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Case 1:12-cr-00243-CMA Document 1 Filed 05/23/12 USDC Colorado Page 1 of 71

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 12-cr-00243-CMA UNITED STATES OF AMERICA, Plaintiff, v. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. ARMANDO MENDOZA-HARO, a/k/a Armando Mendoza Green Eyes Carlos JESUS SEGOVIA, a/k/a Carlos Botitas MIGUEL ANGEL SANCHEZ, a/k/a Miguel Sanchez SERGIO MENDOZA-VALDOVINOS, a/k/a Sergio Mendoza DANIELA MUNGUIA DE ORTIZ, a/k/a Daniela Munguia-Torres Guachita Aurora Casas YULY HERNANDEZ-OROZCO, a/k/a Yuly Yuly Lorena Hernandez-Orozco ERIKA ELENA HERNANDEZ-GALAVIZ, a/k/a Erika Erika Hernandez Erika Quintana ALEJANDRO MORALES-GARCIA, a/k/a Alex RICARDO PANIAGUA-RODRIGUEZ, a/k/a Ricardo Paniagua CARLOS MARTIN SEGURA CHANG, a/k/a Carlos M. Chang Carlos Segura Chang SONIA PEREZ, Defendants.

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______________________________________________________________________________ INDICTMENT 21 U.S.C. 846 21 U.S.C. 841(a)(1), 841(b)(1)(A)(viii) 21 U.S.C. 843(b) 18 U.S.C. 2

18 U.S.C. 1956(a)(1)(A)(i), 1956(a)(1)(B)(i), 1956(a)(1)(B)(ii), 1956(a)(2)(A), 1956(a)(2)(B)(i), and 1956(h)


______________________________________________________________________________ THE GRAND JURY CHARGES: COUNT ONE From on or about December 2010, through on or about May 23, 2012, both dates being approximate and inclusive, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, MIGUEL ANGEL SANCHEZ, SERGIO MENDOZA-VALDOVINOS, DANIELA MUNGUIA DE ORTIZ, YULY HERNANDEZ-OROZCO, ERIKA ELENA HERNANDEZ-GALAVIZ, ALEJANDRO MORALES-GARCIA, did knowingly and intentionally conspire with each other and with others known and unknown to the Grand Jury, to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. All in violation of Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii). 2

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COUNT TWO
On or about July 13, 2011, through on or about May 23, 2012, both dates being approximate and inclusive, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, MIGUEL ANGEL SANCHEZ, SERGIO MENDOZA-VALDOVINOS, DANIELA MUNGUIA DE ORTIZ, YULY HERNANDEZ-OROZCO, ALEJANDRO MORALES-GARCIA, RICARDO PANIAGUA-RODRIGUEZ, CARLOS MARTIN SEGURA CHANG, SONIA PEREZ, did combine, conspire, confederate and agree with each other and with other persons, both known and unknown to the Grand Jury, to commit offenses against the United States in violation of Title 18, United States Code, section 1956, to wit: (a) did knowingly conduct and attempt to conduct financial transactions affecting interstate commerce, which involved the proceeds of a specified unlawful activity, that is the transfer, transportation, and delivery of currency, as well as additional financial transactions in the form of the deposit and subsequent withdrawal of currency into and from accounts at financial institutions, electronic transfers between bank accounts, and domestic and international wire transfers initiated from bank accounts with the intent to promote the carrying on of specified unlawful activity and that while conducting and attempting to conduct such financial transactions knew the property involved in the 3

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financial transaction represented the proceeds of some form of unlawful activity in violation of Title 18, United States Code, Section 1956 (a)(1)(A)(i); (b) did knowingly conduct and attempt to conduct financial transactions affecting interstate commerce, to wit; the deposit and subsequent withdrawal of currency into and from accounts at financial institutions, electronic transfers between bank accounts, and domestic and international wire transfers initiated from bank accounts, which transactions involved the proceeds of a specified unlawful activity, knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of specified unlawful activity, and that while conducting such financial transactions, knew that the property involved in the financial transactions represented the proceeds of some form of unlawful activity, in violation of Title 18, United States Code, Section 1956 (a)(1)(B)(i); (c) did knowingly conduct and attempt to conduct financial transactions affecting interstate commerce, to wit; the deposit of currency into accounts at financial institutions, which transactions involved the proceeds of a specified unlawful activity, knowing that the transactions were designed in whole or in part to avoid a transaction reporting requirement under Federal law, and that while conducting such financial transactions knew that the property involved in the financial transactions, represented the proceeds of some form of unlawful activity, in violation of Title 18, United States Code, Section 1956 (a)(1)(B)(ii); (d) did transport, transmit, or transfer, or attempt to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place 4

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outside the United States with the intent to promote the carrying on of specified unlawful activity in violation of Title 18, United States Code, Section 1956 (a)(2)(A); (e) did transport, transmit, or transfer, or attempt to transport, transmit, or transfer a monetary instrument or funds from a place in the United States to or through a place outside the United States knowing the monetary instrument or funds involved in the transportation, transmission, or transfer represent the proceeds of some form of unlawful activity and knowing that such transportation, transmission, or transfer is designed in whole or in part to conceal and disguise the nature, the location, the source, the ownership or the control of the proceeds of specified unlawful activity in violation of Title 18, United States Code, Section 1956 (a)(2)(B)(i); All in violation of Title 18, United States Code, Section 1956(h). COUNT THREE

On or about December 24, 2010, within the State and District of Colorado, the defendant, ARMANDO MENDOZA-HARO did knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii) and Title 18, United States Code, Section 2.

