Zetas DOJ Indictment Chivis Martinez

Case 5:08-cr-00244 Document 874
Filed in TXSD on 03/04/08 Page 1 of 40
UNITED STATES DTSTRTCT COURT

SOUTHERN DISTRICT OF TEXAS
~nited States District Court
. LAREDO DIVISION
UNITED STATES OF AMERICA

VS.
outhern District of Texas

FiLED
Mt\.~ 0 4 2008
PG
Mihael N. MII~~, Clelk

Laredo OlVi3,gn .
MIGUEL ANGEL TREVINO-MORALES,

A.K.A. "40", A.K.A. "MlKE",
A.K.A. "CUARENTA",
OMAR TREVINO-MORALES,
A.K.A. "42",
IV AN CABALLERO-VELASQUEZ,
A.K.A. "T ALIV AN", A.K.A. "50",
REYMUNDO REYES,
A.K.A. "COMANDANTE MUNDO"

ERNESTO CARREON-VASQUEZ,
A.K.A. "NUNE" ,
ERNESTO ALEJANDRO ESTRADA,
A.K.A. "PEPE",
LUCIO VELEZ-QUINTERO,
A.K.A. "EL VIEJON",
GABRIEL CARDONA-RAMlREZ,
A.K.A. "PELON", A.K.A. "GABY",

JESUS GONZALEZ, 111.,
A.K.A. "JESSE", A.K.A. "JESMAK",

WENCESLAO TOV AR, JR., A.K.A.
"WENCY",
ERIC IV AN MARTINEZ, A.K.A. "47",
RICHARD GUERRERO,
FNU LNU, A.K.A. "THE MARINE",
ROBERTO CAMACHO,
JUAN ANTONIO CARREON-VASQUEZ,

A.K.A. "CAMARON",
FNU LNU, A.K.A. "FLAMA",
FNU LNU, A.K.A. "PALENCIA",
JUAN CARLOS SANCHEZ-GAYTAN,
A.K.A. "CHAP ARRO",
EDUARDO CARREON-IBARRA,
A.K.A. "NEGRO",
RENE GARCIA, A.K.A. "RANN',
L-08--2 44
CRIMINAL NO.
~
.111
ANDRES ALFREDO HERNANDEZ,

JAIME MIGUEL DIAZ DE LEON,
A.K.A. "MICHAEL",
FNU LNU, A.K.A. "CHINO",
.. ARMANDO GARCIA,
A.K.A. "CACHETES",
RAUL JASSO, JR., A.K.A. "RICHARD",
JUAN JOSE ARRIAGA-OVALLE,
A.K.A. "P ANTERA",
JUAN ADOLFO RAMOS,
A.K.A. "CORDLESS",
A.K.A. "KARATE",
JOSE MARTINEZ, A.K.A. "PEPE",
GUST AVO FABIAN CHAP A,
GABRIEL ORTIZ,
PAULA PAOLA PAREDES, AND
AURORA DEL BOSQUE
INDICTMENT
THE GRAND JURY CHARGES THA T:
Introduction
At various times relevant to the Indictment,
l.
The Gulf Cartel, a.k.a. "La Compafiia" [The Company] is a drug-trafficking and money-
laundering organization which imports and distributes marijuana and cocaine from Mexico into the
United States.
2.
The "Zetas" are the enforcement arm of the Gulf Cartel, a.k.a. "La Compafiia" and its
members engage in kidnapping, torture, and murder, as well as drug-trafficking and money
laundering, to fmiher the goals of the organization.
3.
MIGUEL ANGEL TREVINO-MORALES, A.K.A. "40", A.K.A. "MIKE", A.K.A.
"CUARENT A" [FORTY] is aleader and organizer within the Gulf Cartel, a.k.a. "La Compafiia"
and its enforcement arm, the "Zetas".
4.
OMAR TREVINO-MORALES, A.K.A. "42", IV AN CABALLERO-VELASQUEZ,
A.K.A. "TALIVAN", A.K.A. "50", REYMUNDO REYES, A.K.A. "COMANDANTE

MUNDO" are supervisors of cells within the GulfCartel, a.k.a. "La Compafiia" and its enforcement
arm, the "Zetas".
5.
The GulfCartel, a.k.a. "La Compafiia" has been in conflict and competition with the Sinaloa
Cartel, a.k.a. "Los Chapos" for control ofthe Uni ted States-Mexico border in and around Laredo,
Texas, i.e. the "Nuevo Laredo Plaza".
Manner and Means
It was part ofthe conspiracy that the defendants and other members ofthe GulfCaliel, a.k.a.
"La Compafiia" and its enforcement arm, the "Zetas", would impOli cocaine and marijuana into the
United States from Mexico.
It was further pali ofthe conspiracy that the defendants and other members ofthe GulfCartel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would travel in interstate and foreign
commerce to effect the goals of the organization.
It was further part ofthe conspiracy that the defendants and other members ofthe GulfCartel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would secure houses and apartments in
Laredo, Texas to safeguard its controlled substances.
It was further part of the conspiracy that the defendants and other members of the Gulf Cartel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would secure firearms to safeguard its
controlled substances and its members.
It was fUliher part ofthe conspiracy that the defendants and other members ofthe GulfCartel,
3
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would transport firearms in interstate
and foreign commerce to effect the goals of the organization.
It was further part oftheconspiracy that the defendants and other members ofthe GulfCartel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would recruit and hire "sicarios"
[assassins ] to protect its territory and controlled substances from riyal drug-trafficking organizations.
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would obtain transportation for its
"sicarios" .
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would re nt houses and apartments to
house its "sicarios".
It was further part ofthe conspiracy that the defendants and other members of the Gulf Cmiel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would utilize the "sicarios" to kidnap,
torture, and murder rivals and opponents of the organization.
It was fmiher part of the conspiracy that the defendants and other mem bers of the Gulf Cartel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would pay "sicarios" on a weekly basis
with money, controlled substances, and other items of monetary value, to kidnap, torture, and murder
rivals and opponents of the organization.
It was further part of the conspiracy that the defendants and other members of the Gulf Cmiel,
a.k.a. "La Compafiia" and its enforcement arm, the "Zetas", would pay "sicarios" a bonus ofmoney,
controlled substances, and other items of monetary value, after each kidnapping, torture, and murder
of rivals and opponents of the organization.
COUNTONE
(The Drug Conspiracy)
Beginning on or about August 2001, and continuing up to and including the date of this
Indictment, in the Southem District ofTexas and elsewhere, and within the jurisdiction ofthe Court,
Defendants,
A.K.A. "40", A.K.A. "MlKE", A.K.A. "CUARENTA",
OMAR TREVINO-MORALES, A.K.A. "42",
IV AN CABALLERO-VELASQUEZ, A.K.A. "TALIVAN", A.K.A. "50",
REYMUNDO REYES, A.K.A. "COMANDANTE MUNDO",
ERNESTO CARREON-VASQUEZ, A.K.A. "NUNE",
ERNESTO ALEJANDRO ESTRADA, A.K.A. "PEPE",
LUCIO VELEZ-QUINTERO, A.K.A. "EL VIEJON",
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY",
JESUS GONZALEZ, 111., A.K.A. "JESSE", A.K.A. "JESMAK",
WENCESLAO TOVAR, JR., A.K.A. "WENCY",
ERIC IV AN MARTINEZ, A.K.A. "47",
RICHARD GUERRERO,
ROBERTO CAMACHO,
JUAN ANTONIO CARREON-VASQUEZ, A.K.A. "CAMARON",
JUAN CARLOS SANCHEZ-GAYTAN, A.K.A. "CHAPARRO",
EDUARDO CARREON-IBARRA, A.K.A. "NEGRO",
RENE GARCIA, A.K.A. "RANA" ,
JAIME MIGUEL DIAZ DE LEON, A.K.A. "MICHAEL",
ARMANDO GARCIA, A.K.A. "CACHETES",
RAUL JASSO, JR., A.K.A. "RlCHARD",
JUAN JOSE ARRIAGA-OV ALLE, A.K.A. "P ANTERA",
JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE",
GUST A VO F ABIAN CHAP A,
GABRIEL ORTIZ,
PAULA PAOLA PAREDES, AND
AURORA DEL BOSQUE,
did knowingly and intentionaily conspire and agree together and with each other, and with other
persons known and unknown to the Grand Jury, to possess with intent to distribute a controlled
substance. This offense involved:
a)
a quantity of 5 kilo grams or more of a mixture or substance containing a detectable
amount of cocaine, a Schedule II controlled substance, and

b)
a quantity of 1,000 kilograms or more of a mixture or substance containing a
detectable amount of marijuana, a Schedule I controlled substance.

Overt Acts
In furtherance of this conspiracy and to effect and accomplish the objects thereof, one or
more of the defendants and conspirators, both indicted and unindicted, committed, among others,
the following overt acts in the Southern District of Texas and elsewhere:
1.
Begil1l1ing at least in 2001, MIGUEL ANGEL TREVINO-MORALES, A.K.A.
"40", A.K.A. "MlKE", A.K.A. "CUARENTA" ,OMAR TREVINO-MORALES, A.K.A. "42",

and IV AN CABALLERO-VELASQUEZ, A.K.A. "T ALl V AN", A.K.A. "50" and others known
and unknown to the Grand Jury imported marijuana and cocaine from Nuevo Laredo, Tamaulipas,
Mexico into Laredo, Texas.
2.
Beginning at least in 2001, co-conspirators obtained houses in Nuevo Laredo,
Tamaulipas, Mexico and Laredo, Texas to repackage marijuana and cocaine.

3.
Begil1l1ing at least in 2001, co-conspirators transported hundreds of loads of
marijuana and cocaine from Laredo, Texas to Dallas, Texas utilizing automobiles and trucks.
4.
Beginning at least in 2001, co-conspirators transported drug proceeds generated by
the sale of marijuana and cocaine from Dallas, Texas to Nuevo Laredo, Tamaulipas, Mexico.
5.
Beginning at least in 2003, co-conspirators obtained, purchased, and transported
firearms from Dallas, Texas to Nuevo Laredo, Tamaulipas, Mexico.

