UNITED STATES OF AMERICA
V.
JAIME GUILLOT-LARA,
FERNANDO RAVELO-RENEDO,
GONZALO BASSOLS-SUAREZ,
ALDO SANTAMARIA-CUADRADO,
a/k/a Rene Baeza-Rodriguez,
RENE RODRIGUEZ-CRUZ,
DAVID LORENZO PEREZ, JR.,
HECTOR GONZALEZ-QUINONES,
a/k/a Frank Bonilla,
JORGE FELIPE LLERENA-DELGADO,
JOSE DOMINGO MARTINEZ VALDES,
a/k/a Jose Luis Martinez,
JOSE RAFAEL MARTINEZ,
a/k/a Pepe Gato,
CORNELIO RAMOS-VALLADARES,
a/k/a El Cori,
ALBERTO CORTEZ,
LEVINIO OROBIO-MICHELENA,
and
JULIAN LOSADA, a/k/a/ Cachaco
 

The Grand Jury Charges that:
 

1. At all times material to this indictment, the defendant RENE RODRIGUEZ-CRUZ was a member of the Central Committee of the Communist Party of Cuba and President of the Cuban Institute of Friendship with the People (I.C.A.P.), a Cuban Government Agency which, in part, oversees the activities of foreign visitors in Cuba.

2. At all times material to this indictment, until the termination of diplomatic relations between Cuba and Colombia on or about March 23, 1981, the defendant FERNANDO RAVELO-RENEDO was the plenipotentiary Ambassador to Colombia from the Government of Cuba.

3. At all times material to this indictment until the termination of diplomatic relations between Cuba and Colombia on or about March 23, 1981, the defendant GONZALO BASSOLS-SUAREZ was Minister-Counselor of the Cuban Embassy in Colombia.

4. At all times material to this indictment, the defendant ALDO SANTAMARIA-CUADRADO, a/k/a Rene Baeza-Rodriguez, was a member of the Central Committee of the Communist Party of Cuba and held the military rank of Vice-Admiral of the Cuban Navy.

5. From in or about the fall of 1979, and continuing thereafter until in or about January of 1981, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein,

did knowingly, willfully and unlawfully combine, conspire, confederate and agree, together with each other, and with diverse other persons who are both known and unknown to the Grand Jury, to commit certain offenses against the United States, that is:

a. To import a controlled substance, that is: methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, into the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952(a).

b. To possess a controlled substance, that is: methaqualone tablets, also referred to as "Lemmon 714,"a Schedule II controlled substance, with the intent that the controlled substance be unlawfully imported into the United States, in violation of Title 21, United States Code, Section 955a (d) (1).

6. It was part of said conspiracy that the defendant JAIME GUILLOT-LARA and others, both known and unknown to the Grand Jury, would agree with the defendants FERNANDO RAVELO-RENEDO, GONZALO BASSOLS-SUAREZ, and RENE RODRIGUEZ-CRUZ to use Cuba as a loading station and source of supplies for ships transporting methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

7. It was further part of said conspiracy that the defendant ALDO SANTAMARIA-CUADRADO, a/k/a Rene Baeza-Rodriguez, and others, both known and unknown to the Grand Jury, would supervise, in Cuba, the protection and resupply of ships transporting methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

8. It was further part of said conspiracy that the defendant DAVID LORENZO PEREZ, JR., and others, both known and unknown to the Grand Jury, would agree with the defendant JAIME GUILLOT-LARA to purchase, receive, store and possess with intent to distribute methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, supplied by the defendant JAIME GUILLOT-LARA and others from Colombia.

9. It was further part of said conspiracy that the defendant JAIME GUILLOT-LARA and others, both known and unknown to the Grand Jury, would assemble and package methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, in Colombia and would provide ships to transport methaqualone tablets from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

10. It was further part of said conspiracy that the defendants HECTOR GONZALEZ-QUINONES, a/k/a Frank Bonilla, JORGE FELIPE LLERENA-DELGADO, JOSE DOMINGO MARTINEZ-VALDES, a/k/a Jose Luis Martinez, JOSE RAFAEL MARTINEZ, a/k/a Pepe Gato, CORNELIO RAMOS-VALLADARES, a/k/a El Cori, and LEVINIO OROBIO-MICHELENA, and others, both known and unknown to the Grand Jury, would transport methaqualone tablets, also referred to as "Lemmon 714," a Schedule II controlled substance, from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

All in violation of Title 21, United States Code, Section 963.

