Case 5:13-cr-00701-FB Document 3 Filed 08/21/13 Page 1 of 3

$EALED

IJNIT
STATES DISTRICT COIJRT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
UNITED STATES OF AMERICA,

Li3 4L
..

:RM

IF

Plaintiff,

21

EZEQUIEL RODRIGUEZ aka "CHEKE" (1),

Defendant.

CT 1: 21:846 & 841(a)(1)Conspiracy to Possess a Controlled

Substance with Intent to Distribute
(over 5 kilos cocaine);
CT 2: 21:952 & 960(a)(l)Conspiracy to Import with Intent to
Distribute a Controlled Substance
(over 5 kilos cocaine);
CT 3: 21:952 & 960(a)(l)Conspiracy to Import with Intent to
Distribute a Controlled Substance
(over 1000 kilos marijuana);

THE GRAND JURY CHARGES:

COUNT ONE
[21 U.S.C. 841, 8461
Begiiming on or about January 1, 2000 and continuing until on or about January

1, 2011

in the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,

EZEQUIEL RODRIGUEZ aka "CHEKE" (1)

did combine, conspire, confederate and agree with others known and unknown to the Grand Jury
to possess with intent to distribute and distribute 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, 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.

Case 5:13-cr-00701-FB Document 3 Filed 08/21/13 Page 2 of 3

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,

2011, in the Western District of Texas, Defendant,

EZEQUIEL RODRIGUEZ aka "CHEKE" (1)

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others to the Grand Jury known and unknown, to commit offenses against the United States, in

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,

EZEQUIEL RODRIGUEZ aka "CHEKE" (1)

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others to the Grand Jury known and unknown, to commit offenses against the United States, in

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),

960(a)(l) and 960(b)(1)(G).

Case 5:13-cr-00701-FB Document 3 Filed 08/21/13 Page 3 of 3

A TRUE BILL.

FOREPERSN
ROBERT PITMAN
UNITES STATES ATTORNEY

RUS SELL D. LEACHMAN

Assistant United States Attorney

OTHEtD JURY