Operation Family Guy Indictment

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8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 October 2012 Grand Jury

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11 UNITED STATES OF AMERICA, CR No. 1b~------~----12 Plaintiff,

13 v.

14 MILTON URENA, aka "Milton Urena-Vargas,")

15 aka "Big Brother," ) aka "El Bacano," )

16 aka "El Berraco," ) RAFAEL URENA, )

17 aka "Rafa," ) aka "The Cock," )

18 aka "The Mask," ) DANIEL ALEJANDRO AGREDANO )

19 VAZQUEZ, ) aka "Pablito," )

20 aka "Pablin," ) aka "Pablo," )

21 FRANCISCO JAVIER ) VARGAS-OSEGUERA, )

22 aka "Tronco," ) LEONEL URENA-PARTIDA, )

23 aka "Tio," ) aka "Cherokee," )

24 aka "Milfeos," ) CARMEN GARCIA, )

25 aka "Carmelita," ) ELISEO CARRILLO DUARTE, )

26 aka "Noel," ) aka "Pancho, " )

27 aka "Fernando ) Cabrera-Gomez," )

28 aka "Jesus Isais-Cabrera,")

[21 U.S.C, § 846: Conspiracy to Distribute Controlled Substances; 21 u.s.c. §§ 841(a) (1), (b) (1) (A) (viii) : Distribution of Methamphetamine; 21 U.S.C. § 843(b): Use of a Communication Facility in Committing a Felony Drug Offense; 18 U.S.C. § 1956(h): Conspiracy to Launder Monetary Instruments; 18 U.S.C. § 2(a): Aiding and Abetting]

Case 2:13-cr-00287-FMO Document 1 Filed 04/24/13 of 41 Page ID #:1

1 JENNA MICHELLE MARTIN, ) aka "Jenna Michelle )

2 Smith," ) aka "Gabacha," and )

3 BETH RENE FORD I )

aka "Beth Rene Upton," ) 4 aka "Beth Rene Florance," )

) 5 Defendants. ) ___________________________ ) 6

7 The Grand Jury charges:

8 COUNT ONE

9 [21 u.s.c. § 846]

10 A. OBJECT OF THE CONSPIRACY

11 Beginning on an unknown date, and continuing until in or

,12 around July 2012, in San Bernardino and Los Angeles Counties,

13 within the Central District of California, and elsewhere,

14 defendants MILTON URENA, also known as ("aka") "Milton

15 Urena-Vargas," aka "Big Brother," aka "El Bacano," aka "El

16 Berraco" ("MILTON URENA") , RAFAEL URENA, aka "Rafa," aka "The

17 Cock," aka "The Mask" ("RAFAEL URENA"), DANIEL ALEJANDRO AGREDANO

18 VAZQUEZ, aka "Pablito," aka "Pablin," aka "Pablo" ("AGREDANO"),

19 FRANCISCO JAVIER VARGAS-OSEGUERA, aka "Tronco"

20 ("VARGAS-OSEGUERA"), LEONEL URENA-PARTIDA, aka "Tio," aka

21 "Cherokee," aka "Milfeos" ("URENA-PARTIDA"), CARMEN GARCIA, aka

22 "Carmelita" ("GARCIA"), JENNA MICHELLE MARTIN, aka "Jenna

23 Michelle Smith," aka "Gabacha" ("MARTIN"), and BETH RENE FORD, .J .14 aka "Beth Rene Upton," aka "Beth Rene Florance" ("FORD"), and

25 unindicted co-conspirators D.D., K.P., J.N., M.A., G.U., and

26 A.S., and others known and unknown to the Grand Jury, conspired

27 and agreed with each other to knowingly and intentionally

28 distribute at least five kilograms of cocaine, a Schedule II

2


1 narcotic drug controlled substance, in violation of Title 21,

2 United States Code, Sections 841(a) (1) and 841(b) (1) (A) (ii).

3 B. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE ~·.

:: 4 ACCOMPLISHED

5 The object of the conspiracy was to be accomplished in

6 substance as follows:

7 1. Defendant MILTON URENA would organize the shipment of

8 cocaine from the Dominican Republic (the "DR") and Mexico to

9 Italy.

10 2. Defendant MILTON URENA would direct defendant RAFAEL

11 URENA when to send drug couriers to the DR to pick up cocaine

12 that was to be transported to Italy and direct defendant AGREDANO

13 to wire funds to defendant RAFAEL URENA and others in California

14 to pay for expenses related to the recruitment of drug couriers.

3. Defendant RAFAEL URENA would recruit drug couriers

l6 located within the Central District of California, who would

17 transport cocaine from the DR to Italy, and assist the couriers

18 with travel arrangements and obtaining U.S. passports.

19 4. Defendant AGREDANO would arrange for the delivery of

20 cocaine from the DR to Italy and would make travel arrangements

21 for the drug couriers.

22 5. Defendant AGREDANO would transport cocaine to Italy and

23 wire funds to defendant RAFAEL URENA and others at the direction

24 of defendant MILTON URENA.

25 6. Defendants MARTIN and FORD, and unindicted

26 co-conspirators D.D., K.P., and J.N., would receive cash payments .:-:·

27 from defendants MILTON URENA, RAFAEL URENA, and AGREDANO to '~ I

28 transport cocaine from the DR to Italy.

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1 7. Defendants VARGAS-OSEGUERA, GARCIA, and MARTIN would

2 recruit drug couriers for defendants MILTON URENA and RAFAEL

3 URENA.

4 8. Defendant URENA-PARTIDA would provide defendants MILTON

5 URENA and RAFAEL URENA a means to transport cocaine from Mexico

6 to Italy.

7 9 . Defendants MILTON URENA, RAFAEL URENA, and

·; 8 VARGAS-OSEGUERA would direct unindicted co-conspirators G. U. and

9 A.S. to deposit drug proceeds at JP Morgan Chase and Western

10 Union branch locations.

11 c. OVERT ACTS

12 In furtherance of the conspiracy, and to accomplish the

13 object of the conspiracy, on or about the following dates,

14 defendants MILTON URENA, RAFAEL URENA, AGREDANO, VARGAS-O~EGUERA,

15 URENA-PARTIDA, GARCIA, MARTIN, and FORD, and unindicted

16 co-conspirators D.D., K.P., J.N., M.A., G.U., and A.S., and

17 others known and unknown to the Grand Jury, committed various

18 overt acts within the Central District of California, and

';1.9 elsewhere, including but not limited to the following: :,: .. ·

20 1. On September 8, 2010, using coded language during a

21 telephone conversation, defendant MILTON URENA told defendant

22 RAFAEL URENA to ask defendant GARCIA to find two or three "white

23 guys" who could transport drugs from the DR.


