U.S. vs. Juan Rivera-Gutierrez and Pedro Pabon, Jr.

Case 2:17-cr-00060-AWA-DEM Document 1 Filed 04/19/17 Page 1 of 13 PageID# 1
nuo
APR I 9 2017
IN THE UNITED STATES DISTRICT COUR f
FOR THE EASTERN DISTRICT OF VIRGINM
CLEHK, U.S. DiSTRiCT COURT
KOR'-OlK. VA
Norfolk Division
UNITED STATES OF AMERICA UNDER SEAL
V. CRIMINAL NO. 2:17cr
JUAN RIVERA-GUTIERREZ, 21U.S.C. 846

a/k/a "Franky" Conspiracy to Distribute Cocaine
a/k/a "El Gordo" (Count 1)
(Counts 1,4-9, 11-12)
21 U.S.C. 841(a)(1) and (b)(1)(C)
and Distribution of Cocaine
(Counts 2-10)
PEDRO PABON, JR.,
a/k/a "Tony" 18 U.S.C. 924(c)(1)(A)
(Counts 1-3, 10) Possession of Firearms During and Relation
to a Drug Trafficking Crime
Defendants. (Count 11)
26 U.S.C. 5861(d)
Possession of an Unregistered National
Firearms Act Firearm (Silencer)
(Count 12)
18 U.S.C. 924(d), 21 U.S.C. 853,

28 U.S.C. 2461
Criminal Forfeiture
INDICTMENT
April 2017 Term - at Norfolk, Virginia
THE GRAND JURY CHARGES THAT;
COUNT ONE
(Conspiracy to Distribute Cocaine)
Beginning on a date unknown, but no later than September 2013, and continuing
thereafter until in or about April 2017, within the Eastern District of Virginia and elsewhere, the
defendants, JUAN RIVERA-GUTIERREZ, a/k/a "Franky," a/k/a "El Gordo," and PEDRO
PABON, JR., a/k/a "Tony," did unlawfully, knowingly, and intentionally combine, conspire,
confederate, and agree with each other and with other persons, both known and unknown to the
grand jury, to commit the following offense: unlawfully, knowingly and intentionally
manufacture, distribute, and possess with intent to distribute, five hundred (500) grams or more
of a mixture and substance containing a detectable amount of cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B).
Ways, Manner, and Means of the Conspiracy
1. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ and PEDRO
PABON, JR. to serve as suppliers of wholesale quantities of cocaine in the Hampton Roads area.
PABON, JR. to traffic wholesale amounts of cocaine from New York, North Carolina, and
Florida to the Hampton Roads area of Virginia and to West Virginia for resale.
PABON, JR. to use code language for cocaine, like "fire," "motors," and "cheese."
4. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ to sell firearms
along with cocaine.
OVERT ACTS
In furtherance of the conspiracy and to accomplish the objective thereof, the following
overt acts were committed in the Eastern District of Virginia and elsewhere:
1, On or about May 29, 2014, in Virginia Beach, Virginia, PEDRO PABON, JR. sold
approximately one ounce of cocaine for approximately $1,260 in United States currency to a
confidential informant ("CI-1").
2, On or about September 3, 2014, in Virginia Beach, Virginia, PEDRO PABON, JR.

negotiated a sale of cocaine with CI-1.
3. On or about September 25, 2014, in Virginia Beach, Virginia, PEDRO PABON,
JR. sold approximately one ounce of cocaine for approximately $1,250 in United States currency
to CI-1.
4. On or about December 3, 2015, in Virginia Beach, Virginia, PEDRO PABON, JR.
met with CI-1 in the parking lot of a Food Lion grocery store where PABON was employed ("the
Food Lion"). PABON provided advice to CI-1 on how to add cutting agents to cocaine to increase
profits. PABON suggested adding a cutting agent to cocaine known as "Aroma," a product
commonly used as a carpet cleaner.
5. On or about December 7,2015, in Chesapeake, Virginia, PEDRO PABON, JR. met
with CI-1 to advise him/her that JUAN RIVERA-GUTIERREZ was ready to deal wholesale
amounts of cocaine directly to him/her. PABON indicated that the quality of the cocaine was so
good that it was referred to as "fire," and he instructed CI-1 to refer to "motors" when discussing
ounces of cocaine with RIVERA-GUTIERREZ.
6. On or about December 7, 2015, JUAN RIVERA-GUTIERREZ contacted CI-1 to
negotiate the sale of an ounce of cocaine. RIVERA-GUTIERREZ described the cocaine as un
cut and of good quality.
7. On or about December 9, 2015, JUAN RIVERA-GUTIERREZ negotiated the sale
of two ounces of cocaine with CI-1.
8. On or about December 10, 2015, in Virginia Beach, Virginia, in the Food Lion
parking lot, JUAN RIVERA-GUTIERREZ sold approximately two ounces of cocaine for
approximately $2,400 in United States currency to CI-1.
9. On or about December 13,2015, JUAN RIVERA-GUTIERREZ informed CI-1 that