6.
On or about February 2005, in Dallas, Texas, co-conspirators obtained and possessed
approximately 18 firearms for IV AN VELASQUEZ-CABALLERO, A.K.A. "TALIVAN",

A.K.A. "50".
7.
On or about June 6, 2005, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON",
A.K.A. "GABY", traveled from Laredo, Texas to Nuevo Laredo, Tamaulipas, Mexico to meet with
MIGUEL ANGEL TREVINO-MORALES, A.K.A. "40", A.K.A. "MlKE", A.K.A.
"CUARENTA".
8.
On or about June 6, 2005, MIGUEL ANGEL TREVINO-MORALES, A.K.A.
"40", A.K.A. "MlKE", A.K.A. "CUARENTA" introduced GABRIEL CARDONA-RAMlREZ,

A.K.A. "PELON", A.K.A. "GABY" to ERIC IV AN MARTINEZ, A.K.A. "47".
9.
"40", A.K.A. "MIKE", A.K.A. "CUARENTA" recruited GABRIEL CARDONA-RAMIREZ,

A.K.A. "PELON", A.K.A. "GABY" to kidnap and/or kill Bruno Alberto Juarez-Orozco.
10.
A.K.A. "GABY", WENC.ESLAO TOVAR,JR.,A.K.A. "WENCY", ERIC IV AN MARTINEZ,

A.K.A. "47", RICHARD GUERRERO, and FNU LNU, A.K.A. "THE MARINE", met and
formulated a plan to kidnap Bruno Alberto Juarez-Orozco.
11.
On or about June 8, 2005, WENCESLAO TOVAR, JR., A.K.A. "WENCY" shot
and killed Bruno Alberto Juarez-Orozco.

12.
On or aboutAugust 2005, OMARTREVINO-MORALES,A.K.A. "42" andlVAN

7
CABALLER0- VELASQ UEZ, A.K.A. "T ALl VAN", A.K.A. ''50'' and other co-conspirators
known and unknown to the Grand Jury impOlied from Mexico into Laredo, Texas and re-packaged
approximately 307 pounds of marijuana and approximately 8 pounds of cocaine.
13.
On or about November 2005, a co-conspirator rented
Laredo, Texas for use as a safe house for the "sicarios".

14.
On or about November 2005, a co-conspirator rented

Laredo, Texas for use as a safe house for the "sicarios".
15.
On or about November 24, 2005, GABRIEL CARDONA-RAMlREZ, A.K.A.
"PELON", A.K.A. "GABY", JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A.

"KARATE", RAUL JASSO, JR., A.K.A. "RICHARD" and others known and unknown to the
Grand Jury gathered at the safe house located at
16.
Laredo, Texas.
On or about November 24, 2005, GABRIEL CARDONA-RAMlREZ, A.K.A.
"PELON", A.K.A. "GABY", JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A.

"KARATE", RAUL JASSO, JR., A.K.A. "RICHARD" and others known and unknown to the
Grand Jury possessed a Ruger 9mm caliber pistol and aluger 9mm caliber Tec pistol at the safe
house located at ,
17.
, Laredo, Texas.
OnoraboutNovember24,2005,AURORADELBOSQUEhelpedRAULJASSO,
JR., A.K.A. "RICHARD" escape from Police custody at the safe house located at
~,
18.
Laredo, Texas.
On or about December 2005, aco-conspiratorrented ahouse located at
Street, Laredo, Texas for use as a safe house for the "sicarios".
] 9.
On or about December 6, 2005, a co-conspirator purchased a 1997 Ford Expedition

8
at La1'edo Motors, Inc ..

20.
On or about December 6, 2005, a co-conspi1'ator purchased a 1998 Ford Expedition
at Laredo Motors, Inc ..

21.
On or about December 8, 2005, JESUS GONZALEZ, 111., A.K.A. "JESSE"
transported GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" and anothe1'

co-conspi1'ator (JUVENILE #1) to the Torta-Mex Restaurant located at 2020 Corpus Christi,
La1'edo, Texas in a Ford Excursion.
22.
On 01' about December 8, 2005, JESUS GONZALEZ, 111., A.K.A. "JESSE"
transported GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" and another

co-conspirator (JUVENILE # 1) conducted surveillance at the Torta-Mex Restaurant located at 2020
Corpus Christi, Laredo, Texas in a Ford Excursion.
23.
On or about December 8, 2005, a co-conspirator (JUVENILE #1) shot and killed
Moises Garcia in the parking lot of the Torta-Mex Restaurant located at 2020 Corpus Christi,
La1'edo, Texas.
24.
On or about December 8, 2005, aco-conspirator (JUVENILE #1) shot and wounded
Diana Loera in the parking lot ofthe Torta-Mex Restaurant located at 2020 Corpus Christi, La1'edo,
Texas.
25.
On or about Janua1'Y 8, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE",
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" and another coconspirator (JUVENILE #1) obtained aNissan Sentra to use for the murder of Michael David
Lopez.
26.
On or about January 8, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE",

9
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" and another coconspirator (JUVENILE #1) took the Nissan Sentra to the safe house located at
Street, Laredo, Texas.
27.
On or abotit January 8, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE",
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" and another coconspirator (JUVENILE #1) obtained a .40 caliber-pistol and a 9mm-Galiber pistol to use for the
murder of Michael David Lopez.
28.
On or about January 8, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE",
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" and another coconspirator (JUVENILE # 1) shot and killed N oe Flores during the attempt to murder Michael David
Lopei.
29.
On or about January 2006, LUCIO VELEZ-QUINTERO, A.K.A. "EL VIEJON"
provided a co-conspirator $8,800.00 to purchase two vehicles for the use ofthe "sicarios".
30.
On January 19,2006, LUCIO VELEZ-QUINTERO, A.K.A. "EL VIEJON" and
others known and unknown to the Grand Jury gathered at the safe house located at
. Laredo, Texas.
3l.
On or about January 22, 2006, GUSTAVO FABIAN CHAPA drove the 1998 Ford
Expedition from Mexico into the United States.

32.
On or about January 25, 2006, ERNESTO CARREON-VASQUEZ, A.K.A.
"NUNE" arranged for the importation of approximately 1,000 pounds of marijuana by the river near
Pico Road.
33.
On or about January 26,2006, ERNESTO ALEJANDRO ESTRADA, A.K.A.

10
"PEPE" coordinated the importation of marijuana with FNU LNU, A.K.A. "FLAMA" and FNU
LNU, A.K.A. "PALENCIA".
34.
On or about January 26, 2006 ERNESTO CARREON-VASQUEZ, A.K.A.
"NUNE", ERNESTO ALEJANDRO ESTRADA, A.K.A. "PEPE",
FNU LNU, A.K.A.
"FLAMA", FNU LNU, A.K.A. "PALENCIA", JUAN ANTONIO CARREON-VASQUEZ,

A.K.A. "ELCAMARON", and others unknown to the Grand Jury imported approximately 130
kilograms of marijuana.
35.
On or about J anuary 26,2006 JUAN ANTONIO CARREON-VASQUEZ, A.K.A.
"EL CAMARON" fired at Border Patrol Agents from the river banks in Mexico.
36.
On or about February 5, 2006, GABRIEL CARDONA-RAMlREZ, A.K.A.
"PELON", A.K.A. "GABY" attempted to re-enter the United States using a false name.
37.
On or aboutFebruary 6, 2006, GABRIEL ORTIZandPAULAPAOLAPAREDES
possessed approximately 10 kilograms of cocaine at

38.
On or about February 6, 2006, GABRIEL ORTIZ and PAULA PAOLA PAREDES
possessed a MAK-90 7.62x39mm assault rifle at

39.
Laredo, Texas.
Laredo, Texas.
On or about February 8, 2006, RENE GARCIA, A.K.A. "RANA" and ANDRES
ALFREDO HERNANDEZ traveled to Rio Bravo, Tamaulipas, Mexico to meet with MIGUEL
ANGEL TREVINO-MORALES, A.K.A. "40", A.K.A. "MIKE", A.K.A. "CUARENTA".
40.
OnoraboutFebruary8,2006,MIGUELANGELTREVINO-MORALES,A.K.A.
"40", A.K.A. "MIKE", A.K.A. "CUARENTA"gave RENE GARCIA, A.K.A. "RANA" and
ANDRES ALFREDO HERNANDEZ $5,000.00 Dollars for JAIME MIGUEL DIAZ DE LEON,
A.K.A. "MICHAEL".
11
41.
On or about F ebruary 8, 2006, MI GUEL AN GEL TREVINO-MORALES, A.K.A:
"40", A.K.A. "MIKE", A.K.A. "CUARENTA"gave RENE GARCIA, A.K.A. "RANA" and
ANDRES ALFREDO HERNANDEZ a list oftargets (Chapos) for JAIME MIGUEL DIAZ DE
LEON, A.K.A. "MICHAEL".
42.
On or about February 18, 2006, EDUARDO CARREON-IBARRA, A.K.A.
"NEGRO" and JUVENILE #2, crossed intothe UnitQ States.

43.
On or about February 18, 2006, ANDRES ALFREDO HERNANDEZ housed
EDUARDO CARREON-IBARRA, A.K.A. "NEGRO" and JUVENILE #2.

44.
OnoraboutFebruary 18,2006,REYMUNDOREYES,A.K.A. "COMANDANTE
MUNDO" called from Nuevo Laredo, Tamaulipas, Mexico to coordinate lodging for EDUARDO
CARREON-IBARRA, A.K.A. "NEGRO" and JUVENILE #2.
45.
On or about February 18,2006, RENE GARCIA, A.K.A. "RANA" rented a room
at EI Cortez Motel in Laredo, Texas for EDUARDO CARREON-IBARRA, A.K.A. "NEGRO"

and JUVENILE #2.
46.
On or about February 18, 2006, JAIME MIGUEL DIAZ DE LEON, A.K.A.
"MICHAEL" provided four weapons to EDUARDO CARREON-IBARRA, A.K.A. "NEGRO"

and JUVENILE #2 at EI Cortez Motel in Laredo, Texas.
47.
On or about February 18, 2006, JAIME MIGUEL DIAZ DE LEON, A.K.A.
"MICHAEL" provided an automobile to EDUARDO CARREON-IBARRA, A.K.A. "NEGRO"

and JUVENILE #2 at EI Cortez Motel in Laredo, Texas.
48.
On or about March 17,2006, REYMUNDO REYES, A.K.A. "COMANDANTE
MUNDO" provided $5,500 Dollars for the rental of a house to be used by a group of "sicarios".
12
49.
On March 18,2006, a group of"sicarios" shot and wounded Gerardo Ramos.
50.
On March 29, 2006, ERNESTO ALEJANDRO ESTRADA, A.K.A. "PEPE"
traveled to Laredo, Texas to meet a money courier.

