Case 1:18-cr-00081-RC Document 1 Filed 04/02/18 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on July 6, 2017
UNITED STATES OF AMERICA CRIMINAL NO.
V. UNDER SEAL
JOAQUIN GUZMAN LOPEZ, also 21 U.S.C. §§959(a), 960, and 963
known as "EL GUERO," "GUERO (Conspiracy to distribute five kilograms or
MORENO," and "MORENO" more of cocaine, 500 grams or more of
methamphetamine, and 1,000 kilograms of
and marijuana for importation into the United
States)
OVIDIO GUZMAN LOPEZ, also
known as "EL RATON" and "RATON : 18 U.S.C. § 2 (Aiding and Abetting
NUEVO"
21 U.S.C. §§ 853 and 970
Defendants. (Forfeiture)
INDICTMENT
The Grand Jury charges that:
COUNT ONE
From in or around April of 2008, and continuing thereafter, up to and including the date of
this Indictment, the exact dates being unknown to the Grand Jury, in the countries of Mexico, the
United States and elsewhere, the defendants, JOAQUIN GUZMAN LOPEZ, also known as "EL
GUERO," "GUERO MORENO," and "MORENO," and OVIDIO GUZMAN LOPEZ, also known
as "EL RATON" and "RATON NUEVO," and others known and unknown to the Grand Jury, did
knowingly, intentionally, and willfully combine, conspire, confederate and agree to distribute: (1)
five (5) kilograms or more of a mixture or substance containing a detectable amount of cocaine, a
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Schedule II controlled substance; (2) five hundred (500) grams or more of a mixture or substance
containing a detectable amount of methamphetamine, a Schedule II controlled substance; and (3)
one thousand (1,000) kilograms or more of a mixture or substance containing a detectable amount
of marijuana, a Schedule I controlled substance, intending and knowing that such substances would
be unlawfully imported into the United States from a place outside thereof, in violation of Title
21, United States Code, Section 959(a); all in violation of Title 21, United States Code, Section
963, and Title 18, United States Code, Section 2.
With respect to the defendants, the controlled substances 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, is five (5) kilograms or more of a mixture or substance containing
a detectable amount of cocaine, five hundred (500) grams or more of a mixture or substance
containing a detectable amount of methamphetamine, and one thousand (1,000) kilograms or more
of a mixture or substance containing a detectable amount of marijuana, in violation of Title 21,
United States Code, Section 960(b)(1)(B)(ii), 960(b)(1)(1T), 960(b)(1)(G).
(Conspiracy to Distribute 5 Kilograms or More of Cocaine, 500 Grams or More of
Methamphetamine, and 1,000 Kilograms or More of Marijuana, Intending and
Knowing that such substances will be Unlawfully Imported into the United States,
in violation of Title 21, United States Code, Sections 959(a) and 963, and aiding
and abetting in violation of Title 18, United States Code, Section 2.)
FORFEITURE ALLEGATION
The United States hereby gives notice to the defendants that upon conviction of the Title
21 offense alleged in Count One of this Indictment, the Government will seek forfeiture in
accordance with Title 21, United States Code, Sections 853 and 970, of all property constituting
or derived from any proceeds the defendants obtained directly or indirectly as the result of the
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alleged Title 21 violation, and all property used or intended to be used in any manner or part to
commit, and to facilitate the commission of such offense.
If any of the above-described forfeitable property, as a result of any act or omission of the
defendants:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be subdivided
without difficulty;
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it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) to
seek forfeiture of any other property of the said Defendant up to the value of the above forfeitable
property.
(Criminal Forfeiture, in violation of Title 21, United States Code, Sections 853 and
970.)
A TRUE BILL:
AS(WYA T
Chief
Narcotic and Dangerous Drug Section
U.S. Department of Justice
Washington, D.C. 20530
„
By: --
ANTHONY T. AMINOFF
Trial Attorney
Narcotic and Dangerous Drug Section
Criminal Division
U.S. Department of Justice
Washington, D.C. 20530
Telephone: (202) 616-2379
