El Paso Drug Kingpins

Case 3:15-cr-00228-DB Document 476 Filed 10/28/15 Page 1 of 46
IN THE UNITED STATES DISTRICT COURT L F0

FORTHEWESTERNDISTRECTOFTEXAS 'it) j
ELPASODIVISION Y'
UNITED STATES OF AMERICA, CRIMINAL NO.

Plaintiff, SEALED r
FOURTH SUPERSEDING
V. INDICTMENT

EMMANUEL VELASCO GURROLA, CT 1: 18 U.S.C. 1962(d); Conspiracy to
a.k.a. Richie, a.k.a. Ricardo, Conduct the Affairs of an Enterprise
a.k.a. Keke (1); through a Pattern of Racketeering
SAMUEL VELASCO GURROLA (2); Activity;
NORMA URANGA-CONTRERAS, CT 2: 21 U.S.C. 846; Conspiracy to
a.k.a. La Dona (3); Possess with the Intent to Distribute A
JOSE RICARDO RODRIGUEZ (4); Controlled Substances;
CESAR ALFONSO SILVA, CT 3: 21 U.S.C. 963; Conspiracy to
a.k.a. Chikis (5); Import a Controlled Substance;
AURELIO SETURINO, a.k.a. Gordo (6); CTS 4-5: 18 U.S.C. 1956(h);
RICARDO SANCHEZ-OLIVERA, a.k.a. Conspiracy to Launder Monetary
Rica(7); Instruments;
ALFREDO QUINONES, CT 6: 18 U.S.C. 1951; Hobbs Act
a.k.a. Esmerelda, a.k.a. Alfredo Flores, Conspiracy; and
a.ka. Alfred 'Quinones-Macias (8); CTS 7-8: 18 U.S.C. 956(a)(1);
HAZEL RODRIGUEZ (9); Conspiracy to Kidnap in a Foreign
DALIA VALENCIA, a.k.a. Dalia Country.
Velasco, a.k.a. Dalia Krantz, a.k.a. Dalia
Krantz-Valencia (10); NOTICE OF GOVERNMENT'S
GARMENDOZ%M a.k.a. Chuv (in; DEMAND FOR FORFEITURE

Defendants.
COUNT ONE
(RICO Conspiracy)
(18 U.S.C. 1962(d))
THE RACKETEERING ENTERPRISE
The Grand Jury charges:
1. At all times relevant to this Fourth Superseding Indictment, in the Western
District of Texas and elsewhere, the defendants,
EMMANUEL VELASCO GURROLA, a.k.a. Richie, a.k.a. Ricardo, a.k.a. Keke (1);
SAMUEL VELASCO GURROLA (2);
JOSE RICARPO RODRIGUEZ (4);
AURELIO SETURINO, a.k.a. Gordo (6);
ALFREDO QUINONES, a.k.a. Esmerelda, a.k.a. Aifredo Flores, a.k.a. Alfred Quinones-
Maclas (8);
DALIA VALENCIA, a.k.a. Dalia Velasco, a.k.a. Dalia Krantz,
a.k.a. Dalia Krantz-Valencia (10);
EDGAR MENDOZA. a.k.a. Chuv (11);
and others to the Grand Jury known and unknown were members and associates of a criminal
organization engaged in the distribution, possession with the intent to distribute and the
importation of controlled substances, car theft, kidnapping, robbery, extortion, and money
laundering. At all relevant times, this organization has operated in the Western District of Texas
and elsewhere, and will be referred to hereinafter in this Fourth Superseding Indictment as the
"Velasco Criminal Enterprise" or "VCE" or "The Enterprise." VCE, including its membership
and associates, constituted an "enterprise," as defined by Title 18, United States Code, Section
1961(4) (hereinafter "the enterprise"), that is to say, a group of individuals associated in fact.
The enterprise was engaged in and its activities affected interstate and foreign commerce, and
constituted an ongoing organization. VCE is an illegal association in fact entity. The enterprise
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constituted an ongoing organization whose members functioned as a continuing unit for a
common purpose of achieving the objectives of the enterprise.
Purposes of the Enterprise
2. The purposes of the enterprise included the following:
a. Enriching the members and associates of the enterprise through, among

other things, the distribution and importation of controlled substances,
kidnapping, robbery, car theft, extortion and money laundering;
b. Enriching the members and associates of the enterprise through, among

other things, violence and threats of violence;
c. Promoting and enhancing the activities and authority of the enterprise and
its members and associates;
d. Preserving and protecting the continuity and profits of the enterprise

through the use of intimidation, violence and threats of violence;
e. Keeping victims and others in fear of the enterprise and in fear of its
members and associates through violence and threats of violence.
Manner and Means of the Enterprise
3. Among the means and methods by which the defendant, and his associates
conduct and participate in the conduct of the affairs of the Enterprise were the following:
a. Members of the Enterprise and their associates would engage in the
importation into the United States from Mexico of large quantities of controlled substances as a
means to generate income.
b. Members of the Enterprise and their associates would arrange for the
transportation and distribution of large quantities of controlled substances as a means to generate
income.
c. Members of the Enterprise and their associates would conduct financial
transactions in order to distribute the proceeds of the Enterprise's drug trafficking activities.
I_i.IIuhI
d. Members of the Enterprise and their associates would arrange for the
proceeds of their drug trafficking activities to be transported from cities within the interior of the
United States back to El Paso, Texas, and into Mexico.
e. Members of the Enterprise and their associates would steal vehicles as a
means to generate income.
f. Members of the Enterprise and their associates would possess
and utilize firearms and ammunition in order to maintain and advance the goals of the Enterprise.
g. Members of the Enterprise and their associates would kidnap individuals,
extort money from individuals, and rob individuals as a means to generate income.
h. Members of the Enterprise would organize, use, and threaten to use
physical violence against various individuals.
Structure of the Enterprise

