Professional Documents
Culture Documents
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Plaintiff
- (Superseding)
v.
ISMAEL ZAMBADA-GARCIA (1),
aka "EI 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,"
Defendants.
19
20
~------------------------------------~
21
22
23
and (b)
Continuing Criminal
Introductory Allegations
At all times relevant to this Indictment,
1.
24
criminal
25
Cartel
26
Sinaloa, Mexico.
organization known as
is
the
transnational. drug
27
2.
Under
28
aka "EI
Mayo,"
the
ALB:nlv:San Diego
7/23/14
aka
leadership
"Doc,"
"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 collective resources in order to:
a.
b.
transport
drugs
through
Mexico
and
into
the
United
c.
7 States;
8
9 States; and
10
d.
11
trafficking.
12
3.
collect,
launder,
and
transfer
the
proceeds
of
drug
defendant ISMAEL
13
ZAMBADA-GARCIA, aka \\EI Mayo," aka "Doc," and members and associates
14
15 activities
to
American
import
large quantities
including
cocaine
Colombia,
from Central
South
17
18
Ecuador,
and
16
19 Mexico.
countries,
of
Venezuela,
to Mexico, as well
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
transportation
and
storage
of
these
drug
as
trafficking
multi-kilogram
activities
quantities
to
cocaine
within
smuggle
of
shipments
large
quantities
methamphetamine
and
of
ton-
4.
a.
was
the price for and caused to be obtained large quanti ties of cocaine
10
from Central and South American countries to Mexico, and caused multi-
11
kilogram quantities of
12
transported from Mexico to the United States border, and tben into and
13
throughout
14
15
transferred from
16
cocaine,
United
aka
II
primary
of
the
Sinaloa
aka "Doc,
II
II
Cartel.
negotiated
States.
"Doc,"
leaders
It
17
the
Mayo,
aka "Doc,
the
of
"EI
aka
II
one
ZAMBADA-GARCIA,
ISMAEL
Defendant
Defendant
ISMAEL
ZAMBADA-GARCIA,
laundered and
for
the
II
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.
Defendant
to be
caused multi-
ISMAEL
collected
from
27
"Caballero,
28
II
Mexico.
States border,
distribution.
proceeds
laundered
and
transferred
elsewhere
for
the
associates.
to
be
d.
"Chapito, "
collected
and throughout
from
customers
from
benefit
of
the
in
the
United
the
United
States
Sinaloa
to
Cartel's
States
and
Mexico
and
members
and
aka
"Luis,"
10
aka
11
12
States border,
13
distribution.
14
15
laundered
and
transferred
16
elsewhere
for
the
17
associates.
for
from
benefit
of
the
United
States
the
Sinaloa
to
Cartel's
Mexico
and
members
and
18
19
and throughout
of
for
5.
20
ZAMBADA-GARCIA,
21
22
Flaco,"
23
aka "Chapito," and members and associates of the Sinaloa Cartel under
24
25
couriers
Cartel,
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
Sinaloa
GUZMAN-SALAZAR,
to
aka "Mayito
aka
coordinate
"Luis,"
their
other drugs and. drug precursor chemicals to be imported from Asia and
4
1 Central
2 Venezuela,
3 Mexico,
Peru,
using
4 aircraft,
Panama,
various
submarines
5 vessels,
container
Costa
means,
and
Rica,
Honduras,
including
other
ships,
including Colombia,
cargo
submersible
supply
and
vessels,
Ecuador,
Guatemala,
aircraft,
and
to
private
semi-submersible
go-fast
boats,
fishing
and commercial
interstate
and
foreign
carriers.
After
the
b.
10
to
be
transported
13
States border where the drugs were then stored in multiple warehouses,
14
stash
15
houses,
c.
16
17
Mexico
18
elsewhere
from various
and
safe
houses
locations
located
in Mexico
in
the
to
areas
the
of
United
Tijuana,
border
through
using
the
mul tiple
Southern
means,
District
including
of
California
automobiles,
and
tractor
d.
