Case 3:13-cr-04517-DMS Document 29 Filed 05/20/15 PageID.

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1
FILED
2 MAY 2 0 lOI5'
CLERK. uS. Q·'T'ICT COuRT
3 SOUTHERN DISTRICT CF CALIFC~"lI.:\
BY DEPUTY
4 UNITED STATES DISTRICT CO

5 SOUTHERN DISTRICT OF CALIFORNIA

6
UNITED STATES OF AMERICA, Case No.: 13-CR-4517-DMS
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Plaintiff, SUPERSEDING
8 INFORMATION
v.
9 Title 21, U.S.C., Sections 952, 960
JOSE RODRIGO ARECHIGA-GAMBOA, and 963 - Conspiracy to Import
10 a.k.a. "Chino Antrax," C~caine and Marijuana (Felony);
a.k.a. "Norberto Sicairos-Garcia," Title 21, U.S.C., Sec. 853 -
11 Criminal Forfeiture
Defendant.
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13 The United States Attorney charges:
14 Count 1
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Beginning no later than in or about May 2005 and continuing up to and including
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17 December 20, 2013, within the Southern District of California, and elsewhere, defendant

18 JOSE RODRIGO ARECHIGA-GAMBOA, a.k.a. "Chino Antrax," a.k.a. "Norberto

19
Sicairos-Garcia," did knowingly and intentionally conspire with other persons, to import
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21 5 kilograms and more of cocaine, a Schedule II Controlled Substance; and 1000
22 kilograms and more of marijuana; a Schedule I Controlled Substance; into the United
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24 States from a place outside thereof; in violation of Title 21, United States Code, Sections

25 952,960, and 963.

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 Case 3:13-cr-04517-DMS Document 29 Filed 05/20/15 PageID.57 Page 2 of 3

1 Criminal Forfeiture Allegations

2 1. The allegations contained in this Superseding Information are realleged and
3 by reference fully incorporated herein for the purpose of alleging forfeiture to the United
4 States of America pursuant to the provisions of Title 21, United States Code, Section 853.
5 2. As a result of the commission of the felony offense alleged in this
6 Superseding Information, said violations being punishable by imprisonment for more
7 than one year and pursuant to Title 21, United States Code, Sections 853(a)(I) and
8 853(a)(2), defendant JOSE RODRIGO ARECHIGA-GAMBOA, a.k.a. "Chino Antrax,"
9 a.k.a. "Norberto Sicairos-Garcia," shall, upon conviction, forfeit to the United States all
10 his rights, title and interest in any and all property constituting, or derived from, any
11 proceeds any defendant obtained, directly or indirectly, as the result of the felony offense
12 alleged in this Superseding Information, and any and all property used or intended to be
13 used in any manner or part to commit and to facilitate the commission of the violation
14 alleged in this indictment.
15 3. If any of the above-described forfeitable property, as a result of any act or
16 omission ofthe defendant:
17 a. cannot be located upon the exercise of due diligence;
18 b. has been transferred or sold to, or deposited with, a third party;
19 c. has been placed beyond the jurisdiction ofthe COUlt;
20 d. has been substantially diminished in value; or
21 e. has been commingled with other property which cannot be subdivided
22 without difficulty;
23 II
24 II
25 II
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 Case 3:13-cr-04517-DMS Document 29 Filed 05/20/15 PageID.58 Page 3 of 3

1 it is the intent of the United States, pursuant to Title 21, United States Code, Section
2 853(P), to seek forfeiture of any other property of the defendant up to the value of the
3 said property listed above as being subject to forfeiture.
4 All in violation of Title 21, United States Code, Section 853.
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6
7
LAURA E. DUFFY
8 United States Attorney
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10 DATED ~JC111S-
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