.

Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 1 of 43

qLEilc.J SEP 1 i 9 i2:12USDC·0RP

UNITED STATES DISTRICT COURT
DISTRICT OF OREGON
PORTLAND DIVISION

UNITED STATES OF AMERICA

v.
SAMUEL DIAZ, a.k.a. Pariente,
FAUSTINO MONROY, a.k.a. Manuel,
a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino,

INDICTMENT
21 U.S.C. §§ 841(a)(l),
84l(b)(l)(A), 841(b)(l)(B),
841(b)(l)(C), 843(b), 846,
and 856(a)(l)

EDGAR OMAR QUIROZ RODRIGUEZ,
a.k.a. Nano, a.k.a. Marcelino Zambrano
Rodriguez, a.k.a. Midget,

18 U.S.C. §§ 922(g)(l), 922(g)(2),
922(g)(5), 924(c) and 1956(h)

GERSON FERNANDO MARTINEZCRUZ, a.k.a. Shaggy,

Forfeiture Allegations

JESUS GONZALEZ VAZQUEZ,
a.k.a. Chuy,
UNDERSEAL
JUAN ANTONIO ROMO, a.k.a. Tony,
CRISTIAN HANGUIN FERNANDEZ,
a.k.a. Barbas,
MANUEL HERNANDEZ GABRIEL,
a.k.a. Burras,
JOHN DOE, a.k.a. Michocano,
FELIPE DeJESUS SARCO GOMEZ,
YENIRA SANDOVAL,
Indictment

Page 1

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 2 of 43

CONSUELO MORALES RAMIREZ,
YUNUHEN SALAZAR ANDRADE,
LINDSAY ANN MARKS,
OBED VILLA SENOR SANTOS,
MANUEL SANCHEZ CORADO,
a.k.a. Little Man,
CHRISTOPHER GALLEGOS,
a.k.a. Lucky,
EDUARDO MARTINEZ-PEREZ,
MARINA MARTINEZ MALDONADO,
BRYCE MATTHEW HERSE'L,
SEAN ROSS CRAWLEY, a.k.a. Creeper,
TRACY NICHOLS,
JUSTIN KYLE MUNSEY,
GERALD RICHARDS,
TRAVIS MERRELL,
WILLIAM SUITER,
RICK DALHOVER,
MARTIN ANTONIO AGUAYO,
TERESITA ENCISO-ROJAS,
a.k.a. Tere,
ROY SHAW,
JASON BARRETH,
TERINA McCORD,

Indictment

Page2

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 3 of 43

•

TIA ROUSE,
JASON MICHAEL BLYTHE,
a.k.a. JDog,
DONALD LEE BEASLEY,
MATTHEW BENNETT,
a.k.a. Pikos, a.k.a. Burro,
CHAD JACOB CULLEN, a.k.a. Flavel,
GREGORY FISH,
ANGEL BARRERA,
MAYRA ESPINO, and
BRUCE ANTHONY SHIRLEY,
Defendants.
THE GRAND JURY CHARGES:
COUNT 1
(Conspiracy to Distribute and Possess with Intent to Distribute Methamphetamine, Heroin
and Cocaine; to Use Communication Facilities in Furtherance of the Conspiracy; and, to
Maintain Premises to Distribute Controlled Substances)
(21 U.S.C. §§ 841(a)(l), 84l(b)(l)(A), 841(b)(l)(B), 841(b)(l)(C), 843(b), 846, 856(a)(l), and
856(b))
Introduction
1.

As set forth below, the defendants engaged in a vast international drug smuggling

and money laundering conspiracy. As part of the drug smuggling operation, leaders of the drug
trafficking organization caused significant amounts of controlled substances, including hundreds
of kilograms of heroin, and methamphetamine to be transported from Mexico to the greater
Portland, Oregon area for local distribution. These drugs had a total wholesale value of millions
of dollars. As part of the money laundering operation, the drug trafficking organization used

Indictment

Page3

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 4 of 43

money transmitting businesses and their agents to wire substantial amounts of cash generated
from the Portland drug trafficking activity to various nominees in Mexico and in the United
States. The wire transactions were coordinated and structured under the pretense of legal
transactions to conceal the illicit nature of the proceeds and the identity of those involved in the
drug trafficking activity.
The Conspiracy

2.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, within the District of Oregon and
elsewhere, defendants SAMUEL DIAZ, a.k.a. Pariente, FAUSTINO MONROY, a.k.a.
Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR QUIROZ RODRIGUEZ,
a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, JUAN
ANTONIO ROMO, a.k.a. Tony, CRISTIAN HANGUIN FERNANDEZ, a.k.a. Barbas,
MANUEL HERNANDEZ GABRIEL, a.k.a. Burras, JOHN DOE, a.k.a. Michocano,
FELIPE DeJESUS SARCO GOMEZ, YENIRA SANDOVAL, CONSUELO MORALES
RAMIREZ, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN MARKS, OBED VILLA
SENOR SANTOS, MANUEL SANCHEZ CORADO, a.k.a. Little Man, CHRISTOPHER
GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ, MARINA MARTINEZ
MALDONADO, BRYCE MATTHEW HERSEL, SEAN ROSS CRAWLEY, a.k.a.
Creeper, TRACY NICHOLS, JUSTIN KYLE MUNSEY, GERALD RICHARDS, TRAVIS
MERRELL, WILLIAM SUITER, RICK DALHOVER, MARTIN ANTONIO AGUA YO,
TERESITA ENCISO-ROJAS, a.k.a. Tere, ROY SHAW, JASON BARRETH, TERINA
McCORD, TIA ROUSE, JASON MICHAEL BLYTHE, a.k.a. JDog, DONALD LEE

Indictment

Page 4

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 5 of 43

BEASLEY, MATTHEW BENNETT, a.k.a. Pikos a.k.a. Burro, CHAD JACOB CULLEN,
a.k.a. Flavel, GREGORY FISH, ANGEL BARRERA, MAYRA ESPINO, and BRUCE
ANTHONY SHIRLEY, did knowingly and intentionally combine, conspire, confederate, and
agree with each other and with others both known and unknown to the Grand Jury, to carry out
the following objects in furtherance of the conspiracy:

Objects of the Conspiracy
1.

