dark angel indictment 1

7/31/2019 Dark Angel Indictment 1

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Criminal Action No.

UNITED STATES OF AMERICA,

Plaintiff,

v.

1. ARMANDO MENDOZA-HARO,a/k/a Armando Mendoza Green Eyes Carlos

2. JESUS SEGOVIA,

a/k/a Carlos Botitas3. MIGUEL ANGEL SANCHEZ,

a/k/a Miguel Sanchez4. SERGIO MENDOZA-VALDOVINOS,a/k/a Sergio Mendoza

5. DANIELA MUNGUIA DE ORTIZ,

a/k/a Daniela Munguia-Torres Guachita Aurora Casas

6. YULY HERNANDEZ-OROZCO,a/k/a Yuly Yuly Lorena Hernandez-Orozco

7. ERIKA ELENA HERNANDEZ-GALAVIZ,

a/k/a Erika Erika Hernandez Erika Quintana8. ALEJANDRO MORALES-GARCIA,

a/k/a Alex

9. RICARDO PANIAGUA-RODRIGUEZ,a/k/a Ricardo Paniagua

10. CARLOS MARTIN SEGURA CHANG,

a/k/a Carlos M. Chang Carlos Segura Chang11. SONIA PEREZ,

Defendants.

1

Case 1:12-cr-00243-CMA Document 1 Filed 05/23/12 USDC Colorado Page 1 of 71

12-cr-00243-CMA


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______________________________________________________________________________

INDICTMENT

21 U.S.C. 846

21 U.S.C. 841(a)(1), 841(b)(1)(A)(viii)

21 U.S.C. 843(b)18 U.S.C. 2

18 U.S.C. 1956(a)(1)(A)(i), 1956(a)(1)(B)(i), 1956(a)(1)(B)(ii),

1956(a)(2)(A), 1956(a)(2)(B)(i), and 1956(h)______________________________________________________________________________

THE GRAND JURY CHARGES:

COUNT ONE

From on or about December 2010, through on or about May 23, 2012, both dates being

approximate and inclusive, within the State and District of Colorado and elsewhere, the

defendants;

ARMANDO MENDOZA-HARO,

JESUS SEGOVIA,

MIGUEL ANGEL SANCHEZ,SERGIO MENDOZA-VALDOVINOS,

DANIELA MUNGUIA DE ORTIZ,

YULY HERNANDEZ-OROZCO,

ERIKA ELENA HERNANDEZ-GALAVIZ,ALEJANDRO MORALES-GARCIA,

did knowingly and intentionally conspire with each other and with others known and unknown to

the Grand Jury, to knowingly and intentionally distribute and possess with the intent to distribute

50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500

grams or more of a mixture or substance containing a detectable amount of methamphetamine, a

Schedule II controlled substance.

All in violation of Title 21, United States Code, Sections 846 and 841(a)(1), and

841(b)(1)(A)(viii).

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COUNT TWO

On or about July 13, 2011, through on or about May 23, 2012, both dates

being approximate and inclusive, within the State and District of Colorado and elsewhere, the

defendants;

ARMANDO MENDOZA-HARO,

JESUS SEGOVIA,MIGUEL ANGEL SANCHEZ,

SERGIO MENDOZA-VALDOVINOS,

DANIELA MUNGUIA DE ORTIZ,YULY HERNANDEZ-OROZCO,ALEJANDRO MORALES-GARCIA,

RICARDO PANIAGUA-RODRIGUEZ,

CARLOS MARTIN SEGURA CHANG,SONIA PEREZ,

did combine, conspire, confederate and agree with each other and with other persons, both

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

of Title 18, United States Code, section 1956, to wit:

(a) did knowingly conduct and attempt to conduct financial transactions affecting interstate

commerce, which involved the proceeds of a specified unlawful activity, that is the

transfer, transportation, and delivery of currency, as well as additional financial

transactions in the form of the deposit and subsequent withdrawal of currency into and

from accounts at financial institutions, electronic transfers between bank accounts, and

domestic and international wire transfers initiated from bank accounts with the intent to

promote the carrying on of specified unlawful activity and that while conducting and

attempting to conduct such financial transactions knew the property involved in the

