FI L ED IN CLERKS OFFICE

US DISTRICT COURT EDNY

MAR 1 4 2018 BROOKLYN OFFICEMEGLKGJMSAS

F 2017ROl308

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK

- - X

UNITED STATES OF AMERICA S U PERSEDI N G INDICTMENT

- against -Cr No l 7-390 (S-l) (RJD)

VICTOR AGOSTO (T 18 USC sectsect 924(c)(l )(A)(i) also known as Bebo 924(d)( l) 982(a)(l ) 982(b)( l)

ENRIQUE LAPORTE 100l(a)(2) 1956(h) 2 and 3551 etlli

also known as Chiquito T 21 USC sectsect 841(b)(l )(A)i) 846 LUIS LOPEZ 853(a) and 853(p) T 28 USC

also known as Lou sect 246l(c)) ZAIDA LOPEZ PHILIPPE MEDINA CARLOS MATEO CLARISSA VASQUEZ

also known as Clari PETER VAS UEZ and

Defendants

- - X

THE GRAND JURY CHARGES

COUNT ONE (Conspiracy to Distribute and Possess with Intent to Distribute Heroin)

I In or about and between January 2010 and February 2017 both

dates being approximate and inclusive within the Eastern District ofNew York and

elsewhere the defendants VICTOR AGOSTO also known as Bebo ENRIQUE

LAPORTE also known as Chiquito LUIS LOPEZ also known as Lou ZAIDA

2

LOPEZ PHILIPPE MEDINA CARLOS MA TEO CLARISSA VASQUEZ also known

as Clari PETER VASQUEZ and

together with others did knowingly and intentionally conspire to distribute and possess

with intent to distribute a controlled substance which offense involved a substance

containing heroin a Schedule I controlled substance contrary to Title 21 United States

Code Section 841 (a)(l ) The amount ofheroin involved in the conspiracy attributable

to each of the defendants as a result ofhis or her own conduct and the conduct ofother

conspirators reasonably foreseeable to him or her was one kilogram or more of a

substance containing heroin

(Title 2 1 United States Code Sections 846 and 841 (b )(I )(A)(i) Title 18

United States Code Sections 3551 et seq)

COUNT TWO (Use ofFirearms In Connection with a Drug Trafficking Crime)

2 In or about and between January 2010 and February 2017 both

dates being approximate and inclusive within the Eastern District ofNew York and

elsewhere the defendants VICTOR AGOSTO also known as Bebo LUIS LOPEZ

also known as Lou and PETER VASQUEZ together with others did knowingly and

intentionally use and carry one or more firearms during and in relation to a drug

trafficking crime to wit the crime charged in Count One and did knowingly and

intentionally possess such firearms in furtherance ofsaid drug trafficking crime

(Title 18 United States Code Sections 9124(c)(l )(A)(i) 2 and 3551 et seq)

3

COUNT THREE (Conspiracy to Launder Money)

3 In or about and between December 2011 and July 2017 both dates

being approximate and inclusive within the Eastern District ofNew York and elsewhere

the defendants LUIS LOPEZ also known as Lou CLARISSA VASQUEZ also known

as Clari and PETER VASQUEZ together with others did knowingly and intentionally

conspire to conduct one or more financial transactions in and affecting interstate and

foreign commerce to wit the transfer and delivery of United States currency which in

fact involved the proceeds of specified unlawful activity to wit narcotics trafficking in

violation of Title 21 United States Code Section 84la) knowing that the property

involved in the financial transactions represented the proceeds of some form ofunlawful

activity and (a) with the intent to promote the carrying on of the specified unlawful

activity and (b) knowing that the financial transactions were designed in whole and in

part to conceal and disguise the nature the location the source the ownership and the

control of the proceeds of the specified unlawful activity contrary to Title 18 United

States Code Sections 1956(a)l)(A)(i) and 1956(a)(l)(B)(i)

