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; 1 1 1 1 UNITED STATES OF AMERICA, ) ) Plaintiff,) ) v. ) ) BENJAMIN ARELLANO-FELIX (1), ) aka "El Senor", ) aka "Min", ) RAMON ARELLANO- FELIX (), ) aka "Colores", ) EDUARDO ARELLANO-FELIX (), ) aka "El Gualin", ) aka "El Doctor", ) aka "El Profe", ) ) Defendants. ) ----------------------------) The grand jury charges: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA April Grand Jury Count 1 Criminal Case No. crk I N D I C T MEN T (nd superseding) Title, U.S.C, Secs., 0, and - Conspiracy to Import Cocaine; Title, U.s.C., Secs. and 1(a) (1) - Conspiracy to Distribute Cocaine; Title, U.S.C., Sec. 1(a) (1) - Distribution of Cocaine; Title, U.S.C., Sec. - Aiding and Abetting Beginning at a date unknown and continuing up to and including the date of this Indictment, within the Southern District of California, and elsewhere, defendants BENJAMIN ARELLANO-FELIX, aka "El Senor," aka "Min," RAMON ARELLANO-FELIX, aka "Colores," and EDUARDO ARELLANO-FELIX, aka "El Gualin," aka "El Doctor," aka "El Profe," (hereafter defendants) and co-conspirators Ismael Higuera-Guerrero, aka "Mayel," aka "Clave privada," (charged elsewhere), LED:kro:San Diego /0/

1 1 1 1 Gilberto Higuera-Guerrero, aka "Gil," aka "Gilillo," Everardo Arturo Paez-Martinez, aka Arturo Paez-Martinez, aka "Quiti," aka "EI Pelon," aka "EI Moro," aka "Carlos," aka "Juan Carlos Flores-Menchaca," (charged elsewhere); and David Barron-Corona, aka "CH," aka "Charlie Logan," aka "Pancho," (previously charged elsewhere, now deceased) (hereafter coconspirators), did knowingly and intentionally conspire together, and with others known and unknown to the grand jury, to import cocaine, a Schedule controlled substance, and marijuana, a Schedule I controlled substance, in violation of Title, united states Code, sections, 0 and. MANNER AND MEANS Defendants and their co-conspirators, known and unknown, use the following manner and means, among others, in order to carry out the purpose of this conspiracy, to import cocaine and marijuana into the united States: 1. At all times relevant to this Indictment, defendants and their co-conspirators were members of a large, powerful and violent drug trafficking organization based in Baja California, Mexico, and known as the Arellano-Felix Organization CAFO) and the Tijuana Cartel. The AFO I s principal business is the importation and distribution of controlled substances, including cocaine and marijuana, from Mexico into the United states. The three Arellano- Felix Brothers named as defendants are the highest leaders of the AFO; together they are known as "The Arellanos" and "The Brothers." The co-conspirators named herein, are also among the highest leaders of the AFO. The defendants and / /

1 1 1 1 co-conspirators named herein, and other co-conspirators not named herein, perform various roles and duties within the AFO.. Defendant BENJAMIN ARELLANO, aka "El Senor," aka "Min," is one of the highest leaders within the AFO hierarchy. Among other duties, BENJAMIN ARELLANO supervises all of the AFO leaders who, in turn, supervise other groups within the AFO which carry out all of the drug related activities of the AFO. These activities include drug trafficking in Mexico and the United states; collecting and laundering drug proceeds; bribing officials to obtain protection and favor; and, enforcing AFO interests by murdering, kidnaping, torturing, threatening and gathering intelligence about socalled "enemies" of the AFO. "Enemies" of the AFO include disobedient members of the AFO, rival drug traffickers, suspected informants, law enforcement officials who investigate the AFO, and news reporters who draw unfavorable attention to the AFO.. Defendant RAMON ARELLANO, aka "Colores," is one of the highest leaders of the AFO. Among other duties, RAMON ARELLANO enforces the interests of the AFO by killing "enemies" of the AFO and by directing others to do so. RAMON ARELLANO supervises other AFO leaders who lead groups of gunmen who are bodyguards and assassins for the AFO. These gunmen protect AFO leaders and activities; they also enforce the interests of the AFO by attacking and killing its "enemies."

