Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 1 of 34 United States DistricllCourt Southern Digginct of Texas UNITED STATES DISTRICT COURT APR 0 2019 SOUTHERN DISTRICT OF TEXAS . MCALLEN DIVISION David J. Bradley, Clerk UNTED STATES OF AMERICA . v. . RICARDO QUINTANILLA also known as ?Richard? CRIMINAL NO. JOHN F. CUELLAR ARTURO C. CUELLAR, JR. also known as DANIEL J. GARCIA I SUPERSEDING INDICTMENT THE GRAND JURY CHARGES: COUNT ONE 18 U.S.C. 1349 (Conspiracy to Commit Honest Services Wire Fraud) At all times relevant to this Indictment, with dates, times, and amounts being approximates: RELEVANT INDIVIDUALS AND ENTITIES 1. Defendant RICARDO QUINTANILLA (QUINTANILLA) aka ?Richard?- is a businessman who lived and worked in Weslaco, Texas. 2. Defendant ARTURO C. CUELLAR, JR. aka. is a resident of Progreso Lakes, Texas, who served as a commissioner of Hidalgo County, Texas, from March 2010 to November 2010 and approximately January 2013 to December 2016. 3. Defendant JOHN F. CUELLAR is an attorney based in Weslaco, Texas, who served as a Weslaco City Commissioner from May 1995 to November 2014. For large parts of his tenure on the Weslaco City Commission (the ?commission?), including from at least June 2007 to May 2009 and from May 2010 to November 2014, JOHN F. CUELLAR was selected by the Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 2 of 34 commission to serve as mayor pro tem. As a commissioner, JOHN F. CUELLAR was an agent of the City of Weslaco. 4. Defendant DANIEL J. GARCIA (GARCIA) is an attorney based in Rio Grande City, Texas, who seryed on the Rio Grande City Consolidated Independent School District Board of Trustees. 5. Leonel ?Leo? LOPEZ (LOPEZ) is a resident of Starr County, Texas. 6. Gerardo ?Jerry? TAFOLLA (TAFOLLA) is a resident of Weslaco, Texas and an elected member Of the commission. 7. Company A was an international engineering and cOnstruction company that performed large?scale infrastructure projects for public and private clients. Person A was an employee of Company A. - 8. Company was an engineering company based in San Antonio, Texas. Person was the owner of Company B. 9. Company was an engineering company based in McAllen, Texas. Person was the owner of Company 10. Company was a business entity owned, in part, by ARTURO C. CUELLAR, JR. and based in Corpus Christi, Texas. - ?1 1. - Person was an attorney based in Houston, Texas. GENERAL ALLEGATIONS The Weslaco City Commission 12.? The Texas Constitution, the laws of the State of Texas, and the charter of the City of Weslaco established ethical standards of conduct for elected public officials, including Weslaco City Commissioners. These standards included an oath to faithfully execute the duties of the of?ce of commissioner and to preserve, protect, and defend the Constitution and the laws of the United 2 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 3 of 34 States and the State Of Texas. Accordingly, commissioners owed a ?duciary duty to the City of Weslaco, the commission, and the people of the City of Weslaco. 13. As of?cials in the city government, defendant JOHN F. CUELLAR and TAFOLLA each owed a ?duciary duty to the City of Weslaco and to its citizensto perform the . duties and responsibilities of their of?ce free from corrupt in?uence. As elected of?cials in the State of Texas, JOHN F. CUELLAR and TAFOLLA swore to uphold the United States Constitution, the Texas Constitution, and the laws of the State of Texas and to faith?ally execute the duties of their of?ce. 14. The commission was authorized to take of?cial action only when a quorum?a majority of duly elected commissioners?was present. When a quorum was present, the commission could act based on a majority vote. I 15. Pursuant to the Texas Open Meetings Act, Tex. Gov?t Code Ann. 551, et seq., the commission, as a city government in Texas, was authorized to conduct of?cial business only after providing at least 72 hours of public notice of the time, place, and subject matter of the meeting. Such meetings were generally required to be open to the public, with closed meetings and executive sessions permitted only under narrowly drawn exceptions. 16. Prior to May 2008, the commission was comprised of a mayor, a mayor pro tern, and three commissioners elected at large. The mayor pro tem was a commissioner selected by a majority vote of the commissioners to assume the mayor?s duties when the mayor was absent. 17. Starting in or about May 2008, the commission was comprised of six commissioners elected from single-member?districts, a mayor elected at large, and a mayor pro tem, selected in the same manner as prior to May 2008. Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 4 of 34 18. Due to his long tenure ?on the commission and relationship to ARTURO C. CUELLAR, JR., a prominent politician in Hidalgo County, JOHN F. CUELLAP exerted a signi?cant amount of power and in?uence on the commission and over other city of?cials. JOHN F. CUELLAR was the defacto leader of the commission?s majority voting bloc during the vast majority of the charged conspiracy. The Weslaco Water Treatment Facilities 19. In or about 2004, the Texas Commission on Environmental Quality noti?ed the City of Weslaco that its water treatment facilities were in violation of Texas environmental regulations. The city?s water treatment facilities included the Water Treatment Plant (W TP), which processedlthe city?s potable water, and the North Wastewater Treatment Plant and South Wastewater Treatment Plant which together processed the city?s - wastewater. 20. In or about 2007, the commission voted to issue approximately $28. million in municipal bonds to ?nance several infrastructure projects in the Weslaco area. The two largest and costliest projects to be paid for by the bond funds were to rebuild the and to perform repairs to the WTP. 21. In or about 2008, the commission hired Company A to act as the construction manager for the in?'astructure projects to be funded by the bond issuance. Under the contract, Company A would effectively select the companies to perform the infrastructure work to be paid for with the bond ?nds. 22. In or about March 18, 2008, Company A granted to itself, subject to the apprOval of the commission, the contracts to rehabilitate the and WTP, the two costliest projects to be completed using the $28 million in municipal bond proceeds. Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 5 of 34 THE CONSPIRACY 23. From in or about March 2008 through in or about December 2016, in the Southern District of Texas and elsewhere, the defendants, RICARDO QUINTANILLA, also known as ?Richard,? JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., also known as and DANIEL J. GARCIA LOPEZ, and TAFOLLA, did knowingly combine, conspire, confederate, and agree together and with others known and unknown to the Grand Jury, to devise and intend to devise a scheme and I arti?ce to defraud and to deprive, by means of material false and fraudulent pretenses, representations, and promises, and to transmit and cause to be transmitted by means of wire communication in interstate commerce, any writings, signs, signals, pictures, and sounds for the purpose of executing the scheme and arti?ce to defraud and deprive, that is, to deprive the City of Weslaco, the Weslaco City Commission, and the citizens of Weslaco of their right to the honest services of JOHN F. CUELLAR and TAFOLLA through bribery, in violation of l? U.S.C. 1343 and 1346. THE SCHEME TO DEFRAUD 24. From in or about March 2008 through in or about December 2016, in the Southern District of Texas and elsewhere, the defendants, QUINTANILLA, JOHN F. CUELLAR, ARTURO C. CUELLAR, R., GARCIA, LOPEZ, and TAFOLLA, and others known and unknown to the Grand Jury, devised and intended to devise a scheme and arti?ce to defraud and to deprive the City of Weslaco, the Weslaco City Commission, and the citizens of Weslaco of their intangible right to the honest services of JOHN F. CUELLAR and TAFOLLA, both elected of?cials, through bribery. Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 6 of 34 PURPOSE OF THE CONSPIRACY 25. The purposes of the conspiracy included, but were not limited to, the following: a. - For JOHN F. CUELLAR to enrich himself by accepting bribes in exchange for using his of?cial position as a Weslaco City Commissioner to take of?cial acts to bene?t and help Company A, Company B, and Company obtain millions of dollars in contracts from the City of Weslaco; b. For TAFOLLA to enrich himself by accepting bribes in exchange for using his of?cial position as a Weslaco City Commissioner to take of?cial acts to bene?t and help CompanyA, Company B, and Company obtain millions of dollars. in contracts from the City of Weslaco; c. For ARTURO C. CUELLAR, JR. to enrich himself by keeping a portion of the bribe funds paid to him by LOPEZ and then pay the remainder of the bribe funds to JOHN F. d. For QUINTANILLA to enrich himself by keeping a portion of the bribe funds paid to him by LOPEZ and then pay the remainder of the bribe funds to e. For LOPEZ to enrich himself by keeping a portion of the bribe funds paid by Company and Company and f. For GARCIA to help ARTURO C. CUELLAR, JR., JOHN F. CUELLAR, and LOPEZ conceal the bribery conspiracy by laundering the bribes through his interest on lawyers trust account (IOLTA). MANNER AND MEANS OF THE CONSPIRACY 26. The manner and means by which the defendants carried out the conspiracy included, but were not limited to, the following: Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 7 of 34 a. LOPEZ accepted at least approximately $4.1 million, paid through I Company and Company C, in order to pay bribes to JOHN F. CUELLAR and TAFOLLA, through ARTURO C. CUELLAR, JR. and QUIN TAN ILLA, respectively. b. ARTURO C. CUELLAR, JR., QUINTANILLA, and LOPEZ corruptly gave, offered, and promised things of value to JOHN F. CUELLAR and TAFOLLA, including hundreds of thousands of dollars in cash, in exchange for speci?c of?cial action favorable to Company A, Company B, and Company C, including votes authorizing multi- million dollar contracts for water treatment facilities in the City of Weslaco. 0. JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., QUINTANILLA, LOPEZ and TAFOLLA, and other co-conspirators met at various locations in the Southern District of Texas and elsewhere, to discuss the of?cial action that JOHN F. CUELLAR and TAFOLLA should take to bene?t Company A, Company B, and Company C, and to discuss the payment of bribes. - d. In order to conceal the scheme, JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., QUINTANILLA, LOPEZ, and TAFOLLA, took steps to arionymously funnel the bribe payments to JOHN F. CUELLAR and TAFOLLA in a manner to avoid detection that the payments came from Company and Company C, including the following: i. LOPEZ received payments from Company Band Company C, as well as payments from Company A that were passed through Company and Company C, for the purpose of paying bribes to JOHN F. CUEIEJLAR and TAFOLLA, disguised as consulting fees due to LOPEZ. Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 8 of 34 ii. From in or about March 26, 2008 to in or about November 24, 2014, LOPEZ wrote a total of approximately $1,398,000 in checks to ARTURO C. CUELLAR, JR. drawn on accounts at Lone Star National Bank. From on or about April 21, 2011 to on or about November 6, 2014 ARTURO C. CUELLAR, JR. directed employees of Company to make a total of approximately $405,000 in payments to JOHN F. CUELLAR from Company . D, disguised as payments for legitimate legal services. iv. From on or about December 2012 to on or about April 2013, . ARTURO C. CUELLAR, JR., JOHN F. CUELLAR, and DANIEL J. GARCIA funneled at least approximately $90,000 in bribe payments, disguised as payments for legitimate legal services, through the IOLTA account for law ?rm. V. From on or about September 2011 to on or about October 2014, LOPEZ wrote a total of approximately $85,950 in checks to QUINETANILLA drawn on accounts at Lone Star National Bank. vi. QUINTANILLA converted the checks from LOPEZE to cash at Lone Star National Bank and shared approximately half of the :Icash with TAFOLLA. e. JOHN F. CUELLAR and TAFOLLA cast votes, at the direction of LOPEZ, ARTURO C. CUELLAR, R., QUINTANILLA, and their co-conspirators, to . award contracts and payments to Company A, Company B, and Company C, or to bene?t. Company A, Company B, and Company in the execution and adniinistratipn of their contracts with the city. Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 9 of 34 f. JOHN F. CUELLAR directed city of?cials to call special meetings of the commission wherein votes could be taken to bene?t Company A, Company B, and Company C, because special meetings were not publicized or recorded in the same way as regular commission meetings, and the short notice provided for special meetings prevented commissioners who would not vote With JOHN F. CUELLAR from attending. g. In or about 2016, LOPEZ, QUINTANILLA, and their co-conspirators provided TAFOLLA with questions to ask of other city of?cials, and which were intended to bene?t Company B, during a dispute between the City of Weslaco and Company over the City of Weslaco?s refusal to pay Company B?s invoices for the WTP. h. JOHN F. CUELLAR, ARTURO C. CUELLAR, R., QUINTANILLA, LOPEZ and TAFOLLA, and their co?conspirators used wire communications in interstate commerce, such as mobile messaging applications, email, and interstate bank transfers, in furtherance of the scheme to defraud. OVERT ACTS . 27. In furtherance of the conspiracy and in order to accomplish its objects, JOHN F. CUELLAR, ARTURO C. CUELLAR, R., QUINTANILLA, LOPEZ and TAFOLLA and their co-conspirators committed the following overt acts, among others, in the SouthemiDistrict' of Texas and elsewhere: 28. In or about 2008, Person A and Person agreed with LOPEZ that they, would pay LOPEZ to ensure that Company A and Company obtained the contracts for certain construction and engineering projects relating to the city?s water treatment facilities. LOPEZ agreed with ARTURO C. CUELLAR, JR. and JOHN F. CUELLAR that JOHN F. CUELLAR would take of?cial action as a Weslaco City Commissioner to bene?t Company A and Company'B, such as by voting to grant them contracts with the city, in exchange for bribe payments 9 Case Document 30 Filed on 04/09/19 in TXSD Page 10 of 34 29. In or about 2011, LOPEZ, with the knowledge of JOHN F. CUELLAR and ARTURO C. CUELLAR, R., obtained the agreement of QUINTANILLA, to obtain the agreement of another commissioner to accept bribes in exchange for the agreement to take of?cial action as a Weslaco City Commissioner to bene?t Company A and Company B, such as by voting to grant them contracts with the city. QUINTANILLA obtained the agreement of TAFOLLA to take of?cial action as a Weslaco City Commissioner to bene?t Company A and Company B, such as by voting to grant them contracts with the city in exchange for bribe payments paid from LOPEZ through QUINTANILLA. I 30. In or about 2012, Person recruited Person to funnel bribe payments to LOPEZ. Person agreed to do so in exchange for the agreement that Company would receive subcontracts on the WTP and contracts with the City of Weslaco. JOHN F. CUELLAR and TAFOLLA agreed, through C. CUELLAR, JR., and QUINTANILLA, to take of?cial action as a Weslaco City Commissioner to bene?t?Company C, such as by voting to - grant it contracts with the city, in exchange for bribe payments. The Water Treatment Facilities The WTP 31. On or'about March 25, 2008, JOHN F. CUELLAR made a motion to grant a professional services [contract to Company A to perform engineering services to rehabilitate the WTP and to construct a new On the same date, JOHN F. CUELLAR voted in favor of that motion. i 32. In or about May 2008, in the absence of Weslaco?s mayor, JOHN F. CUELLAR executed a'professional services agreement with Company A. 10 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page about November 4, 2008, JOHN F. CUELLAR made a motion to place additional projects under Company A?s contract. On the same date, JOHN F. CUELLAR voted in favor of that motion. 34. On or about August 18, 2009, JOHN F. CUELLAR Spoke againstia motion to reprioritize the 2007 bond funds to shift money from the to the WTP, the contracts for both of which had been granted to Company A. The effect of the shifting of funds, as proposed, would have been to reduce the total amount of money due to Company A under the contracts. On - the same date, JOHN F. CUELLAR voted to oppose that motion, instead asserting to the commission that the and WTP be given equal signi?cance, keeping the amount of money due to Company A under the contracts the same. Despite JOHN F. vote, the motion carried. 35. On or about September 1, 2009, JOHN F. CUELLAR took the following actions: a. - made a motion before the commission to suspend Robert?s Rules of Order to allow the commission to reconsider JOHN F. motion that the and WTP be considered with equal importance with regard to apportioning the 2007 bond ?nds, an initiative that had been defeated at the August 18, 2009 meeting; I b. Voted in favor of the motion to suspend'Robert?s Rules of Order to allow the commission to reconsider JOHN F. motion that the and WTP be considered with equal importance with regard to apportioning the 2007 bond funds; c. made a motion before the commission that the and WTP be considered with equal importance with regard to apportioning the 2007 bond funds; and (1. voted in favor of the motion that the and be considered with equal importance with regard to apportioning the 2007 bond funds. 11 Case Document 30 Filed on 04/09/19 in TXSD Page about 2011, JOHN F. CUELLAR advised and pressured city staff to grant no-bid contracts to Company A and Company to design and-construct a new WTP. 37. On or about January 18, 2011, JOHN F. CUELLAR voted to authorize the city manager and the city attorney to negotiate a new professional services agreement with Company A to prepare a preliminary engineering report on the WTP. 38. On or about August 16, 2011, . a. JOHN F. CUELLAR made a motion before the commission to approve the preliminary engineering report on the WTP prepared by Company b. JOHN F. CUELLAR and TAFOLLA voted to approve the preliminary engineering report on the WTP prepared by Company and c. JOHN F. CUELLAR and TAFOLLA voted to declare that the WTP was exceeding capacity and failing to meet public water demand, thereby creating an imminent threat to public health and safety. This declaration allowed the commission to directly grant construction contracts to address violations issued by TCEQ, bypassing ordinary bidding and qualification procedures. 39. On or about September 8, 2011, JOHN F. CUELLAR and TAFOLLA took the following actions: a. voted to authorize the city manager to negotiate a preconstruction services contract with Company A for the and b. voted in favor of a motion for the city manager to negotiate a contract with Company for the design of an expansion to the WTP and associated projects .