Case 3:16-cr-00406-SI Document 1 Filed 10/05/16 Page 1 of 4

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA

INDICTMENT
v.
21 U.S.C. §§ 84l(a)(l),
ALFREDO NAVARRO-GUTIERREZ 84l(b)(l)(A), 841(b)(l)(C), 846,
Jr., and 853
VICTOR HUGO NAVARRO-
GUTIERREZ and Forfeiture Allegation
JESUS A. SANDOVAL-LEYVA,
UNDER SEAL
Defendants.

THE GRAND JURY CHARGES:

COUNT 1
Conspiracy to Possess with Intent to Distribute Methamphetamine
21 U.S.C. §§ 84l(a)(l), 84l(b)(l)(A), and 846

Beginning at a time unknown and continuing up to and including October 6, 2016, in the

District of Oregon and elsewhere, JESUS A. SANDOVAL-LEYVA, VICTOR HUGO

NAVARRO-GUTIERREZ and ALFREDO NAVARRO-GUTIERREZ Jr., defendants

herein, did knowingly and willfully combine, conspire, confederate and agree together, with each

other, and with other persons known and unknown to the grand jury, to possess with the intent to

distribute and to distribute fifty grams or more ofmethamphetamine (actual), a Schedule II

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controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and

(b)(l)(A) and Title 21, United States Code, Section 846.

COUNT2
Possession with the Intent to Distribute Methamphetamine
21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(A)

On or about January 19, 2016, in the District of Oregon and elsewhere, JESUS A.

SANDOVAL-LEYVA, defendant herein, did knowingly and intentionally possess with the

intent to distribute fifty grams or more ofmethamphetamine (actual), a Schedule II controlled

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

COUNT3
Possession with the Intent to Distribute Methamphetamine
21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A)

On or about February 18, 2016, in the District of Oregon and elsewhere, JESUS A.

SANDOVAL-LEYVA, defendant herein, did knowingly and intentionally possess with the

intent to distribute fifty grams or more ofmethamphetamine (actual), a Schedule II controlled

substance, in violation of Title 21, United States Code, Sections 84l(a)(l) and (b)(l)(A).

COUNT4
Possession with the Intent to Distribute Methamphetamine
21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(A)

On or about May 5, 2016, in the District of Oregon and elsewhere, ALFREDO

NAVARRO-GUTIERREZ Jr., and JESUS A. SANDOVAL-LEYVA, defendants herein, did

knowingly and intentionally possess with the intent to distribute fifty grams or more of

methamphetamine (actual), a Schedule II controlled substance, in violation of Title 21, United

States Code, Sections 84l(a)(l) and (b)(l)(A).

II II

II II

Indictment Page 2
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COUNTS
Possession with the Intent to Distribute Methamphetamine
21 U.S.C. §§ 841(a)(l) and 84l(b)(l)(A)

On or about June 21, 2016, in the District of Oregon and elsewhere, JESUS A.

SANDOVAL-LEVYA, defendant herein, did knowingly and intentionally possess with the

intent to distribute fifty grams or more ofmethamphetamine (actual), a Schedule II controlled

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

COUNT6
Possession with the Intent to Distribute Methamphetamine
21 U.S.C. §§ 841(a)(l) and 841(b)(l)(A)

On or about August 11, 2016, in the District of Oregon and elsewhere, ALFREDO

NAVARRO-GUTIERREZ Jr. and VICTOR HUGO NAVARRO-GUTIERREZ, defendants

herein, did knowingly and intentionally possess with the intent to distribute fifty grams or more

ofmethamphetamine (actual), a Schedule II controlled substance, in violation of Title 21, United

States Code, Sections 841(a)(l) and (b)(l)(A).

COUNT7
Possession with the Intent to Distribute Heroin
21 U.S.C. §§ 841(a)(l) and 841(b)(l)(C)

On or about June 21, 2016, in the District of Oregon and elsewhere, ALFREDO

NAVARRO-GUTIERREZ Jr., and JESUS A. SANDOVAL-LEVYA, defendants herein, did

knowingly and intentionally possess with the intent to distribute a mixture or substance

containing a detectable amount of heroin, a Schedule J controlled substance, in violation of Title

21, United States Code, Sections 84l(a)(l) and (b)(l)(C).

CRIMINAL FORFEITURE ALLEGATIONS

Upon conviction of the controlled substance offenses alleged in Counts 1-7 of this

Indictment, ALFREDO NAVARRO-GUTIERREZ Jr., VICTOR HUGO NAVARRO-

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GUTIERREZ and JESUS A. SANDOVAL-LEYVA, defendants herein, shall forfeit to the

United States, pursuant to Title 21, United States Code, Section 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.

Dated this { day of October 2016.

A TRUE BILL.

~~JCIATING FOREPERSON
Presented by:

\
PL. STRICKLAND, #96118 _ )
ssistant United States Attorney

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