1 1 1. Defendant EDUARDO ARELLANO, aka "EI Gualin," aka "EI Doctor," aka "EI Profe," is one of the highest leaders of the AFO. Among other duties, EDUARDO ARELLANO advises BENJAMIN ARELLANO on important AFO matters, including decisions to kill someone.. co-conspirator Ismael Higuera-Guerrero, aka "Mayel," aka "Clave Privada," is one of the highest leaders of the AFO. Among other duties, Ismael Higuera supervises transportation groups which transport tons of cocaine and marijuana through Mexico, into the united states, and on to Los Angeles where it is distributed throughout the United states. Ismael Higuera also supervises the collection and transportation of drug proceeds from the United states to Mexico, the bribery of corrupt officials who protect the activities and members of the AFO, and the collection of 1 intelligence information through wiretaps. Ismael Higuera also supervises groups of AFO gunmen and enforces the interests of the AFO by killing, kidnaping and torturing "enemies" of the AFO and by directing others to do so.. Co-conspirator Gilberto Higuera-Guerrero, aka "Gil," aka "Gilillo," is one of the highest leaders of the AFO. Gilberto Higuera works under the direction of his brother, Ismael Higuera, and assists in the activities described in paragraph.. Co-conspirator Everardo Arturo Paez-Martinez, aka "Arturo Paez-Martinez," aka Quiti," aka "EI Pelon," aka "EI Moro," aka "Carlos," aka "Juan Carlos Flores-Menchaca," is one of the highest leaders of the AFO. Among other duties, Paez supervised drug transportation groups which transported

1 1 1 1 cocaine through Mexico, into the United States and on to Los Angeles for distribution throughout the united states. Paez also supervised the collection and transportation of drug proceeds from the United states to Mexico.. Co-conspirator David Barron-Corona, aka "CH," aka "Charlie Logan," aka "Pancho," was, until his death in November, one of the highest leaders of the AFO. Among other duties, Barron was a gunman for the AFO who worked under the direction of RAMON ARELLANO. Barron also recruited and supervised gang members from the Logan Heights neighborhood of San Diego, California, to be gunmen for the AFO. These gunmen protected AFO leaders and activities and enforced the interests of the AFO by killing its "enemies." Barron also assisted the AFO in drug trafficking.. Defendants and their co-conspirators meet with Colombian drug traffickers to arrange the transportation of cocaine from Colombia, through Mexico, into the united states and to the Los Angeles area, where the cocaine is distributed to other parts of the united states.. Defendants and their co-conspirators receive at Mexican seaports, airports, and clandestine areas, large shipments of cocaine which are transported within Mexico to locations along the border of Mexico and the United states. They also tax other drug trafficking groups who want permission to operate in AFO territory.

. Defendants and their co-conspirators smuggle controlled substances, including cocaine and marijuana, into the united states by various methods including vehicles with trunks or secret compartments, boats, backpackers and corrupt officials. 1. Defendants and their co-conspirators bribe others, including corrupt Mexican officials who protect the arrival of cocaine in Mexico and the transportation of cocaine and marijuana within Mexico. These corrupt officials also 1 1 1 1 inform the AFO of the activities of law enforcement and of rival drug trafficking groups who are operating without AFO permission.. Defendants and their co-conspirators collect, store, and transport, within the united states and Mexico, united states currency which is the proceeds of drug trafficking. 1. Defendants and their co-conspirators obtain vehicles to use as load vehicles to transport drugs and cash in the United states and Mexico; vehicles. they also recruit drivers for the 1. Defendants and their co-conspirators obtain houses and other locations in Mexico and the united states which they use to store drugs, guns, money, vehicles, and as bases for their operations. 1. Defendants and their co-conspirators maintain listening centers in Mexico which are used to eavesdrop on communications of AFO members, rival drug traffickers, and law enforcement officials in order to monitor their activities and obtain information useful to the AFO.

