Marco Rubio's Brother in Law Indictment

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. UNIJLD STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO.
UNITED STATES OF AMERICA,

Plaintiff,
v.
MARIO S. TABRAUE,
GUILLERMO TABRAUE, SR.,
FRANCISCO QUINTANA,
a/k/a "PUPI",
JOSE LABRADA,
a/k/a JOE VULCANO,
ORLANDO CICILIA,
MIGUEL RAMIREZ,
EDUARDO FERNANDEZ-CARDULI,
CARLOS PAZOS-SANTANA,
ANTONIO MUN!O,
JOSE PEPE ACOSTA,
LUIS VALDESUSO,
a/k/a "FLACO",
a/k/ a "RECITO",
JUAN PORTt!ONDO,
and
PHILIP EPSTEIN
87-928-Cr-KEHOE(S)
18 usc 1962(d)
l~ usc 1962 (c)
18 usc Sl963
18 usc 2
21 USC SB48
21 usc 846
21 usc S963
21 usc 952
21 USC 841 (a) (1)
18 USC S1952 (a) (3)
18 usc S1503
18 usc 1512(b)
26 usc 5861 (d)
26 usc 5871
SUPERSEDING
INDICTMENT
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Defendants.
The Grand Jury charges that:
THE ENTERPRISE
1.
From an unknown date, believed to be in the Summer of
1976, and continuing up to and including December 16, 1987 1 the
d.efendants,
MARIO S. TABRAUE,
FRANCISCO QUINTANA, a/k/a pupr,
JOSE LABRADA, a/k/a JOE VULCANO,
ORLANDO CIC!LIA,
MIGUEL RAMIREZ,
ANTONIO MUNIO,
and
JOSE PEPE ACOSTA,
'
and others known and unknown to the grand jury, did constitute an
enterprise,
("The Enterprise")
United States Code,
duals
associated
within the meaning of Title 18,
Section 1961{4),
in
fact
activities
consisting of:
tation
marijuana,
of
which
that is a group of indivi-
engaged
in
various
conspiracy to import
Schedule
and
controlled
criminal
the
impor-
substance,
in
violation of Title 21, United States Code, Sections 952 and 963;
conspiracy to possess and distribute,
to
distribute,
controlled
controlled
and
distribution
substance,
substance,
and
in
facilitate
marijuana,
a
cocaine,
and 846i
cocaine
United States Code,
of
violation of
Code, Sections 84l{a) (1}

to
the possession with intent
Schedule
Title
21 1
Schedule
II
narcotic
United States
travel in interstate commerce
business,
in
Section 1952 (a) (3};
Florida Statute 782.04;
violation
murder,
of
Title
18,
in violation of
accessory after the fact to murder 1
in
violation of Florida Statutes 777.03 and 775.082t and obstruction

of
justice,
in
violation
of
Title
18,
United
States
Code,
Sections 1503 and 1512(b).

ROLES OF THE DEFENDANTS
2.
The
role
of
the
defendants
in
the
business
TABRAUE
arranged
for
the
large
quanti ties
of
of
the
Enterprise was as follows:

A.
distribution
MARIO
and
sale
5.
of
-2-
importation,
illegal drugs
on
('
. <I
'
.
behalf of the Enterprise.
TABRAUE arranged
To conduct the drug business, MARIO s.
for the importation of marijuana and
for its
sale in the Unit.ed States after it was illegally imported.

times,
MARIO
S.
TABRAUE
broke red
the
loads
by
direct shipment to clients of the Enterprise.
arranging
At
for
on other occa-
sions, MARIO S. TABRAUE took delivery of the marijuana and stored

i t in stash houses,
controlled by the Enterprise, until it was
sold
to
and
'!'ABRADE
delivered
either
client
purchased,
of
brok:ered,
the
or
Enterprise.
had
MARIO
joint
S.
financial
interest in marijuana loads imported by FRANCISCO QUINTANA, a/k/a
"PUPI 11 and others.
The Enterprise also received and distributed
large quantities of cocaine.
GUILLERMO TABRAUE,
SR.
MARIO S.
received 1
TABRAUE and his
father,
collected and distributed the
proceeds from the sale of marijuana and cocaine on behalf of the

Enterprise.
B.
GUILLERMO
TABRAUE,
SR.
operated
the
Guillermo
Tabraue Jewelry store at 940 west Flagler Street, Miami, Florida
(hereinafter
referred
TABRAUE,
assisted his
SR.
to
as
son,
placing his son, defendant MARIO
importers
and
distributors
11
the
jewelry
storert)
defendant MARIO S.
s.
wbo
GUILLERMO
TABRAUE,
by
TABRAUE 1 in contact with drug
frequented
the
jewelry
store.
Many of the drug importers and distributors, who were associated

with
a/k/ a
the
Enterprise,
"PUPI",
including
defendant
FRANCISCO
were introduced to defendant MARIO s.
QUINTANA,
TABRAUE by
GUILLERMO TABRAUE, SR. for the purpose of promoting and expanding

the Enterprise's drug business.
In addition, defendant GUILLERMO
TABRAUE,
for
SR.
was
responsible
-3-
collecting,
receiving
and
'
.
disbursing millions of dollars in cash proceeds generated by the
Enterprise.
as
Specifically, defendant GUILLERMO TABRAUE, SR. acted
clearing
receiving
and
importers,
house
far
disbursing
suppliers
and
drug
associates
payments
for
distributors
of
and
and
the
on
Enterprise,
behalf
collecting
of
the
payments
from clients of the Enterprise.

C.
FRANCISCO
QUINTANA,
a/k/a
"PUPl"
was
associated
with and participated in the affairs of the Enterprise by importing large quantities of marijuana into the United States for and
on behalf of defendant MARIO s. TABRAUE and the Enterprise.
D.
sessed
JOSE
LABRADA a/k/ a JOE VULCANO off loaded,
pos-
transferred and distributed marijuana and cocaine for the
Enterprise.
E.
ORLANDO
CICILIA
received,
possessed,
warehoused
and distributed quantities of cocaine for and on behalf of the

Enterprise.
F.
MIGUEL RAMIREZ received, possessed and distributed
quantities of marijuana for the Enterprise.

G.
EDUARDO
FERNANDEZ-CARDULI
supplied
machine
guns
and silencers to the Enterprise and otherwise associated with and

participated in the affairs of the Enterprise.
H.
CARLOS
PAZOS-SANTANA
received,
possessed
and
distributed quantities of marijuana and cocaine for the Enter-
prise.
I.
ANTONIO
MUNIO
was
soldier
or
employee
of
the
Enterprise and as such, assisted the Enterprise in off-loading,
-4-
''
staring,
guarding,
transferring
and distributing marijuana
and
cocaine for the Enterprise.

J.
JOSE PEPE ACOSTA was a soldier or employee of the
Enterprise and as such, assisted the Enterprise in off-loading,

storing,
transferring ana
guarding,
distributing marijuana and
cocaine far the Enterprise.

PURPOSE, OBJECTS AND
OPERATION OF THE ENTERPRISE
3.
The Enterprise 1 operated in the following manner;

A~
large
The
loads
Enterprise
of marijuana
Defendant
MARIO
QUINTANA,
a/k/a
Enterprise,
who
S.
imported
for
TABRAUE
into
domestic
would
the
distribution
contact
defendant
and MARIO
and
sale.
FRANCISCO
and other importers associated with the
would
make
The
S~
States,
npupin
arrangements
for
the
shipment of marijuana from Colombia to the United

B.
United
defendants
FRANCISCO
purchase
and
States~
QUINTANA,
a/k/a
"PUPI"
TABRAUE, and others associated with the Enterprise,
would arrange for boats, trucks and other vehicles to transport
the drugs.
Boats would be used to import the drugs into Florida,
Georgia and Louisiana.
The marijuana would then be transported
by vehicles from the off-load areas to various stash houses under
the control of the Enterprise or its
clients~
On occasions when
the Enterprise retained possession of the marijuana for resale,
the Enterprise would utilize individuals such as defendants JOSE

LABRADA,
a/k/ a JOE VULCANO, ANTONIO MUNIO,
JOSE PEPE !\COSTA and
others, to off-load and transfer the marijuana from the vessels,

the trucks
houses
and
and other vehicles,
coUnt,
weigh
and
unload
record
-5-
the trucks at the stash
the
amount
of
marijuana
'
..
received
and
Later,
distributed.
the marijuana would
transferred to customers of the Enterprise.
then be
On those occasions
when defendant MARIO S. TABRAUE brokered the loads of marijuana,
he arranged for the delivery to be made directly to the clients

of the Enterprise after the marijuana was off-loaded.
C.
at
In those instances
~hen
the marijuana was stored
stash houses under the control of the Enterprise,
MARIO S.
defendant
TABRAUE would contact distributors and clients of the
Enterprise,
such as defendants MIGUEL RAMIREZ and CARLOS PAZOS-
SANTANA, and arrange for the delivery of the marijuana to them,

including the manner of delivery, the price and terms of payment.
Defendants
JOSE
LABRADA,
a/k/a
JOSE PEPE ACOSTA and others
JOE
VULCANO,
ANTONIO
M.UNIO
under defendant MARIO S ~
and
TABRAUE, s
supervision 1 would assist ln transferring the marijuana from the

stash houses
to trucks belonging
the Enter-
to the clients or
prise.
D.
delivered
by
The
number 1
defendant
weights
MARIO
s.
and
amount
TABRAOE
to
of
the
bales
Enterprise's
clients, and the amount of tnoney received on account,

by defendants MARIO S.
TABRAlJE
being
and
would be
recorded
and
kept
GUILLERMO
TABRAUE,
SR.
After each load was distributed and paid for, these
records would be destroyed.

E.
Payment for each load of marijuana would usually
be made to defendant MARIO s.
TABRAUE or his father,
defendant
GUILLERMO TABRAUE, SR., usually at the jewelry store or MARIO S.

TABRAUE' S residence.
Often,
the distributors would pay
for
at
least a portion of the load immediately upon their receipt of the
-6-
marijuana.
The balance owed would be paid to defendants MARIO s.
TABRAUE or GUILLERMO TABRAUE 1
SR~
usually within a
few Weeks.
As payments were received from the distributors, the defendants
MARIO S. TABRAUE and GUILLERMO TABRAUE, SR., would arrange for

payments
~PUPI"
to
be
made
to
defendant
FRANCISCO
QUINTANA,
a/k/a
, and the other importers and suppliers- associated with the
Enterprise,
for the marijuana imported and supplied by them to
the Enterprise.
F.
Defendants
MARIO
S.
TABRAUE
and
CARLOS
PAZOS-
SANTANA were partners in a marijuana distribution network in the
New
York
area.
Defendant
CARLOS
PAZOS-SANTANA would
receive
quantities of marijuana from the Enterprise and transport it to

utilizing vans and trucks.
New York
Upon
arriving in the New
York area, defendant CARLOS PAZOS-SANTANA would then be in charge

of distributing the marijuana in the New York area.
At times,
CARLOS PAZOS-SANTANA would also receive cocaine from the Enterprise and distribute it for the Enterprise through the New York
network.
G.
The
Enterprise
used
such
associates,
JOSE
as
LABRADA, a/k/a JOE VULCANO and uniformed police officers working

for
the
Enterprise,
to
collect,
receive
and
count
the
monies
received from the Enterprise's sales.

B.
ment,
the
quanti ties
MARIO S.
others,
During the period of time alleged in the indict-
Enterprise
of
cocaine.
TABRAUE,
would
would
CARLOS
either
also
The
receive
Enterprise,
PAZOS-SANTANA,
receive
large
-7-
and
distribute
through
ORLANDO
quantities
of
large
defendants
CICILIA
cocaine
and
on
consignment and distribute it to its various clients throughout

the United States or broker the sale between the supplier and a
Depending on the size of the transaction and the
distributor.
client involved, the arrangements for the receipt and delivery of

cocaine,
and
the
price
through defendants
and
manner
MARIO S.
TABRAUE,
of
payment
would
be
GUILLERMO TABRAUE,
made
SR.
or
ORLANDO CICILIA.
I.
JOE
Defendants ORLANDO CICILIA and JOSE LABRADA, a/k/a
VULCANOr
for
Enterprise
receive
cocaine
distribution
on
consignment
their
to
own
by
ORLANDO CICILIA
for
later
S.
TABRAUE
or
quantity of cocaine,
customer
of
distribution
the
by
defendant
When defendant
Enterprise
defendant MARIO S.
Large
stored or ware-
MARIO S. TABRAUE, to customers of the Enterprise.

