Final Redacted ML Complaint 249

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U.S. DISTRICT CO,TRTNORTHil{\' Pl::;"::'!CT OFTFXASFILEDr------" . ~ - ~ - ....- ... .."-OR\G\NAL UNITED STATES DISTRICT C O U R r ~ .;UL -820"

NORTHERN DISTRICT OF TEXASFORT WORTH DIVISION CLERK, U.S. DISTRICT COURTlly__ ,,--.___Deputy

UNITED STATES OF AMERICA CRIMINAL COMPLAINTv. CASE NO. 4: l l -MJ-clyQRIGOBERTO OROZCO (1) alk/a "Rigo" MARGARITA MONRREAL (2) alk/a "Margarita Orozco" (3) ARASELIOROZCO (4)

JOANN HENRY (5) (6) CRIMINAL COMPLAINT

I, Rahsaan Adams, hereinafter Complainant, being duly sworn, state the followingis true and correct to the best of my knowledge and belief:From on or about July 10,2005, and continuing until on or about November 27,2007, in the Northern District of Texas and elsewhere, defendants RigobertoOrozco, also known as Rigo, and Margarita Monrreal, also known as MargaritaOrozco, did knowingly conspire, and agree with each other and unknown personsto commit offenses against the United States in violation of 18 USC 1957, to wit:money laundering, by knowingly engaging or attempting to engage in a monetarytransaction in criminally derived property of a value greater than $10,000.00 andis derived from specified unlawful activity, to-wit: drug proceeds in violation of 21U.S.C. 841(a)(l ) and 846, in violation of 18 USC 1956(h) (18 U.S.C. 1957(a)).Further, from on or about January 1,2007, and continuing until November 30,2009, in the Northern District of Texas and elsewhere, defendants, Araseli Orozco, Jo Ann Henry, and, and others did knowingly conspire, and agree with each otherand unknown persons to commit offenses against the United States in violation of18 USC 1956, to wit: money laundering, by transporting, transmitting or

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transferring or attempting to transport, transmit or transfer a monetary instrumentor funds from a place in the United States to and through a place outside theUnited States knowing that the monetary instrument or funds involved in thetransportation, transmission, and transfer represented the proceeds of some form ofunlawful activity, that is, distribution of a controlled substance or possession of acontrolled substance with intent to distribute or conspire to distribute a controlledsubstance in violation of21 U.S.C. 841(a)(I) and 846, knowing that suchtransportation, transmission, and transfer was designed in whole or in part to avoida transaction reporting requirement under State or Federal law, in violation of 18USC 1956(h) (18 USC 1956(a)(2)(B)(ii.All in violation of 18 U.S.C. 1956(h).

I. I have been a Special Agent with the Criminal Investigation Division of heInternal Revenue Service since June 10, 2004. I completed the Criminal InvestigatorTraining Program and the Special Agent Basic Training Program at the Federal LawEnforcement Training Center (FLETC) in Glynco, Georgia. In addition to the receipt oftraining involving tax cases, money laundering cases, and tax-related cases, I receivedextensive training in conducting interviews, drafting search and arrest warrants, usingfirearms, and using defensive tactics techniques. Moreover, I am a graduate of Stephen F.Austin State University where I obtained a Bachelor's Degree in Business Administrationwith a major in Management. Additionally, I obtained an MBA with an emphasis inaccounting from the University of North Texas. During my tenure as a Special Agent I havebeen involved in the investigation offmancial crimes including such offenses as Tax Evasion,Failure to File, Failure to Pay Over Employment Taxes, and other currency crimes. I haveanalyzed business records, bank records, tax returns, and other financial data. Through myexperience, I am knowledgeable of he types of documents, books, and records maintained bybusinesses in the course of normal business operations. I have experience as a team leaderand evidence custodian on numerous search warrants. I have worked with other lawenforcement agencies such as the Federal Bureau ofInvestigation, United States PostalService, and Health and Human Services Office of Inspector General. I have also workedwith state and local law enforcement agencies investigating the types of offenses describedabove.

2. I have participated in an Organized Crime Drug Enforcement TaskForce (OCDETF) investigation, named "Operation Storm Cloud," which relates to drugtrafficking activities ofRigoberto Orozco (Rigoberto) and ( aswell as other persons. Based on the testimony and evidence obtained in this investigation,I believe that Rigoberto Orozco (Rigoberto), Margarita Monrreal (Margarita),( Araseli Orozco (Araseli) Jo Ann Henry (Henry) andComplaint Page 2


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have committed money laundering violations byknowingly conducting monetary and financial transactions with monies derived from aspecified unlawful activity (SUA) to wit: 21 USC 841(a)(I) and 846, being moniesderived from the distribution and sale of drugs. These transactions were either withfinancial institution in excess of $10,000.00 or in excess of $3,000.00 with intent to evadefederal reporting requirements.