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COUNT FOUR On or about July 8, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and DANIELA MUNGUIA DE ORTIZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT FIVE On or about July 13, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT SIX On or about July 14, 2011, within the State and District of Colorado, the defendants, 6

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ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT SEVEN On or about August 29, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT EIGHT On or about September 2, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to 7

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distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT NINE On or about October 19, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and DANIELA MUNGUIA DE ORTIZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT TEN On or about October 25, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and MIGUEL ANGEL SANCHEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable

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amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT ELEVEN On or about October 25, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and DANIELA MUNGUIA DE ORTIZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT TWELVE On or about October 29, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). 9

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COUNT THIRTEEN On or about November 15, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and ERIKA ELENA HERNANDEZ-GALAVIZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT FOURTEEN On or about November 17, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and ERIKA ELENA HERNANDEZ-GALAVIZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT FIFTEEN On or about December 7, 2011, within the State and District of Colorado, the defendants, MIGUEL ANGEL SANCHEZ and SERGIO MENDOZA-VALDOVINOS, did knowingly and 10

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intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT SIXTEEN On or about December 13, 2011, within the State and District of Colorado, the defendants, MIGUEL ANGEL SANCHEZ and SERGIO MENDOZA-VALDOVINOS, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT SEVENTEEN On or about January 14, 2012, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and MIGUEL ANGEL SANCHEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II 11

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controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT EIGHTEEN On or about January 16, 2012, within the State and District of Colorado, the defendants, JESUS SEGOVIA and MIGUEL ANGEL SANCHEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT NINETEEN On or about March 24, 2012, within the State and District of Colorado, the defendants, ALEJANDRO MORALES-GARCIA and ARMANDO MENDOZA-HARO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b).

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COUNT TWENTY On or about March 23, 2012, within the State and District of Colorado, the defendants, ALEJANDRO MORALES-GARCIA and ARMANDO MENDOZA-HARO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT TWENTY-ONE On or about July 13, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO and YULY HERNANDEZ-OROZCO, did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit: the transfer and delivery of currency, which involved the proceeds of a specified unlawful activity, that is distribution and possession with the intent to distribute a controlled substance with the intent to promote the carrying on of the specified unlawful activity, to wit: distribution and possession with the intent to distribute a controlled substance and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity. All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i).

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COUNT TWENTY-TWO On or about September 21, 2011, within the State and District of Colorado, the defendants, ARMANDO MENDOZA-HARO, SERGIO MENDOZA-VALDOVINOS, and MIGUEL SANCHEZ, did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foreign commerce, to wit: the transfer and delivery of currency, which involved the proceeds of a specified unlawful activity, that is distribution and possession with the intent to distribute a controlled substance with the intent to promote the carrying on of the specified unlawful activity, to wit: distribution and possession with the intent to distribute a controlled substance and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity. All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i). COUNT TWENTY-THREE On or about January 17, 2012, within the State and District of Colorado, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and MIGUEL SANCHEZ; did knowingly conduct and attempt to conduct a financial transaction, to wit: the transfer and delivery of currency, which involved the proceeds of a specified unlawful activity, that is distribution and possession with the intent to distribute a controlled substance with the intent to promote the carrying on of the specified unlawful activity, to wit: distribution and possession with the intent to distribute a controlled substance and that while conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity. All in violation of Title 18, United States Code, Section 1956(a)(1)(A)(i). 14

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COUNT TWENTY-FOUR On or about August 30, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT TWENTY-FIVE On or about August 30, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.

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COUNT TWENTY-SIX On or about August 30, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the

nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT TWENTY-SEVEN On or about August 30, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and JESUS SEGOVIA, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.

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COUNT TWENTY-EIGHT On or about August 30, 2011, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT TWENTY-NINE On or about October 11, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT THIRTY On or about October 11, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT THIRTY-ONE On or about October 11, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 18

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COUNT THIRTY-TWO On or about October 11, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT THIRTY-THREE On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 19

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COUNT THIRTY-FOUR On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT THIRTY-FIVE On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT THIRTY-SIX On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT THIRTY-SEVEN On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 21

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COUNT THIRTY-EIGHT On or about October 12, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT THIRTY-NINE On or about October 13, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

22

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COUNT FORTY On or about October 13, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT FORTY-ONE On or about October 13, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 23

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COUNT FORTY-TWO On or about October 13, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT FORTY-THREE On or about October 13, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT FORTY-FOUR On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to 24

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conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT FORTY-FIVE On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT FORTY-SIX On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of 25

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unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT FORTY-SEVEN On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of a specified unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(A). COUNT FORTY-EIGHT On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States knowing that the monetary instrument and funds involved in the transportation, transmission, and transfer represented the proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is designed to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i).

