Free Redacted Document - District Court of Delaware - Delaware

. Case 1 :07-cr-00045-SLR Document 12 Filed O3/27/2007 Page 1 of 3 i
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE I 2,
UNITED STATES OF AMERICA, )
Plaintiff l
)
v. ) Criminal Action No. 07- Ll 6 * DLL ‘ U N Q
MARINA LOZOYA, l
JORGE CARRIZALES, ) -_ sy .... , ,
HANIEL MATOS, and ) · I · 2 ,‘_ ' ` · li`}
FELIX SANTOS-ALMONTE ) .. I » 5 CQ
Defendants. l
INDICTMENT
The Federal Grand Jury for the District of Delaware charges that:
COUNT I
From on or about September 29, 2006, and continuing to on or about March 8, 2007, in
the State and District of Delaware and elsewhere, MARINA LOZOYA, JORGE CARRIZALES,
HANIEL MATOS, and FELIX SANTOS—ALl\/IONTE, defendants herein, did knowingly
conspire with each other and with other persons known and unknown to the Grand Jury, to
distribute and to possess with the intent to distribute 500 grams or more of a mixture and
substance containing a detectable-amount of cocaine, a Schedule II narcotic controlled substance,
a violation of Title 21, United States Code, Sections 84l(a)(l) and 841(b)(l)(B), and Title 18,
United States Code, Section 2.
All in violation of Title 21, United States Code, Section 846.
p COUNT II
p On or about February 22, 2007, in the State and District of Delaware and elsewhere,
MARINA LOZOYA and J ORGE CARRIZALES, defendants herein, did knowingly and
intentionally attempt to distribute 500 grams or more of a mixture and substance containing a

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detectable amount of cocaine, a Schedule II narcotic controlled substance, in violation of Title
21, United States Code, Sections 841(a)(1) and 84l(b)(1)(B), and Title 18, United States Code, n
Section 2.
All in violation of Title 21, United States Code, Section 846.
COUNT III
On or about February 28, 2007, in the State and District of Delaware, HANIEL MATOS
and FELIX SANTOS—ALMONTE, defendants herein, did knowingly and intentionally attempt to
possess with the intent to distribute 500 grams or more of a mixture and substance containing a
detectable amount of cocaine, a Schedule II narcotic controlled substance, in violation of Title
21, United States Code, Sections 841(a)(1) and 841(b)(1)(B), and Title 18, United States Code,
Section 2.
All in violation ofTitle 21, United States Code, Section 846.
NOTICE OF FORFEITURE
Upon conviction of the controlled substance offense alleged in Counts I-[II of this
Indictment, defendants MARINA LOZOYA, JORGE CARRIZALES, HANIEL MATOS, and
FELIX SANTOS-ALMONTE shall forfeit to-the United States pursuant to 21 U.S.C. § 853, any
property constituting, or derived from, proceeds obtained, directly or indirectly, as a result of the
said violation and any property used, or intended to be used, in any manner or part, to commit, or
- to facilitate the commission of the said violation, including but not limited to approximately
$18,310 in United States currency. n
If any of the above-described forfeitable property, as a result of any act or omission of th
defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a_ third party;

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(c) has been placed beyond the jurisdiction of the court; .
(d) has been substantially diminished in value; or
(e) ehas been cemmingled withpother property which camiot be divided without difhculty;
it is the intent ofthe UnitedfStatesg pursua.nt to 21 U.S.C. § 853(p), to seek forfeiture of any other
i .;
property of said giefeni1ant(s) up to the value of the forfeitable property described above.
3 t y
J i _ A TRUE BILL:
’ v p Foreperson
. { L __ t
COLM F.‘CONNOLI2Y . _
United s A ey L _ e
I —` L
Robert F. Kravetz .
· Assistant United S tes Attomey
Dated: March 27, 2007
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