3. The participants in "Operation Storm Cloud" investigation are theUnited States Attorney's office of the Northern District of Texas, the FederalBureau ofInvestigation (FBI), the Drug Enforcement Administration (DEA), and the InternalRevenue Service Criminal Investigation (IRS-CI) as well as state and local lawenforcement agencies. The investigation disclosed that from 2002 through the present,Rigoberto and his brother were involved in the distribution of cocaine, heroin,and marijuana in the Fort Worth! Dallas, Texas area, Atlanta, Georgia area, and thePhiladelphia, Pennsylvania area. The investigation disclosed that Rigoberto andmade substantial monies from the sale drugs. Furthermore, the investigation revealed thatRigoberto, Monrreal, Araseli, Henry, and knowingly conductedfinancial transactions with proceeds generated from drug trafficking activities in violationof federal money laundering statutes. Further, Araseli, Henry, andreached an agreement to conduct such transactions via wire transfers from Fort Worth toMexico for the purchase of heroin.

Rigoberto's and Participation in the Drug Trafficking Organization4. A person cooperating with the investigation, stated he/she worked foras a distributor of heroin before he/she went to prison in early 2002 or 2003.Upon getting out of prison in 2006 both Rigoberto and met with this cooperatingwitness to inquire whether the witness was willing to once again work as a drug dealer.

As a result, he/she resumed work for distributing narcotics but also began towork for Rigoberto in the same enterprise. The cooperating witness stated that in Marchof 2007 he/she helped Rigoberto distribute nearly 100 kilograms of cocaine in Atlanta,Georgia. This witness and Rigoberto did this through a series of drug deals involvingbetween 25 and 40 kilograms that resulted in thousands of dollars coming intoRigoberto's possession. The cooperating witness also stated that these types ofshipments occurred once every two weeks for the following year. The cooperatingwitness went on to relate that after that year, he/she began making trips to Philadelphia,on behalf of Rigoberto, to assist in shipping proceeds from drug transactions. Thecooperating witness also said that on one of these occasions he/she was in a hotel inPhiladelphia with over $3 million in drug proceeds. The cooperating witness explainedthat Margarita would arrange travel for these money shipment trips to Philadelphia andComplaint Page 3


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that Rigoberto often sent drug proceeds to Margarita. The witness also explained thatprimarily distributed heroin while Rigoberto primarily distributed cocaine. The

cooperating witness additionally stated that the breadth of the drug dealing activitiesrelating to both and Rigoberto included the localities ofFort Worth, Atlanta andPhiladelphia. The cooperating witness further related that Rigoberto operated and ran thedrug trafficking organization while was in prison in 2005 and 2006.

5. On February 27,2010, Federal Agents with the FBI and the DEA traveledto the Webb County Jail in Laredo, Texas and interviewed Henry who stated she had justbeen arrested in Laredo for transporting approximately .75 kilograms ofheroin into theUnited States from Mexico. During this arrest agents found a soft ball size bundle ofdrugs concealed in Henry's crotch area. Upon seizing the narcotics law enforcementagents arranged for a canine inspection of the bundle. During this inspection the caninemade a positive alert indicating the presence of illegal narcotics. Before her interview,Henry was given Miranda warnings and stated that in February of2007, she became aheroin customer of who is known as ." She went on to say thatsometimes in 2007 she would buy heroin at a body shop in Fort Worth owned byShe also stated that in April of2008, after she was kicked out ofher apartment, she andher boyfriend began living at body shop where she began to see "ounces andounces" of heroin. She estimated the most heroin she saw at onetime in shopwas between 85 and 110 ounces. Henry went on to relate that her relationship toescalated from that of a mere customer to a full-fledged participant in the drug traffickingorganization. She stated that she was employed by to travel to Mexico to pick upheroin and transport such heroin to Fort Worth. Specifically, Henry related that shemade three separate trips to Mexico between June 1, 2009 and July 6, 2009 to purchaseheroin from a contact of named She stated that wouldpurchase bus fare for these trips and she would pick up the heroin from inMexico. After retrieving the heroin in Mexico from she would then transport thedrugs across the border. Henry stated she later moved into different houses owned by

where she would live with girlfriend Henry further stated thateven though owned these houses they may in fact be listed in the name of

wife Araseli. Henry also stated that she and were arrested together forpossession ofheroin in January of2010. Henry also discussed the usage ofWestemUnion by herself, Araceli, and to send money from Fort Worth to

in Mexico to buy heroin. This will be further described below.6. On March 25,2011 Rachel Mae Skidmore (Skidmore) was arrested, along

with for attempting to smuggle narcotics into the United States from Mexico. OnApril 7, 2011, Agents of the FBI interviewed Skidmore. She stated that she wasaccompanied by when crossing into the US from Mexico where both of themComplaint Page 4