4. VCE is based in El Paso, Texas. It has significant resources and activity in other
parts of Texas, Juarez, Mexico, Las Vegas, Nevada, New Mexico, and North and South Carolina.
5. The primary purpose of VCE is to smuggle huge quantities of marijuana, as well
as other drugs such as cocaine, into the United States and distribute them in El Paso, Texas, as
well as to various destination cities in the United States. One method utilized by VCE in its drug
trafficking operations is to rip off or steal drug loads from soures of supply or competing drug
trafficking organizations and then sell those stolen drugs for profit. VCE engages in other
activities, such as theft and burglary of vehicles, kidnapping and extortion, robbery, and money
laundering in order to facilitate the drug trafficking business and also to generate income for the
Enterprise. VCE also engages in actions to ensure its members stay loyal and follow orders from
the VCE leadership; such actions include threats and acts of violence, intimidation, investigation
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into members' criminal cases, hiring lawyers for members who are charged with crimes related
to the Enterprise, and taking steps to ensure that members do not cooperate with law
enforcement.
6. Various members of VCE engage in the theft and burglary of motor vehicles in
the El Paso, Texas, area, in order to sell those vehicles to individuals in Mexico. These stolen
vehicles are also utilized by VCE to transport narcotics andlor to transport drug proceeds into
Mexico.
7. VCE engages in kidnapping individuals and extorting money from these
individuals and these individuals' families; the money made from the kidnapping and extortion
activities is funneled back into the Enterprise. The kidnapping operations for VCE are carried
out in teams, with certain members being responsible for providing names of possible victims,
other members being responsible for scouting the victims and providing intelligence regarding
the victims' schedule or whereabouts, other members purchasing and obtaining the necessary
firearms and ammunition to be used by the team and sending those items south into Mexico,
other members procuring rental vehicles to be used by the kidnapping team, other members
making contact with the victims and abducting them, other members communicating with
victims' families and making ransom demands, and other members transporting ransom
payments from Mexico into the United States.
8. The proceeds generated by trafficking in marijuana and cocaine are returned to
VCE through various methods of money laundering. That money is then used by leadership in
VCE to pay its sources of supply of narcotics in Mexico; to pay its members and associates; to
reinvest in the acquisition, production, and trafficking of drugs; and to invest in the Enterprise by
purchasing assets and properties related to the daily function of VCE, such as buying and renting
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vehicles. Members of VCE also engage in transferring property and assets among themselves in
order to pay members for services and to conceal the identities of the top leadership of VCE.
9. EMMANUEL VELASCO GURROLA a.k.a. Richie, a.k.a. Ricardo, ak.a. Keke
("VELASCO") is the head of VCE, providing instruction and direction to all higher-ranking
members of VCE regarding kidnapping, extortion, robbery, drug trafficking, and money
laundering endeavors. SAMUEL VELASCO GURROLA ("S. VELASCO") is a co-leader of
VCE and has been the head of VCE in the absence of Velasco. YCE engages in
compartmentalization of its members, meaning that certain members of VCE are kept separate
from and have no knowledge of each other. VELASCO and S. VELASCO engage in this
behavior in order to protect themselves and other high-ranking members of the Enterprise from
law enforcement and criminal prosecution and also to ensure that members of the Enterprise do
not bypass or cut them out of the activities of the Enterprise.
Roles of the Defendants
10. Defendant, VELASCO, is the leader of VCE. VELASCO provides instruction and
direction to most all of VCE's members, save and except the most low-level members of VCE,
such as drug couriers. VELASCO is responsible for the importation and distribution of over a
thousand kilograms of marjuana and multi-kilogram quanties of cocaine into and throughout the
United States. VELASCO utlizes his brother and sisters, as well as top associates, to protect his
identity and assets, as well as to ensure that all day-to-day functions of VCE are managed.
VELASCO personally steals and oversees the theft of vehicles for VCE. VELASCO also
organizes and runs all of VCE's kidnapping teams; in addition, VELASCO personally
communicates with the kidnapping victims' families and negotiates ransom payments.
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11. Defendant, S. VELASCO, is a co-leader of VCE and is brother to VELASCO. S.
VELASCO provides direction and instruction to many of VCE's members. S. VELASCO is
responsible for many money laundering aspets of VCE. S. VELASCO is responsible for the
importation and distribution of over a thousand kilograms of marjuana and multi-kilogram
quanties of cocaine into and throughout the United States. S. VELASCO has run the kidnapping
teams for VCE. S. VELASCO provides names of targets for kidnappings, communicates with
the kidnapping victims' families, and negotiates ransom payments.
12. Defendant, JOSE RICARDO RODRIGUEZ ("RODRIGUEZ"), is a member of
VCE primarily responsible for receiving VCE' s narcotics, which are coming from Mexico,
through El Paso, Texas, and then into the Dallas, Texas, area. RODRIGUEZ is also responsible
for ensuring that drug proceeds from the sale of those narcotics are returned to El Paso, Texas,
and Mexico via various money laundering methods. RODRIGUEZ works extensively with
AURELIO SETURINO a.k.a. Gordo ("SETUR1NO") in Dallas,
Texas, in order to sell and distribute VCE's marijuana. RODRIGUEZ has extensive interactions
with and takes direction from both VELASCO and S. VELASCO.
13. Defendant, SETUR1NO is VELASCO and S. VELASCO's cousin. SETUR1NO
is in charge of VCE's Dallas operations, which consists of receiving shipments of drugs from El
Paso, Texas, and then distributing those drugs in Dallas, Texas. SETURINO is also responsible
for ensuring that VCE' s drug proceeds are delivered or transported from Dallas, Texas, to El
Paso, Texas. SETIJRJNO worked closely with RODRIGUEZ and G to faciliate VCE's
operations in Dallas, Texas.
14. Defendant, ALFREDO QUINONES, a.k.a. Esmerelda, a.k.a Aifredo Flores,
a.k.a. Alfred Quinones-Macias ("QUINONES") is one of VELASCO's top associates.
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QU1NONES participated in paying drug couriers, loading, unpackaging, and transporting
narcotics, using and allowing his bank account to be used to launder drug procedes for the
Enterprise, and transporting drug proceeds. QUTNONES is also an active member of VCE's
kidnapping and extortion ring.
15. Defendant, DALIA VALENCIA, a.k.a. Dalia Velasco, a.k.a. Dalia Krantz, a.k.a.
Dalia Krantz-Valencia ("VALENCIA"), is VELASCO and S. VELASCO's sister. VALENCIA
is primarily in charge of handling and storing VCE's money. VALENCIA also engages in
transfer of ownership of property for the Enterprise. Members of VCE would meet with
VALENCIA to deliver drug proceeds to VALENCIA or to pick up drug proceeds from
VALENCIA. VALENCJA would provide money to pay couriers and would also provide
direction to other members of VCE regarding what should be done with the money.
VALENCIA is responsible for renting vehicles for use by VCE members in both the
transportation of narcotics, the transporation of drug proceeds, and also for use in VCE's
kidnapping activities. In addition to renting vehicles for use in kidnappings, as a member of the
kidnapping team, VALENCIA would also provide names of possible victims to kidnap.
16.
17.
S
18. Defendant, EDGAR MENDOZA, a.k.a. Chuy ("MENDOZA"), was an active
member of the drug-trafficking and kidnapping team aspects of VCE. MENDOZA would take
direction from VELASCO and would provide him with whatever assistance was needed with
regard to drug-trafficking and kidnapping efforts.
19.
THE RACKETEERING CONSPIRACY
That beginning on or about 2007 and continuing through and including on or about the
date of this indictment, within the Western District of Texas and elsewhere, the defendants,
SAMUEL VELASCO GUIRROLA (2);
JOSE RICARDO RODRIGUEZ (4);
Macias (8);
EDGAR MIENDOZA, a.k.a. Chuy (11);
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being persons employed by and associated with the Velasco Criminal Enterprise, which engaged
in, and the activities of which affected, interstate and foreign commerce, knowingly combined,
conspired, confederated, and agreed together, and with others known and unknown to the Grand
Jury, to violate Title 18, United States Code, Section 1962(c), that is to say, to conduct and
participate, directly and indirectly, in the conduct of the affairs of that enterprise through a
pattern of racketeering activity, as that term is defined in Sections 1961(1) and 1961(5) of Title
18, United States Code, consisting of multiple acts indictable under the following provisions of
federal law:
a. 18 U.S.C. 1956 (relating to the laundering of monetary instruments);
b. 18 U.S.C. 2312 (relating to interstate I foreign transportation of stolen

vehicles);
c. 18 U.S.C. 1951 (conspiracy to interfere with commerce, robbery, and

extortion);
d. 18 U.S.C. 956(a)(1) (conspiracy to kidnap in a foreign country); and
e. Multiple offenses involving 21 U.S.C. 841(a)(1), 846, 952, and 963

(involving trafficking and importation of controlled substances and
conspiracies to commit trafficking and importation of controlled
substances);
and multiple acts involving the following provisions of state law:
f. Texas Penal Code 29.03 (aggravated robbery), 15.01 (attempt), 15.02