25 telephone conversation, defendants MILTON URENA and RAFAEL URENA

26 discussed the need to find drug couriers who had a good

27 appearance and U.S. passports in order to avoid being questioned

28 or stopped by law enforcement.

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.1 3. On September 12, 2010, using coded language during a


3 RAFAEL URENA that their Italian customers had sent.money back

4 with the drug couriers and that defendant MILTON URENA was

5 receiving drug proceeds "little by little" because there was not

6 a secure way of transporting large amounts of cash from Italy to

7 the DR.



10 RAFAEL URENA that their Italian customers wanted to buy more

11 cocaine on credit.

5. On September 18, 2010, using coded language during a


14 RAFAEL URENA that their Italian customers were not happy with the

15 quality of drugs that were recently delivered.


17 telephone conversation, defendant MILTON URENA told an

18 unidentified co-conspirator that a drug courier delivered drugs

19 to Italy and had already returned.


21 telephone conversation, defendant MILTON URENA told an

22 unidentified co-conspirator that male drug couriers could

23 generally transRort 20 kilograms of cocaine and female drug

24 couriers could transport 15 to 20 kilograms of cocaine.


26 telephone conversation, defendant RAFAEL URENA told defendant

27 MILTON URENA that defendant GARCIA's friend could not transport

28 drugs because the friend was on probation.

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3 RAFAEL URENA that he would send two drug couriers, a male and a :J.

· · 4 female, next week.

5 10. On October 26, 2010, using coded language during a

6 telephone conversation, defendant MILTON URENA and an

7 unidentified co-conspirator discussed flights from Italy to the

8 ·DR.


10 telephone conversation, an unindicted co-conspirator told

11 defendant MILTON URENA that the unindicted co-conspirator almost

12 underwent an X-ray inspection at the airport in Mexico City,

13 Mexico, to check for concealed drugs.

14 12. On November 2, 2010, using coded language during a

l5 telephone conversation, defendant MILTON URENA told defendant

16 RAFAEL URENA that he had purchased 13 kilograms of cocaine for

17 further distribution.



20 MILTON URENA that he had found a female drug courier who needed a

21 U.S. passport.

22 14. On August 5, 2011, using coded language during a

23 telephone conversation, defendant URENA-PARTIDA told defendant

24 RAFAEL URENA that defendants URENA-PARTIDA and MILTON URENA

25 should transport drugs from Mexico to Italy rather than from the

t6 DR to Italy.

27 15. On August 5, 2011, during a telephone conversation,

28 defendant URENA-PARTIDA asked defendant RAFAEL URENA for the

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1 telephone number of defendant MILTON URENA.



4 URENA-PARTIDA that their customers in Italy do not want to

5 purchase drugs from Mexico because the drugs are too expensive.


/.7 BlackBerry Messenger ("BBM") conversation, defendant MILTON URENA ·~··

·8 told defendant RAFAEL URENA that they sent two kilograms of

9 cocaine to Italy, which was an "ice-breaker" with their Italian

10 customers.

11 18. On October 28, 2011, during a BBM conversation,

12 defendant MILTON URENA asked defendant RAFAEL URENA whether a

13 female drug courier had taken her birth certificate and pictures

14 to the passport office~

15 19. On October 28, 2011, defendant AGREDANO used Western

16 Union to wire approximately 14,732.28 Dominican pesos (or

17 approximately $388.10 in U.S. currency) f~om Santo Domingo, DR,

18 to Fontana, California, to pay for the purchase of a U.S.

'1.9 passport for defendant MARTIN.

20 20. On October 28, 2011, defendant RAFAEL URENA drove

21 unindicted co-conspirator G.U. to a check-cashing business in

22 Fontana, California, to pick up the money wired by defendant

23 AGREDANO for defendant MARTIN's passport.

24 21. On November 1, 2011, defendant RAFAEL URENA provided

25 defendant MARTIN with approximately $195 in cash for the purchase

26 of defendant MARTIN's U.S. passport.

27 22. On November 1, 2011, defendant RAFAEL URENA drove

28 defendant MARTIN to a passport office in Los Angeles, California,

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1 to submit her U.S. passport application.

2 23. On November 2, 2011, defendant AGREDANO received an

3 e-mail containing the flight itinerary of unindicted

4 co-conspirator J.N., who was traveling from the DR to Rome,

5 Italy.


7 defendant MARTIN to a passport office in Los Angeles, California,

8 to retrieve defendant MARTIN's U.S. passport.

9 25. On November 2, 2011, using coded language during a BBM

10 conversation, defendant RAFAEL URENA told defendant MILTON URENA

11 that he drove defendant MARTIN back to her house and she was now :!

12 ready to travel to the DR to transport cocaine from the DR to

13 Italy.


15 conversation, defendant MILTON URENA told defendant RAFAEL URENA

16 that they would start earning money once defendant RAFAEL URENA

17 started sending female drug couriers to the DR to transport

18 cocaine to Italy.



21 that he was offering the female drug courier $10,000 to transport

22 cocaine from the DR to Italy.

23 28. On November 5, 2011, unindicted co-conspirator J.N.

24 traveled from the DR to Rome, Italy, to deliver cocaine.



27 that unindicted co-conspirator J.N. had successfully delivered

28 cocaine to a customer in Italy.

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~-3 that defendant MARTIN had friends who wanted to transport drugs

~ 4 to Italy, but the friends wanted to wait until defendant MARTIN

5 had made a successful delivery.


7 conversation, defendant RAFAEL URENA provided defendant MILTON

8 URENA the full·name of defendant MARTIN in preparation for her

9 travel to the DR.

10 32. On November 8, 2011, defendant RAFAEL URENA provided

11 defendant AGREDANO the e-mail address where defendant AGREDANO

12 could send defendant MARTIN's airline ticket.

13 33. On November 8, 2011, defendant AGREDANO received an

*4 e-mail containing the flight itinerary for defendant MARTIN's

15 travel from Los Angeles, California, to Santo Domingo, DR, on

16 November 11, 2011.

17 34. On November _8, 2011, de~endant AGREDANO received an

18 e-mail containing the flight itinerary for defendant MARTIN's

19 travel from Rome, Italy, to Santo Domingo, DR, on November 19,

20 2011.

21 35. On November 9, 2011, during a BBM conversation,

22 defendant RAFAEL URENA provided defendant MILTON URENA the e-mail

23 address where defendant AGREDANO could send defendant MARTIN's

24 airline ticket.

