Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

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1 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 1 of 17 Criminal Case No. UNITED STATES OF AMERICA, v. Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO 1. JORGE R. CARAVEO, d/b/a/ JUAREZ BOOT COMPANY, 2. MARIA DE LOS ANGELES CRUZ PACHECO, d/b/a CREACIONES ANGELES, 3. CARLOS LEAL BARRAGAN, 4. OCTAVIO ANGUIANO MUNOZ, 5. ESTEBAN LOPEZ ESTRADA, d/b/a/ BOTAS EXOTICAS CANADA GRANDE, Defendants. INDICTMENT 18 U.S.C. 545; 18 U.S.C. 1956(a)(2)(A); 18 U.S.C. 2 The Grand Jury charges that: INTRODUCTORY ALLEGATIONS The following statements were true at all times pertinent to this Indictment: 1. The United States, Mexico, and approximately 170 other countries are 1

2 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 2 of 17 signatories to a multilateral treaty called the Convention on International Trade in Endangered Species of Wild Fauna and Flora, 27 U.S.T. 1087, T.I.A.S (commonly referred to as the CITES treaty or the Convention ). The CITES treaty provides a mechanism for regulating international trade in species whose survival is considered threatened by trade. By agreement of the parties, such species are listed on appendices, depending on the level of protection needed for the species. International trade in species listed on these appendices (and their body parts or products made therefrom) is monitored and regulated by permits and quotas. The permit restrictions apply to live and dead specimens, as well as the skins, parts and products made in whole or in part from a listed species. 2. Wildlife species in danger of extinction and which are, or may be, affected by trade (tigers, pandas, elephants and all species of sea turtles, for example) are listed on Appendix I of CITES. CITES allows very limited trade in Appendix I species for scientific and research purposes, and only if the specimen is lawfully acquired and a valid "foreign export permit" issued by the specimen's country of origin (or a valid "foreign reexport certificate" issued by the country of re-export), as well as a valid "import permit" from the destination country, are obtained prior to shipping any such wildlife from one country to another. International trade in Appendix I species for primarily commercial purposes is prohibited. 2

3 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 3 of Listed on Appendix II of CITES are species not necessarily threatened with extinction, but in which trade must be controlled in order to avoid utilization incompatible with their survival. International trade in these species (or skins or products made from them) for commercial purposes is allowed, but only if a valid "foreign export permit" issued by the specimen's country of origin (or a valid "foreign re-export certificate" issued by the country of re-export) is obtained prior to the shipment. The caiman, python and tegu lizard skins and products described below were subject to the Appendix II permit requirements. 4. The CITES treaty is implemented in the United States by the Endangered Species Act of 1973 (the ESA ), which directs the U.S. Fish and Wildlife Service ( USFWS ) to administer the treaty. 16 U.S.C. 1537a, 1540(f). The ESA makes it unlawful to knowingly trade in any specimen contrary to the provisions of [CITES], or to possess any specimen traded contrary to the provisions of [CITES]." 16 U.S.C. 1538(c)(1), 1540(b)(1). "Trade," in this context, includes importation into the United States. The USFWS has promulgated extensive regulations incorporating the specific permit requirements and provisions of CITES and listing the species contained on the CITES appendices. 50 C.F.R. Part Seven species of sea turtles are known to exist: Hawksbill, Green, Loggerhead, Olive Ridley, Kemp s Ridley, Leatherback and Flatback. All seven species of sea turtles 3

4 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 4 of 17 are listed in Appendix I of CITES, prohibiting the commercial importation to the U.S. of their shells, meat, eggs, skins or products made from them. 6. In addition to implementing the CITES treaty, the ESA also designates and protects species considered by the U.S. government to be endangered or threatened. The ESA prohibits the knowing importation of specimens or parts of such listed species without a permit. 16 U.S.C. 1538(a). At all times relevant to this Indictment, the Hawksbill, Leatherback, Kemp s Ridley, Olive Ridley, and Green Sea Turtles were listed pursuant to the ESA as endangered throughout all or part of their ranges. 50 C.F.R The Loggerhead Sea Turtle was listed as threatened throughout its range. Id. Certain species of caiman, and python are also listed as endangered or threatened. 7. In addition to the requirements of CITES and the ESA, federal law generally requires that all wildlife, including sea turtles, caiman, tegu lizard, and python, or parts thereof, must be declared to the United States Customs Service at the port of first arrival in the United States. 19 C.F.R When importing any wildlife, importers or their agents must file with the USFWS a completed Declaration for Importation or Exportation of Fish and Wildlife. 50 C.F.R A USFWS or United States Customs Service officer must clear (or refuse) wildlife being imported into the United States, and the importer or his agent must make available to the officer the wildlife being imported, as well as all required permits, licenses or other documents. 50 C.F.R