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COUNT FORTY-NINE On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of a specified unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(A). COUNT FIFTY On or about October 14, 2011, within the State and District of Colorado and elsewhere, the defendant; RICARDO PANIAGUA-RODRIGUEZ; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States knowing that the monetary instrument and funds involved in the transportation, transmission, and transfer represented the proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is designed to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i). COUNT FIFTY-ONE On or about October 20, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and DANIELA MUNGIA DE ORTIZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction 27

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represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT FIFTY-TWO On or about October 21, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and DANIELA MUNGIA DE ORTIZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT FIFTY-THREE On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants 28

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knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT FIFTY-FOUR On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT FIFTY-FIVE On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction 29

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represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT FIFTY-SIX On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT FIFTY-SEVEN On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and 30

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attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT FIFTY-EIGHT On or about November 4, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT FIFTY-NINE On or about November 7, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to 31

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conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SIXTY On or about November 7, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SIXTY-ONE On or about November 7, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the 32

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unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SIXTY-TWO On or about November 7, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SIXTY-THREE On or about November 8, 2011, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and RICARDO PANIAGUA-RODRIGUEZ; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the

33

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unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SIXTY-FOUR On or about November 28, 2011, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SIXTY-FIVE On or about December 1, 2011, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. 34

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All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SIXTY-SIX On or about January 19, 2012, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SIXTY-SEVEN On or about January 19, 2012, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SIXTY-EIGHT On or about January 20, 2012, within the State and District of Colorado and elsewhere, 35

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the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SIXTY-NINE On or about January 20, 2012, within the State and District of Colorado and elsewhere, the defendant; ARMANDO MENDOZA-HARO; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT SEVENTY On or about March 20, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants 36

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knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SEVENTY-ONE On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SEVENTY-TWO On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and 37

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attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SEVENTY-THREE On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SEVENTY-FOUR On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful 38

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activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SEVENTY-FIVE On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SEVENTY-SIX On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful 39

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activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SEVENTY-SEVEN On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT SEVENTY-EIGHT On or about March 22, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants 40

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knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT SEVENTY-NINE On or about March 23, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT EIGHTY On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was 41

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designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT EIGHTY-ONE On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT EIGHTY-TWO On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was 42

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designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT EIGHTY-THREE On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT EIGHTY-FOUR On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was 43

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designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT EIGHTY-FIVE On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT EIGHTY-SIX On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was 44

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designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT EIGHTY-SEVEN On or about March 24, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT EIGHTY-EIGHT On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to 45

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conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT EIGHTY-NINE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT NINETY On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or 46

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control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT NINETY-ONE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, SONIA PEREZ, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT NINETY-TWO On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was 47

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designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT NINETY-THREE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT NINETY-FOUR On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to 48

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conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT NINETY-FIVE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT NINETY-SIX On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the 49

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unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT NINETY-SEVEN On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT NINETY-EIGHT On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the 50

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unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT NINETY-NINE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the 51

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unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED ONE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED TWO On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. 52

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All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED THREE On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of a specified unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(A). COUNT ONE HUNDRED FOUR On or about March 26, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States knowing that the monetary instrument and funds involved in the transportation, transmission, and transfer represented the proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is designed to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i). COUNT ONE HUNDRED FIVE On or about March 27, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the 53

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financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED SIX On or about March 27, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED SEVEN On or about March 27, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of a specified unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(A).

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COUNT ONE HUNDRED EIGHT On or about March 27, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States knowing that the monetary instrument and funds involved in the transportation, transmission, and transfer represented the proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is designed to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i). COUNT ONE HUNDRED NINE On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, ALEJANDRO MORALES-GARCIA, and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT ONE HUNDRED TEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO, ALEJANDRO MORALES-GARCIA, and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED ELEVEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. 56

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COUNT ONE HUNDRED TWELVE On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED THIRTEEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT ONE HUNDRED FOURTEEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED FIFTEEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT ONE HUNDRED SIXTEEN On or about March 28, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED SEVENTEEN On or about March 29, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED EIGHTEEN On or about March 29, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, 59

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and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States with the intent to promote the carrying on of a specified unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(A). COUNT ONE HUNDRED NINETEEN On or about March 29, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly transport, transmit, transfer, and attempt to transport, transmit, transfer a monetary instrument and funds from a place in the United States to a place outside the United States knowing that the monetary instrument and funds involved in the transportation, transmission, and transfer represented the proceeds of an unlawful activity and knowing such transportation, transmission, and transfer is designed to conceal and disguise the nature, the location, the source, the ownership and the control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(2)(B)(i). COUNT ONE HUNDRED TWENTY On or about March 30, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction

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knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED TWENTY-ONE On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED TWENTY-TWO On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is

61

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designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED TWENTY-THREE On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED TWENTY-FOUR On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is

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designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED TWENTY-FIVE On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED TWENTY-SIX On or about March 31, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is

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designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. COUNT ONE HUNDRED TWENTY-SEVEN On or about April 3, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED TWENTY-EIGHT On or about April 3, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). 64

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COUNT ONE HUNDRED TWENTY-NINE On or about April 4, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED THIRTY On or about April 4, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.

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COUNT ONE HUNDRED THIRTY-ONE On or about April 4, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2. COUNT ONE HUNDRED THIRTY-TWO On or about April 4, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2.