25 36. On November 9, 2011, during a BBM conversation,

26 defendant RAFAEL URENA provided defendant AGREDANO with defendant

27 MARTIN's full name and date of birth in preparation for her

28 travel to the DR.

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2 defendant MARTIN to Los Angeles International Airport so that

3 defendant MARTIN could board her flight to Santo Domingo, DR, via

4 Atlanta, Georgia.

5 38. On November 11, 2011, defendants MILTON URENA and

6 AGREDANO met defendant MARTIN at the airport in Santo Domingo,

~7 DR.

8 39. On November 11, 2011, defendants MILTON URENA and

9 AGREDANO provided transportation for defendant MARTIN in Santo

10 Domingo, DR.


12 conversation, defendants MILTON URENA and RAFAEL URENA agreed to

13 pay defendant MARTIN approximately $3,000 in cash for her time

14 and as an advancement for her next trip to Italy to distribute

15 drugs.



~8 that defendant MARTIN would be paid $1,000 in cash for each drug

19 courier defendant MARTIN recruited.

20 42. On November 16, 2011, via text message, defendant

21 MARTIN told defendant RAFAEL URENA that she was recruiting

22 another female drug courier.



25 to send money to pay for defendant FORD's passport.



28 that defendant AGREDANO had wire.d funds in the amount of $597.58

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· 1 for the benefit of defendant RAFAEL URENA.



4 that he had agreed to meet with defendants MARTIN and FORD around

5 4:00p.m. that day.

6 46. On November 21, 2011, defendants RAFAEL URENA, MARTIN,

7 and FORD met at a coffee shop in Ontario, California, to discuss

8 obtaining a passport for defendant FORD.

9 47. On December 1, 2011, using coded language during a BBM

lO conversation, defendant MILTON URENA told defendant RAFAEL URENA

11 that a shipment of cocaine was ready to be transported to Italy,

12 but they did not yet have a female drug courier or an airline

13 ticket.



16 to find out whether defendant MARTIN or defendant FORD could go

17 to the DR during the upcoming weekend to transport cocaine from

18 the DR to Italy.

19 49. On December 2, 2011, defendant AGREDANO received an

20 e-mail confirmation regarding unindicted co-conspirator J.N.'s

21 travel from the DR to Rome, Italy, on Blue Panorama Airlines, 1 22 flight BV1613, on December 3, 2011.


24 conversation, defendant MILTON URENA told defeNdant RAFAEL URENA

25 that defendant AGREDANO and unindicted co-conspirator J.N. were

26 traveling to Italy with a shipment of cocaine.

27 51. On December 3, 2011, defendant AGREDANO received an

28 e-mail confirmation regarding defendant AGREDANO's travel from

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1 the DR, to Rome, Italy, on Blue Panorama Airlines, flight BV1613,

2 on December 3, 2011.

). 3 52. On December 3, 2011, using coded language during a BBM ,;,


5 that defendant AGREDANO and unindicted co-conspirator J.N. were

6 transporting cocaine to Italy.

7 53. On December 3, 2011, via text message, defendant MARTIN

8 told defendant RAFAEL URENA that defendant FORD will not travel

9 without defendant MARTIN.

10 54. On December 3, 2011, via text message, defendant RAFAEL

11 URENA told defendant MARTIN that he would ask for money to pay

12 for defendant FORD's passport.

13. 55. On December 3, 2011, using coded language during a BBM

~4 conversation, defendant RAFAEL URENA asked defendant MILTON URENA

is to send money to pay for defendant FORD's passport.



18 that once defendant AGREDANO delivered cocaine in Italy,

19 defendant MILTON URENA would ask defendant AGREDANO to lend him

20 money earned from the sale of the cocaine in Italy.



23 that their Italian customers had money to pay for the cocaine.


25 conversation, defendant MILTON URENA told defendant RAFAEL URENA ~ .

?.6 that defendant AGREDANO would send 2,000 Euros to defendant

27 RAFAEL URENA.


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2 that defendant AGREDANO had the drug proceeds, but there was no

3 Western Union to wire the money from Italy.

4 60. On December 7, 2011, via Western Union wire, defendant

5 AGREDANO sent unindicted co-conspirator G.U. approximately 900

;6 Euros (or approximately $1,144.76 in U.S. currency), ~rom Rome, ,.,!_·,

~7 Italy, to Rancho Cucamonga, California, for the benefit of

8 defendant RAFAEL URENA.

9 61. On December 7, 2011, during a BBM conversation,

10 defendant AGREDANO provided defendant RAFAEL URENA a wire

11 transfer number and told defendant RAFAEL URENA to let him know

12 when defendant RAFAEL URENA received the money.

13 62. On December 7, 2011, during a telephone conversation,

14 defendant RAFAEL URENA confirmed that unindicted co-conspirator

15 G.U. had picked up the money sent from Italy.

16 63. On December 7, 2011, during a BBM conversation,

17 defendant RAFAEL URENA told defendant AGREDANO that the money was

:·j_8 received and asked defendant AGREDANO whether he would be sending

19 more money the following day.


21 defendant RAFAEL URENA told unindicted co-conspirator G.U. that

22 the maximum amount of money that could be sent from Italy was

23 1,000 Euros, that the money received that day was the equivalent

24 of 1,000 Euros, and that another 1,000 Euros would be sent the

25 following day.

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65. On December 10, 2011, via text message, defendant FORD

asked defendant RAFAEL URENA for payment in U.S. dollars and told

defendant RAFAEL URENA that she could travel to Italy the

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1 following Monday.


3 conversation, defendant MILTON URENA asked defendant RAFAEL URENA

4 how much he had offered a female drug courier to transport

5 cocaine from the DR to Italy.



8 that he had offered $10,000 in cash to those who agreed to

9 transport cocaine from the DR to Italy.

68. On December 11, 2011, via text message, defendants FORD

11 and RAFAEL URENA made arrangements to meet the following day in

12 order to submit defendant FORD's U.S. passport application.



15 that he would send approximately $300 in cash to pay for

16 defendant FORD's U.S. passport.

17 70. On December 11, 2011, at the direction of defendant

18 MILTON URENA, unindicted co-conspirator A.S. used Western Union

19 to wire unindicted co-conspirator G.U. approximately 13,714.38

20 Dominican pesos (or approximately $359.58 in U.S. currency) from

21 the DR, to Rancho Cucamonga, California, for the benefit of

22 defendant RAFAEL URENA.

23 71. On December 12, 2011, defendant RAFAEL URENA drove

24 defendant FORD to a passport office in Los Angeles, California.