Distribution of Methamphetamine: The conspirators did knowingly and

intentionally combine, conspire, confederate, and agree to distribute 500 grams or more of a
mixture and substance containing a detectible amount of methamphetamine, a Schedule II
controlled substance, in violation of Title 21 , United States Code, Sections 841 (a)(l) and
841 (b)(1 )(A).
2.

Possession with the Intent to Distribute Methamphetamine: The conspirators

did knowingly and intentionally combine, conspire, confederate, and agree to possess with intent
to distribute 500 grams or more of a mixture and substance containing a detectible amount of
methamphetamine, a Schedule II controlled substance, in violation of Title 21, United States
Code, Sections 841(a)(l) and 841(b)(l)(A).
3.

Distribution of Heroin: The conspirators did knowingly and intentionally

combine, conspire, confederate, and agree to distribute one kilogram or more of a mixture and
substance containing a detectible amount of heroin, a Schedule I controlled substance, in
violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
4.

Possession with the Intent to Distribute Heroin: The conspirators did

knowingly and intentionally combine, conspire, confederate, and agree to possess with intent to
distribute one kilogram or more of a mixture and substance containing a detectible amount of

Indictment

Page 5

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 6 of 43

heroin, a Schedule I controlled substance, in violation of Title 21 , United States Code, Sections
841(a)(l) and 841(b)(l)(A).
5.

Distribution of Cocaine: The conspirators did knowingly and intentionally

combine, conspire, confederate, and agree to distribute a mixture and substance containing a
detectible amount of cocaine, a Schedule II controlled substance, in violation of Title 21 , United
States Code, Sections 841(a)(l) and 841(b)(l)(C).
6.

Possession with the Intent to Distribute Cocaine: The conspirators did

knowingly and intentionally combine, conspire, confederate, and agree to possess with intent to
distribute a mixture and substance containing a detectible amount of cocaine, a Schedule II
controlled substance, in violation of Title 21 , United States Code, Sections 841(a)(l) and
841 (b )(1 )(C).
7.

Use of a Communication Facility in Facilitating a Drug Trafficking Offense:

The conspirators did knowingly and intentionally combine, conspire, confederate, and agree to
use communication facilities , to-wit: cellular telephones, in committing, causing, or facilitating
the commission of a felony controlled substance offense under Title 21 , United States Code,
Section 841 (a)(l ), to-wit: the distribution and possession with the intent to distribute a controlled
substance, and in violation of Title 21 , United States Code, Section 843(b ).
8.

Maintaining Drug-Involved Premises: The conspirators did knowingly and

intentionally combine, conspire, confederate, and agree to open, leave, rent, use and maintain
any place, whether permanently or temporarily, for the purpose of manufacturing, distributing
and using any controlled substance, in violation of Title 21 , United States Code, Sections
856(a)(l) and 856(b).

Indictment

Page 6

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 7 of 43

Manner and Means of the Conspiracy
The manner and means used to accomplish the objectives of the conspiracy included,
among others, the following:
1.

It was part of this conspiracy for certain of the defendants and others to transport,

store, distribute, conceal, and possess with the intent to distribute the controlled substances
methamphetamine and heroin for purposes of further distribution.
2.

It was part of this conspiracy for certain of the defendants and others to utilize

cellular telephones to further the possession and distribution of the controlled substances,
including methamphetamine, heroin, and cocaine, and to use coded language to communicate
with each other in the course of the conspiracy.
3.

It was part of this conspiracy for certain of the defendants and others to process,

store, weigh, and package the controlled substances methamphetamine and heroin for
distribution.
4.

It was part of this conspiracy for certain of the defendants and others to maintain

premises for the purposes of storing, packaging, possessing, and distributing the controlled
substances methamphetamine and heroin.
5.

It was part of this conspiracy to use and maintain motor vehicles to transport the

controlled substances methamphetamine and heroin, money, and co-conspirators, to fac ilitate
drug transactions, and to employ counter-surveillance methods while driving or during the
conduct of transactions, in the course of possessing with intent to distribute and distributing the
controlled substances methamphetamine and heroin and transporting drug proceeds.
6.

It was part of this conspiracy to use money remitting services to facilitate drug

transactions and payment for the controlled substances methamphetamine and heroin.
Indictment

Page 7

 Case 3:19-cr-00436-SI

7.

Document 1

Filed 09/25/19

Page 8 of 43

It was part of this conspiracy to provide physical locations for conspirators to

store, process, and organize the distribution of the controlled substances methamphetamine and
heroin.

Overt Acts
In furtherance of this conspiracy, and to effect and accomplish its objectives, the
defendants and other co-conspirators committed one or more of the following overt acts as well
as the acts outlined below in Counts 2 through 60, which are hereby incorporated by reference:

Leaders and Managers
1.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and co1;1tinuing through September 24, 2019, defendants SAMUEL DIAZ, a.k.a.

Pariente and FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a.
Tino, while residing in Mexico and utilizing their associations with criminal organizations based
in Mexico, California, and elsewhere, organized, led, and ran an international drug trafficking
organization in which they obtained and then coordinated the distribution and possession with
the intent to distribute hundreds of kilograms of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, and hundreds of kilograms of
a mixture and substance containing a detectable amount of heroin, a Schedule I controlled
substance, worth millions of dollars, to other drug dealers for further distribution within the
greater Portland, Oregon metropolitan area and elsewhere.
2.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 20 19, defendants EDGAR OMAR QUIROZ

RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget and
GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy managed, supervised, and
Indictment

Page 8

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 9 of 43

coordinated day to day operations of the drug trafficking organization led by defendants
SAMUEL DIAZ, a.k.a. Pariente and FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa,
a.k.a. Vejon, a.k.a. Tino, by receiving and fulfilling orders from customers who were

collectively purchasing as much as 35 kilograms of a mixture and substance containing
methamphetamine and 25 kilograms of a mixture and substance containing heroin per week, for
the purposes of further distribution. After receiving orders from customers, defendants EDGAR
OMAR QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget and GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy would either direct

couriers to deliver the drugs or personally deliver the drugs to the customers themselves.
3.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants EDGAR OMAR QUIROZ
RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget and
GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy would either direct couriers to

collect proceeds from the sale of drugs or collect the drug proceeds themselves.
4.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants EDGAR OMAR QUIROZ
RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a; Midget and
GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy would deliver or direct others to

deliver drug proceeds to defendants JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy and JUAN
ANTONIO ROMO, a.k.a. Tony to facilitate drug transactions and payment for controlled

substances.
5.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendant JESUS GONZALEZ