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COUNT ONE HUNDRED THIRTY-THREE On or about April 4, 2012, within the State and District of Colorado and elsewhere, the defendant; CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendant knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendant conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i). COUNT ONE HUNDRED THIRTY-FOUR On or about April 5, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG; did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and the defendants conducted and attempted to conduct the financial transaction knowing that it was designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of the unlawful activity and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2.

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COUNT ONE HUNDRED THIRTY-FIVE On or about April 5, 2012, within the State and District of Colorado and elsewhere, the defendants; ARMANDO MENDOZA-HARO and CARLOS MARTIN SEGURA CHANG, did knowingly conduct and attempt to conduct a financial transaction, the financial transaction and attempted transaction involved the proceeds of a specified unlawful activity, the defendants knew that the property involved in the financial transaction and attempted transaction represented the proceeds of some form of unlawful activity, and knowing that the transaction is designed to avoid a transaction reporting requirement under State or Federal Law and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2. FORFEITURE ALLEGATION The allegations contained in Counts One and Counts Three through Twenty of this Indictment are hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to the provisions of 21 U.S.C. 853. Upon conviction of the violations alleged in Counts One and three through Twenty of this Indictment involving violations of 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A)(viii) and 21 U.S.C. 843(b), the defendants; ARMANDO MENDOZA-HARO, JESUS SEGOVIA, MIGUEL ANGEL SANCHEZ, SERGIO MENDOZA-VALDOVINOS, DANIELA MUNGUIA DE ORTIZ, YULY HERNANDEZ-OROZCO, ERIKA ELENA HERNANDEZ-GALAVIZ, and ALEJANDRO MORALES-GARCIA, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853 any and all of the defendants right, title and interest in all property constituting and derived from any proceeds obtained directly and indirectly as a result of such offense, and in all property used, or intended to be used, in any manner or part, to 68

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commit, or to facilitate the commission of such offense, including, but not limited to a money judgment in the amount of proceeds obtained by the conspiracy and by the defendants. If any of the property as a result of any act or omission of the defendants: a) b) c) d) e) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said defendants up to the value of the forfeitable property. The allegations contained in Counts Two and Counts Twenty-one through One Hundred Thirty-five of this Indictment are hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to the provisions of 21 U.S.C. 853. Upon conviction of the violations alleged in Counts Two and Counts Twenty-one through One Hundred Thirty-five of this Indictment involving violations 18 U.S.C. 1956(a)(1)(A)(i), 1956(a)(1)(B)(i), 1956(a)(1)(B)(ii), 1956(a)(2)(A), 1956(a)(2)(B)(i) and 1956(h), the defendants: ARMANDO MENDOZA-HARO, JESUS SEGOVIA, MIGUEL ANGEL SANCHEZ, SERGIO MENDOZA-VALDOVINOS, DANIELA MUNGUIA DE ORTIZ, YULY HERNANDEZ-OROZCO, ALEJANDRO MORALES-GARCIA, RICARDO PANIAGUA-RODRIGUEZ, CARLOS MARTIN SEGURA CHANG, and SONIA PEREZ, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(1) any and all of the defendants right, title and interest in all property constituting and derived from any proceeds obtained directly and indirectly as a result of such offense, and in all property used, or 69

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intended to be used, in any manner or part, to commit, or to facilitate the commission of such offense, including, but not limited to a money judgment in the amount of proceeds obtained by the conspiracy and by the defendants. If any of the property as a result of any act or omission of the defendants: a) b) c) d) e) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 18, United States Code, Section 982 to seek forfeiture of any other property of said defendants up to the value of the forfeitable property. A TRUE BILL:

_Ink signature on file in the Clerks Office___ FOREPERSON

APPROVED: JOHN F. WALSH United States Attorney BY: __s/ Zachary Phillips________ ZACHARY PHILLIPS Assistant United States Attorney U.S. Attorneys Office 1225 17th Street, Suite 700 Denver, CO. 80202 Telephone (303) 454-0118 Fax (303) 454-0401 e-mail: zachary.phillips@usdoj.gov Attorney for the Government

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BY:

s/ Kasandra R. Carleton KASANDRA R. CARLETON Assistant U.S. Attorney U.S. Attorneys Office 1225 17th St., Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0401 e-mail: Kasandra.Carleton@usdoj.gov Attorney for the Government

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DEFENDANT 1:

ARMANDO MENDOZA-HARO, a/k/a "Armando Mendoza" "Green Eyes" "Carlos"

YOB: ADDRESS: COMPLAINT FILED? YES T NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Money Laundering. COUNT THREE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) and Title 18, United States Code, Section 2- knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and Aiding and Abetting the Same. COUNTS FOUR, FIVE, SIX, SEVEN, EIGHT, NINE, TEN, ELEVEN, TWELVE, THIRTEEN, FOURTEEN, SEVENTEEN, NINETEEN and TWENTY: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNTS TWENTY-ONE, TWENTY-TWO and TWENTY-THREE: Title 18, United States Code, Section 1956(a)(1)(A)(i). - Money Laundering With Intent to Promote and Carry On the Unlawful Activity. YES T NO