25 72. On December 12, 2011, defendant RAFAEL URENA provided

26 defendant FORD approximately $200 in cash for the purchase of

27 defendant FORD's U.S. passport.


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1 conversation, defendant RAFAEL URENA asked defendant MILTON URENA

:,:2 whether any drug couriers were available to transport drugs that

··3 week .

. 4 74. On December 13, 2011, using coded language during a BBM

5 conversation, defendant RAFAEL URENA advised defendant MILTON

· 6 URENA that defendant FORD would be getting her passport the

7 following day.

8 75. On December 14, 2011, via text message, defendant FORD

9 told defendant RAFAEL URENA that she was picking up her U.S.

10 passport.



13 that they had a large amount of cocaine in the DR to send to ;.

l4 Italy.

15 77. On December 15, 2011, via text message, defendant FORD

16 asked defendant RAFAEL URENA about travel plans.



19 that he would send money after the drug couriers left the DR for

20 Rome, Italy.


22 conversation, defendant AGREDANO told defendant RAFAEL URENA that

23 three drug couriers had just been sent to transport cocaine from

24 the DR to Italy.

25 80. On December 23, 2011, using coded language during a BBM ·.:.. ~ .


27 that two more drug couriers had left the DR for Italy to

28 transport cocaine and that this would be the last drug delivery

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1 until the next year.

2 81. On December 23, 2011, using coded language during a


4 URENA-PARTIDA that they were having difficulty finding a way of

5 bringing drug proceeds from Italy to the DR.

82. On December 23, 2011, using coded language during a


8 RAFAEL URENA that defendants URENA-PARTIDA and MILTON URENA could

9 transport drugs from Mexico to Italy, rather than from the DR to

10 Italy.



13 URENA-PARTIDA that there was a good supply of cocaine in the DR

14 because defendant MILTON URENA and others had been sending

15 cocaine from the DR to Italy twice a week for the past three

16 months.

84. On January 3, 2012, using coded language during a BBM


l9 that he could make more money if defendant RAFAEL URENA sent him

20 female drug couriers more often.

21 85. On January 4, 2012, using coded language during a BBM


23 that an unindicted co-conspirator was working on sending

24 defendant MILTON URENA a female drug courier.



27 that he just needed one more female drug courier.


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2 that defendant VARGAS-OSEGUERA was going to send defendant MILTON

3 URENA a drug courier.


5 conversation, defendant MILTON URENA advised defendant RAFAEL

6 URENA that a drug courier was traveling.to Rome, Italy.

7 89. On January 8, 2012, unindicted co-conspirator M.A.

8 traveled from the DR to Italy.


io conversation, defendant MILTON URENA told defendant RAFAEL URENA

11 that the cocaine was successfully delivered to their Italian

12 customers.

13 91. On January 13, 2012, defendant AGREDANO received an

14 e-mail containing the flight itinerary of unindicted

15 co-conspirator J.N.'s travel from the DR to Italy on January 14,

16 2012.

17 92. On January 14, 2012, unindicted co-conspirator J.N.

18 traveled from the DR to Italy.

19 93. On February 24, 2012, using coded language during a

20 telephone conversation, defendant VARGAS-OSEGUERA told defendant

21 MILTON URENA to send money for the passport of a female drug ~.

22 courier.



25 VARGAS-OSEGUERA that he had two teams of drug couriers scheduled

26 to go to Italy before the female drug courier recruited by

27 defendant VARGAS-OSEGUERA could transport cocaine to Italy.


17


.. 1 telephone conversation, defendants MILTON URENA and .i:

·2 VARGAS-OSEGUERA discussed the travel arrangements and expenses of

3 the female drug courier recruited by defendant VARGAS-OSEGUERA.

4 96. On February 25, 2012, unindicted co-conspirators D.D.

5 and K.P. transported approximately 12 kilograms of cocaine from

6 the DR to Italy.

7 97. On March 25, 2012, unindicted co-conspirator J.N.

8 boarded Blue Panorama Airlines flight BV 1640 from La Romana, DR,

9 to Rome, Italy, transporting approximately 15 kilograms of

10 cocaine.

11 98. On May 8, 2012, unindicted co-conspirator M.A. boarded

12 Blue Panorama Airlines flight BV 1133 from Cancun, Mexico, to

l3 Rome, Italy, transporting approximately 13 kilograms of cocaine.

14 99. On July 9, 2012, using coded language during a BBM

15 conversation, defendant MILTON URENA reminded defendant RAFAEL

16 URENA that "some girls" were arrested with drugs in their

17 possession in Italy.

18 100. On July 9, 2012, using coded language during a BBM


20 that they needed to wait a while before continuing to send drugs

21 to Italy because of the presence of law enforcement.

22

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·.:;,

+· 25

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18


1 COUNT TWO

2 [21 u.s.c. § 846]

3 A. OBJECTS OF THE CONSPIRACY


5 around July 2012, in San Bernardino and Los Angeles Counties,

~- 6 within the Central District of California, and elsewhere,

7 defendants MILTON URENA, also known as ("aka") "Milton

8 Urena-Vargas," aka "Big Brother," aka "El Bacano," aka "El

9 Berraco" ("MILTON URENA"), RAFAEL URENA, aka "Rafa," aka "The

10 Cock," aka "The Mask" ("RAFAEL URENA"), FRANCISCO JAVIER

11 VARGAS-OSEGUERA, aka "Tronco" ("VARGAS-OSEGUERA"), LEONEL

12 URENA-PARTIDA, aka "Tio," aka "Cherokee," aka "Milfeos"

13 ("URENA-PARTIDA"), CARMEN GARCIA, aka "Carmelitai' ("GARCIA"),

14 ELISEO CARRILLO DUARTE, aka "Noel," aka "Pancho," aka "Fernando

15 Cabrera-Gomez," aka "Jesus Isais-Cabrera" ("DUARTE"), and

16 unindicted co-conspirators G.U., K.U., and A.U., and others known ~.

!7 and unknown to the Grand Jury, conspired and agreed with each :•'-

18 other to knowingly and intentionally:

19 1. Distribute at least five kilograms of cocaine, a

20 Schedule II narcotic drug controlled substance, in violation of

21 Title 21, United States Code, Sections 841(a) (1) and

2 2 8 41 (b) ( 1) (A) ( i i) ; and

23 2 . Distribute at least 50 grams of methamphetamine, a

24 Schedule II controlled substance, in violation of Title 21,

25 United States Code, Sections 841(a) (1) and 841(b) (1) (A) (viii).

26 B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE

27 ACCOMPLISHED

.f8 The objects of the conspiracy were to be accomplished in :;

19


. 1 substance as follows:

2 1 . Defendants MILTON URENA, RAFAEL URENA, and

3 VARGAS-OSEGUERA would arrange for the transportation of cocaine

4 and methamphetamine from California to other U.S. locations,

5 including Indiana and New York.