(conspiracy), and 7.02(a)(2) (aiding and abetting);
It was further part of the conspiracy that each defendant agreed that a conspirator would commit
at least two acts of racketeering activity in the conduct of the affairs of the enterprise.
OVERT ACTS
20. On or about October 24, 2007, EMMANUEL VELASCO GURROLA and other
co-conspirators known to the grand jury were found to be in possession of multiple stolen
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vehicles. EMMANUEL VELASCO GURROLA and other members of the Enterprise stole
these vehicles for the purpose of transporting the vehicles to Juarez, Mexico, and selling them.
21. On or about July 25, 2008, a co-conspirator known to the grand jury was in
possession of a vehicle that he and members of the Enterprise had previously stolen.
22. On or about September of 2008 through November of 2008, EMMANUEL
VELASCO GURROLA, SAMUEL VELASCO GURROLA, DALIA VALENCIA, and others
conspired to commit the robbery and murder of FSV, the murder of RSE, the murder of CSE,
and the murder of RMB.
23. On or about October 2, 2008, DALIA VALENCIA rented a Pontiac G6 in El
Paso, Texas, and returned it in El Paso, Texas, on or about October 3, 2008. The Pontiac G6
crossed into the United States from Mexico at an El Paso, Texas, port of ently on or about
October 2, 2008.
24. On or about October 3, 2008, members of VCE committed a robbery and murder
of FSV.
25. On or about November 20, 2008, members of VCE committed the murder of
CSE.
26. On or about November 22, 2008, members of VCE committed the murder of RSE
27. On or about November 23, 2008, Alan Garcia crossed into the United States from
Mexico at an El Paso, Texas, port of entry in a vehicle driven by a co-conspirator known to the
grand jury.
28. On or about November 27, 2008, DALIA VALENCIA rented Cadillac STS in El
Paso, Texas, and returned it in El Paso, Texas, on or about November 29, 2008. Alan Garcia
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crossed that Cadillac STS into the United States from Mexico at an El Paso, Texas, port of entry
on or about November 28, 2008.
29. On or about December 12, 2008, DALIA VALENCIA rented a Chevrolet Malibu
in El Paso, Texas, and returned it in El Paso, Texas, on or about December 13, 2008. The
Chevrolet Malibu was crossed into the United States from Mexico at an El Paso, Texas, port of
entry by Alan Garcia on or about December 12, 2008.
30. On or about December 28, 2008, DALIA VALENCIA rented a Chevrolet
Trailblazer in El Paso, Texas, and returned it in El Paso, Texas, on or about December 30, 2008.
The Chevrolet Trailblazer was crossed into the United States from Mexico at an El Paso, Texas,
port of entry by a co-conspirator known to the grand jury on or about December 30, 2008.
31. On or about December 31, 2008, DALIA VALENCIA rented a Chevrolet Impala
in El Paso, Texas, and returned it in El Paso, Texas, on or about January 2, 2009. The Chevrolet
Impala was crossed into the United States from Mexico at an El Paso, Texas, port of entry by
Alan Garcia on or about January 2, 2009.
32. On or about February 13, 2009, DALIA VALENCIA rented a Chevrolet Malibu
in El Paso, Texas, and returned it in El Paso, Texas, on or about February 16,2009. The
Chevrolet Malibu was crossed into the United States from Mexico at an El Paso, Texas, port of
entry on or about February 14, 2009, and again on or about February 16, 2009, by Alan Garcia.
33. On or about April 22, 2009, members of the Enterprise, including Alan Garcia
and Rodriguo Saenz Garcia, kidnapped two individuals in Juarez, Mexico, in order to extort
money from them and their families. Alan Garcia and Rodrigo Saenz Garcia were killed by
other members of the kidnapping team during the incident.
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34. On or about July 7, 2009, a co-conspirator known to the grand jury and others
entered a victim's garage, entered vehicles in that garage, and attempted to steal those vehicles.
35. On or about July 30, 2009, and continuing through and including August 5, 2009,
SAMUEL VELASCO GURROLA filed a false police report, obstructed a state and local
investigation, and participated in harboring EMMANUEL VELASCO GURROLA, a fugitive.
36. On or about August 1, 2009, EMMANUEL VELASCO GURROLA,
and other members of the Enterprise planned and coordinated the kidnapping of
victim number. one in the United States. Members of the Enterprise kidnapped victim number
one in Mexico and held victim number one for ransom. Members of the Enterprise extorted
money from victim number one and the family of victim number one.
37. On or about August 13, 2009, ALFREDO QUINONES rented a GMC Yukon in
El Paso, Texas, and returned it in El Paso, Texas, on or about August 14, 2009. The GMC
Yukon was crossed into the United States from Mexico at an El Paso, Texas, port of entry on or
about August 14, 2009, by a a co-conspirator known to the grand jury and another person known
to the grand jury.
38. On or about August 14, 2009, ALFREDO QUThTONES rented a silver Infiniti
SUV in El Paso, Texas, and returned it in El Paso, Texas, on or about August 26, 2009.
39. On or about August 15, 2009, August 18, 2009, August 20, 2009, and August 21,
2009, a person known to the grand jury crossed a silver Infiniti SUV into the United States from
Mexico, at an El Paso, Texas, port of entry.
40. On or about August 21, 2009, EMMANUEL VELASCO GURROLA, SAMUEL
VELASCO GURROLA, EDGAR MENDOZA, ALFREDO QUINONES, and other co-
conspirators known to the grand jury planned and coordinated the kidnapping of victim number
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two in the United States. Members of the Enterprise kidnapped victim number two in Mexico
and held victim number two for ransom. Members of the Enterprise extorted and attempted to
extort money from victim number two and the family of victim number two.
41. On or about September 2, 2009, DALIA VALENCIA rented a Ford F-iSO truck
in El Paso, Texas, and returned it in El Paso, Texas, on or about September 3, 2009. A person
known to the grand jury crossed this Ford F- 150 truck into the United States from Mexico at an
El Paso, Texas, port of entry on or about September 3, 2009.
42. On or about September of 2009, SAMUEL VELASCO GURROLA purchased a
2005 Chrysler 300c truck and provided it to a person known to the grand jury.
43. On or about September 12, 2009, SAMUEL VELASCO GURROLA rented a
Pontiac G6 in El Paso, Texas, and returned it in El Paso, Texas, on or about September 13, 2009.
The Pontiac G6 was crossed into the United States from Mexico by a co-conspirator known to
the grand jury on or about September 13, 2009.
44. On or about November 7, 2009, SAMUEL VELASCO GURROLA purchased a 9
mm Smith and Wesson pistol from a pawn shop located in El Paso, Texas.
45. Between at least 2009 and 2013, SAMUEL VELASCO GURROLA,
EMMANUEL VELASCO GURROLA, EDGAR MENDOZA,
DALIA VALENCIA, ALFREDO QU1NONES, and other members of the Enterprise planned
and executed the kidnappings and extortions of multiple individuals in the United States and
Juarez, Mexico, including local business owners, medical professionals, students, and children.
46. On or about December of 2009, a co-conspirator known to the grand jury and
others, extorted items of value, including money and vehicles, from a person known to the grand
14
jury, for the purpose of receiving said items of value and utilizing said items of value to enrich
the Enterprise.
47. On or about February 4, 2010, SAMUEL VELASCO GURROLA rented a Jeep
Commander in El Paso, Texas, and returned it in El Paso, Texas, on or about February 5, 2010.
A person known to the grand jury crossed the Jeep Commander into the United States from
Mexico at an El Paso, Texas, port of entry on or about February 5, 2010.
48. On or about February 11,2010, SAMUEL VELASCO GURROLA rented a
Nissan Murano in El Paso, Texas, and returned it in El Paso, Texas, on or about February 12,
2010. SAMUEL VELASCO GURROLA and a person known to the grand jury crossed the
Nissan Murano from Mexico into the United States at an El Paso, Texas, port of entry on or
about February 12, 2010. A co-conspirator known to the grand jury crossed from Mexico into
the United States at an El Paso, Texas, port of entry on or about February 12, 2010.
49. On or about March 7, 2010, a person known to the grand jury reported a vehicle, a
2008 Chevrolet Silverado, utilized by SAMUEL VELASCO GURROLA, as stolen.
50. On various dates on or about 2011, EDGAR MENDOZA and a person known to
the grand jury crossed a Pontiac vehicle loaded with marijuana from the United States into
Mexico on behalf of the Enterprise.
51. On or about October 29, 2011, ALFREDO QUINONES rented a Kia Sportage in
