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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.
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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
On or about July 13, 2011, within the State and District of Colorado, the defendants,
ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, 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 SIX
On or about July 14, 2011, within the State and District of Colorado, the defendants,
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ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, 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 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.
All in violation of Title 21, United States Code, Section 843(b).
COUNT EIGHT
On or about September 2, 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
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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 NINE
On or about October 19, 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 TEN
On or about October 25, 2011, within the State and District of Colorado, the defendants,
ARMANDO MENDOZA-HARO and MIGUEL ANGEL SANCHEZ, 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
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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 ELEVEN
On or about October 25, 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 TWELVE
On or about October 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.
All in violation of Title 21, United States Code, Section 843(b).
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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.
All in violation of Title 21, United States Code, Section 843(b).
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.
All in violation of Title 21, United States Code, Section 843(b).
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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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 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.
All in violation of Title 21, United States Code, Section 843(b).
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
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
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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 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
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 500 grams or more of a mixture or substance containing a detectable amount of
methamphetamine, as alleged in Count One of this indictment.
All in violation of Title 21, United States Code, Section 843(b).
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
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).
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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
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 TWENTY-ONE
On or about July 13, 2011, within the State and District of Colorado, the defendants,
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.
All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i).
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.
All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i).
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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
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 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
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-SEVEN
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 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-EIGHT
On or about August 30, 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 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
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.
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COUNT THIRTY
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
transaction and 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.
COUNT THIRTY-ONE
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
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.
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COUNT THIRTY-TWO
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
transaction and 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.
COUNT THIRTY-THREE
On or about October 12, 2011, within the State and District of Colorado and elsewhere,
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
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COUNT THIRTY-FOUR
On or about October 12, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT THIRTY-FIVE
On or about October 12, 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
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.
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COUNT THIRTY-SIX
On or about October 12, 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
transaction and 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.
COUNT THIRTY-SEVEN
On or about October 12, 2011, within the State and District of Colorado and elsewhere,
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
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COUNT THIRTY-EIGHT
On or about October 12, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT THIRTY-NINE
On or about October 13, 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
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.
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COUNT FORTY
On or about October 13, 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
transaction and 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.
COUNT FORTY-ONE
On or about October 13, 2011, within the State and District of Colorado and elsewhere,
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
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COUNT FORTY-TWO
On or about October 13, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT FORTY-THREE
On or about October 13, 2011, within the State and District of Colorado and elsewhere,
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i).
COUNT FORTY-FOUR
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to
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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 FORTY-FIVE
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i).
COUNT FORTY-SIX
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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
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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 FORTY-SEVEN
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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 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.
All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i).
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COUNT FORTY-NINE
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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 FIFTY
On or about October 14, 2011, within the State and District of Colorado and elsewhere,
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 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.
All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i).
COUNT FIFTY-ONE
On or about October 20, 2011, within the State and District of Colorado and elsewhere,
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
knew that the property involved in the financial transaction and attempted transaction
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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 FIFTY-TWO
On or about October 21, 2011, within the State and District of Colorado and elsewhere,
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
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 FIFTY-THREE
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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
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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 FIFTY-FOUR
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT FIFTY-FIVE
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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
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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 FIFTY-SIX
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT FIFTY-SEVEN
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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
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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 FIFTY-EIGHT
On or about November 4, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT FIFTY-NINE
On or about November 7, 2011, within the State and District of Colorado and elsewhere,
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
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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 SIXTY
On or about November 7, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT SIXTY-ONE
On or about November 7, 2011, within the State and District of Colorado and elsewhere,
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
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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 SIXTY-TWO
On or about November 7, 2011, within the State and District of Colorado and elsewhere,
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 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.
COUNT SIXTY-THREE
On or about November 8, 2011, within the State and District of Colorado and elsewhere,
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
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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 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
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 SIXTY-FIVE
On or about December 1, 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 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.
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All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i).
COUNT SIXTY-SIX
On or about January 19, 2012, 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 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 SIXTY-SEVEN
On or about January 19, 2012, 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 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 SIXTY-EIGHT
On or about January 20, 2012, within the State and District of Colorado and elsewhere,
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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 SIXTY-NINE
On or about January 20, 2012, 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 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 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
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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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 SEVENTY-ONE
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
COUNT SEVENTY-TWO
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did
knowingly conduct and attempt to conduct a financial transaction, the financial transaction and
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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 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.
COUNT SEVENTY-THREE
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
COUNT SEVENTY-FOUR
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
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
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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 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.
COUNT SEVENTY-FIVE
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
COUNT SEVENTY-SIX
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, 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
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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 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.
COUNT SEVENTY-SEVEN
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.
COUNT SEVENTY-EIGHT
On or about March 22, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO 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
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knew that the property involved in the financial transaction and 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.
All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.
COUNT SEVENTY-NINE
On or about March 23, 2012, within the State and District of Colorado and elsewhere, the
defendant; 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 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 EIGHTY
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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
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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 EIGHTY-ONE
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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 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.
COUNT EIGHTY-TWO
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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
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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 EIGHTY-THREE
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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 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.
COUNT EIGHTY-FOUR
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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
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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 EIGHTY-FIVE
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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 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.
COUNT EIGHTY-SIX
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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
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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 EIGHTY-SEVEN
On or about March 24, 2012, within the State and District of Colorado and elsewhere, the
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 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.
COUNT EIGHTY-EIGHT
On or about March 26, 2012, within the State and District of Colorado and elsewhere, the
defendants; ARMANDO MENDOZA-HARO 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
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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 EIGHTY-NINE
On or about March