23 Indicted in Large Scale Denver Heroin Ring

Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 1 of 25
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO
Criminal Case No. 20-CR-292-WJM
UNITED STATES OF AMERICA,
Plaintiff,
v.
1. BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
2. AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
3. HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
4. JORGE REYES CRUZ-GARCIA,
a.k.a. “Comino,”
5. BRADLEY MICHAEL WHITE,
a.k.a., Brian,”
6. MICHAEL IAN MILLS,
7. ANNA MARIE REBEKAH DAVIS,
a.k.a. “Green,”
8. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Tavo,”
a.k.a. “UM-2911,”
a.k.a. “UM-9465,”
11. KEVEN ALEXANDER PEREZ,
12. VICTORIANO HINOJOSA,
13. OSCAR MANUEL OLIVEROS,
a.k.a. “Vitamina,” and “Mario,”
15. DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,”
a.k.a. “UM-6508,”
17. CHRISTIAN ANTHONY CARVER,
18. ABISAI ESCOBAR FLORES,
a.k.a. “Guerrero,”
a.k.a. “Primo,”
20. NICHO GARCIA,
1
21. JESSE CERVANTES,

22. VICTOR ALONSO CARREON,
a.k.a. “Alonso,” and
23. ADRIANNA RAFAELA HOLGUIN,
a.k.a. “Fela.”
Defendants.
______________________________________________________________________
INDICTMENT
______________________________________________________________________
COUNT 1
On or about and between June 1, 2019 and September 1, 2020, both dates
being approximate and inclusive, within the State and District of Colorado and
elsewhere, the defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” AZUSENA
MARIBEL SIERRA, a.k.a. “Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA, a.k.a. “Comino,” BRADLEY MICHAEL WHITE, a.k.a.
Brian,” MICHAEL IAN MILLS, ANNA MARIE REBEKAH DAVIS, a.k.a. “Green,” FIRST
NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN,
LAST NAME UNKNOWN, a.k.a. “UM-2911,” FIRST NAME UNKNOWN, LAST NAME
UNKNOWN, a.k.a. “UM-9465,” KEVEN ALEXANDER PEREZ, VICTORIANO
HINOJOSA, OSCAR MANUEL OLIVEROS, FIRST NAME UNKNOWN, LAST NAME
UNKNOWN, a.k.a. “Vitamina,” and “Mario,” DIEGO ROMERO-CRUZ, a.k.a. “Enrique,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508,” CHRISTIAN
ANTHONY CARVER, ABISAI ESCOBAR FLORES, a.k.a. “Guerrero,” FIRST NAME
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Primo,” NICHO GARCIA, JESSE
CERVANTES, and VICTOR ALONSO CARREON, a.k.a. “Alonso,” and others known
and unknown to the Grand Jury, did knowingly and intentionally combine, conspire,
2
confederate and agree, with interdependence, to distribute and possess with the intent
to distribute one or more of the following controlled substances: (1) 1 kilogram and 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)(1)
and (b)(1)(A)(i); and (2) 100 grams and 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)(1) and (b)(1)(B)(i).
All in violation of Title 21, United States Code, Section 846.
PENALTY ALLEGATIONS:
With respect to defendants: BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,”
AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a.
“Gordo,” JORGE REYES CRUZ-GARCIA, a.k.a. “Comino,” FIRST NAME UNKNOWN,
LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN, LAST NAME
UNKNOWN, a.k.a. “UM-2911,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-9465,” KEVEN ALEXANDER PEREZ, VICTORIANO HINOJOSA, OSCAR
MANUEL OLIVEROS, FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.
“Vitamina,” and “Mario,” DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” FIRST NAME
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508,” CHRISTIAN ANTHONY
CARVER, ABISAI ESCOBAR FLORES, a.k.a. “Guerrero,” FIRST NAME UNKNOWN,
LAST NAME UNKNOWN, a.k.a. “Primo,” NICHO GARCIA, JESSE CERVANTES, and
VICTOR ALONSO CARREON, a.k.a. “Alonso,” the amount involved in the conspiracy
attributable to these defendants as a result of their own conduct, and the conduct of
others reasonably foreseeable to them is 1 kilogram and more of a mixture and
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substance containing a detectable amount of heroin, a Schedule I controlled substance,
in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(A)(i).
With respect to defendants: BRADLEY MICHAEL WHITE, a.k.a. Brian,”
MICHAEL IAN MILLS, ANNA MARIE REBEKAH DAVIS, a.k.a. “Green,” the amount
involved in the conspiracy attributable to these defendants as a result of their own
conduct, and the conduct of others reasonably foreseeable to them is 100 grams and
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(a)(1)
and (b)(1)(B)(i).
COUNT 2
On or about October 21, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and BRADLEY MICHAEL
WHITE, a.k.a. “Brian,” did knowingly and intentionally use a communications device,
specifically a telephone, in committing, and in causing and facilitating the commission
of, a felony delineated in Title 21 of the United States Code, specifically the crime
alleged in Count 1 of this Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 3
On or about October 21, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and BRADLEY MICHAEL
WHITE, a.k.a. “Brian,” did knowingly and intentionally distribute and possess with the
intent to distribute a mixture and substance containing a detectable amount of heroin, a
4
Schedule I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
command, induce and procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
and Title 18, United States Code, Section 2.
COUNT 4
On or about December 5, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS, did
knowingly and intentionally use a communications device, specifically a telephone, in
committing, and in causing and facilitating the commission of, a felony delineated in
Title 21 of the United States Code, specifically the crime alleged in Count 1 of this
Indictment.
COUNT 5
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS did
knowingly and intentionally distribute and possess with the intent to distribute 100
grams and more of a mixture and substance containing a detectable amount of heroin,