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financial transaction represented the proceeds of some form of unlawful activity in

violation of Title 18, United States Code, Section 1956 (a)(1)(A)(i);

(b) did knowingly conduct and attempt to conduct financial transactions affecting interstate

commerce, to wit; the deposit and subsequent withdrawal of currency into and from

accounts at financial institutions, electronic transfers between bank accounts, and

domestic and international wire transfers initiated from bank accounts, which

transactions involved the proceeds of a specified unlawful activity, knowing that the

transactions were designed in whole or in part to conceal and disguise the nature,

location, source, ownership, and control of the proceeds of specified unlawful activity,

and that while conducting such financial transactions, knew that the property involved in

the financial transactions represented the proceeds of some form of unlawful activity, in

violation of Title 18, United States Code, Section 1956 (a)(1)(B)(i);

(c) did knowingly conduct and attempt to conduct financial transactions affecting interstate

commerce, to wit; the deposit of currency into accounts at financial institutions, which

transactions involved the proceeds of a specified unlawful activity, knowing that the

transactions were designed in whole or in part to avoid a transaction reporting

requirement under Federal law, and that while conducting such financial transactions

knew that the property involved in the financial transactions, represented the proceeds of

some form of unlawful activity, in violation of Title 18, United States Code, Section

1956 (a)(1)(B)(ii);

(d) did transport, transmit, or transfer, or attempt to transport, transmit, or transfer a

monetary instrument or funds from a place in the United States to or through a place

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outside the United States with the intent to promote the carrying on of specified unlawful

activity in violation of Title 18, United States Code, Section 1956 (a)(2)(A);

(e) did transport, transmit, or transfer, or attempt to transport, transmit, or transfer a

monetary instrument or funds from a place in the United States to or through a place

outside the United States knowing the monetary instrument or funds involved in the

transportation, transmission, or transfer represent the proceeds of some form of unlawful

activity and knowing that such transportation, transmission, or transfer is designed in

whole or in part to conceal and disguise the nature, the location, the source, the

ownership or the control of the proceeds of specified unlawful activity in violation of

Title 18, United States Code, Section 1956 (a)(2)(B)(i);

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

COUNT THREE

On or about December 24, 2010, within the State and District of Colorado, the defendant,

ARMANDO MENDOZA-HARO did knowingly and intentionally distribute and possess with

the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled

substance, or 500 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid,

abet, counsel, command, induce or procure the same.

All in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii)

and Title 18, United States Code, Section 2.

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COUNT FOUR

On or about July 8, 2011, within the State and District of Colorado, the defendants,

ARMANDO MENDOZA-HARO and DANIELA MUNGUIA DE ORTIZ, did knowingly and

intentionally use a communication facility, the telephone, in committing and in facilitating the

commission of the offense of conspiracy to knowingly and intentionally distribute and possess

with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II

controlled substance, or 500 grams or more of a mixture or substance containing a detectable

amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this

indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT FIVE


ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly and






indictment.


COUNT SIX


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ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly and






indictment.


COUNT SEVEN

On or about August 29, 2011, within the State and District of Colorado, the defendants,

ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly and intentionally use a

communication facility, the telephone, in committing and in facilitating the commission of the

offense of conspiracy to knowingly and intentionally distribute and possess with the intent to

distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or

500 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, as alleged in Count One of this

indictment.


COUNT EIGHT

On or about September 2, 2011, within the State and District of Colorado, the defendants,




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indictment.


COUNT NINE

On or about October 19, 2011, within the State and District of Colorado, the defendants,







indictment.


COUNT TEN


ARMANDO MENDOZA-HARO and MIGUEL ANGEL SANCHEZ, did knowingly and





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indictment.


COUNT ELEVEN








indictment.


COUNT TWELVE








indictment.


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COUNT THIRTEEN

On or about November 15, 2011, within the State and District of Colorado, the

defendants, ARMANDO MENDOZA-HARO and ERIKA ELENA HERNANDEZ-GALAVIZ,

did knowingly and intentionally use a communication facility, the telephone, in committing and

in facilitating the commission of the offense of conspiracy to knowingly and intentionally

distribute and possess with the intent to distribute 50 grams or more of methamphetamine

(actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance

containing a detectable amount of methamphetamine, a Schedule II controlled substance, as

alleged in Count One of this indictment.


