Case 1:15-cr-00168-CMH Document 1 Filed 06/18/15 Page 1 of 4 PageID# 1

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IN THE UNITED STATES DISTRICT COURT THE

EASTERN DISTRICT OF VIRGINI^I JUN I 8 2015

Alexandria Division

UNITED STATES OF AMERICA

CRIMINAL NO. 1:15-CR-168

V.

Count 1:
JOHANNA JAZMIN SANCHEZ-GUZMAN
A/K/A"Tatiana" 21 U.S.C.§§ 959(a), 960, 963:
Conspiracy to Distribute Five Kilograms or
and, More of Cocaine Knowing and Intending that it
will be Unlawfully Imported into the United
MARCO ANTONIO ROBAYO-BARBOSA, States.

Defendants. Count 2:

21 U.S.C. §§ 959(a), 18 U.S.C. § 2;

Distribution of Five Kilograms or
More of Cocaine Knowing and Intending that it
will be Unlawfully Imported into the United
States; Aiding and Abetting.

Forfeiture: 21 use §§ 853, 970

(Criminal Forfeiture)

INDICTMENT

JUNE 2015 TERM - at Alexandria, Virginia

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COUNT 1

THE GRAND JURY CHARGES THAT:

(Conspiracy to Distribute Five Kilograms or More of Cocaine Knowing and Intending that it
would be Unlawfully Imported into the United States)

From in and around 2012 and continuing to on or about the date of this indictment, the

exact dates being unknownto the Grand Jury, within the jurisdiction of the United States and in

an offense begun and committedoutside the jurisdiction of a particular State or district, the

defendants, JOHANNA JAZMIN SANCHEZ-GUZMAN, a/k/a "Tatiana," and MARCO

ANTONIO ROBAYO-BARBOSA, and others, known and unknown to the Grand Jury, who will

be first brought to the Eastern District of Virginia, did knowingly and intentionally combine,

conspire, confederate, and agreeto committhe following offense againstthe United States: to

knowingly and intentionally distribute five kilograms or more of a mixture and substance

containing a detectable amount of cocaine, a Schedule II controlled substance, knowing and

intending that such substance would be unlawfully imported into the United States, in violation

of Title 21, United States Code, Section 959(a) and 960.

(In violation of Title 21, United States Code, Section 963.)

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COUNT2

THE GRAND JURY FURTHER CHARGES THAT:

(Aiding and Abetting the Distribution of Five Kilograms or More of Cocaine Knowing and
Intending that it would be Unlawfully Imported Into the United States)

On or about October 31,2013, the defendants, JOHANNA JAZMIN

SANCHEZ-GUZMAN, a/k/a "Tatiana," and MARCO ANTONIO ROBAYO-BARBOSA,

within thejurisdiction of the United States and in an offense begun andcommitted outside the

jurisdiction of a particular State or district, andwho will be first brought to the Eastern District of

Virginia, did knowingly and intentionally aid and abet the distribution of five kilograms or more

of a mixture and substance containing a detectable amount of cocaine, a Schedule II controlled

substance, knowing and intending that such substance would be unlawfully imported into the

United States.

(Inviolation of Title 21, United States Code, Section 959(a) and Title 18, United States

Code, Section 2.)

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FORFEITURE NOTICE

The defendants, if convicted of the violation alleged in Count 1 and Count 2 of this

Indictment, shall forfeit to the United States pursuant to Title 21, United States Code, Sections

853(a) and 970, any property constituting, or derived from, any proceeds each defendant

obtained, directly or indirectly, as the result of such violation; and any of the defendant's property

used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of,

such violation. This property includes, but is not limited to $5,000,000 in United States

currency, representing proceeds that the defendant obtained in the course of the conspiracy

alleged in Count 1 and Count 2 of this Indictment.

(Pursuant to Title 21, United States Code, Section 853.)

ATRUEBILL^^
to the-r-Gov»rnmGnt Act,
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Foreperson
Dana
Uana J. Boente

^it(
ited States Attorney

By:
Dennis M. Fitzpatrick
Assistant United Statd's Attorney