Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 1 of 9

UNITED STATES DISTRICT COURT .. , :}7

DISTRICT OF CONNECTICUT

GRAND JURY B-16-2

UNITED STATES OF AMERICA Criminal No. ?/ I lf2 f.E ~ J,kM)

V.

VIOLATIONS:
BIENVENIDO GONZALEZ, a.k.a. "Antonio," a.k.a.
"Julian" 21 U.S.C. 846 (Conspiracy to
ANTONIO GONZALEZ, a.k.a. "Bienve" Distribute, and to Possess with
LUIS GONZALEZ Intent to Distribute, a Controlled
HERSON GONZALEZ, a.k.a. "Titi" Substance)
ROBERTO GONZALEZ
21 U.S.C. 84l(a)(l) (Possession
RAFAEL NEFTALI CASTILLO BAEZ,
with Intent to Distribute, and
a.k.a. Edwin Vinicio Castillo Baez, Distribution of, a Controlled
a.k.a. Yunior Matos Sanchez Substance)
PABLO JOSE CRUZ
JULIO FLORES 18 U.S.C. 2 (Aiding and Abetting)
CHARLES MAY
18 U.S.C. 922(g) (Felon in
JOSE MEDINA, a.k.a. "Tito"
Possession of a Firearm)
ANDRE MILLER
JOSE MINA YA-MELENDEZ 18 U.S.C. 924(d) (Criminal
MARCO PADILLA Forfeiture, Firearms Offense)
WANDA PISCIL
EL VIN PLAZA, a.k.a. "Jordan" 21 U.S.C. 853 (Criminal
JOSE MANUEL RIOS Forfeiture, Drug Trafficking
Offenses)
LUIS ROBLES
EFRAIN ROLON-DONES
MARIMAR ROMAN
ISMAEL RUIZ, a.k.a. "Papo"
JORGE LUIS RUIZ, a.k.a. "Pito"
CARLOS SANTIAGO, .a.k.a. "Carlito"
ROBERTO TORRES

INDICTMENT
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 2 of 9

The Grand Jury charges:

COUNT ONE
(Conspiracy to Distribute and to Possess With Intent to Distribute Heroin)

1. From approximately January 25, 2016 through March 15, 2017, the exact dates

being unknown to the Grand Jury, in the District of Connecticut, the defendants BIENVENIDO

GONZALEZ, a.k.a. "Antonio," a.k.a. "Julian," ANTONIO GONZALEZ, a.k.a. "Bienve," LUIS

GONZALEZ, HERSON GONZALEZ, a.k.a. "Titi," ROBERTO GONZALEZ, RAFAEL

NEFTALI CASTILLO BAEZ, a.k.a. Edwin Vinicio Castillo Baez, a.k.a. Yunior Matos Sanchez,

PABLO JOSE CRUZ, JULIO FLORES, CHARLES MAY, JOSE MEDINA, a.k.a. "Tito,"

ANDRE MILLER, JOSE MINAYA-MELENDEZ, MARCO PADILLA, WANDA PISCIL,

ELVIN PLAZA, a.k.a. "Jordan," JOSE MANUEL RIOS, LUIS ROBLES, EFRAIN ROLON-

DONES, MARIMAR ROMAN, ISMAEL RUIZ, a.k.a. "Papo," JORGE LUIS RUIZ, a.k.a. "Pito,"

CARLOS SANTIAGO, a.k.a. "Carlito," ROBERTO TORRES, and others known and unknown

to the Grand Jury, knowingly and intentionally conspired together and with one another, to possess

with intent to distribute, and to distribute, a controlled substance, namely a mixture and substance

containing a detectable amount of heroin, a Schedule I controlled substance, contrary to the

provisions of Title 21, United States Code, Section 841(a)(l).

QUANTITY OF HEROIN INVOLVED IN THE CONSPIRACY

2. Defendants BIENVENIDO GONZALEZ, a.k.a. "Antonio," a.k.a. "Julian,"

ANTONIO GONZALEZ, a.k.a. "Bienve," RAFAEL NEFTALI CASTILLO BAEZ, a.k.a. Edwin

Vinicio Castillo Baez, a.k.a. Yunior Matos Sanchez, PABLO JOSE CRUZ, JOSE MINAYA-

MELENDEZ, JORGE LUIS RUIZ, a.k.a. "Pito," and CARLOS SANTIAGO, a.k.a. "Carlito"

knew and reasonably should have foreseen from their own conduct and that of other members of

the narcotics conspiracy charged in Count One that the conspiracy involved one kilogram or more

2
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 3 of 9

of a mixture and substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21 , United States Code, Section 841(b)(l)(A).

