IN THE FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION 51151le OF AMERICA V. (4) DAVID SILVA GARCIA AKA. ANIMO (5) DAVID DE LOS SANTOS (6) MELVIN RAY WILLIAMS AKA. BLACK (7) AMBER VASQUEZ (8) MIA VASOUEZ (9) ISRAEL VASOUEZ (10) JOSE GUERRERO AKA. JD. (11) FRANCISCO GALLEGOS, IR. AKA. PANCHITO, BAN (12) ROBERTO RAMIREZ (13) REYES (14) JASON ERIC STOTTS (15) OCTAVIUS DONNELL WILLIAMS (16) JAVIER GUERRA, AKA. CHOP (17) TONY RUVALCABA, AKA. LIL TONY (18) EUSEBIO MARTINEZ RAMIREZ, JR. AKA. SIP (19) EDUARDO RUVALCABA, AKA. LALO (20) KENNETH JOHNSON, AKA KJ GONZALES (22) NOEL ESCAMILLA (23) ADRIAN MIRAMONTEZ (24) ROLANDO BENITEZ AKA. SAN LUIS (25) JUAN AYALA (26) JUAN MANUEL ARELLANO (27) JOSE AMAYA (2S) FUNAKI EALAHOLA, AKA. NOC (29) MONITEVETI KATOA, AKA. VINCE SuDerseding Indictment Page 1 ?aw SEALED INDEQMENI, U1 5 NO. (Supersedes Indictment Rammed July 9, 20M). TRICT COURT {?13 a . (30) MAYRA LOPEZ (31) LUKE LAMIPETI (32) DAVID LOPEZ (33) JESSE ALCALA (34). JUAN ZUNIGA, AKA (35) COREY NELSON (36) PAUL SALAZAR (37) DEMARCUS CALHOUN (38) GEORGE GUERRA (39) NICHOLAS MAYES (40) RUDOLPHO MAYES, AKA. RUDY (41) ALBERT JUAREZ (42) MARCUS DEMON HARDY (43) RODNEY TILLEY (44) MOLITONI KATOA, AKA TONY (45) VILISOLO LAMIPETI (46) JANELLEISAACS (47) ROSAMARIA ELANCO (48) ROBERTO YASQUEZ, IR. (49) ERNEST OLIYAREZ SUPERSEDING INDICTMENT The Grand Jury charges: Count One (COHSpiracy to Possess with Intent to Distribute a Controlled Substance 21 U.S.C. 846, 841(a)(l), Beginning on or about December 1, 2013, the exact date being unknown to the Grand Jury, and continuing thereafter through and including the date of the superseding indictment, in the Dallas Division of the Northern District of Texas, and elsewhere, DAVID SELVA GARCEA, DAVID DE LDS SANTDS, MELVIN RAY WELLIAMS, Superseding Indictment Page 2 ESRAEL VASQUEZ, AMBER VASQUEZ, MEA VASQHEZ, RGBERTG RAMEREZ, GALLEGGS AKA. PAN, AKA, PANCHETQ defendants herein, did knowingly, intentionally and. unlawfully combine, conSpire, confederate, and agree together, with each other and with other persons known and unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute and to distribute one (1) kilogram or more of a mixture or substance containing a detectable amount of heroin, a Schedule 1 controlled substance, in violation of2l use. 846, 84l(a)(l) and Superseding Indictment Page 3 Count Two Conspiracy to Possess with Intent to Distribute a Controlled Substance (21 USC 846, 84l(a)(l), Beginning on or about October 1, 2013, the exact date being unknown to the Grand Jury, and continuing thereafter through and including the date of the superseding indictment, in the Dallas Division of the Northern District of Texas and elsewhere, JDSE GUERRERD AKA. JD, RDBERTO RAMIREZ, FRANCESCO GALLEGGS JR, AKA. PAN, AKA, GERARDD REYES, DAVID DE LQS SANTOS, MELVIN RAY WILLEAMS AKA. BLACK, JASON EREC STOTTS, defendants herein, and others both known and unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons both known and unknown, to commit certain offenses against the'United States, to-wit: to possess with the intent to distribute and to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II controlled substance, in Violation of 21 use. 846, 841(a)(1) and Superseding Indictment Page 4 W2 ConSpiracy to Possess with Intent to Distribute a Controlled Substance (21 USC 846, 841(a)(1), Beginning on or about November 1, 2012, the exact date being unknown to the Grand Jury, and Continuing thereafter through and including the date of the superseding indictment, in the Dallas Division of the Northern District of Texas and elsewhere, JDSE GUERRERG AKA. JED, JAVEER GUERRA AKA. CHDP, TONY RUVALCABA AKA. LIL TONY, EUSEBEO MARTINEZ RAMIREZ, JR. AKA. SEE, EDUARDD RUVALCABA AKA. EAEG, KENNETH AKA. K317, ALEX GDNZAEES, DEL ESCAMELLA, DDNNELL KENNETH AKA. KJ, defendants herein, and others both known and unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons both known and unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute and to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II controlled substance, in Violation of2l U.S.C. 846, 84l(a)(1) and Superseding indictment Page 5 Count Four Conspiracy to Possess with Intent to Distribute a Controlled Substance (21 USC 846, 84l(a)(l), Beginning on or about November 1, 2014, the exact date being unknown to the Grand Jury, and continuing thereafter through and including the date of the superseding indictment, in the Dallas Division of the Northern District of Texas and elsewhere, $08343 GUERRERD, AKA. Jill}, AUREAN MERAMDNTEZ, JUAN AYALA, JUAN MANUEL ARELLAND, JDSE AMAYA, RGLANDU BENETEZ, AKA. SAN LUES, FALAHDLA AKA. NDC, MAYRA LDPEZ, defendants herein, and others both known and unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons both known and unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute and to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II controlled substance, in Violationlof21 U.S.C. 846, 84l(a)(1) and Superseding indictment Page 6 Count Five Conspiracy to Possess with Intent to Distribute a Controlled Substance (21 USC 846, 841(a)(l), On 'or about May 7, 2014, in the Dallas Division of the Northern District of Texas, andielsewhere, LUKE and FUNAKE FALAHOLA, AKA, NDC, defendant herein and others both known and unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons both known and unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute and to distribute 50 grams or more of a mixture or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule 11 controlled substance, in Violation of 21 use. 846, 84l(a)(l) and Superseding Indictment Page 7 Count Six Conspiracy to Possess with Intent to Distribute a Controlled Substance (21 USC 846, 84l(a)(l), Beginning on or about October 1, 2011, and continuing through the ?ling date of the superseding indictment, in the Dallas Division of the Northern District of Texas, I DAVID LQPEZ, and JESSE ALCALA, defendants herein and others both known and unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons both known and unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute and to distribute 50 grams or more of a mixture or substance containing a. detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II controlled substance, in Violation onl U.S.C. 846, 84l(a)(l) and Superseding Indictment Page 8 Count Seven (Conspiracy to Possess with Intent to Distribute a Controlled Substance 21 U.S.C. 846, 841(a)(1), On or about January 1, 2012, and continuing through the ?ling date of the superseding indictment, in the Dallas Division of the Northern District of Texas, and elsewhere, WAN ZUNEGA AKA. Z, RUDOLPHO MAYES ARA. RUDY, ALBERT JUAREZ, COREY NELSON, PAUL SALAZAR, DEMARGUS CALHOUN, MARCUS DEMON HARDY, GEORGE GUERRA, NECHOLAS MAYES, RODNEY defendants herein, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons unknown, to commit certain offenses against the United States, to?wit: to possess with the intent to distribute ?ve kilograms or more of a mixture or substance containing a detectable amount of cocaine, a Schedule controlled substance, in Violation of21 U.S.C. 846, 84l(a)(l) and Superseding Indictment Page 9 Count Eight (Conspiracy to Possess with Intent to Distribute a Controlled Substance 21 U.S.C. 846, 84l(a)(l), On or about June 20, 2013, in the Dallas Division of the?Northern District of Texas, FUNAKE FALAHQLA, LUKE LAMEPETL KATUA AMKAO TDNY, LAMIPETE, NGEL ESEAMELLA AKA. NOE, defendants herein, did knowingly, intentionally and unlawfully combine, conSpire, confederate, and agree together, with each other and with other persons unknown, to commit certain I offenses against the United States, towwit: to possess with the intent to distribute ?ve kilograms or more of a mixture or substance containing a detectable amount of cocaine, a Schedule II controlled substance, in Violation