he had more cocaine to sell and was willing to sell three ounces for $1,000 an ounce.
10. On or about December 16, 2015, in Virginia Beach, Virginia, in the Food Lion
parking lot, JUAN RIVERA-GUTIERREZ sold approximately three ounces of cocaine to CI-1 for
approximately $3,000 in United States currency.
11. On or about December 18, 2015, JUAN RIVERA-GUTIERREZ contacted CI-1
and offered to sell a kilogram of cocaine for $42,000.
12. On or about December 22,2015, PEDRO PABON, JR. told CI-1 that PABON and
RIVERA-GUTIERREZ were looking for new customers who were interested in purchasing
cocaine. PABON informed CI-1 that he could obtain kilogram amounts of cocaine from sources
of supply in New York for approximately $34,000, and offered to provide such cocaine on an
upfront or consignment basis.
13. On or about January 13, 2016, PEDRO PABON, JR. informed CI-1 that he and
JUAN RIVERA-GUTIERREZ could procure kilogram amounts of cocaine and that it was most
profitable to purchase a kilogram and re-sell it in ounce quantities for $1,000 each.
14. On or about March 24, 2016, PEDRO PABON, JR. contacted JUAN RIVERA-
GUTIERREZ to arrange the sale of multiple ounces of cocaine to CI-1.
15. On or about April 12,2016, PEDRO PABON, JR. met with CI-1 to further discuss
a sale of multiple ounces of cocaine. PABON informed CI-1 that he would contact JUAN
RIVERA-GUTIERREZ later that day to organize the transaction.
16. On or about April 13, 2016, PEDRO PABON, JR. informed CI-1 that JUAN
RIVERA-GUTIERREZ had the "white stuff and would soon be ready to sell it.
17. On or about May 23, 2016, in Virginia Beach, Virginia, in the Food Lion parking
lot, JUAN RIVERA-GUTIERREZ sold approximately three ounces of cocaine to CI-1 for
18. On or about June 8,2016, JUAN RIVERA-GUTIERREZ and CI-1 had aphone call
to discuss extra cash that CI-1 had given RIVERA-GUTIERREZ during the May 23,2016, cocaine
transaction. RIVERA-GUTIERREZ informed CI-1 that he/she would be compensated with extra
cocaine during the next drug transaction.
19. On or about June 10, 2016, in Virginia Beach, Virginia, in the Food Lion parking
lot, JUAN RIVERA-GUTIERREZ distributed approximately one ounce of cocaine to CI-1.
20. On or about July 5, 2016, JUAN RIVERA-GUTIERREZ informed CI-1 that a
complete "motor," referring to a kilogram of cocaine, could be purchased from him for $36,000.
21. On or about July 20, 2016, PEDRO PABON, JR. met with CI-1 in the Food Lion
parking lot and informed him/her that JUAN RIVERA-GUTIERREZ was expecting a shipment of
cocaine to sell.
22. On or about August 15, 2016, PEDRO PABON, JR. discussed future sales of
cocaine with CI-1.
23. On or about September 28,2016, JUAN RIVERA-GUTIERREZ contacted CI-1 to
discuss a new shipment of cocaine he had recently received and told CI-1 he could provide CI-1