El Paso, Texas, and returned it in El Paso, Texas, on or about October 31, 2011. The Kia
Sportage was crossed into the United States from Mexico at an El Paso, Texas, port of entry on
or about October 31, 2011 by EDGAR MENDOZA.
52. On or about December of 2011 through January 30, 2012, a person known to the
grand jury imported at least 100 kilograms of marijuana into the United States from Mexico, and
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on or about January 30, 2012, imported approximately 20 kilograms of marijuana into the United
States from Mexico at an El Paso, Texas, port of entry.
53. On or about April 19, 2012, ALFREDO QUINONES rented a GMC Acadia in El
Paso, Texas, and returned it in El Paso, Texas, on or about April 20, 2012.
crossed this GMC Acadia into theUnited States from Mexico on or about April
20, 2012, at an El Paso, Texas, port of entry.
54. On or about March 4, 2013, a person known to the grand jury imported 15
kilograms of marijuana into the United States from Mexico at an El Paso, Texas, port of entry.
55. On or about July 2013, an El Paso Police Department officer observed DALIA
VALENCIA and a co-conspirator known to the grand jury together. The officer observed the co-
cOnspirator known to the grand jury taking keys from the ignition of a 2007 Cadillac Escalade
with temporary tags, while DALIA VALENCIA was in a Jaguar vehicle. DALIA VALENCIA
told the officer that she was selling the 2007 Cadillac Escalade to this co-conspirator known to
the grand jury.
56. EMMANUEL VELASCO GURROLA sent hundreds of pounds of marijuana and
kilograms of cocaine to clients in North Carolina and South Carolina from at least 2013 through
2014. ALFREDO QUINONES provided his Wells Fargo account number to a co-conspirator
known to the grand jury so that the account number could then be provided to the clients in
North Carolina and South Carolina for the purpose of depositing drug proceeds. The co-
conspirator known to the grand jury did provide ALFREDO QUINONES' bank account number
to the clients in North Carolina and South Carolina. Thse clients in North Carolina and South
Carolina deposited drug proceeds into ALFREDO QU1NONES' bank account. After deposits
were made, ALFREDO QUINONES would withdraw the drug proceeds and provide the drug
proceeds to a co-conspirator known to the grand jury. That Co-conspirator would provide the
drug proceeds to DALIA VALENCIA.
57. ALFREDO QUINONES and a person known to the grand jury opened separate
accounts at the same Bank of America branch in El Paso, Texas, on the same day, on or about
May 24, 2013. The last four digits of ALFREDO QU1NONES' account are *2208, and the last
four digits of the account belonging to a person known to the grand jury are *0897. During May
of 2013 and June of 2013, both accounts reveal money deposited in cash in South Carolina and
then immediately withdrawn, in the same amounts, in El Paso, Texas, on the same day or shortly
thereafter.
58. Between on or about August 2013 through March 2014, ALFREDO QUINONES'
Wells Fargo bank account number * 1349 reveals cash deposits, in multiple transactions, going
into this account in North Carolina. The money deposited, mostly in. exact amounts, is then
withdrawn in El Paso, Texas, on the same day or shortly thereafter. Approximately $26,000 was
funneled through ALFREDO QUINONES' account during this time period.
59. On or about August 29, 2013, through September 4, 2013, EMMANUEL
VELASCO GURROLA is recorded discussing drug trafficking activities, including the
movement of drug proceeds, with a person known to the grand jury.
60. On or about September of 2013, DALIA VALENCIA provided a 2007 Cadillac
Escalade, which she owned, to a co-conspirator known to the grand jury.
61. From about September of 2013 through October 24, 2013, EMMANUEL
VELASCO GURROLA negotiated and arranged for the distribution of methamphetamine.
62. On or about October of 2013 through November of 2013, a person known to the
grand jury imported at least 200 kilograms of marijuana into the United States from Mexico, and
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on or about November 16, 2013, a person known to the grand jury imported approximately 20
kilograms of marijuana into the United States from Mexico at an El Paso, Texas, port of entry.
63. On or about November 16, 2013, EMMANUEL VELASCO GURROLA is
recorded talking to a person known to the grand jury about a seizure of marijuana that occurred
at a port of entry in El Paso, Texas.
64. On or about November 3, 2013, a person known to the grand jury imported into
the United States from Mexico about half a kilogram of marijuana at a port of entry located in El
Paso, Texas. Members of the Enterprise had just removed approximately 14 kilograms of
marijuana from the vehicle this person was driving but forgot to remove one of the packages.
65. On or about November 20, 2013, a person known to the grand jury imported into
the United States from Mexico about 35 kilograms of marijuana at a port of entry located in El
Paso, Texas.
66. On or about December 12, 2013, a person known to the grand jury imported into
the United States from Mexico about 25 kilograms of marijuana at a port of entry located in El
Paso, Texas.
67. On or about December 23, 2013, a person known to the grand jury was in
possession of about 13 kilograms of marijuana in Memphis, Texas, belonging to the Enterprise.
68. During December of 2013, a co-conspirator known to the grand jury and
ALFREDO QUINONES coordinated for the importation of hundreds of pounds of marijuana
from Mexico into El Paso, Texas, and the distribution of that marijuana. In addition, on or about
December 4, 2013, ALFREDO QUINONES and a co-conspirator known to the grand jury were
in possession of 150 kilograms of marijuana.
18
69. On or about 2014, co-conspirator one and two, both known to the grand jury,
conducted a cocaine transaction at EMMANUEL VELASCO GURROLA's behest. Co-
conspirator one delivered one kilogram of cocaine to co-conspirator number two. Co-conspirator
two delivered a Cadillac Escalade as payment for the cocaine to co-conspirator number one and
then provided the Cadillac Escalade to
EMMANUEL VELASCO GURROLA.
70. On or about January 9, 2014, JOSE RICARDO RODRIGUEZ, using cellular
telephone, (972) 802-9666, has text message exchanges with the user of cellular telephone 469-
615-0777, which discuss drug trafficking activities.
71. On or about March 28, 2014, ALFREDO QUINONES coordinated with members
of the Enterprise, including EMMANUEL VELASCO GURROLA, to take possession of
approximately 136 kilograms of marijuana that had been crossed into the United States from
Mexico.
72. On or about March 29, 2014, a co-conspirator known to the grand jury and others
imported at least 36 kilograms of marijuana into the United States from Mexico. A co-
conspirator known to the grand jury was arrested for the criminal offense of transporting illegal
aliens. About $7600 of drug proceeds was seized from this co-conspirator by United States
Border Patrol on or about March 29, 2014.
73. On or about April of 2014, SAMUEL VELASCO GURROLA paid the attorney's
fees for a co-conspirator known to the grand jury who had been arrested for criminal offenses
related to the business of the Enterprise.
74. On or about June 30, 2014, SAMUEL VELASCO GURROLA rented a Ford
Mustang in Dallas, Texas, and returned it in El Paso, Texas, on or about July 1, 2014.
19
75. On or about June 30, 2014, a co-conspirator known to the grand jury was arrested
at a port of entry in El Paso, Texas, attempting to travel into Mexico, while driving a 1997
Mitsubishi Eclipse owned by and registered to SAMUEL VELASCO GURROLA. This Co..
conspirator known to the grand jury had in his possession a 32 caliber semi automatic pistol and
various ammunition.
76. On or about July 2, 2014, SAMUEL VELASCO GURROLA filed a false police
report with El Paso Police Department claiming that his 1997 Mitsubishi Eclipse been stolen
from the street outside of his residence.
77. On or about July 3, 2014, SAMUEL VELASCO GURROLA traveled to
Lordsburg, New Mexico, to pick up drug proceeds for the Enterprise and then transported the
proceeds back to El Paso, Texas.
78. On or about July of 2014, EMMANUEL VELASCO GURROLA is recorded
threatening violence on a co-conspirator known to the grand jury because that co-conspirator was
responsible for loss of drug proceeds belonging to the Enterprise.
79. On or about July 12, 2014, SAMUEL VELASCO GURROLA and other co-
conspirators known to the grand jury conducted a financial transaction at Wells Fargo Bank in
order to transfer drug proceeds belonging to the Enterprise from one co-conspirator's possession
