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2CIHAR-5 PH 1:52
SUPERSEDING
INDICTMEN
SA-13CR-400
Plaintiff,
V.
[Vio: 21 USC
84
(1) &
841 (b)( 1 )(A)(viii): Possession with
Intent to Distribute a Controlled
Substance; 18 USC 2: Aiding &
Abetting; 21 USC
846 &
841(a)(1) & 841(b)(1)(A)(viii):
Conspiracy to Possess with Intent to
Distribute a Controlled Substance; 18
USC 924(c)(1)(A)(i): Possession of
Firearm in Furtherance of a Drug
Trafficking Crime; 18 USC sS
922(g)(5) & 924(a)(2): Illegal Alien in
Possession of a Firearm]
[21 USC
COUNT ONE
841(a)(1) & 841(b)(1)(A)(viii); and 18 USC
2]
That on or about APRIL 18, 2013, in the Western District of Texas, Defendants,
(21 U.S.C.
COUNT TWO
846 & 841(a)(1) & 841(b)(1)(A)(viii))
1,
knowingly, intentionally, and unlawfully conspired, combined, confederated, and agreed with
others to the Grand Jury known and unknown, to commit offenses against the United States, in
violation of Title 21, United States Code, Section 846, that is to say, they conspired to possess a
controlled substance, which offense involved 50 grams or more of methamphetamine actual, a
Schedule II Controlled Substance, with intent to distribute same, contrary to Title 21, United
States Code, Sections 846; 841(a)(1) and 841(b)(1)(A)(viii).
COUNT THREE
[18 USC 924(c)(1)(A)(i)]
That on or about APRIL 18, 2013, in the Western District of Texas, Defendant,
controlled substance, charged in Count One, above, and incorporated herein by reference, did
knowingly possess a firearm, specifically: a Rossi/Interarms, .357 magnum caliber revolver,
serial number F404016; in violation of Title 18, United States Code, Section 924(c)(1)(A)(i).
COUNT FOUR
[18 USC 922(g)(5) & 924(a)(2)]
That on or about APRIL 18, 2013, in the Western District of Texas, Defendant,
caliber revolver, serial number F404016; such firearm having been shipped and transported in
interstate commerce, all in violation of Title 18, United States Code, Sections 922(g)(5) and
924(a)(2).
ROBERT PITMAN
United States Attorney
RUSSELL D. LEACHMAN
Assistant United States Attorney