with whatever quantity he/she needed. RIVERA-GUTIERREZ sent a photo to CI-1 of a custom
motorcycle that he had seized from a drug customer who was unable to pay a drug debt.
24. On or about October 1, 2016, JUAN RIVERA-GUTIERREZ told CI-1 that he had
been providing a kilogram ofcocaine on a weekly basis to a customer in North Carolina. Because
the customer was unable to re-pay the debt, RIVERA-GUTIERREZ claimed he had seized a
custom motorcycle and a boat as payment.
25. On or about October 13, 2016, JUAN RIVERA-GUTIERREZ negotiated the sale
of cocaine and multiple firearms with CI-1.
26. On or about October 20, 2016, in Virginia Beach, Virginia, in the Food Lion
parking lot, JUAN RIVERA-GUTIERREZ sold CI-1 approximately two ounces of cocaine for
approximately $2,000 in United States currency and five firearms with high capacity clips and a
silencer for approximately $5,000 in United States currency. RIVERA-GUTIERREZ sold a
Russian Izhmash Saiga 12 caliber shotgun, an Israeli Tavor Sar 556 caliber rifle, a DMPS Panther
223 caliber rifle, a stolen Olympic MRF AR-15 multi-caliber rifle, and a Colt M4LE 556 caliber
rifle. Additionally, RIVERA-GUITIERREZ sold a Knights Armament QD 556 caliber silencer,
which was a United States Department of Defense asset.
27. On or about November 17, 2016, in Virginia Beach, Virginia, in the Food Lion
parking lot, JUAN RIVERA-GUTIERREZ sold approximately four ounces of cocaine to CI-1 for
28. From in or about June 10, 2016, to in or about November 17, 2016, PEDRO
PABON, JR. supplied the cocaine that JUAN RIVERA-GUTIERREZ sold to CI-1.
29. On or about December 28, 2016, JUAN RIVERA-GUTIERREZ contacted CI-1
and offered to sell him/her cocaine.
30. On or about January 17, 2017, JUAN RIVERA-GUTIERREZ negotiated a sale of
four ounces of cocaine with CI-1.
31. On or about January 18, 2017, PEDRO PABON, JR. met with CI-1 to inform
him/her that he would not know the price until he was able to examine the "batch" of cocaine.
PABON informed CI-1 that the price of an ounce of cocaine was higher since it was difficult to
traffic into Virginia. PABON described to CI-1 JUAN RIVERA-GUTIERREZ's methods for
cutting cocaine and adding adulterants to it for additional profit. PABON agreed to sell cocaine
to CI-1 for the same price he was selling it to RIVERA-GUITIERREZ,
32. On or about January 27, 2017, PEDRO PABON, JR. negotiated the sale of cocaine
with CI-1.
33. On or about January 30,2017, in Virginia Beach, Virginia, in the Food Lion parking
lot, PEDRO PABON, JR. sold approximately two ounces of cocaine to CI-1 for approximately
$2,400 in United States currency.
34. On or about March 23, 2017, in Chesapeake, Virginia, PEDRO PABON, JR.
informed CI-1 about the efforts he made the previous day to contact JUAN RIVERA-
GUTIERREZ's source of supply to obtain cocaine.
(All in violation of Title 21, United States Code, Section 846.)

