Case 4:20-cr-00009-EKD Document 36 Filed 02/20/20 Page 1 of 4 CLERK'S

Pageid#: 299U.S. DIST. COURT

OFFICE
AT ROANOKE, VA
FILED

FEB 2 0 2020
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA
DANVILLE DIVISION

UNITED STATES OF AMERICA

v. Criminal No. 4'. :J_O CR., 09

ALEJANDRO ESCARCEGA-AVILA In violation of:
FRANCISCO ALVAREZ-ROSALES,
a/k/a "Meliton Rosales-Alvarez" 8 U.S.C. § 1326(a)
. MELITON ALVAREZ-ROSALES, a/k/a 18 u.s.c. § 922(g)(5)
"Francisco Alvarez-Consuelo" 18 U.S.C. § 924(a)(2)
NOE SALVADOR BECERRA- 18 U.S.C .. §§ 1956(a)(l)(A)(i) and (h)
GONZALEZ

INDICTMENT

The Grand Jury charges that:

COUNT ONE
18 U.S.C. § 1956(h)
Conspiracy to Commit Money Laundering

1. Beginning on an unknown date, but no later than in or about June 2018, and

continuing to in or about January 2020, in the Western District of Virginia and elsewhere, the

defendants, ALEJANDRO ESCARCEGA-AVILA, FRANCISCO ALVAREZ-ROSALES, a/k/a

Meliton Rosales-Alvarez, MELITON ALVAREZ-ROSALES, a/k/a Francisco Alvarez-

Consuelo, and NOE SALVADOR BECERRA-GONZALEZ, did knowingly and intentionally

combine, conspire, and agree with each other and with other persons known and unknown to the

Grand Jury to commit offenses against the United States in violation of Title 18, United States

Code, Section 1956, namely:

a. to knowingly conduct and attempt to conduct financial transactions

affecting interstate and foreign commerce, specifically the transfer, delivery, and
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exchange of United States Currency, which involved the proceeds of a specified unlawful

activity, that is, the distribution and manufacture of controlled substances, in violation of

Title 21, United States Code, Section 841(a) and conspiracy to distribute and manufacture

controlled substances, in violation of Title 21, United States Code, Section 846, with the

intent to promote the carrying on of specified unlawful activity, namely the distribution

and manufacture of controlled substances, in violation of Title 21, United States Code,

Section 841(a) and conspiracy to distribute and manufacture controlled substances, in

I
violation of Title 21, United States Code, Section 846, and that while conducting and

attempting to conduct such financial transaction the defendants knew that the property

involved in the financial transaction represented the proceeds of some form of unlawful

activity in violation of Title 18, United States Code, Section 1956(a)(l)(A)(i).

Manner and Means

2. As part of the conspiracy, members and affiliates of the Jalisco New Generation

Cartel (CJNG), a Mexican-based criminal organization controlling a significant portion of

narcotics trafficking in Mexico, transported cocaine hydrochloride, heroin, and marijuana, and

other controlled substances, into the United States from Mexico.

3. As part of the conspiracy, CJNG recruited individuals from Mexico to reside in

Axton, Virginia, to facilitate the distribution of controlled substances from CJNG throughout the

Mid-Atlantic region of the United States.

4. As part of the conspiracy, CJNG supplied individuals in Axton, Virginia, with

cocaine hydrochloride, heroin, and marijuana to further those purposes.

5. As part of the conspiracy, the defendants and their co-conspirators received large

amounts of United States currency that was payment for the controlled substances, and

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transmitted that currency to members and affiliates of CJNG based in Mexico.

6. All in violation of Title 18, United States Code, Section 1956(h).

COUNT TWO
8 U.S.C. § 1326(a)
Unlawful Reentry After Removal From the United States

7. On or about January 22, 2020, in the Western District of Virginia, the defendant,

ALEJANDRO ESCARCEGA-AVILA, an alien, was found in the United States after having

been removed therefrom on or about January 7, 2010, at or near Laredo, Texas, and not having

obtained the express consent of the Secretary of Homeland Security to reapply for admission to

the United States.

8. All in violation of Title 8, United States Code, Section 1326(a).

COUNT THREE
18 u.s.c. 922(g)(5)
Possession of a Firearm by an Illegal Alien

9. In or about January 2020, in the Western District of Virginia, the defendant,

ALEJANDRO ESCARCEGA-AVILA, knowing that he was an alien illegally and unlawfully in

the United States, knowingly possessed a firearm, that is a shotgun, which had been shipped and

transported in interstate and foreign commerce.

10. All in violation of Title 18, United States Code, Sections 922(g)(5) and 924(a)(2).

NOTICE OF FORFEITURE

11. Upon conviction of the offenses alleged in Count One, the defendants shall forfeit

to the United States any property, real or personal, involved in these offenses, or any property

traceable to such property, pursuant to 18 U.S.C. § 982(a)(l). The United States will seek a

forfeiture money judgment against the defendant in the amount equal to the value of any

property, real or personal, involved in this offense, or any property traceable to such property.

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12. If any of the property described above as being subject to forfeiture, as a result of

any act or omission of the defendant:

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 that cannot be divided without

difficulty;

the defendant shall forfeit to the United States any other property of the defendant, up to the

value of the property described above, pursuant to Title 21, United States Code,_Section 853(p).

A TRUE BILL this 2,..6 day of February, 2020.

s/ Grand Jury Foreperson

FOREPERSON
'

~iv~~
fo~ ROMAS T. CULLEN~
UNITED STATES ATTORNEY