- 12 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 13 of 34 Due to the declaration from the August 16, 2011 meeting that the WTP represented an imminent threat to public health and safety, the commission was able to grant these contracts Without the ordinary competitive bidding and quali?cation process. 40. On or'about October 6, 2011, TAFOELA voted to approve a professional services agreement with Company for the design of the WTP and a professional services agreement with Company A for the pre?construction services for the WTP. 41. On or about March 27, 2012, JOHN F. CUELLAR and TAFOLLA voted to authorize the mayor to execute a contract, valued at approximately $38.5 million, with Company A for the expansion of the WTP. and to authorize city staff to amend the city; budget- to accommodate the $38.5 million contract with Company A. 42. On or about June 5, 2012, JOHN F. CUELLAR and TAFOLLA voted to approve the City of Weslaco?s entering into a professional services agreement with Company C. 43. In or about 2012', Person A and Person told LOPEZ that they needed the commission to approve an amendment increasing the price of Company B?s Contract with the city. Person A and Person told LOPEZ that the additional funds from this amendment would enable Person to continue paying LOPEZ, so that LOPEZ could, in turn, continue paying others. 44. On or about September 20, 2012, JOHN F. CUELLAR and TAFOLEA voted to approve an amendment to the contract with Company to include automation and daily construction inspection in an amount not to exceed $2,978,950, to authorize a budget amendment as appropriate, and to authorize the mayor to execute any related documentsabout 2013, JOHN F. CUELLAR advised and pressured city staff, including the city manager, to grant contracts to Company B. 1 3 . Case Document 30 Filed on 04/09/19 in TXSD Page about July 16, 2013, JOHN CUELLAR and TAFOLLA voted to amend the city?s contract with Company to authorize Company to prepare a preliminary engineering report for repairs to the 47. On or about September 2, 2014, JOHN F. CUELLAR and TAFOLLA voted to approve the ?nal preliminary engineering report for the prepared by Company B, and authorize a budget amendment to pay Company for the report. 48. JOHN F. CUELLAR and TAFOLLA made the motions, cast the votes, and took the other of?cial actions referenced in paragraphs 28 through 47 in their of?cial capacities as Weslaco City Commissioners during Weslaco City Commission meetings. Other Acts 49. JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., QUINTANILLA, LOPEZ, and TAFOLLA, and their co?conspirators used wire communications in interstate commerce, such as mobile messaging applications, email, and interstate bank transfers, in furtherance of the scheme to defraud. _50. In or about February 2016, LOPEZ sent to QUINTANILLA, via! electronic messages over a cellular telephone, questions that LOPEZ wanted TAFOLLA to ask in upcoming city commission meetings. These questions were crafted to bene?t Company in its attempts to recover payments for the WTP from the City of Weslaco, after the city stopped paying Company B. 51. On or about September 1, 2016, LOPEZ and Person discussed the money still owed to LOPEZ as part of the bribery scheme and discussed how Person would provide the remaining funds to LOPEZ. 14 Case Document 30 Filed on' 04/09/19 in TXSD Page 15 of 34 Bribe Payments Payments to LOPEZ 52. In or about 2008, Company began paying LOPEZ approximately $17,000 per month. 53. In or about February 2011, around the time that JOHN F. CUELLAR voted to approve the professional services agreement with Company A to prepare a preliminary engineering report on the WTP, Company increased the amount paid on a basis to LOPEZ from approximately $17,000 to approximately $25,000 to $40,000 per month. 54. From in or about June 2012 to in or about May 2014, Person paid a total of approximately $300,000, in four payments of approximately $75,000 each, to LOPEZ under the pretense that Person was leasing a hunting property that belonged to LOPEZ. In truth, these purported lease payments were another Way for Person to pay bribe money to LOPEZ. 55. In all, from in or about April 2008 through in orabout December 2015, Person and Company paid over approximately $2.5 million to LOPEZ in regular payments of approximately $1,000 to approximately $75,000. I 56. On or about April 2012, shortly after JOHN F. CUELLAR and TAFOLLA voted to authorize the mayor to execute the $38.5 million contract with Company A, Person made a payment of approximately $85,000 to LOPEZ. From that point forward-Person made payments ranging from approximately $75,000 to approximately $150,000 to LOPEZ at various periods throughout the year, until approximately July 2014. 57. From in or about April 2012 through in or about July 2014, Company paid over approximately $1.6 million to LOPEZ. 15 Case Document 30 Filed on 04/09/19 in TXSD Page 16 of 34 Payments to ARTURO C. CUELLAR. JR. 58. LOPEZ shared the money he received from Company and Company with . ARTURO C. CUELLAR, JR. through payments of approximately $5,000 to; ARTURO c. CUELLAR, JR., beginning at least by on or about March 26, 2008, so that ARTURO c. CUELLAR, JR. could pay bribes to JOHN F. CUELLAR. 59. In or about May 2011, payments to ARTURO C. CUELLAR, JR. increased, ranging from approximately $10,000 to more than $60,000 approximately 60. Through these payments, from in or about March 2008 through; in or about November 2014, LOPEZ paid approximately $1,398,000 to ARTURO C. CUELLAR, JR. Payments to JOHN F. CUELLAR 61. In or about April 2011, ARTURO C. CUELLAR, JR. directed employees of Company to begin making payments of approximately $5,000 to $7,500 to JOHN F. CUELLAR, despite the fact that JOHN F. CUELLAR was not providing services to Company D. Company D?s employees complied. 62. From in or about April 2011 through in or about November 2014, ARTURO C. CUELLAR, JR. paid approximately $405,000 to JOHN F. CUELLAR through Company in payments ranging from approximately $5,000to approximately $7,500, disguised as payments for legal services that were never rendered, so that JOHN F. CUELLAR would take of?cial actions to bene?t Company A, Company B, and Company . 63. The payments from LOPEZ to ARTURO C. CUELLAR, JR. and the payments from Company to JOHN F. CUELLAR stopped in November 2014 upon JOHN F. loss of his reelection bid for the commission. 