COUNT TWO
(Distribution of Cocaine)
On or about May 29, 2014, in Virginia Beach, Virginia, within the Eastern District of
Virginia, the defendant, PEDRO PABON, JR., a/k/a "Tony," did unlawfully, knowingly and
intentionally distribute a mixture and substance containing a detectable amount of cocaine, a
schedule II controlled substance.
(In violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).)
COUNTTHREE
On or about September 25, 2014, in Virginia Beach, Virginia, within the Eastern District
of Virginia, the defendant, PEDRO PABON, JR., a/k/a "Tony," did unlawfully, knowingly and
intentionally distribute a mixture and substance containing a detectable amount of cocaine, a
schedule II controlled substance.
COUNT FOUR
On or about December 10, 2015, in Virginia Beach, Virginia, within the Eastem District
of Virginia, the defendant, JUAN RIVERA-GUTIERREZ, a/k/a "Franky," a/k/a "El Gordo," did
unlawfully, knowingly and intentionally distribute a mixture and substance containing a
detectable amount of cocaine, a schedule II controlled substance.
8
COUNT FIVE
On or about December 16, 2015, in Virginia Beach, Virginia, within the Eastern District
COUNT SIX
On or about May 23, 2016, in Virginia Beach, Virginia, within the Eastern District of
Virginia, the defendant, JUAN RIVERA-GUTIERREZ, dJkJdi "Franky," a/k/a "El Gordo," did
COUNT SEVEN
On or about June 10, 2016, in Virginia Beach, Virginia, within the Eastern District of
Virginia, the defendant, JUAN RIVERA-GUTIERREZ, a/k/a "Franky," a/k/a "El Gordo," did
COUNT EIGHT
On or about October 20, 2016, in Virginia Beach, Virginia, within the Eastern District of
COUNT NINE
On or about November 17, 2016, in Virginia Beach, Virginia, within the Eastern District
COUNT TEN
On or about January 30, 2017, in Virginia Beach, Virginia, within the Eastern District of
10
COUNT ELEVEN
(Possession of Firearms During and Relation to a Drug Trafficking Crime)
On or about October 20, 2016, in Virginia Beach, Virginia, within the Eastern District of
Virginia, the defendant, JUAN RIVERA-GUTIERREZ, a/k/a "Franky," ayTi/a "El Gordo," did
knowingly and unlawfully possess one or more firearms in furtherance of, and use and carry one
or more firearms during and in relation to, a drug trafficking crime for which he may be
prosecuted in a court of the United States, including but not limited to the drug trafficking crime
alleged in Count Eight of this Indictment, which description of said drug trafficking crime is re-
alleged and incorporated by reference as if set forth in full herein.
(In violation of Title 18, United States Code, Section 924(c)(1)(A).)
COUNT TWELVE
(Possession of Unregistered Silencer)
On or about October 20,2016, in Virginia Beach, Virginia, within the Eastern District of
knowingly possess a firearm that was required to have been registered in the National Firearms
Registration and Transfer Record, to wit: a Knights Armament QD 556 caliber silencer; and was
not registered to the defendant in the National Firearms Registration and Transfer Record.
(In violation of Title 26, United States Code, Section 5861(d).)
11
CRIMINAL FORFEITURE
THE GRAND JURY FURTHER ALLEGES AND FINDS PROBABLE CAUSE THAT:
1. The defendants, JUAN RIVERA-GUTIERREZ, a/k/a "Franky," a/k/a "El Gordo,"
and PEDRO PABON, JR., a/k/a "Tony," if convicted of any ofthe violations alleged in this
Indictment, shall forfeit to the United States, as part of the sentencing pursuant to Federal Rule of
Criminal Procedure 32.2, any firearm or ammunition involved in or used in the violation.
2. The defendants, JUAN RIVERA-GUTIERREZ, "Franky," Msi "El Gordo,"
and PEDRO PABON, JR., a/k/a "Tony," if convicted of any of the violations alleged in counts
one through ten of this Indictment, shall forfeit to the United States, as part of the sentencing
pursuant to Federal Rule of Criminal Procedure 32.2, and in addition to the property set forth in
paragraph one above:
a. Any property constituting, or derived from, any proceeds the defendant obtained,
directly or indirectly, as the result of the violation; and
b. Any property used, or intended to be used, in any manner or part, to commit, or to
facilitate the commission of, the violation.
3. If any property that is subject to forfeiture above, as a result of any act or
omission of the defendants, (a) cannot be located upon the exercise of due diligence, (b) has been
transferred to, 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 that cannot be divided without difficulty, it is the intention of the United States to
seek forfeiture of any other property of the defendants, as subject to forfeiture under Title 21,
United States Code, Section 853(p).
(In accordance with 18 U.S.C. 924(d) by 28 U.S.C. 2461, and 21 U.S.C. 853.)
12
Sealed Pursuant to the