Indictment

Page 9

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 10 of 43

VAZQUEZ, a.k.a. Chuy would help to broker and arrange the distribution and possession with
the intent to distribute 500 grams or more of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, and one kilogram or more of a
mixture and substance containing a detectable amount of heroin, a Schedule I controlled
substance between various sources of supply and FAUSTINO MONROY, a.k.a. Manuel,
a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a.
Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget.
Sources of Supply
6.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants CRISTIAN HANGUIN
FERNANDEZ, a.k.a. Barbas, JOHN DOE, a.k.a. Michocano, and MANUEL
HERNANDEZ GABRIEL, a.k.a. Burras as well as others known and known, operated within
the District of Oregon and elsewhere, as sources of supply distributing and possessing with the
intent to distribute 500 grams or more of a mixture and substance containing a detectable amount
of methamphetamine and/or one kilogram or more of a mixture and substance containing a
detectable amount heroin, for the purposes of further distribution to members of the drug
trafficking organization run by defendants SAMUEL DIAZ, a.k.a. Pariente and FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino.
Arming Members of the Drug Trafficking Organization
7.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through May 6, 2019, defendants FAUSTINO MONROY, a.k.a.
Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, JESUS GONZALEZ VAZQUEZ, a.k.a.
Chuy, and EDUARDO MARTINEZ-PEREZ obtained and attempted to obtain rifles and

Indictment

Page 10

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 11 of 43

handguns from within the United States for the purpose of sending the firearms to individuals in
Mexico in an effort to strengthen and protect their drug trafficking organization and activities.
Drug Couriers and Money Collectors
Interstate Drug Couriers

8.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants FELIPE DeJESUS
SARCO GOMEZ, YENIRA SANDOVAL, and CONSUELO MORALES RAMIREZ

operated as interstate couriers transporting quantities of methamphetamine and/or heroin from
California to members of the drug trafficking organization, run by defendants SAMUEL DIAZ,
a.k.a. Pariente and FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon,
a.k.a. Tino, in Oregon and elsewhere for purposes of further distribution.
Local Drug Couriers

9.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN
MARKS, OBED VILLA SENOR SANTOS, MANUEL SANCHEZ CORADO, a.k.a. Little
Man, CHRISTOPHER GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ,
MARINA MARTINEZ MALDONADO, and BRYCE MATTHEW HERSEL, operated as ·

drug couriers for the drug trafficking organization run by defendants SAMUEL DIAZ, a.k.a.
Pariente and FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a.
Tino , by distributing and possessing with the intent to distribute as much as 35 kilograms of a

mixture and substance containing methamphetamine and 25 kilograms of a mixture and

Indictment

Page 11

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 12 of 43

substance containing heroin per week to various co-conspirators within the greater Portland
metropolitan area, for the purposes of further distribution.
10.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN
MARKS, OBED VILLA SENOR SANTOS, MANUEL SANCHEZ CORADO, a.k.a. Little
Man, CHRISTOPHER GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ,
MARINA MARTINEZ MALDONADO, and BRYCE MATTHEW HERSEL operated as

money collectors, collecting payment for drugs that had been purchased from the drug trafficking
organization.
Residences Used to Store Methamphetamine and Heroin for
Purposes of Further Distribution

11.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN
MARKS, OBED VILLA SENOR SANTOS, MANUEL SANCHEZ CORADO, a.k.a. Little
Man, CHRISTOPHER GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ,
MARINA MARTINEZ MALDONADO, BRYCE MATTHEW HERSEL, SEAN ROSS
CRAWLEY, a.k.a. Creeper, TRACY NICHOLS, JUSTIN KYLE MUNSEY, GERALD
RICHARDS, TRAVIS MERRELL, WILLIAM SUITER, RICK DALHOVER, MARTIN
ANTONIO AGUAYO, TERESITA ENCISO-ROJAS, a.k.a. Tere, ROY SHAW, JASON
BARRE TH, TERINA McCORD, TIA ROUSE, JASON MICHAEL BLYTHE, a.k.a. JDog,
DONALD LEE BEASLEY, MATTHEW BENNETT, a.k.a. Pikos, a.k.a. Burro, CHAD

Indictment

Page 12

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 13 of 43

JACOB CULLEN, a.k.a. Flavel, and ANGEL BARRERA maintained residences and

premises ("stash houses") for the purpose of storing and distributing methamphetamine and/or
heroin within the greater Portland, Oregon metropolitan area.
Local Drug Dealers

12.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants SEAN ROSS CRAWLEY,
a.k.a. Creeper, TRACY NICHOLS, JUSTIN KYLE MUNSEY, GERALD RICHARDS,
TRAVIS MERRELL, WILLIAM SUITER, RICK DALHOVER, MARTIN ANTONIO
AGUAYO, TERESITA ENCISO-ROJAS, a.k.a. Tere, ROY SHAW, JASON BARRETH,
TERINA McCORD, TIA ROUSE, JASON MICHAEL BLYTHE, a.k.a. JDog, DONALD
LEE BEASLEY, MATTHEW BENNETT, a.k.a. Pikos, a.k.a. Burro, CHAD JACOB
CULLEN, a.k.a. Flavel, GREGORY FISH, ANGEL BARRERA, MAYRA ESPINO, and
BRUCE ANTHONY SHIRLEY possessed 500 grams or more of a mixture and substance

containing a detectable amount of methamphetamine and/or one kilogram or more of a mixture
and substance containing a detectable amount heroin, obtained from their drug courier codefendants, for purposes of further distribution within the District of Oregon and elsewhere.
13 .

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, defendants SEAN ROSS CRAWLEY,
a.k.a. Creeper, TRACY NICHOLS, JUSTIN KYLE MUNSEY, GERALD RICHARDS,
TRAVIS MERRELL, WILLIAM SUITER, RICK DALHOVER, MARTIN ANTONIO
AGUAYO, TERESITA ENCISO-ROJAS, a.k.a. Tere, ROY SHAW, JASON BARRETH,
TERINA McCORD, TIA ROUSE, JASON MICHAEL BLYTHE, a.k.a. JDog, DONALD
LEE BEASLEY, MATTHEW BENNETT, a.k.a. Pikos, a.k.a. Burro, CHAD JACOB

Indictment

Page 13

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 14 of 43

CULLEN, a.k.a. Flavel, GREGORY FISH, and ANGEL BARRERA distributed 500 grams

or more of a mixture and substance containing a detectable amount of methamphetamine and/or
one kilogram or more of a mixture and substance containing a detectable amount heroin within
the District of Oregon and elsewhere.
Tran sfer of Drug Sale Proceeds

14.

