SOUTHEIWDISTQIGT 17 - F 0 FLORIDA or 2R-sc0u

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1 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHEIWDISTQIGT 17 - F 0 FLORIDA or 2R-sc0u CASE NO U.S.C. j 1956(h) 18 c.s.c. j 982(a) /OTM O-REYE: UNITED STATES OF AMERICA ' V. SAMER H. BARM GE RENATO J. RODRIGUEZ, and JUAN P. GM NDA, a/lk/a Eçlinlechar'' Defendants. / rvln,. h. I-, '*. q 'px r5,.x ; 'h k iw ';.,. 1C > 1 S=, u. l7j 1.i H u. Q'h F q 9. kl b /). j. ('t, Q 9. A t è k #*)..F-* Q 'e* C $ u.!' g.- x. a '.u l I.% t.p 't r. k '! 9 :* % jr v',l. 1.). /'.-, : i. 4 u.! 'y..-. iî. s,.'jt. INDICTM ENT The Grand Jury charges that: COUNT 1 Conspiracy to Commit M oney Laundering (18 U.S.C. j1956(h)) Beginning in or around January 2013, and continuing through in or around M arch 2017, in M iam i-dade County, in the Southern D istrict of Florida, and elsew here, the defendants, SAMER H. BARRAGE RENATO J. RODRIGUEZ, JUAN P. GM NDA, and a/k/a tçlinlechar'' did know ingly and w ilfu ly com bine, conspire, confederate, and agree w ith each other and other persons known and unknow n to the Grand Jury, to transport, transm it and transfer m onetary instnlm ents and funds from a place in the U nited States to or tltrough a place outside the United States and to a place in the United States from or through a place outside the United States, with

2 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 2 of 8 the intent to prom ote the carrying on of specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(2)(A). It is further alleged that the specified unlaw ful activity is: The entry of goods by m eans of false statem ents, in violation of Title 18, U nited States Code, Section 542,. (b) A.n ofense against a foreign nation, that is, the crime of ilegal mining against the Republic of Peru, w ith respect to w hich the United States w ould be obligated to by a m ultilateral treaty, either to extradite the alleged offender or to subm it the case for prosecution, if the offender w ere found w ithin the territory of the United States; A n offense against a foreign nation involving the m anufacture, im portation, sale, or distribution of a controled substance (as such term is defined for the purpose of the Controlled Substances Act); and (d) An offense against a foreign nation involving bribery of a public official, or the m isappropriation, theft, or em bezzlem ent of public funds by or for the benefit of a public official. Al1 in violation of Title 18, United States Code, Section 1956(h).

3 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 3 of 8 FORFEITURE ALLEGATIONS The alegations of this Indictment are re-alleged and by this reference fuly incorporated herein for the purpose of alleging crim inal forfeiture to the U nited States of A m erica of certain property in which the defendant, SAM ER H. BARIU GE, RENATO J. RODRIGUEZ, and JUAN P. GRANDA, a/k/a içflecha,'' have an interest. Upon conviction of a violation of Title l 8, United States Code, Section 1956, or conspiracy to com m it such violation, the defendant shal forfeit to the United States of Am elica any W OPCI-Y 1Xa1 Or Personal,involved in such offense, and any property traceable to such property. All pursuant to Title 18, United States Code, Sections 982(a)(1), Title 21, United States Code, Section 853, and Title 28, United States Code, Section 2461(c). The property subject to forfeiture includes, but is not lim ited to, the follow ing: Real property located at M alibu at Pacific M arlin in San Juan del Sur, N icaragua', b) The contents of Suntrust Bank A ccount N um ber ending in 1504; The contents of Suntrust Bank A ccount N um ber ending in 1512; The contents of Suntnlst Balzk A ccount N um ber ending in 1520,. 9 The contents of Suntnlst Bank A ccount N um ber ending in 7779; and entry of a forfeiture moneyjudgment in an amount which represents a sum of m oney equal in value to any property, real or personal, involved in the com m ission of the violations a leged in this lndictm ent; If the property described above as being subject to forfeiture, as a result of any act or omission ofthe defendants, SAMERH.BARRAGE, RENATO J.RODRIGUEZ, and JUAN P. GRANDA, a/k/a çiflecha'' (a) camzot be located upon the exercise of due diligence', (b) has been transferred or sold to, or deposited with a third party; (c) has been placed beyond the jurisdiction of the Court;