16 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 17 of 34 Payment of Bribes to JOHN F. CUELLAR through GARCIA 64. In or about December 2012, GARCIA agreed to assist LOPEZ and ARTURO C. CUELLAR, JR. in providing approximately $90,000 in bribe payments to JOHN F. CUELLAR using law practice and IOLTA account. LOPEZ agreed with GARCIA that, in exchange for assistance in providing bribe funds to JOHN F. CUELLAR, LOPEZ and ARTURO C. CUELLAR, JR. would help Person D, a friend of GARCIA, obtain employment. I i 65. On or about December 18, 2012, LOPEZ wrote Check No. 1109 from Lone Star Bank Adct. No. to GARCIA in the amount of $60,000 and provided instructions for GARCIA to pay those funds to JOHN F. CUELLAR. 66. On or about December 19, 2012, GARCIA deposited Check No. 1109 for $60,000 from LOPEZ into Lone Star National Bank Acct. No. one of IOLTA accounts. I A 67. On or about December 19, 2012, GARCIA wrote Check No. 1022 from Lone Star National Bank Acct. No. *93 62, one of IOLTA accounts, in the amountiof $40,000 to JOHN F. CUELLAR. 68. On or about December 19, 2012, GARCIA wrote Check No. 1184 from Bank of America Acct. No. one of IOLTA accounts, in the amount of $20,000 to JOHN F. CUELLAR. - 69. On or about December 19, 2012, JOHN F. CUELLAR deposited Check Nos. 1022 and 1184 from Lone Star National Bank Acct. No. and Banlc of America Acct. No. in the amounts of $40,000 and $20,000, respectively, into Inter National Bank Acct. No. **623. 17 Case Document 30 Filed on 04/09/19 in TXSD Page 18 of 34 70. on or about January 29, 2013, LOPEZ wrote Check No. 1228 from Lone Star Bank Acct. No. to GARCIA in the .amount of $40,000 and provided instructions for GARCIA to pay those funds to JOHN F. CUELLAR. 71. On or about January 30, 2013, GARCIA deposited Check No. 1228 from Lone Star Bank Acct. No. into Lone Star National Bank Acct. No. one of IOLTA accounts. I 72?. On or about March 12, 2013, GARCIA wrote Check No. 1028 from Lone Star National Bank Acct. No. one of IOLTA accounts, in the amount of 1 5 ,000 to JOHN F. CUELLAR. I 73. On or about March 13, 2013, JOHN F. CUELLAR deposited check no. 1028 from Lone Star National Bank Acct. No. in the amount of $15,000, into Inter National Bank Acct. No. **623. 8 i 74. On or about April .12, 2013, GARCIA wrote Check No. 1030 from Lone Star - National Bank Acct. No. 62, one of IOLTA accounts, in the amount of $15,000 to JOHN F. CUELLAR. 75. On or about April 15, 2013, JOHN F. CUELLAR deposited Check No. 1030 from Lone Star National Bank Acct. No. 62, in the amount of $15,000, into Inter National Bank Acct. No. **623. 76. In or about 2013, LOPEZ, ARTURO C. CUELLAR, JR., and GARCIA discussed payments to JOHN F. CUELLAR using IOLTA account. 77. In or about August 2014, ARTURO C. CUELLAR, JR., and JOHN F. CUELLAR helped Person obtain employment? With the City of Weslaco in exchange for assistance in providing bribe funds to JOHN F. CUELLAR. 18 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page19 of 34 Payments to TAFOLLA 78. In or about 201 1, LOPEZ began writing checks to QUINTANILLA approximately once per month, in amounts ranging from approximately $500 to approximately $3,500. QUINTANILLA cashed these checks and provided approximately half of the cash to .TAFOLLA. 79. From on or about September 15, 2011 to in or about October 22, 2014, LOPEZ I wrote approximately 41 checks drawn on Lone Star National Bank Acct. Nos. and to QUINTANILLA, in the amount of approximately $500 to approximately $5,000 each, for a total of $85,950, so that QUINTANILLA could make bribe payments to TAFOLLA. QUIN TAN ILLA converted these checks to cash at a Lone Star National Bank branch. I Allin violation of Title 18, United States Code, Sections 1343, 1346, and 1349. COUNTS TWO to SEVEN 18 U.S.C. 1343, 1346 (Honest Services Wire Fraud) 80. Paragraphs 1-79 are incorporated by reference as though fully set forth herein. From in or about 2008 and continuing through in or about December 2016, in the Southern District of Texas and elsewhere, the defendants, RICARDO QUINTANILLA, also known as ?Richard? JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., also known as and DANIEL J. GARCIA LOPEZ and TAFOLLA, and others known and unknown to the grand jury, devised and intended to devise a scheme and arti?ce to defraud the City of Weslaco, the Weslaco City Commission, and the citizens of Weslaco of their intangible right to the honest services of JOHN F. CUELLAR and TAFOLLA through bribery; to wit, on or about the dates set forth below, in the Southern 19 Case Document 30 Filed on 04/09/19 in TXSD Page 20 of 34 District of Texas and elsewhere, the defendants, for the purpose of executing and attempting to execute the scheme and arti?ce to defraud and deprive, transmitted and caused to be transmitted . by means of Wire communications in interstate and foreign commerce the following writings, signs, signals, pictures and sounds: COUNT DATE NATURE OF WIRE Email from Person to an employee of the City of 2 April 25, 2014 Weslaco regarding amendments to the WTP. . Email from LOPEZ to'Person regarding argument to 3 May 18, 2015 make to, the City as to the bene?ts of the WTP. - Email from LOPEZ to Person regarding arguments to 4 July 6, 2015 make to the City as to the bene?ts of the WTP. - Email from employee of Company B'to an employee of 5 September 2, 2015 the City of Weslaco and Person submitting a status report on the WTP. 5 Email from employee of Company to an employee of the City of Weslaco and Person submitting a 6 October 5? 2015 status report on the WTP. Email from employee of Company to an employee of the City of Weslaco and Person submitting invoices for 7 December 21? 2015 work conducted on the WTP. All in Violation of Title 18 United States Code, Sections 1343, 1346, and 2. COUNT EIGHT 18 U.S.C. 666(a)(2) (Federal Program Bribery) 82. Paragraphs 1?79 of this Indictment are re-alleged as if fully set forth herein. 83. From in or about August 2011, up to and including in or about November'2014, in the Southern District of Texas and elsewhere within the jurisdiction of the court, the defendant, RICARDO QUINTANILLA, also known as ?Richard? 