(Title 18 United States Code Sections 1956(b) and 3551 et seq)

COUNTFOUR (Making a FaJse Statement)

4 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

4

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that Luis Lopez also known as Lou and Peter Vasquez had no

involvement in her attempt to reclaim approximately $301 400 in United States currency

seized on or about June 11 2014 from a vehicle in Pennsylvania when in fact as the

defendant then and there well knew and believed Lopez and Vasquez had been involved

in the defendants attempt to reclaim said currency

(Title 18 United States Code Sections 100I(a)(2) and 3551 et seq)

COUNT FIVE (Making a False Statement)

5 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau oflnvestigation in that the

defendant falsely stated that the defendant had not made any payment on any vehicle

associated with the defendant or the defendants farnily members since July 26 2017

when in fact as the defendant then and there well knew and believed the defendant had

made one or more payments on said vehicles since July 26 20 l 7

(Title 18 United States Code Sections I00l(a)(2) and 3551 et seq)

5

COUNT SIX (Making a false Statement)

6 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not made any rent payment on the

defendants apartment since July 26 2017 when in fact as the defendant then and there

well knew and believed the defendant had made one or more rent payments on said

apartment since July 26 2017

(Title 18 United States Code Sections 1001(a)(2) and 3551 et seq)

COUNT SEVEN (Making a False Statement)

7 On or about August 21 2017 within the Eastern District of New

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not deposited money into the commissary

account of any inmate other than inmates Luis Lopez also known as Lou and Peter

Vasquez also known as Pete since July 26 2017 when in fact as the defendant then

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

2

LOPEZ PHILIPPE MEDINA CARLOS MA TEO CLARISSA VASQUEZ also known

as Clari PETER VASQUEZ and

together with others did knowingly and intentionally conspire to distribute and possess

with intent to distribute a controlled substance which offense involved a substance

containing heroin a Schedule I controlled substance contrary to Title 21 United States

Code Section 841 (a)(l ) The amount ofheroin involved in the conspiracy attributable

to each of the defendants as a result ofhis or her own conduct and the conduct ofother

conspirators reasonably foreseeable to him or her was one kilogram or more of a

substance containing heroin

(Title 2 1 United States Code Sections 846 and 841 (b )(I )(A)(i) Title 18

United States Code Sections 3551 et seq)

COUNT TWO (Use ofFirearms In Connection with a Drug Trafficking Crime)

2 In or about and between January 2010 and February 2017 both

dates being approximate and inclusive within the Eastern District ofNew York and

elsewhere the defendants VICTOR AGOSTO also known as Bebo LUIS LOPEZ

also known as Lou and PETER VASQUEZ together with others did knowingly and

intentionally use and carry one or more firearms during and in relation to a drug

trafficking crime to wit the crime charged in Count One and did knowingly and

intentionally possess such firearms in furtherance ofsaid drug trafficking crime

(Title 18 United States Code Sections 9124(c)(l )(A)(i) 2 and 3551 et seq)

3

COUNT THREE (Conspiracy to Launder Money)

3 In or about and between December 2011 and July 2017 both dates

being approximate and inclusive within the Eastern District ofNew York and elsewhere

the defendants LUIS LOPEZ also known as Lou CLARISSA VASQUEZ also known

as Clari and PETER VASQUEZ together with others did knowingly and intentionally

conspire to conduct one or more financial transactions in and affecting interstate and

foreign commerce to wit the transfer and delivery of United States currency which in

fact involved the proceeds of specified unlawful activity to wit narcotics trafficking in

violation of Title 21 United States Code Section 84la) knowing that the property

involved in the financial transactions represented the proceeds of some form ofunlawful

activity and (a) with the intent to promote the carrying on of the specified unlawful

activity and (b) knowing that the financial transactions were designed in whole and in

part to conceal and disguise the nature the location the source the ownership and the

control of the proceeds of the specified unlawful activity contrary to Title 18 United