MARIO
the
from
customers.
of cocaine would also be received,
quantities
housed
would
TABRAUE
required
would
instruct
defendant ORLANDO CICILIA as to the amount required and where it

was
to
arrange
be
delivered.
for
the delivery
Defendant
of
ORLANDO
CICILIA
that cocaine
structed by defendant MARIO s.
TABRAUE.
from
storage
then
be
collected
by
associates
then
as
in-
Quantities of cocaine
would either be delivered on account or for cash,

would
would
of
the
the proceeds
Enterprise
and
delivered to defendant MARIO S. TABRAUE.
J.
associates
Defendant MARIO S.
of
the
Enterprise,
TAB~UE,
would
and other members and
take
steps
necessary
to
secure, protect and conceal the affairs of the Enterprise and the
profits derived therefrom.
The affairs of the Enterprise were
protected by armed employees and uniformed police officers bribed
-8-
(
by
Enterprise.
the
PAZOS-SANTANA,
others
Defendants
MIGUEI
associated
RAMIREZ,
with
the
s.
W.RIO
EDUARDO
Enterprise
TABRAOE,
CARLOS
FERNANDEZ-CARDOLI
would
be
armed
and
with
unlawful machine guns and silencers supplied to the Enterprise by

defendants
MARIO S.
TABRAUE
and
EDUARDO
FERNANDEZ-CARDULI.
Force, violence, including murder, bribery of police officers and

attempts to induce false testimony before a federal grand jury,
were all utilized by the Enterprise to protect and conceal- its
affairs from interference by law enforcement authorities and to
prevent defection among the Enterprise 1 s associates.
Indeed to
facilitate the Enterprise 1 s continued and unfettered operation 1
confidential
informant,
Larry
Nash
and
defendant
MARIO
S.
TABRAUE's wife, Maria Tabraue, were murdered by associates of the

Enterprise.
in the
Other associates of the Enterprise then participated
destruction of evidence
W.RIO s.
TABRAUE
and other
that would implicate defendant
associates of the Enterprise
in the
sourcer
nature
murders.
K.
and
amount
corporation,
The Enterprise would conceal the

of
its
illegal
investments,
profits
cashiers
by
the
use
checks,
of
false
an
off-shore
loans
and
mortgages, trusts and attorney trust account.

THE RACKETEERING CONSPIRACY
4.
From on or about an unknown date believed to be in the
the Summer of 1976, and continuing up to and including December
16 1 1997
in the Southern District of Florida and elsewhere 1 the
defendants,
MARIO S. TABRAUE,
-9-
(
FRANCISCO QUINTANA, a/k/ a "PUPI",
JOSE LABRADA, a/k/a JOE VOLCANO,
ORLAh~O CICILIA,
MIGUEL RAMIREZ ,
CARLOS PAZOS-SANTANA
ANTONIO MUNIO,
and
JOSE PEPE ACOSTA,
and others known and unknown to the grand jury, being members of,
employed
by
described
and
in
associated
1
paragraph
intentionally combine,
with
through
conspire,
the
3
Enterprise,
did
above,
confederate and
and with other persons known and unknown to
as
further
knowingly
and
agree together
the grand
jury to
violate Title 18, United States Code, Section 1962{c), that is to

conduct and participate, directly and indirectly,
of the
ering
in the conduct
affairs of the Enterprise through a pattern of racketeactivity,
Sections 1961(1)
as
defined
and 1961(5}
by
Title
18,
United
States
Code,
as set forth in paragraphs 5 and 6
of this count.
All
in violation of Title 18,
United States Code,
Section
1962 (d)
THE PATTERN OF RACKETEERING ACTIVITY:
5.
Title
The
18,
pattern
United
of
racketeering
States
Code,
activity,
Sections
1961 (1)
as
defined
and
in
1961 (5),
through which the defendants conducted and participated in the

affairs of
the Enterprise,
the importation into the

I
controlled substance,
and
agreed
to do
so,
consisted of:
United States, of marijuana, a Schedule

in violation of Title 21, United States
Code, Section 952 and conspiracy to do so in violation of Title

21,
United States Code,
Section 963:
-10-
the possession with intent

to
distribute
marijuana
and
the
distribution
of
marijuana,
Schedule I controlled substance, in violation of Title 21, United
States
Code,
violation
of
Section
Title
84l(a) (1}
21,
and
United
conspiracy
States
Code,
to
do
Section
so,
84 6;
in
the
possession with intent to distribute cocaine and the distribution
of
cocaine,
Schedule
II
narcotic
controlled
substance,
in
violation of Title 21, United States Code, Section B4l(a) (1) and
the conspiracy to do so, in violation of Title 21, United States
Code, Section 846; travel in interstate commerce to facilitate a
cocaine business,
Section
in violation of Title lS, United States Code,
1952(a) {3);
murder,
in
violation
of
Florida
Statute
Section 782.04i accessory after the fact to murder, in violation

of Florida Statutes Sections 777.03 and 775.082; and obstruction
of
justice,
in
violation
of
Title
18,
United
States
Code,
Sections 1503 and 1512(b).

ACTS OF RACKETEERING
6~
The
defendants
directly and indirectly,
agreed
to
conduct
and
participate,
in the conduct of the affairs of the
Enterprise through a pattern of racketeering activity in that two

or more of the following racketeering acts would be committed on
behalf of the Enterprise.
A.
ACTS OF RACKETEERING INVOLVING MURDER
(A-1) Racketeering Act No. 1

On or about July 15, 1980, in Dade County, in the Southern
District of Florida, the defendants, MIGUEL RAMIREZ and EDUARDO
FERNANDEZ-CARDULI did unlawfully and feloniously,
itated design
to
effect the death
-11-
of
from a premed-
human being,
kill
and
murder Larry Nash a human being by shooting the said Larry Nash
with a firearm, to wit: a semi-automatic pistol( in violation of

rlorida Statute 782.04.
on or about July 15, 1980, defendants MARIO s. TABRAUE, JOSE

PEPE ACOSTA, ANTONIO MUNIO, CARLOS PAZOS-SANTANA and others known
and
unknown
to
the grand
Jury,
,did
knowingly
and
feloniously
assist defendants EDUARDO FERNANDEZ-CARDULI and MIGUEL RAMIREZ,

knowing that they had committed a
felony,
the
or escape detection,
intent that they
trial
or
punishment,
shall
avoid
assisting
by
to wit:
them
in
murder, with
the
arrest,
mutilation,
cremation and disposal of Larry Nash's body and by cleaning and

disposing of the automobile, in which Larry Nash
was murdered,
in violation of Florida Statutes, Sections 777.03 and 775.082.

On or about February 6, 1981, in Dade County, in the Southern District of Florida, defendants MARIO
S~
TABRAUE, JOSE PEPE
ACOSTA and ANTONIO MUNIO, did unlawfully and feloniously,
from a
premeditated design to effect the death of a human being,
kill
and murder Maria Tabraue a human being by shooting the said Maria
Tabraue
with
firearm,
to
wit:
-380
Barretta
pistol,
in
violation of Florida Statute 782.04.

B.
ACTS OF RACKETEERING INVOLVING

THE INITIAL DISTRIBUTION OF
MARIJUANA TO OSCAR OLIVA CANTU
(B-1) Racketeering Act No. 4

Between the
Summer of 1976
and
the end
of
1976,
at
Dade
County, in the Southern District of Florida, defendants MARIO
-12-
s.
TABRAUE,
GUILLERMO
together
npopJ",
jury,
knowingly
TABRAUE,
SR.
and
with
others known
and
intentionally
FRANCISCO
and
QUINTANA,
unknown to
the
grand
conspire,
combine,
did
a/k/a
confederate and agree with each other to distribute approximately

eight
thousand
controlled
(8,000)
substance,
pounds
of
marijuana,
in violation of
Title
21,
Schedule
United States
Code, Section 846,

(B-2) Racketeering Act No. 5
From in or about December,
Dade County,
in the Southern District of Florida,
1977, at
the defendant
s. TABRAUE, and others known and unknown to the grand jury
MARIO
knowingly
and
1976 1 through January,
and intentionally did combine,
agree
pounds
to
of
distribute
marijuana,
approximately
Schedule
conspire,
seven
confederate
thousand
controlled
(7,000)
substance 1
in
violation of Title 21, United States Code, Section 846*

C.

THE BARGE CANAl AT CRYSTAL RIVER
(C-1) Racketeering Act No. 6

Between
1978 1
at
in
or
Crystal
about
River,
District
of
TABRAUE,
together with
jury,
Florida
November,
Citrus
and
1977
County,
elsewhere,
the
others known and
and
and
the
in
b~ginning
the
defendant
unknown
committed one or more of the following
to
acts,
of
Southern
MARIO
the
S.
grand
any one of
which would constitute one act of racketeering:

{a)
knowingly and
intentionally imported into
States at Crystal River, Florida,

(201000)
approximately twenty thousand
pounds of marijuana, a Schedule I
-13-
the United
in violation of Title
21 1
United States Code,
Section 952
and
Title 18, United States Code, Section 2; and
(b)
distribute
marijuana,
Title
21,
knowingly
and
intentionally
approximately
a
Schedule I
United
States
twenty
thousand
controlled
Code,
possessed with
(20,000)
substance,
Section
intent
pounds
to
of
in violation of
841(a)(l)
and
Title
18,
United States Code, Section 2; and

{c)
five
knowingly
thousand
and
(5,000}
intentionally distributed
pounds
of
marijuana,
approximately
Schedule
con-
trolled substance, in violation of Title 21, United States Code,

Section 84l{a) {1)
and Title 18, United States Code, Section 2.
D.
(D-1)

TRE NAPLES RIP-OFF
Racketeering Act No. 7

From in or about the end of 1977, until in or about January,
1978,
and
at Naples and Miami,
elsewhere,
the
in the Southern District of Florida
defendant
MARIO
S.
TABRAUE,
together
with
others known and unknown to the grand jury, committed either one
or both of the following acts, either one of which would constitute one act of racketeering:
(a)
knowingly
and
intentionally
did
combine,
conspire,
confederate and agree with each other to import into the United
States, at Naples, Florida, from a place outside thereof, approxirnately fifteen thousand (15,000} pounds of marijuana, a Schedule
I
United States
Code, Section 963; and

(b)
knowingly
and
intentionally
did
combine,
conspire,
confederate and agree with each other to possess with intent to

-14-
distribute
approximately
marijuana,
Schedule
fifteen
thousand
controlled
(15 1 000)
substance,
in
pounds
of
violation of
Title 21, United States Code, Section 846,

(D-2) Rac)teteering Act No. 8
In or about the early part of 1978, but subsequent to the
acts above 1 at Dade County, in the Southern District of Florida
and
elsewhere,
defendants
the
MARIO
S.
TABRAUE
and
GUILLERMO
TABRAUE, SR., together with others known and unknown to the grand
jury, knowingly and intentionally did combine, conspire, confed-
erate
and
agree
marijuana,
Title
21,
with
each
Schedule I
other
to
controlled
United States Code,
distribute
substance,
Section
quantity
of
in violation of
841 (a) (1)
and Title 18,
United States Code, Section 2.
E.
ACTS OF RACKETEERING INVOLVTNG

THE TALLAHASSEE LOADS
(E-1) Raclteteering Act No. 9
From in or about May, l97B, through in or about June, 1978,
at
Tallahassee
and
Dade
Florida,
and
elsewhere 1
TABRAUE,
SR.
and
knowingly
and
agree
thousand
and
others
County
each
(20,000)
the
Southern District
defendants MARIO S
known
and
intentionally did
with
in
other
to
unknown
combine,
distribute
pounds of marijuana,
TABRAUE,
to the
GUILLERMO
grand
conspire,
jury,
confederate
approximately
Schedule
of
twenty
controlled
substance, in violation of Title 21, United States Code, Section
846.
(E-2) Racketeering Act N6. 10
From in or about June, 1978, through in or about July,
at
Tallahassee
and
Dade
County
-15-
in
the
Southern
1~78,
District
of
Florida,
and elsewhere,
TABRAUE,
SR.
knowingly
and
and
others
defendants MARIO S.
known
intentionally
and unknown
did
combine,
TABRAUE,
to
the
GUILLERMO
grand
conspire,
jury,
confederate
and agree with each other to distribute approximately seventeen

thousand
( 17, 000)
Schedule I
controlled
ih violation of Title 21 1 United States Code, Section
substance,
846.
F.
(F-1)
From
1978,

POLICE LIEUTENANT CASAMAYOR
in or about January,
1978,
in Monroe and Dade Countie.s,
until
in the Southern District of
Florida, and elsewhere, the defendant MARIO

with others
kno~n
and
unkno~n
in or about April,
s.
TABRAUE, together
to the grand jury, committed one or
more of the following acts, any one of which would constitute one
act of racketeering:
{a)
knowingly
and
intentionally
did
combine,
conspire,
confederate and agree with each other to import into the United
States,
from
thousand
(30,000)
substance,
place
outside
thereof,
approximately
Schedule I
thirty
controlled
in violation of Title 21, United States Code,
Section
963; and
(b)
States,
knowingly and intentionally did import into the United

from
thousand
substance,
( 30 ,000)
place
outside
thereof,
approximately
a Schedule I
thirty
controlled
in violation of Title 21, United States Code, Section
952 and Title 18, United States Code, Section 2i and
-16-
(
(c}
knowingly
and
intentionally
did
combine,
conspire,
confederate and agree with each other to possess with the intent
to distribute approximately
marijuana,
Title
21,
Schedule
United
thirty thousand
controlled
States Code,
(30, 000)
substance,
pounds of
in violation of
Section 84l(a) (l)
and Title 18,
{d)
knowingly and intentionally did possess with intent to
distribute
juana,
21,
approximately ten thousand
{10 1 000)
a Schedule I controlled substance 1
United States code,
States Code, Section

G.
pounds of mari-
section 841(a) (1)
and Title 18,
United
2~

THE LOXAHATCHEE LOADS
(G-1) Racketeering Act No. 12

In
or
about
the Summer of
1977,
at Dade
County,
in
the
Southern District of Florida, and elsewhere, the defendants MARIO

S. TABRAUE and GUILLERMO TABRAUE, SR., together with others known
and
unknown
following
to
acts,
the grand
any
jury,
committed
one of which would
one
or more
constitute one
of
the
act of
racketeering:
(a)
knowingly
confederated
and
and
agreed
intentionally
to
possess
approximately twenty-five thousand

a
Schedule
controlled
with
(25,000)
substance,
combined,
intent
to
conspired,
distribute
in violation! of
Title
21,