of21 USC. 846, 84l(a)(l) and Superseding Indictment Page 10 Count Nine (Conspiracy to Possess with Intent to Distribute a Controlled Substance 21 U.S.C. 846, 84l(a)(l), Beginning on or about April 18, 2013, and continuing through the ?ling date of the superseding indictment, in the Dallas Division of the Northern District Of Texas, the Northern District of the District of Nevada, the DistriCt of Arizona, the District of New Jersey, the Northern District of California, the District of Kansas, and elsewhere, FUNAKI FALAHDLA, KATCJA AKA. TDNY, JANELLE MDNITEVETE KATDA, AKA. VENCE, defendants herein, did knowingly, intentionally and unlawfully combine, conspire, confederate, and agree together, with each other and with other persons unknown, to commit certain offenses against the United States, to?witi to possess with the intent to distribute five kilograms or more of a mixture or substance containing a detectable amount of cocaine, a Schedule controlled substance, MANNER AND MEANS During the conspiracy alleged herein, it was part of the conspiracy that one or more of the defendants and con-conspirators would: 1. Acquire kilogram?amounts of a substance that was represented to be cocaine; 2. Arrange for the transportation and delivery of kilogram amounts of a substance that was represented to be cocaine through the Dallas/Ft. Worth International Airport and onto commercial airline flights by: Superseding Indictment Page 11 a. Utilizing a position of employment at the Dallas/Ft. Worth International Airport to bypass security, or b. contacting an individual or individuals that they knew had a position of employment at the Dallas/Ft. Worth International Airport in order to get. that individual or individuals to help bypass security measures at the Dallas/Ft. Worth International Airport, or c. aiding an individual or individuals that they knew in bypassing security measures at the Dallas/Ft. Worth International Airport; i 3. TranSport kilogram amounts of a substance represented to be cocaine on commercial airline ?ights from the Northern District of Texas to various locations throughout the United States and deliver the substance in exchange for payment; 4. Divide the payment for transportation and delivery of the substance that was represented to be cocaine; 5. Coordinate the transportation, distribution, and delivery of kilogram amounts of the substance represented to be cocaine with persons both known and unknown to the Grand Jury within the Northern District of Texas and elsewhere; 6. Utilize vehicles, homes, and communication facilities, including telephones and cellular telephones, to discuss, negotiate, and facilitate the success of the conSpiracy; Superseding Indictment Page 12 7. Act as ?look outs? or engage in counter~surveillance to bypass security measures at the Dallas/Ft. Worth International Airport; 8. Act as ?look?outs? or engage in counterusurveillance to become aware of any police presence. OVERT ACTS 1. ln furtherance of the conspiracy alleged in Count Nine of the Superseding Indictment, FUNAKE FALAHGLA, on or about April 18, 2013, informed an undercover of?cer that he could transport drugs through United Airlines and American Airlines by using contacts in Las Vegas, Los Angeles, San Francisco, and Miami International Airports. FUNAKE FALAHGLA informed an of?cer(s) acting in an undercover capacity (hereafter referred to as undercover of?cer) that he would also get his cousin, MGLETGNE KATGA, to assist in this venture: a. On or about May 10, 2013, FUNAKE rnranom introduced KATOA aka. VENCE as his uncle. MQNEYEVETE KATQA told the undercover of?cer he would fly to the airports where the undercover of?cer wanted illegal drugs shipped and conduct a security check to make sure the drugs were not detected by law enforcement. After completing the security check, KATUA told the I undercover of?cer he would fly the drugs on his person to their ?nal destination. MONTIVETI KATOA said his name would be placed on the Supersedng Indictment Page 13 employee" ?ight list as opposed to the standard passenger manifest. FUNAKE FALAHOLA informed the undercover of?cer his cousin and other family members would also be able to help. b. On or about May 23, 2013, MOLHONE MTOA and FUNAKI FALAHOLA provided details as to how they could transport illegal drugs via commercial airlines. 