United States v. Rivera-Gutierrez et. al. c-Caovernment Act of 2002
2:17cr(^0
A TRUE BILL:
REDACTED COPY
FOREPERSON
Dana J. Boente
UNITED STATES ATTORNEY
John F. Butler
Special Assistant United States Attorney
Andrew C. Bosse
Assistant United States Attorney
Attorneys for the United States
United States Attorney's Office
101 West Main Street, Suite 6000
Norfolk, VA 23510
Office Number: 757-441-6331
Email Address: john.f.butler@usdoj.gov
andrew.bosse@usdoj .gov
13
Case 2:17-cr-00060-AWA-DEM Document 1-1 Filed 04/19/17 Page 1 of 4 PageID# 14
REDACTED
JS 45 (11/2002)
Criminal Case Cover Sheet U.S. District Court
Place of Offense: Under Seal: Yes ^ No Judge Assigned:

Citv: EDVA Superseding Indictment: Yes Criminal Number: 2:17cr^^
New Defendant:
County/Parish: Same Defendant:
Magistrate Judge Case Number: Arraignment Date:

Search Warrant Case Number:
R 20/R 40 from District of

Defendant Information;
Juvenile: Yes No 13 FBI#
Defendant Name: JUAN RIVERA-GUTIERREZ Alias Name(s): "Franky" and "El Gordo"
Address; Chesapeake, VA
Employment: Norfolk, VA
Birth Date; 1982 SS#:xxx/xx//3087 Sex; Race: Nationality: Place of Birth:
Height: Weight: Hair: Eyes: Scars/Tattoos;
Interpreter: Yes No 0 List Language and/or dialect:

Location Status:
Arrest Date:
Already in Federal Custody as of: in:
Already in State Custody On Pretrial Release Not in Custody
^ Arrest Warrant Requested Fugitive Summons Requested
Arrest Warrant Pending Detention Sought Bond
Defense Counsel Information:
Name: D Court Appointed

Address: D Retained
Telephone: n Public Defender
office of Federal Public Defendershould not be appointed due to conflictof interest
CJA attomev: should not be appointed due to conflictof interest

U.S. Attorney Information:
SAUSA: John F.Butler Telephone No. 757-441-6331 Bar#: 72788
Complainant Agency. Address & Phone Number or Person & Title:
Drug Enforcement Administration - 200 Granby Street, Suite 435, Norfolk, VA 23510 (757) 314-2200
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) Capital/Felony/Misd/Petty
Set 1 21 U.S.C. 846 Conspiracy to Distribute Cocaine 1 Felony

Defendant's Name: Juan Rivera-Gutierrez
District Court Case Number (To be filled in by Deputy Clerk): 2:17cr
U.S.C. Citations (continued)

21U.S.C. 841(a)(1) &
Set 2 (b)(1)(C) Distribution of Cocaine 4-9 Felony
Possession of Firearms During and
Relation to a Drug Trafficking
Set 3 18 U.S.C. 924(c)(1)(A) Crime 11 Felony
Possession of an Unregistered
National Firearms Act Firearm
Set 4 26 U.S.C. 5861(d) (Silencer) 12 Felony
Set 5
Set 6
Set?
Set 8
Set 9
Set 10
Set 11
Set 12
Set 13
Set 14
Set 15
Set 16
Set 17
Set 18
Set 19
Set 20
Set 21
Set 22
Set 23
Set 24
REDACTED
Criminal Case Cover Sheet U.S. District Court
Place of Offense: Under Seal: Yes IS No Judge Assigned:

Citv; EDVA Superseding Indictment: Yes Criminal Number: 2:17cr
New Defendant:
County/Parish: Same Defendant:
Magistrate Judge Case Number: Arraignment Date:

Search Warrant Case Number:
R 20/R 40 from District of

Defendant Information:
Juvenile: Yes No E! FBI#
Defendant Name: PEDRO PABON, JR. Alias Name(s): "Tony"

Address: Virginia Beach, VA
Employment:
Birth Date: 1974 SS#: xxx/xx/1181 Sex: Race: Nationality: Place of Birth:
Height: Weight: Hair: Eyes: Scars/Tattoos:
Interpreter: Yes No ^ List Language and/or dialect:

Location Status:
Arrest Date:
n Already in Federal Custody as of; in:
D Already in State Custody On Pretrial Release Not in Custody
Kl Arrest Warrant Requested Fugitive Summons Requested
Arrest Warrant Pending Detention Sought Bond
Defense Counsel Information:
Name: D Court Appointed

Address: D Retained
Telephone: Public Defender
Office of Federal Public Defender should not be appointed due to conflict of interest
CJ A attorney: should not be appointed due to conflict of interest

U.S. Attorney Information;
SAUSA; John F. Butler Telephone No. 757-441-6331 Bar #: 72788
Complainant Agency. Address & Phone Number or Person & Title:
Drug Enforcement Administration - 200 Granby Street, Suite 435, Norfolk, VA 23510 (757) 314-2200
U.S.C. Citations:
Set 1 21 U.S.C. 846 Conspiracy to Distribute Cocaine 1 Felony

Defendant's Name: Pedro Pabon, Jr.
District Court Case Number (To be filled in by Deputy Clerk); 2:17cr
U.S.C. Citations (continued)

21 U.S.C. 841(a)(1) &
Set 2 (b)(1)(C) Distribution of Cocaine 2,3,10 Felony
Set 3
Set 4
Set 5
Set 6
Set?
Set 8
Set 9
Set 10
Set 11
Set 12
Set 13
Set 14
Set 15
Set 16
Set 17
Set 18
Set 19
Set 20
Set 21
Set 22
Set 23
Set 24
Set 25
Set 26
Set 27

U.S. vs. Juan Rivera-Gutierrez and Pedro Pabon, Jr.