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COUNTS TWENTY-FOUR, TWENTY-SIX, TWENTY-NINE, THIRTYONE, THIRTY-THREE, THIRTY-FIVE, THIRTY-SEVEN, THIRTYNINE, FORTY-ONE, FIFTY-TWO, FIFTY-THREE, FIFTY-FIVE, FIFTYSEVEN, FIFTY-NINE, SIXTY-ONE, SIXTY-THREE, SEVENTY, SEVENTY-ONE, SEVENTY-THREE, SEVENTY-FIVE, SEVENTYSEVEN, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTY-SIX, EIGHTY-EIGHT, NINETY, NINETY-TWO, NINETY-FOUR, NINETYSIX, NINETY-EIGHT, ONE HUNDRED, ONE HUNDRED NINE, ONE HUNDRED ELEVEN, ONE HUNDRED THIRTEEN, ONE HUNDRED FIFTEEN, ONE HUNDRED TWENTY-ONE, ONE HUNDRED TWENTYTHREE, ONE HUNDRED TWENTY-FIVE, ONE HUNDRED TWENTYNINE, ONE HUNDRED THIRTY-ONE and ONE HUNDRED THIRTYFOUR: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) and Title 18, United States Code, Section 2- knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and Aiding and Abetting the Same. COUNTS TWENTY-FIVE, TWENTY-SEVEN, THIRTY, THIRTY-TWO. THIRTY-FOUR, THIRTY-SIX, THIRTY-EIGHT, FORTY, FORTY-TWO, FIFTY-ONE, FIFTY-FOUR, FIFTY-SIX, FIFTY-EIGHT, SIXTY, SIXTYTWO, SEVENTY-TWO, SEVENTY-FOUR, SEVENTY-SIX, SEVENTYEIGHT, EIGHTY-ONE, EIGHTY-THREE, EIGHTY-FIVE, EIGHTYSEVEN, EIGHTY-NINE, NINETY-ONE, NINETY-THREE, NINETYFIVE, NINETY-SEVEN, NINETY-NINE, ONE HUNDRED ONE, ONE HUNDRED TEN, ONE HUNDRED TWELVE, ONE HUNDRED FOURTEEN, ONE HUNDRED SIXTEEN, ONE HUNDRED TWENTYTWO, ONE HUNDRED TWENTY-FOUR, ONE HUNDRED TWENTYSIX, ONE HUNDRED THIRTY, ONE HUNDRED THIRTY-TWO and ONE HUNDRED THIRTY-FIVE: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering and Aiding and Abetting the Same. COUNTS TWENTY-EIGHT, SIXTY-FOUR, SIXTY-FIVE, SIXTY-SIX, SIXTY-SEVEN, SIXTY-EIGHT and SIXTY-NINE: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering and Aiding and Abetting the Same. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO

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PENALTY:

COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee. COUNT THREE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS FOUR, FIVE, SIX, SEVEN, EIGHT, NINE, TEN, ELEVEN, TWELVE, THIRTEEN, FOURTEEN, SEVENTEEN, NINETEEN and TWENTY: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNTS TWENTY-ONE, TWENTY-TWO and TWENTY-THREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee (per count). COUNTS TWENTY-FOUR, TWENTY-SIX, TWENTY-NINE, THIRTYONE, THIRTY-THREE, THIRTY-FIVE, THIRTY-SEVEN, THIRTYNINE, FORTY-ONE, FIFTY-TWO, FIFTY-THREE, FIFTY-FIVE, FIFTYSEVEN, FIFTY-NINE, SIXTY-ONE, SIXTY-THREE, SIXTY-FOUR, SEVENTY, SEVENTY-ONE, SEVENTY-THREE, SEVENTY-FIVE, SEVENTY-SEVEN, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTYSIX, EIGHTY-EIGHT, NINETY, NINETY-TWO, NINETY-FOUR, NINETY-SIX, NINETY-EIGHT, ONE HUNDRED, ONE HUNDRED NINE, ONE HUNDRED ELEVEN, ONE HUNDRED THIRTEEN, ONE HUNDRED FIFTEEN, ONE HUNDRED TWENTY-ONE, ONE HUNDRED TWENTY-THREE, ONE HUNDRED TWENTY-FIVE, ONE HUNDRED TWENTY-NINE, ONE HUNDRED THIRTY-ONE and ONE HUNDRED THIRTY-FOUR: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee (per count).

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COUNTS TWENTY-FIVE, TWENTY-SEVEN, THIRTY, THIRTY-TWO. THIRTY-FOUR, THIRTY-SIX, THIRTY-EIGHT, FORTY, FORTY-TWO, FIFTY-ONE, FIFTY-FOUR, FIFTY-SIX, FIFTY-EIGHT, SIXTY, SIXTYTWO, SEVENTY-TWO, SEVENTY-FOUR, SEVENTY-SIX, SEVENTYEIGHT, EIGHTY-ONE, EIGHTY-THREE, EIGHTY-FIVE, EIGHTYSEVEN, EIGHTY-NINE, NINETY-ONE, NINETY-THREE, NINETYFIVE, NINETY-SEVEN, NINETY-NINE, ONE HUNDRED ONE, ONE HUNDRED TEN, ONE HUNDRED TWELVE, ONE HUNDRED FOURTEEN, ONE HUNDRED SIXTEEN, ONE HUNDRED TWENTYTWO, ONE HUNDRED TWENTY-FOUR, ONE HUNDRED TWENTYSIX, ONE HUNDRED THIRTY, ONE HUNDRED THIRTY-TWO and ONE HUNDRED THIRTY-FIVE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

