Case 3:11-cr-00088-L Document 4 Filed 03/29/11 Page 1 of 4 PageID 13

IN THE UNITED STATES DISTRICT COU!t¥:TNERPl

FOR THE NORTHERN DISTRICT OF TEXAS n
DALLAS DIVISION
25
DEPUTY
UNITED STATES OF AMERICA §
§
v.

ALONZO RAMOS (01)

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§ .

FACTUAL RESUME

Alonzo Ramos, the defendant, Robert C. Hinton, Jr., the defendant's attorney, and

the government agree that the following elements are correct. The parties also agree that

the stipulated facts are true and that these facts support Ramos' guilty plea to Count One

of the pending information.

ELEMENTS OF THE QFFENSES

To prove the offense alleged Count One of the pending information, the

government must prove each of the following elements beyond a reasonable doubt:

Count One
Interstate Travel in Aid of Racketeering
(Violation of 18 U.S.C. § 1952(a)(I»

First: The defendant traveled in interstate commerce;

Second: The defendant did so with the intent to distribute the proceeds ofany
unlawful activity; and

Third: The defendant perfonned or attempted to perform an act described in the

second element.

A!
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.
,

STIPULATED FACTS

In 2007, L.T. was arrested and detained in Louisiana for drug trafficking and L.T.

began cooperating with federal authorities. In January 2008, L.T. infonned federal

authorities that Alonzo Ramos, the defendant, came to the jail in Louisiana from Texas to

visit him unexpectedly. Ramos is an attorney from Laredo, Texas. L.T. explained that

Ramos visited him to make sure that L.T. was not cooperating with the authorities.

Consequently, federal authorities began recording phone calls between L.T. and Ramos in

February 2008.

On March 5, 2008, Ramos and L.T. spoke in a recorded telephone call. Ramos

offered to facilitate a monetary payment that was the proceeds of unlawful activity - drug

trafficking - to L.T. In a subsequent call that day, Ramos and L.T. discussed putting a

relative ofL.T. in touch with Ramos to receive the payment. Ramos also promised to

travel from Texas to Louisiana to visit L.T. later that week.

On March 7. 2008, as described in Count One ofthe pending information, Ramos

traveled to Louisiana from Texas with the intent to distribute the proceeds of an unlawful

activity, namely, a business enterprise involving the trafficking ofcontrolled substances,

and thereafter he performed and attempted to perform an act to distribute the proceeds of

such unlawful activity. Specifically, Ramos traveled from Texas to Louisiana via a

commercial airline flight, traveling through and stopping in the Northern District of

Texas, and met L.T. at the jail in Louisiana for the purpose of distributing drug trafficking

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proceeds. This meeting was audio/video-recorded by federal law enforcement officers.

During the meeting, Ramos informed L.T. that he had received $48,500, which were drug

trafficking proceeds, and that he had the money at his house in Laredo. Ramos and L. T.

then discussed the details of how the money would be transferred to L.T. Ramos agreed

to give the money to L.T:s relative.

On March 12,2008, L.T. confirmed to Ramos in a recorded telephone call that he

wanted Ramos to deliver the money to his relative. Ramos told L.T. to have his relative

contact him. Unbeknownst to Ramos, L.T.'s relative was also cooperating with federal

law enforcement officers. On March 13,2008; L.T.'s relative contacted Ramos via

telephone. The phone call was recorded. Ramos instructed L.T.'s relative to meet him at

a location in Laredo; Texas. Later that day, Ramos gave L.T.'s relative the $48,500 at the

prearranged location. The delivery was recorded and L.T.'s relative surrendered the cash

to federal law enforcement officers.

[NO FURTHER INFORMATION ON nus PAGE]

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Ramos agrees and stipulates that on or about March 1, 2008, he did travel in

interstate commerce with the intent to distribute the proceeds of unlawful activity, and he

did distribute the proceeds of unlawful activity, as alleged in Count One of the

information.

AGREED TO AND SIGNED this :2.J Mday of ~ ,2011.

ERIC H. HOLDER; JR.

UNITED STATES ATIORNEY GENERAL

GARYC. T MBLA

&. "'
Special Attorney to the U ited States Attorney General
Assistant United States Attorney

~~
Louisiana Bar Roll No. 22665
1100 Commerce Street, Third Floor
Dallas, Texas 75242-1699
RO ETC. HINTON, JR.
Attorney for Defendant
• I

jJ, Telephone: 214.659.8638

Facsimile: 214.767.4913
E-Mail: gary.tromblay@usdoj.iov

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