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U.S. vs. Juan Rivera-Gutierrez and Pedro Pabon, Jr.

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Case 2:17-cr-00060-AWA-DEM Document 1 Filed 04/19/17 Page 1 of 13 PageID# 1

UNITED STATES OF AMERICA UNDER SEAL

V. CRIMINAL NO. 2:17cr

JUAN RIVERA-GUTIERREZ, 21U.S.C. 846

18 U.S.C. 924(d), 21 U.S.C. 853,

April 2017 Term - at Norfolk, Virginia

THE GRAND JURY CHARGES THAT;

(Conspiracy to Distribute Cocaine)

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

Ways, Manner, and Means of the Conspiracy

1. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ and PEDRO

2. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ and PEDRO

3. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ and PEDRO

4. It was part of the conspiracy for JUAN RIVERA-GUTIERREZ to sell firearms

along with cocaine.

confidential informant ("CI-1").

2, On or about September 3, 2014, in Virginia Beach, Virginia, PEDRO PABON, JR.

negotiated a sale of cocaine with CI-1.

3. On or about September 25, 2014, in Virginia Beach, Virginia, PEDRO PABON,

4. On or about December 3, 2015, in Virginia Beach, Virginia, PEDRO PABON, JR.

commonly used as a carpet cleaner.

5. On or about December 7,2015, in Chesapeake, Virginia, PEDRO PABON, JR. met

ounces of cocaine with RIVERA-GUTIERREZ.

6. On or about December 7, 2015, JUAN RIVERA-GUTIERREZ contacted CI-1 to

negotiate the sale of an ounce of cocaine. RIVERA-GUTIERREZ described the cocaine as un

cut and of good quality.

7. On or about December 9, 2015, JUAN RIVERA-GUTIERREZ negotiated the sale

of two ounces of cocaine with CI-1.

approximately $2,400 in United States currency to CI-1.

9. On or about December 13,2015, JUAN RIVERA-GUTIERREZ informed CI-1 that

approximately $3,000 in United States currency.

11. On or about December 18, 2015, JUAN RIVERA-GUTIERREZ contacted CI-1

and offered to sell a kilogram of cocaine for $42,000.

upfront or consignment basis.

GUTIERREZ to arrange the sale of multiple ounces of cocaine to CI-1.

RIVERA-GUTIERREZ later that day to organize the transaction.

approximately $3,300 in United States currency.

cocaine during the next drug transaction.

lot, JUAN RIVERA-GUTIERREZ distributed approximately one ounce of cocaine to CI-1.

20. On or about July 5, 2016, JUAN RIVERA-GUTIERREZ informed CI-1 that a

cocaine with CI-1.

23. On or about September 28,2016, JUAN RIVERA-GUTIERREZ contacted CI-1 to

custom motorcycle and a boat as payment.

of cocaine and multiple firearms with CI-1.

silencer for approximately $5,000 in United States currency. RIVERA-GUTIERREZ sold a

rifle. Additionally, RIVERA-GUITIERREZ sold a Knights Armament QD 556 caliber silencer,

which was a United States Department of Defense asset.

approximately $4,000 in United States currency.

29. On or about December 28, 2016, JUAN RIVERA-GUTIERREZ contacted CI-1

and offered to sell him/her cocaine.

30. On or about January 17, 2017, JUAN RIVERA-GUTIERREZ negotiated a sale of

four ounces of cocaine with CI-1.

to CI-1 for the same price he was selling it to RIVERA-GUITIERREZ,

$2,400 in United States currency.

GUTIERREZ's source of supply to obtain cocaine.

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

intentionally distribute a mixture and substance containing a detectable amount of cocaine, a

schedule II controlled substance.

intentionally distribute a mixture and substance containing a detectable amount of cocaine, a

schedule II controlled substance.

unlawfully, knowingly and intentionally distribute a mixture and substance containing a

detectable amount of cocaine, a schedule II controlled substance.

unlawfully, knowingly and intentionally distribute a mixture and substance containing a

detectable amount of cocaine, a schedule II controlled substance.