20 Case Document 30 Filed on 04/09/19 in TXSD Page 21 of 34 did corruptly give, offer, or agree to give a thing of value to any person intending to in?uence and reward an agent of the City of Weslaco, a local government that received benefits in excess of $10,000 pursuant to a Federal program involving a grant, contract, subsidy, loan guarantee, and other forms of Federal assistance in 2014, in connection with any business, transaction, or series of transactions of such State government and agency involving something of value of $5,000 or more; namely, QUINTANILLA gave, offered, and agreed to give cash to TAFOLLA, a public of?cial of the City of Weslaco, intending to in?uence and reward TAFOLLA in connection with the contracts for the construction and rehabilitation of the city?s water treatment facilities. All in violation of Title 18, United States Code, Sections 666(a)(2) and 2. COUNT NINE 18 U.S.C. 666(a)(2) (Federal Program Bribery) 84. Paragraphs 1?79 of this Indictment are re?alleged as if fully set forth herein. 85. - From in or about March 2008, up to and including in or about November 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the court, the defendant, ARTURO C. CUELLAR, JR., also known as did corruptly give, offer, or agree to give a thing of value to any person intending to influence and reward an agent of the City of Weslaco, a local government that received bene?ts in excess of $10,000 pursuant to a Federal program involving a grant, contract, subsidy, loan guarantee, and other forms of Federal assistance in 2014, in connection with any business, transaction, or series of transactions of such State government and agency involving something of. value of $5,000 or more: namely, ARTURO C. CUELLAR, JR. gave, offered, and agreed to give cash to JOHN F. CUELLAR, a public official of the City of Weslaco, intending to in?uence and reward JOHN F. 21 Case Document 30 Filed on 04/09/19 in TXSD Page 22 of 34 CUELLAR in connection with the contracts for the construction and rehabilitation bf the city?s water treatment facilities. Allin violation of Title 18, United States Code, Sections 666(a)(2) and 2. COUNT TEN 18 U.S.C. 666(a)(1)(B) (Federal Program Bribery) 86. Paragraphs 1-79 of this Indictment are re?alleged as if fully set forth herein. 87. From in or about March 2008, up to and including in or about November 2014, in the Southern District of Texas and elsewhere within the jurisdiction of the court, the defendant, JOHN F. CUELLAR a sitting commissioner of the City of Weslaco, a local government that received bene?ts in excess of $10,000 pursuant to a Federal program involving a grant, contract, subsidy, loan guarantee, and other forms of Federal assistance in 2014, did corruptly solicit and demand for his own bene?t, and accepted and agreed to accept something of- value, that is, money, intending to be in?uenced and rewarded in connection with any business, transaction, or series of transactions of local government and agency involving something of value of $5,000 or more: namely, JOHN F. CUELLAR, a public of?cial of the City of Weslaco, solicited, demanded, accepted and agreed to accept money from ARTURO C. CUELLAR, R., intending to be in?uenced and rewarded in connection with the contracts for the construction and rehabilitation of the city?s water treatment facilities. All in violation of Title 18, United States Code, Sections 666(a)(l)(B) and 2. COUNT ELEVEN 18 U.S.C. 1956(h) (Conspiracy to Launder Monetary Instruments) 88. Paragraphs 1?79 of this Indictment are re-alleged as if fully set forth herein. 22 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 23 of 34 89. From in or about March 2008 and continuing through in or about December 2016, in the Southern District of Texas and elsewhere, the defendants, RICARDO QUINTANILLA, also known as ?Richard? JOHN F. CUELLAR, ARTURO C. CUELLAR, R., also known as and DANIEL J. GARCIA LOPEZ, and TAFOLLA did knowingly combine, conspire, and agree with each other 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 195 to wit: to knowingly conduct and attempt to conduct a ?nancial transaction which in fact involved the proceeds of speci?ed unlawful activity, that is, bribery of a public of?cial, knowing that the transaction was designed in whole or in part to promote speci?ed unlaw?il activity and conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlawful activity, Allin violation of Title 18, United States Code, Sections 1956(h). COUNTS TWELVE to NINETEEN 18 U.S.C. 1956(a) (Money Laundering) 90. Paragraphs 1?79 of this Indictment are re?alleged as if fully set forth herein. 91. On or about the dates listed below, in the Southern District of Texas and elsewhere, the defendant, RICARDO QUINTANILLA, also known as ?Richard? knowing that the property involved in the ?nancial transactions listed below represented the proceeds of some form of unlawful activity, that is, bribery of a public of?cial, knowingly and willfully conducted and caused to be conducted the ?nancial transactions designed in whole or in 23 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 24 of 34 part to promote speci?ed unlawful activity, that is, bribery of a public of?cial, and conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlawful activity, with each transaction affecting interstate commerce, in that QUIN TAN ILLA withdrew ?nds from the bank account at the ?nancial institutions identi?ed below: Count Date (on or about) Financial Transaction Total Amount of Transaction 12 April 16,2014 Conversion of check #1703, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. . $2,000 13 May 8,2014 Conversion of check #1590, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. $2,000 14 June 16, 2014 Conversion of check #1544, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. 5$2,000 15 July 31, 2014 Conversion of check #1631, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. 2$2,000 16 August 9, 2014 Conversion of check #1636, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. $5,000 17 August 18,2014 Conversion of check #1642, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. ?$2,000 19 September 5, 2014 Conversion of check #1634, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. $5,000 24 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 25 of 34 Conversion of check #1739, drawn on Lone Star National Bank Acct. No. made out to QUINTANILLA, to cash at Lone Star National Bank. 19 October 22, 2014 $2,000 All in violation of Title 18, United States Code, Section 195 6(a) COUNTS TWENTY to 18 U.S.C. 1956(a) (Money Laundering) 92. Paragraphs 1 through 79 of this Indictment are re-alleged as if fully set forth herein. 