Académique Documents
Professionnel Documents
Culture Documents
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5
6
10
Plaintiff,
11
12
13
14
15
16
17
18
- 1sU:persediiig)
v.
ISMAEL ZAMBADA-GARCIA (1)
aka "El Mayo,"
aka "Doc, "
,ISMAEL ZAMBADA-IMPERIAL (2),
aka "Mayito Gordo,"
aka "Good Guy,"
ISMAEL ZAMBADA-SICAIROS (3)
aka "Mayito Flaco,"
aka "Caballero,"
IVAN ARCHIVALDO GUZMAN- SALAZAR ( 4) ,
aka "Luis,"
aka "Chapito,"
I
Defendants.
19
20
~--------------------------------------~
21
22
23
Introductory Allegations
At all times relevant to this
1.
24
criminal
organization known
25
Cartel
26
Sinaloa, Mexico.
is
transnational
27
2.
Under
28
aka "El
Mayo,"
the
ALB:nlv:San Diego
7/23/14
aka
as
drug
leadership
"Doc,"
the
Indictment,
"Sinaloa
trafficking
of
the
defendant
Sinaloa
there existed a
Cartel."
The
organization
ISMAEL
Cartel
Sinaloa
based
in
ZAMBADA-GARCIA,
operates
as
an
affiliation
of
drug
traffickers
and
money
launderers
located
in
2 multiple countries throughout the world who coordinate and pool their
3
b.
transport
drugs
through
Mexico
and
into
the
United
c.
States;
transport drugs
States; and
10
d.
11
trafficking.
12
3.
collect,
launder,
and
transfer
the
proceeds
of
drug
defendant ISMAEL
13
ZAMBADA-GARCIA,
14
of
15
activities
16
South
17
18
19
Mexico.
20
and members and associates of the Sinaloa Cartel under him coordinated
21
22
the
23
Mexico.
24
and members and associates of the Sinaloa Cartel under him coordinated
25
their
26
27
well
28
quantities of marijuana,
American
import
countries,
including
of
Colombia,
transportation
and
storage
of
these
drug
as
trafficking
multi-kilogram
activities
quantities
cocaine
to
Ecuador,
cocaine
Central
and
Venezuela,
to Mexico, as well
aka "Doc,"
shipments
smuggle
of
from
large
1 "
within
aka "Doc
quantities
methamphetamine
and
1 "
of
ton-
3
4
a.
Defendant
one
10
from Central and South American countries to Mexico, and caused multi-
11
kilogram quantities of
12
13
throughout
14
15
transferred from
16
States.
aka "Doc,"
the
Cartel.
United
of
Sinaloa
cocaine,
leaders
Mayo,"
the
primary
"El
b.
the
aka
aka "Doc,"
the
of
ZAMBADA-GARCIA,
17
was
ISMAEL
Defendant
ISMAEL
United States
t~en
ZAMBADA-GARCIA,
to be
laundered and
into and
aka
for
the
"Mayito Gordo,"
18
19
20
transported from Mexico to the United States border, and then into"and
21
throughout
22
ZAMBADA-IMPERIAL
23
customers in the United States and laundered and transferred from the
24
United States to Mexico and elsewhere for the benefit of the Sinaloa
25
26
the
c.
United
further
States
for
distribution.
caused drug
proceeds
to
caused multi-
Defendant
be
aka
ISMAEL
collected
from
"Mayito Flaco,"
27
28
defendant ISMAEL
Mexico.
States
distribution.
proceeds
laundered
and
transferred
elsewhere
for
the
associates.
border,
to
then
into
and
throughout
the
United States
for
d.
and
"Chapito,"
collected
from
the
from
benefit
Defendant
customers
of
in
United
United
States
Sinaloa
the
the
to
Cartel's
Mexico
and
members
and
aka
11
12
States
13
distribution.
14
15
laundered
and
transferred
16
elsewhere
for
the
17
associates.
and
throughout
the
and
United States
ton
for
from
benefit
of
the
United
the
States
Sinaloa
to
Cartel's
Mexico
and
members
and
18
19
then into
cocaine
"Luis,"
aka
and
of
and
10
border,
States
5.
20
ZAMBADA-GARCIA,
21
22
Flaco,"
23
aka "Chapito," and members and associates of the Sinaloa Cartel under
24
25
couriers
26
activities to:
27
28
aka
"Caballero,"
affiliated
a.
