I

•

Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.18 Page 1 of 11

1

CASE UNSEALED PER ORDER OF COURT

2
3

Co.;fi;1'

(.\UFORNlA

4

5
6

UNITED STATES DISTRICT COURT 


7

SOUTHERN DISTRICT OF CALIFORNIA 


8

September 2013 Grand Jury 


9

UNITED STATES OF AMERICA 1

10
11

12
13
14
15
16
17
18

Plaintiff

Case No. 14CR0658-DMS
I N D I C T MEN T 

- (Superseding) ­

l

v.
ISMAEL ZAMBADA-GARCIA (1),
aka "EI Mayo,"
aka "Doc,"
ISMAEL ZAMBADA-IMPERIAL (2),
aka "Mayito Gordo,"
aka "Good Guy,"
ISMAEL ZAMBADA-SICAIROS (3),
aka "Mayito Flaco,"
aka "Caballero,"
IVAN ARCHIVALDO GUZMAN-SALAZAR (4),
aka "Luis,"
aka "Chapito,"

1

Defendants.

19
20

~------------------------------------~

21

The grand jury charges:

22
23

Title 211 U.S.C., Sec. 848(a) 

and (b)
Continuing Criminal 

Enterprise; Title 21, U.S.C., 

Secs. 959 960, and 963 ­
Conspiracy to Distribute 

Methamphetamine, Cocaine and 

Marijuana Intended for 

Importation; Title 21, U.S.C., 

Secs. 952, 960, and 963 ­
Conspiracy to Import 

Methamphetamine, Cocaine and 

Marijuanai Title 18, U.S.C., 

. Secs. 1956 (h) and 1956 (a) (2) (A)­
Conspiracy to Launder MoneYi
Title 21, U.S.C., Sec. 853,
Title 18, U.S.C., Sec. 982, and
Title 28, U.S.C., Sec. 2461(c) ­
Criminal Forfeiture

Introductory Allegations
At all times relevant to this Indictment,

1.

24

criminal

25

Cartel

26

Sinaloa, Mexico.

organization known as
is

a

the

transnational. drug

27

2.

Under

28

aka "EI

Mayo,"

the

ALB:nlv:San Diego
7/23/14

aka

leadership
"Doc,"

"Sinaloa

trafficking

of

the

defendant
Sinaloa

there existed a

Cartel."

The

organization

ISMAEL

Cartel

Sinaloa

based

in

ZAMBADA-GARCIA,
operates

as

an

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.19 Page 2 of 11

1

affiliation

of

drug

traffickers

and

money

launderers

located

in

2 multiple countries throughout the world who coordinate and pool their
3 collective resources in order to:
a.

4

5

transport drugs from countries of supply in Asia and

central and South America to Mexico;

6

b.

transport

drugs

through

Mexico

and

into

the

United

c.

distribute drugs to wholesale customers in the United

7 States;
8

9 States; and
10

d.

11

trafficking.

12

3.

collect,

launder,

and

transfer

the

proceeds

At all times relevant to this Indictment,

of

drug

defendant ISMAEL

13

ZAMBADA-GARCIA, aka \\EI Mayo," aka "Doc," and members and associates

14

of the Sinaloa Cartel under him coordinated their drug trafficking

15 activities

to

American

import

large quantities
including

cocaine

Colombia,

from Central

South

17

Peru, Panama, Costa Rica, Honduras, and Guatemala,

18

as import large quantities of methamphetamine precursors from Asia to
Defendant ISMAEL ZAMBADA-GARCIA,

Ecuador,

and

16

19 Mexico.

countries,

of

Venezuela,

to Mexico, as well

aka \lEI Mayo," aka "Doc,"

20

and members and associates of the Sinaloa Cartel under him coordinated

21

the unloading of large shipments of cocaine in Mexico, and coordinated

22

the

23

Mexico.

24

and members and associates of the Sinaloa cartel under him coordinated

25

their

26

cocaine, generally in shipments of hundreds of kilograms at a time, as

27

well

28

quantities of marijuana, from Mexico across the United States border,

transportation

and

storage

of

these

Defendant ISMAEL ZAMBADA-GARCIA,

drug

as

trafficking

multi-kilogram

activities

quantities

2


to

cocaine

within

aka "EI Mayo," aka "Doc,"

smuggle

of

shipments

large

quantities

methamphetamine

and

of

ton-

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.20 Page 3 of 11

1

and then into and throughout the United States,

2

California, and elsewhere.
Structure and Organization

3

4

including San Diego,

At all times relevant to this Indictment,

4.

the roles of the

5 various Sinaloa Cartel members were as follows:

a.

