Jalisco New Generation Cartel Indictment
Jalisco New Generation Cartel Indictment
Jalisco New Generation Cartel Indictment
FEB 2 0 2020
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA
DANVILLE DIVISION
INDICTMENT
COUNT ONE
18 U.S.C. § 1956(h)
Conspiracy to Commit Money Laundering
1. Beginning on an unknown date, but no later than in or about June 2018, and
continuing to in or about January 2020, in the Western District of Virginia and elsewhere, the
combine, conspire, and agree with each other and with other persons known and unknown to the
Grand Jury to commit offenses against the United States in violation of Title 18, United States
affecting interstate and foreign commerce, specifically the transfer, delivery, and
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exchange of United States Currency, which involved the proceeds of a specified unlawful
activity, that is, the distribution and manufacture of controlled substances, in violation of
Title 21, United States Code, Section 841(a) and conspiracy to distribute and manufacture
controlled substances, in violation of Title 21, United States Code, Section 846, with the
intent to promote the carrying on of specified unlawful activity, namely the distribution
and manufacture of controlled substances, in violation of Title 21, United States Code,
attempting to conduct such financial transaction the defendants knew that the property
involved in the financial transaction represented the proceeds of some form of unlawful
2. As part of the conspiracy, members and affiliates of the Jalisco New Generation
narcotics trafficking in Mexico, transported cocaine hydrochloride, heroin, and marijuana, and
Axton, Virginia, to facilitate the distribution of controlled substances from CJNG throughout the
5. As part of the conspiracy, the defendants and their co-conspirators received large
amounts of United States currency that was payment for the controlled substances, and
2
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COUNT TWO
8 U.S.C. § 1326(a)
Unlawful Reentry After Removal From the United States
7. On or about January 22, 2020, in the Western District of Virginia, the defendant,
ALEJANDRO ESCARCEGA-AVILA, an alien, was found in the United States after having
been removed therefrom on or about January 7, 2010, at or near Laredo, Texas, and not having
obtained the express consent of the Secretary of Homeland Security to reapply for admission to
COUNT THREE
18 u.s.c. 922(g)(5)
Possession of a Firearm by an Illegal Alien
the United States, knowingly possessed a firearm, that is a shotgun, which had been shipped and
10. All in violation of Title 18, United States Code, Sections 922(g)(5) and 924(a)(2).
NOTICE OF FORFEITURE
11. Upon conviction of the offenses alleged in Count One, the defendants shall forfeit
to the United States any property, real or personal, involved in these offenses, or any property
traceable to such property, pursuant to 18 U.S.C. § 982(a)(l). The United States will seek a
forfeiture money judgment against the defendant in the amount equal to the value of any
property, real or personal, involved in this offense, or any property traceable to such property.
3
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12. If any of the property described above as being subject to forfeiture, as a result of
e. has been commingled with other property that cannot be divided without
difficulty;
the defendant shall forfeit to the United States any other property of the defendant, up to the
value of the property described above, pursuant to Title 21, United States Code,_Section 853(p).
~iv~~
fo~ ROMAS T. CULLEN~
UNITED STATES ATTORNEY