a Schedule I Controlled Substance, and did knowingly and intentionally aid, abet,
counsel, command, induce and procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B)(i)
5
COUNT 6
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS did
knowingly and intentionally distribute and possess with the intent to distribute 100
grams and more of a mixture and substance containing a detectable amount of heroin,
a Schedule I Controlled Substance, and did knowingly and intentionally aid, abet,
counsel, command, induce and procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B)(i)
COUNT 7
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and ANNA MARIE REBEKAH
DAVIS, a.k.a. “Green,” did knowingly and intentionally use a communications device,
COUNT 8
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and ANNA MARIE REBEKAH
DAVIS, a.k.a. “Green,” did knowingly and intentionally distribute and possess with the
intent to distribute a mixture and substance containing a detectable amount of heroin, a
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Schedule I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
COUNT 9
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and JORGE REYES CRUZ-
GARCIA, a.k.a. “Comino,” did knowingly and intentionally use a communications device,
COUNT 10
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and JORGE REYES CRUZ-
GARCIA, a.k.a. “Comino,” did knowingly and intentionally distribute and possess with
the intent to distribute a mixture and substance containing a detectable amount of
heroin, a Schedule I Controlled Substance, and did knowingly and intentionally aid,
abet, counsel, command, induce and procure the same.
COUNT 11
On or about January 16, 2020, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and HECTOR NUNEZ-
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SANDOVAL, a.k.a. “Gordo,” did knowingly and intentionally use a communications
device, specifically a telephone, in committing, and in causing and facilitating the
commission of, a felony delineated in Title 21 of the United States Code, specifically the
crime alleged in Count 1 of this Indictment.
COUNT 12
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and FIRST NAME
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Vitamina,” and “Mario,” did knowingly
and intentionally use a communications device, specifically a telephone, in committing,
and in causing and facilitating the commission of, a felony delineated in Title 21 of the
United States Code, specifically the crime alleged in Count 1 of this Indictment.
COUNT 13
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and FIRST NAME
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,” did knowingly and intentionally
use a communications device, specifically a telephone, in committing, and in causing
and facilitating the commission of, a felony delineated in Title 21 of the United States
Code, specifically the crime alleged in Count 1 of this Indictment.
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COUNT 14
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-2911,” did knowingly and
intentionally use a communications device, specifically a telephone, in committing, and
in causing and facilitating the commission of, a felony delineated in Title 21 of the
COUNT 15
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” BENJAMIN LOPES-
ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.
“Tavo,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-2911,” did
knowingly and intentionally distribute and possess with the intent to distribute a mixture
and substance containing a detectable amount of heroin, a Schedule I Controlled
Substance, and did knowingly and intentionally aid, abet, counsel, command, induce
and procure the same.
COUNT 16
On or about February 1, 2020, within the State and District of Colorado, the
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-9465,” did knowingly and
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in causing and facilitating the commission of, a felony delineated in Title 21 of the
COUNT 17
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN,
UNKNOWN, a.k.a. “UM-9465,” and HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,” did
knowingly and intentionally distribute and possess with the intent to distribute a mixture
COUNT 18
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and KEVEN ALEXANDER
PEREZ did knowingly and intentionally use a communications device, specifically a
telephone, in committing, and in causing and facilitating the commission of a felony
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this Indictment.
10
COUNT 19
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and VICTORIANO
HINOJOSA did knowingly and intentionally use a communications device, specifically a
1 of this indictment.
COUNT 20
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and OSCAR MANUEL
OLIVEROS did knowingly and intentionally use a communications device, specifically a
COUNT 21
On or about February 13, 2020, within the State and District of Colorado and
elsewhere, the defendant OSCAR MANUEL OLIVEROS did travel in interstate
commerce with the intent to promote, manage, establish, carry on, and facilitate the
promotion, management, establishment, and carrying on, of an unlawful activity,
specifically violations of Title 21, United States Code, Sections 841(a)(1) and 846 as
alleged in Count 1 of this Indictment, and thereafter performed and attempted to
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perform an act to promote, manage, establish, carry on, and facilitate the promotion,
management, establishment, and carrying on, of that unlawful activity.
All in violation of Title 18, United States Code, Section 1952(a)(3)(A).
COUNT 22
On or about February 13, 2020, within the State and District of Colorado, the the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and VICTORIANO HINOJOSA
