Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 1 of 8

FILED
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS CLER.U.SOFS
WACO DIVISION W

uNITED STATES OF AMERICA, CRIM. NO. WA-11-CR-189-AM

Plaintiff,
SUPERSEDiNG INDICTMENT
V.

CT 1: 21:846 & 841(a)(l)-

JUAN FRANCISCO TREVINO CHAVEZ (3) Conspiracy to Possess a Controlled
Substance with Intent to Distribute
(Marijuana);
Defendant. CT2: 21:952 & 960(a)(1)-
Conspiracy to Import with Intent to
Distribute a Controlled Substance
(Marijuana);
CT 3: 21: 959(a)- Unlawful
Distribution of Controlled
Substances Extra-territorial;
CT 4: 21:846 & 84l(a)(l)-
Conspiracy to Possess a Controlled
Substance with Intent to Distribute
(Cocaine);
CT 5: 21:952 & 960(a)(l)-
Conspiracy to Import with Intent to
Distribute a Controlled Substance
(Cocaine);
CT 6: 18:924(o)- Conspiracy to
Possess Firearms in Furtherance of
Drug Trafficking;
CT 7: 18:1956(h)- Money
Laundering Conspiracy.

TIlE GRAND JURY CHARGES:

Ways, Manner, and Means to Accomplish Conspiracy for Counts One through Six

There exists in the Mexican states of Coahuila and Tamaulipas, the Western District of

Texas, and elsewhere, exists an organization which calls itself LOS ZETAS. LOS ZETAS is a

transnational drug cartel that has dedicated itself to the pursuit of organized criminal conduct

principally through drug trafficking, extortion, weapons trafficking, and murder.

 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 2 of 8

LOS ZETAS is a powerful drug trafficking organization operating out of Mexico, which

funnels thousands of kilograms of cocaine, marijuana, and other narcotics into the United States

each year. LOS ZETAS is one of the largest drug cartels operating in Mexico today, with their

influence stretching from Central America through Mexico and into cities throughout the United

States. The organization is based in the city of Nuevo Laredo, Tamaulipas, Mexico, and has

control over several other Mexican cities located on the United States-Mexico border, including

Nuevo Laredo, Tamaulipas and Ciudad Acuna and Piedras Negrasboth located in Coahuila,

Mexico. The large-scale drug trafficking of this organization generates multi-million dollar

revenues.

LOS ZETAS were first established to be the lethal enforcers for another Mexican drug

cartel: the Gulf Cartel. The leaders of the Gulf Cartel recruited former members of the Mexican

military in the late 1990s to work for them as enforcers. However, over time LOS ZETAS broke

away from the Gulf Cartel and began to operate independently. The numbers associated with

some LOS ZETAS leaders (e.g., Z-3) were assigned at the inception of LOS ZETAS as a carry-

over from their military call signs. Heriberto Lascano, aka Z-3, was the leader of the Los Zetas

from 2004 until his death on October 7, 2012 in Coahuila, Mexico. Afler his death, Miguel

Angel Trevino Morales, aka Z-40, and his brother Oscar Omar Trevino Morales, aka Z-42,

assumed the leadership positions.

LOS ZETAS are organized in a hierarchical structure with certain groups or cells

operating in tiers of command. LOS ZETAS divide their territory into areas known as "plazas"

along the Mexico-United States border and assign each "plaza" region a leader, commonly

referred to as a "plaza boss." LOS ZETAS members purchase bulk quantities of narcotics and

sell them abroad as well as to other non- LOS ZETAS drug traffickers operating in Mexico. In
 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 3 of 8

addition to those considered actual members of LOS ZETAS, any large scale narcotics trafficker

operating in a region controlled by LOS ZETAS must support and associate with LOS ZETAS or

risk execution. LOS ZETAS not only supplies the drugs (marijuana, cocaine, methamphetamine,

etc.) to the traffickers, they charge the traffickers a fee (called the "quota") for the privilege of

operating in LOS ZETAS territory. That fee includes cash payments as well as firearms and

other munitions (ammunition, magazines, etc.). In addition to allowing these traffickers to

operate in their territory, LOS ZETAS supplies them with real-time intelligence about the

movement and location of the Mexican military and law enforcement.

The Defendant, JUAN FRANCISCO TREVINO-CHAVEZ, aka "Kiko," worked for

LOS ZETAS, as a poly-drug trafficker (trafficking multiple types of drugs), weapons procurer,

money launderer, and as a leader in the Nueva Laredo, Tamaulipas, Mexico area. In furtherance

of the conspiracy, the Defendant organized the source for and distribution of large quantities of

narcotics, laundered funds, controlled a cell of traffickers and a group of armed sicarios, and met

with and conspired with the highest level operatives with LOS ZETAS.

COUNT ONE
[21 U.S.C. § 841, 846]

Beginning on or about January 1, 2004, and continuing until on or about September 28,

2016, in the Western District of Texas, the Southern District of Texas, the Republic of Mexico,

and elsewhere, the Defendant,

JUAN FRANCISCO TREVINO CHAVEZ, aka Kiko,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with

others known and unknown to the Grand Jury, to possess with intent to distribute and distribute a

controlled substance, which offense involved 1000 kilograms or more of a mixture and substance
 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 4 of 8

containing a detectable amount of marijuana, a Schedule I Controlled Substance, contrary to

Title 21, United States Code, Section 841(a)(1) and 841 (b)(1)(A)(vii), in violation of Title 21,

United States Code, Section 846.