. Defendants and their co-conspirators obtain and use armored vehicles which are specially built with guns, bulletproof glass, and other sophisticated equipment which can be used to attack or evade law enforcement officials and rival traffickers.. Defendants and their co-conspirators sometimes travel in Mexico in convoys of armored and other vehicles which block traffic for clear passage and which guard areas used for meetings.. Defendants and their co-conspirators recruit, organize, train and direct groups of gunmen who work as bodyguards 1 for AFO leaders, AFO activities, and Mexican officials. 1 1 1 These gunmen also work as assassins who enforce AFO interests by killing, kidnaping and torturing disobedient AFO members, rival drug traffickers, suspected informants, law enforcement officials, and members of the press.. Defendants and their co-conspirators obtain, transport, carry, use and train with weapons to further AFO activities.. Defendants and their co-conspirators obtain and use military uniforms and law enforcement identifications, badges and to conduct AFO activities.

1 1 1 1. Defendants and their co-conspirators meet among themselves, with other traffickers, and with corrupt officials to discuss AFO business. They also discuss AFO business over communications equipment, including radios with encryption devices; they use various secret codes and nicknames to disguise their identities and the meaning of their conversation. OVERT ACTS In furtherance of the conspiracy and to effect the objects thereof, defendants and their co-conspirators, known and unknown, committed the following overt acts, among others, within the Southern District of California and elsewhere: The Brothers 1. In or about July, defendants BENJAMIN ARELLANO and RAMON ARELLANO and co-conspirators Ismael Higuera and Gilberto Higuera, and AFO bodyguards traveled to Culiacan, Sinaloa, Mexico for the purpose of meeting with the leaders of other drug trafficking organizations.. In or about November,, defendant RAMON ARELLANO and co-conspirator David Barron and other AFO gunmen had a shootout with rival drug traffickers at Christine's Discotheque, in Puerto Vallarta, Jalisco, Mexico.. In or about January, in Mexico, defendant RAMON ARELLANO and co-conspirator Ismael Higuera gave orders to kill AFO bodyguard "Juvenal," who had shot and killed another AFO bodyguard.

1 1 1 1 // //. In or about May,, defendant RAMON ARELLANO and coconspirator David Barron and other AFO gunmen tried to locate and kill Joaquin Guzman-Loera, aka "Chapo" Guzman, the leader of a rival drug trafficking group, which attempt resulted in a shootout which killed Juan Cardinal Posados- Ocampo, at the airport in Guadalajara, Jalisco, Mexico.. In or about November/December,, in Los Angeles, California, defendant RAMON ARELLANO and co-conspirator Arturo Paez, aided and abetted in the distribution of 0 kilograms of cocaine.. In or about spring/summer of, defendant RAMON ARELLANO and co-conspirator Arturo Paez arranged to transport by plane approximately 0 kilograms of cocaine from Colombia to Mexico.. In or about July,, in San Diego, California, defendant RAMON ARELLANO and co-conspirator Arturo Paez aided and abetted in the distribution of 0 kilograms of cocaine.. In or about November,, defendant BENJAMIN ARELLANO and co-conspirators Ismael Higuera and Gilberto Guerrero arranged to transport by plane approximately - tons of cocaine from Colombia to a clandestine landing strip outside of La Paz, Mexico.. In or about July,, defendant RAMON ARELLANO and other AFO gunmen ambushed "enemies" of the AFO in a shootout which killed several people including Mexican military officials in Zapopan, Jalisco, Mexico.