COUNT FOURTEEN

On or about November 17, 2011, within the State and District of Colorado, the

defendants, ARMANDO MENDOZA-HARO and ERIKA ELENA HERNANDEZ-GALAVIZ,

did knowingly and intentionally use a communication facility, the telephone, in committing and

in facilitating the commission of the offense of conspiracy to knowingly and intentionally

distribute and possess with the intent to distribute 50 grams or more of methamphetamine

(actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance

containing a detectable amount of methamphetamine, a Schedule II controlled substance, as

alleged in Count One of this indictment.


COUNT FIFTEEN

On or about December 7, 2011, within the State and District of Colorado, the defendants,

MIGUEL ANGEL SANCHEZ and SERGIO MENDOZA-VALDOVINOS, did knowingly and

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indictment.


COUNT SIXTEEN

On or about December 13, 2011, within the State and District of Colorado, the

defendants, MIGUEL ANGEL SANCHEZ and SERGIO MENDOZA-VALDOVINOS, did

knowingly and intentionally use a communication facility, the telephone, in committing and in

facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute

and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a

Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a

detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count

One of this indictment.


COUNT SEVENTEEN

On or about January 14, 2012, within the State and District of Colorado, the defendants,

ARMANDO MENDOZA-HARO and MIGUEL ANGEL SANCHEZ, did knowingly and




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indictment.


COUNT EIGHTEEN

On or about January 16, 2012, within the State and District of Colorado, the defendants,

JESUS SEGOVIA and MIGUEL ANGEL SANCHEZ, did knowingly and intentionally use a



distribute 500 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, as alleged in Count One of this indictment.


COUNT NINETEEN

On or about March 24, 2012, within the State and District of Colorado, the defendants,

ALEJANDRO MORALES-GARCIA and ARMANDO MENDOZA-HARO, did knowingly and






indictment.


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COUNT TWENTY

On or about March 23, 2012, within the State and District of Colorado, the defendants,

ALEJANDRO MORALES-GARCIA and ARMANDO MENDOZA-HARO, did knowingly and






indictment.


COUNT TWENTY-ONE


ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly conduct

and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit:

the transfer and delivery of currency, which involved the proceeds of a specified unlawful

activity, that is distribution and possession with the intent to distribute a controlled substance

with the intent to promote the carrying on of the specified unlawful activity, to wit: distribution

and possession with the intent to distribute a controlled substance and that while conducting and

attempting to conduct such financial transaction knew that the property involved in the financial

transaction represented the proceeds of some form of unlawful activity.

All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i).

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COUNT TWENTY-TWO

On or about September 21, 2011, within the State and District of Colorado, the

defendants, ARMANDO MENDOZA-HARO, SERGIO MENDOZA-VALDOVINOS, and

MIGUEL SANCHEZ, did knowingly conduct and attempt to conduct a financial transaction

affecting interstate and foreign commerce, to wit: the transfer and delivery of currency, which

involved the proceeds of a specified unlawful activity, that is distribution and possession with

the intent to distribute a controlled substance with the intent to promote the carrying on of the

specified unlawful activity, to wit: distribution and possession with the intent to distribute a

controlled substance and that while conducting and attempting to conduct such financial

transaction knew that the property involved in the financial transaction represented the proceeds

of some form of unlawful activity.


COUNT TWENTY-THREE

On or about January 17, 2012, within the State and District of Colorado, the defendants;

ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and MIGUEL SANCHEZ; did knowingly

conduct and attempt to conduct a financial transaction, to wit: the transfer and delivery of

currency, which involved the proceeds of a specified unlawful activity, that is distribution and

possession with the intent to distribute a controlled substance with the intent to promote the

carrying on of the specified unlawful activity, to wit: distribution and possession with the intent

to distribute a controlled substance and that while conducting and attempting to conduct such

financial transaction knew that the property involved in the financial transaction represented the

proceeds of some form of unlawful activity.