6 2. Defendant VARGAS-OSEGUERA would obtain vehicles with

7 hidden compartments that could be used to transport and conceal

8 cocaine.

3 . Defendants GARCIA and URENA-PARTIDA would supply

10 defendants MILTON URENA, RAFAEL URENA, and VARGAS-OSEGUERA, and

11 others with methamphetamine.

12 4. Defendant URENA-PARTIDA would broker cocaine deals

13 between his customers and defendant RAFAEL URENA and others.

14 5. Defendants VARGAS-OSEGUERA and DUARTE would broker

15 methamphetamine sales between defendants RAFAEL URENA and GARCIA

16 and drug buyers.

17 6. Unindicted co-conspirators G.U., K.U., and A.U. would

18 pick up and deposit drug proceeds on behalf of defendants RAFAEL

19 URENA and VARGAS-OSEGUERA.

c. OVERT ACTS

21 In furtherance of the conspiracy, and to accomplish the

22 objects of the conspiracy, on or about the following dates and

23 times, defendants MILTON URENA, RAFAEL URENA, VARGAS-OSEGUERA,

24 URENA-PARTIDA, GARCIA, DUARTE, and unindicted co-conspirators

25 G.U., K.U., and A.U., and others known and unknown to the Grand

26 Jury, committed various overt acts within the Central District of

27 California, and elsewhere, including but not limited to the

28 following:

20




3 MILTON URENA that an unidentified co-conspirator brought

4 methamphetamine and "cleaned" it.



7 MILTON URENA that an unidentified co-conspirator could distribute

8 two or three pounds of methamphetamine for them.



11 RAFAEL URENA that he needed individuals who could distribute 10

12 or more pounds of methamphetamine.

4. On November 3, 2010, using coded language during a


15 MILTON URENA that he was ready to sell drugs for defendant MILTON

16 URENA.


18 telephone conversation, defendant VARGAS-OSEGUERA instructed

19 defendant MILTON·URENA to wire him money.

20 6 . On November 10, 2010, during a telephone conversation,

21 defendant RAFAEL URENA provided defendant VARGAS-OSEGUERA the

22 number of a wire transfer in the amount of $1,500, which was

23 coming from Santo Domingo, Dominican Republic ("DR").

7. On July 22, 2011, using coded language during a

25 telephone conversation, defendant VARGAS-OSEGUERA asked defendant

26 URENA-PARTIDA to send methamphetamine from Guadalajara, Mexico,

27 to Los Angeles, California, where defendant VARGAS-OSEGUERA would

28 pick it up.

21


1 8 . On August 25, 2011, using coded language during a


3 URENA-PARTIDA that, in Southern California, the price of

4 methamphetamine was approximately $9,000 per pound and the price

" '5 of cocaine was approximately $20,000 per kilogram.


7 telephone conversation, defendant URENA-PARTIDA asked defendant

8 RAFAEL URENA whether a source of supply had cocaine.


10 BlackBerry Messenger ("BBM") conversation, defendants MILTON

11 URENA and RAFAEL URENA discussed supplying up to 100 kilograms of

12 cocaine at one time.

13

14

15

16

17

18

19

11. On October 2, 2011, using coded language during a

telephone conversation, defendant RAFAEL URENA told defendant

URENA-PARTIDA that one kilogram of methamphetamine could be sold

for $18,000 or $19,000~ but that other dealers were selling one

kilogram of methamphetamine for $17,000 because of

"oversaturation" in the Los Angeles, California, area.

12. On October 2, 2011, using coded language during a


21 URENA-PARTIDA that, in the Los Angeles, California, area, there

22 was good-quality methamphetamine for sale, but because there was

23 an abundance of supply, drug dealers who did not sell the

24 methamphetamine at a low price would have it for a long time.



27 URENA-PARTIDA that one kilogram of cocaine would sell for

28 approximately $20,000 to $21,000 in Los Angeles, California.

22




3 RAFAEL URENA that he had a customer who would like to purchase

4 kilogram quantities of cocaine for between approximately $15,000

5 and $25,000 in cash, with nothing on credit.

6 15. On October 13, 2011, using coded language during a BBM

7 conversation, defendants RAFAEL URENA and MILTON URENA agreed

;a that they would charge an additional $1,000 per kilogram of ~

~9 cocaine, regardless of the cost of the cocaine, for

10 transportation costs from California to New York.



13 that they could earn a lot of money transporting cocaine from

14 California to New York.



17 RAFAEL URENA that a customer wanted two pounds of

18 methamphetamine.

19 18. On December 2, 2011, using coded l~nguage during a .


21 VARGAS-OSEGUERA that he would find out if defendant GARCIA could

22 supply two pounds of methamphetamine.



25 VARGAS-OSEGUERA that defendant GARCIA had previously supplied

26 good-quality methamphetamine.



23


;,1 VARGAS-OSEGUERA that the price of methamphetamine was between

• 2 $9,000 and $9,500 per pound.



5 defendant RAFAEL URENA to charge a customer $12,000 for one pound

6 of methamphetamine and to provide defendant VARGAS-OSEGUERA

7 $2,000 as his broker fee.



10 VARGAS-OSEGUERA that defendant GARCIA had one pound of

11 methamphetamine that was ready to be picked up.


i3 telephone conversation, defendant RAFAEL URENA told defendant

14 VARGAS-OSEGUERA that defendant GARCIA set aside one pound of

15 methamphetamine for their upcoming transaction.



18 GARCIA that a customer was coming to meet defendant RAFAEL URENA

19 on December 18, 2011 to purchase one pound of methamphetamine.



22 RAFAEL URENA that the customer would pay $12,000 for one pound of

23 methamphetamine.



26 defendant RAFAEL URENA that from the $12,000 paid by the

27 customer, defendant RAFAEL URENA should keep $10,000 and then

28 deposit the remaining $2,000 into defendant VARGAS-OSEGUERA's

24


1 bank account.


3 telephone conversation, defendant RAFAEL URENA agreed to meet the

::4 customer the morning of December 18, 2011, in Ontario, !:·

,, 5 California, to sell one pound of methamphetamine for $12, 000.

6 28. On December 16, 2011, using coded language in a text

7 message, defendant GARCIA instructed defendant RAFAEL URENA to

8 come to her house the following day to pick up one pound of

9 methamphetamine.