51.
On March 30, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE", GABRIEL
CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY", and RA UL JASSO, JR., A.K.A.

"RICHARD"Jcidnapped JorgeAlfonso Aviles, a.k.a. "Poncho'2andJnez Villarrealh-.-SI.
On March 30, 2006, JESUS GONZALEZ, 111., A.K.A. "JESSE", GABRIEL
CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY", and RAUL JASSO, JR., A.K.A.
"RICHARD" killed Jorge Alfonso Aviles, a.k.a. "Poncho" and Inez Villaneal.
52.
On March 31, 2006, a group of "sicarios" shot and wounded Julio Cesar Resendez.
53.
On March 31, 2006, JOSE MARTINEZ, A.K.A. "PEPE" dropped a cellular
telephone during the shooting of Julio Cesar Resendez.

54.
On April 2, 2006, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A.
"GABY", JUAN JOSE ARRIAGA-OVALLE, A.K.A. "PANTERA", JOSE MARTINEZ,

A.K.A. "PEPE", ARMANDO GARCIA, A.K.A. "CACHETES", RAUL JASSO, JR., A.K.A.
"RICHARD" and JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE"
conducted surveillance to locate Jesus Maria Resendez, a.k.a. "Chuy".
55.
On April 2, 2006, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A.
"GABY", JUAN JOSE ARRIAGA-OVALLE, A.K.A. "PANTERA", JOSE MARTINEZ,

A.K.A. "PEPE", ARMANDO GARCIA, A.K.A. "CACHETES", RAUL JASSO, JR., A.K.A.
"RICHARD" and JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE" shot
and killed Jesus Maria Resendez, a.k.a. "Chuy" and Mariano Resendez.
13
56.
On or about April 8, 2006, REYMUNDO REYES, A.K.A. "COMANDANTE
MUNDO" arranged for FNU LNU, A.K.A. "CHINO" to provide two semi-automatic pistols.
57.
On April 8, 2006, GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A.
"GABY", RAUL JASSO, JR., A.K;k "RICHARD", JUVENILE #3 and JUAN ADOLFO
RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE" conducted surveillance at Cosmos Night
Clubto find and
58.
kiUMar-GG-AntooiG-p'lGl"eg,a.k.a~"Ma~---------------
On April 8, 2006, GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A.
"GABY", RAUL JASSO, JR., A.K.A. "RICHARD", JUVENILE #3 and JUAN ADOLFO
RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE" conducted surveillance at Taco Palenque
Restaurant to find and kill Michael David Lopez.
59.
On April 8,2006, GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A.
"GABY" called MIGUEL ANGEL TREVINO-MORALES, A.K.A, "40", A.K.A. "MlKE",

A.K.A. "CUARENTA" in Mexico to repOli on the attempts to kill Michael David Lopez and Marco
Antonio Flores, a.k.a. "Mackie".
60.
On April 8, 2006,
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON",
A.K.A. "GABY" traveled to Nuevo Laredo, Tamaulipas, Mexico.

61.
On April 9,2006,
A.K.A. "GABY" traveled from Nevo Laredo, Tamaulipas, Mexico to Laredo, Texas.
62.
On April 10, 2006,
A.K.A. "GABY", GUSTAVO FABIAN CHAPA, and ROBERTO CAMACHO sent

approximately 10 ounces of cocaine to Dallas, Texas.
63.
On April 11, 2006, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON",

14
A.K.A. "GABY", RAUL JASSO, JR., A.K.A. "RICHARD", JUVENILE #3, ROBERTO
CAMACHO, and JUAN ADOLFO RAMOS, A.K.A. "CORDLESS", A.K.A. "KARATE" met
at a safe house located at
Laredo, Texas to prepare for the murder of
FNU LNU, a.k.a. "Checo".

64.
On August 11, 2007, co-conspirators, known and unknown to the grand jury,
attempted to ship approximately 166 kilograms of cocaine to Dallas, Texas.

65.
On August 13, 2007, co-conspirators, known and unknown to the grand jury,
attempted to ship...approximately 88 kilograms of cocaine to Dallas, Texas.

66.
On February 8, 2008, co-conspirators, known and unknown to the grand jury,
attempted to transport approximately $870,535.00 Dollars from Dallas, Texas to Nuevo Laredo,
Tamaulipas, Mexico.
All in violation ofTitle 21, United States Code, Sections 846, 841(a)(l), and 841 (b)(l)(A).
COUNTTWO
(The Money Laundering Conspiracy)
Beginning on or about August 2001, and continuing up to and inciuding the date of this
Indictment, in the Southern District ofTexas and elsewhere, and within the jurisdiction ofthe Comi,
Defendants,
MIGUEL ANGEL TREVINO-MORALES',
IV AN CABALLERO-VELASQUEZ, A.K.A. "TALIVAN", A.K.A. "50",
RENE GARCIA, A.K.A. "RANA",
15
JAIME MIGUEL DIAZ DE LEON, A.K.A. "MICHAEL",

JUAN JOSE ARRIAGA-OVALLE, A.K.A. "PANTERA",
did knowingly and intentionally conspire and agree with other persons known and unknown to the
Grand Jury,
a)
to conduct and attempt to conduct financial transactions affecting interstate and

foreign commerce, then well knowing that the financial transactions involved the
proceeds of some form of unlawful activity, that is, the distribution of controlled
substances, which property involved in the financial transactions represented the
proceeds of a specified unlawful activity, that is the distribution of controlled
substances, with (l) the intent to promote the carrying on of specified unlawful
activity; namely the distribution of controlled substances; and (2) 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 said specified
unlawful activity, in violation ofTitle 18, United States Code, Section 1956(a)(l),
and
b)
to transport and transfer, and attempt to transport and transfer monetary instruments
and funds, that is, U. S. Currency, from a place in the Uni ted States, to a place
outside the United States, with the intent to promote the carrying on of a specified
unlawful activity, that is, the sale and distribution of controlled substances, in
violation of Title 18, United States Code, Sections 1956(a)(2)(A),
In violation of Title 18, United States Code, Seetion 1956(h).
16
COUNTTHREE
(Solicitation to Kidnap Juarez-Orozco)
On or about June 6, 2005, in the Southern District of Texas, and elsewhere, and within the
jurisdiction of the COUli, Defendant,
A.K.A. "40A", A.K.A. "MlKE", A.K.A. "CUARENTA",
with the intent that GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY",
and others known and unknown to the Grand Jury, engage in conduct constituting a felony that has
as an element the use, attempted use, and threatened use of physical force against the person of
another in violation ofthe laws ofthe United States, and under circumstances strongly corroborative
of that intent, did solicit, command, induce, and endeavor to persuade GABRIEL CARDONARAMIREZ, A.K.A. "PELON", A.K.A. "GABY", and others known and unknown to the Grand
Jury to engage in such conduct, that is, to conspire to kidnap and to kidnap Bruno Alberto JuarezOrozco in violation ofTitle 18, United States Code Sections 1201(a)(l) and 1201,
In violation of Title 18, United States Code, Section 373.
COUNT FOUR
(Conspiracy to Kidnap Orozco-Juarez)
From on or about lune 6, 2005 and continuing to on or about June 8, 2005, in the Southern
District of Texas, and elsewhere, and within the jurisdiction of the Court, Defendants,
RICHARD GUERRERO,
ERIC IV AN MARTINEZ, A.K.A. "47", and
17
did knowingly and unlawfully conspire and agree together and with each other, and with other
persons known and unknown to the Grand Jury, to kidnap, abduct, seize, confine, and carry away,
Bruno Alberto Orozco-.Tuarez, and willfully transport the victim in interstate and foreign commerce
from the Uni ted States to Mexico, and hold hirn for reward and otherwise.
Overt Acts
In furtherance of this conspiracy and to effect and accomplish the objects thereof, one or
more of the defendants and co-conspirators, committed, among others, the following oveli acts in
the Southern District ofTexas and elsewhere:
1.
On or about June 6, 2005, in Nuevo Laredo, Tamaulipas, Mexico, defendant,
MIGUEL ANGEL TREVINO-MORALES, A.K.A. "40", A.K.A. "MIKE", A.K.A.

"CUARENTA" ordered the kidnapping and/or murder ofBruno Alberto .Tuarez-Orozco in Laredo,
Texas.
2.
On or about .Tune 6, 2005, in Laredo, Texas, the defendant, GABRIEL CARDONA-
RAMIREZ, A.K.A. "PELON", A.K.A. "GABY", supplied a Volkswagen .Tetta automobile to be

used for the kidnapping.
3.
On or about .Tune 6, 2005, in Laredo, Texas, the defendant, GABRIEL CARDONA-
RAMIREZ, A.K.A. "PELON", A.K.A. "GABY", supplied an Oldsmobile Alero automobile 10

be used fr the kidnapping.
4.
On or about .Tune 6, 2005, in Laredo, Texas, the defendant, ERIC IV AN
MARTINEZ, A.K.A. "47", supplied a Dodge Ram truck to be used for the kidnapping.
5.
On oraboutJune 6, 2005, in Laredo, Texas, thedefendant, WENCESLAOTOVAR,
JR., A.K.A. "WENCY", rented a room at the La Hacienda Hotel.

18
6.
On or about June 7, 2005, in Laredo, Texas, the defendants, ERIC IVAN
MARTINEZ, A.K.A. "47", GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A.