COUNT TWO
[21 U.S.C. § 952(a), 960(a)(1), 960(b)(1)(G) & 9631

Beginning on or about January 1, 2004, and continuing until on or about September 28,

2016, in the Western District of Texas, the Southern District of Texas, the Republic of Mexico,

and elsewhere, the Defendant,

JUAN FRANCISCO TREVINO CHAVEZ, aka Kiko,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with

others known and unknown to the Grand Jury, 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 1000 kilograms or more of a mixture and substance

containing a detectable amount of marijuana, a Schedule I Controlled Substance, into the United

States from Mexico contrary to Title 21, United States Code, Sections 952(a), 960(a)(1) and

960(b)(1 )(G).

COuNT THREE
[21 U.S.C. § 959(a), 963, 960(a)(3) and (b)(1)]

Beginning on or about January 1, 2004, and continuing until on or about September 28,

2016, in the Western District of Texas, the Southern District of Texas, the Republic of Mexico,

Republic of Columbia, and elsewhere, the Defendant,

 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 5 of 8

JUAN FRANCISCO TREVINO CHAVEZ, aka Kiko,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with

others known and unknown to the Grand Jury, to commit offenses against the United States, in

violation of Title 21, United States Code, Section 963, that is to say, they conspired to distribute

1000 kilograms or more of a mixture or substance containing a detectable amount of marijuana, a

Schedule I Controlled Substance, and 5 kilograms or more of a mixture or substance containing a

detectable amount of cocaine, a Schedule II Controlled Substance, intending and knowing that

said controlled substance would be unlawfully imported into the United States, in violation of

Title 21, United States Code, Sections 959(a), 963, and 960(a)(3) and (b)(1).

COUNT FOUR
[21 U.S.C. § 841, 846]

Beginning on or about January 1, 2004, and continuing until on or about September 28,

2016, in the Western District of Texas, the Republic of Mexico, the Republic of Columbia, and

elsewhere, the Defendant,

JUAN FRANCISCO TREVINO CHAVEZ, aka Kiko,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with

others known and unknown to the Grand Jury, to possess with intent to distribute and distribute a

controlled substance, which offense involved 5 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)(l)(A)(ii), in violation of Title 21, United

States Code, Section 846.

 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 6 of 8

COUNT FIVE
[21 U.S.C. § 952(a), 960(a)(1), 960(b)(1)(B) & 963]

Beginning on or about January 1, 2004, and continuing until on or about September 28,

2016, in the Western District of Texas, the Republic of Mexico, Republic of Columbia, and

elsewhere, the Defendant,

JUAN FRANCISCO TREVINO CHAVEZ, aka KIKO,

knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with

others known and unknown to the Grand Jury, 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 5 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).

COIThT SIX
[18 U.S.C. § 924(c)(1) and (0)1

Beginning on or about January 1, 2008, and continuing until on or about September 28,

2016, in the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,

JUAN FRANCISCO TREVINO CHAVEZ, aka 1(11(0,

knowingly combined, conspired, confederated, and agreed with others known and unknown to

the Grand Jury to commit offenses against the United States, that is, the Defendant conspired to

possess firearms in furtherance of the drug trafficking crimes charged in Counts One, Two,

Three, Four, and Five of this Indictment, re-alleged herein, contrary to Title 18, United States

Code, Sections 924(c)(1) and (o).

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COUNT SEVEN
[18 U.S.C. 1956(h)]

Beginning on at least January 1, 2004, the exact date unknown, and continuing until

September 28, 2016, in the Western District of Texas, the Southern District of Texas, and

elsewhere, Defendant,

JUAN FRANCISCO TREVINO CHAVEZ,

aka Kiko,

and others both known and unknown to the Grand Jury, did unlawfully and willfully combinç conspire,

confederate and agree together and with each other and others, to commit an offense as defined by Title 18,

United States Code, Section 1 956(a)(l), namely, knowing that the property involved in a fmancial

transaction represented the proceeds of some form of unlawful activity, did conduct or attempt to conduct

such a financial transaction, affecting interstate or foreign commerce, which in fact involved the

proceeds of specified unlawful activity, that is, the receiving, concealment, buying, selling or otherwise

dealing in a controlled substance, contrary to Title 21, United States Code, Sections 841(a)(1) and 846,

with the intent to promote the carrying on of the said specified unlawful activity,

contrary to Title 18, United States Code, Section 1956(a)(l)(A)(i),or

knowing that the transaction was designed in whole or in part to conceal or disguise the

nature, the location, the source, the ownership and the control of the proceeds of the

said specified unlawful activity, contrary to Title 18, United States Code, Section

195 6(a)(l)(B)(i).
 Case 6:11-cr-00189-AM Document 263 Filed 05/08/18 Page 8 of 8

All in violation of Title 18, United States Code, Section 1956(h).

A TRUE j{T PURSU

p
10 E.G0'4EP
FOREPERSON OF THE GRAND JURY

JOHN F. BASH
United States Attorney

Pc
RUSSELL D. LEACHMAN
MARY KUCERA
Assistant United States Attorneys