into SAMUEL VELASCO GURROLA's possession.
80. On or about July 25, 2014, a co-conspirator known to the grand jury imported
about 22 kilograms of marijuana into the United States from Mexico at an El Paso, Texas, port of
entry.
81. On or about July 28, 2014, SAMUEL VELASCO GURROLA rented a Ford
Mustang in Dallas, Texas, and returned it on or about July 29, 2014, in El Paso, Texas.
20
82. On or about August 15, 2014, through August 17, 2014, EMMANUEL
VELASCO GURROLA, SAMUEL VELASCO GURROLA, JOSE RICARDO RODRIGUEZ,
AURELIO SETURINO, and others coordinated for drug proceeds to be
transported from Dallas, Texas, to El Paso, Texas, and Mexico. SAMTJEL VELASCO
GURROLA was encountered with about $85,000 in drug proceeds, which was seized from him.
83. From on or about February through December of 2014, JOSE R1CARDO
RODRIGUEZ, using cellular telephone (972) 802-9666, has various text message exchanges
with EMIMANUEL VELASCO GURROLA, utilizing cellular telephone (760) 905-4377. These
text message exchanges discuss drug trafficking activities, co-conspirators such as AURELIO
SETURINO, and vehicles utilized as part of the Enterprise.
84. On or about November 24, 2014, EMMANUEL VELASCO GURROLA, using
cellular telephone (805) 806-5246, sends text messages to JOSE RICARDO RODRIGUEZ'
cellular telephone number, (214) 454-4992. The text messages from EMMANUEL VELASCO
GURROLA state "I have the number. Of the piggy bank." EMMANUEL VELASCO
GURROLA then sends JOSE RICARDORODRIGUEZ the full account number followed by the
letters WF. The last four digits of this account are *9545 EMMANUEL VELASCO
GURROLA, on or about November 26, 2014, sends a text message to JOSE RICARDO
RODRIGUEZ that says thank you and that he got the check.
85. Between on or about October of 2014 through December of 2014, ALFREDO
QUINONES' Wells Fargo bank account number * 9545 reveals cash deposits, in multiple
transactions, going into this account in both Garland, Texas, which is a suburb of Dallas, Texas,
and North Carolina. The money deposited, mostly in exact amounts, is then withdrawn in El
21
Paso, Texas, on the same day or shortly thereafter. Approximately $17,000 was funneled
through ALFREDO QUINONES' account during this time period.
86. In ALFREDO QUINONES' Wells Fargo account *9545, on or about November
26, 2014, a deposit of $4500 occurred in Garland, Texas. On or about December 1, 2014, there
was a withdrawal of $4500 from the same account that occurred in El Paso, Texas.
87. In January of 2015, SAMUEL VELASCO GURROLA, utilizing cellular
telephone 915-496-7806, has various text message exchanges with JOSE RICARDO
RODRIGUEZ, utilizing cellular telephone, 214-621-1468, discussing drug trafficking activities.
88. In January of 2015, SAMUEL VELASCO GURROLA, utilizing cellular
telephone 915-496-7806, has various text message exchanges with JOSE RICARDO
RODRIGUEZ, utilizing cellular telephone 214-629-9341. These text message exchanges discuss
the state of drug trafficking activities, co-conspirators such as EMMANUEL VELASCO
GURROLA and AURELIO SETURINO, and vehicles utilized as part of the Enterprise.
89. From on or about February through March of 2015, JOSE RICARDO
RODRIGUEZ, using cellular telephone 214-684-2057, has various text message exchanges with
EMMANUEL VELASCO GURROLA, utilizing cellular telephone 707-343-6214, regarding
contacting each other.
90. On or about February of 2015, JOSE RICARDO RODRIGUEZ, using cellular
telephone 972-896-5916, has various text message exchanges with EMMANUEL VELASCO
GURROLA, utilizing cellular telephone 707-676-0945, regarding contacting each other and drug
trafficking activities.
91. On or about April of 2015, EMMANUEL VELASCO GURROLA is recorded
discussing the arrests of ALFREDO QUINONES and other members of the Enterprise.
22
EMMANUEL VELASCO GURROLA is recorded telling a person known to the grand jury to
investigate the arrests and charges of particular VCE members in order to determine who was
arrested together, who is in jail, and with what they are charged.
92. On or about March 28, 2015, through April 8, 2015, EMMANUEL VELASCO
GURROLA arranged for currency to be delivered to members of the Enterprise to pay for drug
trafficking activities.
93. On or about April of 2015, EMMANUEL VELASCO GURROLA is recorded
discussing registering a vehicle in order for it to be used to transport drug proceeds.
94. On or about April of 2015, EMMANUEL VELASCO GURROLA, a person
known to the grand jury, and are recorded discussing drug trafficking activities,
specifically sending narcotics to Dallas, coming to El Paso to pick up narcotics, and that
owes EMMANUEL VELASCO GURROLA money.
95. On or about May 14, 2015, a co-conspirator known to the grand jury imported
about 50 kilograms of marijuana into the United States from Mexico at a port of entry in El Paso,
Texas.
96. On or about May 12, 2015, two black ski masks were seized from an Isuzu
vehicle owned and/or operated by SAMUEL VELASCO GURROLA.
NOTICE OF SPECIAL SENTENCING FACTORS
I.
On or about August 1, 2009, in the Western District of Texas and elsewhere, Defendants
EMMANUEL VELASCO GURROLA. a.k.a. Richie, a.k.a. Ricardo, a.k.a. Keke (1);
23
knowingly conspired with others known and unknown to the Grand Jury, to commit at any place
outside of the United States, namely, Mexico, an act that would constitute kidnapping if
committed in the special maritime and territorial jurisdiction of the United States and did commit
an act within the jurisdiction of the United States to effect an object of that conspiracy, in
violation of Title 18, United States Code, Section 956(a)( 1).
LI.
On or about August 21, 2009, in the Western District of Texas and elsewhere, Defendants
SAMUEL YELASCO GURROLA (2);
Macias (8);
and
EDGAR MENDOZA, a.k.a. Chuy (13),
knowingly conspired with others known and unknown to the Grand Jury, to commit at any place
outside of the United States, namely, Mexico, an act that would constitute kidnapping if
committed in the special maritime and territorial jurisdiction of the United States and did commit
an act within the jurisdiction of the United States to effect an object of that conspiracy, in
violation of Title 18, United States Code, Section 956(a)(1).
III.
That beginning on or about 2011 and continuing through and including on or about the
date of this indictment, in the Western District of Texas and elsewhere, the defendants
Macias (8);
24
EDGAR MENDOZA, a.k.a. Chuy (11);
knowingly and intentionally conspired to possess with the intent to distribute, and conspired to
import into the United States from Mexico, one thousand kilograms or more of marijuana, in
violation of Title 21, United States Code, Sections 846, 84 1(a), and 841(b)(1)(A)(vii) and 963,
952, and 960(b)(l)(G).
Iv.
On or about August 1, 2009, within the Western District of Texas and elsewhere, the
Defendant,
EMMANUEL YELASCO GURROLA, a.k.a. Richie, a.k.a. Ricardo, a.k.a. Keke (1),
did then and there unlawfully, while in the course of committing theft of property owned by
victim one, and with intent to obtain and maintain control of the property, intentionally and
knowingly threatened and placed victm one in fear of imminent bodily injury and death, and the
Defendants did then and there use and exhibit a deadly weapon, to wit: a firearm, in violation of
Texas Penal Code Section 29.03 and and 7.02.
Defendant,
EMMANUEL VELASCO GURROLA, a.k.a. Richie, a.k.a. Ricardo, a.k.a. Keke (I),
victim one, and with intent to obtain and maintain control of the property, intentionally and
25
knowingly threatened and placed victm one in fear of imminent bodily injury and death, and
victim one is sixty-five (65) years of age or older, in violation of Texas Penal Code Section
29.03 and and 7.02.
VI.
Defendants,
Maclas (8); and
EDGAR MENDOZA, a.k.a. Chuy (11)
victim two, and with intent to obtain and maintain control of the property, intentionally and
knowingly threatened and placed victm two in fear of imminent bodily injury and death, and the
Defendants did then and there use and exhibit a deadly weapon, to wit: a firearm, in violation of
Texas Penal Code Section 29.03 and and 7.02.
VII.
On or about October 3, 2008, within the Western District of Texas and elsewhere, the
Defendants,
SAMUEL VELASCO GURROLA (2); and
a.k.a. Dalia Krantz-Valencja (10);
FSV, and with intent to obtain and maintain control of the property, intentionally and knowingly
26
threatened and placed FSV in fear of imminent bodily injury and death, and the Defendants did
then and there use and exhibit a deadly weapon, to wit: a firearm, in violation of Texas Penal
Code Section 29.03 and and 7.02.
All in violation of Title 18, United States Code, Section 1962(d).
COUNT TWO
(Conspiracy to Possess with Intent to Distribute Marijuana)