0. On or about August 16, 2013, FUNAKE FALAHOLA toldan undercover officer KATOA would be able to bypass TranSportation Safety Administration (TSA) Security and transport four kilograms of cocaine to Las Vegas for a fee. The total agreed fee was $9000 in US. currency. d. On or about Septeinber 11, 2013,? and in furtherance of the conspiracy alleged in Count Nine of the Superseding Indictment, FUNAKE FALAHOLA told an undercover officer that he and MONETEVETI would be meeting with Morr?ronr KATOA shortly after the cocaine was provided but before MOLITONE KATOA began his shift at the Dallas/Ft. Worth International Airport. Undercover of?cers provided FUNAKI FALAHOLA a backpack containing four kilograms of a substance that was represented to be cocaine. Subsequently, FUNAKI FALAHOLA and MONETEVETE KATOA boarded an American Airlines ?ight to Las Vegas. FUNAKE FALAHOLA and MONETEVETE Superseding Indictment Page 14 KATUA then delivered the four kilograms of a substance that was represented to, be cocaine, in the District of Nevada, to an undercover of?cer who paid the remaining amount of the agreed upon fee of $9000. e. On September 18, 2013, and in furtherance of the conspiracy alleged in Count Nine of the Superseding Indictment, MUNITEVETI MTGA told an undercover of?cer that he thought FHNAKI FALAHGLA was bragging about taking drugs to Las Vegas, Nevada. MGNITEVETI KATOA suggested to the undercover officer that he should allow him (MGNTEVETI MTGA) to transport illegal drugs. MQNITEVETI KATQA told an undercover of?cer he had several ways to transport illegal drugs, that he had been ?ying several times a month to observe how TSA conducted security checks in various cities and that he had been waiting fOr the opportunity to transport drugs on American'Airlines. 2. On or about September 15, 2014, and in furtherance of the conSpiracy alleged in Count Nine of the Superseding Indictment, MQNITEVETI KATQA agreed to transport three kilograms of a substance that was represented to be cocaine from Dallas/Ft. Worth International Airport, via commercial airline, to a destination in Newark, New Jersey: a. .On September 22, 2014, an undercover officer provided MTGA with three kilograms of a substance that was represented to be cocaine. KATQA took the three Superseding Indictment Page 15 kilograms of a substance he believed to be cocaine and transported them via commercial airline from the Dallas/Ft. Worth International Airport to Newark, New Jersey, where he met an undercover of?cer, in the District of New Jersey, at a location away from the airport. b. MONITEVETI MTOA was paid $5500 in US. currency for the tranSportation services. MGNITEVETI KATQA told the undercover of?cer he had been delayed for an hour before boarding and that he was asked to check his bag. MONITEVETI KATGA told the undercover of?cer he was nervous but knew it was a routine request. MGNITEVETI MTOA then called JANELLE ISAACS and asked her to check on return ?ights for him. During the conversation, the undercover of?cer overheard JANEILLE ask MGNITEVEII KATQA if everything had gone In response to a question from the undercover of?cer, MGNITVETI MTOA stated had helped him get the drugs on the plane and that his fee was $2000 in U.S. currency. 