REDACTED

COP' oc 23 2019
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS CLERK, US. O5TRCT CLERK
SAN ANTONIO DIVISION

UNITED STATES OF AMERICA CR$A1 9 CR07 8 !

Plaintiff, INDICTMENT

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

THE GRAND JURY CHARGES:

 The Defendant, JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO", is the current

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

Mexico, and elsewhere, the Defendant,

JUAN GERARIO TREVINO-CHAVEZ aka "ifiJEVO",

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

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

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

States Code, Section 846.

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

elsewhere, the Defendant,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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

elsewhere, the Defendant,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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

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

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

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

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

detectable amount of cocaine, a Schedule II Controlled Substance, 500 grams or more of a mixture

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

3
substance, intending and knowing that said controlled substance would be unlawfully imported

into the United States, in violation of Title 21, United States Code, Sections .959(a), 963, and

960(a)(3) and (b)(l).

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

the Western District of Texas and elsewhere, Defendant,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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

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

controlled substance, which offense involved 5 kilograms or more of a mixture and substance

containing a detectable amount of cocaine, a Schedule II Controlled Substance, contrary to Title

21, United States Code, Section 841(a)(1) and 841 (b)(l)(A)(ii), in violation of Title 21, United
States Code, Section 846.

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,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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

containing a detectable amount of methamphetamine, a Schedule II Controlled Substance, contrary

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,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

and agreed with
knowingly, intentionally, and unlawfully conspired, combined, confederated,
the United States, in
others known and unknown to the Grand Jury, to commit offenses against
to import a
violation of Title 21, United States Code, Section 963, that is to say, they conspired
mixture and substance
controlled substance, which offense involved 500 grams or more of a
Substance, into the
containing a detectable amount of methamphetamine, a Schedule II Controlled
952(a), 960(a)(1)
United States from Mexico contrary to Title 21, United States Code, Sections

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

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

and unknown to the
knowingly combined, conspired, confederated, and agreed with others known
conspired to
Grand Jury to commit offenses against the United States, that is, the DEFENDANT
in Counts One, Two, Three,
possess firearms in furtherance of the drug trafficking crimes charged
to Title 18, United States
Five, Six, Seven, and Eight of this Indictment, re-alleged herein, contrary

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

 COUNT TEN
(18 U.S.C. § 924(c)(1)(B)(ii), 2)

That beginning on or about March 10, 2016, in the Western District of Texas,
the

Defendant,

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

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))

including the date of

Beginning on or about January 1, 2010, and continuing through and
Defendants,
this indictment, in the Western District of Texas and elsewhere, the

JUAN GERARDO TREVINO-CHAVEZ aka "HUEVO",

unknown to the Grand Jury to
did knowingly conspire with each other and others known and
interstate and foreign
conduct and to attempt to conduct financial transactions, affecting
activity, to-wit: drug trafficking
commerce, which involved the proceeds of a specified unlawful
963, 952, 959 and 960(a)( 1),
violations of Title 21, United States Code, Sections 846, 841 (a)(1),
activity knowing that the
with the intent to promote the carrying on of the specified unlawful

7
property involved in the financial transaction represented the proceeds of some form of unlawful

activity.

UNITED STATES OF AMERICA'S NOTICE OF DEMAND FOR FORFEITURE

[See Fed. R. Crim. P. 32.2]

I.

Controlled Substance Forfeiture Statutes and Violations

[Title 21 U.S.C. § 841(a)(1), (b), (b)(1)(A)(ii), 841(b)(1)(A)(vii), 846,
861(a)(1) and (b), 952(a), 959 and 959(a), 960(a)(1), 960(a)(1), (a)(3), (b)(1)(B),
And (b)(1)(G); 961(a)(1) and (b); 963; subject to forfeiture pursuant to
Title 21 U.S.C. § 853(a)(1) and (a)(2) and Title 21 U.S.C. § 970]

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:

§ 853 Criminal forfeitures

(a) Property subject to criminal forfeiture
Any person convicted of a violation of this subchapter or subchapter II of this chapter
punishable by imprisonment for more than one year shall forfeit to the United States,
irrespective of any provisions of State law-
(1) any property constituting, or derived from, any proceeds the person obtained,
directly or indirectly, as the result of such violation;
(2) any of the person's property used, or intended to be used, in any manner or part,
to commit, or to facilitate the commission of, such violation.

§ 970. Criminal forfeitures

Section 853 of this title, relating to criminal forfeitures, shall apply in every respect to a
violation of this subchapter punishable by imprisonment for more than one year.

This Notice of Demand for Forfeiture includes, but is not limited to, the property described

in paragraph III below.

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:

§ 982. Criminal forfeiture

(a)(1) The court, in imposing sentence on a person convicted of an offense
in violation of section 1956, 1957, or 1960 of this title, shall order that the
person forfeit to the United States any property, real or personal, involved
in such offense, or any property traceable to such property.

This Notice of Demand for Forfeiture includes, but is not limited to, the property described in

paragraph III below.

A TRUE BILL.
I

FEPE1ö OF THE GkAJD JURY

JOHN F. BASH
United States Attorney

Assistant United States Attorney