6

was

Defendant ISMAEL ZAMBADA-GARCIA, aka "EI Mayo,

9

the price for and caused to be obtained large quanti ties of cocaine

10

from Central and South American countries to Mexico, and caused multi-

11

kilogram quantities of

12

transported from Mexico to the United States border, and tben into and

13

throughout

14

aka "EI Mayo,

15

transferred from

16

benefit of the Sinaloa Cartel's members and associates.
b.

cocaine,

United
aka

II

primary

of

the

Sinaloa

aka "Doc,

II

II

Cartel.

negotiated

methamphetamine and marijuana to be

States.

"Doc,"

leaders

It

8

17

the

Mayo,

aka "Doc,

the

of

"EI

aka

7

II

one

ZAMBADA-GARCIA,

ISMAEL

Defendant

Defendant

ISMAEL

ZAMBADA-GARCIA,

caused drug proceeds to be

laundered and

the United States to Mexico and elsewhere

Defendant ISMAEL ZAMBADA-IMPERIAL,

for

the

aka "Mayito Gordo,

II

18

"Good Guy," the son of defendant ISMAEL' ZAMBADA-GARCIA,

19

kilogram quantities of cocaine and ton quantities of marijuana to be

20

transported from Mexico to the United States border, and then into'and

21

throughout

22

ZAMBADA-IMPERIAL

23

customers in the united States and laundered and transferred from the

24

united States to Mexico and elsewhere for the benefit of the Sinaloa

25

Cartel's members and associates ..

26

the

c.

United
further

States

for

distribution.

caused drug proceeds

Defendant

to be

Defendant ISMAEL ZAMBADA-SICAIROS,

caused multi-

ISMAEL

collected

from

aka "Mayito Placo,"

27

"Caballero,

28

kilogram quantities of methamphetamine to be transported from Asia to

II

the son of defendant ISMAELZAMBADA-GARCIA, caused multi

3


 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.21 Page 4 of 11

1

Mexico.

Once the methamphetamine arrived in Mexic·o, defendant ISMAEL

2

ZAMBADA-SICAIROS caused it to be transported from Mexico to the United

3

States border,

and then into

4

distribution.

Defendant ISMAEL ZAMBADA-SICAIROS further caused drug

5

proceeds

6

laundered

and

transferred

7

elsewhere

for

the

8

associates.

to

be

d.

9

"Chapito, "

collected

and throughout

from

customers

from

benefit

of

the

in

the

United

the

the United States

United

States

Sinaloa

to

Cartel's

Defendant IVAN ARCHIVALDO GUZMAN-SALAZAR,
caused multi-kilogram quantities

States

and

Mexico

and

members

and

aka

"Luis,"

10

aka

11

quantities of marijuana to be transported from Mexico to the United

12

States border,

13

distribution.

14

drug proceeds to be collected from customers in the United States and

15

laundered

and

transferred

16

elsewhere

for

the

17

associates.

and then into

cocaine and ton

the United States

for

Defendant IVAN ARCHIVALDO GUZMAN-SALAZAR further caused

from

benefit

of

the

United

States

the

Sinaloa

to

Cartel's

Mexico

and

members

and

Purpose and Methodology

18
19

and throughout

of

for

5.

At all times relevant to this Indictment, defendants ISMAEL

20

ZAMBADA-GARCIA,

21

aka "Mayito Gordo,"

22

Flaco,"

23

aka "Chapito," and members and associates of the Sinaloa· Cartel under

24

them pooled their collective resources

and used shared networks of

25

couriers

Cartel,

26

activities to:

27

28

aka

"Caballero,"

affiliated

a.

"El Mayo,"
"Good Guy,"
IVAN

with

aka

"Doc,"

ZAMBADA-IMPERIAL,

ISMAEL ZAMBADA-SICAIROS,

ARCHIVALDO

the

ISMAEL

Sinaloa

GUZMAN-SALAZAR,

to

aka "Mayito
aka

coordinate

"Luis,"

their

Cause large quantities of cocaine, methamphetamine and

other drugs and. drug precursor chemicals to be imported from Asia and
4


 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.22 Page 5 of 11

1 Central

and South American countries,

2 Venezuela,
3 Mexico,

Peru,

using

4 aircraft,

Panama,
various

submarines

5 vessels,

container

Costa
means,

and

Rica,

Honduras,

including

other

ships,

including Colombia,

cargo

submersible

supply

and

vessels,

Ecuador,

Guatemala,

aircraft,

and

to

private

semi-submersible

go-fast

boats,

fishing

6 vessels, buses, rail cars, tractor trailers, trucks, automobiles, and
7 private

and commercial

interstate

and

foreign

carriers.