did knowingly and intentionally use a communications device, specifically a
COUNT 23
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” BENJAMIN LOPES-
ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.
“Tavo,” KEVEN ALEXANDER PEREZ, VICTORIANO HINOJOSA, OSCAR MANUEL
OLIVEROS, and HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,” did knowingly and
intentionally distribute and possess with the intent to distribute one kilogram and more
of a mixture and substance containing a detectable amount of heroin, a Schedule I
Controlled Substance, and did knowingly and intentionally aid, abet, counsel, command,
induce and procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i)
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COUNT 24
On or about May 21, 2020, within the State and District of Colorado, the
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508” did knowingly and intentionally
use a communications device, specifically a telephone, in committing, and in causing
and facilitating the commission of a felony delineated in Title 21 of the United States
Code, specifically the crime alleged in Count 1 of this indictment.
COUNT 25
On or about May 21, 2020, within the State and District of Colorado and
elsewhere, the defendant CHRISTIAN ANTHONY CARVER did travel in interstate
commerce with the intent to promote, manage, establish, carry on, and facilitate the
promotion, management, establishment, and carrying on, of an unlawful activity,
specifically violations of Title 21, United States Code, Sections 841(a)(1) and 846 as
alleged in Count 1 of this Indictment, and thereafter performed and attempted to
perform an act to promote, manage, establish, carry on, and facilitate the promotion,
management, establishment, and carrying on, of that unlawful activity.
COUNT 26
On or about May 21, 2020, within the State and District of Colorado, the
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN,
UNKNOWN, a.k.a. “UM-6508” and CHRISTIAN ANTHONY CARVER, did knowingly
13
and intentionally distribute and possess with the intent to distribute one kilogram and
more of a mixture and substance containing a detectable amount of heroin, a Schedule
I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
COUNT 27
On or about June 7, 2020, within the State and District of Colorado, the
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and DIEGO ROMERO-
CRUZ, a.k.a. “Enrique,” did knowingly and intentionally use a communications device,
specifically a telephone, in committing, and in causing and facilitating the commission of
a felony delineated in Title 21 of the United States Code, specifically the crime alleged
in Count 1 of this indictment.
COUNT 28
defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,” KEVEN ALEXANDER PEREZ, and FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. “Tavo,” did knowingly and intentionally distribute and possess
with the intent to distribute one kilogram and more of a mixture and substance
containing a detectable amount of heroin, a Schedule I Controlled Substance, and did
knowingly and intentionally aid, abet, counsel, command, induce and procure the same.
14
COUNT 29
defendants KEVEN ALEXANDER PEREZ and DIEGO ROMERO-CRUZ, a.k.a.
“Enrique,” did knowingly and intentionally use a communications device, specifically a
COUNT 30
defendants KEVEN ALEXANDER PEREZ and FIRST NAME UNKNOWN, LAST NAME
UNKNOWN, a.k.a. “Tavo,” did knowingly and intentionally use a communications
commission of a felony delineated in Title 21 of the United States Code, specifically the
crime alleged in Count 1 of this indictment.
COUNT 31
On or about June 10, 2020, within the State and District of Colorado and
elsewhere, the defendant NICHO GARCIA did travel in interstate commerce with the
intent to promote, manage, establish, carry on, and facilitate the promotion,
management, establishment, and carrying on, of an unlawful activity, specifically
15
violations of Title 21, United States Code, Sections 841(a)(1) and 846 as alleged in
Count 1 of this Indictment, and thereafter performed and attempted to perform an act to
promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on, of that unlawful activity.
COUNT 32
defendants KEVEN ALEXANDER PEREZ, DIEGO ROMERO-CRUZ, a.k.a. “Enrique,”
NICHO GARCIA, FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,”
ABISAI ESCOBAR FLORES, a.k.a. “Guerrero” and FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. “Primo,” did knowingly and intentionally distribute and
possess with the intent to distribute one kilogram and more of a mixture and substance
containing a detectable amount of heroin, a Schedule I Controlled Substance, and did
knowingly and intentionally aid, abet, counsel, command, induce and procure the same,
in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i) and Title
18, United States Code, Section 2.
COUNT 33
On or about July 18, 2020, within the State and District of Colorado, the
defendants KEVEN ALEXANDER PEREZ and JESSE CERVANTES did knowingly and
in causing and facilitating the commission of a felony delineated in Title 21 of the United
States Code, specifically the crime alleged in Count 1 of this indictment.
16
COUNT 34
On or about July 18, 2020, within the State and District of Colorado and
elsewhere, the defendant JESSE CERVANTES did travel in interstate commerce with
the intent to promote, manage, establish, carry on, and facilitate the promotion,
management, establishment, and carrying on, of an unlawful activity, specifically
violations of Title 21, United States Code, Sections 841(a)(1) and 846 as alleged in
Count 1 of this Indictment, and thereafter performed and attempted to perform an act to
promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on, of that unlawful activity.
COUNT 35
On or about July 18, 2020, within the State and District of Colorado, the
defendants KEVEN ALEXANDER PEREZ, FIRST NAME UNKNOWN, LAST NAME
