Received: IN U.S. Dis1'Rict E.O.N.Y
Received: IN U.S. Dis1'Rict E.O.N.Y
Received: IN U.S. Dis1'Rict E.O.N.Y
IN CLERK'S OFFICE
F. #2019R00927 U.S. DIS1'RICT COURT E.O.N.Y.
---------------------------X
THE GRAND JURY CHARGES:
INTRODUCTION
indicated:
1. From approximately 2001 to the present, the Sinaloa Cartel was one of
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the world's largest and most prolific drug trafficking organizations.
including: (a) the leadership of the Sinaloa Cartel, who were the ultimate decision makers in
the organization with respect to its drug trafficldng and money laundering activities, as well
as its. conuption and enforcement activities undertaken to preserve and protect its illegal
activities; (b) security personnel, who protected the leadership of the Sinaloa Cartel and
engaged in violent acts to further the goals of the organization; (c) plaza bosses, who
controlled certain territories for the Sinaloa Cartel and wqe responsible for transporting
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drugs through those territories; (d) transporters, such as boat and submarine crews, pilots and
truck drivers, who transported drugs from Colombia through Mexico and into the United
States; (e) money launderers, who funneled drug proceeds from the United States back to
Mexico; and (f) cmTupt public officials, who provided protection for the Sinaloa Cartel in
3. While at times there were rifts and infighting among the leaders of the
Sinaloa Cartel, they generally coordinated their criminal activities, shared and controlled
violence and ensured that the Sinaloa Cartel received the protection of corrupt public
·officials.
close coordination with South American cocaine sources of supply. The Sinaloa Cartel
directed a large scale narco_tics transportation network involving the use of land, air and sea
transportation assets, shipping multi-ton quantities of cocaine from South America, through
Central America and Mexico, and finally into the United States. The vast majority of drugs
trafficked by the Sinaloa Cartel were imported into the United States, where they were
consumed.
5. The Sinaloa Cartel's drug sales in the United States generated billions
of dollars in profit. The drug proceeds were laundered back to Mexico, and often the drug
money was physically transpo1ied from the United States to Mexico in vehicles containing
a means and method of achieving the goals of its drug trafficking enterprise. The
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PEQUENO GARCIA were high-level officials in the Mexican government who protected
the Sinaloa Catiel in exchange for millions of dollars of bribe payments. In exchange for
the bribes, the defendants GENARO GARCIA LUNA, LUIS CARDENAS PALOMINO and
RAMON PEQUENO GARCIA abused their public offices by committing the following acts
shipments in Mexico, which typically consisted of multi-ton quantities of narcotics, and the
Cat.iel members, and providing sensitive law enforcement information about rival cartel
members; and
COUNT ONE
(Continuing Criminal Enterprise)
8. In or about and between January 2001 and the present, both dates being
approximate and inclusive, within the Eastern District ofNew York and elsewhere, the
defendant GENARO GARCIA LUNA, together with others, did knowingly and intentionally
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engage in a continuing criminal enterprise, in that the defendant GENARO GARCIA LUNA
committed violations of Title 21, United States Code, Sections 841, 846, 959, 960 and 963,
including Counts Two through Four and Violations One through Six set forth below, which
violations were part of a continuing series of violations of those statutes unde1iaken by the
defendant GENARO GARCIA LUNA, in concert with five or more other persons, with
respect to whom the defendant GENARO GARCIA LUNA occupied supervisory and
management positions, and from which continuing series of violations the defendant
GENARO GARCIA LUNA obtained substantial income and resources. The continuing
series of violations, as defined by Title 21, United States Code, Section 848(c), includes, but
is not limited to, the violations charged in Counts Two through Four and the following
Violation One
(International Cocaine Distribution -
Approximately 5,000 Kilograms of Cocaine)
of the United States, the defendant GENARO GARCIA LUNA, together with others, did
knowingly and intentionally distribute a controlled substance, intending and knowing that
such substance would be unlawfully imported into the United States from a place outside
thereof, which offense involved five ldlograms or more of a substance containing cocaine, a
Schedule II controlled substance, in violation of Title 21, United States Code, Sections ·
959(a), 959(c), 960(a)(3) and 960(b)(l)(B)(ii), and Title 18, United St.ates Code, Section 2.
