Free Redacted Document - District Court of Delaware - Delaware

* · Case 1:07-cr-00021-JJF Document 11 Filed 02/15/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT .
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
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Plaintifi )
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v. ) Criminal Action N0. 07- * DLL- \}
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PEDRO HERNANDEZSANCHEZ and ) r__ __ ___?_ __ Ah r___ _
RICARDO ZANELA-CASTELAN, ) [-_, tg Pu"} ,·' , [»’
) | _`_.: |· 7___: In It __ in- U : r_,.i
Defendants. ) Q_. C`; . { . T'
INDICTMENT ‘
The Grand Jury for the District of Delaware charges that:
COUNT ONE
On or about January 17, 2007, in New Castle County, in the State and District of Delaware,
Defendants Pedro Hernandez-Sanchez and Ricardo Zanela—Castelan, knowing and in reckless
disregard ofthe fact that certain aliens had come to, entered and remained in the United States in
violation of law, did transport and move said aliens within the United States by means of
transportation and otherwise in furtherance of such violation of law, and for the purpose of
commercial advantage and private financial gain.
All in violation of Title 8, United States Code, Section l324(a)(l)(A)(ii) & (a)(l)(B)(i).
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· i Case 1 :07-cr-00021-JJF Document 11 Filed 02/15/2007 Page 2 of 3 ..
j counr rwo
On or about January 8, 2007, in the State and District of Arizona, Defendant Pedro Hernandez-
Sanchez, an alien and subject of Mexico, did knowingly and unlawfully enter the United States from
Mexico at a point near Sasabe, Arizona, which said time and place was then and there other than as
designated by immigration officials of the United States for the entrance of immigrants into the
United States, and was apprehended in the District of Delaware, in violation of Title 8, United States
Code, Sections 1325(a)(1) & 1329. l
COUNT THREE
On or about January 9, 2007, in the State and District of Arizona, Defendant Ricardo Zanela-
Castelan, an alien and subject ofMexico, did knowingly and unlawfully enter the United States from
Mexico at a point near Nogales, Arizona, which said time and place was then and there other than
as designated by immigration officials of the United States for the entrance of immigrants into the
United States, and was apprehended in the District of Delaware, in violation of Title 8, United States
I Code, Sections 1325(a)(1) & 1329. A
NOTICE OF FORFEITURE
Upon conviction of the offense alleged in Count One of this Indictment, Defendants Pedro
Hemandez—Sanchez and Ricardo Zanela-Castelan shall forfeit to the United States pursuant to 18
U.S.C. § 982(a)(6), 8 U.S.C. § l324(b), and 28 U.S.C. § 2461(c), all conveyances used in the
commission ofthe violation; all property, real and personal, that constitutes or is derived from or is
traceable to proceeds obtained directly or indirectly from the commission of the offense; and all
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‘ · Case 1 :07-cr-00021-JJF Document 11 Filed 02/15/2007 Page 3 of 3 ·.
U property, real or personal, that was used to facilitate, or was intended to be used to facilitate the
commission of the offense, including, but not limited to, a brown 1998 Chevrolet Express van.
If any of the above-described forfeitable property, 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 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; it is the intent ofthe United States, pursuant to18 U.S.C. § 982(b) and
21 U.S.C. § 853(p), to seek forfeiture of any other property of said defendant up to the value of the
forfeitable property described above.
All pursuant to 18 U.S.C. § 982(a)(6) & (b), 21 U.S.C. § 853(p), 8 U.S.C. § 1324, 28 U.S.C. .
§2461(c), and Fed. R. Crim. P. 32.2.
A TRUE BILL:
Foreperson i`
COLM F. CONNOLLY _
UNITED STATES ATTORNEY
By: / »fr~%/'/
Robert F. Kravetz
Assistant U.S. Attomey
i Dated: February 15, 2007
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