Case 3:17-cr-02976-CAB Document 1 Filed 09/22/17 PageID.

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6 UNITED STATES DISTRICT~COURT

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7 SOUTHERN DISTRICT OF CAThIFORNIA

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8 September 2016 Grand Jury l CR l CAB
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9 UNITED STATES OF AMERICA, Case No.

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10 Plaintiff,
11 v.
and 963 - International Conspiracy
959, 960 j
12 SAJID EMILIO QUINTERO NAVIDAD, to Distribute Controlled
aka "CADETE," Substancesi Title 21, U.S.C.,
13 Secs. 952, 960, and 963 -
Defendant. Conspiracy to Import Controlled
14 Substancesi Title 18, U.S.C.,
Sec. 1956 (a) (2) (B) (i) and (h) -
15 Conspiracy to Launder Monetary
Instrumentsi Title 21, U.S.C.,
16 Sec. 853, and Title 18, U.S.C.,
Sec. 982 - Criminal Forfeiture
17
18 The grand jury charges:

19 Count 1
20 Beginning at a date unknown to the grand jury and continuing up to

21 and including September 22, 2017, within the country of Mexico and
22 elsewhere, defendant SAJID EMILIO QUINTERO NAVIDAD, aka "CADETE, /1
who
23 will first enter the United States within the Southern District of

24 California, did knowingly and intentionally conspire with other persons

25 known and unknown to the grand jury, to distribute and cause the
26 distribution of a controlled substance, to wit: 1 kilogram and more of
27 a mixture and substance containing a detectable amount of heroin, a

28 Schedule I Controlled Substance; and 5 kilograms and more of a mixture

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1 and substance containing a detectable amount of cocaine, a Schedule II

2 Controlled Substance; intending, knowing and having reasonable cause to

3 believe that such heroin and cocaine would be unlawfully imported into

4 the United States; all in violation of Title 21, United States Code,

5 Sections 959, 960, and 963.

6 Count 2

7 Beginning at a date unknown to the grand jury and continuing up to

8 and including September 22, 2017, within the Southern District of

9 California, and elsewhere, defendant SAJID EMILIO QUINTERO NAVIDAD,

10 aka "CADETE," did knowingly and intentionally conspire with other

11 persons, known and unknown to the grand jury, to import a controlled

12 substance, to wit: 1 kilogram and more of a mixture and substance

13 containing a detectable amount of heroin, a Schedule I Controlled

14 Substance; and 5 kilograms and more of a mixture and substance containing

15 a detectable amount of cocaine, a Schedule II Controlled Substance; into

16 the United States from a place outside thereof; in violation of Title 21,

17 United States Code, Sections 952, 960, and 963.

18 Count 3

19 Beginning at a date unknown to the grand jury and continuing up to

20 and including September 22, 2017, within the Southern District of

21 California and elsewhere, defendant SAJID EMILIO QUINTERO NAVIDAD,

22 aka "CADETE," did knowingly combine, conspire, and agree with other

23 persons known and unknown to the grand jury to commit offenses against

24 the United States, to wit: to transport, transmit, and transfer, a

25 monetary instrument and funds involving the proceeds of specified

26 unlawful activity, that is, Conspiracy to Possess with Intent to

27 Distribute and to Distribute Controlled Substances, in violation of

28 Title 21, United States Code, Sections 84l(a) (1) and 846, from a place

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1 in the United States to and through a place outside the United States,

2 knowing that the funds involved in the transportation, transmission, and

3 transfer represented the proceeds of some form of unlawful activity and

4 knowing that such transportation, transmission, and transfer was

5 designed in whole and in part to conceal and disguise the nature,

6 location, source, ownership, and control of the proceeds of specified

7 unlawful activity, in violation of Title 18, United States Code,

8 Section 1956 (a) (2) (B) ( i) ; all in violation of Title 18, United States
9 Code, Section 1956(h).

10 Criminal Forfeiture Allegations

11 1. The allegations contained in Counts 1 through 3 are realleged

12 and by their reference fully incorporated herein for the purpose of

13 alleging forfeiture to the United States of America pursuant to the

14 provisions of Title 21, United States Code, Section 853, and Title 18,

15 United States Code, Section 982.

16 2. As a result the commission of the felony offenses alleged

17 in Counts 1 and 2 of this indictment, said violations being punishable

18 by imprisonment for more than one year and pursuant to Title 21, United

19 States Code, Sections 853(a) (1) and 853(a) (2), defendant SAJID EMILIO

20 QUINTERO NAVIDAD, aka "CADETE," shall, upon conviction, forfeit to the

21 United States all his rights, title and interest in any and all property

22 cons ti tu ting, or derived from, any proceeds the defendant obtained,

23 directly or indirectly, as the result of the offenses, and any and all

24 property used or intended to be used any manner or part to commit and

25 to facilitate the commission of the violations alleged in this

26 indictment.

27 3. As a result of the commission of the felony offense leged

28 in Count 3 of this Indictment, pursuant to Title 18, United States Code,

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1 Section 982 (a) (1) t defendant SAJID EMILIO QUINTERO NAVIDAD,

2 aka "CADETE," shall forfeit to the United States, all property, real and

3 personal, involved in such offense, and all property traceable to such

4 property.

5 4. If any of the above referenced forfei table property, as a

6 result of any act or omission of the defendant:

7 a. cannot be located upon the exercise of due diligence;

8 b. has been transferred or sold to, or deposited with, a third

9 party;

10 c. has been placed beyond the j sdiction of the Court;

11 d. has been substantially diminished in value; or

12 e. has been commingled with other property which cannot be

13 subdivided without di iculty; it is the intent of the United States,

14 pursuant to Title 21, United States Code, Section 853(p) and Title 18,

15 United States Code, Section 982 (b), to seek forfeiture of any other

16 property of the defendants up to the value of the said property listed

17 above as being subject to forfeiture.

18 All in violation of Title 21, United States Code, Section 853, and

19 Title 18, United States Code, Section 982.

20 DATED: September 22, 2017.

21 A TRUE BILL:
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23

24 ALANA W. ROBINSON
Acting United States Attorney
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By:
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