Treviño Morales
Treviño Morales
COP' oc 23 2019
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS CLERK, US. O5TRCT CLERK
SAN ANTONIO DIVISION
V.
CT 1: 21 U.S.C. 846, 841(a)(1) & (b)(1)(A)
J J(
Conspiracy to Possess a Controlled Substance
JUAN GERARDO TREVINO-CHAVEZ with Intent to Distribute (Marijuana);
also known as "HUEVO," (1), CT 2: 21 U.S.C. 952 & 960(a)(1) Conspiracy
to Import with Intent to Distribute a
Controlled Substance (Marijuana);
Defendant. CT 3: 21 U.S.C. 959(a)- Unlawful
Distribution of Controlled Substances Extra-
territorial;
CT4: 21 U.S.C. 861(a)(1) and846
Conspiracy to Employ a Person Under 18
years of Age in Drug Operations; Aiding &
Abetting
CT 5: 21 U.S.C. 846, 841(a)(1) & (b)(1)(A)
Conspiracy to Possess a Controlled Substance
with Intent to Distribute (Cocaine);
CT 6: 21 U.S.C. 952 & 960(a)(1) Conspiracy
to Import with Intent to Distribute a
Controlled Substance (Cocaine);
CT 7: 21 U.S.C. 846, 841(a)(l) & (b)(1)(A)
Conspiracy to Possess a Controlled Substance
with Intent to Distribute (Methamphetamine);
CT 8: 21 U.S.C. 952 & 960(a)(1) Conspiracy
to Import with Intent to Distribute a
Controlled Substance (Methamphetaniine);
CT 9: 18 U.S.C. 924(o) Conspiracy to
Possess Firearms in Furtherance of Drug
Trafficking;
CT 10: 18 U.S.C. 922(o) and 2 Possession of
a Machine Gun in Furtherance of Drug
Trafficking and Attempt; Aiding and Abetting
CT 11: 18 U.S.C.1956(a)(l)(A)- Laundering
of Monetary Instruments
leader of the Cartel Del Noreste drug cartel, also known as "CDN". CDN is the successor cartel
to the LOS ZETAS International Drug Cartel. CDN was established by JUAN GERARDO
TREVINO-CIIAVEZ and other members of his family after Miguel Trevino-Morales, aka as
"Zeta 40", and Omar Trevino-Morales, aka "Zeta 42", who were the leaders of the LOS ZETAS
Drug cartel, were arrested in Mexico. Prior to this time, JUAN GERARDO TREVINO-
CHAVEZ had worked for LOS ZETAS as a leader, drug trafficker, enforcer, weapons procurer,
and, for a period of time, as a plaza leader. In furtherance of the conspiracy, the Defendant ordered,
counseled, commanded, induced, procured, and caused the deaths of multiple people.
COUNT ONE
121 U.S.C. § 846, 841(a)(1) & (b)(1)(A)J
Beginning on or about January 1, 2006, and continuing until on or about the date of this
indictment, in the Western District of Texas, the Southern District of Texas, the Republic of
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to possess with intent to distribute and distribute a
controlled substance, which offense involved 1000 kilograms or more of a mixture and substance
21, United States Code, Section 841(a)(1) and 841 (b)(1)(A)(vii), in violation of Title 21, United
COUNT TWO
[21 U.S.C. § 952(a), 960(a)(1), 960(b)(1)(G) & 963J
Beginning on or about January 1, 2006, and continuing until the date of this indictment,
in the Western District of Texas, the Southern District of Texas, the Republic of Mexico, and
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to commit offenses against the United States, in
violation of Title 21, United States Code, Section 963, that is to say, they conspired to import a
controlled substance, which offense involved 1000 kilograms or more of a mixture and substance
containing a detectable amount of marijuana, a Schedule 1 Controlled Substance, into the United
States from Mexico contrary to Title 21, United States Code, Sections 952(a), 960(a)(1) and
960(b)( 1 )(G).
COUNT THREE
[21 U.S.C. § 959(a), 963, 960(a)(3) and (b)(1)]
Beginning on or about January 1, 2006, and continuing until the date of this indictment,
in the Western District of Texas, the Southern District of Texas, the Republic of Mexico, and
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to commit offenses against the United States, in
violation of Title 21, United States Code, Section 963, that is to say, they conspired to distribute
detectable amount of cocaine, a Schedule II Controlled Substance, 500 grams or more of a mixture
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substance, intending and knowing that said controlled substance would be unlawfully imported
into the United States, in violation of Title 21, United States Code, Sections .959(a), 963, and
COUNT FOUR
[21 U.S.C. §846, 861(a)(1) and (b)J
Beginning on or about January 1, 2006 and continuing until the date of this indictment, in
being a person of at least eighteen (18) years of age, did knowingly and intentionally and
unlawfully conspire, combine, confederate, and agree with others known and unknown to the
Grand Jury to employ, hire, use, persuade, induce, entice, and coerce a person or persons under
eighteen (18) years of age, to violate Title 21, United States Code, Sections 841(a)(1), 846, 952(a),
960(a)(1), 959, and 963, in violation of Title 21, United States Code, Section 846, 861(a)(1) and
(b).