(b)
knowingly and
intentionally possessed with
intent to
distribute approximately twenty-fi,e thousand (25 ,000) pounds of
marijuana,
Schedule I
-17-
in violation of
(_,
Title 21,
United States Code, Section 841 (a) Ill;
and Title 18,
United States Code, Section 2i and

{c)
knowingly
and intentionally
twenty-five thousand
controlled
distributed approximately
(25,000) pounds of marijuana, a Schedule I
substance,
21,
United
States
Code, Section B4l{a} (1) and Title 18, United States Code, Section
2'
{G-2) Racketeering Act No. 13
Between in or about the Fall of 1977, and the beginning of
1978,
Loxahatchee,
at
Florida
and
Florida,
elsewhere,
the
in
the
defendants
Southern
MARIO
District
S.
of
TABRAUE
and
GUILLERMO TABRAUE, SR., together with others known and unknown to

the grand jury, conunitted one or more of the following acts, any
one of which would constitute one act of racketeering:

(a)
knowingly
States, at Georgia,
forty thousand
and
intentionally imported into the United
from a place outside
{40,000)
thereof~
approximately
Schedule I
con-
trolled substance, in violation of Title 21, United States Code,

Section 952 and Title 18 1 United States Code, Section 2; and
(b)
knowingly
confederated and
and
intentionally
agreed with
mately forty thousand (40,000)

controlled
substance,
combined,
conspired,
each other to distribute
approxi-
21,
United
States
Code, Section 846; and

{c)
forty
knowingly
thousand
controlled
and
{40,000)
substance 1
pounds
of
marijuana,
-18-
21,
approximately
Schedule
United States
(
Code, Section 84l(a)(l) and Title 18, United States Cadet Section
2.
(G-3)

In or about the end of 1978, at Dade County and Loxahatchee,
in the Southern District of Florida, and elsewhere, the defendant
MARIO S. TABRAUE, together with others known and unknown to the

grand jury,
committed either one or both of the following acts 1
either one of which would constitute one act of racketeering:

knowingly
(a)
and
conspired,
combinedt
intentionally
confederated and agreed to distribute approximately twenty-nine

thousand
( 29,000)
substance,
Schedule I
controlled
in violation of Title 21 1 United States Code, Section
646; and
(b) knowingly and intentionally distributed and caused to be
distributed approximately twenty-nine thousand (29 1 000) pounds of

marijuana,
Title 21,
Schedule
United
controlled
States Code,
substance,
section
in
841 (a) (1)
violation
and Title
of
18,
United States Code, Section 2,

H.

THE PALMETTO/APPOLLO BEACH LOAD
(H-1) Racketeering Act No. 15
In or about July, 1978, at Hillsborough County, Florida and

dant,
FRANCISCO QUINTANA,
and elsewhere,
a/k/a "PUPI",
the de fen-
and JOSE LABRADA,
a/k/a
JOE VULCANO, together with others known and unknown to the grand
jury,
knowingly
and
intentionally
did
import
into
the
United
States from a place outside thereof approximately fifty thousand

(50,000)
a Schedule I
-19-
21,
United States Code,
Section 952
and
Title 18, United States Code, Section 2.

(H-2)

In
or
about July
1978,
at
Hillsborough County
and in the
Southern District of Florida( and elsewhere, the defendant MARIO

S.
TABRAUE
and
others
known
and
unknown
to
the
grand
jury,
knowingly and intentionally combined, conspired, confederated and

agreed with each
quantity
of
other to possess with
marijuana,
Schedule
intent to distribute
controlled
substance,
a
in
violation of Title 21, United States Code, Section 841(a) {1) and
l.

THE SMALL HOUSES LOAD
(I-1) Racketeering Act No. 17

Bet'W"een in or about the end of
1978
and the beginning of
1979, at Monroe County, in the Southern District of Floridat and

elsewhere,
the defendants FRANCISCO QUINTANA,
JOSE LABRADA,
a/k/a JOE VULCANO,
a/k/a
"PUPI"
and
together with others known and
unknown to the grand jury, knowingly and intentionally did import

into
the
United
States,
from
place
outside
thereof,
approximately twenty-five thousand (25,000) pounds of marijuana,

a
Schedule
controlled
substance,
in
violation
of
Title
21,
United States Code, Section 952 and Title 18, United States Code,
Section 2.
(I-2) Racketeering Act No. 18
Between in or about the end of 1978, and the beginning of

1979t at Monroe County,
in the Southern District of Florida, and
-20-
(
elsewhere,
the
defendant
MARIO
S.
TABRAUE,
together
with
and
others known and unknown to the grand jury, knowingly and intentionally did combine,
conspire,
confederate and agree with each
other to possess with intent to distribute approximately twenty-
five
thousand
(25 1 000)
Schedule I
con-
trolled substance; in violation of Title 21, United States Code,

Section B46.
(I-3) Racketeerina Act No. 19
In or about the end of 1978 and the beginning of 1979, but
subsequent
to
the
District
of
TABRAUE,
together
acts,
above
Florida,
and
with
at Dade County
elsewhere,
others
the
known
and
in
the southern
defendant,
unknown
to
MARIO
the
S.
grand
jury, knowingly and intentionally distributed approximately five
thousand
(5,000}
a Schedule I
controlled

B4l(a) (1) and Title 18, United States Code, Section 2.
J.

TBE ACAPULCO BOUSE LOADS
(J-1) Racketeering Act No. 20

In or about the Spring of 1979,
Southern
bistrict
of
Florida,
MARIO S.
TABRAtJE,
FRANCISCO
or
at Monroe County, in the
elsewhere,
QUINTANA,
a/k/ a
the
"PUPI"
defendants
and
JOSE
LABRADA, a/k/a JOE VULCANO, along with others known and unknown
to the grand jury, committed one or more of the following acts,

any one of which would constitute one act of racketeering:
(a)
knowingly
and
intentionally
combined,
conspired,
confederated and agreed with each other to import into the United
-n-
'
States, at Monroe County, Florida,
approximately
thousand
fifty
from a place outside thereof,
(50, 000)
pounds
of
marijuana,

States Code, Section 963; and
(b)
knowingly and intentionally did import into the United
States froro a place outside thereof approximately fifty thousand

(50,000) pounds of marijuana, a Schedule I
in
violation of Title
21,
United States Code,
Section 952
and
(c)
knowingly
and
intentionally
did
combine,
conspire,
confederate and agree with each other to possess with intent to
distribute
substance,
quantity
of
marijuana,
Schedule
controlled
846; and
{d}
knowingly and intentionally did possess with intent to
distribute
substance,
84lla) 11)
quantity
of
marijuana,
Schedule
controlled

IJ-2) Racketeering Act No. 21

In or about the Summer of
Southern
District
of
MARIO S.
TABRAUE,
FRANCISCO
LABRADA,
a/k/a
JOE
Florida,
VOLCANO,
1979,
and
at Monroe County,
elsewhere,
QUINTANA,
together
a/k/a
with
the
"PUPl"
others
in the
defendants
and
known
JOSE
and
unknown to the grand jury, committed one or more of the following

acts, any one of which would constitute one act of racketeering:
(a}
knowingly
and
intentionally
combined,
conspired,
confederated and agreed with each other to import into the Dnited
-22-
States, at Monroe county, Florida, from a place outside thereof,

at least fifty thousand
(50,000) pounds of marijuana, a Schedule
in violation of Title 21, Onited States
Code1 Section 963; and

(b)
knowingly
and
intentionally
imported
into
the
United
States, at Monroe County, Florida, from a place outside thereof,

at least fifty thousand
(50,000) pounds of marijuana,
in violation of Title 21, United States
controlled substance 1
Code, Section 952 and Title 18, United States
Code~
a Schedule
Section 2;
and
(c)
knowingly
and
intentionally
combined,
conspired,
confederated and agreed to possess with intent to distribute a

quantity
of
marijuana,
Schedule
controlled
substance,
in
violation of Title 21, United States Code, Section 846; and

(d}
knowingly
distribute
and
quantity

of
marijuana 1
substance, in violation of Title 21,
Schedule
intent
to
controlled
United States Code, Section
841(a) (ll and Title 18, United States Code, Section 2.

(J-3) Racketeering Act No. 22
From in or about November, 1979r until in or about December

1979, at Monroe County, in the Southern District of Florida, and
elsewhere,
the defendants MARIO S.
a/k/a "PUPI" and JOSE LAB'RADA,
TABRAUE,
FRANCISCO QUINTANA,
a/k/a JOE VULCANO,
together with
others known and unknown to the grand jury, committed one or more
of the following acts, any one of which would constitute one act
of racketeering:
-23-
(
knowingly
(a)
and
intentionally
combined,
conspired,
States, at Monroe County, Florida, from a place outside thereof,
approximately
fifty
thousand
(50,000)
pounds
Of
marijuana,

States Code, Section 963i and
(b)
knowingly
and
intentionally
imported
into
the United
States from a place outside thereof approximately fifty thousand

(50,000)
pounds of marijuana, a Schedule I controlled substance,
21,
United
States Code,
Section
952
and

(c)
knowingly
and
intentionally
conspired,
combined,
confederated and agreed with each other to possess with intent to

distribute
quantity
of
marijuana,
Schedule
controlled

846; and
(d)
distribute
knowingly
and
quantity

of
marijuana,
Schedule
intent
to
controlled
substance, in violation of Title 21, Dnited States Code, Section

84l(a) (1)
K.

THE ROUND HOUSE
(K-1} Racketeering Act No. 23

In or about the fall of 1979,
at Southern Dade County,
in
the Southern District of Florida, and elsewhere, the defendants,
MARIO
S.
TABRAUE,
JOSE
PEPE ACOSTA,
ANTONIO MUNIO
and
others
known and unknown to the grand jury, committed one or more of the
-24-
following
acts,
any one
of which
would
constitute
one act of
intentionally
combined,
conspired,
racketeering~
(a)
knowingly
and
States,
from a place outside thereof, a quantity of marijuana, a

(b)
knowingly
and
intentionally
combined,
conspired,
distribute
fourteen
thousand
{14,000)
pounds
of
marijuana,

States Code, Section B46; and
fourteen
distr~buted
knowingly and intentionally
{c)
thousand
controlled
(14,000)
substance,
pounds
of
in violation
marijuana,
of Title
21,
approximately
a
Schedule
United States
Code, Section 84l(a) (1) and Title 18, United States Code, Section
2.
(K-2) Racketeering Act No. 24
In or about November, 1979, at Southern Dade county, in the
Southern
District
of
MARIO S.
TABRAUE,
JOSE
Florida,
PEPE
and
ACOSTA,
elsewhere,
ANTONIO
the
MtJNIO
defendant,
and
others
known and unknown to the grand jury, committed one or more of the
following
acts,
any
one of which
would
constitute
intentionally
combined,
one
act of
racketeering:
(a)
knowingly
and
conspired,
States, from a place outside thereof, approximately thirty-eight
-25-
thousand
( 38,000}
substance,
a Schedule I
controlled
in violation of Title 21 1 United States Code, Section
963; and
knowingly
(b)
intentionally
and
combined,
conspired,

distribute thirty-eight thousand
{38,000} pounds of marijuana, a

{c)
knowingly
and
thirty-eight thousand
controlled
substance,
intentionally distributed approximately
(38,000)
in violation
of
Title
21,
United States
Code, Section 841(a) (1) and Title 18 1 United States Code 1 Section
2.

In or about December 1
1979, at Southern Dade county, in the
Southern District of Florida, and elsewhere, the defendant, MARIO

S. TABRAUE, JOSE PEPE ACOSTA, ANTONIO MUNIO and others known and
unknown to the grand jury, committed one or more o the following
acts, any one of which would constitute one act of racketeering:
{a)
knowingly
and
intentionally
combined,
conspired,
States,
from a place outside thereof, a quantity of marijuana, a

(b)
knowingly
and
intentionally
combined,
conspired,

distribute
twenty
thousand
(20,000)
-26-
pounds
of
marijuana,
Schedule I controlled substance 1 in violation of Title 21., United

States Code 1 Section 846; and
{c)
twenty
knowingly and
thousand
controlled
{20,000}
substance,
in
pounds
of
marijuana,
violation of Title
approximately
21,
Schedule
United
States
Code, Section 84l(a) (1) and Title 18, United States Code, Section
{K-4) Racketeering Act No. 26

In
or
about
the
Fall
of
1979,
at
Dade
County,
in
the
Southern District of Florida, the defendants 1 MIGUEL RAMIREZ and

together with others known and unknown to
the grand jury knowingly and intentionally possessed with intent
to distribute a quantity of marijuana,

substance,
84l(a) {1)
a Schedule I
controlled

In or about the early part of 1980, at Dade county, in the

Southern District of Florida, the defendants, MIGUEL RAMIREZ and
together with others known and unknown to
the grand jury, knowingly and intentionally possessed with intent

to distribute a quantity of marijuana,
substance 1
a Schedule I
controlled
84l(a) (1) and Title lB, United States Code, Section 2.

In or about Spring,
District
of
Florida,
the
1980 at Dade County,

defendant,
-27-
CARLOS
in the
Southern
PAZOS-SANTANA
and

\..
other individuals known and unknown to the grand jury, knowingly
and
intentionally
combined,
conspired,
confederated
and
agreed
with each other to possess with intent to distribute quantities

of marijuana, a Schedule I controlled substance, in violation of
In or about February, 1981, at Dade County, in the Southern
District
of
Florida,
the
defendant,
CARLOS
PAZOS-SANTANA,
together with others known and unknown to the grand jury, knowingly
and
quantity

of
marijuana,
Schedule
intent
to
controlled
distribute
substance,
violation of Title 21, United States Code, Section 84l(a} (1)
a
in
and

L.