3. On or about October 3, 2014, and in furtherance of the conSpiracy alleged in Count Nine of the Superseding Indictment, FUNAKI PALAHGLA asked an undercover of?cer to contact him any time he wanted drugs smuggled from the Dallas/Ft. Worth International Airport via commercial airline to any other Superseding lndictment Page 16 city, that he did not know MONETVETI KATOA had been smuggling drugs independently, and that he wanted to be included in any further transactions. a. On October 24, 2014, undercover of?cers met with FALAHOLA and provided a backpack that contained three kilograms of a substance that was represented to be cocaine. FUNAKE FALAHOLA said he would give the backpack to MOLETONE who would be able to bypass the security checkpoints at the Dallas/F t. Worth International Airport due to his employment. MOLETONE KATOA would then deliver the backpack with the three kilograms to KATOA who would transport them to Phoenix, Arizona. b. rnuem rereuom received $3000 in us. currency from an undetecver of?cer for the transportation of the three kilograms of a substance that was represented to be cocaine. FUNAKE FALAHOLA told an undercover of?cer that MONETEVETI KATOA would be I taking a 3 :00 pm. or 7:00 pm. ?ight depending upon seat availability. c. On October 24, 2014, KATOA delivered the three kilograms that were represented to be cocaine to an undercover of?cer in Tempe Arizona, which is in the District of Arizona, and was paid $3 000 in US. currency. Superseding Indictment Page 17 4. On November 6, 2014, and in furtherance of the conspiracy alleged in Count Nine of the superseding indictment, KATGA told an undercover officer he was ready to transport three?kilograms of a substance that was represented to be cocaine to Chicago, Illinois from the Dallas/F t. Worth International Airport via commercial Airline. a. KAng told an undercover of?cer that an associate and KATGA were available to smuggle the backpack containing the three kilograms inside the secure areas of the Dallas/Ft. Worth International Airport, and described how the three kilograms would be smuggled in and returned to him. MGNTIVIEII KATGA said he had a girlfriend, his wife (JANELLE ISAACS), KATGA, and an unidentified. associate, assisting him in transporting the substance represented to be cocaine. b. Upon his arrival in Chicago, Illinois, which is located in the Northern District of Illinois, MGNITEVETI KATQA met with an undercover officer and turned over the three kilograms of the substance that was represented to be cocaine. 0. MONITEVETI KATOA was paid $2000 when he picked up the three kilograms and $43 00 when he delivered the three kilograms. 5. On December 8, 2014, and in furtherance of the conspiracy alleged in Count Nine of the Superseding Indictment, MQNITEVETI KATOA met with Superseding Indictment Page 18 an undercover officer to ?nalize plans for the delivery of three kilograms of a substance that was represented to be cocaine to Wichita, Kansas. a. On December 2014, KATOA told an undercover officer there were only four ?ights departing the Dallas/Ft. Worth International Airport to Wichita, Kansas. MONHEVETE KATOA then contacted JANELLE ESAAQS and placed her on speaker phone. JANELLE ESAACS informed MONITEVEH KATOA that the flight would cost about $500 and told her to book the ?ight and JANELLE 18AACS agreed to do so. MONHEVETE KATOA told the undercover of?cer he would be using JANELLE ESAAQS, MONETONE KATOA, and either his girlfriend or another unknown associate to smuggle the backpack into the airport. The undercover officer then provided MONHEVETE KATOA three kilograms of a substance that was represented to be cocaine and paid him $2000. b. On or about December 8, 2014, JANELLE ESAACS left her work area at the Dallas/Ft. Worth International Airport with a backpack and met with KATOA. c. On December 9, 2014, MONETEVETE KATOA met with an undercover officer in Wichita, Kansas, in the District of Kansas, and delivered the three kilograms of the substance that was represented to Superseding Indictment Page 19 be cocaine MONETEVETI KATQA was paid $43 00 by the undercover officer after the delivery. 