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were detained and agents searched Skidmore. During this search agents foundapproximately .56 kilograms ofheroin concealed in the girdle Skidmore was wearing.Skidmore stated she was having work done on her vehicle at shop located inFort Worth when he asked her if she wanted to make some money. Skidmore stated shelater agreed to work for and was to be paid $2,000.00 to pick up a package fromPiedras Negras, Mexico and deliver it to him in San Antonio for him to take to FortWorth. She related that she was not told what was in the package but she expected it tobe narcotics. Skidmore stated on the trip to Mexico she was accompanied by andthe two drove from Fort Worth to San Antonio, Texas together where they met ata hotel. Skidmore stated provided a hotel room, bus fare, and expense money forthem to travel from San Antonio to Mexico. Skidmore stated while in Mexico she andmet an unknown woman at a church and went to her hotel room. Skidmorerelated that this person gave her clothes to wear and a package containing narcotics,which she hid within her clothes. Then they departed the hotel. Skidmore stated theunknown female told her the package contained narcotics and that she had been carryingit for two days. Skidmore stated she and departed to the Point ofEntry Bridge atthe U.S./Mexico border and that is where they were stopped for questioning andsubsequently arrested with the heroin. Skidmore stated the day of the arrest was the firsttime she crossed the border from Mexico to the U.S. Skidmore also stated thatwife Araseli knows what he does, but does not care.

7. Agents questioned pursuant to the same arrest described in paragraph 6above. During this interview she admitted to crossing the border and accompanyingSkidmore but denied knowledge of any transport of narcotics. She additionally toldagents she had been arrested before and pled guilty to a state charge for delivery andmanufacture of heroin under one gram. This arrest was also described by Skidmore inparagraph 5 above. has a child with

8. Agents from the FBI obtained authorization from a Federal Judge toconduct a Title III (wire tap) on telephones numbers associated with Rigoberto andAs a result several telephone conversations between Rigoberto, andothers were recorded. Some recordings contained discussions of drugs to be sold and thecollection of drug proceeds relating to drug sales. One of these calls includes aconversation where Rigoberto was attempting to get a hold of to collect on adrug debt. A recorded conversation from November 11, 2010, includes Rigoberto andanother unknown male discussing the sale of drugs and monies owed to him. OnNovember 17,2010, another recorded conversation took place where told MiguelVargas, a participant of the drug trafficking organization, that he is waiting for one personto come to his location so that he may pay for drugs.Complaint Page 5


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Use of Drug Trafficking Proceeds in Financial TransactionsPurchase of 1103 Meadow Crest

9. On July 10,2005, Rigoberto and Margarita purchased 1103 MeadowCrest Lane in Mansfield, Texas with drug proceeds. Furthermore, the final payment wasin excess of $J 0,000.00 to a financial institution which is a company that makes loans,makes real estate investments, and employs an owner that is involved in real estateclosings and settlements. This final payment was for $28,850.00. The source of thispayment, along with all other payments for the residence, was drug proceeds in violationof 18 USC 1956(h) (18 U.S.C. 1957(a)).

10. As part of this investigation an agent with the FBI made contact with theowner of the real estate investment company described in paragraph 9 above. The ownergave a statement to a federal agent where he indicated that on July 10,2005, Margaritaunder the direction ofRigoberto, contracted to purchase a house located at 1103 MeadowCrest Lane, Mansfield, Texas. He explained that the total purchase price of the home was$133,844.00, which included $128,844.00 for the price of the home plus $5,000.00 forthe option to buy. The owner also stated primarily Rigoberto made the house payments.The owner also stated that all payments were in cash except for one in which Margaritaprovided the owner a $7,000.00 cashier's check from Wells Fargo Bank in August of2005. This initial payment was not the only payment made by Margarita, it is simply theonly non cash payment. The owner explained that he typically took payments by meetingRigoberto in various parking lots in Arlington, Texas. The owner went on to say that atother times he would meet Rigoberto at his residence located at 1103 Meadow CrestLane in Mansfield, TX to receive cash payments. The owner stated when he picked uppayments at the house, Rigoberto would go to the back bedroom and return with cashwhich usually consisted ofU.S. currency wrapped with black rubber bands usuallydenominated in either $100.00 bills or $20.00 bills. The owner also stated that whenRigoberto was out of town Margarita would meet him to make cash payments. Theowner related that Margarita made more than one cash payment for the home. Theowner stated the Orozco's finished paying for the residence on June 5,2007 and providedrecords pertaining to the sale of the house. The records indicate that Rigoberto andMargarita combined to make 13 cash payments. Six of the payments were for$9,000.00, one was for $8,900.00, one was for $8,000.00, one was for $7,400.00, and onewas for $7,000.00 while the final payment was a cash installment for $28,850.00. Thehome was paid for outright in less than two years. The final payment was made in thepresence of the owner and Margarita and Rigoberto.