"El
Mayo,"
"Good Guy,"
IVAN
with
aka
"Doc,"
ZAMBADA-IMPERIAL,
ISMAEL ZAMBADA-SICAIROS,
ARCHIVALDO
the
ISMAEL
resources
Sinaloa
GUZMAN-SALAZAR,
aka "Mayito
aka
"Luis,"
to
coordinate
of
their
methamphetamine and
other drugs and drug precursor chemicals to be imported from Asia and
Central
2 Venezuela,
3
Mexico,
aircraft,
Peru,
using
Panama,
various
submarines
5 vessels,
container
Rica,
Costa
means,
and
Colombia,
Honduras,
and
including
cargo
submersible
other
ships,
including
supply
vessels,
7 private
and
commercial
interstate
and
Guatemala,
aircraft,
and
to
private
semi-submersible
go-fast
Ecuador,
boats,
fishing
foreign
carriers.
After
the
b.
to
be
transported
13
States border where the drugs were then stored in multiple warehouses,
14
stash
houses,
from
and
various
safe
houses
locations
located
in Mexico
in
the
to
areas
the
of
United
Tijuana,
c.
17 Mexico
border
through
19
the
drugs
21
affiliated
22
houses,
23
means,
District
elsewhere
d.
multiple
Southern
18
20
using
the
including
of
California
automobiles,
and
tractor
Sinaloa
Cartel,
and
stored
at
multiple
stash
24
e.
Cause
cocaine,
25
transported
throughout
26
including
27
28
II
automobiles,
the
methamphetamine
United
tractor
States,
trailers,
and
using
trucks,
marijuana
various
and
to
be
means,
private
and
f.
g.
counted,
packaged,
7 Mexico,
and
and
transferred
elsewhere,
using
and
multiple
laundered
means,
from
the
including
United
bulk
cash
transfers,
alternative
use
11
systems
in
which
12
13
14
items,
other
including
luxury
goods-based
vehicles
17
cellular
18
Use
trafficking
satellite
coded
activities,
telephones,
language
including
computers,
instant
to misrepresent,
20
21
hidden,
22
concealed and
j.
23
and
order
telephones,
drug
high-end
means,
16
19
coordinate
to
traditional
transfer money
the
to
or
to
without
h.
wires
used
10
15
of
credit-based systems
drug
24
their
distribution
25
26
and threats
27
members of
28
of violence;
activities,
including:
obtaining
guns
and
law enforcement,
and members of
Count 1
1.
of
this
Indictment
2.
are
realleged
and
incorporated by
reference
as
California,
Mayo,"
and elsewhere,
aka
"Doc,
11
Controlled
did
10
of
11
12
States Code,
13 'sections 952,
defendant
knowingly
Substances
Sections
2014,
ISMAEL
and
Act
ZAMBADA-GARCIA,
intentionally
(Title
21,
aka
engage
United
"El
in
States
Code,
as alleged in Count 2,
as alleged in Count 3,
and
which violations
14
were part of a
15
16
17
and
18
series
19
resources.
20
other
position
of
3.
of
violations
management,
defendant
and
from
obtained
which
such
substantia~
continuing
income
and
"Doc,"
21
aka
22
leader of
23
24
Substance,
25
26
27
28
Schedule
was
the
for
II
principal administrator,
criminal
enterprise,
which
Controlled Substance,
organizer,
11
involved
importation
into
the
supervisor and
a
conspiracy
into
United
to
the United
States
from
Count 2
1'
"Doc,"
Mayo,"
ISMAEL
aka "Good
aka "Caballero,"
aka "Chapito,"
other,
ZAMBADA-SICAIROS,
ISMAEL
Guy,"
and
did
ZAMBADA-IMPERIAL,
IVAN
ARCHIVALDO
knowingly
and
aka
aka
"Mayito
"Mayito
GUZMAN-SALAZAR,
intentionally
aka
conspire
Gordo,"
Flaco,"
"Luis,"
with
each
and with other persons known and unknown to' the grand jury,
amount
of
methamphetamine
10
detectable
11
cocaine,
12
and
13
purpose
14
violation of Title 21, United States Code, Sections 959, 960, and 963.
