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Indictment charging Victor Alfonso Mosquera Perez with conspiring to distribute cocaine knowing that it would be imported into the United States
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 14-cr-20332-MOORE-MCALILEY
21 U.S.C. § 963
21 U.S.C. §853
UNITED STATES OF AMERICA
VICTOR ALFONSO MOSQUERA PEREZ,
Defendant. FILED BY RB
MAY 9, 2014
STEVEN M. LARIMORE
CLERK U.S. DISTRICT CT.
S.D. OF FLA, Miami
The Grand Jury charges that:
From at least as early as in and around 2008, and continuing through in and around the date of the return of this Indictment, in the countries of Colombia, Honduras, and Nicaragua, and elsewhere, the defendant,
VICTOR ALFONSO MOSQUERA PEREZ,
did knowingly and willfully combine, conspire, confederate, and agree with persons known and unknown to the Grand Jury, to distribute a controlled substance in Schedule II, knowing that such controlled substance would be unlawfully imported into the United States, in violation of Title 21, United States Code, Section 959(a)(2); all in violation of Title 21, United States Code, Section 963.
Pursuant to Title 21, United States Code, Section 960(b)(1)(B), with respect to defendant VICTOR ALFONSO MOSQUERA PEREZ, a/k/a "Negro," the controlled substance involved in the conspiracy attributable to him as a result of his own conduct, and the conduct of other conspirators reasonably foreseeable to him, is 5 kilograms or more of a mixture and substance containing a detectable amount of cocaine.
1. The allegations contained in this Indictment are re-alleged and incorporated by reference as though fully set forth herein for the purpose of alleging forfeiture to the United States of America of certain property in which the defendant, VICTOR ALFONSO MOSQUERA PEREZ, a/k/a "Negro," has an interest.
2. Upon conviction of any violation alleged in this Indictment, the defendant shall forfeit all of his respective right, title and interest to the United States in any property constituting, or derived from, any proceeds obtained, directly or indirectly, as the result of such violation and in any property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of, such violation.
3. If any of the forfeitable property described in the forfeiture section of this indictment, 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 person;
(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 subdivided without difficulty;
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 said defendant up to the value of the above forfeitable property.
All pursuant to Title 21, United States Code, Section 853.
A TRUE BILL
WIFREDO A. FERRER
UNITED STATES ATTORNEY
MICHAEL B. NADLER
ASSISTANT UNITED STATES ATTORNEY
DDHH en Colombia
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