Beginning on or about November 2018, the exact date being unknown to the

grand jury, and continuing through September 24, 2019, JESUS GONZALEZ VAZQUEZ,
a.k.a. Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony, operated a wire remitter business in

Portland, Oregon, which they used to wire transfer proceeds of methamphetamine and/or heroin
sales to other co-conspirators in Mexico and elsewhere in the United States.
General Acts by Conspirators

15 .

Defendants used cellular telephones to facilitate the distribution of

methamphetamine, heroin, and cocaine in Oregon and elsewhere.
16.

Defendants would periodically switch ("drop") cellular telephones in an effort to

thwart the investigative efforts of law enforcement. In violation of Title 21, United States Code,
Sections 841(a)(l), 841(b)(l)(A), 841(b)(l)(B), 841(b)(l)(C), 843(b), 846, 856(a)(l) and 856(b).
COUNT2
(Conspiracy to Commit Money Laundering)
(18 U.S.C. §1956(h))

All allegations in Count One are incorporated herein.
Background

1.

Tienda Mexicana Gonzalez, Inc. (also known as "Gonzalez Bros.") is a market

located at 12441 S.E. Powell Boulevard, Portland, Oregon. As part of its business, Gonzalez
Bros. offers services where customers, for a fee, can transmit money from the United States to
Indictment

Page 14

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 15 of 43

other locations, including Mexico. In order to transmit customer funds internationally, Gonzalez
Bros. entered into agency agreements with various money transmitting businesses. These money
transmitting businesses specialize in electronically wiring money and have agent locations
throughout the United States and other countries, including Mexico. Gonzalez Bros. is
authorized by wire transmitting companies to serve as an agent in Oregon to receive and transmit
money to and from Mexico, and to other locations in the United States. Money transmitting
businesses and its agents are required to maintain records accurately recording details of wire
transactions, including customer information and amounts electronically wired. Banks accepting
the cash deposits of money transmitting businesses and its agents are required to submit cash
transaction reports and notify officials if customers are engaged in illegal or suspicious activity.
This information is available to U.S. law enforcement and regulatory agencies to help combat
illegal money laundering.
2.

A legitimate wire transaction from the United States to Mexico and elsewhere in

the United States typically involves a customer bringing in U.S. cash with a request to
electronically transmit the funds to a recipient, oftentimes a relative in Mexico. The U.S.
customer provides identity and transaction information, as required, including contact
information of the sender in the United States and the recipient in Mexico or elsewhere. The
wire transmitting business accepts the customer's cash, and uses the money transmitting business
arrangement to generate a wire transaction electronically transferring the funds to the intended
recipient in Mexico or elsewhere. The recipient then visits a money transmitting business agent
in Mexico or elsewhere in the United States, presents proof of identity, and is given the funds ,
often in Mexican pesos.

Indictment

Page 15

 Case 3:19-cr-00436-SI

3.

Document 1

Filed 09/25/19

Page 16 of 43

As part of the money laundering conspiracy, defendants manipulated this

otherwise lawful process by using the wire transmitting business services at Gonzalez Bros. to
take cash generated from the drug trafficking organization and structure low denomination wire
transactions to the drug trafficking organization in Mexico, and to other locations in the United
States, under the pretense of legal wire transfers.
Objects of the Conspiracy
Beginning on or about November 2018, the exact date being unknown to the grand jury,
and continuing through September 24, 2019, within the District of Oregon and elsewhere,
defendants SAMUEL DIAZ, a.k.a. Pariente, FAUSTINO MONROY, a.k.a. Manuel, a.k.a.
Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a. Nano,
a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, JUAN
ANTONIO ROMO, a.k.a. Tony, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN
MARKS, MANUEL SANCHEZ CORADO, a.k.a. Little Man, CHRISTOPHER
GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ, and BRYCE MATTHEW
HERSEL, and other persons whose identities are known and unknown to the grand jury, did
knowingly combine, conspire, confederate, and agree to commit offenses against the United
States in violation of Title 18, United States Code, Section 1956(h), that is:
(a)

to knowingly conduct and attempt to conduct financial transactions affecting

interstate and foreign commerce and involving the proceeds of the unlawful distribution of a
controlled substance, a specified unlawful activity, knowing that the property involved in the
financial transactions represented the proceeds of some form of unlawful activity, and knowing
that the transactions were designed in whole or in part to conceal and disguise the nature,

Indictment

Page 16

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 17 of 43

location, source, ownership, and control of the proceeds of specified unlawful activity, in
violation of Title 18, United States Code, Section 1956(a)(l)(B)(i); and
(b)

to knowingly conduct and attempt to conduct financial transactions affecting

interstate and foreign commerce and involving the proceeds of the unlawful distribution of a
controlled substance, a specified unlawful activity, with the intent to promote the carrying on of
specified unlawful activity, and knowing that the property involved in the transactions
represented the proceeds of some form of unlawful activity, in violation of Title 18, United
States Code, Section 1956(a)(l)(A)(i).
Manner and Means of the Conspiracy

The manner and means used to accomplish the objectives of the conspiracy included,
among others, the following:
1.

Defendants SAMUEL DIAZ, a.k.a. Pariente, FAUSTINO MONROY, a.k.a.

Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and EDGAR OMAR QUIROZ
RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget directed

other defendants to collect cash generated from illegal drug sales and to deliver it to Gonzalez
Bros. This occurred on a regular basis during the conspiracy. The amount of weekly cash
deliveries to Gonzalez Bros ranged between $25,000-$100,000.
2.

Defendants JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy and JUAN

ANTONIO ROMO, a.k.a. Tony worked at and helped operate the wire transmitting service

operations at Gonzalez Bros. They were notified by other members of the conspiracy, including
EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano
Rodriguez, a.k.a. Midget when other conspirators would be delivering cash from illegal drug

sales to them at Gonzalez Bros.
Indictment

Page 17

 Case 3:19-cr-00436-SI

3.

