.Case 7:19-cr-01623 Document 1 Filed on 08/27/19 in TXSD Page 1 of 4

United States District Court
Southern District of Texas
FILED

4 .-

UNITED STATES DISTRICT COURT 3 - 

SOUTHERN DISTRICT OF TEXAS 5 David J. Bradley, Clerk 
DIVISION I 

UNITED STATES OF AMERICA

CriminalNo. 9 r? 1?23 i

V.

ARNOLDO JESUS
GERARDO VELA



jsh10/2/19 Wm JENNIFER HERRERA 

AKA: JENNIFER CUTAIA 
. ALEJANDRO HERRERA AMENDED
- SEALED INDICTMENT

THE-GRAND JURY CHARGES:
M9112 

From on or about 'April 18 2018, to on or about November. 5, 201 8, in the Southern District



of Texas and'within the jurisdiction of the Court, defendants,

ARNOLDO PRUNEDA
JESUS GERARDO VELA
. JENNIFERHERRERA

 

and
ALEJANDRO HERRERA

did kiowingly and intentionally conspire and agree together and with other persons known and"
unknown to the Grand Jurors, to possess-with intent to distribute a controlled "Substance. The
controlled substance involved was 5 kilograms or more of a mixture or substance'containing' a 
detectable amount of. cocaine, a Schedule II controlled substance.

-In violation of Title 21, United States Code, Sections 8,46 841(a)(1), and 

Co'unt Two I

From on or about April 18, 2018, to on or about April-22, 2018, in the Southern DistriCt ot? 

Texas and within the jurisdiction of the Court, defendants, -

ARNOLDO PRUNEDA
and .



in

i? 

AUG-2 7 2919 ..

 

 

 

.Case Document 1 Filed on' 08/27/19 in TXSD Page 2 of 4

JESUS GERARDO VELA
did knowingly and intenti'onallj'r peasess with intent to distribute a controlled substance. The .-
controlled substance involVed Was 5' kilograms or more, that is, approximately 25 kilograms of a_
Aime or substance containing 'a detectable amount of cocaine, a Schedule 11 calmed 
substance. I I 
'In violation of Title 21, United States Code, Sections 84l(a)(1) and 841(b)(1)(A) and Title 
i . 18,-United States code,?Section Count Three.- -
. From on or about April 18, 2018, to On or about April 22, 2018, in the Southern District of
Texas and within the jurisdiction of the Court, defendants, . I
. ARNOLDO PRUNEDA
. and .
JESUS GERARDO VELA
did knowingly and intentionally pessess with intent to. distribute a controlled substance. The
controlled substance'involved was 1 kilogram or more, that1s, approximately 14 kilograms of a
mixture or substance containing a detectable amount of heroin, a Schedule I c'ontroll?ed sub stance;
In Violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A) and Title
.- 1-8, United States Code, Section 2. i
992%

or about October 2018, in the Southern District oflTex?asj and within the jurisdiction 

 

. "of the Court, defendants,
Jesus GERARDO VELA 
.1 . 433%; . JENNIFER HERRERA
and 
ALEJANDRO HERRERA

did knowingly and intentionally possess with intent to distribute a controlled substance. The.



 

Case 7:19-cr-01623 Document 1 Filed on 08/27/19 in TXSD Page 3 of 4

controlled substance involved was 5 kilograms or more, that is, approximately 22ki1ogramsiof a
- 'rnixture or. substance containing a detectable amount of cocaine, a Schedule ?11 controlled
substance. I i
In violation of Title 21, United States Code, sections 841 and 841 and Title . . .
l8, United States Code, Section 2. I
mains.
On or about Naivember 5, 2018, in the Southern District of Texas and within the jurisdiction
of the Court, defendant,- . I
JESUS VELA 
.I did knowingly and intentionally possess with intent to distribute a controlled substance. The
controlled. substance involved was 5 kilograms or more, that is, a?prbximately 30 kilograms of 'a I
mixture or substance containing a detectable amount of cocaine, a Schedule lI controlled
substance. - I I
In Violation of Title 21, United States Code, Sections 84l(a)(1) and 841(b)(1)(A) and Title
18, United States Code, Section 2. 

NOTICE OF CRIMINAL FORFEITURE
21 use. 853(a)

Pursuant to Title 21, United States Code, Section 853, upon cornfiction of an offense and
. as aresult of the conimission of a xiiolation of. Title 21, United States Code, Sections 841 or 846,
consniracg. to possess with the intent. to distribute narcotics and possession with the intent to
distribute narcotics, as alleged in Counts One (l Two (2), Three (3), Four (4) and Five (5) of this i 
indictment, notice is given to the Defendants that they shall forfeit to the United States:

(1) any proPerty constituting, or derived from, any proceeds obtained, directly or 
indirectly, as the result of such offenses and .

 

 

Case 7:19fcr-01623 DbCument 1 Filed on 08/27/19 in TXSD Page 4_ of 4

(2) any property used, or intended to be used, 1n any manner or part, to commit, or to
facilitate the commission of, the offense. .

MONEY. JUDGMENT AND SUBSTITUTE ASSETS
Defendants are noti?ed that a money judgment may be imposed equal to the total value .of

the property subject to forfeiture.

If any of- the property subject to forfeiture, as a result of any act or omission of the

?defendants: - I i

a. - cannot be located upon the exercise of due diligence;

b. hasbeen transferred or sold to, or deposited-Mm a third party;

0.. has been placed beyond the jurisdiction ofthe Court;

Id. has?been. substantially diminishedinvalue; or I

e. . has been commingled with [other property. which cannot be divided Without .

dif?culty, i

the United States of Arnerica shall be entitled to forfeiture of substitute property pursuant to Title

21, United States Code, 

A TRUE BILL

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