knowingly and intentionally combine, conspire, confederate, and agree with each other, and others known and unknown to the Grand Jury, to knowingly and in reckless disregard of the fact that certain aliens had come to, entered, or remained in the United States in violation of law, transport, move, conceal, harbor, shield from detection, and. conspire to transport, move, conceal, harbor, and shield from detection such aliens within the United States, and. did so in furtherance of the aliens entering or remaining in the United States in violation of law, and did so for the purpose of commercial advantage and private gain, and in so doing, did place the lives and physical safety of said aliens in jeopardy. In violation of Title 8, United States, Code, Sections l324(a)(1)(A)(ii), and and and MANNER AND MEANS The unlawful conspiracy was accomplished in the manner and means alleged in paragraphs 1 through 26 of the Indictment, and Counts Nineteen through Twenty-one of this Indictment, which are re?alleged and incorporated herein by reference. OVERT ACTS In furtherance of this conspiracy, and in order to effect and accomplish its objectives, one or more of the defendants committed in the Southern District of Texas the overt acts alleged in paragraphs 1 through 26 of the Indictment, and Counts Nineteen through Twenty-one of this Indictment which are re?alleged and incorporated herein by reference. COUNT NINETEEN Transporting, Moving, Concealing, Harboring, Shielding From Detection, and Conspiring to Transport, Move, Conceal, Harbor and Shield From Detection Aliens On or about April 19, 2017, in the Southern District of Texas, 24 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 25 of 45 MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL UAREZ SIFUENTES, a/k/a and ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a defendants herein, aided and abetted by each other, did knowingly and in reckless disregard of the fact that a certain alien had come to, entered, or remained in the United States in violation of law, transport, move, conceal, harbor, shield from detection, and conspire to tranSport, move, conceal, harbor, and shield from detection such alien within the United States, and did so in furtherance of the aliens entering or remaining in the United States in violation of law, and did so for the purpose of commercial advantage and private gain. In violation of Title 8, United States, Code, Sections l324(a)(1)(A)(ii), and and COUNT TWENTY Transporting, Moving, Concealing, Harboring, Shielding From Detection, and Conspiring to Transport, Move, Conceal, Harbor and Shield From Detection Aliens On or about July 17, 2017, in the Southern District of Texas, MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GRISEL SALAS, a/k/a and 25 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 26 of 45 JOSE RUBEN defendants herein, aided and abetted by each other, did knowingly and in reckless disregard of the fact that certain aliens had come to, entered, or remained. in the United States in violation of law, transport, move, conceal, harbor, shield from detection, and con3pire to transport, move, conceal, harbor, and shield from detection such aliens within the United States, and did so in furtherance of the aliens entering or remaining in the United States in violation of law, and did so for the purpose of commercial advantage and private gain, and in so doing, did place the lives and physical safety of said aliens in jeOpardy. In violation of Title 8, United States, Code, Sections l324(a)(1)(A)(ii), and and and COUNT TWENTY-ON Transporting, Moving, Concealing, Harboring, Shielding From. Detection, and Conspiring to Transport, Move, Conceal, Harbor and Shield From Detection Aliens On or about July 24, 2017, in the Southern District of Texas, ERIK IVAN ALVAREZ-CHAVEZ, a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, afk/a a/k/a DENIS AMAYA CABALLERO, a/k/a DENNIS CABALLERO, a/k/a CHRISTOPHER CABALLERO, a/k/a ARNOLD LOPEZ, a/k/a and MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a defendants herein, aided and abetted by each other, did knowingly and in reckless disregard of the fact that certain aliens had come to, entered, or remained in the United States in violation of law, tranSport, move, conceal, harbor, shield from detection, and conspire to transport, move, conceal, harbor, and shield from detection such aliens within the United States, and did so in 26 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 27 of 45 furtherance of the aliens entering or remaining in the United States in Violation of law, and did so for the purpose of commercial advantage and private gain. In Violation of Title 8, United States, Code, Sections 1324(a)(1)(A)(ii), and (V), and I324(a)(l COUNT TWENTY-TWO Conspiracv to Import Aliens for Immoral Purposes Beginning on or about January 10, 2009, and continuing until on