1 1 1 1. In or about March, defendants BENJAMIN ARELLANO, RAMON ARELLANO and EDUARDO ARELLANO gave the "green light" (authorization) to kill an AFO associate who they suspected of cooperating with law enforcement. lhe Higuera Group. In or about 1, co-conspirator Ismael Higuera directed others to kidnap a drug trafficker who worked for another organization and to bring the trafficker to a location outside of Mexicali, Mexico, where Ismael Higuera was directing the torture of others; while the trafficker watched others being tortured, Ismael Higuera asked the trafficker to transport cocaine for him. 1. On or about November, 1, co-conspirator Ismael Higuera directed others to transport approximately 01 kilograms of cocaine, which was hidden under crates inside a semi-tractor trailer and was seized by law enforcement officers at the Border Patrol checkpoint in Salton City, California.. On or about February,, co-conspirator Ismael Higuera directed others to transport approximately 1 kilograms of cocaine, which was inside the trunks, door panels, hoods and under the seats of four cars and was seized by law enforcement officers in Calexico, California. 1. On or about February -,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was delivered in a van to a field in El Centro, California, was transferred to a truck and hidden under bales of hay, and was delivered to a trucking company in the area of Los Angeles, California.

1 1 1 1 1. On or about February,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was delivered in a van to a field in El Centro, California, was transferred to a hay truck, and was seized by law enforcement officers in El Centro, California. 1. On or about March,, co-conspirator Ismael Higuera directed others to transport approximately 0 kilograms of cocaine, which was inside boxes in a tractor-trailer at a truck lot and was seized by law enforcement officers in Calexico, California.. On or about March,, co-conspirator Ismael Higuera directed others to transport approximately $,0, which was inside the trunk of a car, and to store approximately $1,,.1, which was inside a stash house, which were both drug proceeds and were seized, together with weapons, by law enforcement officers in Baldwin Park, California.. On or about June,, co-conspirator Ismael Higuera directed others to store approximately $1,1,, which was inside a stash house and was seized, together with weapons, by law enforcement officers in Downey, California.. In or about December,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine and kilograms of marijuana, which was later delivered to Whittier, California, where law enforcement officers seized it together with approximately $,, and weapons.

1 1 1 1. In or about January, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was inside false wall compartments of a semi-tractor trailer, and was delivered to Indio, california, where law enforcement officers seized it.. On or about February,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was delivered in a yellow van to calexico, California, transferred to a truck, and delivered to a house in ontario, California, where law enforcement officers seized it.. In or about April, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was delivered in a yellow van to Calexico, California, transferred to a truck, and delivered to a restaurant in Rancho cucamonga, California, where law enforcement officers seized it, together with $,.. On or about November,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was delivered to a house in Huntington Park, California, where law enforcement officers seized it, together with weapons.. On or about November,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was inside the cab of a semitractor trailer and was seized by law enforcement officers at the Calexico Port of Entry, California.

1 1 1 1 S. In or about December or January, co-conspirator Ismael Higuera received approximately 0 kilograms of cocaine in Mexicali, Mexico, and directed one of his workers to smuggle it into the united states.. On or about January 1,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was inside the dashboard of a Honda automobile and was seized by law enforcement officers at the Calexico Port of Entry, California.. On or about March,, co-conspirator Ismael Higuera and AFO gunmen engaged in a shootout with Mexican officials in Tijuana, Baja California, Mexico.. On or about June,, co-conspirator Ismael Higuera directed others to transport approximately 00 kilograms of cocaine, which was smuggled across the border and delivered to a stash house in Rancho CUcamonga, California, where law enforcement officials seized it, together with more kilograms of cocaine.. On or about June 1,, co-conspirator Ismael Higuera directed others to transport approximately 01 kilograms of cocaine, which was smuggled across the border and delivered to a stash house in west Covina, California, where law enforcement officials seized it with an additional kilograms of cocaine. 0. On or about November,, co-conspirator Ismael Higuera directed others to transport approximately 0 kilograms of cocaine, which was inside a compartment in the bed of a pickup truck and was seized by law enforcement officers on Interstate in Imperial County, California.