"GABY", RICHARD GUERRERO, WENCESLAO TOVAR, JR., FNU LNU, A.K.A. "THE
MARINE", and others known and unknown to the Grand Jury, gathered at Jett Bowl North to plan
the kidnapping of Bruno Alberto Juarez-Orozco.
7.
On or about June 7, 2005, in Laredo, Texas and elsewhere, the defendants,
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. " GABY" and others known and
unknown to the Grand Jury, brought firearms from the Mexico to the United States to be used in the
kidnapping ofBruno Alberto Juarez-Orozco.
8.
On or about June 8, 2005, in Laredo, Texas, the defendants, FNU LNU, A.K.A.
"THE MARINE", RICHARD GUERRERO, and GABRIEL CARDONA-RAMlREZ, A.K.A.

"PELON", A.K.A. "GABY" used police-type visor lights to intercept and stop the victim, Bruno
Alberto Juarez-Orozco.
9.
On or about June 8, 2005, in Laredo, Texas, the defendant, FNU LNU, A.K.A. "THE
MARINE" posed a plain-clothes Police Officer, wearing a sidearm and handcuffs.

10.
On or about June 8, 2005, in Laredo, Texas, the defendant, FNU LNU, A.K.A.
"THE MARINE" attempted to handcuff the victim, Bruno Alberto Juarez-Orozco, in a ploy to
kidnap the said victim.
11.
On or aboutJune 8, 2005, in Laredo, Texas, the defendant, WENCESLAO TOV AR,
JR., A.K.A. "WENCY", shot and killed the victim, Bruno Albe110 Juarez-Orozco.
12.
On or aboutJune 8, 2005, in Laredo, Texas, the defendant, GABRIEL CARDONA-
RAMlREZ, A.K.A. "PELON", A.K.A. "GABY", drove defendants FNU LNU, A.K.A. "THE
19
MARINE" and RICHARD GUERRERO away from the scene ofthe attempted kidnapping and
murder ofBruno Alberto Juarez-Orozco.
13.
On or about June 8, 2005, in Laredo, Texas and elsewhere, ROBERTO CAMACHO
drove defendant WENCESLAO TOV AR, JR., A.K.A. "WENCY" to Nuevo Laredo, Tamaulipas,
Mexico to escape apprehension.
14.
On or about June 8, 2005, in Laredo, Texas, the defendant, FNU LNU, A.K.A. "THE
MARINE" threw a firearm and the police-type visor lights out ofthe automobile onto the street.
In violation ofTitle 18, United States Code, Sections 1201(a)(l) and 120l.
COUNTFIVE
(Accessory After the Fact)
On or about June 8, 2005, in the Southern District ofTexas, and elsewhere, and within the
jurisdiction of the Court, Defendant,
ROBERTO CAMACHO,
knowing that an offense against the Uni ted States has been committed, that is, Conspiracy to Kidnap
as charged in Count Four of the Indictment, did receive, relieve, comfort and assist the offender,
WENCESLAO TOVAR, JR., A.K.A. "WENCY", in order to hinder and prevent the offender's
apprehension, trial and punishment,
COUNT SIX
(Conspiracy to Use ofFirearm in Violent Crime)
From on or about June 6, 2005 and continuing to on or about June 8, 2005, in the Southern
District of Texas, and elsewhere, and within the jurisdiction of the Court, Defendants,
20

GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY",
RlCHARD GUERRERO,
WENCESLAO TOV AR, JR., A.K.A. "WENCY",
ERle IVAN MARTINEZ, A.K.A. "47", and
did knowingly and intentionally conspire and agree together and with each other, and with other
persons known and unknown to the Grand Jury, to:
a)
b)
carry, use, and discharge at least one firearm during and in relation to, and
possess and discharge at least one firearm in furtherance of,
a crime of violence which may be prosecuted in a court ofthe United States, that is, Conspiracy to
Kidnap as alleged in Count Four ofthe Indictment, that is:
a)
b)
a Bushmaster, Model XMI5E2S, .223 caliber, semi-automatic assault rifle, bearing

serial number
which was equipped with a firearm silencer or firearm
muffler; and
a Dan Wesson, .357 caliber revolver, bearing serial number
Overt Acts
In furtherance ofthe conspiracy and to effect and accomplish the objects thereof, one or more
of the defendants and conspirators, both indicted and unindicted, committed, among others, the
following overt acts in the Southem District ofTexas and elsewhere:
1.
A.K.A. "GABY" traveled from Laredo, Texas to Nuevo Laredo, Tamaulipas, Mexico to meet with
MIGUEL ANGEL TREVINO-MORALES, A.K.A. "40A", A.K.A. "MIKE", A.K.A.
"CUARENTA".
2.
"40A", A.K.A. "MIKE",A.K.A. "CUARENTA" showed GABRIEL CARDONA-RAMlREZ,
21
A.K.A. "PELON", A.K.A. "GABY" a rifle that was to be used to carry out the kidnapping and/or
murder ofBruno Alberto Juarez-Orozco.
3.
"40", A.K.A. "MIKE", A.K.A. "CUARENTA" had the rifle and revolver brought from Nuevo
Laredo, Tamaulipas, Mexico to Laredo, Texas.
4.
On or about June 7,2005, GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON",
A.K.A. "GABY", and others known and unknown to the grand jury, picked up the rifle and revolver
that were to be used for the kidnapping and/or murder of Bruno Alberto Juarez-Orozco.
5.
On or about June 7, 2005 GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON",
A.K.A. "GABY", RICHARD GUERRERO, WENCESLAO TOV AR; JR., A.K.A. "WENCY",
ERI C IV AN MARTINEZ, A.K.A. "47", FNU LNU, A.K.A. "THE MARINE", and others known
and unknown to the grand jury, met to plan the kidnapping and/or murder ofBruno Alberto JuarezOrozco.
6.
On or about June 8, 2005, FNU LNU, A.K.A. "THE MARINE" possessed and
carried a .357 caliber revolver to pose as a Police Officer.

7.
On or about June 8, 2005, WENCESLAO TOVAR, JR., A.K.A. "WENCY"
possessed and carried a Bushmaster, .223 caliber assault rifle equipped with a firearm silencer or
firearm muffler.
8.
On or about June 8, 2005, WENCESLAO TOVAR, JR., A.K.A. "WENCY" used
and discharged a Bushmaster, .223 caliber assault rifle equipped with a firearm silencer or firearm
muffler.
9.
On or about June 8, 2005, WENCESLAO TOVAR, JR., A.K.A. "WENCY" shot

22
and killed Bruno Alberto Juarez-Orozco with a Bushmaster, .223 caliber assault rifle equipped with
a firearm silencer or firearm muffler.
In violation ofTitle 18, United States Code, Sections 924( c)(1 )(A)(iii), 924( c)(1 )(B)(ii), and
924(0).
COUNTSEVEN
(Use ofFirearm in Violent Crime)
From on or about June 6, 2005 and continuing to on or about June 8, 2005, in the Southern
District ofTexas, and elsewhere, and within thejurisdiction ofthe Court, Defendants,

A.K.A. "40", A.K.A. "MIKE", A.K.A. "CUARENTA",
RICHARD GUERRERO,
ERIC IV AN MARTINEZ, A.K.A. "47", and
aiding and abetting each other, did knowingly and intentionally possess at least one firearm, that is:
a)
b)
a Bushmaster, Model XMI5E2S, .223 caliber, semi-automatic assault rifle, bearing

serial number
Nhich was equipped with a firearm silencer or firearm
muffler; and
a Dan Wesson, .357 caliber reyQlyer, bearillgs~IiaJnllmber
in furtherance of a crime of violence which may be prosecuted in a court of the United States, that
is, Conspiracy to Kidnap as alleged in Count Four ofthe Indictment,
In violation ofTitle 18, United States Code, Sections 924( c)(1 )(A)(iii), 924( c)(1 )(B)(ii), and
2.
COUNTEIGHT
(Travel Act - Attempted Murder of Jason Fraga)
On or about November 24,2005, in the Southern District ofTexas, and elsewhere, and within
23
the jurisdiction of the COUli, Defendants,

and other co-conspirators, known and unknown to the Grand Jury, aiding and abetting each other,
did travel in foreign commerce, that is, to and from the United States and to and from Mexico, and
use a facility in interstate and foreign commerce, that is, a cellular telephone, with the intent to
cOlnmit a crime of violence to further an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Title 21, United States Code, Sections 841(a)(l) and 846, and
thereafter intentionally and knowingly committed and attempted to commit the crime ofviolence to
further such unlawful activity.
In violation ofTitle 18, Uni ted States Code, Sections 1952(a)(2) and 2.
COUNTNINE
(Use ofFirearm in Drug-Trafficking Crime)
On or about November 24,2005, in the Southern District ofTexas, and elsewhere, and within
the jurisdiction of the Court, Defendants,
MIGUEL TREVINO-MORALES, A.K.A. "40",

A.K.A. "MlKE", A.K.A. "CUARENTA",
did knowingly and intentionally:
a)
carry, use, and discharge a firearm, that is, a 9mm caliber pistol, the model and type
unknown to the Grand Jury, during and in relation to; and
24
b)
possess and discharge a firearm, that is, a 9mm caliber pistol, the model and type
unknown to the Grand Jury, in furtherance of,
a drug trafficking crime which may be prosecuted in a court ofthe United States, that is, Conspiracy
to Possess with lntent to Distribute a Controlled Substance as alleged in Count One of the
lndictment,
In violation of Title 18, United States Code, Sections 924( c)(1 )(A)(iii), and 2.
COUNTTEN
(Travel Act - Murder of Moises Garcia)
On or about December 8, 2005, in the Southern District ofTexas, and elsewhere, and within

commit a crime of violence to further an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Tide 21, United States Code, Sections 841 (a)(1) and 846, and
thereafter intentionally and knowingly committed the crime of violence to further such unlawful
activity. The crime ofviolence resulted in the death ofMoises Garcia.
In violation of Tide 18, United States Code, Seetions 1952(a)(2) and 2.
COUNT ELEVEN
(Use of Juvenile to Commit Violent Crime)
25
On or abou! December 8, 2005, in the Southern District ofTexas, and eisewhere, and within