COUNT FIVE
[21 U.S.C. § 846, 841(a)(1) & (b)(1)(A)]
Beginning on or about January 1, 2005, and continuing until the date of this indictment,
in the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to possess with intent to distribute and distribute a
controlled substance, which offense involved 5 kilograms or more of a mixture and substance
21, United States Code, Section 841(a)(1) and 841 (b)(l)(A)(ii), in violation of Title 21, United
States Code, Section 846.
COUNT SIX
[21 U.S.C. 952(a), 960(a)(1), 960(b)(1)(B) & 963]
Beginning on or about January 1, 2005, and continuing until the date of this indictment in
the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to commit offenses against the United States, in
violation of Title 21, United States Code, Section 963, that is to say, they conspired to import a
controlled substance, which offense involved 5 kilograms or more of a mixture and substance
containing a detectable amount of cocaine, a Schedule II Controlled Substance, into the United
States from Mexico contrary to Title 21, United States Code, Sections 952(a), 960(a)(l) and
960(b)( 1 )(B).
COUNT SEVEN
[21 U.S.C. § 846, 841(a)(1) & (b)(1)(A)J
Beginning on or about May 1, 2008, and continuing until the date of this indictment, in
the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others known and unknown to the Grand Jury, to possess with intent to distribute and distribute a
controlled substance, which offense involved 500 grams or more of a mixture and substance
to Title 21, United States Code, Section 841(a)(l) and 841 (b)(l)(A)(viii), in violation of Title 21,
United States Code, Section 846.
COUNT EIGHT
[21 U.S.C. § 952(a), 960(a)(1), 960(b)(1)(B) & 963]
in
Beginning on or about January 1, 2005, and continuing until the date of this indictment
the Western District of Texas, the Republic of Mexico, and elsewhere, the Defendant,
and 960(b)(l)(B).
COUNT NINE
[18 U.S.C. § 924(c)(1) and (0)1
Beginning on or about January 1, 2008, and continuing until the date of this indictment, in
Defendant,
the Western District of Texas, the Republic of Mexico, and elsewhere, the
That beginning on or about March 10, 2016, in the Western District of Texas,
the
Defendant,
furtherance of a crime of
did knowingly possess and aid and abet the possession of a firearm in
a court of the United
violence and a drug trafficking crime for which he may be prosecuted in
L3 53631, a Bushmaster,
States, that is, a Bushmaster, XMl 5, .223-caliber Machinegun, S/N
XM15, .223-caliber
XM15, .223-caliber Machinegun, S/N L353701, and a Bushmaster,
Section 924(c)(1)(B)(ii)
Machinegun, S/N L528469, in violation of Title 18, United States Code,
and 2.
COUNT ELEVEN
(18 U.S.C. § 1956 (a)(1)(A)(i) & (ii) and 1956(h))
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property involved in the financial transaction represented the proceeds of some form of unlawful
activity.
I.
As a result of the foregoing criminal violations set forth in Counts One, Two, Three, Four,
Six, and Eight, the United States of America gives notice to Defendants of its intent to seek the
forfeiture of the below described property upon conviction and pursuant to Fed. R. Crim. P. 32.2,
Title 21 U.S.C. § 853(a)(1) and (a)(2), and Title 21 U.S.C. § 970, which state the following:
This Notice of Demand for Forfeiture includes, but is not limited to, the property described
II.
Money Laundering Forfeiture Statutes and Violations
[Title 18 U.S.C. § 1956(a)(1)(A)(i), (ii), and (h); subject to
forfeiture pursuant to Title 18 U.S.C. § 982(a)(1)]
As a result of the foregoing criminal violations set forth in Count Seven, the United States
of America gives notice to Defendants of its intent to seek the forfeiture of the below listed
property upon conviction and pursuant to Title 18 U.S.C. § 982(a)(l), which states the following:
This Notice of Demand for Forfeiture includes, but is not limited to, the property described in
A TRUE BILL.
I
JOHN F. BASH
United States Attorney