Document 1

Filed 09/25/19

Page 18 of 43

Relying on instructions provided by other conspirators, defendants GERSON

FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy, YUNUHEN SALAZAR ANDRADE,
LINDSAY ANN MARKS, MANUEL SANCHEZ CORADO, a.k.a. Little Man,
CHRISTOPHER GALLEGOS, a.k.a. Lucky, EDUARDO MARTINEZ-PEREZ, and
BRYCE MATTHEW HERSEL took cash they knew to be proceeds of unlawful activity to

Gonzalez Bros., and gave the proceeds to defendants JESUS GONZALEZ VAZQUEZ, a.k.a.
Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony.

4.

Defendants JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, and JUAN

ANTONIO ROMO, a.k.a. Tony counted the cash given to them by the cash couriers, notified

other co-conspirators in Mexico that they had received the cash, and advised they were ready to
begin the wire transfer process to transmit the proceeds to Mexico, and elsewhere in the United
States.
5.

To avoid detection by law enforcement and regulatory officials, defendants in

Mexico and elsewhere, including FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a.
Vejon, a.k.a. Tino provided a list of names to defendants JESUS GONZALEZ VAZQUEZ,
a.k.a. Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony to use in low denomination wire

transfers to Mexico and elsewhere in the United States. Defendants JESUS GONZALEZ
VAZQUEZ, a.k.a. Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony then used those names

to prepare and send wire transfers from Oregon to Mexico and elsewhere in the United States,
structured in low denomination amounts, and designed to prevent law enforcement or regulatory
anti-money laundering scrutiny.
6.

Knowing that the funds involved proceeds of unlawful activity, defendants

JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony

Indictment

Page 18

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 19 of 43

provided false and misleading information on wire transmitting paperwork about the customers
supposedly involved in the wire transactions from Oregon to Mexico and elsewhere in the United
States.
7.

After sending the wire transfers, defendants JESUS GONZALEZ VAZQUEZ,

a.k.a. Chuy, and JUAN ANTONIO ROMO, a.k.a. Tony notified drug trafficking organization

co-conspirators, including defendant FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa,
a.k.a. Vejon, a.k.a. Tino that the unlawfully derived proceeds had been successfully transmitted

to Mexico or elsewhere, and provided them with specifics of the wire transfers, allowing drug
trafficking organization members in Mexico and elsewhere to redeem the laundered funds.
8.

During the course of this conspiracy, defendants wire transferred substantial

amounts of the proceeds of unlawful activity to Mexico and elsewhere in the United States. This
was done to facilitate the drug trafficking activity set forth in Count One and to conceal and
disguise the nature, location, source, ownership and control of the proceeds of the drug
trafficking activity.
In violation of Title 18, United States Code, Section 1956(h).
COUNT3
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))

On or about February 6, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDUARDO
MARTINEZ-PEREZ, and MARINA MARTINEZ MALDONADO did knowingly and

intentionally distribute 50 grams or more of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
Indictment

Page 19

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 20 of 43

COUNT4
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about February 8, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and EDUARDO
MARTINEZ-PEREZ did knowingly and intentionally distribute heroin, a Schedule I controlled
substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNTS
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))
On or about February 15, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and BRYCE
MATTHEW HERSEL did knowingly and intentionally distribute 50 grams or more of a
mixture and substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance;
In violation of Title 2 1, United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT6
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about February 15 , 2019, within the District of Oregon, subsequent to the Count
alleged above, defendants FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a.

Vejon, a.k.a. Tino, and BRYCE MATTHEW HERSEL did knowingly and intentionally
distribute 50 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841 (a)(l) and 841 (b )(1 )(B).

Indictment

Page 20

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 21 of 43

COUNT7
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about February 22, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and BRYCE
MATTHEW HERSEL did knowingly and intentionally distribute heroin, a Schedule I
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNTS
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about February 27, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and BRYCE
MATTHEW HERSEL did knowingly and intentionally distribute 50 grams or more of a
mixture and substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT9
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about March 5, 2019, within the District of Oregon, defendant FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, did knowingly and
intentionally distribute heroin, a Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

Indictment

Page 21

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 22 of 43

COUNT 10
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))
On or about March 8, 2019, within the District of Oregon, defendant FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, did knowingly and
intentionally distribute 50 grams or more of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT 11
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about March 26, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and YUNUHEN
SALAZAR ANDRADE did knowingly and intentionally distribute 50 grams or more of a
mixture and substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT 12
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about March 26, 2019, within the District of Oregon, subsequent to the Count
alleged above, defendants FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Comp3, a.k.a.
Vejon, a.k.a. Tino, and YUNUHEN SALAZAR ANDRADE did knowingly and intentionally
distribute heroin, a Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841 (a)(l) and 841 (b )(1 )(C).

Indictment

Page 22,

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 23 of 43

COUNT 13
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about April 4, 2019, within the District of Oregon, defendants FA US TINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and LINDSAY ANN MARKS did knowingly and intentionally distribute 50 grams or
more of a mixture and substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT 14
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about April 24, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a. Nano,
a.k.a. Marcelino Zambrano Rodriguez, a.k.a. Midget, and TERESITA ENCISO-ROJAS,
a.k.a. Tere did knowingly and intentionally distribute 500 grams or more of a mixture and
substance containing a detectable amount of methamphetamine, a Schedule II controlled
substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).
Ill
Ill
Ill

Indictment

Page 23

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 24 of 43

COUNT 15
(Unlawful Possession of a Firearm)
(18 U.S.C. §§ 922(g)(2), 922(g)(5), and 924(a)(2))
On or about May 6, 2019, in the District of Oregon, defendant EDUARDO MARTINEZ

PEREZ, unlawfully and knowingly possessed one or more of the following firearms, to-wit:
A.

Taurus Model PT92AFS bearing serial # TAX94375;

B.

Ruger 9mm handgun bearing serial #305-28019;

C.

American Tactical Imports Omni-Hybrid .223 assault rifle bearing serial
#AN008072 ; and,

D.

Ruger 357 Revolver handgun bearing serial #176-51026,

which had previously been shipped or transported in interstate or foreign commerce, knowingly
being a prohibited person, to-wit: an alien who was illegally and unlawfully present in the United
States and who was a fugitive from justice;
In violation of Title 18, United States Code, Sections 922(g)(2), 922(g)(5), and 924(a)(2).

COUNT 16
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(C))
On or about August 1, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and YUNUHEN SALAZAR ANDRADE did knowingly and intentionally distribute
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841 (a)(l) and 841 (b )(1 )(C).