12 defendant RAFAEL URENA to contact him after he sold the one pound

13 of methamphetamine for $12,000, at which time defendant

14 VARGAS-OSEGUERA would provide a bank account number for the

15 deposit of $2,000.

16 30. On December 17, 2011, in San Bernardino, California,

17 defendant RAFAEL URENA picked up one pound of methamphetamine

18 from defendant GARCIA's residence.

19 31. On December 18, 2011, using co~ed language during a BBM


21 that defendant MILTON URENA would send money to pay for a truck

22 with a hidden compartment.



25 that it would cost between $15,000 and $20,000 to purchase a

26 truck with a hidden compartment.

33. On December 18, 2011, using coded language during a

28 telephone conversation, defendant RAFAEL URENA agreed to meet the

25


1 drug customer, who, in fact, was an undercover agent ("the UC"),

2 at a coffee shop in Ontario, California, to deliver the one pound

3 of methamphetamine.

4 34. On December 18, 2011, in Ontario, California, defendant

5 RAFAEL URENA sold approximately one pound of methamphetamine that

6 was 100% pure (that is, approximately 443 grams of

7 methamphetamine) to the UC in exchange for $12,000 in cash.

35. On December 18, 2011, using coded languag.e during a

9 telephone conversation, defendant RAFAEL URENA informed defendant

10 VARGAS-OSEGUERA that he had sold the one pound of methamphetamine

11 for $12,000.

12 36. On December 18, 2011, via text message, defendant

13 RAFAEL URENA received from unindicted co-conspirator A.U.

14 defendant VARGAS-OSEGUERA's JP Morgan Chase bank account number

15 ending in 7350 ("defendant VARGAS-OSEGUERA's Bank Account").


17 telephone conversation, defendant VARGAS-OSEGUERA asked defendant

18 RAFAEL URENA whether he had received the bank account number for

19 defendant VARGAS-OSEGUERA's Bank Account.


21 telephone conversation, defendant.VARGAS-OSEGUERA told defendant

22 RAFAEL URENA to give the bank account number for defendant

23 VARGAS-OSEGUERA's Bank Account to unindicted co-conspirator G.U.,

24 who would make the deposit.


26 defendant RAFAEL URENA told unindicted co-conspirator G.U. to

27 pick up $2,000 from defendant RAFAEL URENA's house and deposit

28 the money into a Chase bank account and that defendant RAFAEL

26


1 URENA would provide the account number at a later time.


3 RAFAEL URENA provided unindicted co-conspirator G.U. with

4 defendant VARGAS-OSEGUERA's bank account number.


6 defendant GARCIA asked defendant RAFAEL URENA whether he was

7 going to call defendant VARGAS-OSEGUERA and ask him to give $300

8 to defendant GARCIA.

9 42. On December 18, 2011, during a telepho~e conversation,

10 defendant RAFAEL URENA told defendant GARCIA that he had already

11 told unindicted co-conspirator G.U. to give $300 to defendant . 12 GARCIA.


14 RAFAEL URENA told unindicted co-conspirator G.U. that unindicted

15 co-conspirator G.U. could give $300 to defendant GARCIA.

16 44. On December 19, 2011, unindicted co-conspirator G.U.

17 deposited.$1,700 in cash into defendant VARGAS-OSEGUERA's

18 Bank Account.


20 RAFAEL URENA told defendant VARGAS-OSEGUERA that a deposit had

21 been made for $1,700.


23 RAFAEL URENA told unindicted co-conspirator A.U. that cash was 1 .

24 deposited into defendant VARGAS-OSEGUERA's Bank Account.

25 47. On December 19, 2011, defendant VARGAS-OSEGUERA

26 withdrew $1,000 in cash from defendant VARGAS-OSEGUERA's Bank

27 Account.

28 48. On December 24, 2011, defendant VARGAS-OSEGUERA

27


1 withdrew $1,000 in cash from defendant VARGAS-OSEGUERA's Bank

2 Account.

3 49. On January 3, 2012, using coded language during a -,.

~4, telephone conversation, defendant VARGAS-OSEGUERA told defendant

5 RAFAEL URENA to talk to defendant MILTON URENA about obtaining a

6 truck with a hidden compartment that they could use to transport

7 cocaine from California to New York.



10 .that defendant MILTON URENA and others in the DR were preparing

11 to transport cocaine from California to New York.



14 that money earned from the next sale of cocaine in Italy would be

15 used to pay the start-up costs of transporting cocaine from

16 California to New York.

17 52. On January 9, 2012, using coded language during a


19 RAFAEL URENA that he had found a truck trailer they could use to

20 transport cocaine from California to New York and also to

21 transport money back to Los Angeles, California.



24 that he wanted to send 30 kilograms of cocaine from California to

25 New York.



28 that they needed a hidden compartment that held at least 10

28


1 kilograms of cocaine at one time.



4 that $19,000 was the lowest amount that a kilogram of cocaine

5 could be purchased for in Los Angeles, California.


'/7 conversation, defendant MILTON URENA asked defendant RAFAEL URENA ''·

8 what kind of vehicle defendants RAFAEL URENA and VARGAS-OSEGUERA

9 needed in order to transport cocaine from Southern California to

10 New York.


12 telephone conversation, defendants RAFAEL URENA and

13 VARGAS-OSEGUERA discussed the types of vehicles they needed to

14 transport cocaine from Southern California to New York.



17 GARCIA that he and defendant VARGAS-OSEGUERA wanted five pounds

18 of methamphetamine. ·: ... · -·~

19 59. On January 28, 2012, defendant VARGAS-OSEGUERA obtained

20 a vehicle containing a hidden compartment in which to transport

21 drugs and money.



24 that defendant VARGAS-OSEGUERA had obtained a vehicle with a

25 hidden compartment that could hold up to 10 kilograms of cocaine.



28 VARGAS-OSEGUERA that defendant GARCIA had agreed to supply five

29


1 pounds of methamphetamine.

2 62. On June 15, 2012, using coded language in a text

3 message, defendant RAFAEL URENA told an unindicted . 4 co-conspirator that he would accept $11,000 for one pound of

5 methamphetamine.

6 63. On June 15, 2012, using coded language in a text

7 message, defendant RAFAEL URENA told an unindicted

8 co-conspirator that defendant VARGAS-OSEGUERA had told him that

9 an unindicted co-conspirator was going to give defendant RAFAEL

10 URENA some cash.

11 64. On June 16, 2012, using coded language in a BBM

12 conversation, defendant RAFAEL URENA provided defendant DUARTE

13 with his name, address, and driver's license number so that

14 defendant DUARTE could rent a car in preparation for their trip

15 to Indiana to inspect the quality of methamphetamine they had

16 previously sent there.

