Redacted Indictment U.S. v. Nestor Isidro Perez Salas 508 Compliant 0

FILED IN OPEN COURT1
UNITED STATES DISTRICT COURT FEE3 2 2 202 I

FOR THE DISTRICT OF COLUMBIA
CLERK, U.S. DISTRICT COURr
Holding a Criminal Term L. DISTRICT OF COLUMBIA .J
Grand Jury Sworn on January 28, 2021
UNITED STATES OF AMERICA ) CRIMINAL NO. _ _ _ __

)
) UNDER SEAL
v. )
) 21 U.S.C. §§ 959(a), 960, 963
) (Conspiracy to Manufacture and
NESTOR ISIDRO PEREZ SALAS, ) Distribute Five Kilograms or More
also known as "Nestor Ernesto Perez Salas," ) of Cocaine and 500 Grams or More
"Nini," "El General," "19," "09," "Novena" ) of Methamphetamine for
) Importation into the United States)
Defendant. )
) 18 U.S.C. § 924(c)
) (Use, Carry, and Possession of a
) Firearm)
)
) 18 u.s.c. §§ 1513, 1111
) (Conspiracy to Obstruct Justice by
) Retaliating Against Witness and
) Infonnant)
)
) 18 u.s.c. § 2
) (Aiding and Abetting)
)
) 21 U.S.C. § 853 and§ 970
) (Criminal Forfeiture)
Case: 1:21-cr-00146
INDICTMENT Assigned to: Judge Rudolph Contreras
Assign Date: 2/22/2021
The Grand Jury charges that: Description: INDICTMENT (B)
Related Case: 19-cr-178 (RC)
COUNT ONE
Beginning in and around 2012, and continuing to the date of this Indictment, the exact dates
being unknown to the Grand Jury, in the countries of Guatemala, Mexico, the United States and
elsewhere, the Defendant, NESTOR ISIDRO PEREZ SALAS, also known as "Nestor Ernesto
Perez Salas," "Nini," "El General," "19," "09," "Novena," together with others, both known
and unknown to the Grand Jury, did knowingly, intentionally, and willfully combine, conspire,
confederate, and agree to manufacture and distribute five (5) kilograms or more of a mixture or
substance containing a detectable amount of cocaine, a Schedule II controlled substance, and five
hundred (500) grams or more of a mixture or substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance, intending, knowing, and having reasonable
cause to believe that such substances would be unlawfully imported into the United States from a
place outside thereof, in violation of Title 21, United States Code, Sections 959(a) and 960, all in
violation of Title 21, United States Code, Section 963 and Title 18, United States Code, Section 2.
With respect to the Defendant, the controlled substances involved in the conspiracy
attributable to the Defendant as a result of his own conduct and the conduct of other conspirators
reasonably foreseeable to him is: five (5) kilograms or more of a mixture and substance containing
a detectable amount of cocaine and five hundred (500) grams or more of a mixture or substance
containing a detectable amount ofmethamphetamine, in violation of Title 21, United States Code,
Sections 960(b)(l)(B)(ii) and 960(b)(l)(H).
(Conspiracy to Manufacture and Distribute Five Kilograms or More of Cocaine and