LUCIO VELEZ-QUINTERO, A.K.A. "EL VIEJON", and
persons who were eighteen (18) years of age and older, aiding and abetting each other, did knowingly
and intentionaUy use a minor, that is, JUVENILE #1, to commit a crime ofviolence for which such
person may be prosecuted in a court of the United States, that is, a violation of Title 18, United
States Code, Section 1952(a)(2) as charged in Count Ten ofthe Indictment,
In violation of Title 18, United States Code, Sections 25 and 2.
COUNT TWELVE

a)
b)
carry, use, and discharge a firearm, that is, a 9mm caliber pistoL the model and type
26
to Possess with lntent to Distribute a Controlled Substance as alleged in Count One of the
Indictment,
In violation of Title 18, Uni ted States Code, Sections 924( c)(1 )(A)(iii), and 2.
COUNT THIRTEEN
(Accessory After the Fact)
the jurisdiction of the Court, Defendant,
AURORA DEL BOSQUE,

knowing that an offense against the Uni ted States has been committed, that is, lnterstate and Foreign
Travel in Aid of Racketeering Enterprise as charged in Count Ten of the Indictment, did receive,
relieve, cOlnfort and assist the offenders, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON",
A.K.A. "GABY", JESUS GONZALEZ, 111., A.K.A. "JESSE', A.K.A. "JESMAK", AND
JUVENILE #1, in order to hinder and prevent the offenders' apprehension, trial and punishment,
COUNT FOURTEEN
(Travel Act - Attempted Murder oflvan Santos)
On or ab out December 9,2005, in the Southern District ofTexas, and elsewhere, and within

and other co-conspirators, known and unknown to the Grand Jury, ai ding and abetting each other,
27
Se a facility in interstate ami foreign commerce, that is, a ceilular telephone, with the intent to
cOlnmit a crime of violence to further an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Title 21, United States Code, Sections 841(a)(1) and 846, and
thereafter intentionally and knowingly attempted to commit the crime of violence to further such
unlawful activity.
In violation of Title 18, United States Code, Sections 1952(a)(2) and 2.
COUNT FIFTEEN
On or about December 9,2005, in the Southern District ofTexas, and elsewhere, and within

persons who were eighteen (18) years of age and older, ai ding and abetting each other, did knowingly
and intentionally use a minor, that is, JUVENILE #1, to commit a crime ofviolence for which such
person may be prosecuted in a court of the United States, that is, a violation of Title 18, Uni ted
States Code, Section 1952(a)(2) as charged in Count Fourteen ofthe Indictment,
In violation ofTitle 18, United States Code, Sections 25 and 2.
COUNT SIXTEEN

28
LUCIO VELEZ-QUINTERO, A.K.A. "EL VIEJON;;,

a)
carry, use, and discharge a firearm, that is, a 9mm caliber pistol, the model and type
b)
a drug trafficking crime which may be prosecuted in a court of the United States, that is, Conspiracy
to Possess with Intent to Distribute a Controlled Substance as alleged in Count One of the
Indictment,
COUNTSEVENTEEN
(Travel Act - Murder ofNoe Flores)
On or about January 8, 2006, in the Southern District of Texas, and elsewhere, and within

did travel in foreign commerce, that is, to and from the Uni ted States and to and from Mexico, and
commit a crime of violence to fUliher an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Title 21, United States Code, Sections 841 (a)(1) and 846, and
29
activity. The crime ofviolence resulted in the death ofNoe Flores.
COUNT EIGHTEEN
the jurisdiction of the COUli, Defendants,
persons who were eighteen (18) years of age and older, ai ding and abetting each other, did knowingly
States Code, Section 1952(a)(2) as charged in Count Seventeen ofthe Indictment,
COUNT NINETEEN
A.K.A. "MIKE", A.K.A. "CUARENTA",
30

a)
b)
carry, use, and discharge at least one firearm, that is, a .40 caliber pistol and a 9mm
caliber pistol, the model and type unknown to the Grand Jury, during and in relation
to; and
possess and discharge at least one firearm, that is, a .40 caliber pistol and a 9mm
caliber pistol, the model and type unknown to the Grand Jury, in furtherance of,
to Possess with Intent to Distribute a Controlled Substance as alleged in Count ne of the
Indictment,
COUNT TWENTY
(Pos session with Intent to Distribute Marijuana)
From on or about January 25, 2006 and continuing to on or about January 26, 2006, in the
Southern District of Texas, and elsewhere, and within the jurisdiction of the Court, Defendants,

FNU LNU, A.K.A. "PALENCIA", and
aiding and abetting each other, did knowingly and intentionally possess with intent to distribute a
controlled substance. This offense involved a quantity of 100 kilograms or more of a mixture or
substance containing a detectable amount of marijuana, a Schedule I controlled substance,
In violation ofTitle 21, Uni ted States Code, Sections 841(a)(1), 841(b)(1)(B) and Title 18,
United States Code, Section 2.
COUNT TWENTY -ONE

31
On or about January 26,2006, in the Southern District ofTexas, and elsewhere, and within

ERNESTO ALEJANDRO ESTRADA, A.K.A. "PEPE" ,
FNU LNU, A.K.A. "PALENCIA", and
aiding and abetting each other, did knowingly and intentionally:
a)
b)
carry, use, and discharge a firearm, that is, the model and type unknown to the Grand
Jury, during and in relation to; and
possess and discharge a firearm, that is, the model and type unknown to the Grand
Jury, in furtherance of,
to Possess with Intent to Distribute a Controlled Substance as alleged in Counts One and Twenty of
the Indictment,
COUNT TWENTY-TWO
(Possession with Intent to Distribute Cocaine)
On or about February 6, 2006, in the Southern District ofTexas, and within the jurisdiction
of the Court, Defendants,

A.K.A. "MlKE", A.K.A. "CUARENTA" ,
GABRIEL ORTIZ, and
PAULA PAOLA PAREDES,
aiding and abetting each other, did knowingly and intentionally possess with intent to distribute a
controlled substance. This offen se involved a quantity of 5 kilograms or more of a mixture or
32
substance containing a detectable amount of cocaine, a Schedule II controlled substance,

In violation of Title 21, United States Code, Sections 841 (a)(1), 841 (b)(1 )(A) and Title 18,
COUNT TWENTY -THREE
(Possession ofFirearm in Drug-Trafficking Crime)
On or about February 6,2006, in the Southern District ofTexas, and within the jurisdiction
GABRIEL ORTIZ, and
PAULA PAOLA PAREDES,
aiding and abetting each other, did knowingly and intentionally possess a firearm, that is, a Norinco,
MAK-90 Sporter, 7.62x39mm, semi-automatic assault rifle, bearing serial nu mb er
111
furtherance of a drug trafficking crime which may be prosecuted in a court ofthe United States, that
is, Possession with Intent to Distribute a Controlled Substance as alleged in Counts One and TwentyTwo of the Indictment,
In violation of Title 18, United States Code, Sections 924( c)(1 )(A)(i), and 2.
COUNT TWENTY -FOUR
(Travel Act - Attempted Murder ofChapos)
On or about February 8, 2006, in the Southern District ofTexas, and elsewhere, and within
the jurisdiction ofthe Court, Defendants,
ERNESTO CARREON-V ASQUEZ, A.K.A. "NUNE" ,
33
JAIME MIGUEL DIAZ DE LEON, A.K.A. "MICHAEL", and

thereafter intentionally and knowingly attempted to cOlnmit the crime of violence to further such
unlawful activity.
COUNT TWENTY-FIVE
On or about February 18,2006, in the Southern District ofTexas, and elsewhere, and within

and intentionally use a minor, that is, JUVENILE #2, to commit a crime of violence for which such
person may be prosecuted in a court of the United States, that is, a violation of Title 18, Uni ted
States Code, Section 1952(a)(2) as charged in Count Twenty-Four of the lndictment,
34

COUNT TWENTY -SIX
(U se of Firearm in Drug-Trafficking Crime)
From on or about February 18,2006 and continuing to on or about February 19,2006, in the
Southern District of Texas, and within the jurisdiction ofthe Court, Defendants,
aiding and abetting each other, did knowingly and intentionally possess at least one firearm, to-wit:
a)
b)
c)
d)
AR-lS, .223 caliber machinegun, with an obliterated serial number;

MAK-90, 7.62X39mm caliber semi-automatic assault rifle, serial number
Glock, .40 caliber pistol, serial number .
and
Smith and Wesson, 9mm caliber pistol, serial number .
in furtherance of a drug trafficking crime which may be prosecuted in a court of the Uni ted States,
that is, Conspiracy to Possess with Intent to Distribute a Controlled Substance as alleged in Count
One of the Indictment,
In violation of Title 18, United States Code, Sections 924( c)(1 )(A)(i), 924( c)(1 )(B)(ii) and
2.
COUNT TWENTY -SEVEN

(Travel Act - Promoting Unlawful Activity)
From on or about March 17, 2006, and continuing to on or about March 18,2006, in the
Southern District of Texas, and elsewhere, and within the jurisdiction of the COUli, Defendants,
35
A.K.A. "l\HKE l l , A.K.A. "CUARENTA;; , and

did use a facility in interstate and foreign commerce, that is, a cellular telephone, with the intent to
promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of an unlawful activity, that is, a business enterprise involving controlled substan1:es in
violation to Title 21, United States Code, Sections 841 (a)(1) and 846, and thereafter intentionally
and knowingly performed an act to promote, manage, establish, and carry on, and to facilitate the
promotion, management, establishment and carrying on of such unlawful activity, that is, provide
Five Thousand Five Hundred Dollars ($5,500.00) in United States Currency for the acquisition of
arental house in Laredo, Texas,
In violation of Title 18, Uni ted States Code, Sections 1952(a)(3) and 2.
COUNT TWENTY -EIGHT
(Travel Act - Attempt on Gerardo Ramos)
On or about March 18,2006, in the Southern District ofTexas, and elsewhere, and within
the jurisdiction ofthe Court, Defendants,
and other co-conspirators, known and unknown tothe-GrandJury, aidingand-abetting each other,
commit a crime of violence to fmiher an unlawful activity, that is, a business enterprise involving
controIIed substances in violation to Title 21, United States Code, Sections 841 (a)(l) and 846, and
36
thereafter intentionally and knowingly committed and attempted to cOlnmit the crime ofviolence to
COUNT TWENTY -NINE