States Code Sections 1956(a)l)(A)(i) and 1956(a)(l)(B)(i)

(Title 18 United States Code Sections 1956(b) and 3551 et seq)

COUNTFOUR (Making a FaJse Statement)

4 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

4

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that Luis Lopez also known as Lou and Peter Vasquez had no

involvement in her attempt to reclaim approximately $301 400 in United States currency

seized on or about June 11 2014 from a vehicle in Pennsylvania when in fact as the

defendant then and there well knew and believed Lopez and Vasquez had been involved

in the defendants attempt to reclaim said currency

(Title 18 United States Code Sections 100I(a)(2) and 3551 et seq)

COUNT FIVE (Making a False Statement)

5 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau oflnvestigation in that the

defendant falsely stated that the defendant had not made any payment on any vehicle

associated with the defendant or the defendants farnily members since July 26 2017

when in fact as the defendant then and there well knew and believed the defendant had

made one or more payments on said vehicles since July 26 20 l 7

(Title 18 United States Code Sections I00l(a)(2) and 3551 et seq)

5

COUNT SIX (Making a false Statement)

6 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not made any rent payment on the

defendants apartment since July 26 2017 when in fact as the defendant then and there

well knew and believed the defendant had made one or more rent payments on said

apartment since July 26 2017

(Title 18 United States Code Sections 1001(a)(2) and 3551 et seq)

COUNT SEVEN (Making a False Statement)

7 On or about August 21 2017 within the Eastern District of New

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not deposited money into the commissary

account of any inmate other than inmates Luis Lopez also known as Lou and Peter

Vasquez also known as Pete since July 26 2017 when in fact as the defendant then

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

3

COUNT THREE (Conspiracy to Launder Money)

3 In or about and between December 2011 and July 2017 both dates

being approximate and inclusive within the Eastern District ofNew York and elsewhere

the defendants LUIS LOPEZ also known as Lou CLARISSA VASQUEZ also known

as Clari and PETER VASQUEZ together with others did knowingly and intentionally

conspire to conduct one or more financial transactions in and affecting interstate and

foreign commerce to wit the transfer and delivery of United States currency which in

fact involved the proceeds of specified unlawful activity to wit narcotics trafficking in

violation of Title 21 United States Code Section 84la) knowing that the property

involved in the financial transactions represented the proceeds of some form ofunlawful

activity and (a) with the intent to promote the carrying on of the specified unlawful

activity and (b) knowing that the financial transactions were designed in whole and in

part to conceal and disguise the nature the location the source the ownership and the

control of the proceeds of the specified unlawful activity contrary to Title 18 United

States Code Sections 1956(a)l)(A)(i) and 1956(a)(l)(B)(i)

(Title 18 United States Code Sections 1956(b) and 3551 et seq)

COUNTFOUR (Making a FaJse Statement)

4 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

4

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that Luis Lopez also known as Lou and Peter Vasquez had no

involvement in her attempt to reclaim approximately $301 400 in United States currency

seized on or about June 11 2014 from a vehicle in Pennsylvania when in fact as the

defendant then and there well knew and believed Lopez and Vasquez had been involved

in the defendants attempt to reclaim said currency

(Title 18 United States Code Sections 100I(a)(2) and 3551 et seq)

COUNT FIVE (Making a False Statement)

5 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau oflnvestigation in that the

defendant falsely stated that the defendant had not made any payment on any vehicle

associated with the defendant or the defendants farnily members since July 26 2017

when in fact as the defendant then and there well knew and believed the defendant had

made one or more payments on said vehicles since July 26 20 l 7

(Title 18 United States Code Sections I00l(a)(2) and 3551 et seq)

5

COUNT SIX (Making a false Statement)

6 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not made any rent payment on the

defendants apartment since July 26 2017 when in fact as the defendant then and there

well knew and believed the defendant had made one or more rent payments on said

apartment since July 26 2017

(Title 18 United States Code Sections 1001(a)(2) and 3551 et seq)