21 affiliated
Cause drugs
with
the
to be
Sinaloa
Cartel,
and
stored at
mUltiple
stash
24
Cause
cocaine,
25
transported
throughout
26
including
27
28
//
automobiles,
the
methamphetamine
United
tractor
States,
trailers,
and
using
trucks,
marijuana
various
and
to
be
means,
private
and
f.
counted,
packaged,
Mexico,
transfers,
and
and
transferred
elsewhere,
alternative
multiple
laundered
means,
credit-based systems
other
including
used
to
bulk
cash
transfer money
use
11
systems
in
which
12
13
14
including
items,
luxury
goods-based
vehicles
order
17
cellular
18
telephones,
i.
Use
drug
high-end
means,
16
19
coordinate
traditional
United
the
to
or
the
without
h.
wires
from
10
15
of
using
and
trafficking
satellite
coded
language
activities,
telephones,
in
including
computers,
and
instant
to misrepresent,
20
21
22
23
j.
drug
concealed and
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
are
realleged and
incorporated
by
reference
as
California,
Mayo,
II
the
and
aka
elsewhere,
"Doc,
II
defendant
knowingly
and
intentionally
United
in
States
12
States Code,
13
Sections 952,
14
were part of a
15
16
17
and
18
series
19
resources.
"Doc,
21,
engage
"EI
3.
(Title
aka
11
Code,
Sections 959,
960 and 963,
as alleged in Count 2,
as alleged in Count 3,
and
which violations
position
of
Act
ZAMBADA-GARCIA,
of
other
Substances
ISMAEL
10
20
Controlled
did
2014,
of
violations
management,
defendant
and
from
obtained
which
such
substantia~
continuing
income
and
21
aka
22
leader of
23
24
Substance,
25
26
27
28
II
Schedule
was
the
for
II
a principal administrator,
criminal
enterprise,
the purpose
of
which
unlawful
Controlled Substance,
organizer,
involved
importation
into
the
supervisor and
a
conspiracy
into
United
to
the United
States
from
count 2
and including July 25, 2014, defendants ISMAEL ZAMBADA-GARCIA, aka "El
Mayo,"
aka "Good
aka "Caballero,"
other, and with other persons known and unknown to' the grand jury, to
aka
"Doc,"
Guy,"
ISMAEL
ISMAEL
and
did
amount
ZAMBADA-IMPERIAL,
ZAMBADA-SICAIROS,
IVAN
ARCHIVALDO
knowingly
of
and
aka
aka
"Mayito
GUZMAN-SALAZAR,
intentionally
methamphetamine
"Mayito
conspire
"Luis,"
with
11
cocaine,
12
and more
13
purpose
14
violation of Title 21, United States Code, Sections 959, 960, and 963.
of
marijuana;
unlawful
Controlled Substances;
Schedule
importation
15
and
each
detectable
of
5 kilograms
Flaco,"
10
both Schedule II
and
aka
Gordo,"
and 1000
the
United
of
kilograms
Controlled Substance;
into
more
States;
for
the
all
in
Count 3
16
17
and
18
California,
19
Mayo,"
20
aka "Good
21
aka "Caballero,"
22
aka "Chapito,"
23
other,
and with other persons known and unknown to the grand jury, to
24
import
500
25
detectable
26
cocaine,
27
including
aka
July
25,
2014,
and elsewhere,
"Doc,"
Guy,"
and
did
grams
amount
IVAN
ZAMBADA-IMPERIAL,
ZAMBADA-SICAIROS,
ARCHIVALDO
knowingly
and more
of
of
and
Southern
aka
aka
District
mixture
and
and
28
"Mayito
aka
conspire
of
aka
"El
Gordo,"
Flaco,"
"Luis,"
with
each
substance containing a
kilograms
Controlled Substances;
Schedule I
"Mayito
GUZMAN-SALAZAR,
intentionally
methamphetamine
both Schedule II
the
ISMAEL
ISMAEL
within
and
more
of
and 1000
kilograms
Controlled Substance;
into the
Count 4
and
California
Mayo,"
aka "Chapito, II
other, and with other persons known and unknown to the grand jury,
including
July
25,
2014,
and elsewhere,
aka
"Doc,"
did
offenses
and
defendants
IVAN
the
ISMAEL
ARCHIVALDO
knowingly
against
within
and
the
Southern
ZAMBADA-GARCIA,
GUZMAN-SALAZAR,
intentionally
with
to
12
13
place in the United States to and through a place outside the United
14
States,
15
unlawful activity,
16
17
the
intent
to
18,
each
States Code,
transport,
Title
"Luis,"
11
namely:
under
"EI
commit
with
States
aka
aka
conspire
of
10
Section 1956,
United
District
United
promote
the
carrying
on
of
specified
18
FORFEITURE ALLEGATIONS
19
1.