(21 U.S.C. 846 and 841(a)(1) and 841(b)(1)(A)(vii))
That beginning on or about 2011, and continuing through and including on or about the
date of this indictment, within the Western District of Texas and elsewhere, the Defendants,
EMMANUEL VELASCO GURROLA, a.k.a. Richie, a.k.a. Ricardo (1);

Maclas (8);
EDGAR MENDOZA. a.k.a. Chuv (lfl;
did knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed
together, 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 846, that is to say, they
conspired to possess a controlled substance, which offense involved marijuana, a Schedule I
Controlled Substance, with intent to distribute same, contrary to Title 21, United States COde,
Sections 841(a)(1) in the quantities set forth below:
QUANTITY OF CONTROLLED SUBSTANCE INVOLVED IN THE CONSPIRACY
27
The quantity of the mixture or substance containing marijuana involved in the conspiracy
and attributable to each Defendant as a result of each Defendants own conduct and as a result of
the conduct of other conspirators reasonably foreseeable to each Defendant is as follows:
DEFENDANT QUANTITY STATUTE

EMMANUEL YELASCO 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)
GURROLA, a.k.a. Richie, mixture or substance
a.k.a. Ricardo, a.k.a. Keke containing a detectable
(1) amount of marijuana
SAMUEL VELASCO 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)

GURROLA (2) mixture or substance
c.ontaining a detectable
amount of marijuana
JOSE RICARDO 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)
RODRIGUEZ (4) mixture or substance
containing a detectable
amount of marijuana
AURELIO SETURINO, 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)
a.k.a. Gordo (6) mixture or substance
amount of marijuana
ALFREDO QUINONES, 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)
a.k.a. Esmerelda, a.k.a. mixture or substance
Aifredo Flores, a.k.a. Alfred containing a detectable
Quinones-Macias (8) amount of marijuana
DALIA VALENCIA, a.k.a. 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)

Dalia Velasco, a.k.a. Dalia mixture or substance
Krantz, a.k.a. Dalia Krantz- containing a detectable
Valencia (10) amount of marijuana
EDGAR MIENDOZA, a.k.a. 1000 kilograms or more of a 21 U.S.C. 841(b)(1)(A)(vii)

Chuy (11) mixture or substance
amount of marijuana
28
im.i.rniiui
All in violation of Title 21, United States Code, Section 846.
COUNT THREE
(Conspiracy to Import Marijuana)
(21 U.S.C. 963, 952, and 960(b)(G))
That beginning on or about 2011, and continuing through and including on or about the
date of this indictment, in the Western District of Texas, and elsewhere, the Defendants,
ALFREDO QUINONES, a.k.a. Esmerelda, a.k.a. Alfredo Flores, a.k.a. Alfred Quinones-
Maclas (8);
DALIA VALENCIA, ak.a. Dalia Velasco, a.k.a. Dalia Krant'z,
did knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed
together, 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 marijuana, a Schedule I
Controlled Substance, into the United States from Mexico, contrary to Title 21, United States
Code, Sections 952(a) and 960(a)(1) in the quantities set forth below:
QUANTITY OF CONTROLLED SUBSTANCE INVOLVED IN THE CONSPIRACY
29
The quantity of the mixture or substance containing marijuana involved in the conspiracy
and attributable to each Defendant as a result of each Defendant's own conduct and as a result of
the conduct of other conspirators reasonably foreseeable to each Defendant is as follows:
DEFENDANT QUANTITY STATUTE

EMMANUEL VELASCO 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)
GURROLA, a.k.a. Richie, mixture or substance
a.k.a. Ricardo, a.k.a. Keke containing a detectable
(1) amount of marijuana
SAMUEL VELASCO 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)

GURROLA (2) mixture or substance
amount of marijuana
JOSE RICARDO 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)
RODRIGUEZ (4) mixture or substance
amount of marijuana
AURELIO SETURINO, 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)
a.k.a. Gordo (6) mixture or substance
amount of marijuana
ALFREDO QUINONES, 1000 icilograms or more of a 21 U.S.C. 960(b)(1)(G)
a.k.a. Esmerelda, a.k.a. mixture or substance
Aifredo Flores, a.k.a. Alfred containing a detectable
Quinones-Macias (8) amount of marijuana
DALIA VALENCIA, a.k.a. 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)

Dalia Velasco, a.k.a. Dalia mixture or substance
Krantz, containing a detectable
a.k.a. Dalia Krantz-Valencia amount of marijuana
(10)
EDGAR MENDOZA, a.k.a. 1000 kilograms or more of a 21 U.S.C. 960(b)(1)(G)
Chuy (11) mixture or substance
amount of marijuana
30
All in violation of Title 21, United States Code, Section 963.
COUNT FOUR
(Conspiracy to Launder Monetary Instruments)
(18 U.S.C. 1956(a)(1)(A)(i) & (B)(i) & (ii) & (h))
That beginning on or about 2011, and continuing through and including on or about about
the date of this indictment, in the Western District of Texas, and elsewhere, the Defendants,
JOSE RICARDO RODRiGUEZ (4);
ALFREDO QIJINONES, a.k.a. Esmerelda, a.k.a. Aifredo Flores, a.k.a. Alfred Quinones-
Maclas (8);
did knowingly conspire and agree with others known and unknown to the Grand Juiy, to
knowingly conduct and attempt to conduct financial transactions affecting interstate commerce,
knowing that the property involved in such financial transactions represented the proceeds of
some forni of unlawful activity, such property being, in fact, the proceeds of a specified unlawful
activity, to wit: conspiracy to possess with the intent to distribute a controlled substance:
a. with the intent to promote the carrying on of said specified unlawful activity, in
violation of Title 18, United States Code, Section 1956(a)(1)(A)(i); and
b. knowing that the transactions were designed in whole or in part to conceal and disguise
the nature, the source, the ownership, and the control of the proceeds of said specified unlawful
activity, in violation of Title 18, United States Code, Section 1 956(a)( 1 )(B)(i); and
31
c. knowing that the transactions were designed in whole or in part to avoid a transaction
reporting requirement under State or Federal Law, in violation of Title 18, United States Code,
Section 1 956(a)(l )(B)(ii).
All in violation of Title 18, United States Code, Section 1956(a)(1) & (h).
COUNT FIVE
(Conspiracy to Launder Monetary Instruments)
(18 U.S.C. 1956(a)(2)(A) & (h))
That beginning on or about 2011, and continuing through and including the date of this
indictment, in the Western District of Texas and elsewhere, the Defendants,
AURELLO SETURINO, a.k.a. Gordo (6);
Macias (8);
did knowingly conspire and agree with others known and unknown to the Grand Jury to transport
and transfer and attempt to transport and transfer monetary instruments and funds from a place
inside the United States to a place outside the United States, that is Mexico, with the intent to
promote the carrying on of a specified unlawful activity, that is conspiracy to possess with intent
to distribute a controlled substance, in violation of Title 18, United States Code, Sections
1956(a)(2)(A) and (h).
32
COUNT SIX
(Hobbs Act Conspiracy)
(18 U.S.C. 1951)
That beginning on or about 2009, and continuing through and including on or about 2013,
within the Western District of Texas and elsewhere, the Defendants,
Macias (8);
did knowingly conspire with others known and unknown to the Grand Jury, to commit offenses
against the United States, in violation of Title 18, United States Code, Section 195 1(a), that is to
say they conspired to affect commerce and the movement of an article and commodity in
commerce, as that term is defined in Title 18 United States Code, Section 1951 (b)(2), in that the
defendants did conspire to obtain and attempt to obtain monetary instruments by extortion, and
the property of such persons known and unknown with the consent of such persons having been
induced by wrongful use of actual and threatened force, violence and fear.
All in violation of Title 18, United States Code, Section 1951(a).
COUNT SEVEN
(Conspiracy to Kidnap in a Foreign Country)
(18 U.S.C. 956(a))
On or about August 1, 2009, in the Western District of Texas, Defendants, /
and others known and unknown to the Grand Jury, at least one of whom having been within the
jurisdiction of the United States, knowingly, willfully, and unlawfully conspired with one
33
another to commit outside the United States an act that would constitute the offense of
kidnapping if committed in the special maritime and territorial jurisdiction of the United States,
that is, the kidnapping of victim number one, and one or more of the conspirators committed an
act within the jurisdiction of the United States to effect an object of the conspiracy.
All in violation of Title 18, United States Code, Sections 956(a)(1)
COUNT EIGHT
(Conspiracy to Kidnap in a Foreign Country)
(18 U.S.C. 956(a))
On or about August 21, 2009, in the Western District of Texas, Defendants,
Machis (8); and
EDGAR MENDOZA, a.k.a. Choy (11),
and others known and unknown to the Grand Jury, at least one of whom having been within the
jurisdiction of the United States, knowingly, willfully, and unlawfully conspired with one
another to commit outside the United States an act that would constitute the offense of
kidnapping if committed in the special maritime and territorial jurisdiction of the United States,
that is, the kidnapping of victim number two, and one or more of the conspirators committed an
act within the jurisdiction of the United States to effect an object of the conspiracy.
All in violation of Title 18, United States Code, Sections 956(a)(1).
NOTICE OF GOVERNMENT'S DEMAND FOR FORFEITURE