1 1 1 1 1. On or about January 1,, co-conspirator Ismael Higuera directed others to transport approximately $00,000 from a stash house in Downey, California, to a stash house in Mexicali, Baja California, Mexico.. On or about January 1,, co-conspirator Ismael Higuera directed others to transport approximately kilograms of cocaine, which was smuggled across the border and delivered to Downey, California.. On or about May 1,, co-conspirator Ismael Higuera directed others to transport approximately $,1 in drug proceeds which were inside a spare tire under the rear floorboard of a car and were seized by law enforcement officers in Palm springs, California.. On or about May,, co-conspirator Ismael Higuera directed others to transport approximately $,1 in drug proceeds which were inside the rear quarter panel of a car and were seized by law enforcement officers at the Calexico Port of Entry, California, en route to a stash house in Mexicali, Baja California, Mexico.. In or about January, co-conspirator Ismael Higuera directed others to transport approximately 1 kilograms of cocaine to Los Angeles, where the cocaine was later seized in Fontana, California. The Paez Group. In or about, co-conspirator Arturo Paez directed others to transport and distribute cocaine in the united states and to return the drug proceeds to him in Tijuana, Baja California, Mexico.

1 1 1 1. In or about April-July 1, co-conspirator Arturo Paez directed others to receive in Fontana, California, approximately 0-1 kilograms of cocaine, of which approximately kilograms were later "fronted" to a customer.. In or about May 1, co-conspirator Arturo Paez directed others to distribute cocaine, of which approximately kilograms were seized by law enforcement officers in Coronado, california; thereafter, Paez held one of his workers responsible for payment for the loss.. In or about July 1, co-conspirator Arturo Paez received one large duffle bag, which had been transported from the united states to Tijuana, Baja california, Mexico, and which was filled with united states currency which was the proceeds of drug trafficking. 0. In or about August or September 1, co-conspirator Arturo Paez directed others to unload a bus containing approximately 0 kilograms of cocaine, to transport the cocaine in a pickup truck, to store the cocaine in a house in San Diego, California, and to distribute the cocaine to others. 1. In or about November 1, co-conspirator Arturo Paez directed others to distribute cocaine, of which approximately kilograms were seized by law enforcement officers in Jefferson County, Missouri; thereafter, Arturo Paez and David Barron told one of their workers that he was responsible for payment of the loss.

1 1 1 1. In or about November 1, co-conspirator Arturo Paez directed others to pick up hundreds of kilograms of cocaine in a parking lot in Chula Vista, California, and to distribute the cocaine to others.. In or about November 1, co-conspirator Arturo Paez directed others to pick up a truck loaded with hundreds of kilograms of cocaine at the Palomar Trolley Station in Chula Vista, California, to unload the cocaine according to a certain method, and to distribute the cocaine to others.. In or about January, co-conspirator Arturo Paez directed others to pick up a truck containing cocaine in Chula Vista, California, to unload the cocaine at a ranch in Winchester, California, and to distribute the cocaine to others.. In or about January, co-conspirator Arturo Paez directed others to pick up a second truck containing cocaine in Chula Vista, California, to unload the cocaine at a ranch in Winchester, California; and to distribute the cocaine to others.. On or about February,, co-conspirator Arturo Paez directed others to be ready to receive a truck loaded with cocaine, which never arrived because law enforcement officers seized the truck en route, in Campo, California, with approximately kilograms of cocaine.. On or about February,, co-conspirator Arturo Paez directed others to be ready to receive a truck loaded with cocaine, which never arrived because law enforcement officers seized the truck en route, in Campo, California, with approximately 1 kilograms of cocaine.

1 1 1 1. On or about May,, co-conspirator Arturo Paez directed others to be ready to receive a load of cocaine being smuggled across the border, which never arrived because law enforcement officers seized approximately kilograms of cocaine from a group of backpackers at a junk yard in otay Mesa, California.. In or about March or April, co-conspirator Arturo Paez directed others to deliver approximately 00 kilograms of cocaine to "Emiliano" at a specific pager number in the Los Angeles, California, area. 0. In the winter of, co-conspirator Arturo Paez and others flew to Colombia to meet cocaine traffickers and to discuss the transportation of cocaine from Colombia to Mexico. 1. In or about November or December, co-conspirator Arturo Paez directed others to pick up approximately 0 kilograms of cocaine in the united states, distribute it to others, and return the proceeds to Arturo Paez in Tijuana.. In or about April, co-conspirator Arturo Paez directed others to transport drug proceeds from Kentucky to San Diego, California.. In or about July, co-conspirator Arturo Paez directed others to smuggle approximately 0 kilograms of cocaine, which was part of the 0 kilogram load, into the United States, to store the cocaine, and to transport it to La Jolla, where law enforcement officials seized the cocaine on July,.

