SEALED UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS MIDLAND-ODESSA DIVISION

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1 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 1 of 7 IIR SEALED UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS MIDLAND-ODESSA DIVISION JU2, 2014 CLERK, u.s.iict COURT WESTERN D RICT OF TEXAS V) DEPUTY UNITED STATES OF AMERICA, JOE OCTAVIO GRANADO, JUAN ANTONIO MEZA, Plaintiff, CRIMINAL NO. INDICTMENT [Vio: 18 U.S.C Conspiracy; 18 U.S.C Wire Fraud] Defendants. THE GRAND JURY CHARGES: Description of the Fraudulent Scheme 1. At material times to the Indictment, Joe Octavio Granado was employed as a Sales Representative for SC Fuels located in Midland, Texas. Juan Antonio "Tony" Meza was the owner/operator of Red X Truck Stop located in Ector County, Texas. 2. As the Sales Representative, Granado was authorized to instruct SC Fuels dispatchers to deliver fuel to customers of SC Fuels. 3. At material times to the Indictment, BJ Services was a business located in Odessa, Texas that was a customer of SC Fuels.d BJ Services business model involved pressure pumping, well completion, production enhancement and pipeline services to the petroleum industry. BJ Services typically ordered from SC Fuels approximately three (3) loads every month, with each load containing about 7,500 gallons of fuel. 4. At material times to the Indictment, BJ Services operated as a subsidiary of Baker-I-Iughes, headquartered in Houston, Texas. Bill payments associated with BJ Services were

2 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 2 of 7 conducted through Baker-Hughes in Houston, Texas. 5. Beginning in late 2009, Granado began instructing an SC Fuels drive, J.Q., to divert one of the three loads of fuel that was destined for BJ Services, and instead deliver it to the Red X Truck Stop. Typically, a single load of fuel was about 7,500 gallons. 6. After J.Q. had madethe deliveries, Granado would provide a hand-written invoice to Meza for the fuel delivery. In turn, Meza would provide Granado with a check from the Red X company account for the fuel load. Granado charged Meza between $19,250 and $23,250 per load of 7,500 gallons, with an average of $21,453 per load. 7. By intentionally diverting the load to Red X, Granado would deceive both BJ Services and SC Fuels itself, thereby causing SC Fuels to send a bill to BJ Services for that same 7,500 gallons at a price of about $26,809 per load. BJ Services would in turn pay the bill to SC Fuels for the loads it received as well as the loads it did not receive. 8. In 2010, after the scheme began, Granado opened a new bank account that his wife did not know about so that he could deposit the money received from Meza into that account without her knowledge. 9. Each time SC Fuels in Midland sold a load of fuel, it would electronically notify SC Fuels corporate office in California. SC Fuels in Midland would then send a bill via to Baker-Hughes, the parent company of BJ Services, in Houston, Texas. Baker-Hughes would then execute a wire transfer of money from a Baker-Hughes bank account to a bank account belonging to SC Fuels in California. Thus, each time Granado fraudulently diverted a load of fuels, he caused SC Fuels to wire information to its corporate headquarters in California, which in turn caused a series of wire communications to Baker-Hughes and banks associated with each financial transaction.

3 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 3 of From approximately December 15, 2009 through April 18, 2012, Meza paid Granado approximately $774, for fuel that was owed to BJ Services but never delivered. SC Fuels invoiced BJ Services for the amount of fuel that Granado fraudulently diverted to Meza. BJ Services then paid approximately $965, for the fuel it never received. 11. During the timefrarne of the conspiracy, Granado made several large purchases. For example, in December 2011, approximately two years after the scheme began, Granado purchased a residence for $276,497. Similarly, in March 2012, Granado purchased a used BMW for approximately $20,000 in cash. Granado also purchased a truck for $28,000 in cash and a travel trailer for $15,000 in cash, both during the timeframe of the conspiracy. Granado also purchased a membership at Greentree Country Club, among other personal luxuries. COUNT ONE [18 U.S.C. 1349] Paragraphs 1 through ii of the "Description of Fraudulent Scheme" section of the Indictment are hereby incorporated as if set forth in full. That from on or about December 15, 2009 to April 18, 2012, in the Western District of Texas and elsewhere, the Defendants, JOE OCTAVIO GRANADO and JUAN ANTONIO MEZA, did combine, conspire, and confederate together for the purpose of executing a scheme and artifice to defraud and obtain money by means of materially false and fraudulent pretenses, representations, and promises, intentionally and knowingly transmitted and caused to be transmitted information via wire from Texas to other states which process caused writings, signs, and signals to be transmitted in interstate and foreign commerce, in violation of Title 18, United