AS TO COUNT ONE
(18 U.S.C. 1963)
1. The allegations contained in Count One of this Fourth Superseding Indictment are
hereby repeated, realleged, and incorporated by reference herein as though fully set forth at
34
length for the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section
1963.
2. As a result of the conspiracy offense alleged in Count One of this Fourth
Superseding Indictment, the United States of America gives notice to the Defendants,
JOSE RICAJ(DO RODRIGUEZ (4);
Maclas (8);
EDGAR MENDOZA, a.k.a. Choy (11);
of its intent to seek forfeiture to the United States, pursuant to Title 18, United States Code,
Section 1963, of the following:
a. All interests acquired and maintained in violation of Title 18, United States Code,
Section 1962;
b. All interests in, securities of, claims against, and property and contractual rights
of any kind affording a source of influence over, the enterprise named and
described herein, which the defendants established, operated, controlled,
conducted, and participated in the conduct of, in violation of Title 18, United
States Code, Section 1962; and
c. All property constituting and derived from any proceeds obtained directly and
indirectly from racketeering activity in violation of Title 18, United States Code,
Section 1962.
35
The property subject to forfeiture to the United States pursuant to Title 18, United
States Code, Section 1963,. includes but is not limited to the following:
a. A sum of United States Currency representing the amount of interests acquired

and the gross proceeds obtained as a result of the offense charged in Count
One, for which the defendants are jointly and severally liable, with said
proceeds including the following specific assets, which are subject to forfeiture
to the United States:
1. Approximately $85,000.00 in United States Currency seized on or about

August 17, 2014, from a vehicle driven by Samuel Velasco, in El Paso, Texas;
and
2. Real property and appurtenances located at 12236 Diana Natalicio Dr., El

Paso, Texas 79936, with all improvements and attachments thereon; and
3. Real property and appurtenances located at 12612 Sun Empress, El Paso,

Texas 79936, with all improvements and attachments thereon; and
4. Real property and appurtenances located at 2013 Thunder Ridge Drive, El

Paso, Texas 79938, with all improvements and attachments thereon; and
5. Real property and appurtenances located at 3722 Las Vegas Boulevard

South, Unit # 604, Las Vegas, Nevada 89158, with all improvements and
attachments thereon; and
6. Real property and appurtenances located at the West half of the Southwest
Quarter of the Southwest Quarter of the Southeast Quarter of Section 17, Block
79, Township 3, T&PRYCO. Surveys, El Paso County, Texas (5 acres), with all
improvements and attachments thereon;
7. Real property and appurtenances located at Lot 10, Block 491, HORIZON
CITY (UNIT SIXTY-FOUR), an Addition in El Paso County, Texas, according to
the Plat thereof recorded in Volume 20, Page 33, Plat Records of El Paso County,
Texas, with all improvements and attachments thereon; and
8. a 3 acre tract of land located at SE/4, Sec: 44, Block 38-TIS (out of 19.154
Acres), Track 6, Survey, also known as 1818-A, 1818-B, and 1818-C South
County Road 1150, Midland, Texas 79706, with all improvements, attachments,
and appurtenances thereon.
b. One Beretta BU9 Nano 9mm Pistol, bearing serial number NU102465; and
c. One Beretta 92FS 9mm Pistol, bearing serial number BER6372 19; and
36
d. One RomarmlCugir GP WASR 10/63 7.62mm Rifle, bearing serial number

1982SA04029; and
e. One RomarmlCugir Mini Draco 7.62mm Pistol, bearing serial number PD-5013-
2014; and
f. Approximately five assorted magazines, seized on or about March 17, 2015, from
Jose Ricardo Rodriguez, in Dallas, Texas;
4. If any of the above-described forfeitable property, as a result of any act or
omission of the defendants:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third person;
(3) has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot be subdivided without
difficulty;
it is the intent of the United States, pursuant to Title 18, United States Code, Section 1963(m), to
seek forfeiture of any other property of said defendants up to the value of the above forfeitable
property.

AS TO COUNTS TWO AND THREE
(21 U.S.C. 853)
1. The allegations contained in Counts Two and Three of this Fourth Superseding
Indictment are hereby repeated, realleged, and incorporated by reference herein as though fully
set forth at length for the purpose of alleging forfeiture pursuant to Title 21, United States Code,
SectiOn 853.
37
2. As a result of the controlled substance offenses alleged in Counts Two and Three
of this Fdurth Superseding Indictment, the United States of America gives notice to the
Defendants,
AIJRELIO SETURINO, a.k.a. Gordo (6);
Macias (8);
EDGAR MENDOZA (1fl
Section 853, of any and all property constituting, or derived from, any proceeds that said
defendants obtained directly or indirectly as a result of said violations, and of any and all
property used or intended to be used, in any manner or part, to commit, or to facilitate the
commission of, such violations, including but not limited to the follOwing:
a. A sum of United States Currency representing the amount of proceeds obtained as

a result of the offenses, for which the defendants are jointly and severally liable;
and
b. Approximately $85,000.00 in United States Currency seized on or about August

17, 2014, from a vehicle driven by Samuel Velasco, in El Paso, Texas; and
c. One Beretta BU9 Nano 9mm Pistol, bearing serial number NU102465; and
d. One Beretta 92FS 9mm Pistol, bearing serial number BER637219; and
e. One RomarmlCugir GP WASR 10/63 7.62mm Rifle, bearing serial number

1982SA04029; and
f. One RomarmlCugir Mini Draco 7.62mm Pistol, bearing serial number PD-501 3-
2014; and
38
g. Approximately five assorted magazines, seized on or about March 17, 2015, from
Jose Ricardo Rodriguez, in Dallas, Texas; and
h. Real property and appurtenances located at 12236 Diana Natalicio Dr., El Paso,
i. Real property and appurtenances located at 12612 Sun Empress, El Paso, Texas
79936, with all improvements and attachments thereon; and
j. Real property and appurtenances located at 2013 Thunder Ridge Drive, El Paso,
k. Real property and appurtenances located at 3722 Las Vegas Boulevard South,
Unit # 604, Las Vegas, Nevada 89158, with all improvements and attachments
thereon; and
Real property and appurtenances located at the West half of the Southwest
m. Real property and appurtenances located at Lot 10, Block 491, HORIZON CITY
(UNIT SIXTY-FOUR), an Addition in El Paso County, Texas, according to the
Plat thereof recorded in Volume 20, Page 33, Plat Records of El Paso County,
n. a 3 acre tract of land located at SE/4, Sec: 44, Block 38-TIS (out of 19.154
39
difficulty;
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 said defendants up to the value of the above
forfeitable property.

AS TO COUNTS FOUR AND FIVE
(18 U.S.C. 982)
1. The allegations contained in Counts Four and Five of this Fourth Superseding
Indictment are hereby repeated, realleged, and incorporated by reference herein as though
fully set forth at length for the purpose of alleging forfeiture pursuant to Title 18, United
States Code, Section 982.
2. As a result of the conspiracy to commit money laundering offenses set forth in
Counts Four and Five of this Fourth Superseding Indictment, the United States of America
gives notice to the Defendants,
SAMUEL VELASCO GURROLA(2);
AIJRELIO SETURINO, a.k.a. Gordo (6);
Macias (8);
Section 982(a)(1), of any and all property, real and personal, involved in such offenses, and
any property traceable to such property, including but not limited to the following:
40
a. A sm-n of United States Currency representing the amount of property involved

in the offenses, for which the defendants are jointly and severally liable;

c. One Beretta BU9 Nano 9mm Pistol, bearing serial number NU1 02465; and
e. One Romarm/Cugir GP WASR 10/63 7.62mm Rifle, bearing serial number

1982SA04029; and
f. One Romarm/Cugir Mini Draco 7.62mm Pistol, bearing serial number PD-5013-
2014; and
Real property and appurtenances located at 2013 Thunder Ridge Drive, El Paso,
thereon; and
Real property and appurtenances located at the West half of the Southwest
n. a 3 acre tract of land located at SE/4, See: 44, Block 38-TIS (out of 19.154
41
3. If any of the above-described forfeitable property, as a result of any act or i

(I) cannot be located upon the exercise of due diligence; I
I

I
(5) has been cormningled with other property which cannot be subdivided without
difficulty;
I
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p),
as incorporated by Title 18, United States Code, Section 982(b), to seek forfeiture of any other I
property of said defendants up to the value of the above forfeitable property.