3. Defendants JULIO FLORES, JOSE MEDINA, ANDRE MILLER, WANDA

PISCIL, ELVIN PLAZA, a.k.a. "Jordan," JOSE MANUEL RIOS, MARIMAR ROMAN,

ISMAEL RUIZ, a.k.a. "Papo," and ROBERTO TORRES knew and reasonably should have

foreseen from their own conduct and that of other members of the narcotics conspiracy charged in

Count One that the conspiracy involved 100 grams or more of a mixture and substance containing

a detectable amount of heroin, a Schedule I controlled substance, in violation of Title 21 , United

States Code, Section 841 (b)(1 )(B).

4. Defendants LUIS GONZALEZ, HERSON GONZALEZ, ROBERTO

GONZALEZ, CHARLES MAY, MARCO PADILLA, LUIS ROBLES , and EFRAIN ROLON-

DONES knew and reasonably should have foreseen from their own conduct and that of other

members of the narcotics conspiracy charged in Count One that the conspiracy involved a mixture

and substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21 , United States Code, Section 841(b)(l)(C).

All in violation of Title 21 , United States Code, Section 846.

COUNT TWO
(Possession with Intent to Distribute and Distribution of Heroin)

5. On or about January 25, 2016, in the District of Connecticut, the defendant JOSE

MEDINA, a.k.a. "Tito," knowingly and intentionally possessed with intent to distribute and did

distribute a mixture and substance containing a detectable amount of heroin, a Schedule I

controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

3
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 4 of 9

COUNT THREE
(Possession with Intent to Distribute and Distribution of Heroin)

6. On or about October 5, 2016, in the District of Connecticut, the defendant EFRAIN

ROLON-DONES knowingly and intentionally possessed with intent to distribute and did

distribute a mixture and substance containing a detectable amount of heroin, a Schedule I

controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNTFOUR
(Possession with Intent to Distribute and Distribution of Heroin)

7. On or about October 17, 2016, in the District of Connecticut, the defendant

EFRAIN ROLON-DONES knowingly and intentionally possessed with intent to distribute and did

distribute a mixture and substance containing a detectable amount of heroin, a Schedule I

controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT FIVE
(Possession with Intent to Distribute and Distribution of Heroin)

8. On or about August 30, 2016, in the District of Connecticut, the defendant LUIS

GONZALEZ knowingly and intentionally possessed with intent to distribute and did distribute a

mixture and substance containing a detectable amount of heroin, a Schedule I controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT SIX
(Possession with Intent to Distribute and Distribution of Heroin)

9. On or about September 7, 2016, in the District of Connecticut, the defendant LUIS

GONZALEZ knowingly and intentionally possessed with intent to distribute and did distribute a

mixture and substance containing a detectable amount of heroin, a Schedule I controlled substance.

4
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 5 of 9

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT SEVEN
(Possession with Intent to Distribute and Distribution of Heroin)

10. On or about October 7, 2016, in the District of Connecticut, the defendant LUIS

GONZALEZ knowingly and intentionally possessed with intent to distribute and did distribute a

mixture and substance containing a detectable amount of heroin, a Schedule I controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT EIGHT
(Possession with Intent to Distribute and Distribution of Heroin)

11. On or about November 10, 2016, in the District of Connecticut, the defendant

MARIMAR ROMAN knowingly and intentionally possessed with intent to distribute and did

distribute a mixture and substance containing a detectable amount of heroin, a Schedule I

controlled substance.

In violation of Title 21 , United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT NINE
(Possession with Intent to Distribute and Distribution of Heroin)

12. On or about November 15, 2016, in the District of Connecticut, the defendant

CARLOS SANTIAGO, a.k.a. "Carlito," knowingly and intentionally possessed with intent to

distribute and did distribute a mixture and substance containing a detectable amount of heroin, a

Schedule I controlled substance.

In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT TEN
(Possession with Intent to Distribute Heroin)

13. On or about March 15, 2017, in the District of Connecticut, the defendants

BIENVENIDO GONZALEZ, a.k.a. "Antonio," a.k.a. "Julian," PABLO JOSE CRUZ, and JOSE

5
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 6 of 9

MINA YA-MELENDEZ knowingly and intentionally possessed with intent to distribute one

kilogram or more of a mixture and substance containing a detectable amount of heroin, a Schedule

I controlled substance.

In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A), and Title

18, United States Code, Section 2.

COUNT ELEVEN
(Possession with Intent to Distribute Heroin)

14. On or about March 16, 2017, in the District of Connecticut, the defendant JOSE

MANUEL RIOS knowingly and intentionally possessed with intent to distribute a mixture and

substance containing a detectable amount of heroin, a Schedule I controlled substance.

In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C).

COUNT TWELVE
(Possession with Intent to Distribute Cocaine Base)

15. On or about March 16, 2017, in the District of Connecticut, the defendant

ROBERTO TORRES knowingly and intentionally possessed with intent to distribute a mixture

and substance containing 28 grams or more of a detectable amount of cocaine base, a Schedule II

controlled substance.

In violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B).

COUNT THIRTEEN
(Unlawful Possession of a Firearm by a Felon)

16. On or about March 16, 2017, in the District of Connecticut, defendant ANDRE

MILLER, having been convicted in the Superior Court of the State of Connecticut for a crime

punishable by imprisonment for a term exceeding one year, that is, Sale of Narcotics, in violation

of Connecticut General Statutes 21a-277(a), on May 19, 2016, did knowingly possess a firearm

6
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 7 of 9

in and affecting commerce, namely one SigSauer P933 9mm semi-automatic handgun with serial

number 52b225095, which was transported and shipped in interstate and foreign commerce.

In violation of Title 18, United States Code, Sections 922(g)( 1) and 924(a)(2).

FORFEITURE ALLEGATION
(Firearms Offense)

17. Upon conviction of the firearms offense alleged in Count Thirteen of this

Indictment, the defendant ANDRE MILLER shall forfeit to the United States, pursuant to Title 18,

United States Code, Section 924( d), and Title 28, United States Code, Section 2461 (c), all firearms

and ammunition involved in the commission of that offense, including but not limited to one

SigSauer P933 9mm semi-automatic handgun with serial number 52b225095.

FORFEITURE ALLEGATION
(Controlled Substance Offenses)

18. Upon conviction of one or more of the controlled substance offenses alleged in

Counts One through Twelve of this Indictment, the defendants BIENVENIDO GONZALEZ, a.k.a.

"Antonio," a.k.a. "Julian," ANTONIO GONZALEZ, a.k.a. "Bienve," LUIS GONZALEZ,

HERSON GONZALEZ, a.k.a. "Titi," ROBERTO GONZALEZ, RAFAEL NEFTALI CASTILLO

BAEZ, a.k.a. Edwin Vinicio Castillo Baez, a.k.a. Yunior Matos Sanchez, PABLO JOSE CRUZ,

JULIO FLORES, CHARLES MAY, JOSE MEDINA, a.k.a. "Tito," ANDRE MILLER, JOSE

MINA YA-MELENDEZ, MARCO PADILLA, WANDA PISCIL, EL VIN PLAZA, a.k.a.

"Jordan," JOSE MANUEL RIOS, LUIS ROBLES, EFRAIN ROLON-DONES, MARIMAR

ROMAN, ISMAEL RUIZ, a.k.a. "Papo," JORGE LUIS RUIZ, a.k.a. "Pito," CARLOS

SANTIAGO, a.k.a. "Carlito," and ROBERTO TORRES shall forfeit to the United States, pursuant

to Title 21 , United States Code, Section 853 , all right, title, and interest in any property

constituting, or derived from, proceeds obtained, directly or indirectly, as a result of the violations

7
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 8 of 9

of Title 21, United States Code, Sections 841 and 846, and any property used, or intended to be

used, in any manner or part, to commit, or to facilitate the commission of, those violations and a

sum of money equal to the total amount of proceeds obtained as a result of the offenses.

19. The property subject to forfeiture includes, but is not limited to, the following

property seized on March 15, 2017, and March 16, 2017: (a) approximately $10,000 seized from

641 Main Street, East Haven, Connecticut; (b) approximately $4,737 seized from 24 High Street

in West Haven, Connecticut; (c) approximately $7,722 seized from 103 Hemingway A venue, Apt.

E, East Haven, Connecticut; (d) approximately $9,558 seized from 231 Forbes Avenue, New

Haven; Connecticut; (e) approximately $1 ,500 seized from 30 Arch Street, New Haven,

Connecticut; (f) approximately $1,413 seized from the person of Pablo Jose CRUZ at 641 Main

Street, East Haven, Connecticut; (g) $18,180 seized from 16 Stefaniak A venue, Webster,

Massachusetts.

20. If any of the above-described forfeitable property, as a result of any act or omission

of the defendants named in this Indictment: (a) cannot be located upon the exercise of due

diligence; (b) has been transferred or sold to, or disposed with, a third person; (c) has been placed

beyond the jurisdiction of the United States District Court for the District of Connecticut; (d) has

been substantially diminished in value; or (e) has been commingled with other property that 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 those defendants, up to

8
 Case 3:17-cr-00062-JAM Document 23 Filed 03/29/17 Page 9 of 9

the value of the above-described forfeitable property.

All in accordance with Title 21 , United States Code, Section 853, and Rule 32.2(a) of the

Federal Rules of Criminal Procedure.

A TRUE BILL,

/s/
FOREPERSON

UNITED STATES OF AMERICA

DEIRDRE M. DALY
UNITED STATES ATTORNEY

~-
..

AMYC.BROWN
ASSISTANT UNITED STATES ATTORNEY