5 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 5 of JORGE R. CARAVEO (hereinafter CARAVEO ) was a United States citizen living in El Paso, Texas. The means by which CARAVEO committed the offenses with which he is charged herein include the following: a. CARAVEO operated a business called JUAREZ BOOT COMPANY in El Paso, Texas, and just across the border in Juarez, Mexico. CARAVEO lived in El Paso but crossed the international border between El Paso and Juarez routinely to conduct business in Mexico. This routine travel made him subject to less scrutiny when he crossed the border and allowed him to become familiar with the inspection process when entering and leaving the United States; b. CARAVEO received shipments of sea turtle and other exotic skins and products in Juarez, Mexico, which were shipped there from the interior of Mexico by suppliers including the defendants MARIA DE LOS ANGELES CRUZ PACHECO, CARLOS LEAL BARRAGAN, ESTEBAN LOPEZ ESTRADA and OCTAVIO ANGUIANO MUNOZ; c. CARAVEO clandestinely imported, or crossed the wildlife merchandise from Juarez, Mexico to El Paso, Texas, personally or using a paid associate, by concealing the goods from customs and law enforcement agents at the border. When bringing the sea turtle parts and products, and 5

6 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 6 of 17 other skins, into the United States, CARAVEO, or his associate, did not declare the items to customs or wildlife inspectors at the border, nor did they obtain or present any of the permits or documentation required for bringing the wildlife merchandise lawfully into the United States; d. After crossing the wildlife merchandise from a particular shipment into the United States, CARAVEO shipped or delivered the goods from El Paso, Texas to the purchasers in the District of Colorado by commercial delivery services; e. CARAVEO collected fees from the purchasers for his services in clandestinely importing the wildlife merchandise from Mexico into the United States. 9. MARIA DE LOS ANGELES CRUZ PACHECO (hereinafter CRUZ ) was a Mexican resident of Leon, Guanajuato, Mexico. The means by which CRUZ committed the offenses with which she is charged herein include the following: a. CRUZ operated a business called CREACIONES ANGELES in Leon, Guanajuato, Mexico. Through this business, CRUZ obtained tanned sea turtle skins (skins processed into leather) and, on occasion, other skins including caiman, python, stingray, and tegu lizard skins, and offered them for sale to a customer in the District of Colorado; 6

7 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 7 of 17 b. CRUZ negotiated the sale of sea turtle skins and other exotic skins to a U.S. customer in Colorado via telephone, facsimile or , telling the customer she would refer to sea turtle skins as imitacion ( imitation ) because genuine sea turtle skins were prohibited. CRUZ told the customer they should refer to the sea turtle skins as chamarras ( jackets ) to avoid apprehension; c. CRUZ shipped CITES-protected caiman, tegu, python, and stingray skins, via air freight from Leon, Mexico to the customer in the District of Colorado, without permits or declaration, mis-marking the shipment to declare that it contained leather bovine cow jackets; d. CRUZ shipped sea turtle skins to Juarez, Mexico, for pick-up and clandestine import into the United States by CARAVEO; e. CRUZ received payment for the wildlife merchandise from her U.S. customer by international wire transfer of funds from the District of Colorado to a bank account in Mexico she designated for that purpose. 10. CARLOS LEAL BARRAGAN (hereinafter LEAL ) was a Mexican resident living in Guzman, Jalisco, Mexico. The means by which LEAL committed the offenses with which he is charged herein included the following: a. LEAL operated a clandestine tannery business in Mexico. LEAL 7