THE LOUISIANA LOADS
(L-1) Racketeering Act No. 30

From in or about February of 1980 1
the exact date being unknown,
County,
through March of 1980,
at Lafayette, Louisiana,
and Dade
in the Southern District of Florida, and elsewhere,
the
defendant, MARIO S. TABRAUE and JOSE LABRADA, a/k/a JOE VOLCANO,
and
others known and unknown
intentionally combined,
each
other
marijuana,
to
the
conspired 1
to possess with intent

a
Schedule
controlled
grand
jury 1
knowingly
and
confederated and agreed with

to distribute
substance,
in
quantity of
violation
of
Title 21 1 United States Code, Section 846.

(L-2) Racketeering Act No. 31
From in or about April 1980 through May, 1980, at Lafayette 1
-28-
(
Louisiana, Dade County in the Southern District of Florida,
elsewhere,
the defendant,
MARIO S. TABRAUE,
JOSE LABRADA,
and
a/k/a
JOE VULCANO, MIGUEL RAMIREZ and others known and unknown to the
grand
jury,
knowingly
and
intentionally
combined,
conspired

distribute
substance,
quantity
of
marijuana,
Schedule
controlled
846.
M,

MIDDLE TORCH KEY SEIZURES
(M-1) Racketeering Act No. 32

In or about September 1980, at Monroe County, in the Southern District of Florida, and elsewhere, the defendant, FRANCISCO
QUINTANA, a/k/a "PUPI", together with others known and unknown to

the
grand
jury,
knowingly
and
intentionally imported
into
the
United States 1 from a place outside thereof, a quantity of marijuana, a Schedule I

21,
controlled substance, in violation of Title
United States Code, Section 952 and Title 18, United States
Code, Section 2.
(M-2) Racketeering Act No. 33
In or about September 1980, at Monroe and Dade Counties, in
the Southern District of Florida, and elsewhere, the defendant,
MARIO S.
TABRAUE and JOSE LABRADA,
a/k/ a JOE VULCANO,
together
with others known and unknown to the grand jury 1 knowingly and
intentionally possessed with intent to distribute a quantity of
marijuana,
Title 21,
Schedule
controlled
united States Code,
substance,
in
Section 84l(a) (1)
United States Code 1 Section 2.

-29-
violation of
and
Title 18,
(
N.
ACT OF RACKETEERING INVOLVING

NEW YORK
JN-ll Racketeering Act No. 34
the
In or about November, 1980, at New York and Dade County,
in
Southern
S.
District
of
Florida,
the
defendants,
MARIO
TABRAUE and CARLOS PAZOS-SANTANA, and others known and unknown to

the grand jury, knowingly and intentionally combined, conspired,
confederated and agreed with each other to distribute quantities
of marijuana, a Schedule I controlled substance, in violation of
0.

THE VESSELS "DOS HERMANOS" and "LOVE"
(0-1) Racketeering Act No. 35
In or about July, 1981, at Monroe County and Dade County, in
the
Southern
District
of
Florida,
and
elsewhere,
defendant,
MARIO S. TABRAUE, and others known and unknown to the grand jury,
knowingly and intentionally combined, conspired, confederated and
agreed
with
approximately
each
other
thirty
to
possess
thousand
with
(30, 000)
intent
pounds
to
of
distribute
marijuana,

States Code, Section 846.
(0-2) Racketeering Act No. 36
In or about September 1981, at Monroe County, in the Southern District of Florida,
TABRAUE,
ingly
agreed
and elsewhere,
the defendant, MARIO s.
and others known and unknown to the grand
and
intentionally
with
approximately
each
other
fifteen
combined,
to
possess
thousand
conspired,
with
{15,000)
-30-
know-
confederated
intent
pounds
jury 1
to
and
distribute
of marijuana;
(
States Code, Section 84l(a) (ll and Title 18, United States Code,
Section 2.
P.
ACTS OF RACKETEERING INVOLVING THE

VESSEL uW1NDJAMMERn
(P-1) Racketeering Act No. 37

Between in or about July, 1981 and November 1981, at Monroe
County in the Southern District of Florida,
and elsewhere,
the
defendant, FRANCISCO QUINTANA, a/k/a nPUPI'', together with others
known and unknown to the grand jury, knowingly and intentionally

did import into the united States,
in the Florida Keys_,
place outside thereof,
approximately
pounds
of
marijuana,
Schedule
fourteen thousand
controlled
from a
( 14,0 00}
substance 1
in
violation of Title 21, United States Code, Section 952 and Title
18, United States Code, Section 2.
(P-2) Racketeering Act No. 38
ln or about November, 1981, at Monroe County, in the Southern District of Florida, and elsewhere 1 the defendant, MARIO S.
TABRAUE,
jury,
erated
together with others- known
knowingly
and
and
and unknown
intentionally combined,
agreed with
each
other
distrib~te
approximately- fourteen
marijuana,
a Schedule I
controlled
to
-31-
grand
confed-
with
intent
to
{14,000)
pounds
of
substance,
the
conspired,
possess
thousand
to
in violation of
Q.
(Q-1)

THE VESSEL "C & R'1
Racketeering Act No.
39
In or about February and March, 1982 1 at Monroe Countyt in

the Southern District of Florida 1 and elsewhere 1 the defendant,
FRANCISCO QUINTANA,
a/k/a nPUPI"', together with others known and
unknown to the grand jury, knowingly and intentionally did import

into
the
United
from
States,
place
outside
thereof,
approximately twenty-two thousand (22,000) pounds of marijuana, a
Schedule I controlled substance, in violation of Title 21., United
States
Code,
Section
952
and
Title
18,
United
States
Code,
section 2.
!Q-2) Racketeering Act No. 40
In or about February and March 1 1982, at Monroe County,
in
the Southern Distr.ict of Florida, and elsewhere, the defendant,

MARIO
s.
TABRAUE, and others known and unknown to the grand jury,
knowingly
and intentionally possessed with intent to distribute
approximately twenty-two thousand (22,000) pounds of marijuana, a

Schedule I
controlled substance, in violation of Title 21, United
States Code, Section 841(a) (1)
and Title 18, United States Code,
Section 2.
R.
(R-1)

T!IE VESSEL "BLUE WATER"
From in or about June,

1983,
at Dade County,
elsewhere,
1982 through in or about February,
the defendants,
FRANCISCO QUINTANA,
a/k/ a
and
"PUPI'1 and
MARIO s. TABRAUE, and others known and unknown to the grand jury,
-32-
co-mbined 1 conspired, confederated and agreed with each other to

import
into
the
United
States,
from
approximately twenty-five thousand
Schedule
controlled
place
outside
thereof,
(25,000) pounds of marijuana;
substance,
in
violation
of
Title
21,
Florida 1
the
United States Code, Section 963.
S,

THE VESSEL "YENYA", A/K/A "GINGER"
(S-1) Racketeering Act No. 42

In
or
about March,
defendants,
'~PUPI",
MARIO
S.
1983,
TABRAUE
at Monroe
and
County,
FRANCISCO
QUINTANA,
a/k/a
together with others known and unknown to the grand jury 1
committed one or more of the following
acts,
any one of which
constitutes one act of racketeering:

(a)
knowingly
and
intentionally
combined,
conspired,
confederated and agreed to import into the United States, from a
place
outside
controlled
thereof,
substance,
Cadet Section 963;
(b)
quantity
of marijuana 1
21,
Schedule
United States
and
knowingly and intentionally imported into the United
States, from a place outside thereof, a quantity of marijuana, a
Schedule I controlled substance, as alleged in Count VI of this

indictment, which is incorporated herein by reference as if set
out in full; and
(c)
knowingly
confederated
and
marijuana,
Schedule
and
agreed
intentionally
to
possess
with
combined,
conspired,
intent
distribute
Title 21 1 United States Code 1 Section 846; and
-33-
to
in v-iolation of
(d)
knowingly and intentionally possessed with
intent to
distribute marijuana 1 as alleged in Count VII of this indictment,

which is incorporated herein by reference as if set out in full.
T.

THE DISTRIBUTION OF COCAINE
{T-1} Racketeering Act No. 43

In or about the beginning of 1977 1 at Miami 1 in the Southern
District
of
TABRAUE,
and others known
ingly
and
Florida,
and
intentionally
approximately
three
{3)
elsewhere,
and
unknown
defendant,
to the grand
possessed
with
kilograms
of
controlled narcotic substance,
the
intent
jury 1
to
cocainet
MARIO
S.
know-
distribute
Schedule
II
United
84l{a} (1) and Title 18, United States Code,
Section 2.
In
or
about
March,
1977,
in
Miami,
Dade
Southern District of Florida,
the defendant,
and others known and unknown
to
MARIO S.
the grand jury,
intentionally distributed approximately twenty
cocaine,
Schedule
lation of Title
21,
II
County,
narcotic controlled
United States Code,
the
TABAAUE 1
knowingly and
(20)
kilograms of
substance,
section
in
in vio-
84l(a) {1}
and
Title 18 1 United States Code, Section 2.

In or about May or June 1 1977, in Miami, Dade County 1 in the
Southern District of Florida 1
the defendant,
and others known and unknown
to the grand
intentionally
cocaine,
distributed
Schedule
II
approximately
narcotic
-34-
ten
MARIO S.
jury,
(10}
controlled
TABRADE,
knowingly and
kilograms
substance,
of
in
violation of Title 21, United States Code, Section B41{a) {1} and
Title lB, United States Code, Section 2.

{T-4) Racketeering Act No. 46
In
or
about
the
Spring of
Southern District of F1orida 1
19SO,
at
Dade
the defendant,
and others known and unknown to the grand
County,
MARIO St
jury,
in
the
TABRAUE,
knowingly and
intentionally did possess with intent to distribute approximately

eleven
(11)
kilograms
of cocaine,
Schedule II
narcotic
con-
trolled. substance, in violation of Title 21 1 United States Code,
Section 84l(a) (1) and Title 18, United States Code, Section 2.
In or about the Spring of 1980, but subsequent to Act No. 46
above,
at Dade County, in the Southern District of Florida, and
elsewhere, the defendants, MARlO S. TABRAUE, CARLOS PAZOS-SANTANA

and others
known and unknown to the grand
intentionally
kilograms
stance 1
of
did
possess
cocaine,
with
intent
Schedule
21,
II
to
jury,
knowingly and
distribute
narcotic
six
controlled
United States Code 1
(6)
sub-
Section
841 (a) (1) and Title 18, United states Code, Section 2.
(T-6) Racketeering Act No. 48
Between
County,
in
or
about
August
and
November,
defendant MARIO S.
1982,
at
and elsewhere,
Dade
the
TABRAUE and others known and unknown to the
grand jury 1
knowingly and intentionally did distribute not less
than
(7)
seven
controlled
kilograms
substance,
of
cocaine,
Schedule
-35-
II
narcotic
united States
(
Code, Section 84l{a) (1) and Title 18, United States Code, Section
2.
(T-71 Racketeering Act No. 49

From in or about June, 1983, until in or about July 1
at Dade County,
where,
the
defendant_,
MARIO
S.
'!'ABRAUE,
and
others
1983,
and elseknown
and
unknown to the grand jury, knowingly and intentionally combined,

conspired,
confederated and agreed with each other to distribute
approximately
twenty
(:20)
kilograms
narcotic controlled substance,
of
cocaine,
Schedule
II
United
States Code, Section 846.
(T-8 I Racketeering Act No. 50

In
or
about
the
Summer
of
1983,
at
Dade
County,
in
the
Southern District of Florida, and elsewhere, the defendant 1 MARIO

s. TABRAUB, and others known and unknown to the grand jury, know-
ingly and
intentionally did distribute a quantity of cocaine, a
Schedule Il narcotic controlled substance, in violation of Title
21 ,
United States Code,
Section 8 41 (a) ( 1 I and Title 18, United
2~

on or
and
ORLANDO
about February
CICILIA,
20,
1986 1
distributed
defendants MARlO s.
cocaine 1
as
alleged
TABRAUE
in
Count
VII! of this indictment, which is incorporated herein by reference as if set out in full.

On or about March 10,
1986, Defendants MARIO S.
ORLANDO CICILIA, distributed cocaine,
-36-
TABRAUE and
as alleged in Count IX of
(
this indictmeilt, which is incorporated herein by reference as if
set out in full.

On
or
about May
ORLANDO CICILIA,
7,
1986,
defendants MARIO
distributed cocaine,
S.
TABRAUE
and
as alleged in Count X of
this indictment, which is incorporated herein by reference as if

set out in full.
(T-13)
On
or
Southern
about
District
september
of
26 I
Florida
1986 r
and
at
Dade
elsewhere,
County I
defendant
in
the
ORLANDO
CICILIA knowingly and intentionally committed one or both of the
following acts, either one of which would constitute one act of

racketeering:
(a)
distribute
cocaine
as
alleged
in
Count
XI
of
this
indictment which is incorporated herein by reference as if set

out in full i and
{b)
travel act violation as alleged in count XIX of this
indictment which is incorporated herein by reference as if set

out in full.
J~-14)
On
or
about
October
24
1986,
the
defendants 1
MAR+O S.
TABRAUE, ORLANDO CICILIA and PHILIP EPSTEIN, distributed cocaine,
as alleged in Count XII of this indictment, which is incorporated
herein by reference as if set out in full.

On
TABRAUE
or
about
November
19,
and ORLANDO CICILIA,
198-6,
the
defendants,
MARIO s.
distributed cocaine as alleged in
Count XIII of this indictment,
which is incorporated herein by
reference as if set out in full.
-37-
U.

