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$EALED
IJNIT
STATES DISTRICT COIJRT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
UNITED STATES OF AMERICA,
Li3 4L
..
:RM
IF
Plaintiff,
21
1, 2011
in the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,
five kilograms or more of a mixture and substance containing a detectable amount of cocaine, a
Schedule II Controlled Substance, contrary to Title 21, United States Code, Section 841(a)(1)
and 841 (b)(1)(A)(ii), in violation of Title 21, United States Code, Section 846.
L9
/.......
[SEALEDI
V.
COUNT TWO
(21 U.S.C. 952(a), 960(a)(1), 960(b)(1)(B) & 963)
That beginning on or about January 1, 2000 and continuing until on or about January
1,
violation of Title 21, United States Code, Section 963, that is to say, they conspired to import a
controlled substance, which offense involved five kilograms or more of a mixture and substance
containing a detectable amount of cocaine, a Schedule II Controlled Substance, into the United
States from Mexico contrary to Title 21, United States Code, Sections 952(a), 960(a)(1) and
960(b)(l)(B).
COUNT THREE
(21 U.S.C. 952(a), 960(a)(1), 960(b)(1)(G) & 963)
That beginning on or about January 1, 2000 and continuing until on or about January 1,
2011, in the Western District of Texas, Defendant,
violation of Title 21. United States Code, Section 963, that is to say, they conspired to import a
controlled substance, which offense involved one thousand kilograms or more of a mixture and
substance containing a detectable amount of marijuana, a Schedule II Controlled Substance, into
the United States from Mexico contrary to Title 21, United States Code, Sections 952(a),
A TRUE BILL.
FOREPERSN
ROBERT PITMAN
UNITES STATES ATTORNEY
OTHEtD JURY