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Violation Two
(International Cocaine Distribution -
Approximately 23,000 Kilograms of Cocaine)
the United States, the defendant GENARO GARCIA LUNA, together with others, did
knowingly and intentionally distribute a controlled substance, intending and knowing that
such substance would be unlawfully imported into the United States from a place outside
thereof, which offense involved five kilograms or more of a substance containing cocaine, a
Schedule II controlled substance, in violation of Title 21, United States Code, Sections
959(a), 959(c), 960(a)(3) and 960(b)(l)(B)(ii), and Title 18, United States Code, Section 2.
Violation Three
(International Cocaine Distribution -
Approximately 19,000 Kilograms of Cocaine)
the United States, the defendant GENARO GARCIA LUNA, together with others, did
knowingly and intentionally distribute a controlled substance, intending and knowing that
such substance would be unlawfully imported into the United States from a place outside
thereof, which offense involved five kilograms or more of a substance containing cocaine, a
Schedule II controlled substance, in violation of Title 21, United States Code, Sections
959(a), 959(c), 960(a)(3) and 960(b)(l)(B)(ii), and Title 18, United States Code, Section 2.
Violation Four
(Cocaine Distribution -
Approximately 1,997 Kilograms of Cocaine)
12. On or about January 28, 2003, within the Eastern District of New York
and elsewhere, the defendant GENARO GARCIA LUNA, together with others, did
knowingly and intentionally distribute and possess with intent to distribute a controlled
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substance, which offense involved five kilograms or more of a substance containing cocaine,
a Schedule II controlled substance, in violation of Title 21, United States Code, Sections
841(a)(l) and 841(b)(l)(A)(ii)(II), and Title 18, United States Code, Section 2.
Violation Five
(Cocaine Distribution
Approximately 1,925 Kilograms of Cocaine)
13. On or about August 16, 2002, within the Northe+n District of Illinois
and elsewhere, the defendant GENARO GARCIA LUNA, together with others, did
knowingly and intentionally distribute and possess with intent to distribute a controlled
substance, which offense involved five kilograms or more of a substance containing cocaine,
a Schedule II controlled substance, in violation of Title 21, United States Code, Sections
84l(a)(l) and 841(b)(l)(A)(ii)(II), and Title 18, United States Code, Section 2.
Violation Six
(Cocaine Dirtribution -
Approximately 1,923 Kilograms of Cocaine)
14. On or about May 24, 2002, within the Eastern District of New York
and elsewhere, the defendant GENARO GARCIA LUNA, together with others, did
lmowingly and intentionally dis~foute and possess with intent to distribute a controlled
substance, which offense involved five kilograms or more of a substance containing cocaine,
a Schedule II controlled substance, in violatio;n of Title 21, United States Code, Sections
84l(a)(l) and 84 l(b)(l)(A)(ii)(II), and Title 18, United States Code, Section 2.
(Title'21, United States Code, Sections 848(a) and 848(c); Title 18, United
15. The allegations contained in paragraphs one through six are realleged
16. In or about and between January 2001 and the present, both dates being
approximate and inclusive, within the extraten-itorial jurisdiction of the United States, the
defendants GENARO GARCIA LUNA, LUIS CARDENAS PALO MINO and RAMON
PEQUENO GARCIA, together with others, did knowingly and intentionally conspire to
distribute a controlled substance, intending, knowing and having reasonable. cause to believe
that su~h substance would be unlawfully imported into the United States from a place outside
substance, contrary to Title 21, United States Code, Sections 959(a) and 960(a)(3). The
their own conduct, and the conduct of other conspirators reasonably foreseeable to them, was
(Title 21, United States Code, Sections 963, 960(b)(l)(B)(ii) and 959(d); Title
COUNT THREE
(Conspiracy to Distribute and Possess with Intent to Distribute Cocaine)
17. The allegations contained in paragraphs one through six are realleged
18. In. or about and between January 2001 and the present, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
PEQUENO GARCIA, together with others, did knowingly and intentionally conspire to .
distribute and possess with intent to distribute one or more controlled substance~, which
to Title 21, United States Code, Section 84l(a)(l). The amount of cocaine involved in the
conspiracy attributable to the defendants as a result of their own conduct, and the conduct of
other conspirators reasonably foreseeable to them, was five kilograms or more ofa substance
containing cocaine.