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DEFENDANT 2:

JESUS SEGOVIA, a/k/a Carlos Botitas 1980

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money COUNTS SEVEN, EIGHT, TWELVE and EIGHTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNT TWENTY-THREE: Title 18, United States Code, Section 1956(a)(1)(A)(i) - Money Laundering with Intent to Promote and Carry on the Unlawful Act.. YES T NO

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COUNTS TWENTY-FOUR, TWENTY-SIX, TWENTY-NINE, THIRTYONE, THIRTY-FIVE, THIRTY-NINE, SEVENTY-THREE, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTY-SIX and NINETY-TWO: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. COUNTS TWENTY-FIVE, TWENTY-SEVEN, THIRTY, THIRTY-TWO. THIRTY-SIX, FORTY, SEVENTY-FOUR, EIGHTY-ONE, EIGHTYTHREE, EIGHTY-FIVE, EIGHTY-SEVEN and NINETY-THREE: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering to Avoid a Reporting Requirement and Aiding and Abetting the Same. . LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years, NMT 5 years supervised release, $100 Special Assessment Fee. COUNTS SEVEN, EIGHT, TWELVE and EIGHTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNT TWENTY-THREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee (per count). COUNTS TWENTY-FOUR, TWENTY-SIX, TWENTY-NINE, THIRTYONE, THIRTY-FIVE, THIRTY-NINE, SEVENTY-THREE, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTY-SIX and NINETY-TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count).

Case 1:12-cr-00243-CMA Document 1-2 Filed 05/23/12 USDC Colorado Page 3 of 3

COUNTS TWENTY-FIVE, TWENTY-SEVEN, THIRTY, THIRTY-TWO. THIRTY-SIX, FORTY, SEVENTY-FOUR, EIGHTY-ONE, EIGHTYTHREE, EIGHTY-FIVE, EIGHTY-SEVEN and NINETY-THREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count).

AGENT:

TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-3 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 3:

MIGUEL ANGEL SANCHEZ, a/k/a "Miguel Sanchez" 1981

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money COUNTS TEN, FIFTEEN, SIXTEEN, SEVENTEEN and EIGHTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNTS TWENTY-TWO and TWENTY-THREE: Title 18, United States Code, Section 1956(a)(1)(A)(i). - Money Laundering With the Intent to Promote and Cary On the Unlawful Act. YES T NO

Case 1:12-cr-00243-CMA Document 1-3 Filed 05/23/12 USDC Colorado Page 2 of 2

LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. COUNTS TEN, FIFTEEN, SIXTEEN, SEVENTEEN and EIGHTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNTS TWENTY-TWO and TWENTY-THREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 year supervised release, $100 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-4 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 4:

SERGIO MENDOZA-VALDOVINOS, a/k/a Sergio Mendoza

YOB: 1959 ADDRESS: COMPLAINT FILED? YES T NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money. COUNTS FIFTEEN and SIXTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the in committing and in causing and facilitating the commission of a felony offense. COUNT TWENTY-TWO: Title 18, United States Code, Section 1956(a)(1)(A)(i). - Money Laundering With the Intent to Promote and Cary On the Unlawful Act. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 NMT 5 years supervised release, $100 Special Assessment Fee. YES T NO

telephone, drug

Case 1:12-cr-00243-CMA Document 1-4 Filed 05/23/12 USDC Colorado Page 2 of 2

COUNTS FIFTEEN and SIXTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNT TWENTY-TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-5 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 5:

DANIELA MUNGUIA DE ORTIZ, a/k/a Daniela Munguia-Torres Guachita Aurora Casas 1978

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money COUNTS FOUR, NINE and ELEVEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNTS FIFTY-ONE and FIFTY-TWO: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. YES T NO

Case 1:12-cr-00243-CMA Document 1-5 Filed 05/23/12 USDC Colorado Page 2 of 2

COUNTS FOUR, NINE and ELEVEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNTS FIFTY-ONE and FIFTY TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-6 Filed 05/23/12 USDC Colorado Page 1 of 3

DEFENDANT 6:

YULY HERNANDEZ-OROZCO, a/k/a Yuly Yuly Lorena Hernandez-Orozco 1982

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money. COUNTS FIVE and SIX: Title 21, United States Code, Section 843(b) knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNT TWENTY-ONE: Title 18, United States Code, Section 1956(a)(1)(A)(i). - Money Laundering with the Intent to Promote and Carry on the Unlawful Act. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. YES T NO

Case 1:12-cr-00243-CMA Document 1-6 Filed 05/23/12 USDC Colorado Page 2 of 3

Case 1:12-cr-00243-CMA Document 1-6 Filed 05/23/12 USDC Colorado Page 3 of 3

COUNTS FIVE and SIX: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNT TWENTY-ONE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-7 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 7:

ERIKA ELENA HERNANDEZ-GALAVIZ, a/k/a Erika Erika Hernandez Erika Quintana 1985

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS THIRTEEN and FOURTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS THIRTEEN and FOURTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys YES T NO