After

the

8 drugs and drug precursor chemicals arrived in Mexico, the conspirators
9 used shared resources to unload and store the drugs in Mexico.
Cause large quantities of cocaine, methamphetamine and

b.

10

11 marijuana, at times in shipments of hundreds of kilograms at a time,
12

to

be

transported

13

States border where the drugs were then stored in multiple warehouses,

14

stash

15

Mexicali, and elsewhere.

houses,

c.

16

17

Mexico

18

elsewhere

from various

and

safe

houses

locations

located

in Mexico

in

the

to

areas

the

of

United

Tijuana,

Cause drugs to be smuggled across the United States­

border

through

using

the

mul tiple

Southern
means,

District

including

of

California

automobiles,

and

tractor

19 trailers, trucks, fishing vessels and tunnels.
20

d.

21 affiliated

Cause drugs
with

the

to be

Sinaloa

unloaded by stash house operators

Cartel,

and

stored at

mUltiple

stash

22 houses, safe houses, and warehouse locations in the Southern District
23 of California and elsewhere.
e.

24

Cause

cocaine,

25

transported

throughout

26

including

27

commercial interstate carriers.

28

//

automobiles,

the

methamphetamine
United

tractor

States,

trailers,

5


and
using

trucks,

marijuana
various
and

to

be

means,

private

and

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.23 Page 6 of 11

1

f.

Cause cocaine, methamphetamine and marijuana to be sold

2

and distributed to wholesale customers in the greater Los Angeles,

3

California area; the greater Chicago, Illinois area, and elsewhere.
g.

4

Cause drugs proceeds to be collected from customers,

5

counted,

packaged,

6

States through the Southern District of California, and elsewhere, to

7

Mexico,

8

smuggling, structured bank deposits, wire transfers, currency exchange

9

transfers,

and

and

transferred

elsewhere,

alternative

multiple

laundered

means,

credit-based systems
other

including

used

to

bulk

cash

transfer money

use

11

systems

in

which

12

airplanes, were purchased in one location and transferred to another

13

location, and other methods by shared networks of money couriers and

14

money launderers associated with the Sinaloa Cartel.

including

items,

Use various means
their

luxury

goods-based
vehicles

to communicate with each other

order

17

cellular

18

messaging applications on smart phones, and email accounts.

telephones,

i.

Use

drug

high-end

means,

16

19

coordinate

traditional

United

the

to

or

the

without

h.

wires

from

10

15

of

using

and

trafficking

satellite

coded

language

activities,

telephones,

in

including

computers,

and other means

and

instant

to misrepresent,

20

conceal and hide,

21

hidden, the drug trafficking activities of the Sinaloa Cartel, and to

22

avoid detection and apprehension by law enforcement authorities.

23

j.
drug

and to cause to be misrepresented,

concealed and

Use various means to evade law enforcement and protect

24

their

distribution

25

other weaponsi bribing corrupt public officials; engaging in violence

26

and threats

27

members of

28

their own drug trafficking organization.

of violence;

activities,

including:

obtaining

guns

and

and intimidating with threats of violence

law enforcement,

rival drug traffickers,

6


and members of

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.24 Page 7 of 11

Count 1

1

1.

2

Paragraphs one through five of the Introductory Allegations

3

of

this

Indictment

4

though fully set forth herein.
2.

5

are

realleged and

incorporated

by

reference

as

Beginning no later than in or about May 2005 and continuing

6

up to and including July 25,

7

California,

8

Mayo,

9

continuing criminal enterprise by violating various felony provisions

II

the

and

aka

elsewhere,

"Doc,

II

within the Southern District of

defendant

knowingly

and

intentionally

United

in

States

a

12

States Code,

13

Sections 952,

14

were part of a

15

undertaken by defendant in concert with five or more other person with

16

respect to whom defendant occupied a position of organizer, supervisor

17

and

18

series

19

resources.

"Doc,

21,

engage

"EI

Sections 801, et seq.),

3.