93. On or about the dates listed below, in the Southern District of Texas and elsewhere, the defendants, JOHN F. CUELLAR and ARTURO C. CUELLAR, JR., also known as knowing that the property involved in the ?nancial transactions listed below represented the proceeds of some form of unlawful activity, knowingly and willfully conducted and caused to be conducted the ?nancial transactions listed below, which were designed in whole or: in part to promote, conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlawful activity, that is, bribery of a public of?cial, and each transaction affecting interstate commerce, in that the defendants withdrew funds from the bank account at the ?nancial institutions identi?ed below: Count Date Financial Transaction Total Amount (on or about) of Transaction Deposit of check #26819, drawn on First Victoria National Bank Acct. No. 20 4/10/2014 into Inter National Bank Acct. No. **623 in the $5,000 name of JOHN F. CUELLAR. Deposit of check #1701, drawn on Lone Star 21 4/15/2014 Bank Acct. No. into Elsa State Bank $45,000 25 Case Document 30 Filed on 04/09/19 in TXSD Page. 26 of 34 Acct. No. in the name of ARTURO C. CUELLAR, JR. 22. 4/24/2014 Deposit of check #26898, drawn on First . Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 23 5/1/2014 Deposit of check #1720, drawn on Lone Star Bank Acct-No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $15,000 24 5/7/2014 Deposit of check #26950, drawn on First Victoria National Bank Acct. No. **7700, into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 I 25 5/20/2014 Deposit of check #27083, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 26 6/4/2014 Deposit of check #27165, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 27 6/10/2014 Deposit of Check #1543, drawn on Lone Star Bank Acct. No. made out to ARTURO C. CUELLAR, JR. $15,000 28 6/18/2014' Deposit of check #27243, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 29 7/1/2014 Deposit of check #1554, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $15,000 30 7/9/2014 Deposit of check #27353, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 26 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 27 of 34 31 7/23/2014 Deposit of check #27427, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 32 7/29/2014 Deposit of check #1567, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $15,000 33 7/29/2014 Deposit of check #1570, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $5,000 34 8/7/2014 Deposit of check #27521, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 35 8/19/2014 Deposit of check #1643, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $12,500 36 8/20/2014 Deposit of check #27608, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 37 9/11/2014 Deposit of check #27728, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in- the name of JOHN F. CUELLAR. $5,000 38 9/23/2014 Deposit of check #27794, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. N0. **623 in the name of JOHN F. CUELLAR. $5,000 39 9/29/2014 Deposit of check #1684, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. $25,000 40 10/6/2014 Deposit of check #1685, drawn on Lone Star Bank Acct. No. into Elsa State Bank $30,000 27 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 28 of 34 Acct. No. 1213, in the name of ARTURO C. CUELLAR, JR. 41 10/8/2014 Deposit of check #27870, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. I . $5,000 42 10/20/2014 Deposit of check #1737, drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. - $25,000 43 10/22/2014 Deposit of check #27957, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 44 10/31/2014 Deposit of check #1782, drawn on Lone Star Bank Acct. No. made out to ARTURO C. CUELLAR, JR. $50,000 45 11/6/2014 Deposit of check #28009, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR. $5,000 46 11/24/2014 Deposit of check #1787, drawn on Lone Star Bank Acct. No. made out to ARTURO C. CUELLAR, JR. $4,000 Allin violation of Title 18,1United States Code, Section 1956(a) and 2. 94. 95. defendant, COUNT 18 U.S.C. 1952 (Travel Act) Paragraphs 1 through 79 of this Indictment are .re?alleged as if fully set forth herein. On or about February 2, 2016, in the Southern District of Texas and elsewhere, the RICARDO QUINTANILLA, also known as ?Richard? 28 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 29 of 34 knowinglyand willfully did use and cause to be used a facility in interstate and foreign commerce, namely a telephone and a wire and electronic communication, with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of an unlawful activity, namely bribery, contrary to Article XVI, 41 of the Texas Constitution and Texas Penal Code 36.02, and therea?er performed and attempted to perform an act to promote, manage, establish and carry on, and to facilitate the promotion, management, establishment and carrying on of the above unlawful activity. All in violation of Title 18, United States Code, Section 1952(a)(3). COUNTS FORTY-EIGHT to 18 U.S.C. 1952 (Travel Act) 96. Paragraphs 1 through 79 of this Indictment are re-alleged as if fully set forth herein. 97. On or about the dates listed below, in the Southern District of Texas and elsewhere, the defendants, JOHN F. CUELLAR and ARTURO C. CUELLAR, JR., also known as knowingly and willfully did use and cause to be used a facility in interstate and foreign; commerce, namely a computer network, with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of an .unlawful activity, namely bribery, contrary to Article XVI, 41 of the Texas Constitution and Texas Penal Code 36.02, and thereafter performed and attempted to perform an act to promote, manage, establish and carry on, and to facilitate the promotion, management, establishment and carrying on of the above unlawful activity. 29 . Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 30 of 34 Count Date (on or about) Use of Interstate Facility 48 4/10/2014 Deposit of check #26819, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 49 4/15/2014 Deposit of check #1701, in the amount of $45,000 drawn on Lone - Star Bank Acct. No. into Lone Star Bank Acct. No. in the name of ARTURO C. CUELLAR, JR., causing the funds to be routed over a computer network, a facility in interstate commerce. I 50 4/24/2014. Deposit of check #26898, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 51 5/1/2014 Deposit of check #1720, in the amount of $15,000 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. 