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COUNT TWENTY-FOUR

On or about August 30, 2011, within the State and District of Colorado and elsewhere,

the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA; did knowingly

conduct and attempt to conduct a financial transaction, the financial transaction and attempted

transaction involved the proceeds of a specified unlawful activity, the defendants knew that the

property involved in the financial transaction and attempted transaction represented the proceeds

of some form of unlawful activity, and the defendants conducted and attempted to conduct the

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

nature, location, source, ownership, or control of the proceeds of the unlawful activity and did

knowingly and intentionally aid, abet, counsel, command, induce or procure the same.

All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

COUNT TWENTY-FIVE


the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly




of some form of unlawful activity, and knowing that the transaction is designed to avoid a

transaction reporting requirement under State or Federal Law and did knowingly and

intentionally aid, abet, counsel, command, induce or procure the same.

All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.

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COUNT TWENTY-SIX


the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA; did knowingly




of some form of unlawful activity, and the defendants conducted and attempted to conduct the

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

nature, location, source, ownership, or control of the proceeds of the unlawful activity and did



COUNT TWENTY-SEVEN


the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly




of some form of unlawful activity, and knowing that the transaction is designed to avoid a

transaction reporting requirement under State or Federal Law and did knowingly and



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COUNT TWENTY-EIGHT


the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct

a financial transaction, the financial transaction and attempted transaction involved the proceeds

of a specified unlawful activity, the defendant knew that the property involved in the financial

transaction and attempted transaction represented the proceeds of some form of unlawful

activity, and the defendant conducted and attempted to conduct the financial transaction knowing

that it was designed in whole or in part to conceal or disguise the nature, location, source,

ownership, or control of the proceeds of the unlawful activity.

All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i).

COUNT TWENTY-NINE

On or about October 11, 2011, within the State and District of Colorado and elsewhere,

the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO

PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial

transaction, the financial transaction and attempted transaction involved the proceeds of a

specified unlawful activity, the defendants knew that the property involved in the financial


activity, and the defendants conducted and attempted to conduct the financial transaction

knowing that it was designed in whole or in part to conceal or disguise the nature, location,

source, ownership, or control of the proceeds of the unlawful activity and did knowingly and



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COUNT THIRTY



PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial




activity, and knowing that the transaction is designed to avoid a transaction reporting

requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel,

command, induce or procure the same.


COUNT THIRTY-ONE












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COUNT THIRTY-TWO











COUNT THIRTY-THREE


the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ;

did knowingly conduct and attempt to conduct a financial transaction, the financial transaction

and attempted transaction involved the proceeds of a specified unlawful activity, the defendants

knew that the property involved in the financial transaction and attempted transaction

represented the proceeds of some form of unlawful activity, and the defendants conducted and

attempted to conduct the financial transaction knowing that it was designed in whole or in part to

conceal or disguise the nature, location, source, ownership, or control of the proceeds of the

unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or

procure the same.


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COUNT THIRTY-FOUR


the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ,




represented the proceeds of some form of unlawful activity, and knowing that the transaction is

designed to avoid a transaction reporting requirement under State or Federal Law and did



COUNT THIRTY-FIVE












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COUNT THIRTY-SIX











COUNT THIRTY-SEVEN










procure the same.


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COUNT THIRTY-EIGHT










COUNT THIRTY-NINE












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COUNT FORTY











COUNT FORTY-ONE










procure the same.


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COUNT FORTY-TWO










COUNT FORTY-THREE


the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to

conduct a financial transaction, the financial transaction and attempted transaction involved the

proceeds of a specified unlawful activity, the defendant knew that the property involved in the

financial transaction and attempted transaction represented the proceeds of some form of

unlawful activity, and the defendant conducted and attempted to conduct the financial

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

location, source, ownership, or control of the proceeds of the unlawful activity.


COUNT FORTY-FOUR



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COUNT FORTY-FIVE










COUNT FORTY-SIX






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COUNT FORTY-SEVEN


the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly transport, transmit,

transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a

place in the United States to a place outside the United States with the intent to promote the

carrying on of a specified unlawful activity.

All in violation of Title 18, United States Code, Sections 1956(a)(2)(A).