6. On February 2, 2015, and in furtherance of the conSpiracy alleged in Count Nine of the Superseding Indictment, an undercover officer met with MTGA and gave MGNETEVETE MTGA a backpack containing three kilograms of a substance that was represented to be cocaine after MONTEVETE KATQA agreed to transport the three kilograms via commercial airline from the Dallas/Ft. Worth International Airport to Wichita, Kansas. a. MGNETEVETI MTQA told the undercover officer he would be using another associate instead of MTGA and was provided a backpack containing three kilograms of a substance that was represented to be cocaine. b. On February 3, 2015, MTQA arrived at a hotel located in the District of Kansas, met ?with an undercover of?cer, and delivered the three kilograms of a substance that was represented to be cocaine. 0. MUNETEVETE KATGA received payment of $43 00 for smuggling the three kilograms of a substance that was represented to be cocaine. 7. On or about May 24, 2015, and in furtherance of the conspiracy alleged in Count Nine of the Superseding Indictment, KATGA and Superseding Indictment Page 20 0N1 bypassed security at the Dallas/Ft. Worth International Airport. After bypassing security, MUNITEVEH KATOA boarded a commercial airline and transported three kilograms of a substance that was - represented to be cocaine to San Francisco, California, Which is located in the Northern District of California. then. delivered the three kilograms to an undercover officer in exchange for payment. All in Violation of21 U.S.C. 846, 84l(a)(l) and Superseding indictment Page 21 Count Ten Conspiracy to Launder Monetary Instruments (Violation of 18 U.S.C. 1956(h)) On or about August 1, 2013, in the Dallas Division of the Northern District of Tekas, and elsewhere, the defendants, JGSE GUERRERQ and RDSAMARIA BLANCD, did knowingly combine, conSpire, confederate, and agree with each other to knowingly conduct and attempt to conduct ?nancial transactions affecting interstate commerce, that is, withdraw $17,040.00 in US. currency from a safe deposit box located at JPMorgan Chase Bank; (2) deposited $17,040.00 in the form of a cheek payable to BLANQD into an account in that name at JP Morgan Chase; involving the proceeds of specified unlawful activity, that is, conspiracy to distribute and possess with intent to distribute a controlled substance, in violation of 846, knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of the specified unlawful activity, and that'while conducting and attempting to conduct such financial transactions, knew that the property involved in the transactions represented the proceeds of some form of unlawful activity. In violation of 18 use. l956(a)(1)(B)(i) and 1956(h). Superseding indictment Page 22 Count Eleven Laundering of Monetary Instruments (Violation of 18 U.S.C. 1956(a)(3)(B)) On or about April 21, 2015, in the Dallas Division of the Northern District of Texas, and elsewhere, the defendant, JGSE AMAYA, with the intent to conceal or disguise the nature, location, source, ownership, or control of property believed to be the proceeds of specified unlawful activity, did knowingly conduct a financial transaction affecting interstate commerce; that is, the deposit of a check: in the amount of $1 1,100.01) made payable to GCJA, LLC into an accoUnt at Capital One Bank in the name of GCJA, LLC, involving property represented by a law enforcement officer to be proceeds of speci?ed unlawfulactivity, that is conspiracy to distribute and possess with intent to distribute controlled substances in violation of 21, U.S.C. 846. Inviolation of 18 U.S.C. l956(a)(3)(B). Superseding Indictment Page 23 Count Twelve Laundering of Monetary Instruments (Violation of 18 U.S.C. 1956(a)(3)(B)) On or about April 30, 2015, in the Dallas Division ofthe Northern District of Texas, and elsewhere, the defendant, JOSE AMAYA, with the intent to conceal or disguise the nature, location, source, ownership, or control of