Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS McALLEN DIVISION ' ' v. ' ' SANTIAGO VILLALOBOS ' also known as “Jimbo” ' JUAN ALBERTO VILLALOBOS ' also known as “Albert” ' VIRGIL LEE CARRILLO ' ERIC GOMEZ ' ERIC CARRILLO ' MICHAEL GRAVES ' URIEL MAYORQUIN CARRILLO ' DANIEL MAYORQUIN CARRILLO ' ROMULO CHAPA ' REYES HERNANDEZ, III ' CHRISTOPHER HAM ' JORGE REYNALDO TAMEZ ' JACOB GARCIA ' ESTEBAN SOLOMON ' ROBERTO EMMANUEL MONTENEGRO ' also known as “Beto” ' also known as “Oso” ' also known as “Panda” ' DEALLEN NETTLES ' JUAN MANUEL FONSECA ' also known as “Red” ' MONICA FONSECA ' JOSE LUIS GONZALEZ JR. ' RUDIS EDGARDO ZELAYA ' TOMAS VILLAREAL ' also known as “Canas” ' RUBY GUZMAN ' LIANG GUO YU ' JONATHAN XIE ' MICHAEL TOVAR ' CHRISTIAN ELIUD BENAVIDES PEREZ ' MARIA E. GARCIA ' GONZALO HERNANDEZ ' UNITED STATES OF AMERICA Criminal No. M-18-0960 Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 2 of 18 SEALED INDICTMENT THE GRAND JURY CHARGES: Count One From on or about May 2012, to on or about the date of this indictment, in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” VIRGIL LEE CARRILLO ERIC GOMEZ JACOB GARCIA ESTEBAN SOLOMON ROBERTO EMMANUEL MONTENEGRO also known as “Beto” also known as “Oso” also known as “Panda” DEALLEN NETTLES JUAN MANUEL FONSECA also known as “Red” JOSE LUIS GONZALEZ JR. and RUDIS EDGARDO ZELAYA 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 mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance. In violation of Title 21, United States Code, Sections 846, 841(a)(1), and 841(b)(1)(A). Count Two From on or about November 2012, to on or about the date of this indictment, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, the defendants, Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 3 of 18 SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” VIRGIL LEE CARRILLO ERIC CARRILLO MICHAEL GRAVES URIEL MAYORQUIN CARRILLO DANIEL MAYORQUIN CARRILLO ROMULO CHAPA REYES HERNANDEZ, III CHRISTOPHER HAM JORGE REYNALDO TAMEZ ROBERTO EMMANUEL MONTENEGRO also known as “Beto” also known as “Oso” also known as “Panda” DEALLEN NETTLES JUAN MANUEL FONSECA also known as “Red” MONICA FONSECA TOMAS VILLAREAL also known as “Canas” RUBY GUZMAN LIANG GUO YU JONATHAN XIE MICHAEL TOVAR CHRISTIAN ELIUD BENAVIDES PEREZ MARIA E. GARCIA and GONZALO HERNANDEZ did knowingly and intentionally conspire and agree together and 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: a) 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 specified unlawful activity, that is, the distribution of a controlled substance, an offense punishable under Title 21 of the laws of the United States. Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 4 of 18 In violation of Title 18, United States Code, Section 1956(a)(2)(A). and, b) to conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit, the purchase of the properties, both real and personal, which involved the proceeds of a specified unlawful activity, that is, the distribution of a controlled substance, a violation of Title 21, knowing that the transaction was designed in whole and in part to conceal and disguise, the nature, source, ownership, and control of the proceeds of said specified unlawful activity and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is, funds represented the proceeds of some form of unlawful activity, in violation of Title 18 United States Code Sections 1956(a)(1)(B)(i). In violation of Title 18, United States Code, Section 1956(h). Count Three Beginning on or about April 24, 2013, and continuing to on or about December 12, 2014, in the in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, JUAN MANUEL FONSECA also known as “Red” and MONICA FONSECA did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit, the purchase of the property located at 8533 Edinburg Ct. Houston, Texas which involved the proceeds of a specified unlawful activity, that is, the distribution of a controlled substance, an offense punishable under Title 21 of the laws of the United States, knowing that the transaction was designed in whole and in part to conceal and disguise, the nature, source, ownership, and control of the proceeds of said specified unlawful activity and that while Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 5 of 18 conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is, funds represented the proceeds of some form of unlawful activity. In violation of Title 18 United States Code Sections 1956(a)(1)(B)(i) and 2. Count Four On or about May 23, 2013, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” VIRGIL LEE CARRILLO ERIC CARRILLO MICHAEL GRAVES and URIEL MAYORQUIN CARRILLO did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $559,225.00 in United States Currency, from a place in the United States, that is Houston, Texas to a place outside the United States, 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 Five On or about September 14, 2013, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 6 of 18 and ROMULO CHAPA did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $1,575,448.00 in United States currency, from a place in the United States, that is, Houston, Texas to a place outside the United States, 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 Six On or about January 21, 2014 in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and URIEL MAYORQUIN CARRILLO did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $300,040.00 in United States currency, from a place in the United States, that is Houston, Texas to a place outside the United States, 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. Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 7 of 18 Count Seven On or about February 12, 2015 in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” DANIEL MAYORQUIN CARRILLO and REYES HERNANDEZ, III did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $699,760.00 in United States currency, from a place in the United States, that is Houston, Texas to a place outside the United States, 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 Eight On or about February 19, 2015, in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” VIRGIL LEE CARRILLO ERIC GOMEZ and JACOB GARCIA did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 78 kilograms of a Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 8 of 18 mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance. In violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A) and Title 18, United States Code, Section 2. Count Nine On or about December 14, 2015, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” CHRISTOPHER HAM JORGE REYNALDO TAMEZ and ROBERTO EMMANUEL MONTENEGRO also known as “Beto” also known as “Oso” also known as “Panda” did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $1,039,960.00 in United States currency, from a place in the United States, that is Houston, Texas to a place outside the United States, 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 Ten On or about December 29, 2015, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 9 of 18 JUAN ALBERTO VILLALOBOS also known as “Albert” ROBERTO EMMANUEL MONTENEGRO also known as “Beto” also known as “Oso” also known as “Panda” and DEALLEN NETTLES did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $332,117.00 in United States currency, from a place in the United States, that is Chicago, Illinois to a place outside the United States, 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 Eleven On or about February 26, 2016 , in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and ESTEBAN SOLOMON did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 131.5 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 841(a)(1) and 841(b)(1)(A) and Title 18, United States Code, Section 2. Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 10 of 18 Count Twelve On or about March 18, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” and JUAN ALBERTO VILLALOBOS also known as “Albert” did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 158 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 841(a)(1) and 841(b)(1)(A) and Title 18, United States Code, Section 2. Count Thirteen From on or about May 18, 2016, to on or about May 19, 2016, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” TOMAS VILLAREAL also known as “Canas” RUBY GUZMAN LIANG GUO YU JONATHAN XIE and MICHAEL TOVAR did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $701,116.00 in United States currency, from a place Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 11 of 18 in the United States, that is Houston, Texas to a place outside the United States, 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 Fourteen On or about July 11, 2016, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” CHRISTIAN ELIUD BENAVIDES PEREZ and MARIA E. GARCIA did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $196,715.00 in United States currency, from a place in the United States, that is Houston, Texas to a place outside the United States, 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 Fifteen On or about July 17, 2016, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and JUAN MANUEL FONSECA Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 12 of 18 also known as “Red” did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $399,920.00 in United States currency, from a place in the United States, that is Combes, Texas to a place outside the United States, 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 Sixteen On or about July 19, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” JUAN MANUEL FONSECA also known as “Red” and JOSE LUIS GONZALEZ JR. did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 10.95 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 841(a)(1) and 841(b)(1)(A) and Title 18, United States Code, Section 2. Count Seventeen On or about August 4, 2016, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 13 of 18 SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and GONZALO HERNANDEZ did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $318,120.00 in United States currency, from a place in the United States, that is Pasadena, Texas to a place outside the United States, 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 Eighteen On or about August 5, 2016, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and GONZALO HERNANDEZ did transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instruments and funds, that is, approximately $1,570,214.00 in United States currency, from a place in the United States, that is Pasadena Texas to a place outside the United States, 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. Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 14 of 18 Count Nineteen On or about October 22, 2016, in the Southern District of Texas and within the jurisdiction of the Court, defendants, SANTIAGO VILLALOBOS also known as “Jimbo” JUAN ALBERTO VILLALOBOS also known as “Albert” and RUDIS EDGARDO ZELAYA did knowingly and intentionally possess with intent to distribute a controlled substance. The controlled substance involved was 5 kilograms or more, that is, approximately 63.5 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 841(a)(1) and 841(b)(1)(A) and Title 18, United States Code, Section 2. Count Twenty On or about December 16, 2016, and continuing to on or about May 14, 2018, in the Southern District of Texas and elsewhere within the jurisdiction of the Court, defendants, JUAN MANUEL FONSECA also known as “Red” and MONICA FONSECA did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit, the purchase of the property and improvements to 18563 Michaels Run Houston, Texas which involved the proceeds of a specified unlawful activity, that is, the distribution of a controlled substance, an offense punishable under Title 21 of the laws of the United States, knowing that the transaction was designed in whole and in part to conceal and Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 15 of 18 disguise, the nature, source, ownership, and control of the proceeds of said specified unlawful activity and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction, that is, funds represented the proceeds of some form of unlawful activity. In violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. NOTICE OF CRIMINAL FORFEITURE (21 U.S.C. § 853(a)) Pursuant to Title 21, United States Code, Section 853(a), the United States of America gives notice to defendants SANTIAGO VILLALOBOS (Counts 1, 8, 11, 12, 16 and 19) also known as “Jimbo” JUAN ALBERTO VILLALOBOS (Counts 1, 8, 11, 12, 16 and 19) also known as “Albert” VIRGIL LEE CARRILLO (Counts 1 and 8) ERIC GOMEZ (Counts 1 and 8) JACOB GARCIA (Counts 1 and 8) ESTEBAN SOLOMON (Counts 1 and 9) ROBERTO EMMANUEL MONTENEGRO (Count 1) also known as “Beto” also known as “Oso” also known as “Panda” DEALLEN NETTLES (Count 1) JUAN MANUEL FONESCA (Counts 1 and 16) also known as “Red” JOSE LUIS GONZALEZ JR. (Counts 1 and 16) and RUDIS EDGARDO ZELAYA (Counts 1 and 19) that upon conviction of an offense in violation of Title 21, United States Code, §§ 841 and 846, the following is subject to forfeiture: 1) all property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such violation; and Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 16 of 18 2) all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, such violation. NOTICE OF FORFEITURE (18 U.S.C. ' 982(a)(1)) Pursuant to Title 18, United States Code, Section 982(a)(1), the United States gives notice to defendants SANTIAGO VILLALOBOS (Counts 2, 4, 5, 6, 7, 9, 10, 13, 14, 15, 17 and 18) also known as “Jimbo” JUAN ALBERTO VILLALOBOS (Counts 2, 4, 5, 6, 7, 9, 10, 13, 14, 15, 17 and 18) also known as “Albert” VIRGIL LEE CARRILLO (Counts 2 and 4) ERIC CARRILLO (Counts 2 and 4) MICHAEL GRAVES (Counts 2 and 4) URIEL MAYORQUIN CARRILLO (Counts 2, 4 and 6) DANIEL MAYORQUIN CARRILLO (Counts 2, 4, 6 and 7) ROMULO CHAPA (Counts 2 and 5) REYES HERNANDEZ, III (Counts 2 and 7) CHRISTOPHER HAM (Counts 2 and 9) JORGE REYNALDO TAMEZ (Counts 2 and 9) ROBERTO EMMANUEL MONTENEGRO (Counts 2, 9 and 10) also known as “Beto” also known as “Oso” also known as “Panda” DEALLEN NETTLES (Counts 2 and 10) JUAN MANUEL FONESCA (Counts 2, 3, 15 and 20) also known as “Red” MONICA FONESCA (Counts 2, 3 and 20) TOMAS VILLAREAL (Counts 2 and 13) also known as “Canas” RUBY GUZMAN (Counts 2 and 13) LIANG GUO YU (Counts 2 and 13) JONATHAN XIE (Counts 2 and 13) MICHAEL TOVAR (Counts 2 and 13) CHRISTIAN ELIUD BENAVIDES PEREZ (Counts 2 and 14) MARIA E. GARCIA (Counts 2 and 14) and GONZALO HERNANDEZ (Counts 2, 17 and 18) that upon conviction in violation of Title 18, United States Code, §§ 1956(h), 1956(a)(2)(A) and 1956(a)(1)(B)(i), all property, real or personal, involved in money laundering offenses or traceable Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 17 of 18 to such property, is subject to forfeiture. PROPERTY SUBJECT TO FORFEITURE Defendants are notified that the property subject to forfeiture includes, but is not limited to, the following property: Asset Asset Type Description 1 $159,544.22 Net sale proceeds from the sale of real property at 18567 and 18563 Michaels Run, Montgomery, Texas on April 30, 2018 2 $599,255.00 United States currency seized on or about May 23, 2013 3 $1,575,488.00 United States currency seized on or about September 14, 2013 4 $300,040.00 United States currency seized on or about January 21, 2014 5 $699,760.00 United States currency seized on or about February 12, 2015 6 $1,039,960.00 United States currency seized on or about December 14, 2015 7 $332,117.00 United States currency seized on or about December 29, 2015 8 $701,116.00 United States currency seized on or about May 19, 2015 9 $196,715.00 United States currency seized on or about July 11, 2016 10 $399,920.00 United States currency seized on or about July 17, 2016 11 $318,120.00 United States currency seized on or about August 4, 2016 12 $1,570,214.00 United States currency seized on or about August 5, 2016 Case 7:18-cr-00960 Document 37 Filed in TXSD on 06/13/18 Page 18 of 18' The United States intends to seek the imposition of a money judgment against each defendant. Defendants are noti?ed that in the event that one or more conditions listed in Title 21, United States Code, Section 853(p) exists, the United States will seek to forfeit any other property of the defendants up to the total value of the property subject to forfeiture. A TRUE BILL FOREPERSON RYAN K. PATRICK UNITED STATES ATTORNEY @217?; QM ASSISTANT UNITED STATES ATTORNEY