COUNT SEVEN (Making a False Statement)

7 On or about August 21 2017 within the Eastern District of New

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not deposited money into the commissary

account of any inmate other than inmates Luis Lopez also known as Lou and Peter

Vasquez also known as Pete since July 26 2017 when in fact as the defendant then

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

4

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that Luis Lopez also known as Lou and Peter Vasquez had no

involvement in her attempt to reclaim approximately $301 400 in United States currency

seized on or about June 11 2014 from a vehicle in Pennsylvania when in fact as the

defendant then and there well knew and believed Lopez and Vasquez had been involved

in the defendants attempt to reclaim said currency

(Title 18 United States Code Sections 100I(a)(2) and 3551 et seq)

COUNT FIVE (Making a False Statement)

5 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau oflnvestigation in that the

defendant falsely stated that the defendant had not made any payment on any vehicle

associated with the defendant or the defendants farnily members since July 26 2017

when in fact as the defendant then and there well knew and believed the defendant had

made one or more payments on said vehicles since July 26 20 l 7

(Title 18 United States Code Sections I00l(a)(2) and 3551 et seq)

5

COUNT SIX (Making a false Statement)

6 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not made any rent payment on the

defendants apartment since July 26 2017 when in fact as the defendant then and there

well knew and believed the defendant had made one or more rent payments on said

apartment since July 26 2017

(Title 18 United States Code Sections 1001(a)(2) and 3551 et seq)

COUNT SEVEN (Making a False Statement)

7 On or about August 21 2017 within the Eastern District of New

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not deposited money into the commissary

account of any inmate other than inmates Luis Lopez also known as Lou and Peter

Vasquez also known as Pete since July 26 2017 when in fact as the defendant then

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

5

COUNT SIX (Making a false Statement)

6 On or about August 21 2017 within the Eastern District ofNew

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not made any rent payment on the

defendants apartment since July 26 2017 when in fact as the defendant then and there

well knew and believed the defendant had made one or more rent payments on said

apartment since July 26 2017

(Title 18 United States Code Sections 1001(a)(2) and 3551 et seq)

COUNT SEVEN (Making a False Statement)

7 On or about August 21 2017 within the Eastern District of New

York the defendant CLARISSA VASQUEZ also known as Clari did knowingly and

willfully make one or more materially false fictitious and fraudulent statements and

representations in a matter within the jurisdiction of the executive branch of the

Government of the United States to wit the Federal Bureau of Investigation in that the

defendant falsely stated that the defendant had not deposited money into the commissary

account of any inmate other than inmates Luis Lopez also known as Lou and Peter

Vasquez also known as Pete since July 26 2017 when in fact as the defendant then

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

6

and there well knew and believed the defendant had made one or more deposits into the

commissary accounts ofone or more other inmates since July 26 2017

(Title 18 United States Code Sections 100l(a)(2) and 3551 et seq)

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT ONE

8 The United States hereby gives notice to the defendants that upon

their conviction of the offense charged in Count One the government will seek forfeiture

in accordance with Title 21 United States Code Section 853( a) which requires any

person convicted of such offense to forfeit (a) any property constituting or derived from

proceeds obtained directly or indirectly as a result of such offense and (b) any property

used or intended to be used in any manner or part to commit or to facilitate the

commission of such offense

9 If any of the above-described forfeitable property as a result of an

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

7

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture of any other property of the defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 21 United States Code Sections 853(a) and 853(p))

CRIMINAL FORFEITURE ALLEGATION AS TO COUNT TWO

l 0 The United States hereby gives notice to the defendants charged in

Count Two that upon their conviction of such offense the government will seek

forfeiture in accordance with Title 18 United States Code Section 924( d)( l) and Title

28 United States Code Section 2461(c) which require the forfeiture of any firearm or

ammunition involved in or used in any knowing violation of Title 18 United States Code