property believed to be the proceeds of speci?ed unlawful activity, did knowingly conduct a financial transaction affecting interstate commerce, that is, the Defendant deposited a check in the amount of $8,900.00 payable to GCJA, LLC, into an account at Capital OneBank in the name of G-CJ A, LLC, involving prOperty represented by a law enforcement officer to be proceeds of specified unlawful activity, that is conspiracy to distribute and possess with intent to distribute controlled substances in violation of 21, U.S.C. 846. In violation of 18 U.S.C. l956(a)(3)(B). Superseding Indictment Page 24 Count Thirteen Laundering of Monetary Instruments (Violation of 18 use. 1956(a)(3)(B)) On or about December 20, 2014, in the Dallas Division ofthe Northern District of Texas, and elsewhere, the defendant, ADREAN MERAMDNTEK with the intent to conceal or disguise the nature, location, source, ownership, or control of property believed to be the proceeds of specified unlawful activity, did knowingly conduct a ?nancial transaction, affecting interstate commerce, that is, the deposit of Bank of America check #1029 for 339,5 00.00 made payable to ADRIAN MERAMDNTEZ into an account at View Point Bank in the name of ADRIAN MKRAMQNTEZ, involving property represented by a law enforcement of?cer to be proceeds of specified unlawful activity, that is conspiracy to distribute and possess with intent to distribute controlled substances in violation of21, U.S.C. 846. in violation of 18 U.S.C. 1956(a)(3)(B). Superseding Indictment Page 25 Count Fourteen Laundering of Monetary Instruments (Violation of 18 U.S.C. On or about February 22, 2013, in the Dallas Division of the Northern District of Texas, the defendant, ERNEST OLEVAREZ, did knowingly conduct and attempt to conduct a ?nancial transaction affecting interstate commerce, that is, the delivery and transfer of 13,000.00 in US. currency to JOSE GUERRERG, involving the proceeds of speci?ed unlawful activity, that is, conspiracy to distribute and possess with intent to distribute a controlled substance, in violation of 21, U.S.C. 846, with the intent to promote the carrying on of the specified unlawful activity, that is, conspiracy to distribute and possess with intent to distribute a controlled substance, in violation of 21, U.S.C. 846, and that while conducting and attempting to conduct the financial transaction, knew that the?property involved in the transaction represented the proceeds of some form of unlawful activity. in violation of 18 use. l956(a)(1)(A)(i)l. Superseding Indictment Page 26 Count Fifteen Conspiracy to Launder Monetary Instruments (Violation of 18 U.S.C. 1956(h)) From Sometime in November 2013 and continuously thereafter through the end of November 2013, in the Dallas Division of the Northern District of Texas, and elsewhere, the defendants, DAVTD DE IDS SANTOS and TSRATEL VASQUEZ, did knowingly combine, conspire, confederate, and agree with each other and others known and unknown to the Grand Jury to knowingly tranSport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument or funds from a place in the United States to a place outside the United States, that is, (1) Transfer $900.00 by wire through MoneyGram on November 23, 2013 to a beneficiary/receiver listed as Media Vasquez Leon in the Republic of Mexico; (2) Transfer $1,800.00 by wire through MoneyGram on November 24, 2013 to a beneficiary/receiver listed as Jaime Rios Marin in the Republic of Mexico; and (3) Transfer $1,800.00 by wire through MoneyGram on November 24, 2013 to a beneficiary/receiver listed as Elena Guizar Baraj as in the Republic of Mexico, with the intent to promote the carrying on of specified unlawful activity, that is, conspiracy to distribute and possess with intent to distribute a controlled substance, in violation of21 U.S.C. 846. Superseding Indictment Page 27 In Violation of 18 U.S.C. 1956(a)(2)(A) and 195601). Superseding