or about May 5, 2017, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a and 27 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 28 of 45 GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, did knowingly and intentionally combine, conspire, confederate, and agree with each other, and others known and unknown to the Grand Jury, to knowingly import into the United States, aliens for the purpose of prostitution, and did knowingly hold aliens in pursuance of the importatation of said aliens into the United States for the purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor aliens in pursuance of the importatation of said aliens into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section 371. MANNER AND MEANS The unlawful conspiracy was accomplished in the manner and means alleged in paragraphs 1 through 26 of the Indictment, and Counts Twenty?three through Twenty-seven of this Indictment, which are re?alleged and incorporated herein by reference. OVERT ACTS In furtherance of this conspiracy, and in order to effect and accomplish its objectives, one or more of the defendants committed in the Southern District of Texas the overt acts alleged in paragraphs 1 through 26 of the Indictment, and Counts Twenty?three through Twenty?seven of this Indictment, which are re-alleged and incorporated herein by reference. COUNT Importation of Alien for Immoral Purpose Beginning on or before January 1, 2009, and continuing until on or about December 31, 2011, in the Southern District of Texas, MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a 28 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 29 of 45 WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and RAUL a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly import into the United States, an alien, for the purpose of prostitution, and did knowingly hold an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section 1328 and 18, United States Code, Section 2. COUNT TWENTY-FOUR Importation of Alien for Immoral Purpose Beginning on or before April 20, 2012, and continuing until on or about July 18, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a 29 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 30 of 45 GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly import into the United States, an alien, for the purpose of prostitution, and did knowingly hold an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section I328 and 18, United States Code, Section 2. COUNT TWENTY-FIVE Importation of Alien for Immoral Purpose Beginning on or before September I, 2012, and continuing until on or about September 30, 2013, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/lda and GABRIELA GONZALEZ-FLORES, a/k/a a/k/a 30 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 31 of 45 a/lda GABRIELA a/k/a IELA GONZALES, defendants herein, aided and abetted by each other, and by other persons, did knowingly import into the United States, an alien, for the purpose of prostitution, and did knowingly hold an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor an alien, in pursuance of the importatation'of said alien into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section 1328 and 18, United States Code, Section 2. COUNT Importation of Alien for Immoral Purpose Beginning on or before April 1, 2016, and continuing until on or about May 5, 2017, in the Southern District of Texas, GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a JOSE LUIS MORENO, a/k/a a/k/a and RAUL a/k/a 31 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 32 of 45 defendants herein, aided and abetted by each other, and by other persons, did knowingly import into the United States, an alien, for the purpose of prostitution, and did knowingly hold an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section 1328 and 18, United States Code, Section 2. COUNT TWENTY-SEVEN Importation of Alien for Immoral Purpose Beginning on or before April 12, 2017, and continuing until on or about April 19, 2017, in the Southern District of Texas, MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a and ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a defendants herein, aided and abetted by each other, and by other persons, did knowingly import into the United States, an alien, for the purpose of prostitution, and did knowingly hold an alien, in pursuance of the importatation of said alien into the United States for the 32 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 33 of 45 purpose of prostitution, and did knowingly keep, maintain, control, support, employ, and harbor an alien, in pursuance of the importatation of said alien into the United States for the purpose of prostitution. In Violation of Title 8, United States Code, Section 1328 and 18, United States Code, Section 2. COUNT TWENTY-EIGHT Possession with Intent to Distribute Heroin On or about September 