Ill
Ill
Indictment

Page 24

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 25 of 43

COUNT 17
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about August 1, 2019, within the District of Oregon, defendant CHAD JACOB
CULLEN, a.k.a. Flavel did knowingly and intentionally possess with the intent to distribute
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).
COUNT 18
(Possession of a Firearm in Furtherance of a Drug Trafficking Crime)
(18 U.S.C. § 924(c))
On or about August 1, 2019, within the District of Oregon, defendant CHAD JACOB
CULLEN, a.k.a. Flavel and in furtherance of a drug trafficking crime for which he may be
prosecuted in a court of the United States, that is, possession with the intent to distribute
methamphetamine, in violation of Title 21, United States Code, Sections 841(a)(l), as set forth in
Count 17, did knowingly possess a firearm, to-wit: a Hi-Point .380 caliber pistol;
In violation of Title 18, United States Code, Section 924( c).
COUNT 19
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about August 1, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, JOHN DOE a.k.a. Michocano, GERSON FERNANDO MARTINEZ-CRUZ, a.k.a.
Shaggy, and YUNUHEN SALAZAR ANDRADE did knowingly and intentionally distribute 50

Indictment

Page 25

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 26 of 43

grams or more of a mixture and substance containing a detectable amount of methamphetamine,
a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT20
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))
On or about August 1, 2019, within the District of Oregon, defendant MATTHEW
BENNETT, a.k.a. Pikos, a.k.a. Burro did knowingly and intentionally possess with the intent
to distribute 50 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT21
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about August 2, 20 19, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and MANUEL SANCHEZ CORADO, a.k.a. Little Man did knowingly and
intentionally distribute 50 grams or more of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).

Ill
Ill
Ill

Indictment

Page 26

 .

Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 27 of 43

,.

COUNT22
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about August 2, 2019, within the District of Oregon, defendant TIA ROUSE did
knowingly and intentionally possess with the intent to distribute 50 grams or more of a mixture
and substance containing a detectable amount of methamphetamine, a Schedule II controlled
substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 84l(b)(l)(B).
COUNT23
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about August 3, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, JOHN DOE a.k.a. Michocano, GERSON FERNANDO MARTINEZ-CRUZ, a.k.a.
Shaggy, and YUNUHEN SALAZAR ANDRADE did knowingly and intentionally distribute
500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 84l(b)(l)(A).
COUNT24
(Possession with the Intent to Distribute Methamphetamine)
(21U.S.C. §§ 84l(a)(l) and 84l(b)(l)(A))
On or about August 3, 2019, within the District of Oregon, defendant MATTHEW
BENNETT, a.k.a. Pikos, a.k.a. Burro did knowingly and intentionally possess with the intent

Indictment

Page 27

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 28 of 43

to distribute 500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).

COUNT25
(Attempted Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l), 84l(b)(l)(A), and 846)
On or about August 4, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and YUNUHEN SALAZAR ANDRADE did knowingly and intentionally attempt to
possess with the intent to distribute one kilogram or more of a mixture and substance containing
a detectable amount of heroin, a Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l), 841(b)(l)(A), and 846.

COUNT26
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about August 4, 2019, within the District of Oregon, defendant OBED VILLA

SENOR SANTOS did knowingly and intentionally possess with the intent to distribute one
kilogram or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).

COUNT27
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))
On or about August 7, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
Indictment
Page 28

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 29 of 43

QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and
intentionally distribute 50 grams or more of a mixture and substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 84l(a)(l) and 84l(b)(l)(B).
COUNT28
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about August 7, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, and GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy, did knowingly and
intentionally distribute heroin, a Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 84l(a)(l) and 841(b)(l)(C).
COUNT29
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(A))
On or about August 8, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR
QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy, and LINDSAY ANN
MARKS did knowingly and intentionally distribute 500 grams or more of a mixture and
substance containing a detectable amount of methamphetamine, a Schedule II controlled
substance;
In violation of Title 21 , United States Code, Sections 841 (a)(l) and 841 (b )(1 )(A).
Indictment

Page 29

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 30 of 43

COUNT 30
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about August 8, 2019, within the District of Oregon, defendants ROY SHAW and

TERINA McCORD did knowingly and intentionally possess with the intent to distribute 500
grams or more of a mixture and substance containing a detectable amount of methamphetamine,
a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).

COUNT31
(Attempted Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l), 841(b)(l)(A), and 846)
On or about August 8, 2019, within the District of Oregon, defendants SAMUEL DIAZ,

FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, EDGAR
OMAR QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano Rodriguez, a.k.a.
Midget, CHRISTOPHER GALLEGOS, a.k.a. Lucky, and LINDSAY ANN MARKS did
knowingly and intentionally attempt to possess with the intent to distribute one kilogram or more
of a mixture and substance containing a detectable amount of heroin, a Schedule I controlled
substance;

In violation of Title 21 , United States Code, Sections 841(a)(l), 841(b)(l)(A), and 846.
COUNT32
(Possession with the Intent to Distribute Heroin)
(2~ U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about August 8, 2019, within the District of Oregon, defendant YUNUHEN

SALAZAR ANDRADE did knowingly and intentionally possess with the intent to distribute

Indictment

Page 30

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 31 of 43

one kilogram or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT33
(Possession of a Firearm in Furtherance of a Drug Trafficking Crime)
(18 U.S.C. § 924(c))

On or about August 8, 2019, within the District of Oregon, defendant YUNUHEN
SALAZAR ANDRADE, in furtherance of a drug trafficking crime for which she may be

prosecuted in a court of the United States, that is, possession with the intent to distribute heroin,
in violation of Title 21 , United States Code, Section 841(a)(l), as set forth in Count 32, did
knowingly possess a firearm, to-wit: Derringer .22 caliber double-shot pistol, serial number
463312;
In violation of Title 18, United States Code, Section 924(c).
COUNT34
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))

On or about August 16, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, and LINDSAY ANN
MARKS did knowingly and intentionally distribute metharnphetarnine, a Schedule II controlled

substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).
COUNT35
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))

On or about August 29, 2019, within the District of Oregon, defendant CHRISTOPHER,
GALLEGOS, a.k.a. Lucky did knowingly and intentionally possess with the intent to distribute
Indictment
Page 31