On or about March 18, 2006, in the Southern District of Texas, and within the jurisdiction

did knowingly and intentionally possess and discharge a firearm, that is, 9mm caliber pistol, the
model and type unknown to the Grand Jury, in furtherance of a drug trafficking crime which may
be prosecuted in a court ofthe United States, that is, Conspiracy to Possess with lntent to Distribute
a Controlled Substance as alleged in Count One of the Indictment,
In violation of Title 18, United States Code, Sections 924( c)( 1)(A)(iii) and 2.
COUNT THIRTY
(Travel Act - Promote Unlawful Activity)
On or about March 29, 2006, in the Southern District of Texas, and elsewhere, and within

37
promote, manage, establish, carry on, and faciiitate the promotion, management, establishment, and
canying on of an unlawful activity, that is, a business enterprise involving controlled substances in
violation to Title 21, Uni ted States Code, Sections 841(a)(l) and 846, and thereafter intentionally
promotion, management, establishment and carrying on of such unlawful activity, that is, the receipt
ofU. S. Cunency from a courier,
In violation ofTitle 18, United States Code, Sections 1952(a)(3) and 2.
COUNT THIRTY -ONE
(Travel Act - Murder of Jorge Alfonso Aviles, a.k.a. "Poncho" and Inez Villarreal)
RAUL JASSO, JR., A.K.A. "RICHARD", and
controlled substances in violation to Title 21, United States Code, Sections 841(a)(I) and 846, and
activity. The crime ofviolence resulted in the deaths of Jorge Alfonso Aviles, a.k.a. "Poncho" and
Inez Villaneal.
38
COUNT THIRTY-TWO
(Conspiracy to Kill, Kidnap, or Maim in Foreign Country)
From on or about March 30, 2006, and continuing through on or about March 31, 2006, in
the Southern District of Texas, and elsewhere, and within the jurisdiction of the Court, Defendant,

knowingly and willfully conspired and agreed with other persons, known and unknown to the Grand
Jury, to murder, kidnap, and maim aperson, that is, Jorge Alfonso Aviles, a.k.a. "Poncho", in a place
outside of the Uni ted States, namely, Nuevo Laredo, Tamaulipas, Mexico.
Overt Acts
In furtherance of this conspiracy and to effect and accomplish the objects thereof, the
defendant and one or more of the co-conspirators, known and unknown to the Grand Jury,
committed, among others, the following overt acts in the Southern District ofTexas and elsewhere:
1.
On or about March 30, 2006, in Nuevo Laredo, Tamaulipas, Mexico, defendant
JESUS GONZALEZ, 111., A.K.A. "JESSE", A.K.A. "JESMAK" called GABRIEL

CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" in Laredo, Texas to inform
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY, that Jorge Alfonso
Aviles, a.k.a. "Poncho" was inside a nightclub in Nuevo Laredo, Tamaulipas, Mexico.
2.
On or about March 30, 2006, in Nuevo Laredo, Tamaulipas, Mexico, JESUS
GONZALEZ, 111., A.K.A. "JESSE", A.K.A. "JESMAK", and others co-conspirators known and
unknown to the Grand Jury kidnapped Jorge Alfonso Aviles, a.k.a. "Poncho" and Inez Villarreal
from inside a nightclub in Nuevo Laredo, Tamaulipas, Mexico.
39
j.
RAUL JASSO, JR., A.K.A. "RICHARD" called GABRIEL CARDONA-RAMlREZ, A.K.A.

"PELON", A.K.A. "GABY" in Laredo, Texas to inform GABRIEL CARDONA-RAMIREZ,
A.K.A. "PELON", A.K.A. "GABY", that Jorge Alfonso Aviles, a.k.a. "Poncho" and Inez Villarreal
had been "picked up".
4.
On or about March 30, 2006, in Laredo, Texas, defendanLGABRIEL CARDONA- .
RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" directed RAUL JASSO, JR., A.K.A.
"RICHARD" to take Jorge Alfonso Aviles, a.k.a. "Poncho" and Inez Villarreal to a safe-house in
Nuevo Laredo, Tamaulipas, Mexico.
5.
On or about March 30, 2006, in Laredo, Texas, defendant GABRIEL CARDONA-
RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" traveled to a safe-house in Nuevo Laredo,

Tamaulipas, Mexico.
6.
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" moved Jorge Alfonso

Aviles, a.k.a. "Poncho" and Inez Villarreal to a second safe-house in Nuevo Laredo, Tamaulipas,
Mexico.
7.
GABRIEL CARDONA-RAMlREZ,-A.K.A."EELON..",.-A.K.~GAB.Y" eHt a~.ahbed-JQr.ge

Alfonso Aviles, a.k.a. "Poncho".
8.
On or about March 30, 2006, in Nuevo Laredo, Tamaulipas, Mexico, defendant,
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" collected blood from

Alfonso Aviles, a.k.a. "Poncho" and offered a toast to the "Santa Muerte" (the Death Saint).
40
Case 5:08-cr-00244 Document 874-1
9.
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELON", A.K.A. "GABY" killed Jorge Alfonso

A viles, a.k.a. "Poncho" and Inez Villarreal.
10.
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY" burned Jorge Alfonso

Aviles, a.k.a. "Poncho" and Inez Villarreal.
In violation of Tide 18, United States Code, Section 956 (a)(1) ad (a)(2)(A).
COUNT THIRTY-THREE
(Travel Act - Attempt on Julio Cesar Resendez)

did traveJ in foreign commerce, that is, to and from the Uni ted States and to and from Mexico, and
controlled substances in violation to Tide 21, United States Code, Sections 841 (a)(1) and 846, and
thereafter intentionally and knowingly cOlnmitted and attempted to commit the crime ofviolence to
In violation of Title 18, Uni ted States Code, Sections 1952(a)(2) and 2.
COUNT THIRTY-FOUR
41
On or about March 31, 2006, in the Southern District of Texas, and within the jurisdiction

did knowingly and intentionally possess and discharge at least one firearm, that is, a
a)
b)
c)
7.62X39mm caliber semi-automatic assault rifle, the model and type unknown to the
Grand Jury;
.40 caliber pistol, the model and type unknown to the Grand Jury; and
9mm caliber pistol, the model and type unknown to the Grand Jury,
in furtherance of a drug trafficking crime which may be prosecuted in a court ofthe United States,
that is, Conspiracy to Possess with Intent to Distribute a Controlled Substance as alleged in Count
One of the Indictment,
In violation ofTitle 18, United States Code, Sections 924(c)(1)(A)(iii) and 2.
COUNT THIRTY -FIVE

(Travel Act - Murder of Jesus Maria Resendez and Mariano Resendez)
On or about April 2, 2006, in the Southern District ofTexas, and elsewhere, and within the
jurisdiction ofthe Court, Defendants,

ARMANDO GARCIA, A.K.A. "CHACHETES",
42
commit a crime ofviolence to further an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Title 21, United States Code, Seetions 841(a)(1) and 846, and
The crime of violence resulted in the deaths of Jesus Maria Resendez and Mariano
activity.
Resendez.
In violation ofTitle 18, Uni ted States Code, Seetions 1952(a)(2) and 2.
COUNT THIRTY-SIX
On or about April 2, 2006, in the Southem District ofTexas, and elsewhere, and within the
jurisdiction ofthe Court, Defendants,

ARMANDO GARCIA, A.K.A. "CHACHETES",
ai ding and abetting each other, did knowingly and intentionally possess at least one firearm, that is:
a)
b)
a 7.62X39mm caliber, semi-automatic assault rifle, the model and type unknown to
the Grand Jury; and
a 9mm caliber pistol, the model and type unknown to the Grand Jury,
in furtherance of a crime of violence which may be prosecuted in a court of the United States, that
is, Conspiracy to Possess with lntent to Distribute a Controlled Substance as alleged in Count One
of the Indictment,
In violation ofTitle 18, United States Code, Seetions 924( c)(1 )(A)(iii), 924( c)(1 )(B)(ii), and
43
2.
COUNT THIRTY-SEVEN
(Travel Act - Promoting Unlawful Activity)
On or about April 8, 2006, in the Southem District ofTexas, and elsewhere, and within the
jurisdiction of the Court, Defendants,

REYMUNDO REYES, A.K.A. "COMANDANTE MUNDO", and
did use a facility in interstate and foreign commerce, that is, a cellular telephone, with the intent to
promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of an unlawful activity, that is, a business enterprise involving controlled substances in
violation to Title 21, United States Code, Sections 841 (a)(1) and 846, and thereafter intentionally
promotion, management, establishment and carrying on of such unlawful activity, that is, procure
a Glock, .40 caliber, semi-automatic pistol, and a Berretta 9mm caliber, semi-automatic pistol,
COUNT THIRTY-EIGHT
(Travel Act - Attempt on Marco Antonio Flores, a.k.a. "Mackie")
On or about April 8,2006, in the Southem District ofTexas, and elsewhere, and within the

44

commit a crime of violence to fmiher an unlawful activity, that is, a business enterprise involving
controlled substances in violation to Title 21, United States Code, Sections 841(a)(l) and 846, and
unlawful activity.