12, 2016, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a a defendant herein, knowingly and intentionally possessed with intent to distribute a mixture and substance containing a detectable amount of heroin, a Schedule 1 narcotic controlled substance. In violation of 21 United States Code, Sections 84l(a)(l) and 84l(b)(l COUNT TWENTY-NIN Possession with Intent to Distribute at Least 50 Grams of Methamphetamine On or about December 5, 2016, in the Southern District of Texas, FREDDY MONTES, a/k/a FREDDY MON TEZ, a/k/a a/k/a a defendant herein, knowingly and intentionally possessed with intent to distribute at least 50 grams of methamphetamine, a Schedule II controlled substance. In Violation of 21, United States Code, Sections 84l(a)(l) and 33 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 34 of 45 COUNT THIRTY Illegal Dealing in Firearms On or about October 7, 2016, in the Southern District of Texas, GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a and VICTOR JAVIEL GONZALEZ, a/k/a VICTOR MANUEL a/k/a a/k/a COCHE, a/k/a CHUCHE, defendants herein, aided and abetted by each other, not being licensed dealers, importers, and manufacturers of ?rearms within the meaning of Chapter 44, Title 18, United States Code, did willfully engage in the business of dealing in firearms. In Violation of 18, United States Code, Sections 923(a), and COUNT THIRTY-ONE Convicted Felon in Possession of a Firearm On or about October 7, 2016, in the Southern District of Texas, VICTOR GONZALEZ, a/k/a VICTOR MANUEL a/k/a a/k/a COCHE, a/lda CHUCHE, a defendant herein, being previously convicted of a crime that is punishable by a term of imprisonment in excess of one year, did knowingly possess, in and affecting foreign and interstate commerce: One (1) Glock Model 42 .380 pistol (serial number One (1) Stoeger Model Cougar 800 9 mm. pistorl (serial number One (1) Smith and Wesson Model BG380 .380 pistol (serial number and 34 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 35 of 45 One (1) Smith and Wesson Moel SW40VE .40 caliber pistol (serial number PBD3 743). In violation of 18 United States Code, Section 922(g)(1). COUNT THIRTY-TWO Illegal Re?entgy On or about September 7, 2017, in the Southern District of Texas, CLAUDIA a/k/a a/k/a CLAUDIA JACKELY SORIANO, a defendant herein, an alien who previously had been denied admission, excluded, deported, and removed from the United States, knowingly and unlawfully was present in the United States i when found in Houston, Texas, without having obtained consent before March 2003, from the Attorney General of the United States to reapply for admission into the United States; and without having obtained corresponding consent after February 2003, from the Secretary of the Department of Homeland Security pursuant to 6 U.S.C. 202(3) and (4) and 6 U.S.C. 557. In violation of Title 8, United States Code, Section 1326(a). COUNT THIRTY-THREE Illegal Re?entry On or about September 7, 2017, in the Southern District of Texas, JIMMY IA CHAVEZ, a/k/a YIMMY MEI IA CHAVEZ, a/k/a JIMY JOSUE MEJIA CHAVEZ, a defendant herein, an alien who previously had been denied admission, excluded, deported, and removed from the United States, knowingly and unlawfully was present in the United States when found in Houston, Texas, without having obtained consent before March 2003, from the Attorney General of the United States to reapply for admission into the United States; and 35 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 36 of 45 without having obtained corresponding consent after February 2003, from the Secretary of the Department of Homeland Security pursuant to 6 U.S.C. 202(3) and (4) and 6 U.S.C. 557. In Violation of Title 8, United States Code, Section 1326(a). COUNT THIRTY-FOUR Illegal Re?entry On or about September 7, 2017, in the Southern District of Texas, JUAN CARLOS CONTRERAS CERVANTES, a/k/a a defendant herein, an alien who previously had been denied admission, excluded, deported, and removed from the United States, knowingly and unlawfully was present in the United States when found in Houston, Texas, without having obtained consent before March 2003, from the Attorney General of the United States to reapply for admission into the United States; and without having obtained corresponding consent after February 2003, from the Secretary of the Department of Homeland Security pursuant to 6 U.S.C. 202(3) and (4) and 6 U.S.C. 557. In Violation of Title 8, United States Code, Section 1326(a). COUNT THIRTY-FIVE False Statement in an Immigration Document On or about Jilly 19, 2013, in the Southern District of Texas, ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a the defendant, did knowingly make a false statement that he subscribed as true under oath and penalty of perjury in a Form I?82l Application for Temporary Protected Status, which is a document prescribed under the immigration