1213, .in the name of ARTURO C. CUELLAR, JR., causing the funds to be routed over a computer network, a facility in interstate commerce. 52 5/7/2014 Deposit of check #26950, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 53 5/20/2014 Deposit of check #27083, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 54 6/4/2014 Deposit of check #27165, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. **7700, into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 55 6/10/2014 Deposit of Check #1543, in the amount of $15,000 drawn on Lone Star Bank Acct. No. made out to ARTURO C. 30' Case Document 30 Filed on 04/09/19 in TXSD Page 31 of 34 CUELLAR, JR. causing the funds to be routed over a computer network, a facility 1n interstate commerce. 56 6/18/2014 Deposit of check #27243, in the amount of $5,000, drawn on First. Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 57 7/1/2014 Deposit of check #1554, 1n the amount of $15,000 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR.,icausing the funds to be routed over a computer network, a facility'in interstate commerce. 58 7/9/2014 Deposit of check #27353, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the ?lnds to be routed over a computer network, a facility in interstate commerce. 59 7/23/2014 Deposit of check #27427, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National. Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 60 7/29/2014 Deposit of check #1567, in the amount of $15,000 drawn: on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR. ,jcausing the funds to be routed over a computer network, a facility in interstate commerce. 61 7/29/2014 Deposit of check #1570, in the amount of $5,000 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR.,Ncausing the funds to be routed over a computer network, a facility in interstate commerce. 62 8/7/2014 Deposit of check #27521 in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National. Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, 'a facility ininterstate commerce. 63 8/19/2014 Deposit of check #1643, in the amount of $12,500 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. 31 Case Document 30 Filed on 04/09/19 in TXSD Page 32 of 34 in the name of ARTURO C. CUELLAR, JR., causing the funds to be routed over a computer network, a facility! in interstate commerce. 64 8/20/2014 Deposit of check #27608, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 65 9/11/2014 Deposit of check #27728, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. *7700, into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 66 9/23/2014 Deposit of check #27794, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 67 9/29/2014 Deposit of check #1684, in the amount of $25,000 drawnon Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name ,of ARTURO C. CUELLAR, R., causing the funds to be routed over a computer network, a facility in interstate commerce. 68 10/6/2014 Deposit of check #1685, in the amount of $30,000 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR, causing the funds to be routed over a computer network, a facility in interstate commerce. 69 10/8/2014 Deposit of check #27870, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 70 10/20/2014 Deposit of check #1737, in the amount of $25,000 drawn on Lone Star Bank Acct. No. into Elsa State Bank Acct. No. in the name of ARTURO C. CUELLAR, JR., causing the funds to be routed over a computer network, a facility in interstate commerce. 32 Case 7:19-cr-00522 Document 30 Filed on 04/09/19 in TXSD Page 33 of 34 Deposit of check #27957, in the amount of $5,000, drawn on First Victoria National Bank Acct. N0. into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 71 10/22/2014 Deposit of check #1782, in the amount of $50,000 drawnron Lone Star Bank Acct. No. made out to ARTURO C. 72 10/31/2014 CUELLAR, R., causing the funds to be routed over a computer network, a facility in interstate commerce. Deposit of check #28009, in the amount of $5,000, drawn on First Victoria National Bank Acct. No. **7700, into Inter National Bank Acct. No. **623 in the name of JOHN F. CUELLAR, causing the funds to be routed over a computer network, a facility in interstate commerce. 73 11/6/2014 Deposit of check #1787, in the amount of $4,000 drawn on Lone Star Bank Acct. No. made out to ARTURO C. 74 11/24/2014 CUELLAR, R., causing the funds to be routed over a computer network, a facility in interstate commerce. All in violation of Title 18, United States Code, Section 1952(a)(3) and 2. NOTICE OF CRIMINAL FORFEITURE 18 U.S.C. 981(a)(1)(C) and 28 use. 2461(c) 1. Pursuant to Title 18, United States Code, Section and Title 28, United- States Code, Section 2461(c), the United States gives notice to the defendants, RICARDO QUINTANILLA, also known as ?Richard,? JOHN F. CUELLAR, ARTURO C. CUELLAR, JR., also known as and DANIEL J. GARCIA that upon conviction of an offense in violation of Title 18, United States Code, Sections 1343, 1349, 666, 1956, and 1952, as charged in Counts 1 through 74 of this Superseding Indictment, all 33 Case Document 30 Filed on 04/09/19 in TXSD Page 34 of 34 property, real or personal, which constitutes or is derived from proceeds traceable to such offense, is subject to forfeiture. Property Subiect to Forfeiture The property subject to forfeiture is approximately $4,100,000. In the event that a condition listed in Title 21, United States Code, Section 853 exists, the United States Will seek to forfeit any other property of the defendant in substitution up to the total value of the property subject to forfeiture. The United States may seek the imposition of a money judgment. A TRUE BILL: FOREPERSON, OF THE GRAND JURY RYAN K. PATRICK ANNALOU TIROL United States Attorney Acting Chief Public Integrity Section Q/f/ Peter M. Nothstein Robertd Lop - Peter M. Nothstein Assistant ates Attorney Jessica C. Harvey Southern Di Texas Trial Attorneys Email: Roberto.L e22@usdoj. gov Public Integrity Section, Criminal DiVision Email: Peter.Nothstein@usdoj . gov Email: essica.Harvey@usdoj . gov 34