Indictment Page 28 Wen Conspiracy to Launder Monetary Instruments (Violation of 18 U.S.C. Beginning on or about January 1, 2011, and continuing through the filing date of the Superseding Indictment, in the Northern District of Texas, and elsewhere, the defendants ESRAEL VASQUEZ and AMBER VASQUEZ did knowingly conspire and agree with each other, and other persons, known and unknown to the Grand Jury, to conduct financial transactions involving proceeds of some form of unlawful activity affecting interstate and foreign commerce, which in fact involved the proceeds from the unlawful distribution of a controlled substance in violation of 21 U.S.C. 841(a) of the Controlled Substances Act: a. with the intent to promote the carrying on of said specified unlawful activity, in violation iof Title 18 United States Code, Section 1956(a)(1)(A)(i) and b. knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of proceeds of said Specified unlawful activity, in violation of Title 18, United States Code, Section 1n violation of Title 18 United States Code, Section 1956(h) and Section (2). Superseding Indictment Page 29 Count Seventeen False Statement in Application for Passport (18 On or about the 16th day of December, 2013, in the Northern District of Texas, the defendant ROBERTO VASQUEZ, JR, willfully and knowingly made a false statement in an application for a passport with intent to induce and secure for the use of another, namely Israel Vasquez, the issuance of a passport under the authority of the United States, contrary to the laws regulating the issuance of such passports and the rules prescribed pursuant to such laws, in that in such application the defendant claimed that he was applying for a pasSport for Roberto Vasquez, Jr. when in truth and in fact he was going to allow the passport to be used by another individual identi?ed as Israel Vasquez, which statement he knew to be false. In Violation of Title 18, United States Code, Section 1542. Superseding Indictment Page 30 Forfeiture Notice (21U.S.C. ?853(a); 18 USC. 982(a)(1)) Upon conviction for any of the offenses alleged in Counts One, Two, Three, Four, Five, Six, Seven, and Eight and pursuant to 21 U.S.C. 853(a), the defendants, DAYTD STLYA GARCTA ARA. DAYTD DE LOS RAY ARA. AMBER MTA TSRAEL JDSE GUERRERD ARA. GALLEGDS. .TR. ARA. AKA. RDRERTD GERARDD JASDN ERTC DCTAYTUS .TAYTER GUERRA, ARA. TONY RUYALCAEA, AKA. LTL EUSERTD MARTTNEZ A RAMTREE. .TR. ARA. EDUARDO RUYALDADA. ARA. KENNETH AKA ALEX NDEL ADRTAN RDLANDD RENTTEZ ARA. SAN JUAN TU AN MANUEL JDSE EUNAKT EALARDLA, ARA. ARA. MAYRA LURE DAYTD JESSE JUAN ZUNTGA, ARA. CDREY PAUL DEMARCUS GEDRGE .NTUTTDLAS MAYES. ARA. ALBERT MARCUS DEMDN HARDY RODNEY KATDA, AKA. JANELLE RDSAMARTA RGBERTD YASQUEZ, ERNEST DLTYAREE shall forfeit to the United States of America any property constituting or derived from Superseding indictment Page 31 proceeds obtained, directly or indirectly, as a result of the respective offense and any property used, or intended to housed, in any?ngiianneror part,?to commit, or to facilitate the commission of, the respective offenses? '1 a - Upon conviction for any of the offenses alleged in Counts, Ten, Eleven, Twelve, Thirteen, Fourteen, Fifteen, and Sixteen and pursuant to 18 U.S.C. 982(a)(1), the defendants, JOSE GUEWRO and RUSAMAREA ELANCQ, JOSE AMAYA, ADRIAN MTRAMONTEZ, ERNEST GLEVAREZ, DAVID DE EQS SANTGS, AMBER VASQUEZ, and ISRAEL VASQUEZ, shall forfeit to the United States of America any property involved in, or traceable to property involved in, the respective offenseJOHN R. PARKER . UNITED STATES AT George Leal\ John ull Hman?j?te? States Attorney Assi ?tant US. Attorney Texas State Bar No. 00794150 Tex 3 Bar No. 00794150 1 Commerce St, Suite 300 1100 Commerce St, Suite 300 llaE?TE? a. :Dallas, Texas 75242 i I f. Ohlff. de1\a Gar a orney .3 Texas Ba .0. 0079 5 -- 1100 Commerce Street, Suite 300 Dallas, Texas 75242 Supersedng Indictment Page 32