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 32 of 43

one kilogram or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT36
(Possession of a Firearm in Furtherance of a Drug Trafficking Crime)
(18 U.S.C. § 924(c))
On or about August 29, 2019, within the District of Oregon, defendant CHRISTOPHER
GALLEGOS, a.k.a. Lucky, in furtherance of a drug trafficking crime for which he may be
prosecuted in a court of the United States, that is, possession with the intent to distribute heroin,
in violation of Title 21, United States Code, Section 841(a)(l), as set forth in Count 35, did
knowingly possess a firearm, to-wit: a Taurus .357 revolver, serial number MA44065;
In violation of Title 18, United States Code, Section 924(c).
COUNT37
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(C))
On or about September 10, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and GERSON
FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and intentionally distribute
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).
COUNT38
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))
On or about September 11, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and GERSON
FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and intentionally distribute
Indictment
Page 32

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 33 of 43

100 grams or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT39
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about September 11 , 2019, within the District of Oregon, defendant GREGORY
FISH did knowingly and intentionally possess with the intent to distribute 100 grams or more of
a mixture and substance containing a detectable amount of heroin, a Schedule I controlled
substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT40
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about September 12, 20 19, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, and MANUEL SANCHEZ CORADO, a.k.a. Little Man
did knowingly and intentionally distribute 500 grams or more of a mixture and substance
containing a detectable amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT 41
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about September 12, 2019, within the District of Oregon, defendants ROY SHAW
and TERINA McCORD did knowingly and intentionally possess with the intent to distribute

Indictment

Page 33

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 34 of 43

500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).

COUNT42
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about September 12, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, and MANUEL SANCHEZ CORADO, a.k.a. Little Man
did knowingly and intentionally distribute 100 grams or more of a mixture and substance
containing a detectable amount of heroin, a Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT43
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about September 12, 2019, within the District of Oregon, defendant ROY SHAW
and TERINA McCORD did knowingly and intentionally possess with the intent to distribute
100 grams or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT44
(Attempted Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l), 84l(b)(l)(A), and 846)
On or about September 12, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, and MANUEL SANCHEZ CORADO, a.k.a. Little Man
Indictment
Page 34

 Case 3:19-cr-00436-SI
>

Document 1

Filed 09/25/19

Page 35 of 43

•

did knowingly and intentionally attempt to possess with the intent to distribute one kilogram or
more of a mixture and substance containing a detectable amount of heroin, a Schedule I
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l), 841(b)(l)(A), and 846.
COUNT45
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))

On or about September 12, 2019, within the District of Oregon, defendants CONSUELO
MORALES RAMIREZ and MANUEL HERNANDEZ GA~RIEL did knowingly and

intentionally possess with the intent to distribute one kilogram or more of a mixture and
substance containing a detectable amount of heroin, a Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT46
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))

On or about September 16, 2019, within the District of Oregon, defendant DONALD
LEE BEASLEY did knowingly and intentionally possess with the intent to distribute 500 grams

or more of a mixture and substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
Ill
Ill
Ill

Indictment

Page 35

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 36 of 43

COUNT47
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about September 16, 20 19, within the District of Oregon, defendant DONALD

LEE BEASLEY did knowingly and intentionally possess with the intent to distribute heroin, a
Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT48
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about September 16, 2019, within the District of Oregon, defendant JASON

MICHAEL BLYTHE, a.k.a. JDog did knowingly and intentionally possess with the intent to
distribute 50 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT49
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C))
On or about September 16, 20 19, within the District of Oregon, defendant JASON

MICHAEL BLYTHE, a.k.a. JDog did knowingly and intentionally possess with the intent to
distribute heroin, a Schedule I controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT SO
(Felon in Possession of a Firearm)
(18 U.S.C. §§ 922(g)(l) and 924(a)(2))
On or about September 16, 20 19, in the District of Oregon, defendant MICHAEL

BLYTHE, a.k.a. JDog, knowing that he had been previously convicted of a crime punishable by
Indictment
Page 36

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 37 of 43

imprisonment for a term exceeding one year, specifically: Unlawful Delivery of Heroin, on or
about September 14, 2018, in Washington County Circuit Court, State of Oregon, Case Number
C142416CR, did knowingly and unlawfully possess the following firearm: a Smith & Wesson
M&P-15 .556 caliber semiautomatic assault rifle, serial number SY37091, which had previously
been shipped or transported in interstate or foreign commerce;
In violation of Title 18, United States Code, Sections 922(g)(l) and 924(a)(2).
COUNTSl
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about September 18, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and GERSON
FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and intentionally distribute
500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT 52
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))
On or about September 18, 2019, within the District of Oregon, defendant MAYRA
ESPINO did knowingly and intentionally possess with the intent to distribute 50 grams or more
of a mixture and substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).

Indictment

Page 37

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 38 of 43

COUNT 53
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))

On or about September 18, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy, and MANUEL SANCHEZ CORADO, a.k.a. Little Man

. did knowingly and intentionally distribute 100 grams or more of a mixture and substance
containing a detectable amount of heroin, a Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT 54
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(B))

On or about September 18, 2019, within the District of Oregon, defendant BRUCE
ANTHONY SHIRLEY did knowingly and intentionally possess with the intent to distribute 100

grams or more of a mixture and substance containing a detectable amount of heroin, a Schedule I
controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT55
(Distribution of Heroin)
(21 U.S.C. §§ 841(a)(l) and ~41(b)(l)(B))

On or about September 18, 2019, within the District of Oregon, defendants FAUSTINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and GERSON
FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and intentionally distribute

100 grams or more of a mixture and substance containing a detectable amount of heroin, a
Schedule I controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
Page 38
Indictment

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 39 of 43

COUNT 56
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))

On or about September 18, 2019, within the District of Oregon, defendants FA US TINO
MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino and GERSON
FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy did knowingly and intentionally distribute

500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).
COUNT 57
(Possession with the Intent to Distribute Heroin)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(B))

On or about September 18, 2019, within the District of Oregon, defendant ROY SHAW
did knowingly and intentionally possess with the intent to distribute 100 grams or more of a
mixture and substance containing a detectable amount of heroin, a Schedule I controlled
substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(B).
COUNT 58
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(A))

On or about September 18, 2019, within the District of Oregon, defendant ROY SHAW
did knowingly and intentionally possess with the intent to distribute 500 grams or more of a
mixture and substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance;
In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(A).