COUNT THIRTY -NINE
(Travel Act - Attempt on Michael David Lopez)
On or about April 8, 2006, in the Southern District ofTexas, and elsewhere, and within the

controlled substances in violation to Title 21, United States Code, Sections 841 (a)(!) and 846, and
45
unlawful activity.
COUNT FORTY
On or about April 8,2006, in the Southern District ofTexas, and elsewhere, and within the
ROBERTO CAMACHO, and
States Code, Section 1952(a)(2)
as charged in Counts Thirty-Eight and Thirty-Nine of the
Indictment,
COUNT FORTY-ONE
GABRIEL CARDONA-RAMIREZ, A.K.A. "PELDN", A.K.A. "GABY",
46
a)
carry and use a firearm, the model and type unknown to the Grand Jury, during and
in relation to; and
possess a firearm, the model and type unknown to the Grand Jury, in furtherance of,
b)
a drug trafficking crime which may be prosecuted in a court ofthe Uni ted States, that is, Conspiracy
to Possess with Intent to Distribute a Controlled Substance as alleged in Count One of the
Indictment,
In violation of Title 18, United States Code, Sections 924( c)(1 )(A)(i), and 2.
COUNT FORTY-TWO
On or about April 10,2006, in the Southern District ofTexas, and within the jurisdiction of
the Court, Defendants,
MIGUEL TREVINO-MORALES, A.K.A. "40'';
GUST A VO F ABIAN CHAP A, and
ROBERTO CAMACHO,
did knowingly and intentionally possess with intent to distribute a controlled substance. This offen se
involved a quantity ofless than 500 grams of a mixture or substance containing a detectable amount
of cocaine, a Schedule II controlled substance,
In violation ofTitle 21, Uni ted States Code, Sections 841(a)(1), 841(b)(1) and Title 18,
COUNT FORTY -THREE
(Travel Act - Attempt on FNU LNU, A.K.A. "Checo")
47
On or about April 11 ,2006, in the Southern District ofTexas, and elsewhere, and within the
unlawful activity.
In violation ofTitle 18, United States Code, Sections 1952(a)(2) and 2.
COUNT FORTY-FOUR
persons who were eighteen (18) years ofage and older, aiding and abetting each other, did knowingly
48
States Code, Section 1952(a)(2) as charged in Count Forty-Three ofthe Indictment,
COUNT FORTY-FIVE
(possession with Intent to Distribute Cocaine)
On or about August 11,2007, in the Southem District ofTexas, and within the jurisdiction

did knowingly and intentionally possess with intent to distribute a controlled substance. This offense
involved a quantity of 5 kilograms or more of a mixture 01' substance containing a detectable amount
of cocaine, a Schedule II controlled substance,
In violation ofTitle 21, United States Code, Sections 841 (a)(1), 841 (b)(1 )(A) and Title 18,
COUNT FORTY-SIX
On 01' about August 13,2007, in the Southem District ofTexas, and within the jurisdiction

did knowingly and intentionally possess with intent to distribute a controlled substance. This offense
49
involved a quantity of 5 kilograms or more of a mixture or substance containing a detectable amount

of cocaine, a Schedule II controlIed substance,
In violation ofTitle 21, United States Code, Sections 841(a)(1), 841 (b)(1)(A) and Title 18,
Uni ted States Code, Section 2.
COUNT FORTY-SEVEN
(Money Laundering)
On or about February 8, 2008, in the Southern District ofTexas, and within the jurisdiction

did knowingly and willful1y transport and transfer, and attempt to transport and transfer monetary
instruments and funds, that is, Eight Hundred Seventy Thousand, Five Hundred Thirty-Five Dollars
in U. S. Currency ($870,535.00), from a place in the United States, that is Dallas, Texas, to a place
outside the Uni ted States, that is, Nuevo Laredo, Tamaulipas, Mexico, with the intent to promote the
carrying on of a specified unlawful activity, that is, the sale and distribution of controlled
substances,
In violation of Title 18, United States Code, Sections 1956(a)(2)(A) and Section 2.
NOTICE OF CRIMINAL FORFEITURE

Pursuant to Title 21, United States Code, Section 853, as a result ofthe commission ofthe
violations charged in Counts One, Twenty, Twenty-Two, Forty-Two,F{)rty-Five and Forty-Six of
the Indictment and pursuant to Title 18, United States Code, Section 982, as a result of the
commission of the violation charged in Counts Two and Forty-Seven of the Indictment, notice is
50
given that the defendants,

IV AN CABALLERO-VELASQUEZ, A.K.A. "T ALIV AN", A.K.A. "50",
GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON", A.K.A. "GABY", and
shall forfeit to the United States of America(1) any property constituting, or derived from, any proceeds obtained, directly or indirectly,
as the result ofthe offense charged in Counts One, Twenty, Twenty-Two, Forty-Two, FortyFive and Forty-Six;
(2) any property used or intended to be used, in any manner or pmi, to commit, or to facilitate
the commission ofthe offense charged in Counts One, Twenty, Twenty-Two, Forty-Two,
Forty-Five and Forty-Six; and
(3) all property, real and personal, involved in the offense charged in Counts Two and FortySeven, and all property traceable to such property,
including, but not limited to, the following property:
a money judgment in the amount of ten million dollars ($10,000,000).
In the event that the property which is subject to forfeiture to the United States, as a result
of any act or omission of any ofthe defendants:
(1)
cannot be located upon exercise of due diligence;
(2) has been placed-beyomhhe-jurisdictmlTUf-the-eourt;----------------- .

(3)
has been transferred or sold to, or deposited with a third party;
(4)
has been substantially diminished in value; or
(5)
has been commingled with other property which cannot be divided without difficulty,
it is the intent ofthe United States to seek forfeiture of any other property ofthe defendants up to the
51
value of such property, pursuant to 21 U .S.C. 853(p), and Title 18, United States Code, Section
982(b)(1) incorporating Title 21, United States Code, Section 853(p).
A TRUE BILL:
ORlGINAL SIGNA TURE ON FILE
FOREMAN OF THE GRAND JURY
DONALD J. DeGABRIELLE, JR.

UNITED STA TES ATTORNEY
.TOSE ANGEL MORENO

Assistant United States Attomey
52
USA-74-24b
(Rev 6-1-71)
LAREDO
FILE:
INDICTMENT
DIVISION
L-J}.8-244
CRIMINAL DOCKET
Filed: _ _ _ _ _ _ _ _ _ _ Judge:
ATTORNEYS:
UNITED STATES OF AMERICA
VS.
DONALD J. DeGABRIELLE JR., USA

JOSE ANGEL MORE NO , AUSA
Appt'd Priv ate

A.K.A. "40", A.K.A. "MIKE",
A.K.A. "CUARENTA" ,
OMAR TREVINO-MORALES,
A.K.A. "42",
IVAN CABALLERO-VELASQUEZ,
A.K.A. "TALIVAN" , A.K.A. "50",
REYMUNDO REYES,
A.K.A.
COMANDANTE MUNDO",
ERNESTO CARERON-VASQUEZ,A.K.A. " NUNE " ,
ERNESTO ALEJANDRO-ESTRADA, .
A . K . A . " PEPE" ,
LUCIO VELEZ-QUINTERO,
A.K.A. "EL VIEJON",
GABRIEL CARDONA-RAMIREZ,
A.K.A. PELON", A.K.A. "GABY",
JESUS GONZALEZ, III,
A.K.A. "JESSE" , A.K.A. "JESMAK",
WENCESLADO TOVAR, JR.,
A.K.A.WENCY",
ERIC IVAN MARTINEZ,
A.K.A. "47",
RICHARD GUERRERO,
ROBERTO CAMACHO,
JUAN ANTONIO CARREON-VASQUEZ,
A.K.A. "CAMARON",
FNU LNU, A. K .A. "FLAMA",
JUAN CARLOS SANCHEZ-GAYTAN,
A.K.A. "CHAPARRO",
EDUARDO CARREON - IBARRA, A. K . A. "NEGRO" ,
JAIME MIGUEL DIAZ DE LEON,
A . K . A . "MI CHAEL" ,
FNU LNU, A.K.A. "CHINO" ,
ARMANDO GARCIA, A.K.A. "CACHETES",
JUAN JOSE ARRIAGA-OVALLE,
A.K.A. "PANTERA",
JUAN ADOLFO RAMOS,
A.K.A. "CORDLESS", A.K.A. "KARATE",
JOSE MARTINEZ, A.K.A. "PEPE" ,
GUSTAVO FABIAN CHAPA,
GABRIEL ORTIZ,
PAULA-PAOLA PAREES,
AURORA DEL BOSQUE
111
CHA RG E: __
------'C"-'t~.5:08-cr-00244
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---'w'-'l.=-t=ch=-=i-=n=-=to.;:eo=n=.t=---=t.::;o---,d=i=s:::..t=-=.r=i=b;..::u::..:t::..:e=--a=-.=lqc::u:.:a::.:n=.t:::.;l.:::.
: :.t.,Ly_of
_15
_ _ _ _ _ __
Case
Document
874-1
Filed in TXSD on 03/04/08 Page .14
(TOTAL) _________~l.~n~_~e~x::.:c~e~s.:::.s--'o::.:f~~l~,-'O~O~O~k~i~l~o;..::g~r::..:a=m~s__=o_=f~m~a~r=-=i=h~u=-=a:.:n::.:a=--~a=n~d~c::..:o::..:c~a~i=n~e~_ _ _ _ _ _ _ _ __
COUNTS:) _____________~[~2~1~U~S~C~8~4~6L,~8~4~1~(a~)~(1~)~,~&~8~4~1~(~bL)~(~lL)~(A~)LJ_____________________
_________-'C::..:t~2~:~L~a-=u=n~d:.:e~r'-'i::..:n~g~.:::.o=f~M~o~n::.:e::..:t::..:a~r=_y~=I=n~s;..::t~r~um==e=n=-t:::.;s=--___[~1~8=--U=-S=C~1~9~5~6~(~h~)~J'_________________________
Solicitation to Corrmit a Crime of Violence
[18 SC 373J
3:
Kidnapping [18 USC 1201 (a) (1) & 1201 (c) J
4:
5, 13: Accessory After the Fact [18 USC 3J
carrying or using a firearm during and in Relation to a Drug Crime or a crime of
6:
violence or possessing a firearm in furtherance of a drug trafficking crime or crime
of violence
[18 U.S.C. 924(c)(1)(A)(iii), 924(c)(1)(B)(ii)& 924(0)]
Carrying or using a firearm during and in Relation to a Drug Crime or a crime of
Ct. 7:
of violence
[18 U.S.C. 924(c) (1) (A) (iii), 924(c) (1) (B) (ii)& 18 USC 2J
Ct. 36:
of violence
[18 U.S.C. 924(c) (1) (A) (iii), 924(c) (1) (B) (ii)& 18 USC 2]
cts. 8,14, 24, 28, 33, 38, 39, 43:
Interstate and foreign travel or transportation in aid of racketerring enterprises [18
USC 1952 (a) (2) & 2]
Ct s . 10, 17, 31, 35:
Interstate and foreign travel or transportation in aid of racketerring enterprises [18
USC 1952 (a) (2) & 2]
Cts 9, 16, 29:
of violence
[18 U.S.C. 924(c) (1) (A) (iii),& 2]
ct s 12, 19, 34:
of violence
[18 U.S.C. 924(c) (1) (A) (iii),& 2]
Cts 21:
of violence
[18 U.S.C. 924 (c) (1) (A) (iii), & 2]
Ct s 11, 15, 25, 40, 44:
Use of Minors in a crime of violence [18 USC 25 & 2]
CL 18:
Use of Minors in a crime of violence [18 USC 25 & 2J
Ct. 20:
Possess with intent to distribute Marihuana in excess of 100 Kilos of Marihuana
[21 USC 841 (a) (1), 841 (b) (1) (B) & 18 usc 2]
Cts 22, 45, 46:
Possess with intent to distribute Marihuana in excess of 1000 Kilos of Marihuana
[21 USC 841 (a) (1), 841 (b) (1) (A) & 18 usc 2]
Cts. 23,41: Carrying or using a firearm during and in Relation to a Drug Crime or a crime of
of violence [18 USC 924 (c) (1) (A) (i) & 2]
Ct. 26
of violence [18 USC 924 (c) (1) (A) (i), 924 (c) (1) (B) (ii) & 2]
Ct. 27, 30, 37:
Interstate and foreign travel or transportation in aid of racketerring enterprises
[18 USC 1952 (a) (3) & 2]
Ct.32:
Conspiracy to kill, kidnap, maim, or injure persons or damage property in a foreign
country [18 USC 956 (a) (1), (a) (2) (A) & 2]
Ct 42:
Possess with intent to distribute Cocaine in excess of 50 Kilos
[21 USC 841 (a) (1), 841 (b) (1) (C) & 18 usc 2]
Money Laundering [18 USC 1956 (a) (2) (A) & 2]
Ct. 47:
Ct. 48:
Criminal Forfeiture [21 USC 853]
(48)
r"+'--'- .
Ct.
Cts
CL
PENALTY:
Ct 1:
Ct. 2:
10 Yrs. To Life And/or $4 Million, $100 Spec Assessment