(Title 21, United States Code, Sections 846 and 841(b)(l)(A)(ii)(II); Title 18,
COUNTFOUR
(Conspiracy to Import Cocaine)
19. The allegations contained in paragraphs one through six are realleged
20. In or about and between January 2001 and the present, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
PEQUENO GARCIA, together with others, did knowingly and intentionally conspire to
import a controlled substance into the United States from a place outside thereof, which
to Title 21, United States Code, Sections 952(a) and 960(a)(l). The amount of cocaine
involved in the conspiracy atti;ibutable to the defendants as a result of their own conduct, and
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the conduct of other conspirators reasonably foreseeable to them, was five kilograms or more
(Title 21, United States Code, Sections 963 and 960(b)(l)(B)(ii); Title 18,
COUNT FIVE
(Maldng False Statements)
21. On or about June 1, 2018, within the Eastern District of New York and
elsewhere, the defendant GENARO GARCIA LUNA did knowingly and intentionally mal<:e
one or more materially false, fictitious and fraudulent statements and representations, in a
matter within the jurisdiction of the, executive branch of the Government of the United
States, to wit: a statement to the United States Customs and Immigration Services
("USCIS"), in that the defendant falsely stated and represented to USCIS that he had never
committed, assisted in committing and attempted to commit a crime or offense for which he
had not been arrested, when, in fact, the defendant then and there knew and believed he had
committed, assisted in committing and attempted to commit crimes and offen_ses for which
(Title 18, United States Code, Sections 1001(a)(2) and 3551 et seq.)
22. The United States hereby gives notice to the defendant charged in
Count One that, upon his conviction of the offense charged in Count One, the government
will seek forfeiture in accordance with Title 21, United States Code, Section 853(a), which
requires any person convicted of such offense to forfeit any property constituting, or derived
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from, proceeds obtained, directly or indirectly, and any property used, or intended to be used,
in any manner or part, to commit, or to facilitate the commission of, such offense, and any of
his interest in, claims against, and property or contractual rights affording a source of control
(b) has been transferred or sold to, or deposited with, a third party;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
to seek forfeiture of any other prope~ of the defendant up to the value of the forfeitable
24. The United States hereby gives notice to the defendants charged in
Counts Two through Four that, upon their conviction of any of the offenses charged in
Counts Two through Four, the government will seek forfeiture in accordance with Title 21,
United States Code, Sections 853(a) and 970, which require any person convicted of such
. )
offenses to forfeit: (a) any property constituting, or derived from, any proceeds obtained
(
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directly or indirectly as the result of such offenses, and (b) any property used, or inte tied to
be used, in any manner or part, to commit, or to facilitate the commission of, such o rises.
(b) has been transferred or sold to, or deposited with, a third p,arty;
it is the intent of the United States, pursuant to Title 21, United States Code, Secti.on 53 (p),
to seek forfeiture of any other property of the defendants up to the value of the forfeit ble
(Title 21, United States CQde, Sections 853(a), 853(p) and 970)
A TRUEBILL
• U~~"" ~~H~
ACTING UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK
F.#: 2019R00927
FORMDBD-34 No.
JUN. 85
CRIMINAL DIVISION
Defendants.
INDICTMENT
cT, 18, U.S.C., §§ 100l(a)(2), 1451(e), 3238, 2 and 3551 et seq.; T. 21,
U.S.C., §§ 846, 841(b)(l)(A)(ii)(II), 848(a), 848(c), 853(a), 853(p), .
959(d), 960(b)(l)(B)(ii), 963 and 970)
Foreperson
Clerk
Bail,$
(
Michael Robotti, Ryan Harris and Erin Reid, Assistant U.S. Attorneys
(718) 254-7000