Indictment

Page 39

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 40 of 43

•

COUNT59
(Distribution of Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about September 18, 2019, within the District of Oregon, defendants FAUSTINO

MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino, GERSON FERNANDO
MARTINEZ-CRUZ, a.k.a. Shaggy and MANUEL SANCHEZ CORADO, a.k.a. Little Man
did knowingly and intentionally distribute 500 grams or more of a mixture and substance
containing a detectable amount of methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).

COUNT60
(Possession with the Intent to Distribute Methamphetamine)
(21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A))
On or about September 19, 2019, within the District of Oregon, defendant SEAN ROSS

CRAWLEY, a.k.a. Creeper did knowingly and intentionally possess with the intent to
distribute 500 grams or more of a mixture and substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance;
In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A).

Criminal Forfeiture Allegation:
(Narcotics Offense)
Upon conviction of a controlled substance offense listed above in Count 1, and Counts 3
through 14, 16-17, 19-32, 34-35, 37-49, and 51-60, defendants SAMUEL DIAZ, a.k.a.

Pariente, FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa, a.k.a. Vejon, a.k.a. Tino,
EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a. Marcelino Zambrano
Rodriguez, a.k.a. Midget, GERSON FERNANDO MARTINEZ-CRUZ, a.k.a. Shaggy,
JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, JUAN ANTONIO ROMO, a.k.a. Tony,
Indictment

Page 40

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 41 of 43

CRISTIAN HANGUIN FERNANDEZ, a.k.a. Barbas, MANUEL HERNANDEZ
GABRIEL, a.k.a. Burras, JOHN DOE, a.k.a. Michocano, FELIPE DeJESUS SARCO
GOMEZ, YENIRA SANDOVAL, CONSUELO MORALES RAMIREZ, YUNUHEN
SALAZAR ANDRADE, LINDSAY ANN MARKS, OBED VILLA SENOR SANTOS,
MANUEL SANCHEZ CORADO, a.k.a. Little Man, CHRISTOPHER GALLEGOS, a.k.a.
Lucky, EDUARDO MARTINEZ-PEREZ, MARINA MARTINEZ MALDONADO,
BRYCE MATTHEW HERSEL, SEAN ROSS CRAWLEY, a.k.a. Creeper, TRACY
NICHOLS, JUSTIN KYLE MUNSEY, GERALD RICHARDS, TRAVIS MERRELL,
WILLIAM SUITER, RICK DALHOVER, MARTIN ANTONIO AGUAYO, TERESITA
ENCISO-ROJAS, a.k.a. Tere, ROY SHAW, JASON BARRETH, TERINA McCORD, TIA
ROUSE, JASON MICHAEL BLYTHE, a.k.a. JDog, DONALD LEE BEASLEY,
MATTHEW BENNETT, a.k.a. Pikos a.k.a. Burro, CHAD JACOB CULLEN, a.k.a. Flavel,
GREGORY FISH, ANGEL BARRERA, MAYRA ESPINO, and BRUCE ANTHONY
SHIRLEY, shall forfeit to the United States pursuant to Title 21 , United States Code, Section

· 853, any property constituting or derived from, proceeds obtained, directly or indirectly, as a
result of the said violations and any property used, or intended to be used, in any manner or part,
to commit, or to facilitate the commission of the said violations, to include, but not limited to:
1.

A sum of money representing the amount of proceeds obtained as a result of the

offense, in the form of a money judgment.
2.

Any specific bank accounts constituting drug proceeds or property facilitating the

drug conspiracy or drug offense.
3.

Indictment

Any specific vehicles constituting drug proceeds or facilitating property.

Page 41

 Case 3:19-cr-00436-SI

Document 1

Filed 09/25/19

Page 42 of 43

Criminal Forfeiture Allegation
(Money Laundering)

Upon conviction of the money laundering offense listed above in Count 2, defendants
SAMUEL DIAZ, a.k.a. Pariente, FAUSTINO MONROY, a.k.a. Manuel, a.k.a. Compa,
a.k.a. Vejon, a.k.a. Tino, EDGAR OMAR QUIROZ RODRIGUEZ, a.k.a. Nano, a.k.a.
Marcelino Zambrano Rodriguez, a.k.a. Midget, GERSON FERNANDO MARTINEZCRUZ, a.k.a. Shaggy, JESUS GONZALEZ VAZQUEZ, a.k.a. Chuy, and JUAN ANTONIO
ROMO, a.k.a. Tony, YUNUHEN SALAZAR ANDRADE, LINDSAY ANN MARKS,
MANUEL SANCHEZ CORADO, a.k.a. Little Man, CHRISTOPHER GALLEGOS, a.k.a.
Lucky, EDUARDO MARTINEZ-PEREZ, BRYCE MATTHEW HERSEL, shall forfeit to

the United States pursuant to Title 18, United States Code, Section 982(a)(l), all property, real or
personal, involved in such offense and all property traceable to such offense, including but not
limited to a money judgment.
Criminal Forfeiture Allegation
(Firearms)

Upon conviction of a firearm offense as alleged above in Counts 15, 18, 33 , 36, and 50,
defendants EDUARDO MARTINEZ PEREZ, CHAD JACOB CULLEN, a.k.a. Flavel,
YUNUHEN SALAZAR ANDRADE, CHRISTOPHER GALLEGOS, a.k.a. Lucky, and
JASON MICHAEL BLYTHE, a.k.a. JDog shall forfeit to the United States pursuant to Title

18, United States Code, Section 924(d) and Title 28, United States Code, Section 2461(c), the
firearm(s) and ammunition involved in the offense, including but not limited to:
1.

Hi-Point .380 caliber pistol;

2.

Derringer .22 caliber double-shot pistol, serial number 463312;.

3.

Taurus .357 revolver, serial number MA44065

Indictment

Page 42

 Case 3:19-cr-00436-SI

4.

Document 1

Filed 09/25/19

Page 43 of 43

Smith & Wesson M&P-15 .556 caliber semiautomatic assault rifle, serial number
SY37091

5.

Taurus Model PT92AFS bearing serial # TAX94375;

6.

Ruger 9mm handgun bearing serial #305-28019.

7.

American Tactical Imports Omni-Hybrid .223 assault rifle bearing serial
#AN008072; and,

8.

Ruger 357 Revolver handgun bearing serial #176-51026.

Dated: Septembe~

, 2019.

A TRUE BILL.

Presented by:
BILLY J. WILLIAMS
United States Attorney

Indictment

Page 43