UNKNOWN, a.k.a. “Tavo,” JESSE CERVANTES did knowingly and intentionally
distribute and possess with the intent to distribute one kilogram and more of a mixture
COUNT 36
On or about August 3, 2020, within the State and District of Colorado, the
defendants DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” and VICTOR ALONSO
17
CARREON, a.k.a. “Alonso,” did knowingly and intentionally use a communications
commission of a felony delineated in Title 21 of the United States Code, specifically the
crime alleged in Count 1 of this indictment.
COUNT 37
On or about and between June 1, 2019 and September 1, 2020, both dates
being approximate and inclusive, within the State and District of Colorado and
elsewhere, the defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” AZUSENA
MARIBEL SIERRA, a.k.a. “Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA, a.k.a. “Comino,” FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. “Tavo,” KEVEN ALEXANDER PEREZ, DIEGO ROMERO-
CRUZ, a.k.a. “Enrique,” VICTOR ALONSO CARREON, a.k.a. “Alonso,” and ADRIANNA
RAFAELA HOLGUIN, a.k.a. “Fela,” did knowingly combine, conspire, confederate and
agree with other persons known and unknown to the Grand Jury, to commit offenses
against the United States in violation of Title 18, United States Code, Section 1956, in
that the defendants did knowingly conspire to conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce knowing that the transaction
involved the proceeds of a specified unlawful activity (“SUA”), that SUA specifically being
the conspiracy charged in Count 1 of this Indictment, with the intent to promote the
carrying on of the SUA, in violation of Title 18, United States Code, Sections
1956(a)(1)(A)(i), and with the intent to conceal or disguise the nature, the location, the
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source, the ownership, and the control of the proceeds of the SUA in violation of Title 18,
United States Code, Sections 1956(a)(1)(B)(i) .
All in violation of Title 18, United States Code Section 1956(h).
MANNER AND MEANS OF THE MONEY LAUNDERING CONSPIRACY
1. It was part of this money-laundering conspiracy that Mexico-based
defendant FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,”
(“hereinafter TAVO”) on a routine and consistent basis, arranged for, supplied, and sent
shipments of heroin from Mexico to Colorado-based defendants BENJAMIN LOPES-
ALVARADO, a.k.a. “Juan,” KEVEN ALEXANDER PEREZ and DIEGO ROMERO-CRUZ,
a.k.a. “Enrique.”
2. It was part of this money laundering conspiracy that the defendants
BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” KEVEN ALEXANDER PEREZ and
DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” also received heroin from other sources of
supply located in Mexico, Colorado, and other locations within the United States.
3. It was part of this money-laundering conspiracy that the defendants
BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” AZUSENA MARIBEL SIERRA, a.k.a.
“Suzy,” KEVEN ALEXANDER PEREZ and DIEGO ROMERO-CRUZ, a.k.a. “Enrique,”
on a routine and consistent basis, collected and possessed large sums of money (“bulk-
cash drug proceeds”) generated from the sale of heroin supplied by TAVO and other
heroin sources of supply.
“Suzy,” KEVEN ALEXANDER PEREZ and DIEGO ROMERO-CRUZ, a.k.a. “Enrique,”
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on a routine and consistent basis, used bulk-cash drug proceeds to pay for physical
items and monetary costs associated with maintaining their heroin trafficking operations.
Such costs included, but were not limited to, money spent on apartments, vehicles,
cellular telephones, money-remitter fees, bond payments, and weekly salaries.
DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” on a routine and consistent basis, were
communicating with TAVO and receiving instructions pertaining to collecting and
distributing bulk-cash drug proceeds.
DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” on a routine and consistent basis, were
communicating with each other and arranging in-person meetings. During these
meetings, defendants either personally or directing others, collected and combined bulk-
cash drug proceeds owed to TAVO and other heroin sources.
DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” either personally or directing others, on a
routine and consistent basis, were transporting bulk-cash drug proceeds to Money
Service Businesses (“MSBs”) located in Colorado.
“Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,” JORGE REYES CRUZ-
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GARCIA, a.k.a. “Comino,” KEVEN ALEXANDER PEREZ, DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,” VICTOR ALONSO CARREON,” a.k.a. “Alonso,” and ADRIANNA
RAFAELA HOLGUIN, a.k.a. “Fela,” either personally or using others, on a routine and
consistent basis, wire-transferred bulk cash drug proceeds from Colorado MSBs to
various MSBs located in Mexico.
9. It was part of this money laundering conspiracy that the bulk cash drug
proceeds sent via wire-transfers represented payment for heroin supplied by TAVO and
other heroin sources. The wire-transfers promoted the conspiracy alleged in Count 1
because TAVO and other sources used the bulk-cash proceeds to purchase more
heroin and then sent that heroin to defendants in Colorado.
10. It was part of this money laundering conspiracy that the defendants
“Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,” JORGE REYES CRUZ-
GARCIA, a.k.a. “Comino,” KEVEN ALEXANDER PEREZ, DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,” VICTOR ALONSO CARREON, a.k.a. “Alonso,” and ADRIANNA
RAFAELA HOLGUIN, a.k.a. “Fela,” in connection with the wire-transfers, engaged in
activities designed to disguise the nature, location, source, ownership, and control of the
bulk-cash drug proceeds. Such activities included, but were not limited to the following:
a. The defendants used their real names as well as combinations of