8 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 8 of 17 obtained sea turtle skins in Mexico, tanned the skins, and sold them to distributors and manufacturers in Mexico, including defendant OCTAVIO ANGUIANO MUNOZ, and a customer in the District of Colorado; b. Once a sale to the U.S. customer had been negotiated by telephone, facsimile and/or , LEAL shipped the sea turtle skins to Juarez, Mexico, for pick-up by CARAVEO, clandestine import from Mexico into the United States, and delivery to the U.S. customer; c. LEAL received payment for the sea turtle skins from his U.S. customer by international wire transfers of funds from the District of Colorado to a bank account in Mexico he designated for that purpose. 11. OCTAVIO ANGUIANO MUNOZ (hereinafter MUNOZ ) was a Mexican resident living in Leon, Guanajuato, Mexico. The means by which MUNOZ committed the offenses with which he is charged herein include the following: a. MUNOZ operated a business in Leon, Guanajuato, Mexico. Through this business, MUNOZ obtained sea turtle skins, sometimes from LEAL, and offered them for sale to a customer in the District of Colorado; b. MUNOZ acknowledged that the sale of sea turtle skins to the U.S. customer was unlawful, and would suggest the use of false names, concealed shipments and persons who would clandestinely import the skins, in order to 8

9 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 9 of 17 avoid apprehension; c. Each time a sale to the U.S. customer had been negotiated by telephone, facsimile and/or , MUNOZ shipped, or arranged the shipment, of the sea turtle skins or other exotic skin items to Juarez, Mexico, for pick-up by CARAVEO, clandestine import into the United States, and delivery or shipment to the U.S. customer; d. MUNOZ received payment for the wildlife merchandise from his U.S. customer by international wire transfers of funds from the District of Colorado to a bank account in Mexico he designated for that purpose. 12. ESTEBAN LOPEZ ESTRADA (hereinafter ESTRADA ) was a Mexican resident residing in Leon, Guanajuato, Mexico. The means by which ESTRADA committed the offenses with which he is charged herein include the following: a. ESTRADA operated a business called BOTAS EXOTICAS CANADA GRANDE in Leon, Guanajuato, Mexico. Through this business, ESTRADA obtained tanned sea turtle skins and products such as boots and belts made from sea turtles and other wildlife, and offered them for sale to a customers in the District of Colorado; b. ESTRADA claimed an inventory of 500 sea turtle boots for sale, offered to sell them to a U.S. customer, acknowledging that they would have to be 9

10 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 10 of 17 imported into the United States as contraband. ESTRADA offered to ship sea turtle boots to the border towns of Juarez, Reynosa, or Tijuana, for subsequent clandestine import into the United States; c. ESTRADA listed sea turtle items on his price list as imitacion and informed his U.S. customer that the items were genuine, but had to be called imitation in order to avoid apprehension. d. Once a sale to the U.S. customer had been negotiated by telephone, facsimile and/or , ESTRADA shipped, or arranged the shipment, of the sea turtle skins and other sea turtle products to Juarez, Mexico, sometimes using a false shipper name in order to avoid apprehension, for pick-up by CARAVEO, clandestine import into the United States, and shipment or delivery to the U.S. customer; e. ESTRADA received payment for the wildlife merchandise from his U.S. customer by international wire transfers of funds from the District of Colorado to a bank account in Mexico he designated for that purpose. 13. The Grand Jury incorporates and realleges by reference the preceding introductory allegations set forth in paragraphs 1 through 12 in each and every Count of this Indictment. 10

11 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 11 of 17 COUNTS ONE THROUGH TWELVE (18 U.S.C. 545 and 2, Smuggling) On or about the dates listed below, within the District of Colorado and elsewhere, JORGE R. CARAVEO, MARIA DE LOS ANGELES CRUZ PACHECO, CARLOS LEAL BARRAGAN, ESTEBAN LOPEZ ESTRADA, and OCTAVIO ANGUIANO MUNOZ defendants herein, did fraudulently and knowingly import and bring into the United States merchandise, to wit: wildlife, as described below, contrary to law, in that said merchandise was traded contrary to CITES, was imported in violation of the Endangered Species Act, and was not declared to any official of the United States government upon its entry into the United States, in violation of Title 16, United States Code, Sections 1538(c)(1), 1540(b)(1); Title 19, Code of Federal Regulations, Section , and Title 50, Code of Federal Regulations, Sections and 14.52, and did knowingly receive, conceal, buy, sell, and facilitate the transportation, concealment, and sale of such merchandise after importation knowing the same to have been imported and brought into the United States contrary to law. Count Date Defendant Wildlife Merchandise 1 4/18/2006 MUNOZ 62 sea turtle skins, 10 sea turtle skin pieces 11