TRAVEL IN VIOLATION OF TITLE lS
UNITED STATES CODE, SECTION 1952(a) (3)
(0-l) Racketeering Act No. 57

The
May,
in
travel
1986
Cou~
by
act violation
defendant
involving travel to Indianapolis 1
ORLANDO
CICILIA
in
Indiana as alleged
XIV of this indictment, which is incorporated herein by

(0-2)

The
act
travel
violation by
January
22,
alleged
in Cou111t XV of
1986
involving travel
this
defendant ORLANDO
CICILIA on
to Boston, Massachusetts as
indictment,
which
is
incorporated

{U-3) Racketeering Act No. 59
The
travel
act violation
by
defendant ORLANDO
CICILIA on
June 5, 1986, involving travel to Honolulu, Hawaii as alleged in
Cou):tt XVI
of
this
indictment,
which
is
incorporated herein by
(U-4) Racketeering Act No. 60

The
travel
act
violation
by
defendant
ORLANDO
CICILIA
on
July 24, 1986 1 involving travel to Honolulu, Hawaii as alleged in

CouAtt XVII of this indictment,
which is incorporated herein by

(U-5) Racketeering Act No. 61
The
September
travel
18,
act
1986,
violation
involving
by
defendant ORLANDO
travel
to
Honolulu,
CICILIA on
Hawaii
as
alleged in Cout XVIII of this indictment, which is incorporated
-38-
v.
ACT OF RACKETEERING INVOLVING CONSPIRACY

IN VIOLATION OF TITLE 21, UNITED STATES
CODE, SECTIONS 841 (a) (1) ~0. 963 we.$
e_S
(V-1) Racketeering Act No. 62
Conspiracy
to
Sections B41(a) {1)
violate/
If'
r.S
~e 963,~as
Title
21,.
United
alleged in Count
States
Code,
of this indict-
ment, which is incorporated herein by reference as if set out in

full.
W.

OBSTRUCTION OF JUSTICE
(W-1) Racketeering Act No. 63

On or
about November
District of Florida,
20,
1986,.
at Miami,
the defendant, MARIO
S~
in the Southern
TABRAUE,
committed
either one or both of the following acts of racketeering, either

one of which would constitute one act of
(a)
the obstruction of justice,
1986, as alleged in Count
X~
racketeering~
on or about November 20,
of this indictment, which is incor-
porated herein by reference as if set out in full; and,

(b}
witness tampering, on or about November 20,
1986,
as
alleged in Count XXI of this indictment which is incorporated by

OVERT ACTS
In furtherance of the aforesaid conspiracy,

the
objects
thereof,
in
and
to effect
the Southern District of Florida,
and
elsewhere, one or more of the defendants committed and caused to

be committed one or more of the following overt acts:
1.
In or about 1976,
at Dade County,
Florida, defendant,
GUILLERMO TABRAUE, SR., introduced Jose Luis Acosta to Colombian

sources of marijuana.
-39-
2.
In or about 1976,
GUILLERMO TABRAUE 1 SR.
at Dade County,
Florida, defendant,
introduced Oscar Oliva Cantu to Jose Luis
Acosta and defendant FRANCISCO QUINTANA, a/k/a "PUPI".

3.
In
or
about
the
Summer
of
1976,
at
Dade
County,
Florida, defendants, MARIO S. TABRAUE and GUILLERMO TABRAUE, SR.,

received $800,000 in cash from osCar Oliva Cantu, at the Tabraue
jewelry store on Flagler Street, in Miami, Florida, in connection
witb the sale of eight thousand (8,000) pounds of marijuana.
4.
in
Dade
From in or about December 1976,
County,
defendants,
Florida,
GUILLERMO TABRAUE,
Oscar Oliva Cantu,
through January 1977,
MARIO
S.
TABRAUE
and
SR., received at least $500,000 in cash from
at the Tabraue Jewelry store,
in connection
with the sale of seven thousand (7,000) pounds of marijuana.
5.
TABRAUE,
In
or
SR.,
about
the
introduced
fall
of
Carlos
1976,
Enrique
defendant,
GUILLERMO
Botero
defendant
to
MARIO S. TABRAUE.
6.
TABRAUE,
In or about the beginning of 1977, defendant, MARIO S.

received
three
(3)
kilograms
of
cocaine
Enrique Botero at the parking lot of Tabraue' s
from
Carlos
jewelry store in
Miami, Florida.
7.
received
In or about March,
twenty
{20}
1977,
kilograms
of
defendant,
cocaine
Botero at the parking lot of Tabraue' s
MARlO s.
from
Carlos
TABRAUE,
Enrique
jewelry store in Miami,
Florida.
8.
TABRAUE,
In or about March or April,
sold
twenty
(20)
kilograms
Cantu.
-40-
1977 1
of
defendant,
MARIO
s.
cocaine to Oscar Oliva
(
9,
In or about April, 1977, subsequent to Overt Act No. 8,
defendants, MARIO S. TABRAOE and GUILLERMO TABRAUE, SR., received

$600,000 in cash from Oscar Oliva Cantu,
store
in
connection with
the
sale
of
at the Tabraue jewelry
twenty
(20)
kilograms
of
cocaine.
10.
In or about April, >977,
introduced
Carlos
Enrique
defendant, MARIO S.
Botero
to
Oscar
Oliva
TABRAUE,
Cantu
and
received a fee from each of them for the introduction.

11.
In
arranged
for
or
about May,
the
sale
of
1977,
ten
defendant,
{10}
MARIO S.
kilograms
of
TABRAUE,
cocaine
from
carlos Enrique Botero to Oscar Oliva Cantu.

12.
ln
TABRAUE,
or
about
received
the
Summer of
approximately
1977,
defendant,
twenty-five
thousand
MARIO
S.
{25,000)
pounds of marijuana from Jesus Carnet at a farm in Dade County,

Florida.
13~
In or about the Summer of 1977,
TABRAUE,
delivered
approximately
defendant,
t~enty-five
thousand
MARIO S ..
{25,000)
pounds of marijuana to Jose Antonio Fernandez and Gerardo "Tinon
Guevara at a farm in Dade County, Florida.

14.
No.
In or about the summer of 1977, subsequent to Overt Act
13,
defendant,
MA~IO
S.
TABRAUE,
received
payment
of
approximately $1,000,000 in cash from Jose Antonio Fernandez and

Gerardo
11
Tino"
Guevara
in
connection
with
the
sale
and
dis-
tribution of twenty-five thousand (25,000) pounds of marijuana.

15.
In or about the Summer of 1977, subsequent to Overt Act
No. 14, Jose Antonio Fernandez paid defendants, MARIO S. TABRAUE

and GUILLERMO TABRAUE,
SR.,
approximately $3,500 1 000
in cash in
several installments in connection with the sale and distribution

of twenty-five thousand (25,000) pounds of marijuana.
16.
No.
In or about the Summer of 1977, subsequent to Overt Act
15, defendant, GUILLERMO TABRAUE, SR., met with Jose Antonio
Fernandez at Fernandez' home.

17~
Between the Fall and end of 1977 1
TABRAUE,
arranged
(40 ,000}
pounds of marijuana from Jesus Carnet to .Jose Antonio
Fernandez,
for
delivery of
defendant, MARIO S.
approximately
forty
thousand
Gerardo "Tinon Guevara and Robert Govern at a farm in
Loxahatchee, Florida.
18.
Act No.
Between the Fall and end of 1977,
17,
Jose Antonio Fernandez
subsequent to Overt
and Gerardo
"Tinofl
Guevara
paid to defendants, MARIO S. TABRAUE and GUILLERMO TABRAUE, SR.,

approximately $7,000,000 in cash in several installments.
19.
Between the Fall and end of 1977,
subsequent to Overt
Act No. 17, defendant, GUILLERMO TAERAUE, SR., received $450,000

in
currency
from Jose Antonio Fernandez
at
Fernandez'
home
in
Dade County, Florida.

20.
dants,
Between the Fall of 1977

MARIO S.
and
the end of 1977,
TABRAUE and GUILLERMO TABRAUE,
SR.,
defen-
employed a
then City of Miami police officer, to assist them in collecting

and
counting
the
money
received
in
connection
with
the
dis-
tribution of marijuana.
21.
In
1977,
defendant
GUILLERMO
TABRAUE,
Gustavo Fernandez, a boat captain, to Jose Luis

22.
Between November,
1977 and December,
SR.
introduced
Acosta~
1977 1
defendant 1
MARIO S. TABRAUE, made arrangements with Jose Luis Acosta for the
-42-
(
off-loading
and
transfer
of at
least
twenty
thousand
(20, 000)
pounds of marijuana from a ' 1mother ship!!" located in the Gulf of
Mexico to a location in or about Crystal River 1 Florida.

23.
22,
In or about December, 1977, subsequent to overt Act No.
defendant,
MARIO
s.
TABRAUE,
sold
five
thousand
(5,000)
pounds of marijuana to Oscar Oliva Cantu at the parking lot of
the Tabraue jewelry store in Miami,

24.
Between December,
Florida~
1977 and January,
Cantu paid defendants, MARIO S.
197S 1
Oscar Oliva
TABRAUE and GUILLERMO TABRAUE,
SR., $500,000 cash at Tabraue 1 s jewelry store, in Miami, Florida,

in connection with the sale of five thousand
(5,000)
pounds of
marijuana ..
25.
travelled
In
to
or
about
December,
Baranquilla 1
1977 1
Colombia
Carlos
on
behalf
Enrique
of
Botero
defendant
MARIO s. TABRAUE for the purpose of purchasing and importing into

the United States,
at least fifteen thousand (15,000)
pounds of
marijuana.
26.
In or about January, 1978 1 Oscar Oliva Cantu delivered
four vans to defendant, MARIO s. TABRAUE, in connection with the

distribution of ten thousand (10,000) pounds of marijuana.
27.
In or about January, 1978, subsequent to Overt Act No.
26, defendant, MARIO s. TABRAUE,
imported approximately fifteen
thousand (15,000) pounds of marijuana into the United States.

28.
In or about January or February,
1978, subsequent to
Overt Act No. 27, Oscar Oliva Cantu met with defendant, GUILLERMO
TABRAUE, SR., to discuss the fifteen thousand (15,000) pounds of
marijuana imported by defendant MARIO s. TABRAUE.
-43-
(
29.
In or about January, 1978, defendant, MARIO S. TABRAUE,
delivered to Oscar Oliva Cantu approximately one thousand eight
hundred (l,BOO} pounds of marijuana.

30.
In or about January, 1978, defendants, MARIO S. TABRAUE
SR.,
instructed Oscar Oliva Cantu to pay
Carlos Enrique Botero approximately $100,000
with
the
distribution
of
one
thousand
cash in connection
eight
hundred
(1,800}
pounds of marijuana.
31.
dant,
Sometime between January, 1978 and April, 1979, defen-
MARIO
$150,000
S.
TABRAUE,
paid
Gustavo
Fernandez
approximately
in cash for the purpose of bribing police officers in
Monroe County, Florida and obtaining their protection during the

off-loading of approximately thirty thousand
(30, 000)
pounds of
marijuana.
32.
Sometime between January, 1978 and April, 1978, Gustavo
Fernandez paid approximately $170,000 to various police officers

ih Monroe County,
Florida,
including police lieutenant,
Raymond
Casarnayor.
33.
In or about April,
1978,
defendant,
received approximately ten thousand
(10,000}
MARIO 5.
TABRAUE,
pounds of marijuana
from Gustavo Fernandez.

34.
dant,
Between in or about May,
MARIO S.
twenty
TABRAUE,
thousand
(20 1 000)
arranged
pounds
1978 and July,
for the
of
1978,
defen-
sale of approximately
marijuana
from
Jose
Luis
Acosta to Oscar Oliva Cantu.

35.
arranged
In or about July,
for
the
sale
of
1978,
defendant,
approximately
-44-
MARIO
S.
seventeen
TABRAUE 1
thousand
(
(17,000) pounds of marijuana from Jose Luis Acosta to Oscar Oliva
Cantu.
36.
paid
Between May, 1978 and October, 1978, Oscar Oliva Cantu
defendants,
MARIO S.
TABRAUE
SR.,
approximately $6,000,000 in cash in connection with the purchase

of thirty-seven thousand
pounds of marijuana from Jose
(37r000)
Luis Acosta.
3?.
a/k/a
In or about July, 1978, defendants FRANCISCO QUINTANA,

"PUPI"
approximately
and
JOSE
fifty
LABRADA,
thousand
a/k/a
JOE VULCANO,
pounds
(50,000)
of
off-loaded
marijuana
at
Appollo Beach, Florida.

38.
In or about July, 1978, subsequent to Overt Act No. 37,
defendant,
MARIO
s~
TABRAUE,
received
quantity of marijuana
from defendant, FRANCISCO QUINTANA, a/k/a "PUP!'.

39.
TABAAUE,
In
or
about
the
end
of
1978,
Defendant,
MARIO
S.
arranged for the sale and delivery of at least twen-
ty-nine thousand
(29, 000)
of marijuana
pounds
to Jose Antonio
Fe:t;nandez, Gerardo ,.Tinou Guevara and E.obert Govern at a farm in
Loxahatchee, Florida.
40.
In or about the end of 1978,
subsequent to Overt Act
No. 39, defendants, MARIO S. TABRAUE and

received
approximately
$5,000,000
in
GUILLE~ID
cash
from
TABRAUE, SR.,
Jose
Antonio
Fernandez and Gerardo hTino" Guevara.