500 Grams or More of Methamphetamine, Intending, Knowing, and Having
Reasonable Cause to Believe That Such Substances Would be Unlawfully Imported
into the United States, in violation of Title 21, United States Code, Sections 959(a),
960(b)(l)(B)(ii), 960(b)(l)(H), and 963; and Aiding and Abetting in violation of
Title 18, United States Code, Section 2.)
COUNT TWO
From in or about January 2017, and continuing thereafter up to and including the date of
the filing of this Indictment, the exact dates being unknown to the Grand Jury, the Defendant,
NESTOR ISIDRO PEREZ SALAS, also known as "Nestor Ernesto Perez Salas," "Nini," "El
General," "19," "09," "Novena," did lmowingly and intentionally use, carry, brandish, and
discharge a firearm, during and in relation to one or more drug trafficking crimes, to wit: the crime
2
charged in Count One, and did knowingly and intentionally possess a firearm in furtherance of
such drug trafficking crimes, one or more of which firearms was a semiautomatic assault weapon
and a machinegun and a destructive device, in violation of Title 18, United States Code, Sections
924(c)(l)(A)(i), 924(c)(l)(A)(ii), 924(c)(l)(A)(iii), 924(c)(l)(B)(i), 924(c)(l)(B)(ii), and 2.
(Use, Carry, and Possession of a Firearm, in violation of Title 18, United States
Code, Sections 924(c)(l)(A)(i), 924(c)(l)(A)(ii), 924(c)(l)(A)(iii), 924(c)(l)(B)(i),
and 924(c)(1 )(B)(ii); and Aiding and Abetting, in violation of Title 18, United
States Code, Section 2)
COUNT THREE
Beginning on or about January 2017 and continuing to the date of this Indictment,
the exact dates being unknown to the Grand Jury, in the United States, Mexico and
elsewhere, the Defendant, NESTOR ISIDRO PEREZ SALAS, also known as "Nestor
Ernesto Perez Salas," "Nini," "El General," "19," "09," "Novena," together with
others, both known and unknown to the Grand Jury, did conspire to kill and attempt to kill
one or more persons and to knowingly engage in conduct, attempt to engage in conduct,
and threaten to engage in conduct that caused bodily injury to one or more persons and
damaged the tangible property of one or more person, with the intent to retaliate -
violation of Title 18, United States Code, Sections 1513(a)(l)(A), 1513(a)(1)(B), 1513(f),
'
111 1, and 2.
(Conspiracy to Obstruct Justice by Retaliating Against a Witness and Informant, in

violation of Title 18, United States Code, Sections 1513(a)(l)(A), 1513(a)(l)(B),
1513(f), and 111 1; Aiding and Abetting in violation of Title 18, United States Code,
Section 2)
3
CRIMINAL FORFEITURE ALLEGATION
The United States hereby gives notice to the Defendant that upon conviction of the Title
21 offense alleged in Count One of this Indictment, the Government will seek forfeiture in
accordance with Title 21, United States Code, Sections 853 and 970, of all property constituting
or derived from any proceeds the Defendant obtained directly or indirectly as a result ofthe alleged
Title 21 violation, and all prope1iy used or intended to be used in any manner or part to commit
and to facilitate the commission of such offense.
Said property includes, but is not limited to:
A sum of money equal to all proceeds the Defendant obtained directly or indirectly as a
result of the Title 21 offense charged in this Indictment, and all property used or intended to be
used to facilitate the offense, that is, not less than a sum ofmoney representing the amount of funds
involved in the offense, and all interest and proceeds traceable thereto; in that such sum, in
aggregate, was received by the Defendant in exchange for the distribution of controlled substances
or is traceable thereto. If any of the above-described forfeitable property, as a result of any act or
omission of the Defendant -
(a) cannot be located upon the exercise of due diligence;
(b) has been transforred or sold to, or deposited with, a third person;
(c) has been placed beyond the jurisdiction of the Court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be subdivided
without difficulty;
4
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) to seek forfeiture of any other
property of the said Defendant up to the value of the above forfeitable property.
(Criminal Forfeiture, in violation of Title 21, Untied States Code, Sections 853 and
970.)
A TRUE BILL:
Foreperson
ARTHUR WYATT
Chief
Narcotic and Dangerous Drug Section
Crirnirial Division
U.S. Department of Justice
Washington, D.C. 20530
By:~
KA~
KIRK HANDRICH
Trial Attorney
Narcotic and Dangerou_s Drug Section
Criminal Division
U.S. Department of Justice
Washington, D.C. 20530
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FILED IN OPEN COURT1

UNITED STATES DISTRICT COURT FEE3 2 2 202 I

UNITED STATES OF AMERICA ) CRIMINAL NO. _ _ _ __

hundred (500) grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, intending, knowing, and having reasonable

Sections 960(b)(l)(B)(ii) and 960(b)(l)(H).

(Conspiracy to Manufacture and Distribute Five Kilograms or More of Cocaine and

924(c)(l)(A)(i), 924(c)(l)(A)(ii), 924(c)(l)(A)(iii), 924(c)(l)(B)(i), 924(c)(l)(B)(ii), and 2.

(Conspiracy to Obstruct Justice by Retaliating Against a Witness and Informant, in

and to facilitate the commission of such offense.

Said property includes, but is not limited to:

omission of the Defendant -

(a) cannot be located upon the exercise of due diligence;

(c) has been placed beyond the jurisdiction of the Court;

(d) has been substantially diminished in value; or

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