12 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 12 of 17 2 Between 4/27/2006 to 4/28/2006 CRUZ 5 caiman skins, 1 python skin, 2 stingray skins, 5 tegu lizard skins 3 Between 7/26/2006 and 8/9/ Between 11/24/2006 and 12/11/ Between 12/5/2006 and 12/13/ Between 11/30/2006 and 12/13/ Between 12/1/2006 and 12/13/ Between 11/29/2006 and 1/11/ Between 2/8/2007 and 2/23/ Between 2/16/2007 and 3/2/ Between 4/11/2007 and 4/25/2007 ESTRADA; CARAVEO CRUZ; CARAVEO ESTRADA; CARAVEO MUNOZ; CARAVEO CRUZ; CARAVEO MUNOZ; CARAVEO LEAL; CARAVEO CRUZ; CARAVEO LEAL; CARAVEO 20 sea turtle skins 10 sea turtle skins, 18 caiman skins 50 sea turtle skins and 3 pairs of sea turtle shoes 28 sea turtle skins 10 sea turtle skins 73 whole sea turtle skins, 32 sea turtle flipper skins, 2 sea turtle neck skin pieces 98 sea turtle skins 26 sea turtle skins 102 sea turtle skins, 1 pair sea turtle boots, 1 pair sea turtle shoes, 1 sea turtle skin wallet, 1 bottle of sea turtle oil 12

13 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 13 of Between 5/19/2007 and 6/4/2007 MUNOZ; CARAVEO 2 pairs sea turtle/ostrich skin shoes, 2 pair lizard skin boots, 2 lizard skin belts, 2 pair caiman skin boots, 2 caiman skin belts, 2 pair python skin boots, 2 python skin belts. All in violation of Title 18, United States Code, Sections 545 and 2. COUNTS THIRTEEN THROUGH TWENTY-SIX (18 U.S.C. 1956(a)(2)(A), Money Laundering) On or about the dates listed below, within the District of Colorado and elsewhere, MARIA DE LOS ANGELES CRUZ PACHECO, CARLOS LEAL BARRAGAN, ESTEBAN LOPEZ ESTRADA, and OCTAVIO ANGUIANO MUNOZ defendants herein, intending to promote the carrying on of specified unlawful activity, that is, the smuggling of wildlife merchandise from Mexico into the United States, in violation of Title 18, United States Code, Section 545, did knowingly transport, transmit, and transfer monetary instruments and funds from places within the United States, specifically the District of Colorado, to places outside the United States, specifically Mexico, as described below. 13

14 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 14 of 17 Count Date Defendant Amount Transaction 13 4/11/2006 MUNOZ $ International wire transfer from USA, to MUNOZ s HSBC bank account number in Leon, Mexico 14 4/18/2006 CRUZ $1, International wire transfer from USA, to CRUZ s HSBC bank account number in Leon, Mexico 15 7/27/2006 ESTRADA $1, International wire transfer from USA, to ESTRADA s Bancomer bank account number in Leon, Mexico 16 11/16/2006 ESTRADA $3, International wire transfer from USA, to ESTRADA s Bancomer bank account number in Leon, Mexico 17 11/21/2006 CRUZ $2, International wire transfer from USA, to CRUZ s HSBC bank account number in Leon, Mexico 14

15 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 15 of /28/2006 CRUZ $ International wire transfer from USA, to CRUZ s HSBC bank account number in Leon, Mexico 19 12/18/2006 MUNOZ $2, International wire transfer from USA, to MUNOZ s relative s HSBC bank account number in Leon, Mexico 20 1/17/2007 CRUZ $1, International wire transfer from USA, to CRUZ s HSBC bank account number in Leon, Mexico 21 2/6/2007 LEAL $3, International wire transfer from USA, to LEAL s HSBC bank account number in Guzman, Mexico 22 4/4/2007 LEAL $4, International wire transfer from USA, to LEAL s HSBC bank account number in Guzman, Mexico 15

16 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 16 of /17/2007 MUNOZ $ International wire transfer from USA, to MUNOZ s relative s HSBC bank account number in Leon, Mexico 24 4/19/2007 MUNOZ $ International wire transfer from USA, to MUNOZ s relative s HSBC bank account number in Leon, Mexico 25 5/2/2007 LEAL $1, International wire transfer from USA, to LEAL s HSBC bank account number in Guzman, Mexico 26 7/27/07 LEAL $1, International wire transfer from USA, to LEAL s HSBC bank account number in Guzman, Mexico All in violation of Title 18, United States Code, Section 1956(a)(2)(A). A TRUE BILL: s/foreperson FOREPERSON 16