COUNT FORTY-EIGHT




place in the United States to a place outside the United States knowing that the monetary

instrument and funds involved in the transportation, transmission, and transfer represented the

proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is

designed to conceal and disguise the nature, the location, the source, the ownership and the

control of the proceeds of the unlawful activity.


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COUNT FORTY-NINE




place in the United States to a place outside the United States with the intent to promote the

carrying on of a specified unlawful activity.

All in violation of Title 18, United States Code, Sections 1956(a)(2)(A).

COUNT FIFTY




place in the United States to a place outside the United States knowing that the monetary

instrument and funds involved in the transportation, transmission, and transfer represented the

proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is

designed to conceal and disguise the nature, the location, the source, the ownership and the

control of the proceeds of the unlawful activity.


COUNT FIFTY-ONE


the defendants; ARMANDO MENDOZA-HARO and DANIELA MUNGIA DE ORTIZ; did

knowingly conduct and attempt to conduct a financial transaction, the financial transaction and

attempted transaction involved the proceeds of a specified unlawful activity, the defendants


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procure the same.


COUNT FIFTY-TWO


the defendants; ARMANDO MENDOZA-HARO and DANIELA MUNGIA DE ORTIZ; did








procure the same.


COUNT FIFTY-THREE

On or about November 4, 2011, within the State and District of Colorado and elsewhere,




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procure the same.


COUNT FIFTY-FOUR










COUNT FIFTY-FIVE






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procure the same.


COUNT FIFTY-SIX










COUNT FIFTY-SEVEN







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procure the same.


COUNT FIFTY-EIGHT










COUNT FIFTY-NINE








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procure the same.


COUNT SIXTY










COUNT SIXTY-ONE









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procure the same.


COUNT SIXTY-TWO










COUNT SIXTY-THREE









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procure the same.


COUNT SIXTY-FOUR

On or about November 28, 2011, within the State and District of Colorado and

elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt

to conduct a financial transaction, the financial transaction and attempted transaction involved

the proceeds of a specified unlawful activity, the defendant knew that the property involved in

the financial transaction and attempted transaction represented the proceeds of some form of


transaction knowing




COUNT SIXTY-FIVE

On or about December 1, 2011, within the State and District of Colorado and elsewhere,








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COUNT SIXTY-SIX

On or about January 19, 2012, within the State and District of Colorado and elsewhere,









COUNT SIXTY-SEVEN










COUNT SIXTY-EIGHT


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COUNT SIXTY-NINE










COUNT SEVENTY

On or about March 20, 2012, within the State and District of Colorado and elsewhere, the

defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did



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procure the same.


COUNT SEVENTY-ONE










procure the same.


COUNT SEVENTY-TWO


defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did


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COUNT SEVENTY-THREE


defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN

SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the

financial transaction and attempted transaction involved the proceeds of a specified unlawful

activity, the defendants knew that the property involved in the financial transaction and

attempted transaction represented the proceeds of some form of unlawful activity, and the

defendants conducted and attempted to conduct the financial transaction knowing that it was

designed in whole or in part to conceal or disguise the nature, location, source, ownership, or

control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet,

counsel, command, induce or procure the same.


COUNT SEVENTY-FOUR


defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA and CARLOS MARTIN

SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the


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attempted transaction represented the proceeds of some form of unlawful activity, and knowing

that the transaction is designed to avoid a transaction reporting requirement under State or

Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or

procure the same.


COUNT SEVENTY-FIVE


defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN










COUNT SEVENTY-SIX


defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN



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procure the same.


COUNT SEVENTY-SEVEN










procure the same.


COUNT SEVENTY-EIGHT


defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did



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COUNT SEVENTY-NINE


defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to








COUNT EIGHTY








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COUNT EIGHTY-ONE









procure the same.


COUNT EIGHTY-TWO








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COUNT EIGHTY-THREE









procure the same.


COUNT EIGHTY-FOUR








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COUNT EIGHTY-FIVE









procure the same.


COUNT EIGHTY-SIX








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COUNT EIGHTY-SEVEN









procure the same.


COUNT EIGHTY-EIGHT








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procure the same.


COUNT EIGHTY-NINE

On or about March

dark angel indictment 1

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