41.
In
or
about
the
end
of
1978,
defendant,
MARIO
S.
TABRAUE, paid James Ricky Brown approximately $10,000 for assisting
him
in
the
counting,
sorting
-45-
and
distribution
of
cash
collected by defendant, MARIO S. TABRAUE 1 in connection with the

sale of marijuana.
42.
Between
defendant,
United
the
end
of
1978
FRANCISCO QUINTANA,
States,
at
and
a/k/ a
Islamorada,
the
beginning
"PUPI",
Florida,
of
imported
at
least
1979,
into
the
twenty-five
thousand (25,000) pounds of marijuana.

43.
Between
subsequent
to
the
end
Overt Act
of
No.
1978
42,
and
the
beginning
defendant,
MARIO
of
S.
1979,
TABRAUE,
arranged for the delivery of approximately five thousand
(5,000)
pounds of marijuana, in Dade County, Florida.

44.
Between
the
subsequent
to Overt
direction
and
end
of
Act No.
supervision
1978
43,
of
James
of
marijuana
and
the
beginning
Ricky
defendant,
collected the money due from the
pounds
and
of
Brown,
MARIO
under
S.
that
money
the
TABRAUE,
sale of five thousand
delivered
1979,
to
(5 ,000}
defendant,
FRANCISCO QUINTANA, a/k/a "PUPI".

45.
In or about the Spring of 1979, defendant,
FRANCISCO
QUINTANA, a/k/a "PUPI"; arranged for the use of a large house in
Islamorada,
Florida,
as
stash
house
for
the
purpose
of
importing marijuana into the United States (hereinafter referred

to as the Acapulco house),
46.
QUINTANA,
In or about the Spring of 1979 1 defendants, FRANCISCO

a/k/a
off-loaded
"PUPI"
and
approximately
JOSE
fifty
LABRADA,
thousand
a/k/a
JOE
(50,000)
VULCANO,
pounds
of
marijuana at the Acapulco house in Islamorada, Florida.

4 7.
TABRAUE,
In
or
about
received
the
Spring of
approx~ately
-46-
1979 1
defendant,
twenty-five
thousand
~.ARIO
S~
(25,000)
pounds
of
marijuana
from
defendant,
FRANCISCO
QUINTANA,
a/k/ a
"PUPI", at the Acapulco house in Islamorada, Florida.

48.
In or
about
the Spring of
1979,
defendant,
MARIO
S.
TABRAUE, received approximately 2.2 million dollars in connection

with
the
distribution
of
approximately
twenty-two
thousand
In or about the Su:mmer of 1979, defendants,
FRANCISCO
(22,000} pounds of marijuana.

49.
QUINTANA,
a/k/a
"PUPI"
and
JOSE
LABRADA,
off-loaded at least fifty thousand
at the Acapulco house in Islamorada

JOSE LABRADA,
50,
a/k/a
(50,000}
1
JOE
VOLCANO,
pounds of marijuana
Florida.
a/k/a JOE VULCANO,
paid $100,000 to to
Eduardo Macias.
51.
In or
TABRAUE 1
pick-up
about
arranged
for
approximately
the Sununer of
drivers
in
twenty-five
1979,
defendant,
campers
and
thousand
MARIO S.
mobile homes
(25,000)
pounds
to
of
marijuana from defendant FRANCISCO QUINTANA, a/k/a pupr at the
Acapulco house in Islamorada 1 Florida.

52.
Between
defendants,
JOE
a/k/a
in
or
about
FRANCISCO QUINTANA,
VULCANO,
November
a/k/ a
off-loaded
and
"PUPI
December~
1979,
and JOSE LABRADA,
approximately
fifty
thousand
(50,000) pounds of marijuana at the Acapulco house in Islamorada,

Florida.
53.
Between
in
or
about
November
and
December,
1979,
defendant, MARIO S. TABRAUE, arranged for drivers in campers and

mobile
homes
(25, 000)
a/k/a
to
pick-up
approximately
twenty-fi\re
thousand
pounds of marijuana from defendant FRANCISCO QUINTANA,
PUPI'1 , at the Acapulco house in Islamorada,
-47-
~lorida.
(.
54.
Between the Spring of 1979 and December,
1979 1
de fen-
dant, MARIO S. TABRAUE, paid approximately $2 per pound to stash

marijuana at a small farm located in South Dadef Florida.
55.
In
TABRAUE,
or about the
Spring
of
1979,
defendant,
MARIO
s.
leased a farm, known as the "Round Housesfl, located in
southern Dade County, for the purpose of storing marijuana.

56.
Between
the
Fall
Defendants ANTONIO MUNIO,
a/k/ a
"'FLACO"
and
57.
TABRAUE,
In
JOSE
or
about
loaded
and
the
and
unloaded
the
Fall
of
1979,
of
1981,
quantities
defendants
PEPE ACOSTA and ANTONIO MUNIO,
the "Round Houses 11
Spring
of
Housesn~
approximately fourteen thousand
58.
1979
JOSE PEPE ACOSTA and LUIS VALDESUSO,
RECITO"
marijuana at the nRound
of
(14,000)
MARIO
S.
took possession of
pounds of marijuana at
In or about the Fall of 1979, subsequent to overt Act
No. 56, defendant, MARIO S. TABRAUE, sold approximately fourteen

thousand (14,000) pounds of marijuana, for approximately $235 per
pound.
59.
TABRAUE,
In
or
about
November,
1979,
defendants
MARIO
S.
JOSE PEPE ACOSTA and ANTONIO MUNIO took possession of
approximately thirty-eight thousand
(38,000)
pounds of marijuana
at the "Round Houses".

60.
In or about November, 1979r subsequent to Overt Act No.
59, defendant, MARIO s. TABRAUE, sold approximately thirty- eight
thousand
(38,000)
pounds of marijuana for approximately $235 per
pound.
-48-
61,
In or
SANTANA
about
November,
and MIGUEL RAMIREZ
(10,000)
defendants
received approximately
pounds of marijuana from defendant M;_RIO
the "Round Houses 0

62.
In
TABRAUE,
1979,
or
C.I>.RLOS
ten
S~
PAZOS-
thousand
TABRAUE at
about
December,
1979,
defendants
MARIO
S.
ANTONIO MUNIO and JOSE PEPE ACOSTA took possession of
approximately twenty thousand {20 1 000) pounds of marijuana at the

"Round Houses".
In
63~
TABRAUE,
or
sold
about
December,
1979(
defendant,
approximately twenty thousand
MARIO
{20, 000)
S.
pounds of
marijuana, for approximately $235 per pound.

64.
MA.R10
Between the Fall of 1979 and December, 1979, defendant 1
s.
TABRAUE,
connection
with
received approximately $14,000,000
the
sale
of
approximately
in cash in
sixty
thousand
(60,0000) pounds of marijuana,

65.
11
PUPI"
During
1979,
and MARIO s.
$200,000
to
defendants,
TABRAUE 1
obtain
and
~Rhl,CISCO
paid Eduardo Macias
operate
various
a/k/a
QUINTANA,
boats
in excess of
used
for
the
off-loading of marijuana into the United States.

~rom
66.
defendant,
the Fall of 1979, until at least the end of 1979,
MARIO S.
TABRAUE,
had City of Miami police officers
assist him in collecting r counting and disbursing large amounts
of
currency
received
in
connection
with
the
distribution
of
marijuana.
67.
MIGUEL
In or about December 1 1979 or January, 1980, defendants

RAMIREZ,
EDUARDO
~ERNANDEZ-CARDULI
met at the "Round Houses."
-49-
and MARIO
S,
TABRAUE
(
68.
Between in or about late 1979 and the Winter of 1980 1
defendants MARIO S. TABRAUE, JOSE PEPE ACOSTA, ANTONIO MUNIO and
others travelled from Miami to
69.
MARIO
Between
S.
February,
TABRAUE 1
travelled
James
charter
by
Ne~
1980
Ricky
jet
York with firearms.
and
April?
Brown,
from
Juan
ort
1980,
defendant,
Medina
and
Lauderdale,
others
Florida
to
Lafayette, Louisiana.
70.
Between February, 1980 and April, 1980, defendant JOSE
LABRADA, a/k/a JOE VULCANO travelled to Louisiana for the purpose

of distributing marijuana.
71.
Between February,
Overt Act No.
69,
1980 and April,
defendant, MARIO S.
1980,
TABRAUE,
subsequent to
arranged far the
sale of approximately three thousand {3,000) pounds of marijuana,

located in Louisiana.
72.
In or about February or March,
PAZOS-SANTANA and MIGUEL RAMIREZ
1980, defendant CARLOS
received
pounds of marijuana from defendant MARIO
S~
five
thousand
(5,000)
TABRAUE at the "Round
Houses."
73.
In or
about
the
Spring
of
1980 1
defendant,
MARIO
s.
TABRAUE 1 received approximately eleven (11} kilograms of cocaine,

as
payment
for
approximately
three
thousand
( 3, 000}
pounds
of
marijuana.
74.
No.
73,
In or about the Spring of 1980, subsequent to Overt Act

defendant
CARLOS
PAZOS-SANTANA
possessed
approximately
six (6} kilograms of cocaine.

75.
In
or
about May,
1980,
defendant,
MARIO
S.
arranged for the sale of marijuana located in Louisiana.
-so-
TABRAUE 1
76.
MA.RIO
In or about May,
S.
charter
TABRAUE 1
jet
James
from
1980, at the direction of defendant,
Ricky
Fort
Brown,
and
Lauderdale,
others
Florida
by
travelled
to
Lafayette,
Louisiana.
77.
In
JOSE LABRADA 1
or
about
May,
a/k/a JOE VULCANO 1
purpose of distributing
78.
On
travelled
1980,
or
about
defendants
RAMIREZ
and
travelled to Louisiana for the
marijuana~
May
16,
1980,
defendant
from Louisiana to Mississippi with
sixteen thousand (16,000) pounds of

79.
MIGUEL
MIGUEL
trucks
RAMIREZ
containing
marijuana~
On or about May 16, 1980, defendant JOSE LABRADA, a/k/a
JOE VULCANO, travelled from Louisiana to Alabama in a motor home

containing two large scales 1 five handguns and one machine gun.
80.
On or about May 23, 1980, defendant, MARIO S. TABRAUE
and others
arranged to pay,
in cash,
$400,000 in fines for the
release of defendant MIGUEL RAMIREZ and other individuals after
their arrests in Mississippi.

81.
about
From in or about the beginning: of 1980,

the
middle
of
1980,
supplied defendant MARIO
s.
defendant
EDUARDO
through in or
FERNl\NDEZ-CARDULI
TABRADE and James Ricky Brown with
firearms including two automatic pistols.

82.
on or about June 12, 1980, defendant EDUARDO FERNANDEZ-
CARDULI meet with Larry Nash,
a confidential informant,
for the
purpose of discussing the sale of machine guns.

83.
On or about July 11, 1980, defendant EDUARDO FERNANDEZ-
CARDULI met with Larry Nash at EDUARDO FERNANDEZ-CARDULI's borne.
-51-
(_
84.
and
On
EDUARDO
or
about
July 15,
FERNANDEZ-CARDULI
1980,
met
defendants MIGUEL
with
Larry
at
Nash
RAMIREZ
EDUARDO
FERNANDEZ-CARDULI's home in Miami, Florida.

SS.
On
or
Larry Nash was
and MIGUEL
about July
murdered by
RAMIREZ
with
15,
1980,
in Dade County,
Florida,
defendants EDUARDO FERNANDEZ-CARDULI
two .shots
from
. 38 0
Barretta
semi-
automatic gun registered to defendant EDUARDO FERNANDEZ-CARDULI 1
in
an
automobile
being
driven
by
and
belonging
to
defendant
MIGUEL RAMIREZ.
86.
In or about July, 1980, subsequent to Overt Act No. 85,
defendants MARIO S. TABRAUE, CARLOS PAZOS-SANTANA, ANTONIO MUNIO

and JOSE PEPE ACOSTA,
assisted in the mutilation,
cremation and
disposal of Larry Nash's body.

87.
In
July,
1980,
subsequent
to
Overt
Act
No.
85,
the
vehicle in which Larry Nash was shot and killed was brought to
the residence of a
individual known to the grand jury,
for the
purpose of removing blood from the interior of the car.

88.
In
July,
19BO,
subsequent
to
Overt
Act
No.
87,
the
automobile in which Larry Nash was shot and killed was moved to
the residence of James Ricky Brown at which time efforts to clean

the car
89.
continued~
At
the
direction of
defendant MARIO
S.
TABRAUE,
the
vehicle in which Larry Nash was shot and killed, was ultimately
sold.
90.
In
or
about
September,
1980,
defendant
FRANCISCO
QUINTANA, a/k/a "PUPI" imported into the United States, at Middle
-52-
Torch
Key
or
Big
Pine Key,
approximately
twenty-five
thousand
{25,000) pounds of marijuana.
91.
In
or
about
September,
1980 1
defendants
MARIO
S.
TABRAUE and JOSE LABRADA, a/k/a JOE VULCANO, arranged for drivers
F~~CISCO
in vans to pick-up marijuana from defendant
QUINTANA,
a/k/a "PUPI" and deliver it to the nRound Bousesn.
9 2.
ln or about September 1
1980,
but subsequent to Overt
Act No. 91, defendants FRANCISCO QUINTANA, a/k/ a "PUPI" , MARIO S,

TABRAUEI
ana
Medina,
Juan
met
at
11
the
Round
Houses"
for
the
purpose of inspecting the marijuana received by defendant MARIO

S. TABRAUE.
93.
In or about September, 1980, defendant MARIO s. TABRAUE
purchased shares in Damar a, Inc., N. V., an offshore corporation.

94.
In
or about November 1
1980,
defendants
CARLOS
PAZOS-
SANTANA and MARIO S. TABFAUE met in New York City.
95.
In or about November
1980,
Defendants CARLOS PAZOS-
SANTANA ana MARIO s. TABRAUE distributed a quantity of marijuana
in New York City.