17 Case 1:07-cr EWN Document 1 Filed 08/22/2007 Page 17 of 17 TROY A. EID UNITED STATES ATTORNEY By: s/robert Anderson ROBERT S. ANDERSON Special Assistant United States Attorney Environmental Crimes Section U.S. Department Justice 105 East Pine, Second Floor Missoula, MT Telephone: Robert.Anderson8@usdoj.gov By: s/linda McMahan LINDA McMAHAN Assistant United States Attorney United States Attorney s Office th Street, Suite 700 Denver, CO Telephone: Linda.McMahan@usdoj.gov By: s/colin Black COLIN L. BLACK Trial Attorney Environmental Crimes Section U.S. Department Justice 601 D St. NW, Room 2814 Washington, DC Telephone: Colin.Black@usdoj.gov 17

18 Case 1:07-cr EWN Document 1-2 Filed 08/22/2007 Page 1 of 2 (Rev. 04/07) DATE: August 21, 2007 DEFENDANT: JORGE R. CARAVEO YOB: 1973 ADDRESS (CITY/STATE): El Paso, Texas COMPLAINT FILED? YES X NO IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO IF NO, A NEW WARRANT IS REQUIRED OFFENSE: Counts 3-12: 18 U.S.C. 545 and 2 (Smuggling) LOCATION OF OFFENSE (COUNTY/STATE): Englewood, Arapahoe County, CO PENALTY: For each violation of 18 U.S.C. 545 and 2 in Counts 3-12: NMT 5 years incarceration; NMT $ 250,000 fine; $ Special Assessment; up to 3 years supervised release AGENT: SA George Morrison USFWS AUTHORIZED BY: Linda A. McMahan Assistant U.S. Attorney ESTIMATED TIME OF TRIAL: Robert S. Anderson Special Assistant U.S. Attorney Colin L. Black Trial Attorney five days or less X over five days other THE GOVERNMENT

19 Case 1:07-cr EWN Document 1-2 Filed 08/22/2007 Page 2 of 2 X will seek detention in this case will not seek detention in this case The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: Yes X No

20 Case 1:07-cr EWN Document 1-3 Filed 08/22/2007 Page 1 of 2 (Rev. 04/07) DATE: August 21, 2007 DEFENDANT: MARIA DE LOS ANGELES CRUZ PACHECO, d/b/a CREACIONES ANGELES YOB: ADDRESS (CITY/STATE): Leon, Guanajuato, Mexico COMPLAINT FILED? YES X NO IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO IF NO, A NEW WARRANT IS REQUIRED OFFENSE: Counts 2, 4, 7, 10: 18 U.S.C. 545 and 2 (Smuggling) Counts 14, 17, 18, 20: 18 U.S.C. 1956(a)(2)(A) (Money Laundering) LOCATION OF OFFENSE (COUNTY/STATE): Englewood, Arapahoe County, Colorado PENALTY: For each violation of 18 U.S.C. 545 and 2 in Counts 2, 4, 7, 10: NMT 5 years incarceration; NMT $ 250,000 fine; $ Special Assessment; up to 3 years supervised release For each violation of 18 U.S.C. 1956(a)(2)(A) in Counts 14, 17, 18, 20: NMT 20 years incarceration; NMT $ 500,000 fine; $ Special Assessment; up to 3 years supervised release AGENT: AUTHORIZED BY: SA George Morrison USFWS Linda A. McMahan Assistant U.S. Attorney ESTIMATED TIME OF TRIAL: Robert S. Anderson Special Assistant U.S. Attorney Colin L. Black Trial Attorney

21 Case 1:07-cr EWN Document 1-3 Filed 08/22/2007 Page 2 of 2 five days or less X over five days other THE GOVERNMENT X will seek detention in this case will not seek detention in this case The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: Yes X No