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11. The owner stated once the residence was paid off Rigoberto directed himto list the owner of the residence as M.J.J.X. Corporation on the deed. The owner statedRigoberto provided the corporation name. Nevada corporate records indicate M.JJ.X.Corporation was incorporated in Las Vegas, NY on November 15,2007. The ownerstated he personally went with Rigoberto and Margarita to the Tarrant Countycourthouse to transfer the title of the house. The owner stated Margarita signed thewarranty deed and listed herself as the President . Within a yearof the final installment for the purchase of the home, forfeited itscorporate status for nonpayment of financial obligations.

12. Internal Revenue records revealed that both Rigoberto and Margaritafailed to file returns from 2005 through 2007.

Wire Transfers

13. Between January 8, 2007 and November 13,2009, Araseli,Henry, and combined to make at least 64 wire transfers from Fort Worth tolocations in Mexico to purchase heroin. Furthermore, these transfers often were made onthe same day by two or more of these participants in an effort to evade federal reportingrequirements in violation of 18 USC 1956(h) (18 USC 1956(a)(2)(B)(ii.

14. Skidmore stated that the date ofher arrest mentioned in paragraph 6 abovewas the first time that she had crossed the border from Mexico to the United States. Asmentioned previously, Skidmore was arrested and agents found her in possession of 56kilograms of heroin when she crossed the border from Mexico into the United States. Inher interview, Skidmore also stated that wife Araseli knows what he does, butdoes not care.

15. Henry, in addition to the information she provided investigators described inparagraph 5 above, also related facts regarding transmission of drug proceeds via wiretransfers pertaining to the drug trafficking organization. She told investigators that at thedirection of a number ofpeople used Western Union to wire money to Mexicoto buy heroin for him. She also told investigators that herself andothers had wired money to Mexico for the purpose ofpurchasing drugs. She stated thatthe payments went to a man named Henry also stated, that in an effort to avoiddetection she gathered and burned all of the Western Union wire transfer receipts shecould find at body shop. This was done for her benefit as well asAfter cooperating with agents during her interview Henry contacted from ajail inLaredo informing her that she had been arrested in possession of 772 grams ofheroin andasked her to warn that federal law enforcement agents were investigating him.Complaint Page 7


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Henry told that she was shown pictures of body shop that were a yearold to warn her and that law enforcement officials had been investigatingfor a year. She also told that agents were also inquiring as to who supplied herwith the heroin she held when she was arrested at the border. Henry also asked Annouto send her $200.00 from Western Union to the Laredo jail. This conversation wasrecorded.

16. Western Union records show that wired a total of $38,070.00 fromJanuary 8,2007 to November 9, 2009 from Fort Worth, Texas to Mexico. He did so byaggregation from at least 24 occasions. IRS records shpw received wages fromhis employer Inc. of $32,565.00 in 2007 and did not file tax returns for2008 and 2009.17. Western Union records show that Araseli wired a total of$18,200.00 from

10/20/2008 to 10/412009 from Fort Worth, Texas to Mexico. She did so by aggregationfrom at least 11 occasions. IRS records indicate Araseli reported wages of $8,360.00 in2008. Texas Workforce Commission records indicate Araseli did not have any wages in2009.

18. Western Union records show wired a total of$50,325.00 fromNovember 4,2008 to October l3, 2009 from Fort Worth, Texas to Mexico. She did so byaggregation from at least 28 occasions. Texas Workforce Commission records revealdid not have any income until the last quarter of 20 10 where she earned W2wages of$I,684.76 from . As shown above, all wire transfersoccurred before 2010. Additionally, admitted to being unemployed wheninterviewed during her above mentioned arrest with Skidmore on March 25,2010.