17 65. On June 17, 2012, defendants RAFAEL URENA and

18 VARGAS-OSEGUERA, and other unidentified co-conspirators, drove

19 together from California to Indiana to inspect the quality of

20 methamphetamine previously sent there.

21 66. On June 17, 2012, using coded language during a


23 VARGAS-OSEGUERA that defendant RAFAEL URENA had purchased one

24 kilogram of methamphetamine for $19,000.



27 VARGAS-OSEGUERA to sell one kilogram of methamphetamine for

28 $20,000 in order to make a profit of $1,000.

30




;,3 VARGAS-OSEGUERA that certain customers should return the

4 methamphetamine previously sent to Indiana because defendant

5 RAFAEL URENA had found another buyer who would purchase the

6 methamphetamine for $13,000 per pound.

7 69. On June 29, 2012, during a telephone conversation,

8 defendant RAFAEL URENA asked for unindicted co-conspirator K.U.'s

9 bank account number.


11 defendant RAFAEL URENA told defendant VARGAS-OSEGUERA that he had

12 sent unindicted co-conspirator K.U.'s bank account number to an

13 unidentified co-conspirator.

14 71. On June 29, 2012, during a telephone conversation, ~· ·.

is defendant VARGAS-OSEGUERA gave his bank account number to

16 defendant RAFAEL URENA and told defendant RAFAEL URENA to send

17 the bank account information to an unidentified co-conspirator

18 "right now" because the unidentified co-conspirator would

19 "probably deposit it fast" and "right away."

20 72. On June 29, 2012, at 11:18 a.m., in Indianapolis,

21 Indiana, an unidentified co-conspirator deposited $2,000 in cash

22 into defendant VARGAS-OSEGUERA's Bank Account.



25 into defendant VARGAS-OSEGUERA's Bank Account.



28 into unindicted co-conspirator K.U.'s JP Morgan Chase bank

31


1 account number ending 9419 ("K.U.'s Bank Account").



4 VARGAS-OSEGUERA that half of the cash was deposited into

5 defendant VARGAS-OSEGUERA's Bank Account.

6 76. On June 29, 2012, at 11:53 a.m., in Fontana,

::7 California, defendant VARGAS-OSEGUERA withdrew $4,000 in cash

8 from defendant VARGAS-OSEGUERA's Bank Account.


10 defendant VARGAS-OSEGUERA told defendant RAFAEL URENA that he has

11 the "withdrawal."

12 78. On June 29, 2012, at 12:12'p.m., in Indianapolis,


14 into K.U.'s Bank Account.

15 79. On June 29, 2012, in Rancho Cucamonga, California,

16 defendant RAFAEL URENA went with unindicted co-conspirator K.U.

17 to a JP Morgan Chase branch.

;1.8 80. On June 29, 2012, at 12:52 p.m., in Rancho Cucamonga,

19 California, unindicted co-conspirator K.U. withdrew $4,500 in

20 cash from K.U. 1 s Bank Account.


22 telephone conversation, defendant DUARTE told defendant RAFAEL

23 URENA that defendant DUARTE was at the stash house where drugs

24 are stored.



27 URENA that they had been given a deadline to provide payment to

28 the drug sources in California who had supplied the

32


1 methamphetamine sent to Indiana and that had been ruined by the

2 addition of too much cutting agent.

3 83. On 0uly 2, 2012, in Rancho Cucamonga, California,

4 unindicted co-conspirator A.U. withdrew $3,500 in cash from

5 defendant VARGAS~OSEGUERA's Bank Account.

6 84. On July 9, 2012, in Fontana, California, defendant

7 VARGAS-OSEGUERA withdrew $2,000 in cash from defendant

8 VARGAS-OSEGUERA's Bank Account.

9 85. On July 9, 2012, using coded language during a

to telephone conversation, defendant RAFAEL URENA told defendant

11 DUARTE that defendant RAFAEL URENA had provided a vehicle worth

12 $10,000 to $15,000 to the drug sources in California for the

13 methamphetamine that had been sent to Indiana and that could not

14 be sold.

15 86. On July 9, 2012, during a telephone conversation, an

16 unidentified co-conspirator told defendant RAFAEL URENA that a

17 customer had asked whether defendants RAFAEL URENA and

18 VARGAS-OSEGUERA, and an unidentified co-conspirator, were selling

19 "crack" cocaine.


21 telephone conversation, defendant RAFAEL URENA told an ·:f

22 unidentified co-conspirator to tell the buyer that

23 methamphetamine was better than "crack."


25 telephone conversation, defendants RAFAEL URENA and DUARTE

26 discussed selling drugs in order to get money to pay off their

27 drug debt.


33



2 DUARTE that he had three units of drugs for sale.

90. On July 11, 2012, using coded language during a


5 URENA that he was going to meet a drug customer.

6 91. On July 11, 2012, defendants RAFAEL URENA and

7 VARGAS-OSEGUERA drove to Modesto, California, to pick up

8 methamphetamine for further distribution.

9 92. On July 12, 2012, defendants RAFAEL URENA and

10 VARGAS-OSEGUERA stored methamphetamine at defendant RAFAEL

11 URENA's residence.


13 telephone conversation, defendant DUARTE instructed defendant

14 RAFAEL URENA to have defendant VARGAS-OSEGUERA prepare samples of r; ...

is drugs for defendant DUARTE's customer.



18 RAFAEL URENA that he had removed some of the methamphetamine from

19 defendant RAFAEL URENA's residence.

20 95. On July 12, 2012, defendant VARGAS-OSEGUERA transported

21 methamphetamine from defendant RAFAEL URENA's residence to

22 defendant DUARTE's stash house.

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25 ·-~-

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1 COUNT THREE

2 [21 u.s.c. §§ 841(a) (1), (b) (1) (A) (viii); 18 u.s.c. § 2(a)]

3 On or about December 18, 2011, in San Bernardino County,

4 within the Central District of California, defendant RAFAEL

5 URENA, also known as ("aka") "Rafa," aka "The Cock," aka "The

6 Mask," knowingly and intentionally distributed at least 50 grams,

7 that is, approximately 443 grams, of methamphetamine, a Schedule

8 II controlled substance.

9 on or about the above time and place, defendants FRANCISCO

10 JAVIER VARGAS-OSEGUERA, aka "Tronco," and CARMEN GARCIA, aka

11 "Carmelita," intentionally aided, abetted, counseled, commanded,

12 induced, and procured the commission of the offense alleged

13 above.

