UNITED STATES OF AM ERICA VS. HUGO CARVAJAL BARRIOS, a/k/a Pollo Sealed Defendant. INDICTMENT The Grand Jury charges that: COUNT I At all times relevant to this Indictment: 1. The North Valley Cartel (hereinafter NVC) was a criminal organization based in Colombia whose members engaged in: (a) the illegal trafficking of cocaine to the United States and elsewhere; (b) the laundering of drug proceeds; (c) the bribing of law enforcement officials; and (d) the kidnaping, torture, and murder of informants, rival drug traffickers, and other perceived enemies of the NVC. 2. HUGO CARVAJAL BARRIOS, a/k/a Pollo, was a high-ranking military intelligence officer with the Dirección de lnteligencia Militar de Venezuela (Venezuelan Directorate of Military Intelligence) (hereinafter DIM) and its successor agency. 3. Starting in the early-1990s and continuing through the early-2000s, high-ranking members of the NVC began splintering off and forming rival factions. 4. From at least as early as 1998 until his death on or about January 29, 2008,the exact dates being unknown to the Grand Jury, Wilber Varela, a/k/a (çlabony (hereinafter ççvarela) was the leader of one of these NVC factions. 5. In and around 2004,the exact date being unknown to the Grand Jury, Varela relocated his base of operations to the country of Venezuela for reasons including the threat of capture by Colombian law enforcement authorities and the threat of violence from competing narcotraffickers. Several of the high ranking members of Varelas faction also ultimately relocated to Venezuela. From at least as early as in and arotmd 2004 until his death on or about January 29, 2008, the exact dates being unknown to the Grand Jury, Varela and other members of Varelas faction sent thousands of kilograms of cocaine from Venezuela to countries such as Mexico, with the knowledge that the cocaine would be unlawfully imported into the United States. 8. From at least as early as in and around 2004 until his death on or about January 29, 2008, the exact dates being unknown to the Grand Jury, Varela paid HUGO CARVAJAL BARRIOS, a/k/a PoIIo, and other high-ranking Venezuelan law enforcement and military officials to assist Varelas factions drug trafficking activities. HUGO CARVAJAL BARRIOS, a/k/a POIIO, and other high-ranking Venezuelan Law enforcement and military officials assisted Varelas factions drug trafficking activities by, among other things: 1) allowing members of Varelas faction to export cocaine from Venezuela; 2) providing members of Varelas faction with protection from capture; and 3) providing information regarding the activities of Venezuelan military and 1aw enforcement personnel. 10. Following Varelas death, members of his faction continued to pay HUGO CARVAJAL BARRIOS, a/k/a Pollo, and other high-ranking Venezuelan law enforcement and military officials to assist their own drug trafficking activities. 11. ln addition to the assistance described above in Paragraphs Nine and Ten, HUGO CARVAJAL BARRIOS, a/k/a Pollo, sold hundreds of kilograms of cocaine to a member of Varelas faction. 12. From at least as early as in and around 2004 and continuing th ough in and around September 2010, the exact dates being unknown to the Grand Jury, HUGO CARVAJAL BARRIOS, a/k/a PolIo, also provided assistance to narcotraffickers and their transportation organizations other than Varela and members of his faction. 13. HUGO CARVAJAL BARRIOS, a/k/a Pollo, assisted these narcotraffickers and their transportation organizations by, among other things:1) allowing these narcotraffickers and their transportation organizations to export cocaine from, and import money into,Venezuela; 2) providing these narcotraffickers and their transportation organizations with protection from capture; 3) providing information regarding the activities of Venezuelan military and law enforcement personnel; and 4) investing in cocaine loads being exported from Venezuela. (Conspiracy to Distribute Cocaine with the Knowledge and lntent that it will be Unlawfully Imported into the United States) 21 U.S.C. j 963 14. From at least as early as in and around 2004 and continuing through in and around September 2010, the exact dates being unknown to the Grand Jury, in the countries of Colombia,Venezuela, Mexico, and elsewhere, the defendant, HUGO CARVAJAL BARRIOS,a/k/a Pollo, did knowingly and willfully combine, conspire, confederate, and agree with Wilber Varela, a/k/a/ Jabon, and with persons known and unknown to the Grand Jury, to distribute a controlled substance in Schedule II, knowing and intending that such controlled substance would be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959(a)(1) and 959(a)(2); al1 in violation of Title 21, United States Code,Section 963. 15. Pursuant to Title 21, United States Code, Section 960(b)(1)(B), it is further alleged that this violation involved five (5) kilograms or more of a mixture and substance containing a detectable nmount of cocaine. FORFEITURE ALLEGATIONS 16. The allegations of this Indictment are re-alleged and by this reference fully incorporated herein for the purpose of alleging forfeiture to the United States of America of certain property in which the defendant, HUGO CARVAJAL BARRIOS, a/k/a Pollo has an interest. Upon conviction of a violation of Title 21, United States Code, Section 963, as alleged in this Indictment, the defendant shall forfeit to the United States any property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such violation, and any property used, or intended to be used, in any mnnner or part, to commit,or to facilitate the commission of, such violation, pursuant to Title 21, United States Code, Sections 853(a)(1) and (2). 18. All pursuant to Title 21, United States Code, Section 853, as made applicable by Title 21, United States Code, Section 970.
Posted on: Sat, 26 Jul 2014 18:52:30 +0000
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