4 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 4 of 7 States Code, Section All in violation of Title 18, United States Code, Section UNITED STATES OF AMERICA'S NOTICE OF DEMAND FOR FORFIEITURE I. Wire Fraud Violations and Forfeiture Statutes ETitle 18 U.S.C and 1349 subject to forfeiture pursuant to Title 18 U.S.C. 982(a)(2)(A) and Title 18 U.S.C. 981(a)(1)(C), made applicable to criminal forfeiture by Title 28 U.S.C See Fed. R. Crim. P As a result of the foregoing criminal violations set forth in Count One, the United States of America gives notice to Defendants Joe Octavio Granado and Juan Antonio Meza of its intent to seek forfeiture of the property described below upon conviction pursuant to Title 18 U.S.C. 982(a)(2)(A) and Title 18 U.S.C. 98 l(a)(l)(c), made applicable to criminal forfeiture by Title 28 U.S.C. 2461, which state the following: Title 18 U.S.C Criminal forfeiture (a) (2) The court, in imposing sentence on a person convicted of a violation of, or a conspiracy to violate- (A) section of this title, affecting a financial institution... shall order that the person forfeit to the United States any property constituting, or derived from, proceeds the person obtained directly or indirectly, as the result of such violation. Title 18 U.S.C Civil forfeiture (a)(1) The following property is subject to forfeiture to the United States: (C) Any property, real or personal, which constitutes or is derived from proceeds traceable to... any offense constituting "specified unlawful activity" (as defined in section 1 956(c)(7) of this title), or a conspiracy to commit such offense. This notice of forfeiture includes but is not limited to the property described below. II. Money Judgment Money Judgment: A sum of money equal to Nine Hundred Sixty Five Thousand One Hundred Forty Two Dollars and Eight Six Cents ($965,142.86) that represents proceeds obtained directly or indirectly as a result of the violations set forth in the counts described above and for which Defendants Joe Octavio

5 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 5 of 7 Granado and Juan Antonio Meza are jointly and severally liable. III. Substitute Assets If any of the money judgment described above as being subject to forfeiture for violations of Title 18 U.S.C. above: 1343 and 1349, as a result of any act or omission of the Defendants named a. cannot 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; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States of America to seek forfeiture of any other property, up to the value of said money judgment, as substitute assets pursuant to Title 21 U.S.C. 853(p) and Fed. R. Crim. P. 32.2(e)(1). A TRUE BILL. Oriqjn signed by the ;rsflfl ofthe.dj FORERSON OF THE GND JURY ROBERT PITMAN UNITED STATES ATTORNEY AUST M.BERRY Assistant United States Attorney

6 Sealed PERSONAL DATA SHEET (REDACTED) UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS COUNTY: Ector DIVISION: MIDLAND/ODESSA JUDGE: DATE: June 25, 2014 MAG CT #: FBI #: CASE NO: MO-14-CR- DEFENDANT: Joe Octavio Granado ASSISTANT U.S. ATTORNEY: ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXX CITIZENSHIP: INTERPRETER NEEDED LANGUAGE: DEFENSE ATTORNEY: EMPLOYED APPOINTED DEFENDANT IS: Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 6 of 7 M014CR153 DUB: XX)O(X)O(XXX DATE OF ARREST: BENCH WARRANT: XXX PROBATION OFFICER: NAME AND ADDRESS OF SURETY: YOUTH CORRECTIONS ACT APPLICABLE: No PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct USC 1349 Conspiracy to commit Mail and Wire fraud OFFENSE IS: FELONY MAXIMUM SENTENCE: Ct. 1 - A term of imprisonment not to exceed 20 years; a term of supervised release not to exceed 3 years; a fine not to exceed $250,000; and a mandatory $100 special assessment. PENALTY IS MANDATORY: As stated above. REMARKS: AGENT: A. Lamar Pruitt, FBI WDT-Cr-3

7 Case 7:14-cr RAJ Document 1 Filed 06/25/14 Page 7 of 7 PERSONAL DATA SHEET (REDACTED) UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS Sealed MC 14 CR 153 COUNTY: Ector DIVISION: MIDLAND/ODESSA JUDGE: DATE: June25, 2014 MAGCT#: FBI#: CASE NO: MO-14-CR- DEFENDANT: Juan Antonio Meza ASSISTANT U.S. ATTORNEY: ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXX CITIZENSHIP: INTERPRETER NEEDED LANGUAGE: DEFENSE ATTORNEY: EMPLOYED APPOINTED DEFENDANT IS: DOBXXXXXXXXXX DATE OF ARREST: BENCH WARRANT: XXX PROBATION OFFICER: NAME AND ADDRESS OF SURETY: YOUTH CORRECTIONS ACT APPLICABLE: No PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct USC 1349 Conspiracy to commit Mail and Wire fraud OFFENSE IS: FELONY MAXIMUM SENTENCE: Ct. 1 A term of imprisonment not to exceed 20 years; a term of supervised release not to exceed 3 years; a fine not to exceed $250,000; and a mandatory $100 special assessment. PENALTY IS MANDATORY: As stated above. REMARKS: AGENT: A. Lamar Pruitt, FBI WDT-Cr-3