AS TO COUNT SIX
(18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c))
1. The allegations contained in Count Six of this Fourth Superseding Indictment
are hereby repeated, realleged, and incorporated by reference herein as though fully set forth
at length for the purpose of alleging forfeiture pursuant to Title 18, United States Code,
Section 981 and Title 28, United States Code, Section 2461.
i
2. As a result of the Hobbs Act offense set forth in Count Six of this Fourth
Superseding Indictment, the United States of America gives notice to the Defendants, I
Macias (8);
42 I
Section 98l(a)(1)(C) and Title 28, United States Code, Section 2461(c), of any and all
property, real and personal, which constitutes or is derived from proceeds traceable to the
violation, and pursuant to Title 18, United States Code, Section 924(d) and Title 28, United
States Code, Section 246 1(c), of any and all firearms and ammunition involved in or used in
the offense, including but not limited to the following:

a result of the offense, for which the defendants are jointly and severally liable;
and

c. One Beretta BU9 Nano 9mm Pistol, bearing serial number NU102465; and
e. One Romarm/Cugir GP WASR 10/63 7.62mm Rifle, bearing serial number

1982SA04029; and
f. One RomarmlCugir Mini Draco 7.62mm Pistol, bearing serial number PD-5013-
2014; and
j. Real property and appurtenances located at 2013 Thunder Ridge Drive, El Paso,
thereon; and
43
1. Real property and appurtenances located at the West half of the Southwest
n. a 3 acre tract of land located at SE/4, Sec: 44, Block 38-TIS (out of 19.154
Acres), Track 6, Survey, also known as 181 8-A, 1818-B, and 1818-C South
(1) carmot be located upon the exercise of due diligence;
difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 85 3(p),
as incorporated by Title 28, United States Code, Section 2461(c), to seek forfeiture of any
other property of said defendants up to the value of the above forfeitable property.

AS TO COUNTS SEVEN AND EIGHT
(18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c))
1. The allegations contained in Counts Seven and Eight of this Fourth
Superseding Indictment are hereby repeated, realleged, and incorporated by reference herein
44
as though fully set forth at length for the purpose of alleging forfeiture pursuant to Title 18,
United States Code, Section 981 and Title 28, United States Code, Section 2461.
2. As a result of the offenses of conspiracy to kidnap set forth in Counts Seven
and Eight of this Fourth Superseding Indictment, the United States of America gives notice to
the Defendants,
EMMANUEL VELASCO GURROLA, a.k.a. Richie, a.k.a. Ricardo, a.ka. Keke (1);
SAMUEL VELASCO GURROLA (2)
Macias (8);
EDGAR MENDOZA. a.k.a. Chuy (11);
Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), of any and all
property, real and personal, which constitutes or is derived from proceeds traceable to the
violations, including but not limited to the following:

a result of the offenses, for which the defendants are jointly and severally liable;
and
b. Real property and appurtenances located at 12236 Diana Natalicio Dr., El Paso,
c. Real property and appurtenances located at 12612 Sun Empress, El Paso, Texas
d. Real property and appurtenances located at 2013 Thunder Ridge Drive, El Paso,
e. Real property and appurtenances located at 3722 Las Vegas Boulevard South,
thereon; and
f. Real property and appurtenances located at the West half of the Southwest
45
g. Real property and appurtenances located at Lot 10, Block 491, HORIZON CITY
h. a 3 acre tract of land located at SE/4, See: 44, Block 3 8-TIS (out of 19.154
Acres), Track 6, Survey, also known as 1818-A, 181 8-B, and 181 8-C South

difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section
853@), as
incorporated by Title 28, United States Code, Section 2461(c), to seek forfeiture of any other
property of said defendants up to the value of the above forfeitable property.
A TRUEJNAL
SIGNATURE
REDACTED PURSUANT TO
s-GOVERNMENT ACT OF 2002
FOREPERSON OF THE GRAND JURY
pqr:,i1p
Daphne Newaz
Assistant United
46

El Paso Drug Kingpins

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El Paso Drug Kingpins

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Case 3:15-cr-00228-DB Document 476 Filed 10/28/15 Page 1 of 46

IN THE UNITED STATES DISTRICT COURT L F0

UNITED STATES OF AMERICA, CRIMINAL NO.

THE RACKETEERING ENTERPRISE

The Grand Jury charges:

1. At all times relevant to this Fourth Superseding Indictment, in the Western

District of Texas and elsewhere, the defendants,

constituted an ongoing organization whose members functioned as a continuing unit for a

common purpose of achieving the objectives of the enterprise.

Purposes of the Enterprise

2. The purposes of the enterprise included the following:

a. Enriching the members and associates of the enterprise through, among

b. Enriching the members and associates of the enterprise through, among

d. Preserving and protecting the continuity and profits of the enterprise

Manner and Means of the Enterprise

a. Members of the Enterprise and their associates would engage in the

means to generate income.

transportation and distribution of large quantities of controlled substances as a means to generate

c. Members of the Enterprise and their associates would conduct financial

United States back to El Paso, Texas, and into Mexico.

e. Members of the Enterprise and their associates would steal vehicles as a

means to generate income.

f. Members of the Enterprise and their associates would possess

g. Members of the Enterprise and their associates would kidnap individuals,

h. Members of the Enterprise would organize, use, and threaten to use

physical violence against various individuals.

Structure of the Enterprise

5. The primary purpose of VCE is to smuggle huge quantities of marijuana, as well

7. VCE engages in kidnapping individuals and extorting money from these

payments from Mexico into the United States.

8. The proceeds generated by trafficking in marijuana and cocaine are returned to

9. EMMANUEL VELASCO GURROLA a.k.a. Richie, a.k.a. Ricardo, ak.a. Keke

laundering endeavors. SAMUEL VELASCO GURROLA ("S. VELASCO") is a co-leader of

not bypass or cut them out of the activities of the Enterprise.

Roles of the Defendants

11. Defendant, S. VELASCO, is a co-leader of VCE and is brother to VELASCO. S.

VELASCO provides direction and instruction to many of VCE's members. S. VELASCO is

importation and distribution of over a thousand kilograms of marjuana and multi-kilogram

the kidnapping victims' families, and negotiates ransom payments.

12. Defendant, JOSE RICARDO RODRIGUEZ ("RODRIGUEZ"), is a member of

AURELIO SETURINO a.k.a. Gordo ("SETUR1NO") in Dallas,

with and takes direction from both VELASCO and S. VELASCO.

13. Defendant, SETUR1NO is VELASCO and S. VELASCO's cousin. SETUR1NO

operations in Dallas, Texas.

14. Defendant, ALFREDO QUINONES, a.k.a. Esmerelda, a.k.a Aifredo Flores,

a.k.a. Alfred Quinones-Macias ("QUINONES") is one of VELASCO's top associates.

QU1NONES participated in paying drug couriers, loading, unpackaging, and transporting

kidnapping and extortion ring.

Dalia Krantz-Valencia ("VALENCIA"), is VELASCO and S. VELASCO's sister. VALENCIA

VALENCIA to deliver drug proceeds to VALENCIA or to pick up drug proceeds from

18. Defendant, EDGAR MENDOZA, a.k.a. Chuy ("MENDOZA"), was an active

regard to drug-trafficking and kidnapping efforts.

THE RACKETEERING CONSPIRACY

a. 18 U.S.C. 1956 (relating to the laundering of monetary instruments);

b. 18 U.S.C. 2312 (relating to interstate I foreign transportation of stolen

c. 18 U.S.C. 1951 (conspiracy to interfere with commerce, robbery, and

d. 18 U.S.C. 956(a)(1) (conspiracy to kidnap in a foreign country); and

e. Multiple offenses involving 21 U.S.C. 841(a)(1), 846, 952, and 963

and multiple acts involving the following provisions of state law:

f. Texas Penal Code 29.03 (aggravated robbery), 15.01 (attempt), 15.02

22. On or about September of 2008 through November of 2008, EMMANUEL

VELASCO GURROLA, SAMUEL VELASCO GURROLA, DALIA VALENCIA, and others

and the murder of RMB.

23. On or about October 2, 2008, DALIA VALENCIA rented a Pontiac G6 in El