(Title

aka

11

Code,

including but not limited to Title 21, United

Sections 959,
960 and 963,

960 and 963,

as alleged in Count 2,

as alleged in Count 3,

and

which violations

continuing series of violations of said Act and were

position

of

Act

ZAMBADA-GARCIA,

of

other

Substances

ISMAEL

10

20

Controlled

did

2014,

of

violations

management,
defendant

and

from

obtained

which

such

substantia~

continuing
income

and

Furthermore, defendant ISMAEL ZAMBADA-GARCIA, aka "EI Mayo,"

21

aka

22

leader of

23

distribute 150 kilograms and more of cocaine, a Schedule II Controlled

24

Substance,

25

States, and a conspiracy to import 150 kilograms and more of cocaine,

26

a

27

place outside thereof.

28

All in violation of Title 21, U.S.C., Section 848(a) and (b).

II

Schedule

was
the

for

II

a principal administrator,
criminal

enterprise,

the purpose

of

which

unlawful

Controlled Substance,

7


organizer,
involved

importation

into

the

supervisor and
a

conspiracy

into

United

to

the United

States

from

a

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.25 Page 8 of 11

count 2

1

2

Beginning no later than in or about May 2005 and continuing up to

3

and including July 25, 2014, defendants ISMAEL ZAMBADA-GARCIA, aka "El

4

Mayo,"

5

aka "Good

6

aka "Caballero,"

7

aka "Chapito, "

8

other, and with other persons known and unknown to' the grand jury, to

9

distribute 500 grams and more of a mixture and substance containing a

aka

"Doc,"
Guy,"

ISMAEL
ISMAEL

and
did

amount

ZAMBADA-IMPERIAL,
ZAMBADA-SICAIROS,

IVAN

ARCHIVALDO

knowingly

of

and

aka
aka

"Mayito

GUZMAN-SALAZAR,

intentionally

methamphetamine

"Mayito

conspire

"Luis,"

with

11

cocaine,

12

and more

13

purpose

14

violation of Title 21, United States Code, Sections 959, 960, and 963.

of

marijuana;
unlawful

Controlled Substances;

a

Schedule

importation

15

I

and

each

detectable

of

5 kilograms

Flaco,"

10

both Schedule II

and

aka

Gordo,"

and 1000

the

United

of

kilograms

Controlled Substance;

into

more

States;

for

the

all

in

Count 3

16

Beginning no later than in or about May 2005 and continuing up to

17

and

18

California,

19

Mayo,"

20

aka "Good

21

aka "Caballero,"

22

aka "Chapito,"

23

other,

and with other persons known and unknown to the grand jury, to

24

import

500

25

detectable

26

cocaine,

27

and more of marijuana;

including

aka

July

25,

2014,

and elsewhere,
"Doc,"
Guy,"

and
did

grams
amount

IVAN

ZAMBADA-IMPERIAL,
ZAMBADA-SICAIROS,
ARCHIVALDO

knowingly

and more
of

of

and

a

Southern

a

aka
aka

District

mixture
and

and

28

8


"Mayito

5

aka

conspire

of

aka

"El

Gordo,"
Flaco,"
"Luis,"

with

each

substance containing a
kilograms

Controlled Substances;
Schedule I

"Mayito

GUZMAN-SALAZAR,

intentionally

methamphetamine

both Schedule II

the

defendants ISMAEL ZAMBADA-GARCIA,

ISMAEL
ISMAEL

within

and

more

of

and 1000

kilograms

Controlled Substance;

into the

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.26 Page 9 of 11

1

United States from a place outside thereof; all in violation of Title

2

21, United States Code, Sections 952, 960, and 963.

3

Count 4

4

Beginning no later than in or about May 2005 and continuing up to

5

and

6

California

7

Mayo,"

8

aka "Chapito, II

9

other, and with other persons known and unknown to the grand jury,

including

July

25,

2014,

and elsewhere,

aka

"Doc,"
did

offenses

and

defendants

IVAN

the

ISMAEL

ARCHIVALDO

knowingly

against

within

and

the

Southern

ZAMBADA-GARCIA,

GUZMAN-SALAZAR,

intentionally

with

to

12

monetary instruments and funds,

13

place in the United States to and through a place outside the United

14

States,

15

unlawful activity,

16

in violation of Title 18,

17

all in violation of Title 18, United States Code, Section 1956(h).

the

intent

to

18,

each

States Code,

transport,

Title

"Luis,"

11

namely:

under

"EI

commit

with

States

aka

aka

conspire

of

10

Section 1956,

United

District

United

transmit and transfer

that is United states currency, from a

promote

the

carrying

on

of

specified

that is the distribution of controlled substances,

18

united States Code,

Section 1956 (a) (2) (A) ;

FORFEITURE ALLEGATIONS

19

1.