96.
1981,
In or about January, 1981 or the beginning of February,

the
Florida to
97.
defendant
MARIO s.
Scottsdale~
Arizona.
In
or
about
February,
1981,
defendant
MARIO S.
located at 7025
January,
defendant
S.W~
TABRAUE
TABRAUE
ANTONIO
(known
travelled
1981,
or
MUNIO
as
the
the
leased
Miami,
beginning
a
"Playboy
BOth Street, Miami, Florida.
-53-
from
house
of
for
Mansion"),
98.
On or about February 6, 1981, defendants ANTONIO MUNIO
and JOSE PEPE ACOSTA met with Maria Tabraue at her apartment in
Coral Gables 1 Florida.
99.
On or about February 6, 1981, defendants ANTONIO MUNIO
an.d JOSE PEPE ACOSTA shot and killed Maria Tabraue at her apart-
ment.
On or about April, 28, 1981, defendant MARIO s. TABRAUE
100.
arranged for $650 1 000 in United States currency to be deposited

in an offshore bank. in Aruba,
to the account of Damar a,
Inc.,
N.V., an offshore corporation.

101
In
or
about July,
1981,
Jose
imported approximately thirty thousand

juana into the United States,
vessels
102.
received
11
Luis Acost.a and

(30,000}
at Key Largo,
others
pounds of mari-
Florida,
using the
Happy Time" and nDos Hermanos".

In
from
or
about
Jose
July 1
Luis
1981,
Acosta
defendant
approximately
MARIO
S.
TABRAUE
twenty
thousand
(20,000) pounds of marijuana.

103.
others,
In
or
imported
about
into
September,
1981 1
the
States
United
Jose
Luis
Acosta
approximately
thousand ( 15 1 000) pounds of marijuana, using the vessel

104.
Between
FAANC!SCO QUINTANA,
July,
1981
a/k/a "PUPI 11
and
1
November 1
1981,
and
fifteen
"Love~"~.
defendant
Juan Medina and Eduardo Macias
arranged for the importation of fourteen thousand (14,000} pounds

of marijuana into the United States 1 off Sugar Loaf Key, Florida,
using the vessels "Windjammer", "Veness a" and "Little John".

105.
In or about November, 1981, defendants MARIO s. TABRAUE
and FRANCISCO QUINTANA, a/k/a "PUPI" met at FRANCISCO QUINTANA's
-54-
house,
during
thousand
which
(14,000)
arrangements
pounds
of
for
the
marijuana
payment
of
defendant
by
fourteen
MARIO
S.
TABRAUE were discussed.

106.
In
or
about
F'ebruary
FRANCISCO QUINTANA, a/k/a

imported
into
approximately
the
United
twenty-two
or
~pupr,_Eduardo
States
thousand
at
19S2,
March,
defendant
Macias and Juan Medina
Sugar
Loaf
(22, 000)
Florida~
Key,
pounds
of marijuana
using the vessel "C & R".
In
107.
or
QUINTANA, a/k/ a
Watern
travel
thousand
about
11
to
(25 1 000)
June,
1982,
the
defendant,
FRANCISCO
PUPI", had Eduardo Macias and the vessel "Blue

Barranquilla,
Colombia
to
pounds of marijuana for
twenty-five
obtain
importation into the
United States,
Between August and November,
108.
TABRAUE distributed between seven
{7)
defendant MARIO S.
1982,
and ten
(10}
kilogra..TO.s of
cocaine to individuals known to the grand jury.
109.
On or about the beginning of 1983,
CICILIA was employed by defendant !'.ARlO
store 1
Pets
Unlimited,
Inc.
located on
s.
defendant ORLANDO
TABRAUE,
27th Avenue
at his pet
in Miami,
Florida.
110.
defendant
In or about March,
FRANCISCO QUINTANA,
19 83,
a/k/a
Eduardo Macias was hired by

"PUPI"
to
off-load
sixteen
thousand (16{000) pounds of marijuana from a Mexican shrimp boat

off the coast of the Yucatan
Peninsula for importation into the
United States.
-55-
Between
111.
defendant
MARIO
in
S.
or
about
TABRAUE
June,
1983
received
and
July,
approximately
1983,
the
twenty
(20)
kilograms of cocaine.
112.
Between
in
or
about
June,
1983
and
July,
defendant MARIO S. TABRAUE sold approximately twenty
1983,
(20)
the
kilo-
grams of cocaine to individuals known to the grand jury.

113.
In or about July,
JOE VULCANO,
1983, defendant JOSE LABRADA,
was employed by defendant MARIO S.
a/k/a
TABAAUE at his
pet store, Pets Unlimited, Inc., located on 27th Avenue in Miami,

Florida.
114.
TABRAUE
In
or
about
distributed
the
Summer
quantities
of
of
1983,
defendant
cocaine
to
MARIO s.
defendant
LUIS
VALDESUSO, a/k/a "FLACOv or JlRECITO".

115.
In or
about
the
Summer
of
1983,
TABRAUE sold between two {2} and three
(3)
defendant
MARIO
S.
kilograms of cocaine
to an individual known to the grand jury.

116.
and James
TABRAUE,
collateral
In or about the Summer of 1983, defendant ANTONIO MUNIO
Ricky Brown,
removed
for
at the
jewelry
payment
of
direction of
defendant MARIO S.
from
an
individual's
two
(2)
to
three
(3)
residence,
as
ltilograms
of
cocaine.
117.
In
or
about
August
or
September,
1983,
defendant
MARIO s. TABRAUE sold Raymond Van Nostrand a kilogram of cocaine

for thirty-two thousand dollars
llB.
PORTUONDO
TABRAUE 1 s
In
the
and
($32,000).
Summer of 1984,
MARIO S.
pet business,
TABRAUE
defendants JOSE LABRADA,

met
Pets Unlimited r
-56-
at
defendant
lnc.
JUAN
MARIO S.
d/b/a Zoological
Imports
Unli.tni.ted
Imports},
(hereinafter
located at 3075 S.W.
referred
to
39th Avenue,
as
Zoological
in Miami,
Florida,
for the purpose of weighing and cutting cocaine.
119.
Xn
late
1984,
defendant
JOSE
LABRADA,
a/k/a
JOE
\nw.LCANOf distributed quantities of cocaine to an individual known

to
the
grand
j:ury
at
defendant
S~
MARIO
TABRAUE f s
business,
Zoological Imports.
120.
In or about January,
1985, defendant MARIO S.
pistol~
gave Jose Martinez, an employee of his, a .45 caliber

121.
In or about April or May,
1985,
TABRAUE
several grocery bags
full of money were delivered to defendant MARIO S. TABRAOE at his

residence at 3940 Douglas Road, Miami, Florida.
122.
8~
Between January,
TABRAUE
~as
in
1985 and July,
possession
of
1985 1 defendant MARIO
suitcases
filled
with
large
amounts of currency at his residence at 3940 Douglas Road 1 Miami 1
Florida.
123.
In or about April, 1985, defendant, MARIO
S~
TABRAUE,
was in possession of approximately twenty (20) pounds of cocaine

at his residence at 3940 Douglas Road, Miami, Florida.
124.
S.
Between .January,
TABRAUE
used
four
1985
safes
and July 1
located
in
1985 1
his
defendant MhRIO
residence
to
store
large amounts of cash.

125.
Between
January,
1985
and
December,
1987,
defendant
MARIO S. TABRAUE was in possession of two machine guns 1 rifles,

shotguns
and
other
firearms
at
his
Douglas Road, Miami, Florida.
-57-
residence
located at
3940
\"'
In or about March, 1985, defendant ORLANDO CICILIA met
126.
with individuals,
known to the grand
the
discussing
purpose
of
jury, at his residence for
distribution
of
cocaine
in
the
Indianapolis area.
127.
Between
defendant
in
ORLANDO
individuals
or
about
CICILIA
krJoWn
to
May,
1985
delivered
grand
the
and
September,
quantities
for
jury 1
of
1986,
cocaine
distribution
to
in
Indianapolis, on approximately ten separate occasions.

128.
In or about November 1
1985,
defendant ORLANDO CICILIA
met with individuals 1 known to the grand jury 1 for the purpose of
discussing the quality of cocaine being distributed.
129.
ORLANDO
Between April,
CICILIA,
1985 and the Summer of 1986, defendant
received
kilogram
quantities
of
cocaine
from
defendant MARIO S. TABRAUE and stored it in his residence at 3825
s.w.
132nd Avenue, Miami, Florida.
130.
During the Spring and Summer of 1985, defendant ORLANDO
CICILIA distributed quantities of cocaine to an individual known

to the grand jury,
for delivery to Cleveland, Ohio,
on approxi-
mately six separate occasions.
131.
1986,
to
Between in or about the beginning of 1985 and January,
defendant 0RLA:1i"DO CICILIA delivered quantities of cocaine
individuals
known
to
the
grand
jury,
for
distribution
in
Boston, Massachusettst on approximately eight separate occasions.

132.
Between the Spring of 1985 and September, 1986, defen-
dants ORLANDO CICILIA, MARIO S. TABRAUE,
and others known to the
grand jury, met at MARIO S. TABRAUE's residence located at 3940
-58-
(
Douglas Road in Miami, Florida,
for the purpose of weighing and
distributing kilograms of cocaine.

133.
In
or
distributed a
a/k/a "FLAC0
134.
11
In
about
late
1985,
defendant
quantity of cocaine
11
or
or
MARIO S.
TABRAUE
to defendant LU!S VALDESUSO,
RECITO"~
about
late
1985,
defendant
PHILIP
EPSTEIN
returned a quantity of cocaine to defendant MARlO S,. TABRAUE a.t
Zoological Imports.
135.
Between
April,
1986
and
September,
1986 1
defendant
ORLANDO CICILIA distributed quantities of cocaine to an individual known to the grand jury for delivery to Hawaii, on at least
five separate occasions.
136.
Between
the
Summer of
1986
and
the
Summer
of
1987,
defendant ORLANDO CICILIA stored kilogram quantities of cocaine
at a warehouse located in l't1iami, Florida.

Between
137.
1985
and
August,
1986,
Raymond
Van
Nostrand
received quantities of cocaine from defendant JUAN PORTUONDO.

13B~
MARIO
February,
Between
s.
1985
and
August,
19B6,
defendant
TABRAUE employed Raymond Van Nostrand at his pet busi-
ness, zoological Imports.

139.
ORLANDO
Between
CICILI1\
quantities
of
February,
and
1985
MARIO S.
cocaine
to
and
August,
TABRAUE
Raymond
arranged
Van
1986,
for
Nostrand
defendants
delivery
on
of
numerous
occasions at Zoological Imports.

140.
defendant
Between
ORLANDO
the
Swnmer
CICILlA
of
1986
arranged
and
for
quantities of cocaine to defendant JOAN
-59-
the
summer
delivery
PORTUONDO~
of
of
1987,
Kilogram
(
On or about February 14, 1986, at Dade County 1 Florida,
141.
a meeting was held at the defendant MARIO S. TABRAUE'S business,
Zoological
Imports,
in
which
the
defendant
MARIO
S.
TABRAUE
discussed the sale of several thousand dollars worth of cocaine.

On or about
142.
vered one
(1)
February
ounce of
20,
cocaine
1986,
Orlando CICILIA deli-
to Jose Martinez
at
Zoological
Imports.
On March 10 1 1986, Orlando CICILIA delivered one ounce
143.
of cocaine to Jose Martinez, at Zoological Imports.

144.
On
or
about
April
14,
1986,
meeting
was
held
at
Zoological Imports in Miami, Florida 1 in which defendant MARIO S.
TABRAUE discussed the sale of one
(1)
pound of cocaine to Jose
Martinez for $13,000.

On or about May 7, 1986, Orlando C!CILIA met with Jose
145.
Martinez
one (1)
at
Zoological Imports,
for the purpose of
selling him
pound of cocaine for $13t000.
146.
On or about May
13,
1986,
defendant MARIO S.
met with Jose Martinez at Zoological Imports,
discussing
the
sale
of
one
( 1)
kilogram
TABRAUE
for the purpose of
of
cocaine
to
Jose
met
with
Martinez for $26,000.

14 7.
Orlando
On
or
about
CICILIA
at
July
22,
Zoological
discussing a cocaine deal,
1986,
Jose
Imports,
Martinez
for
the
purpose
of
and received a sample of cocaine from
ORLANDO CICII.lA.
148.
TAERAUE
On or
met
about October 24,
with
Jose
Martinez
-60-
1986,
at
the defendant MARIO S.
Zoological
Imports,
and
discussed the sale of one
(1} pound of cocaine to Jose Martinez
for $13,000.
149.
On or about October 24, 1986, defendant PHILIP EPSTEIN
delivered one {1) pound of cocaine to defendant ORLANDO ClCILlA.

150.
On or about October 24,
1986,
Jose Martinez
received
one (l} pound of cocaine from Orlando CICILIA for $13,000.

151.
On or about November 19,
vered approximately two
( 2)
1986,
Orlando CIC!LIA deli-
ounces of cocaine
to Jose Martinez
for $2,200 at Zoological Imports.