4 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 4 of 8 (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to Title 2 1, United States Code, Section 8531), to seek forfeiture of any other property of the defendants, including but not lim ited to the follow ing'. a) Real property located at 8460 SW 84 Tenuce, M iami, FL 33143; b) Real property located at SW 76th Street, Miami, FL c) Fidelity Investments 401k Account in the name of Samer Barrage, ending in 3927; and d) One 2015 Porsche Macan Utility 4D, Vm # W P1AB2A58FLB71525, Florida plate PZ3IY. A l pursuant to Title l 8, United States Code, Section 982(a)(1), Title 18, and the procedures set forth in Title 21, U nited States Code, Section 853, m ade applicable by Title 18, United States Code, Section ) and Title 28, United States Code, Section 2461(c). A TRUE BILL S W..> ệ f.' x 1 '*'*'. jh we.' J ;' *' BE J G. EENBERG A ING UNIT D STATES ATTORNEY FOREPERSON #. f y F NCISCO R. MAD ASSISTANT UNITED STATES ATTORNEY 4

5 UNITED STATES DISTRICT CO URT Case 1:17-cr RNS Document SOUTHERN 12 DISTRICT Entered OF on FLORIDA FLSD Docket 03/23/2017 Page 5 of 8 UNITED STATES OF AM ERICA V. SAM ER BARRAGE, et ai. Defendants. / CASE NO. CERTIFICATE OF TRIAL ATTORNEY* Superseding Case Inform ation: Court Division: (select One) X Miami FTu Ke wib West FTp I do hereby certify that: 4. New Defendants) Yes No Number of New Defendants Total num ber of counts I have carefuly considered the alegations 9f the indictmqnt, the number of defendants, the number of Probable witnesses and the Iegal complexlties of the Indlctm ent/lnformation attached hereto. I am aware that thç information s u pplied oq this jtqtemeqt wil be relied upon by the Judges of this Court in seting thelr cal:ndars and schedulng crlm lnal trlals under the mandate of the Speedy Trial Act, Title 28 U.S.C. Sectlon Iqterpreter: (Yes qr No) No LIst Ianguage and/or dlalect This case wil take 30 days for the parties to try. 5. Please check appropriate category and type of ofense listed below: (Check only one) 0 to 5 days 6 to 10 days 11 to 20 days 21 to 60 days 61 days and over (Check only one) pgtty M! nor Mlsdem. Felony N - 6. Has this case been previously filed in this District Court? (Yes or No) No If yes: Judge: Case No. (Atach copy c) lsposltlve (?r eq Has a complalnt been filed In thls mater? (Yes or No) Yes If yej: Maglstrate Case No. 16-MJ GARBER', 17-MJ SIMO NTON Related M iscqlaneous numbers: Defendants) ln federal custody as of arc, efendantls) ln state custody as of Rule 20 from the Is ric o Is this a potential death penalty case? (Yes or No) MN D?es this case or gi inate from a mater pending in the Northern Region of the U.S. A torney's O fice prlor to October 14-, 2003? Yes X No 8. Dges this case originate from a ma ter pending in the Central Region of the U.S. A torney's O fice prlor to Septem ber 1, 2007:2 Yes X No *penalty Sheets) atached r CISCO.c a ra ASSISTANT UNITED STA S ATTORNEY Florida Bar No REV 4/8/08

6 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 6 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PENALTY SHEET Defendant's Name: SAMER H. BARRAGE Case No: Count #: 1 Conspiracy to Com m it M oney Laundering Title 18, United States Code, Section 1956(h) *M ax. Penalty: 20 Years' lm plisonm ent er efers only to possible term of incarceration, does not include possible fines, restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.

7 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 7 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PENALTY SHEET Defendant's Nam e: RENATO J. RO DRIG UEZ Case No: Count #: 1 Conspiracy to Com m it M oney Laundering Title 18, United States Code, Section 1956(h) *M ax. Penalty: 20 Years' Im plisonm ent

8 Case 1:17-cr RNS Document 12 Entered on FLSD Docket 03/23/2017 Page 8 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLOW DA PENALTY SHEET Defendant's Name: JUA N P. G RANDA, a.k.a., dlflecha' Case N o: Count #: l Conspiracy to Com m it M oney Laundering Title 18, United States Code, Seçtigp 19j6(h) *M ax. Penalty: 20 Y ears' Im prisonm ent er efers only to possible term of incarceration, does not include possible fines, restitution, special assessm ents, parole term s, or forfeitures that m ay be applicable.