The

allegations

in

Counts

through

of

this

21

for the purpose of alleging forfeiture to the United States of America

22

pursuant

23

Section 853, and Title 18, United States Code, Section 982.
2.

the

provisions

of

Title

fully

4

Indictment

to

realleged and by reference

1

20

24

are

contained

21,

incorporated herein

United States

Code,

As a result of the commission of the felony offenses alleged

25

in

Counts

1

through

26

punishable

by

27

Title

21,

United

28

defendants

ISMAEL

3

of

imprisonment
States

this
for

Indictment,

more

Code,

ZAMBADA-GARCIA,

than one

Sections
aka

9


"EI

said

violations

year

and pursuant

8 5 3 (a) (I)
Mayo, II

being

aka

and

to

8 5 3 {a} {2} ,

"Doc,

II

ISMAEL

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.27 Page 10 of 11

1

ZAMBADA-IMPERIAL,

2

SICAIROS,

3

GUZMAN-SALAZAR,

4

forfeit to the United States all their rights,

5

any and all property constituting,

6

defendant

7

felony offense alleged in this Indictment,

8

used or intended to be used in any manner or part to commit and to

9

facilitate the commission of the violation alleged in this indictment.

aka

aka "Mayito Gordo," aka "Good Guy,"

"Mayito
aka

obtained,

"Luis,"

The property

11

following:

12

States

13

Mercedes

14

GTR bearing

15

bearing

16

VIN #ZHWBU37S58LA02742.

1982

tail

McLaren
VIN

VIN

3.

forfeited

N1218U

"Chapito,

or

210

bearing

shall,

II

indirectly,

and

and

title and interest in

as

any proceeds any

the

is

not

bearing Serial

VIN

result

#ZHWBU8AHXALA03904

tail

2010

and

of

the

limited to,
#21064675,

number

Lamborghini

2008

the

United

XB-NKYi

#WDDAJ76F66M000890i

#JNIAR5EF4EM270727 i

conviction,

and any and all property

but

Mexican

IVAN ARCHIVALDO
upon

or derived from,

includes,

Cessna Turbo

number

SLR

aka "Caballero,"

aka

directly

10

17

to be

Flaco,"

ISMAEL ZAMBADA­

2014

2006
Nissan

Murcielago

Lamborghini

bearing

As a result of the commission of the felony offense alleged

18

in

19

imprisonment for more than one year, and pursuant to Title 18, United

20

States

21

aka "EI

22

aka "Luis,"

23

United States all rights,

24

involved in such offense, and any property traceable to such property.

25

Count

4.

4

of

Code,

Indictment,

Section

Mayo,

If

this

II

aka

any

aka

982{a) (I),
"Doc,"

"Chapito,"

of

said violation being punishable

the

defendants

by

ISMAEL

ZAMBADA-GARCIA,
GUZMAN-SALAZAR,

and

IVAN

ARCHIVALDO

shall,

upon

conviction,

forfeit

to

the

title and interest in any and all property

above-described

forfeitable

26

result of any act or omission of the defendants:

27

II

28

II
10 


property,

as

a

 Case 3:14-cr-00658-DMS Document 6 Filed 07/25/14 PageID.28 Page 11 of 11

1

a.

cannot be located upon the exercise of due diligence;

2

b.

has been transferred or sold to,

or deposited with,

a

third party;

3
4

c.

has been placed beyond the jurisdiction of the Court;

5

d.

has been substantially diminished in value; or

6

e.

has been commingled with other property which cannot be
subdivided without difficultYi

7

8

it

is

the

intent

9 united states

United

Section

853 (p),

and

incorporated

by

13

the said property listed above as being subject to forfeiture.
United

as

through 3,

forfeiture of any other property of the defendant up to the value of

21,

853 (p),

1

Title 21,

12

Title

Section

to Counts

to

Title 18, United States Code, Section 982(b) (1) as to Count 4, to seek

of

Code,

as

pursuant

11

violation

States

States,

Title

in

United

the

10

14 All

21,

Code,

of

States

Code,

Section 853,

15

Title 18, United States Code, Section 982, and Title 28, United States

16

Code, Section 2461 (c) .
DATED: July 25, 2014.

17

18

A TRUE BILL:

19
20
21
22

23
24

Foreper
LAURA E. DUFFY
United States Attorney
By:

Assistant U.S. Attorney

25
26
27

28
11