15 2.
On
or
about
November
20,
1986 1
defendant
MARIO
S.
TABRAUE had a meeting with James Ricky Brown for the purpose of
discussing Brown's testimony before the grand jury.
COUNT II
RACKETEERING
1~
Each
and
every
allegation
contained
in
paragraphs
through 3, 5 and 6A through 6T of Count I of this indictment is
incorporated in this Count by reference as if
fully
set forth
herein.
2.
1976,
From an unknown date, believed to be in the Summer of
and continuing up to and including December 16 1 1987, in
the Southern District of Florida, and elsewhere, the defendants 1

MARIO S. TABRAUE
FRANCISCO QUINTANA, a/k/a
11
PUPI",
JOSE LABRADA, a/k/a JOE VULCANO,

and
ORLZ..NDO CICILIA,
and
other
persons known
employed by
and
unknown
to
the grand
and associated with the Enterprise,
jury,
being
as more
fully
described in paragraphs 1 through 3 and 6A through 6T of Count I,
(
knowingly and intentionally did conduct and participate, directly
and indirectly r in the conduct o the affairs of the Enterprise
through a pattern of racketeering activity.

THE PATTERN OF RACKETEERING ACTIVITY
3.
Title
The
18,
pattern
United
of
racketeering
States
Code,
activity,
Sections
as
1961{1)
defined
and
by
1961(5)
through which the defendants conducted and participated in the
affairs
of
marijuana,
Title 21 1
with
the
Schedule
consisted
controlled
United States Code,
intent
Schedule
Enterprise
to
distribute
controlled
States Code,
Sections
the
substance
Sections
and
952
and
importation
in
and
distribution
substance,
narcotic controlled substance,
of:
violation
963;
of
cocaine,
of
of
possession
marijuana,
Schedule
II
in violation of Title 21, United
841(a)(l)
and
846;
travel
in interstate
commerce to facilitate a cocaine business, in violation of Title

18, United States Code, Section 1952(a) (3); murder, in violation
of Florida Statute 777.04; accessory after the fact to murder, in
violation
of Florida Statutes Sections 777.03 and 775.082;
and
obstruction of justice, in violation of Title 18, United States

Code,
Sections
1503
the
acts
pattern of
racketeering activity being
those
paragraphs
6A
through
and
6T
1512{b);
of
Count
of
constituting
said
acts described
this
Indictment 1
in
the
allegations of which are incorporated in this Count by reference,

as if fully set forth herein,
All in violation of Title 18, United States Code,
1962(c), 1963 and 2.
-62-
Sections
COUNT XIV THROUGH XIX

On or
about the dates listed below according to Count,
in
the Southern District of Florida, and elsewhere, the defendant,

ORLANDO CICILIA,
did knowingly and willfully travel and cause another to travel in
interstate
commerce
as
listed
below,
with
intent
to
establish and carry on and facilitate the promotion,
promote,
establish-
ment and carrying on of an unlawful activity, that is, a business

enterprise involving the distribution of cocaine, in violation of
Title
21,
thereafter,
United
States
Code,
did
knowingly
and
Section
841(a} (1}
willfully
perform,
and
846,
attempt
and
to
perform and cause to be performed, acts to promote, establish and

carry on and facilitate the promotion, establishment and carrying
on of said unlawful activity:
DATE
TRAVEL
XIV
May, 1985
Travel by Randy Chatfield from

Miami, FL to Indianapolis, IN
XV
January 22, 1986

Miami, FL to Boston, MA
XVI
June 5'
1986
Travel by Randy chatfield from

Miami, FL to Honolulu 1 HI
XVII
July 24, 1986

Miami, FL to Honolulu.r HI
XVIII
September 18, 1986

Miami, FL to Honolulu 1 HI
XIX
September 26, 1986
Miami, FL to Indianapolis, IN
All in violation of Title 18, United States Code, Sections
l952ia)(3)
and 2.
-69-
(
COUNT III
From an unknown date, believed to be in or about the Summer

of 1976, and continuing up to at least December 16, 1987, in Dade
County,
and elsewhere,
the
defendant,
MARIO S. TABRAUE,
did knowingly and intentionally engage in a continuing criminal

enterprise;
Title
21,
United States Code,
960(a} (1)
are
in that he did knowingly
and intentionally violate
Sections
84l{a) (1},
846,
952{a),
and 963, as alleged in Count I, which racketeering acts
realleged
indictment,
herein,
and
in
Counts
through
XIII
counts are incorporated herein by
which
of
this
reference,
which violations are part of a continuing series of violations of

subchapters I
and II of the Drug Abuse and Control Act of 1970
undertaken by the defendant, MARIO

least
five
MARIO S.
other
persons with
TABRAUE,
occupied
S~
TABRAUE, in concert with at
respect
to
whom
the
defendant,
position of organizer,
supervisor
and manager and from which continuing series of violations the

defendant
MARIO S.
TABRAUE,
did obtain
substantial
income
and
resources.
All
21,
United States Code,
Section
848.
COUNT IV
From an unknown date, believed to be in or about the Summer

of
1976,
County,
and
continuing
up
to
at
least March,
defendant,
-63-
1983,
in
and elsewhere,
Dade
the
(
FRANCISCO QUINTANA 1 a/k/a ''PUP!"
did knowingly and intentionally engage in a continuing criminal
enterprise 1
Title
21,
in that he did knowingly and intentionally violate

United States Code,
Sections
841 (a) (1),
846,
952 (a),
960(a) \1} and 963, as alleged in Count r, which racketeering acts

are realleged herein, and in Counts V through VII of this indictment 1
which counts are
violations
are
subchapters I
part
incorporated here.in by reference,
of
continuing
series
of
which
violations
of
and II of the Drug Abuse and Control Act of 1970
undertaken by the defendant, FRANCISCO QUINTANA, a/k/a "PUPI"
in
concert with at least five other persons with respect to whom the
defendant, FRANCISCO QUINTANA, a/k/a "PUP! .. , occupied a position
of organizer,
series
of
supervisor and manager and from which continuing
violations
the
defendant
FRANCISCO
QUINTANA,
a/k/a
"PUPl,, did obtain substantial income and resources.

All in violation of Title 21 1
United States Code,
Section
848.
COUNT V
From an unknown date 1 believed to be in or about the Summer
of 1976,
and continuing up to and including December 16,
1987 1
Dade County, in the Southern District of Florida, and elsewhere,
the defendants,
MARIO S. TABRAUE,
FRANCISCO QUINTANA, a/k/a "PUPI",
JOSE LABRADA, a/k/a JOE VOLCANO,
ORLANDO CICILIA,
MIGUEL RAMIREZ,
ANTONIO MUNIO,
JOSE PEPE ACOSTA,
-64-
(
LUIS VALDESUSO, a/k/.e "FLAC0 11
a/k/a nRECITO",
JUAN PORTUONDO,
and
PHIL!P EPSTEIN,
knowingly
and
intentionally
did
combine,
conspire 1
confederate
and agree with each other, and with persons known and unknown to
the grand
jury,
to
commit offenses
against
the
United States,
that is:
to possess with intent to distribute and to distribute
{a)
quantities
of marijuana,
Schedule I
controlled
substance,
in
violation of Title 21, United States Code, Section 841{a) (1); and
(b)
to possess with intent to distribute and to distribute
quantities
of
cocaine
and
its
salt,
cocaine
Schedule II narcotic controlled substance,
hydrochloride 1
as
21, United States Code, Section 84l{a)(l).

846,
as
Octobe~
amended;
November
10 1
1978,
September
26,
1980,
12, 1984 and October 27, 1986.

COUNT VI
In or about March,
1983,
at Dade County,
in
the
Southern
District of Florida, and elsewhere 1 the defendants 1

FRANCISCO QUINTANA, a/k/a "PUP!",
and
MARIO S. TABRAUE,
together
knowingly
with
persons
known
and
and intentionally did
unknown
import
to
the
grand
jury,
into the United States,
from a place outside thereof, a quantity of marijuana, a Schedule

I controlled substance.
-65-
(
952 and 960, and Title 18, United states Code, Section 2.
COUNT Vll
In or about March 1
1983 1
at Dade County 1
els~where,
District of Florida, and
in
the
Southern
the defendants,
FRANCISCO QUINTANA, a/k/a "PUPI",

and
MARIO S. TABRAUE,
together with others known and unknown to the grand jury, knowingly and intentionally did possess with intent to distribute a
quantity of marijuana, a Schedule I controlled substance.

All
84l(a) (1)
United States Code,
Section

COUNT VIII
On
or
about
February
20,
1986,
at
Dade
County,
in
the
Southern District of Florida, and elsewhere, the defendants,

MARIO S. TABRAUE,
and
ORLANDO CICILIA,
knowingly a.nd intentionally did distribute cocaine and its salt

cocaine.
hydrochloride,-
Schedule
II
narcotic
controlled
sub-
stance.
All
84l(a)U)
21,-
United St-ate Code,
-66-
Section
COUNT IX
On or about March 10, 1986, at Dade County,
in the southern
District of Florida, and elsewhere, the defendants,

MARIO 5, TABRAUE,
and
ORLANDO CICILill,
knowingly and intentionally did distribute cocaine and its salt
cocaine
hydrochloride 1
in violation
of
Schedule
II
narcotic
controlled
sub-
stance~
All
Title
21,
United
State Code,
Section
B41(a) (1) and Title 18, united States Code, Section 2.

COUNT X
On or about M.ay 7,
1986,
at Dade County,
in the Southern
District of Florida, and elsewhere, the defendant,

MARIO S, TABRAUE,
and
ORLANDO CICILill,
knowingly and intentionally did distribute cocaine and its salt
cocaine
hydrochloride,
Schedule
II
narcotic
controlled
sub-
stance.
in violation of Title 21, United States Code,
All
Section
84l(a) 11) and Title 18, United States Code, Section 2.

COUNT XI
On
or
about
September
26,
1986~
at
Dade
County,
in the
Southern District of Florida, the defendant,

ORLAh~O
CICILill,
together with others known and unknown to the grand
knowingly
and
intentionally
distribute
-67-
cocaine
and
jury,
its
did
salt
(
cocaine
hydrochloride,
Schedule
!I
narcotic
controlled
sub-
stance~
All
in
violation of Title
21,
United
State Codef
Section
841(a) (1) and Title 18, United States Code, Section 2.

COUNT XII
On or about October 24. t 1986 1 at Dade County 1 in the South-
ern District of Florida, and elsewhere 1 the defendants,

MARIO S TABRAUE,
ORLANDO CICILIA,
and
PHILIP EPSTEIN,
knowingly and intentionally did distribute cocaine and its salt,
cocaine
hydrochloride,
Schedule
II
narcotic
controlled
sub-
stance.
All in violation of Title 21r
United States Code,
Section
84l(a) (1) and Title 18, united States Code, Section 2.

COUNT XIII
On
o:r
about
November
19,
19"86,
at
Dade
County,
in
the
Southern District of Florida, and elsewhere, the defendants,

MARI 0 S TABRAUE ,
and
ORLANDO CICILIA,
together vith others known and unknown to the grand jury, knowingly
and
cocaine
intentionally
hydrochloride,
did
a
distribute
Schedule
II
cocaine
narcotic
and
its
controlled
salt,
sub-
stance.
All in violation of Title 21,
United States Code,
841(a) (1) and Title 18, United States Code, Section 2.
-68-
section
I
I
I
I
I
I
I
I

Marco Rubio's Brother in Law Indictment

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Marco Rubio's Brother in Law Indictment

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s~-

UNITED STATES OF AMERICA,

From an unknown date, believed to be in the Summer of

1976, and continuing up to and including December 16, 1987 1 the

United States Code,

within the meaning of Title 18,

that is a group of indivi-

United States Code,

Code, Sections 84l{a) (1}

the possession with intent

travel in interstate commerce

Section 1952 (a) (3};

Florida Statute 782.04;

accessory after the fact to murder 1

violation of Florida Statutes 777.03 and 775.082t and obstruction

Sections 1503 and 1512(b).

Enterprise was as follows:

To conduct the drug business, MARIO s.

for the importation of marijuana and

sale in the Unit.ed States after it was illegally imported.

direct shipment to clients of the Enterprise.

sions, MARIO S. TABRAUE took delivery of the marijuana and stored

controlled by the Enterprise, until it was

interest in marijuana loads imported by FRANCISCO QUINTANA, a/k/a

"PUPI 11 and others.

The Enterprise also received and distributed

large quantities of cocaine.

TABRAUE and his

collected and distributed the

proceeds from the sale of marijuana and cocaine on behalf of the

Tabraue Jewelry store at 940 west Flagler Street, Miami, Florida

placing his son, defendant MARIO

TABRAUE 1 in contact with drug

Many of the drug importers and distributors, who were associated

were introduced to defendant MARIO s.

GUILLERMO TABRAUE, SR. for the purpose of promoting and expanding

In addition, defendant GUILLERMO

Specifically, defendant GUILLERMO TABRAUE, SR. acted

from clients of the Enterprise.

LABRADA a/k/ a JOE VULCANO off loaded,

transferred and distributed marijuana and cocaine for the

and distributed quantities of cocaine for and on behalf of the

MIGUEL RAMIREZ received, possessed and distributed

quantities of marijuana for the Enterprise.

and silencers to the Enterprise and otherwise associated with and

distributed quantities of marijuana and cocaine for the Enter-

Enterprise and as such, assisted the Enterprise in off-loading,

and distributing marijuana

cocaine for the Enterprise.

JOSE PEPE ACOSTA was a soldier or employee of the

Enterprise and as such, assisted the Enterprise in off-loading,

distributing marijuana and

cocaine far the Enterprise.

The Enterprise 1 operated in the following manner;

and other importers associated with the

shipment of marijuana from Colombia to the United

TABRAUE, and others associated with the Enterprise,

would arrange for boats, trucks and other vehicles to transport

Boats would be used to import the drugs into Florida,

Georgia and Louisiana.

The marijuana would then be transported

by vehicles from the off-load areas to various stash houses under

the control of the Enterprise or its