laws and regulations of the United States, by stating: 36 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 37 of 45 (1) His name is Jorge Ovidio Hernandez and the only other name he has ever used is Jorge O. Hernandez Rosales; (2) He is a native, citizen and national of El Salvador; and (3) He was born on September 15, 1975 in Santa Isabel, El Salvador, and such statements had no reasonable basis in law or fact. In violation of Title 18, United States Code, Sections 1546(a). COUNT False Statement in an Immigration Document On or about March 3, 2015, in the Southern District of Texas, ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a the defendant, did knowingly make a false statement that he subscribed as true under oath and penalty of perjury in a Form 1?821 Application for Temporary Protected Status, which is a document prescribed under the immigration laws and regulations of the United States, by stating: (1) His name is Jorge Ovidio Hernandez and the only other name he has ever used is Jorge Ovidio Hernandez Rosales; (2) He is a native, citizen and national of El Salvador; (3) He was born on September 15, 1975 in Santa Isabel, El Salvador; (4) He has never been convicted of or has ever committed acts which constitute the essential elements of a crime (other than a purely political offense) (5) He has never engaged in any other unlawful activity in the United States; and 37 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 38 of 45 (6) He has never, by fraud of willfully misrepresenting a material fact, sought to obtain a visa or other documentation, admission to the United States, or any other immigration bene?t, and such statements had no reasonable basis in law or fact. In violation of Title 18, United States Code, Section 1546(a). COUNT THIRTY-SEVEN Aggravated Identity Theft On or about July 19, 2013, in the Houston Division of the Southern District of Texas, ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a the defendant herein, did knowingly possess and use without lawful authority a means of identi?cation of another person, to~wit, name, date of birth, and place of birth, and birth certi?cate of .O.H, during and in relation to a violation of Title 18, United States Code, Section 1546(a) (False Statement in an Immigration Document). In violation of 18 United States Code, Section 1028A. NOTICE OF CRIMINAL FORFEITURE (18 U.S.C. 924(d) and 28 U.S.C. ?2461(c)) Pursuant to Title 18, United States Code, Section 924(d) and Title 28, United States Code, Section 2461(0), the United States gives notice to the defendants, GIOVANMAVMI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a and VICTOR GONZALEZ, a/k/a VICTOR MANUEL a/k/a a/k/a COCHE, a/k/a CHUCHE, 38 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 39 of 45 that in the event of a conviction of an offense in violation of Title 18, United States Code, Sections 922(g) or 924, all ?rearms and ammunition involved in or used in such offense(s) are subject to forfeiture. NOTICE OF FORFEITURE (18 U.S.C. 1594(d)) Pursuant to Title 18, United States Code, Section 1594(d), the United States gives notice - to defendants, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA MORENO-REYNA, a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a 'a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA. GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a and EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a HECTOR REYNA, a/k/a a/k/a a/k/a ANADALIT DUARTE, a/k/a a/k/a ANN DALIT DUARTE GARCIA, 39 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 40 of 45 ISRAEL JUAREZ SIFUENTES, a/k/a and BIANCA STEPHANIE REYNA, a/k/a that in the event of conviction of an offense in Violation of 18 U.S.C. 1591 or 1594, the following property is subject to forfeiture: (1) all property, real or personal, that was involved in, used, or intended to be used to commit or to facilitate the commission of such Violation, and any property traceable to such property; and (2) all property, real or personal, constituting or derived from, proceeds obtained, directly or indirectly, as a result of such Violation, and any property traceable to such property. NOTICE OF FORFEITURE (18 U.S.C. 982(a)(6); 8 use. 1324(b) and 28 U.S.C. 2461(c)) The United States gives notice to defendants, MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA MORENO-REYNA, a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a and ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GRISEL SALAS, a/k/a and JOSE RUBEN and DENIS AMAYA CABALLERO, a/k/a DENNIS CABALLERO, a/k/a CHRISTOPHER CABALLERO, a/k/a ARNOLD LOPEZ, a/k/a 40 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 41 of 45 that in the event of conviction of an offense in violation of 8 U.S.C. 1324(8), the following property is subject to forfeiture: (1) all conveyances, including vessels, vehicles, and aircraft, used in