19. Western Union records show Henry wired $2,000.00 on July 16,2009 fromFort Worth, Texas to Mexico. On this date, and each also wired$2,000.00 via Western Union to Mexico. Texas Workforce Commission records revealHenry did not have any income until first quarter of 2011 where she earned W2 wages of$1,972.00 from . The wire transfer was conducted whenHenry did not have a known legal source of income.

20. Western Union records show that the 64 wire transfers described in paragraphs15 through 18 above were primarily sent to four common recipient addresses in Mexico.Western Union records also show that on 7 occasions between February 22,2009 andOctober 4,2009 transferred $2,000.00 to Mexico on the same day astransferred that same amount. 6 of these 7 times and wired $2,000.00Complaint PageS


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each within 20 minutes of one another. Also, such records show that on 3 occasionsbetween February 22,2009 and October 4,2009 transferred $2,000.00 on thesame day as Araseli transferred that same amount. On July 16, 2009 Henry, andall transmitted $2,000.00 each to Mexico. On this occasion, the three of themtransferred $2,000.00 each within 7 minutes of one another. On May 30, 2009 and July 3,2009 both Araseli and transferred currency to Mexico. On September 12,2009Araseli, and each transferred $2,000.00 to Mexico. With the exception

of transfers on May 30, 2009, the aggregate amount ofmoney transferred on the samebusiness day was either $4,000.00 or $6,000.00 among these four money launderers.Based on my training and experience structuring wire transactions in this manner isconsistent with drug traffickers attempting to avoid Currency Transaction Report filingrequirements when conducting wire transactions aggregating to more than $3,000.00 in asingle business day. Specifically, 31 C.F.R. 103.29 requires financial institutions to reportthe name of purchaser, date ofpurchase, serial number, and amount of currency used forthe purchase of any money order which involves currency in amounts of $3,000.00$10,000.00. Further, the transactions described in this paragraph only relate to transfersdone by the four money launderers named in this complaint. There are additionaltransfers from Fort Worth to Mexico by persons, other than those identified by thiscomplaint as money launderers, that are participants in this drug trafficking organizationin this time frame.

21. Henry also stated that at the direction of four or five people would goto Western Union at onetime to wire money to Mexico to purchase drugs.22. In addition to the $18,200.00 Araseli wired from October 20,2008 to October

04,2009 through Western Union, she purchased real estate and vehicles with drugproceeds. During the course ofthis investigation, 23 vehicles had Araseli listed as theowner. Some of these vehicles were used by drug couriers to sell and purchase narcoticsfor Henry informed investigators that Araseli lives in a cream colored housewhere she knew that kept between $70,000.00 and $100,000.00 in cash.I believe based on the testimony and the evidence obtained in the investigation, thenarcotics distribution activities ofRigoberto, and the amount of currency combined with

the lack of legitimate income of both Rigoberto and Margarita to justify the rapidpayment for the residence at 1103 Meadow Crest, that Rigoberto and Margaritaknowingly conducted a monetary and financial transaction with drug proceeds whenpurchasing their home in excess of$10,000.00 from a financial institution derived fromdrug trafficking in violation of 18 U.S.C. 1956 (h) (18 U.S.C. I 957(a)).

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Furthermore, based on the testimony and evidence obtained in the investigation, thenarcotics distribution activity of Henry, and the lack of legitimateincome of Araseli, Henry, and to explain the source for the wiretransfers to Mexico, the lack oflegitimate income ofAraseli to explain the source of thereal property and vehicles she owned, the commonality of recipient addresses, and theutilization ofmore than one person in the organization making wire transfers on the samebusiness day, as well as the arrests ofSkidmore, and JoAnn at the U.S. border,that Araseli, Henry, and conspired to knowingly conduct financialtransactions with drug proceeds by wiring drug proceeds from various Western Unionlocations in Fort Worth to Mexico to evade federal reporting requirements. Their actionsin conducting the financial transactions with drug proceeds were in a conspiracy totransmit money from the United States to Mexico in an effort to evade such requirementsin violation of 18 U.S.C. 1956(h) (18 U.S.C. 1956(a)(2)(B)(ii.~ . f V \ . QJ

Rahsaan Adams, Special Agent,Internal Revenue S e r v i c e ~ C I Sworn to before me and subscribed in my presence, July ,2011, at Fort Worth,Texas, at C(: 20 o'clock,

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Complaint

. ~ . I J J . 1 A C . / JEFFREY L. CURETON~ ~ ~ ' l u T A T E S MAGISTRATE JUDGE

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Final Redacted ML Complaint 249

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