The
allegations
in
Counts
through
of
this
21
22
pursuant
23
Section 853, and Title 18, United States Code, Section 982.
2.
the
provisions
of
Title
fully
Indictment
to
20
24
are
contained
21,
incorporated herein
United States
Code,
25
in
Counts
through
26
punishable
by
27
Title
21,
United
28
defendants
ISMAEL
of
imprisonment
States
this
for
Indictment,
more
Code,
ZAMBADA-GARCIA,
than one
Sections
aka
"EI
said
violations
year
and pursuant
8 5 3 (a) (I)
Mayo, II
being
aka
and
to
8 5 3 {a} {2} ,
"Doc,
II
ISMAEL
ZAMBADA-IMPERIAL,
SICAIROS,
GUZMAN-SALAZAR,
defendant
aka
"Mayito
aka
obtained,
"Luis,"
The property
11
following:
12
States
13
Mercedes
14
GTR bearing
15
bearing
16
VIN #ZHWBU37S58LA02742.
1982
tail
McLaren
VIN
VIN
3.
forfeited
N1218U
"Chapito,
or
210
bearing
shall,
II
indirectly,
and
and
as
the
is
not
bearing Serial
VIN
result
#ZHWBU8AHXALA03904
tail
2010
and
of
the
limited to,
#21064675,
number
Lamborghini
2008
the
United
XB-NKYi
#WDDAJ76F66M000890i
#JNIAR5EF4EM270727 i
conviction,
but
Mexican
IVAN ARCHIVALDO
upon
or derived from,
includes,
Cessna Turbo
number
SLR
aka "Caballero,"
aka
directly
10
17
to be
Flaco,"
ISMAEL ZAMBADA
2014
2006
Nissan
Murcielago
Lamborghini
bearing
18
in
19
imprisonment for more than one year, and pursuant to Title 18, United
20
States
21
aka "EI
22
aka "Luis,"
23
24
25
Count
4.
of
Code,
Indictment,
Section
Mayo,
If
this
II
aka
any
aka
982{a) (I),
"Doc,"
"Chapito,"
of
the
defendants
by
ISMAEL
ZAMBADA-GARCIA,
GUZMAN-SALAZAR,
and
IVAN
ARCHIVALDO
shall,
upon
conviction,
forfeit
to
the
above-described
forfeitable
26
27
II
28
II
10
property,
as
a.
b.
or deposited with,
third party;
3
4
c.
d.
e.
it
is
the
intent
9 united states
United
Section
853 (p),
and
incorporated
by
13
as
through 3,
21,
853 (p),
Title 21,
12
Title
Section
to Counts
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
the
10
14 All
21,
Code,
of
States
Code,
Section 853,
15
Title 18, United States Code, Section 982, and Title 28, United States
16
17
18
A TRUE BILL:
19
20
21
22
23
24
Foreper
LAURA E. DUFFY
United States Attorney
By:
25
26
27
28
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