1 1 1 1. On or about May,, co-conspirator Arturo Paez directed others to transport from Los Angeles, California, to New York, approximately kilograms of cocaine, which law enforcement officers seized en route in Illinois. Xhe Barron/Logan Group. In or about late 1, and in early, co-conspirator David Barron discussed with others the purchase of trucks which were used by the AFO to transport cocaine into the united states.. In or about April,, co-conspirator David Barron directed Logan gang members to kill Jose Luis Cruz, aka "cracks," in San Diego, California.. On or about September 1,, Logan gang members had a shootout with Mexican military officials in an attempt to defend an AFO safe house in culiacan, Sinaloa, Mexico. Count Beginning at a date unknown, and continuing up to and including the date of defendant's arrest, within the southern District of California and elsewhere, defendants BENJAMIN ARELLANO-FELIX, aka "EI Senor," aka "Min," RAMON ARELLANO-FELIX, aka "Colores," EDUARDO ARELLANO-FELIX, aka "EI Gualin," aka "EI Doctor," aka "EI Profe" (hereafter defendants) and co-conspirators Ismael Higuera-Guerrero, aka "Mayel," aka "Clave Privada," (charged elsewhere) i Gilberto Higuera-Guerrero, aka "Gil," aka "Gilillo," Everardo Arturo Paez- Martinez, aka Arturo Paez-Martinez, aka "Quiti," aka "EI Pelon," aka "EI Moro," aka "Carlos," aka "Juan Carlos Flores-Menchaca," (charged elsewhere), and David Barron-Corona, aka "CH," aka "Charlie Logan," aka "Pancho," (previously charged elsewhere, now deceased), (hereafter

1 1 1 1 co-conspirators), did knowingly and intentionally conspire together, and with others known and unknown to the grand jury, to possess with intent to distribute cocaine, a Schedule controlled substance, and marijuana, a Schedule I controlled substance; in violation of Title, United States Code, sections and l(a) (1). MANNER AND MEANS Defendants and their co-conspirators, known and unknown used the Manner and Means alleged in Count 1 above (which are incorporated herein by reference), among others, in order to carry out the purpose of this conspiracy, to possess cocaine and marijuana with intent to distribute it in the United States. OYERT ACTS In furtherance of the conspiracy and to effect the objects thereof, defendants and their co-conspirators, known and unknown, committed the Overt Acts alleged in Count 1 above, (which are incorporated herein by reference), among others, within the Southern District of California and elsewhere.

1 1 1 Count On or about July,, within the Southern District of California, defendant RAMON ARELLANO-FELIX, aka "Colores," and coconspirators Everardo Arturo Paez-Martinez, aka "Arturo Paez- Martinez," aka "EI Morro," aka "EI Pelon, aka "Quiti," aka "Carlos," aka "Juan Carlos Flores Menchaca," and Gonzalo Sanchez-Castro, aka "Chalo, Jorge Granado-Alonso, aka "Chi Chij" Raul Jaime Reyes, aka "Olivia;" Luis Roberto Zapata-Buitron, aka "copete," each charged elsewhere, did knowingly and unlawfully distribute and aid and abet in the distribution of, approximately 0 kilograms of cocaine, a Schedule controlled substance, in violation of Title, united states Code, Section 1 (a) (1), and Title, united states Code, Section. DATED: October,. A TRUE BILL 1 CHARLES G. La BELLA united States Attorney By: Foreperson Assistant united States Attorney