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SEALEDUNITED STATESDISTRICT COURT
FiLED
2UI2MI13OPM
3:L41
WESTERNDISTRICT
OFTEXAS
CLY
U11TL
COURT
AUSTINDIVISION
f
TEA
A
S
UNITEDSTATES
OF
AMERICA,Plaintiff,
V.
MIGUEL
ANGEL
TRIEVINO
MORALES(1)
aka "40"
OSCAROMARTREVINO MORALES(2)
aka "42"JOSE
TREVINO-MORALES(3)ZULEMA
TEE
VINO(4)
CARLOS MIGUEL
NAYEN BORBOLLA(5)
aka "Carlito,
aka,
Piotos"
FRANCISCOANTONIO COLORADO
CESSA(6)FERNANDO SOLISGARCIA(7)
aka FreddyVICTOR
MANUEL
LOPEZ(8)SERGIO
ROGELIOGUERRERO
RINCON(9)
aka "El
Negro"
ADANFARIAS(10)
EUSEVIO
MALDONADO
HtJITRON(11)
FELIPE
ALEJANDROQUINTERO(13)RAUL RAMIREZ(14)
LS
GERARDO AGUIRRE(15)Defendants.
THE
GRAND
JURYCHARGES:
BY
-
DdUT
CRIMINALNO. A-12-CR-
Al2Cp
21OSS
iNDICTMENT
{Vio:
CtI:
18
U.S.C.
§
1956(h).
Conspiracyto LaunderMonetaryInstruments]
INTRODUCTION
At various times material to this indictment:Defendants,
MIGUEL ANGEL TREVINO
MORALES(1),
OSCAROMAR
TEE
VINO
Case 1:12-cr-00210-SS Document 45 Filed 05/30/12 Page 1 of 25
 
MORALES(2),
JOSE
TREVINOMORALES(3), ZULEMATREYINO(4),
CARLOS
MIGUEL
NAYEN
BORBOLLA(5),FRANCISCOANTONIOCOLORADO
CESSA(6),
FERNANDOSOLISGARCIA(7),
VICTOR
MANUEL
LOPEZ(8),SERGIOROGELIOGUERRERORINCON(9),
ADANFARIAS(1O),
EUSEVIO MALDONADO
HUITRON(1
1),
FELIPEALEJAN1RO
QUINTERO(13),RAULRAMIREZ(14),
LUTS
GERAIWOAGUIRRE(15)
andothers, were
members
of
a
money
launderingconspiracy using
proceedsderived
from
thesale
of
cocaine,
marijuana
and other illegal
narcotics
by
anorganizationknown
as
the
LOS
ZETAS.The LOSZETAS Drug Cartel
isa
powerful
drug
organization operating
out
of
Mexico
which funnels
thousands
of
kilos
of
cocaine
and
othernarcoticsinto
theUnited
Stateseach
year.
LOS ZETAS
are
the
largest
drugcartel in Mexico ingeographical
presence
and
control
Ii
states
within
Mexico.Theorganization
is
based in the city
of
Nuevo Laredo,Tamaulipas,directlyacross the borderfrom Laredo,
Texas. The huge-scale drug
trafficking
of
thisorganization
generatesmulti-million dollar
revenues.
LOS ZETAS
funnels drugproceeds
from
Miguel Angel
TrevinoMorales,
a.k.a.
"40,"
(hereafterreferred
to either by
first and lastname
orjust"40")
and
hisbrother
Oscar Omar TrevinoMorales,
a.k.a.
"42,"(hereafter referred
to
either
by
firstand last
nameor
just
"42")
intothe
United
States.
"40,"
and HeribertoLazcano-Lazcano,
a.k.a.
"3,"
are
the
two co-leaders
of
LOS
ZETAS.The numbersassociated
with theirnames
werefirst assignedatthe
inception
of
LOS ZETAS
to
show
members'
rank
within the criminalorganization
(the
"3," therefore,would
demonstrate third
in
rank in theoverallorganization
when
LOS
ZETAS
wasfirstorganized).
In
the last several years, however,killingsandcaptures haveeliminated
thosepreviouslydesignated
as
higher ranking
members,
and"3"
and
"40"have
nowassumed top
2
Case 1:12-cr-00210-SS Document 45 Filed 05/30/12 Page 2 of 25
 
leader
status.
"40"
and
his brother
"42"
utilize anotherbrother
living
within
the
United
States,
JOSETREV1NO MORALES,
as
well
as
other contacts
to
helplaunder
their
drug
money through
the
purchase
of
American Quarter Horses.
Theownership
of
thehorses and
the source
of
the
funds
to
purchase
the
horses
are
placed
in
various nominee names
to
disguise
"40's"
and
"42's"
connection
to
these
assets.
Nominees
arereal
or
fictitious persons or entities
that
are
used
instead
of
the
real and true owner,Thishelps legitimizetheappearance
of
their
drug moneysince
horse racing
is
alegal
activity and
also
provides"40,"
"42,"
and those working with themfree
standing
assetsthatcanlaterbe sold
or
"cashed in."
It
also generates
legitimate
looking
income duringthe intervening time
period. Themoney laundering
network
of
this
conspiracy
reache.d
from
the
United States/Mexico border
to
numerouslocations
in and
near
Austin,Texas,and
elsewhere.Telephones
were
utilized extensively
by
members
of
theconspiracy in order for
co-
conspirators
to coordinate aspects
of
their money
laundering.
Co-conspiratorswould
attend
quarter horse auctions
to
purchase racing quarter
horses. Via
electronic
andwire
communications, members
of
theconspiracywould
coordinatethepurchase
of
various
racing
quarterhorses
and the
payment
of
boarding, breeding
arid
racingfeesusing
the proceeds
derived
fromthesale
of
illegal narcotics.
OBJECTIVE
OFTHECONSPIRACY
It
was
the object
of
the conspiracy
tolaunder U.S.
currencygained from
thesale
of
illegal
controlledsubstances
by LOS
ZETAS
to
purchase,breed, train and racequarter horses
in the
UnitedStates
and Mexico.
Case 1:12-cr-00210-SS Document 45 Filed 05/30/12 Page 3 of 25
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