aka Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 1 of 10 FILED UNITED STATES DISTRICT COURT NOV 0 2015 SOUTHERN DISTRICT OF TEXAS DIVISION ?m:.mq.anucout UNITED STATES OF AMERICA 5 V. . - CnminalNo 36-1589 GUILLERMO MORALES also known as ?Don Gin? ERICK ALAN TORRES DAVILA also known as ?Cachorro? ELIZABETH LOPEZ-PEREZ DAVID MARTINEZ EFRAIN ROBLEDO 5 also known as ?Payo? RAUL VILLEGAS VILLANUEVA OLEOMAR MONT ALVO also known as ?Omar? JESUS REMEDIOS MANQUEROS ANTHONY RAY SANCHEZ 8 AMAIRANI FLORES also known as ?Lizeth? 11/?7/16 cr MARIO GONZALEZ NORBERTO CANTU HECTOR HERNANDEZ CARDENAS 3 ELMER MACARIO RAMOS OSCARTANGUMA . JR 11/21/16 ?cr also known as ?Flaco? ARMANDO TANGUMA ANDREW MARTINEZ True Name MARTINEZ 11/7/ 1 6 Cr HEATHER SEGURA EFRAIN DIMAS LOPEZ SAMUEL JESUS OLIVO SEALED INDICTMENT THE GRAND JURY CHARGES: ave-4r Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 2 of 10 Count One From on or about February 2013, to on or about the date of this Indictment, in the Southern District of Texas and within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gio? ERICK ALAN TORRES DAVILA also known as ?Cachorro? ELIZABETH LOPEZ-PEREZ DAVID MARTINEZ EFRAIN ROBLEDO also known as ?Payo? RAUL VILLEGAS VILLANUEVA OLEOMAR MONT ALVO also known as ?Omar? JESUS REMEDIOS MANQUEROS ANTHONY RAY SANCHEZ AMAIRANI FLORES also known as ?Lizeth? MARIO GONZALEZ NORBERTO CANTU HECTOR HERNANDEZ CARDENAS ELMER MACARIO RAMOS OSCAR TANGUMA . JR also known as ?Flaeo? ARMANDO TANGUMA aka ANDREW MARTINEZ True Name: ANDRES MARTINEZ HEATHER SEGURA and DIMAS LOPEZ did knowingly and intentionally conspire and agree together and with other persons known and unknown to the Grand Jurors, to possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more of a mixwre or substance containing a detectable amount of cocaine, a Schedule 1] controlled substance; 50 grams or more of Case 7216-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 3 of 10 methamphetamine, a Schedule 1] controlled substance; 100 kilograms or more of a mixture or substance containing a detectable amount of marijuana, a Schedule I centrolled substance. in violation of Title 21. United States Code, Seetions 846, 84l(a)(l), 84l(b)(l)(A) and Count Two From on or about January 20l5 and up to this date, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gio? SAMUEL JESUS OLIVO - and NORBERTO CANTU did knowingly conspire and agree together and with other persons known and unknown to the Grand Jurors to transport, transmit and transfer and attempt to transport, transmit and transfer monetary instruments and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of Speci?ed unlawful activity. that is the distribution of a controlled substance. In violation of Title 18, United States Code, Sections 1956(a)(2)(A) and Count Three On or about April l2, 2015, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gio? and SAMUEL JESUS OLIVO did attempt to transport monetary funds, that is approximately $998,030.00 in United States currency, from a place in the United States, that is Alabama, to a place outside the United States, T?vr' w?r?nlw Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 4 of 10 that is Mexico, with the intent to promote the carrying on of specified unlawful activity, that is the distribution of a controlled substance. in violation of Title 18, United States Code, Sections 1956(a)(2)(A) and 2. Count Four On or about October 7, 2015, in the Southern District of Texas and within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gio? ERICK ALAN TORRES DAVILA also known as ?Caehorro? and ELIZABETH LOPEZ-PEREZ did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 42 kilograms of a mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance. In violation of Title 21, United States Code, Sections 84 and 84l(b)(l)(A) and Title l8, United States Code, Section 2. Count Five On or about March 31, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gio? DAVID MARTINEZ OLEOMAR MONTALVO also known as ?Omar? JESUS REMEDIOS MANQUEROS ANTHONY RAY SANCHEZ and m. twp-Rm .M -ot. Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 5 of 10 did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 100 kilograms or more, that is, approximately 425 kilograms of a mixture or substance containing a detectable amount of marijuana a Schedule I controlled substance. In violation of Title 21 . United States Code, Sections 841(aXl) and 84l(b)(l)(B) and Title is; United States Code, Section 2. Count Six On or about April 1 1, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, ERICK ALAN TORRES DAVILA also known as ?Cachorro? WW AMAIRAN I FLORES also known as ?Linda? and MARIO GONZALEZ did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substances involved were 5 kilograms or more, that is, approximately 13 kilograms of a mixture or substance containing a detectable amount of cocaine, :1 Schedule II controlled substance. In violation 0f Title 21, United States Code, Sections 841 and 84l(b)(l and Title 18, United States Code, Section 2. Count Seven On or about April 25, 20 i 6, in the Southern District of Texas and within the jurisdiction of the Court. defendants. GUILLERMO MORALES -. . We. "Wart? Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 6 of 10 also known as ?Don Gio? ERICK ALAN TORRES DAVILA also known as ?Cachorro? DAVID MARTINEZ HECTOR HERNANDEZ CARDENAS ELMER MACTRIO RAMOS did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substances involved were 5 kilograms or more, that is, approximately 2i 5 kilograms of a mixture or substance containing a detectable amount of cocaine, a Schedule controlled substance. In violation of Title 21, United States Code, Sections 841(c)(1) and 841(b)(i)(A) and Title 18, United States Code, Section 2. Count Eight On or about May 12, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, DAVID MARTINEZ OSCAR TANGUMA . JR also known as ?Flaco? ARMANDO TANGUMA MARTINEZ True Name: ANDRES MARTINEZ and HEATHER SEGURA did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substances involved were 500 grams or more, that is, approximately 4 kilograms of a mixture or substance containing a detectable amount of cocaine, :1 Schedule [1 controlled substance. .: vs?! .uwvu "er . qw?Wa?M?vv-ir we" . ?um Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 7 of 10 In violation of Title 21, United States Code, Sections 841(a)(1) and 84l(b)(1)(B) and Title 18, United States Code, Section 2. Count Nine On or about May 17, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, GUILLERMO MORALES also known as ?Don Gin? and did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 50 kilograms or more, that is, approximately 82 kilograms of a mixture or substance containing a detectable amount of marijuana a Schedule 1 controlled substance; In violation of Title 21, United States Code, Sections 841 and 84l(b)(1)(C) and Title 18, United States Code, Sectioa 2. Count On or about August 30, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, DAVID MARTINEZ and EFRAINLOIIEZ DIMAS LOPEZ did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 50 grams or more, that is, approximately 1,955 grams of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. In violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A) and Title i l8, United States Code, Section 2. SW Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 8 of 10 *u NOIICE OF CRIMINAL FQRFEITURE NOTICE or FORFEITURE (21 U.S.C. 353) Pursuant to Title 21, United States Code, Section 853, the United States gives notice to the Defendants charged in Counts and 4 through 10 of this Indictment, that upon conviction of a violation of Title 21, United StateS Code, Sections 841 and/or 846, I. all property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such violation; and 2. all property used, or intended to be used, in any manner or part. to commit, or to facilitate the commission of, such violation, is subject to forfeiture. NOTICE or FORFEITURE (is use. 982(a)(l)) Pursuant to Titie 18, United States Code, Section 982(a)(1), the United States gives notice to the Defendants charged in Counts 2 and 3 of this Indictment that upon conviction of a violation of Title 18, United States Code, Section 1956, including conspiracy, all property, real and personal, involved in such violation, and all property traceable to such property, is subject to forfeiture. MONEY JUDGMENT Defendants are notified that upon conviction, a money judgment may be imposed equal to the total value of the property subject to forfeiture, for which the Defendants may be jointly and severally liable. EEOPEBIY SUBJEQI IO Defendants are noti?ed that the property subject to forfeiture includes, but is notJimited to, the following property: a. at least $6,000,000.00 in United States currency; m. w. -1 .. Case 7 :16?cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 9 of 10 b. real property, improvements and appurtenances located in Donna, Texas and legally described as follows: Lot 54 Birch Subdivision Phase II, Hidalgo County. Texas, according to the map recorded in Volume 55, Page 60-62, Map Records in the Of?ce of the County Clerk of Hidalgo County Texas. c. real property, improvements and appurtenances located in Edinburg, Texas and legally described as follows: Lot 22, SEMINOLE VALLEY, an addition to the City of Edinburg, Hidalgo County, Texas, according to the map or plat thereof recorded in Volume 31, Page 99, Map Records in the Of?ce of the County Clerk of Hidalgo County, Texas, reference to which here made for all purposes. d. real property, improvements and appurtenances located in Weslaco, Texas and legally described as follows: A 5.60 acres out of Farm Tract 198, Block 181, West Tract Subdivision, Hidalgo County, Texas, according to the map recorded in Volume 2, Page 34, Map Records in the Of?ce of the County Clerk of Hidalgo County. Texas, reference to which is here made for all purposes. SUBSTITUTE ASSETS In the event that property subject to forfeiture, as a result of any act or omission of a Defendant, (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with, a third party; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without dif?culty; the United States will seek to forfeit any other property of the Defendant up to the total value of w, Case 7:16-cr-01589 Document 289 Filed in TXSD on 11/01/16 Page 10 of 10 (5) has been cummingled with other property which cannot be subdivided without dif?culty; the United States will seek to forfeit any other property of the Defendant up to the total value of the property subject to forfeiture, pursuant to Title 21, United States Code, Section 853(1)), and Title 18, United States Code, Section 982(b) incorporating by reference Title 21, United States Code, Section 853(p). A TRUE BILL F0 PERSON f? KENNETH MAGIDSON UNITED STATES ATTORNEY . ASSISTANT UNITED STATES ATTORNEY wh- WW