AUTHORIZED BY:

Case 1:12-cr-00243-CMA Document 1-7 Filed 05/23/12 USDC Colorado Page 2 of 2

ESTIMATED TIME OF TRIAL:

5 days or more

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-8 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 8:

ALEJANDRO MORALES-GARCIA, a/k/a Alex 1982

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money.. COUNTS NINETEEN and TWENTY: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. COUNT ONE HUNDRED NINE: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. COUNT ONE HUNDRED TEN: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering to Avoid a Reporting Requirement and Aiding and Abetting the Same. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO YES T NO

Case 1:12-cr-00243-CMA Document 1-8 Filed 05/23/12 USDC Colorado Page 2 of 2

PENALTY:

COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. COUNTS NINETEEN and TWENTY: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). COUNT ONE HUNDRED NINE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment. COUNT ONE HUNDRED TEN: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee.

AGENT:

TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-9 Filed 05/23/12 USDC Colorado Page 1 of 3

DEFENDANT 9:

RICARDO PANIAGUA-RODRIGUEZ-RODRIGUEZ, a/k/a "Ricardo Paniagua"

YOB: ADDRESS:

1973

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money COUNTS TWENTY-NINE, THIRTY-ONE, THIRTY-THREE, THIRTYFIVE, THIRTY-SEVEN, THIRTY-NINE, FORTY-ONE, FIFTY-THREE, FIFTY-FIVE, FIFTY-SEVEN, FIFTY-NINE, SIXTY-ONE and SIXTYTHREE: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. COUNTS THIRTY, THIRTY-TWO. THIRTY-FOUR, THIRTY-SIX, THIRTY-EIGHT, FORTY, FORTY-TWO, FIFTY-FOUR, FIFTY-SIX, FIFTY-EIGHT, SIXTY, SIXTY-TWO: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering to Avoid a Reporting Requirement and Aiding and Abetting the Same. COUNTS FORTY-THREE, FORTY-FOUR, FORTY-FIVE and FORTYSIX: Title 18, United States Code, Sections 1956(a)(1)(B)(i) - Money Designed to Conceal the Nature, Source and Ownership of the Financial Transaction. COUNTS FORTY-SEVEN and FORTY-NINE: Title 18, United States Code, Section 1956(a)(2)(A) - Money Laundering to Promote an Unlawful Act By Transferring Money to A Place Outside the United States. COUNTS FORTY-EIGHT and FIFTY: Title 18, United States Code, Sections 1956(a)(2)(B)(i). - Money Laundering Designed to Conceal the Nature, Source, Ownership and Control of the Financial Transaction by Transferring Money to A Place Outside the United States. YES T NO

Laundering

Case 1:12-cr-00243-CMA Document 1-9 Filed 05/23/12 USDC Colorado Page 2 of 3

LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee. COUNTS TWENTY-NINE, THIRTY-ONE, THIRTY-THREE, THIRTYFIVE, THIRTY-SEVEN, THIRTY-NINE, FORTY-ONE, FIFTY-THREE, FIFTY-FIVE, FIFTY-SEVEN, FIFTY-NINE, SIXTY-ONE and SIXTYTHREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). COUNTS THIRTY, THIRTY-TWO. THIRTY-FOUR, THIRTY-SIX, THIRTY-EIGHT, FORTY, FORTY-TWO, FIFTY-FOUR, FIFTY-SIX, FIFTY-EIGHT, SIXTY, SIXTY-TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). COUNTS FORTY-SEVEN and FORTY-NINE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). COUNTY FORTY-EIGHT and FIFTY: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count).

AGENT:

TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. 2

Case 1:12-cr-00243-CMA Document 1-9 Filed 05/23/12 USDC Colorado Page 3 of 3

OCDETF CASE:

Yes

No

Case 1:12-cr-00243-CMA Document 1-10 Filed 05/23/12 USDC Colorado Page 1 of 3

DEFENDANT 10:

CARLOS MARTIN SEGURA CHANG, a/k/a Carlos M. Chang Carlos Segura Chang 1965

YOB: ADDRESS:

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money. COUNTS SEVENTY, SEVENTY-ONE, SEVENTY-THREE, SEVENTYFIVE, SEVENTY-SEVEN, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTY-SIX, EIGHTY-EIGHT, NINETY, NINETY-TWO, NINETYFOUR, NINETY-SIX, NINETY-EIGHT, ONE HUNDRED, ONE HUNDRED NINE, ONE HUNDRED ELEVEN, ONE HUNDRED THIRTEEN, ONE HUNDRED FIFTEEN, ONE HUNDRED TWENTYONE, ONE HUNDRED TWENTY-THREE, ONE HUNDRED TWENTYFIVE, ONE HUNDRED TWENTY-NINE, ONE HUNDRED THIRTY-ONE and ONE HUNDRED THIRTY-FOUR: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. YES T NO