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17 ~~.

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1 COUNT FOUR

. 2 [21 u.s.c. § 843 (b)]

3 On or about August 28, 2011, in Los Angeles County, within

4 the Central District of California, and elsewhere, defendant

5 LEONEL URENA-PARTIDA, also known as ("aka") "Tio," aka

6 "Cherokee," aka "Milfeos," knowingly and intentionally used a

7 communication facility, that is, a telephone, in committing,

8 causing, and facilitating the commission of an act constituting a

9 felony under Title 21, United States Code, Section 846, namely,

10 conspiracy to distribute controlled substances, as alleged in

11 Count Two of this Indictment.

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1 COUNT FIVE

:,2 [21 u.s.c. § 843 (b)]

3 On or about October 2, 2011, in Los Angeles County, within

4 the Central District of California, and elsewhere, defendant

5 LEONEL URENA-PARTIDA, also known as ("aka") "Tio," aka

6 "Cherokee," aka "Milfeos," knowingly and intentionally used a

7 communication facility, that is, a telephone, in committing,

8 causing, and facilitating the commission of an act constituting a

9 felony under Title 21, United States Code, Section 846, namely,

10 conspiracy to distribute controlled substances, as alleged in

11 Count Two of this Indictment.

12

l3

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1 COUNT SIX

2 [21 u.s.c. § 843 (b)]

3 On or about December 10, 2011, in Los Angeles County, within

4 the Central District of California, defendant BETH RENE FORD, \

·5 also known as ("aka") "Beth Rene Upton," aka "Beth Rene ' :.1. •· 6 Florance," knowingly and intentionally used a communication

7 facility, that is, a telephone,· in committing, causing/ and

8 facilitating the commission of an act constituting a felony under

9 Title 21, United States Code, Section 846, namely, conspiracy to

10 distribute controlled substances, as alleged in Count One of this

11 Indictment.

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1 COUNT SEVEN

2 [18 u.s. c. § 1956 (h)]

3 A. OBJECTS OF THE CONSPIRACY


5 around July 2012, in Los Angeles County, within the Central

6 District of California, and elsewhere, defendants MILTON URENA,

7 also known as ("aka") "Milton Urena-Vargas," aka "Big Brother,"

.. 8 aka "El Bacano," aka "El Berraco" ("MILTON URENA") , RAFAEL URENA,

·9 aka "Rafa," aka "The Cock," aka "The Mask" ("RAFAEL URENA"),

10 DANIEL ALEJANDRO AGREDANO VAZQUEZ, aka "Pablito," aka "Pablin,"

11 aka "Pablo" ("AGREDANO"), and FRANCISCO JAVIER VARGAS-OSEGUERA,

12 aka "Tronco" ("VARGAS-OSEGUERA"), and unindicted co-conspirators

13 G.U. and A.U., and others known and unknown to the Grand Jury,

14 conspired and agreed with each other to knowingly and

15 intentionally commit the following offenses against the United

16 States:

17 (1) Knowing that property involved in a financial

18 transaction represented the proceeds of some form of unlawful

19 activity, and which property was, in fact, the proceeds of a

QO specified unlawful activity, that is, conspiracy to distribute

21 controlled substances in violation of Title 21, United States

22 Code, Section 846, conducted and attempted to conduct financial

23 transactions with the intent to promote the carrying on of said

24 specified unlawful activity, in violation of Title 18, United

25 States Code, Section 1956(a) (1) (A) (i); and

26 (2) Transported, transmitted, and transferred, and

27 attempted to transport, transmit, and transfer, monetary

28 instruments and funds to a place in the United States, that is,

39


1 California 1 from a place outside the United States/ that is/ the

2 Dominican Republic 1 with the intent to promote the carrying on of

3 specified unlawful activity/ namely 1 conspiracy to distribute

4 controlled substances in violation of Title 21 1 United States

5 Code 1 Section 846 1 all in violation of Title 18 1 United States

6 Code 1 Section 1956 (a) ( 2) (A) .

7 C. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE

8 ACCOMPLISHED

9. The objects of the conspiracy were to be accomplished in

10 substance as follows:

11 1. Defendant MILTON URENA would direct defendant AGREDANO

12 to send drug proceeds to defendant RAFAEL URENA after cocaine was

13 transported to Italy to pay for the passports of drug couriers.

14 2. Defendant RAFAEL URENA would sell methamphetamine in

15 Los Angeles 1 California 1 and provide defendant VARGAS-OSEGUERA a

16 broker 1 s fee.

17 3. Defendant RAFAEL URENA would direct unindicted

18 co-conspirator G.U. to deposit defendant VARGAS-OSEGUERA 1 S broker

19 fee in defendant VARGAS-OSEGUERA 1 S JP Morgan Chase bank account

20 number ending 7350 1 and to also pick up drug proceeds sent by

21 defendant AGREDANO for the benefit of defendant RAFAEL URENA.

22 4. Defendant VARGAS-OSEGUERA would direct unindicted

23 co-conspirator A.U. to provide defendant VARGAS-OSEGUERA 1 S

24 JP Morgan Chase bank account number ending in 7350 to defendant

25 RAFAEL URENA.

26 D. OVERT ACTS

27 In furtherance of the conspiracy/ and to accomplish the

28 objects of the conspiracy/ on or about the following dates 1

40


1 defendants MILTON URENA, RAFAEL URENA, AGREDANO, and

2 VARGAS-OSEGUERA, and unindicted co-conspirators G.U. and A.U.,

3 and others known and unknown to the Grand Jury, committed various

4 overt acts within the Central District of California, and

5 elsewhere, including but not limited to the following:

6 1-195. The allegations contained in Section C of Counts

7 One and Two of this Indictment are re-alleged in this Count and

8 are incorporated by reference as if fully set forth herein.

9 A TRUE BILL

10

11 /.S/ Foreperson

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i9

20

ANDRE BIROTTE JR. Uni ed States Attorney

'Z. J R ERT E. DUGDALE Assistant United States Attorney Chief, Criminal Division

RODRIGO A. CASTRO-SILVA Assistant United States Attorney Chief, Organized Crime Drug

Enforcement Task Force Section

ROB B. VILLEZA 21 Assistant United States Attorney

Deputy Chief, Organized Crime Drug 22 Enforcement Task Force Section

23 CHRISTINE S. BAUTISTA Assistant United States Attorney

24 Organized Crime Drug Enforcement Task Force Section

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Operation Family Guy Indictment

Documents

Transcript of Operation Family Guy Indictment