Section 924

11 If any of the above-described forfeitable property as a result ofany

act or omission of such defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

8

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p ) to seek forfeiture ofany other property of such defendants up to the value of the

forfeitable property described in this forfeiture allegation

(Title 18 United States Code Section 924( d)( 1 ) Title 21 United States

Code Section 853(p) Title 28 United States Code Section 246l(c))

CRIMlNAL FORFEITURE ALLEGATION AS TO COUNT THREE

12 The United States hereby gives notice to the defendants charged in

Count Three that upon conviction ofsuch offense the government will seek forfeiture in

accordance with Title 18 United States Code Section 982(a)(l ) which requires any

person convicted of such offense to forfeit any property real or personal involved in

such offense and any property traceable to such property including but not limited to

approximately five million dollars and zero cents (S500000000)

13 If any of the above-described forfeitable property as a result of any

act or omission of the defendants

(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

9

it is the intent of the United States pursuant to Title 21 United States Code Section

853(p) as incorporated by Title 18 United States Code Section 982(b)l) to seek

forfeiture ofany other property of the defendants up to the value of the forfeitable

property described in this forfeiture allegation

(Title 18 United States Code Sections 982(a)(t) and 982(b)(l) Title 21

United States Code Section 853(p))

A TRUE BLLL

RICHARD P DONOGHU UNITED STA TES ATTORNEY EASTERN DISTRICT OF NEW YORK

l112017R0 l30d

FORM 000middot34 No JUN 85

UNITED STATES DISTRICT COURT EASTERN District of NEW YORK

CRIMINAL DIVISION

THE UNITED STATES OF AM ERICA V

VICTOR AGOSTO also known as Bebo ENRIQUE LAPORTE also known as Chiquito LUIS LOPEZ also known as Lou

ZAIDA LOPEZ PHILI PPE MEDINA CARLOS MATEO CLAR1SSA VASQ UEZ also known as Clari PETER VASQUEZ also known as Pete

Defendants

SUPERSEDING INDICTMENT (T 18 USC ~sect 924(c)(l)(A)(i) 924(d)( l ) 982(a)(1) 982(b)(L)

100l (a)(2) 1956(h) 2 and 3551 et~ T 21 USC sectsect 84l(b)(l)(A)(i) 846 853(a) and 853(p) f 28 USC sect 2461(c))

A tme bill

Foreperson

Filed i11 optJ11 court this __ _ _ -middot tiny of AD 20

Clerk

Bail$ __________ _

Littdsy K Genie (718) 254-6155 Je11nifer M Sasso (718) 254-6402

A11drey Spektor (718) 254-6155

l112017R0 l30d

FORM 000middot34 No JUN 85

UNITED STATES DISTRICT COURT EASTERN District of NEW YORK

CRIMINAL DIVISION

THE UNITED STATES OF AM ERICA V

VICTOR AGOSTO also known as Bebo ENRIQUE LAPORTE also known as Chiquito LUIS LOPEZ also known as Lou

ZAIDA LOPEZ PHILI PPE MEDINA CARLOS MATEO CLAR1SSA VASQ UEZ also known as Clari PETER VASQUEZ also known as Pete

Defendants

SUPERSEDING INDICTMENT (T 18 USC ~sect 924(c)(l)(A)(i) 924(d)( l ) 982(a)(1) 982(b)(L)

100l (a)(2) 1956(h) 2 and 3551 et~ T 21 USC sectsect 84l(b)(l)(A)(i) 846 853(a) and 853(p) f 28 USC sect 2461(c))

A tme bill

Foreperson

Filed i11 optJ11 court this __ _ _ -middot tiny of AD 20

Clerk

Bail$ __________ _

Littdsy K Genie (718) 254-6155 Je11nifer M Sasso (718) 254-6402

A11drey Spektor (718) 254-6155