the commission of the offense pursuant to 18 U.S.C. 982(a)(6); (2) all real and personal property that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the offense pursuant to 18 U.S.C. 982(a)(6); (3) all real and personal property that is used to facilitate, or is intended to be used to facilitate, the commission of the offense pursuant to 18 U.S.C. 982(a)(6); and (4) all conveyances, including vessels, vehicles, and aircraft, used in the commission of the offense, the gross proceeds of such violation, and all property traceable to such conveyances or proceeds pursuant to 8 U.S.C. 1324(b) and 28 U.S.C. 2461(c). NOTICE OF FORFEITURE (18 U.S.C. 2428; 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c)) The United States gives notice to defendants, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, 41 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 42 of 45 WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/ a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a and GILBERT ESPTNOZA GARCIA, a/k/a GIL GARCIA, a/k/a that in the event of conviction of an offense in violation of 18 U.S.C. 2421, 2422, or a conSpiracy to commit such offense(s), the following is subject to forfeiture: (1) All property, real or personal, that was used or intended to be used to commit or to facilitate the commission of a violation of 18 U.S.C. 2421 or 2422 pursuant to 18 U.S.C. 2428; (2) A11 pr0perty, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of a violation of 18 U.S.C. 2421 or 2422 pursuant to 18 U.S.C. 2428; and (3) All preperty, real or personal, which constitutes or is derived from proceeds traceable to a violation of 18 U.S.C. 2421 or 2422 or conspiracy to commit such offense(s) pursuant to 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c). NOTICE OF CRIMINAL FORFEITURE (18 U.S.C. and 28 U.S.C. 2461(c)) Pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), the United States gives notice to defendants: FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a GIOVANI ALEXANDER ALECIO, a/k/a JOSE EDGARDO GONZALEZ, a/k/a MELISA DOMINGUEZ, a/k/a MELISA BAZAN DOMINGUEZ, a/k/a MELISA RUBIO, a/k/a MELISA BASAL, a/k/a a/k/a MARIA ANGELICA a/k/a a/k/a a/k/a a/k/a a/k/a a/k/a 42 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 43 of 45 WILLIAM ALBERTO LOPEZ, a/k/a WILIAM ALBERTO LOPEZ-MORENO, a/k/a DAVID MALDONADO, a/k/a a/k/a a/k/a ISRAEL JUAREZ SIFUENTES, a/k/a ERIK IVAN ALVAREZ-CHAVEZ, a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a GABRIELA a/k/a a/k/a a/k/a GABRIELA a/k/a IELA GONZALES, WALTER LOPEZ, a/k/a WALTER BARRIOS MORENO, a/k/a EDDIE ALEJANDRO TORRES, a/k/a RAUL a/k/a JOSE LUIS MORENO, a/k/a a/k/a and GILBERT ESPINOZA GARCIA, a/k/a GIL GARCIA, a/k/a that in the event of conviction of an offense in violation of Title 8, United States Code, Section 1328 or a conspiracy to commit such offense, all property, real or personal, which constitutes or is derived from proceeds traceable to such violation or such conspiracy are subject to forfeiture. NOTICE OF CRIMINAL FORFEITURE (18 U.S.C. Pursuant to Title 18, United States Code, Section 982(a)(6), the United States gives notice to defendant, ERIK IVAN a/k/a JORGE OVIDIO HERNANDEZ, a/k/a GEORGE HERNANDEZ, a/k/a a/k/a that in the event of conviction of an offense in violation of 18 U.S.C. 1546, the following is subject to forfeiture: (I) all conveyances, including vessels, vehicles, and aircraft, used in the commission of the offense; 43 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 44 of 45 (2) all real and personal property that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the offense; and (3) all real and personal prOperty that is used to facilitate, or is intended to be used to facilitate, the commission of the offense. NOTICE OF CRIMINAL FORFEITURE (21 U.S.C. 853) Pursuant to Title 21, United States Code, Section 853, the United States gives notice to the defendant, FREDDY MONTES, a/k/a FREDDY MONTEZ, a/k/a a/k/a that in the event of conviction of an offense in Violation of Title 21, United States Code, Section 841, the following is subject to forfeiture: (1) all property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such offense; and (2) all property used or intended to be used, in any manner or part, to commit, or to facilitate the commission of such offense. PROPERTY SUBJECT TO FORFEITURE The property subject to forfeiture includes, but is not limited to, the following: One (1) Glock Model 42 .380 pistol (serial number (2) One (1) Stoeger Model Cougar 800 9 mm. pistol (serial number (3) One (1) Smith and Wesson Model BG380 .380 pistol (serial number (4) One (1) Smith and Wesson Moel SW40VE .40 caliber pistol (serial number PBD3743). (5) One (1) 2007 black Chevrolet Trailblazer; (6) One 1) 2013 grey Dodge Ram pickup; 44 Case 4:17-cr-00651 Document 1 Filed in TXSD on 11/03/17 Page 45 of 45 ORIGINAL SIGNATURE ON FILE