fictitious information pertaining to the senders, recipients,
addresses, and telephone numbers connected to the transfers;
b. The defendants, on a routine and consistent basis, traveled to a

single MSB and divided the total amount of bulk-cash into multiple
wire-transfers often sending multiple wire-transfers to multiple
recipients within a short time frame;
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c. The defendants, on a routine and consistent basis traveled to

multiple MSBs on a single day and sent wire-transfers containing
bulk-cash drug proceeds from the multiple locations to multiple
recipients often within a short time frame.
FORFEITURE ALLEGATION
The allegations contained in Counts 1 through 36 of this Indictment are hereby
re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant
to the provisions of Title 21, United States Code, Section 853. Upon conviction of the
violations described Counts 1 through 36 above, the defendants:
BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA,
BRADLEY MICHAEL WHITE,
a.k.a., Brian,”
MICHAEL IAN MILLS,
ANNA MARIE REBEKAH DAVIS,
a.k.a. “Green,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Tavo,”
a.k.a. “UM-2911,”
a.k.a. “UM-9465,”
KEVEN ALEXANDER PEREZ,
VICTORIANO HINOJOSA,
OSCAR MANUEL OLIVEROS,
a.k.a. “Vitamina,” and “Mario,”
DIEGO ROMERO-CRUZ,
a.k.a. “UM-6508,”
CHRISTIAN ANTHONY CARVER,
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ABISAI ESCOBAR FLORES,