22 Case 1:07-cr EWN Document 1-4 Filed 08/22/2007 Page 1 of 2 (Rev. 04/07) DATE: August 21, 2007 DEFENDANT: CARLOS LEAL BARRAGAN DOB: ADDRESS (CITY/STATE): Guzman, Jalisco, Mexico COMPLAINT FILED? YES X NO IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO IF NO, A NEW WARRANT IS REQUIRED OFFENSE: Counts 9, 11: 18 U.S.C. 545 and 2(Smuggling) Counts 21, 22, 25, 26: 18 U.S.C. 1956(a)(2)(A) (Money Laundering) LOCATION OF OFFENSE (COUNTY/STATE): Englewood, Arapaho County, Colorado PENALTY: For each violation of 18 U.S.C. 545 and 2 in Counts 9, 11: NMT 5 years incarceration; NMT $ 250,000 fine; $ Special Assessment; up to 3 years supervised release For each violation of 18 U.S.C. 1956(a)(2)(A) in Counts 21, 22, 25, 26: NMT 20 years incarceration; NMT $ 500,000 fine; $ Special Assessment; up to 3 years supervised release AGENT: SA George Morrison USFWS AUTHORIZED BY: Linda A. McMahan Assistant U.S. Attorney Robert S. Anderson Special Assistant U.S. Attorney Colin L. Black Trial Attorney

23 Case 1:07-cr EWN Document 1-4 Filed 08/22/2007 Page 2 of 2 ESTIMATED TIME OF TRIAL: five days or less X over five days other THE GOVERNMENT X will seek detention in this case will not seek detention in this case The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: Yes X No

24 Case 1:07-cr EWN Document 1-5 Filed 08/22/2007 Page 1 of 2 (Rev. 04/07) DATE: August 21, 2007 DEFENDANT: OCTAVIO MUNOZ YOB: ADDRESS (CITY/STATE): Leon, Guanajuato, Mexico COMPLAINT FILED? YES X NO IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO IF NO, A NEW WARRANT IS REQUIRED OFFENSE: Counts 1, 6, 8, 12: 18 U.S.C. 545 and 2 (Smuggling) Counts 13, 19, 23, 24: 18 U.S.C. 1956(a)(2)(A) (Money Laundering) LOCATION OF OFFENSE (COUNTY/STATE): Englewood, Arapaho County, Colorado PENALTY: For each violation of 18 U.S.C. 545 and 2 in Counts 1, 6, 8, 12: NMT 5 years incarceration; NMT $ 250,000 fine; $ Special Assessment; up to 3 years supervised release For each violation of 18 U.S.C. 1956(a)(2)(A) in Counts 13, 19, 23, 24: NMT 20 years incarceration; NMT $ 500,000 fine; $ Special Assessment; up to 3 years supervised release AGENT: AUTHORIZED BY: SA George Morrison USFWS Linda A. McMahan Assistant U.S. Attorney ESTIMATED TIME OF TRIAL: Robert S. Anderson Special Assistant U.S. Attorney Colin L. Black Trial Attorney five days or less X over five days other

25 Case 1:07-cr EWN Document 1-5 Filed 08/22/2007 Page 2 of 2 THE GOVERNMENT X will seek detention in this case will not seek detention in this case The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: Yes X No

26 Case 1:07-cr EWN Document 1-6 Filed 08/22/2007 Page 1 of 2 (Rev. 04/07) DATE: August 21, 2007 DEFENDANT: ESTEBAN LOPEZ ESTRADA, d/b/a BOTAS EXOTICAS CANADA GRANDE YOB: ADDRESS (CITY/STATE): Leon, Guanajuato, Mexico COMPLAINT FILED? YES X NO IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO IF NO, A NEW WARRANT IS REQUIRED OFFENSE: Counts 3, 5: 18 U.S.C. 545 and 2 (Smuggling) Counts 15, 16: 18 U.S.C. 1956(a)(2)(A) (Money Laundering) LOCATION OF OFFENSE (COUNTY/STATE): Englewood, Arapaho County, Colorado PENALTY: For each violation of 18 U.S.C. 545 and 2 in Counts 3, 5: NMT 5 years incarceration; NMT $ 250,000 fine; $ Special Assessment; up to 3 years supervised release For each violation of 18 U.S.C. 1956(a)(2)(A) in Counts 15, 16: NMT 20 years incarceration; NMT $ 500,000 fine; $ Special Assessment; up to 3 years supervised release AGENT: AUTHORIZED BY: SA George Morrison USFWS Linda A. McMahan Assistant U.S. Attorney Robert S. Anderson Special Assistant U.S. Attorney Colin L. Black Trial Attorney

27 Case 1:07-cr EWN Document 1-6 Filed 08/22/2007 Page 2 of 2 ESTIMATED TIME OF TRIAL: five days or less X over five days other THE GOVERNMENT X will seek detention in this case will not seek detention in this case The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: Yes X No