Mono Munoz

Case 5:15-cr-00024-DAE Document 3 Filed 01/07/15 Page 1 of 4
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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
UNITED STATES OF AMERICA,

k
Plaintiff,
INDICTMENT
V.
JUAN MANUEL MUNOZ-LUEVANO aka "EL

INGENIERO" aka "EL INGE" aka "MONO" aka
"THE ENGINEER" aka "MANUELITO"
Defendant.
DAE
CT 1: 21:846 & 841(a)(1)Conspiracy to Possess a Controlled

Substance with Intent to Distribute
(Cocaine);
CT 2: 21:952 & 960(a)(1)Conspiracy to Import with Intent to
Distribute a Controlled Substance
(Cocaine);
CT 3: 21: 95 9(a)- Unlawful
Distribution of a Controlled
Substance Extra-territorial;
CT 4: 21:841(a)(1) and 18:2Possession with Intent to Distribute
(Cocaine); Aiding & Abetting
CT 5: 18:924(c)(1) & (o)Conspiracy to Possess Firearms in
Furtherance of Drug Trafficking;
CT:6 18:1956- Laundering of
Monetary Instruments
THE GRAND JURY CHARGES:

COUNT ONE
[21 U.S.C. 841, 846]
Beginning on or about January
1, 1999
and continuing through and including the date of
this indictment, in the Western District of Texas, the Northern District of Texas, the Republic of
Mexico, and elsewhere, the Defendant,
JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

aka "EL INGE" aka "MONO" aka "THE ENGINEER" aka "MANUELITO"
did combine, conspire, confederate and agree together and with each other and others known and
unknown to the Grand Jury to possess with intent to distribute and distribute a controlled
substance, which offense involved
kilograms or more of a mixture or substance containing a
detectable amount of cocaine, a Schedule II Controlled Substance, with intent to distribute same,
contrary to Title 21, United States Code, Sections 846, 841(a)(l) and 841(b)(1)(A)(ii).
COUNT TWO
(21 U.S.C. 952(a), 960(a)(1), 960(b)(1)(G) & 963)
That beginning on or about January
1,
1999 and continuing through and including the
date of this indictment, in the Western District of Texas, Defendant,
JIJAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed
together, and with each other, and with others to the Grand Jury unknown, to commit offenses
against the United States, in violation of Title 21, United States Code, Section 963, that is to say,
they conspired to import a controlled substance, which offense involved five kilograms or more
of a mixture or substance containing a detectable amount of cocaine, a Schedule II Controlled

Substance, into the United States from Mexico, contrary to Title 21, United States Code,
Sections 952(a), 960(a)(l) and 960(b)(1)(B).
COUNT THREE
(21 U.S.C. 959(a), 963, 960(a)(3) and (b)(1)(G))
1,
1999, and continuing through and including the date of
this indictment, in the Republic of Mexico and elsewhere, Defendant,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and

agreed
together, and with each other, and with others to the Grand Jury unknown, to commit
offenses
against the United States, in violation of Title 21, United States Code, Section
they conspired to distribute
963,
that is to say,
kilograms or more of a mixture or substance containing a
detectable amount of cocaine, a Schedule II Controlled Substance, intending and knowing

that
said controlled substance would be unlawfully imported into the United States,
in violation of
Title 21, United States Code, Section
959.
COUNT FOUR
(21 U.S.C.
That on or about December
5,
841(a)(1) and (b); 18 U.S.C.
2)
2011, in the Western District of Texas, Defendant,

knowingly and intentionally possessed with intent to distribute a controlled substance, and
aided
and abetted the knowing and intentional possession with intent to distribute a
controlled
substance, which offense involved five 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 841(a)(1) and 841(b)(1)(A)(ii).
COUNT FIVE
(18 U.S.C. 924(c)(1) and (o))
1,
2007, and continuing through and including the date of
this indictment, in the Western District of Texas and elsewhere, the Defendant,

knowingly combined, conspired, confederated, and agreed with each other and others known
and
unknown to the Grand Jury to commit offenses against the United States, that is,
the
DEFENDANTS conspired to possess firearms in furtherance of the drug trafficking crimes

3
charged in Counts One, Two, Three and Four of this Indictment, re-alleged herein, contrary to
Title 18, United States Code, Sections 924(c)(1) and (o).
COUNT SIX
(18 U.S.C. 1956 (a)(l)(A)(i) & (ii) and 1956(h))
Beginning on or about January 1, 1999, and continuing through and including the date of
this indictment, in the Western District of Texas and elsewhere, the Defendant,

did knowingly conspire with others known and unknown to the Grand Jury to conduct and to
attempt to conduct financial transactions, affecting interstate and foreign commerce, which
involved the proceeds of a specified unlawful activity, to-wit: drug trafficking violations of Title
21, United States Code, Sections 846 and 841(a)(1), with the intent to promote the carrying on of
the specified unlawful activity knowing that the property involved in the financial transaction
represented the proceeds of some form of unlawful activity.
A TRUE BILL.
ROBERT PITMAN
UNITES STATES ATTORNEY
RUSSELL D. LEACHMAN
Assistant United States Attorney

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Case 5:15-cr-00024-DAE Document 3 Filed 01/07/15 Page 1 of 4

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA,

JUAN MANUEL MUNOZ-LUEVANO aka "EL

CT 1: 21:846 & 841(a)(1)Conspiracy to Possess a Controlled

THE GRAND JURY CHARGES:

Beginning on or about January

and continuing through and including the date of

Mexico, and elsewhere, the Defendant,

JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

Case 5:15-cr-00024-DAE Document 3 Filed 01/07/15 Page 2 of 4

kilograms or more of a mixture or substance containing a

1999 and continuing through and including the

date of this indictment, in the Western District of Texas, Defendant,

JIJAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

of a mixture or substance containing a detectable amount of cocaine, a Schedule II Controlled

Sections 952(a), 960(a)(l) and 960(b)(1)(B).

Beginning on or about January

1999, and continuing through and including the date of

this indictment, in the Republic of Mexico and elsewhere, Defendant,

JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

Case 5:15-cr-00024-DAE Document 3 Filed 01/07/15 Page 3 of 4

knowingly, intentionally, and unlawfully conspired, combined, confederated, and

kilograms or more of a mixture or substance containing a

detectable amount of cocaine, a Schedule II Controlled Substance, intending and knowing

That on or about December

841(a)(1) and (b); 18 U.S.C.

2011, in the Western District of Texas, Defendant,

JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

detectable amount of cocaine, a Schedule II Controlled Substance, in violation of Title

United States Code, Sections 841(a)(1) and 841(b)(1)(A)(ii).

2007, and continuing through and including the date of

JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

DEFENDANTS conspired to possess firearms in furtherance of the drug trafficking crimes

Case 5:15-cr-00024-DAE Document 3 Filed 01/07/15 Page 4 of 4

JUAN MANUEL MUNOZ-LUEVANO aka "EL INGENIERO"

represented the proceeds of some form of unlawful activity.

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