a.k.a. “Guerrero,”
a.k.a. “Primo,”
NICHO GARCIA,
JESSE CERVANTES, and
VICTOR ALONSO CARREON,
a.k.a. “Alonso,”
shall forfeit to the United States pursuant to Title 21, United States Code, Section 853
any and all of the defendant’s right, title and interest in all property constituting and
derived from any proceeds obtained directly and indirectly as a result of such offense,
and in all property used, or intended to be used, in any manner or part, to commit, or to
facilitate the commission of such offense, including, but not limited to: a money
judgment in the amount of the proceeds obtained by the defendants.
If any of the property described in the paragraph above, as a result of any act or
omission of the defendants:
(1) cannot be located upon the exercise of due diligence;

(2) has been transferred or sold to, or deposited with, a third
party;
(3) has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which
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 said defendant up to the value of the
forfeitable property.
Upon conviction of the violations alleged in Count 37 of this Indictment, including
violations of Title 18, United States Code, Sections 1956(a)(1)(A)(i), 1956(a)(1)(B)(i),
and 1956(h), the defendants
23
BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA,
a.k.a. “Tavo,”
KEVEN ALEXANDER PEREZ,
DIEGO ROMERO-CRUZ,
VICTOR ALONSO CARREON,
a.k.a. “Alonso,” and
ADRIANNA RAFAELA HOLGUIN,
a.k.a. “Fela,”
shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a)(1) any and all of the defendant’s right, title and interest in all property constituting
and derived from any proceeds obtained directly and indirectly as a result of such
offense, and in all property used, or intended to be used, in any manner or part, to
commit, or to facilitate the commission of such offense, including, but not limited to: a
money judgment in the amount of the proceeds obtained by the defendants.
If any of the property described above, as a result of any act or omission of the
defendant;
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third
party;
(3) has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot be
subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section
853(p), incorporated by Title 18, United States Code, Section 982, to seek forfeiture of
any other property of said defendant[s] up to the value of the forfeitable property.
24
All in violation of Title 18, United States Code, Section 982(a)(1) and Title 21,
United States Code, Section 853.
A TRUE BILL:
Ink signature on file in Clerk’s Office

FOREPERSON
JASON R. DUNN
United States Attorney
By: s/Stephanie Podolak____

Stephanie Podolak
Assistant United States Attorney
U.S. Attorney’s Office
1801 California St., Ste. 1600
Denver, CO 80202
Telephone: 303-454-0100
Fax: 303-454-0406
E-mail: Stephanie.Podolak@usdoj.gov
Attorney for the United States
25