Case 1:12-cr-00243-CMA Document 1-10 Filed 05/23/12 USDC Colorado Page 2 of 3

COUNTS SEVENTY-TWO, SEVENTY-FOUR, SEVENTY-SIX, SEVENTY-EIGHT, EIGHTY-ONE, EIGHTY-THREE, EIGHTY-FIVE, EIGHTY-SEVEN, EIGHTY-NINE, NINETY-ONE, NINETY-THREE, NINETY-FIVE, NINETY-SEVEN, NINETY-NINE, ONE HUNDRED ONE, ONE HUNDRED TEN, ONE HUNDRED TWELVE, ONE HUNDRED FOURTEEN, ONE HUNDRED SIXTEEN, ONE HUNDRED TWENTYTWO, ONE HUNDRED TWENTY-FOUR, ONE HUNDRED TWENTYSIX, ONE HUNDRED THIRTY, ONE HUNDRED THIRTY-TWO and ONE HUNDRED THIRTY-FIVE: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering to Avoid a Reporting Requirement and Aiding and Abetting the Same. COUNTS SEVENTY-NINE, ONE HUNDRED TWO, ONE HUNDRED FIVE, ONE HUNDRED SIX, ONE HUNDRED SEVENTEEN, ONE HUNDRED TWENTY, ONE HUNDRED TWENTY-SEVEN, ONE HUNDRED TWENTY-EIGHT and ONE HUNDRED THIRTY-THREE: Title 18, United States Code, Sections 1956(a)(1)(B)(i) - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction. COUNT ONE HUNDRED THREE, ONE HUNDRED SEVEN and ONE HUNDRED EIGHTEEN: Title 18, United States Code, Section 1956(a)(2)(A) Money Laundering to Promote an Unlawful Act By Transferring Money to a Place Outside the United States.

LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee. COUNTS SEVENTY, SEVENTY-ONE, SEVENTY-THREE, SEVENTYFIVE, SEVENTY-SEVEN, EIGHTY, EIGHTY-TWO, EIGHTY-FOUR, EIGHTY-SIX, EIGHTY-EIGHT, NINETY, NINETY-TWO, NINETYFOUR, NINETY-SIX, NINETY-EIGHT, ONE HUNDRED, ONE HUNDRED NINE, ONE HUNDRED ELEVEN, ONE HUNDRED THIRTEEN, ONE HUNDRED FIFTEEN, ONE HUNDRED TWENTYONE, ONE HUNDRED TWENTY-THREE, ONE HUNDRED TWENTYFIVE, ONE HUNDRED TWENTY-NINE, ONE HUNDRED THIRTY-ONE and ONE HUNDRED THIRTY-FOUR: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years supervised release, $100 Special Assessment Fee (per count). 2

Case 1:12-cr-00243-CMA Document 1-10 Filed 05/23/12 USDC Colorado Page 3 of 3

COUNTS SEVENTY-TWO, SEVENTY-FOUR, SEVENTY-SIX, SEVENTY-EIGHT, EIGHTY-ONE, EIGHTY-THREE, EIGHTY-FIVE, EIGHTY-SEVEN, EIGHTY-NINE, NINETY-ONE, NINETY-THREE, NINETY-FIVE, NINETY-SEVEN, NINETY-NINE, ONE HUNDRED ONE, ONE HUNDRED TEN, ONE HUNDRED TWELVE, ONE HUNDRED FOURTEEN, ONE HUNDRED SIXTEEN, ONE HUNDRED TWENTYTWO, ONE HUNDRED TWENTY-FOUR, ONE HUNDRED TWENTYSIX, ONE HUNDRED THIRTY, ONE HUNDRED THIRTY-TWO and ONE HUNDRED THIRTY-FIVE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). COUNTS SEVENTY-NINE, ONE HUNDRED TWO, ONE HUNDRED FIVE, ONE HUNDRED SIX, ONE HUNDRED SEVENTEEN, ONE HUNDRED TWENTY, ONE HUNDRED TWENTY-SEVEN, ONE HUNDRED TWENTY-EIGHT and ONE HUNDRED THIRTY-THREE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). COUNT ONE HUNDRED THREE, ONE HUNDRED SEVEN and ONE HUNDRED EIGHTEEN: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count).

AGENT:

TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

Case 1:12-cr-00243-CMA Document 1-11 Filed 05/23/12 USDC Colorado Page 1 of 2

DEFENDANT 11: YOB: ADDRESS:

SONIA PEREZ

COMPLAINT FILED?

YES

NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT TWO: Title 18, United States Code, Section 1956(h) - Conspiracy to Launder Money. COUNTS SEVENTY-FIVE and NINETY: Title 18, United States Code, Sections 1956(a)(1)(B)(i) and 2 - Money Laundering Designed to Conceal the Nature, Source and Ownership of the Financial Transaction, and Aiding and Abetting the Same. COUNTS SEVENTY-SIX and NINETY-ONE: Title 18, United States Code, Sections 1956(a)(1)(B)(ii) and 2 - Money Laundering and Aiding and Abetting the Same. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT TWO: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee. COUNTS SEVENTY-FIVE and NINETY: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). YES T NO

Case 1:12-cr-00243-CMA Document 1-11 Filed 05/23/12 USDC Colorado Page 2 of 2

COUNTS SEVENTY-SIX and NINETY-ONE: NMT 20 years imprisonment, $500,000 fine (or twice the value of the property, whichever is greater), or both; NLT 3 years NMT 5 years supervised release, $100 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more

AUTHORIZED BY:

ESTIMATED TIME OF TRIAL:

THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No

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