4 Yrs Term of Supervised Release
Maximum of 20 Yrs and a Fine of Not More than $500,000 or Twice the Value
Of the Property Involved in the Transaction, Whichever Is Greater
Ct 3:
Y2
Ct 4:
Death Then a Maximum of 20 Years

Any Term of Years or for Life and If
Punished by Death or Life Imprisonment
the Sentence and ~ the Fine, but If Underlying Offense Is Punishable by Life
the Death of Any Person Results,
or
Shall Be
Cts 5, 13:
~ the Sentence and ~ the Fine, but If Underlying Offense Is Punishable by Life
Death Then a Maximum of 15 Years
or
Ct. 6:
Life Sentence, $100 Spec Assessment
Ct. 7:
30 Yrs to Life, $100 Spec Assessment

1mposition of a Term of Supervised Release 1s Governed by the Provisions
of 5d1.1 1.
Imposition of a Term of Supervised Release Is Governed by the Provisions of 5dl.l
Ct. 36:
10 Yrs to Life, $100 Spec Assessment

Imposition of a Term of Supervised Release Is Governed by the Provisions of5d1.1
cts 8,14, 24, 28, 33, 38, 39, 43;
a Maximum of 20 Years for a Crime of Violence, but If Death Results, a Maximum of Life
Imposition of a Term of Supervised Release Is Governed by the Provisions of 5d1.1
cts. 10, 17, 31, 35:
Maximum of 20 Years, Not More than $250,000, $100 Spec Assessment
4 Yrs Min, 5 Yrs Max Term of Supervised Release
Cts. 9, 16, 29:
10 Yrs to Life And/or $4 Million, $100 Spec Assessment
Imposition of a Term of Supervised Release Is Governed by the Provisions of5d1.1
Cts 12, 19, 34:
Life Term And/or $4 Million, $100 Spec Assessment
5 Yrs Max Term of Supervised Released
Ct 21:
5 to Life. And/or $4 Million, $100 Spec Assessment
Cts 11, 15, 25, 40, 44:
40 Yrs. And/or $4 Million, $100 Spec Assessment Ea Ct
5 Yrs Term of Supervised Release for Each Ct.
Ct. 18:
Life Term And/or $4 Million, $100 Spec Assessment
Ct. 20:
5 to 40 Yrs. And/or $2 Million, $100 Spec Assessment for Ea Ct.
4 Yrs Min, 5 Yrs Max Term of Supervised Release for Each Ct.
Ct s 22, 45, 46:
10 Yrs to Life And/or $4 Million, $100 Spec Assessment
Cts. 23, 41:
5 to Life. And/or $4 Million, $100 Spec Assessment
30 Yrs. To Life And/or $4 Million, $100 Spec Assessment Ea Ct
Ct. 26:
5 Yrs Term of Supervised Release for Each Ct.
Ct s. 27, 30, 37:
5 Yrs. And/or $250,000.00, $100 Spec Assessment for Ea Ct
2 Yrs Min, 3 Yrs Max Term of Supervised Release for Each Ct.
Li.fe Term And/or $4 Million, $100 Spec Assessment
Ct. 32:
o to 20 Yrs. And/or $2 Million, $100 Spec Assessment for Ea Ct
Ct. 42:
3 Yrs Max Term of Supervised Release for Each Ct.
10 Yrs. and/or $2 Million, $100 Spec Assessment
Ct. 47:
In Jail:
NAME & ADDRESS

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Zetas DOJ Indictment Chivis Martinez

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Case 5:08-cr-00244 Document 874

Filed in TXSD on 03/04/08 Page 1 of 40

UNITED STATES DTSTRTCT COURT

~nited States District Court

UNITED STATES OF AMERICA

outhern District of Texas

Mihael N. MII~~, Clelk

MIGUEL ANGEL TREVINO-MORALES,

A.K.A. "T ALIV AN", A.K.A. "50",

A.K.A. "COMANDANTE MUNDO"

ERNESTO ALEJANDRO ESTRADA,

A.K.A. "EL VIEJON",

A.K.A. "PELON", A.K.A. "GABY",

A.K.A. "JESSE", A.K.A. "JESMAK",

ERIC IV AN MARTINEZ, A.K.A. "47",

FNU LNU, A.K.A. "THE MARINE",

JUAN ANTONIO CARREON-VASQUEZ,

FNU LNU, A.K.A. "FLAMA",

FNU LNU, A.K.A. "PALENCIA",

JUAN CARLOS SANCHEZ-GAYTAN,

A.K.A. "CHAP ARRO",

Case 5:08-cr-00244 Document 874

ANDRES ALFREDO HERNANDEZ,

Filed in TXSD on 03/04/08 Page 2 of 40

MIGUEL ANGEL TREVINO-MORALES, A.K.A. "40", A.K.A. "MIKE", A.K.A.

Case 5:08-cr-00244 Document 874

Filed in TXSD on 03/04/08 Page 3 of 40

and its enforcement arm, the "Zetas".

OMAR TREVINO-MORALES, A.K.A. "42", IV AN CABALLERO-VELASQUEZ,

A.K.A. "TALIVAN", A.K.A. "50", REYMUNDO REYES, A.K.A. "COMANDANTE

Case 5:08-cr-00244 Document 874

Filed in TXSD on 03/04/08 Page 4 of 40

Case 5:08-cr-00244 Document 874

Filed in TXSD on 03/04/08 Page 5 of 40

Case 5:08-cr-00244 Document 874

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a quantity of 5 kilo grams or more of a mixture or substance containing a detectable

amount of cocaine, a Schedule II controlled substance, and

a quantity of 1,000 kilograms or more of a mixture or substance containing a

detectable amount of marijuana, a Schedule I controlled substance.

Begil1l1ing at least in 2001, MIGUEL ANGEL TREVINO-MORALES, A.K.A.

"40", A.K.A. "MlKE", A.K.A. "CUARENTA" ,OMAR TREVINO-MORALES, A.K.A. "42",

Beginning at least in 2001, co-conspirators obtained houses in Nuevo Laredo,

Tamaulipas, Mexico and Laredo, Texas to repackage marijuana and cocaine.

Begil1l1ing at least in 2001, co-conspirators transported hundreds of loads of

Beginning at least in 2001, co-conspirators transported drug proceeds generated by

Case 5:08-cr-00244 Document 874

Filed in TXSD on 03/04/08 Page 7 of 40

Beginning at least in 2003, co-conspirators obtained, purchased, and transported

firearms from Dallas, Texas to Nuevo Laredo, Tamaulipas, Mexico.

On or about February 2005, in Dallas, Texas, co-conspirators obtained and possessed

approximately 18 firearms for IV AN VELASQUEZ-CABALLERO, A.K.A. "TALIVAN",

On or about June 6, 2005, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON",

On or about June 6, 2005, MIGUEL ANGEL TREVINO-MORALES, A.K.A.

"40", A.K.A. "MlKE", A.K.A. "CUARENTA" introduced GABRIEL CARDONA-RAMlREZ,

On or about June 6, 2005, MIGUEL ANGEL TREVINO-MORALES, A.K.A.

"40", A.K.A. "MIKE", A.K.A. "CUARENTA" recruited GABRIEL CARDONA-RAMIREZ,

On or about June 8, 2005, GABRIEL CARDONA-RAMlREZ, A.K.A. "PELON",

A.K.A. "GABY", WENC.ESLAO TOVAR,JR.,A.K.A. "WENCY", ERIC IV AN MARTINEZ,

On or about June 8, 2005, WENCESLAO TOVAR, JR., A.K.A. "WENCY" shot