23 Indicted in Large Scale Denver Heroin Ring

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23 Indicted in Large Scale Denver Heroin Ring

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Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 1 of 25

IN THE UNITED STATES DISTRICT COURT

Criminal Case No. 20-CR-292-WJM

UNITED STATES OF AMERICA,

21. JESSE CERVANTES,

elsewhere, the defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” AZUSENA

MARIBEL SIERRA, a.k.a. “Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a. “Gordo,”

JORGE REYES CRUZ-GARCIA, a.k.a. “Comino,” BRADLEY MICHAEL WHITE, a.k.a.

UNKNOWN, a.k.a. “UM-9465,” KEVEN ALEXANDER PEREZ, VICTORIANO

HINOJOSA, OSCAR MANUEL OLIVEROS, FIRST NAME UNKNOWN, LAST NAME

UNKNOWN, a.k.a. “Vitamina,” and “Mario,” DIEGO ROMERO-CRUZ, a.k.a. “Enrique,”

FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508,” CHRISTIAN

ANTHONY CARVER, ABISAI ESCOBAR FLORES, a.k.a. “Guerrero,” FIRST NAME

UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Primo,” NICHO GARCIA, JESSE

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

detectable amount of heroin, a Schedule I Controlled Substance, in violation of Title 21,

United States Code, Sections 841(a)(1) and (b)(1)(B)(i).

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

With respect to defendants: BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,”

AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” HECTOR NUNEZ-SANDOVAL, a.k.a.

“Gordo,” JORGE REYES CRUZ-GARCIA, a.k.a. “Comino,” FIRST NAME UNKNOWN,

UNKNOWN, a.k.a. “UM-2911,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN,

a.k.a. “UM-9465,” KEVEN ALEXANDER PEREZ, VICTORIANO HINOJOSA, OSCAR

MANUEL OLIVEROS, FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.

“Vitamina,” and “Mario,” DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” FIRST NAME

UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508,” CHRISTIAN ANTHONY

CARVER, ABISAI ESCOBAR FLORES, a.k.a. “Guerrero,” FIRST NAME UNKNOWN,

others reasonably foreseeable to them is 1 kilogram and more of a mixture and

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

With respect to defendants: BRADLEY MICHAEL WHITE, a.k.a. Brian,”

involved in the conspiracy attributable to these defendants as a result of their own

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

defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and BRADLEY MICHAEL

specifically a telephone, in committing, and in causing and facilitating the commission

alleged in Count 1 of this Indictment.

defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and BRADLEY MICHAEL

intent to distribute a mixture and substance containing a detectable amount of heroin, a

command, induce and procure the same.

and Title 18, United States Code, Section 2.

knowingly and intentionally use a communications device, specifically a telephone, in

counsel, command, induce and procure the same.

and Title 18, United States Code, Section 2.

counsel, command, induce and procure the same.

and Title 18, United States Code, Section 2.

specifically a telephone, in committing, and in causing and facilitating the commission

alleged in Count 1 of this Indictment.

intent to distribute a mixture and substance containing a detectable amount of heroin, a

command, induce and procure the same.

and Title 18, United States Code, Section 2.

specifically a telephone, in committing, and in causing and facilitating the commission

alleged in Count 1 of this Indictment.

the intent to distribute a mixture and substance containing a detectable amount of

abet, counsel, command, induce and procure the same.

and Title 18, United States Code, Section 2.

defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and HECTOR NUNEZ-

SANDOVAL, a.k.a. “Gordo,” did knowingly and intentionally use a communications

device, specifically a telephone, in committing, and in causing and facilitating the

crime alleged in Count 1 of this Indictment.

defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and FIRST NAME

and intentionally use a communications device, specifically a telephone, in committing,

defendants BENJAMIN LOPES-ALVARADO, a.k.a. “Juan,” and FIRST NAME

use a communications device, specifically a telephone, in committing, and in causing

Code, specifically the crime alleged in Count 1 of this Indictment.