both Schedule II
more
of
of
marijuana;
unlawful
and
5 kilograms
and
Controlled Substances;
and
Schedule
Substance;
importation
15
Controlled
into
the
United
1000
more
to
of
kilograms
States;
for
the
all
in
Count 3
Beginning no later than in or about May 2005 and continuing up to
16
including
17
and
18
California,
19
Mayo,
2 o aka "Good
25,
2014,
and elsewhere,
"Doc,"
aka
11
July
21
aka "Caballero,"
and
22
aka "Chapito,"
23
other,
24
import
25
detectable
26
cocaine,
27
did
defendants
ISMAEL
ISMAEL
Guy,"
IVAN
within
the
Southern
ISMAEL ZAMBADA-GARCIA,
ZAMBADA-IMPERIAL,
ZAMBADA-SICAIROS,
ARCHIVALDO
knowingly
and
District
aka
aka
"Mayito
"Mayito
GUZMAN-SALAZAR,
intentionally
aka
conspire
of
aka
"El
Gordo,"
Flaco,"
"Luis,
with
each
and with other persons known and unknown to the grand jury,
500
grams
and
amount
of
both
more
of
mixture
methamphetamine
Schedule II
a
and
and
5
28
to
substance
containing a
kilograms
and
Controlled Substances;
Schedule
11
and 1000
Controlled Substance;
more
of
kilograms
into
the
Count 4
and
including
July
25,
2014,
California
Mayo,"
aka "Chapito,"
other,
10
commit
11
States Code,
12
13
place in the United States to and through a place outside the United
14
States,
15
unlawful activity,
16
17
and elsewhere,
aka
"Doc,"
did
and
within
defendants
IVAN
the
ISMAEL
ARCHIVALDO
knowingly
and
Southern
District
ZAMBADA-GARCIA,
GUZMAN-SALAZAR,
intentionally
aka
aka
conspire
of
"El
"Luis,"
with
each
and with other persons known and unknown to the grand jury, to
offenses
against
the
Section 1956,
with
the
intent
United
States
namely:
to
under
transport,
Title
18,
United
promote
the
carrying
on
of
from a
specified
18
FORFEITURE ALLEGATIONS
The
1.
19
allegations
contained
in
Counts
through
of
this
2o
Indictment
21
22
pursuant
23
Section 853, and Title 18, United States Code, Section 982.
to
the
provisions
of
Title
fully
21,
incorporated herein
United States
Code,
2.
24
are
Counts
through
25
in
26
punishable
by
27
Title
21,
United
28
defendants
ISMAEL
of
imprisonment
States
this
for
Indictment,
more
Code,
than one
Sections
ZAMBADA-GARCIA,
aka
"El
said
violations
year
and pursuant
being
aka
and
to
"Doc,"
ISMAEL
ZAMBADA-IMPERIAL,
SICAIROS,
GUZMAN-SALAZAR, aka
defendant
aka
"Mayito
obtained,
to
11
following:
12
States
13
Mercedes
14
GTR bearing
15
bearing
16
VIN #ZHWBU37S58LA02742.
1982
tail
number
SLR
VIN
"Chapito,"
or
includes,
210
bearing
shall,
indirectly,
and
and
as
#ZHWBU8AHXALA03904
the
result
is
not
tail
limited
2010
and
of
the
number
the
United
XB-NKY;
2014
Lamborghini
2008
to,
#21064675,
#WDDAJ76F66M000890;
#JN1AR5EF4EM270727;
conviction,
bearing Serial
VIN
ARCHIVALDO
but
Mexican
IVAN
upon
or derived from,
Indictment,
Turbo
N1218U
McLaren
VIN
aka
11
forfeited
Cessna
aka "Caballero,"
11
directly
The
3.
be
"Luis,
10
17
property
Flaco,
ISMAEL ZAMBADA-
2006
Nissan
Murcielago
Lamborghini
bearing
18
in
19
20
States
21
aka "El
22
aka "Luis,"
23
24
25
Count
4.
of
Code,
Indictment,
Section
Mayo,
If
this
11
aka
any
aka
982(a) (1),
"Doc,"
"Chapito,
of
said violation
the
11
being punishable
by
defendants
ISMAEL
ZAMBADA-GARCIA,
GUZMAN-SALAZAR,
and
IVAN
ARCHIVALDO
shall,
upon
conviction,
forfeit
to
the
above-described
forfeitable
26
21
II
28
II
10
property,
as
a.
b.
or deposited with,
third party;
3
4
c.
d.
e.
it
is
the
United States
Code,
the
United
Section
853 (p),
Counts
3,
14
All
15
Title 18, United States Code, Section 982, and Title 28, United States
16
20
21
22
23
24
States
Foreper
LAURA E. DUFFY
United States Attorney
By:
25
26
27
28
11
incorporated
and
13
United
as
through
21,
853 (p),
Title 21,
12
Title
Section
to
to
Title 18, United States Code, Section 982(b) (1) as to Count 4, to seek
of
Code,
as
pursuant
11
violation
States
States,
Title
in
United
of
10
17
21,
intent
Code,
by
Section 853,