1. Paragraphs 1 through 4 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. From in or about the fall of 1979, and continuing thereafter until on or about July 31, 1981, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein,

did knowingly, willfully and unlawfully combine, conspire, confederate and agree, together with each other, and with diverse other persons who are both known and unknown to the Grand Jury, to commit certain offenses against the United States, that is:

a. To import a controlled substance, that is: marijuana, a Schedule I controlled substance, into the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952 (a).

b. To possess a controlled substance, that is: marijuana, a Schedule I controlled substance, with the intent that it be unlawfully imported into the United States, in violation of Title 21, United States Code, Section 955a (d) (1).

3. It was part of said conspiracy that the defendant JAIME GUILLOT-LARA, and others, both known and unknown to the Grand Jury, would agree with the defendants RENE RODRIGUEZ-CRUZ, FERNANDO RAVELO-RENEDO, and GONZALO BASSOLS-SUAREZ, to use Cuba as a loading station and source of supplies for ships transporting marijuana from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

4. It was further part of said conspiracy that the defendant ALDO SANTAMARIA-CUADRADO, a/k/a Rene Baeza-Rodriguez, and others, both known and unknown to the Grand Jury, would supervise, in Cuba, the protection and resupply of ships transporting marijuana from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

5. It was further part of said conspiracy that the defendants, DAVID LORENZO PEREZ, JR., ALBERTO CORTEZ and others, both known and unknown to the Grand Jury, would agree with the defendant JAIME GUILLOT-LARA to purchase, receive, store and possess, with intent to distribute, marijuana supplied by the defendants JAIME GUILLOT-LARA and JULIAN LOSADA, a/k/a Cachaco, and others both known and unknown to the Grand Jury.

6. It was further part of said conspiracy that the defendants, JAIME GUILLOT-LARA and JULIAN LOSADA, a/k/a Cachaco, and others, both known and unknown to the Grand Jury, would assemble and package marijuana in Colombia and would provide ships to transport marijuana from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

7. It was further part of said conspiracy that the defendants HECTOR GONZALEZ-QUINONES, a/k/a Frank Bonilla, JORGE FELIPE LLERENA-DELGADO, JOSE DOMINGO MARTINEZ-VALDEZ, a/k/a JOSE LUIS MARTINEZ, JOSE RAFAEL MARTINEZ, a/k/a Pepe Gato, CORNELIO RAMOS-VALLADARES, a/k/a El Cori, and LEVINIO OROBIO-MICHELENA, and others, both known and unknown to the Grand Jury, would transport marijuana from Colombia to the Southern District of Florida and elsewhere, by way of Cuba.

All in violation of Title 21, United States Code, Section 963.

1. Paragraphs 1 through 4 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. In or about the months of October and November, 1980, in the Southern District of Florida and elsewhere, the defendants herein,

did knowingly, willfully and unlawfully attempt to import into the United States, from a place outside thereof, a controlled substance, that is: in excess of five million methaqualone tablets, also referred to as "Lemon 714," a Schedule II controlled substance, in violation of Title 21, United States Code, Section 952 (a).

In violation of Title 21, United States Code, Section 963, and Title 18, United States Code, Section 2.

1. Paragraphs 1 through 3 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. On or about November 26, 1980, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein:

did knowingly, willfully and unlawfully import into the United States, from a place outside thereof, a controlled substance, that is: marijuana, a Schedule I controlled substance.

In violation of Title 21, United States Code, Section 952 (a), and Title 18, United States Code, Section 2.

1. Paragraphs 1 through 3 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. In or about the first two weeks of December, 1980, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein,

did knowingly, willfully and unlawfully import into the United States, from a place outside thereof, a controlled substance, that is: marijuana, a Schedule I controlled substance.

In violation of Title 21, United States Code, Section 952 (a), and Title 18, United States Code, Section 2.

In or about December of 1980, the exact date being unknown to the Grand Jury, at Homestead, in the Southern District of Florida, and elsewhere, the defendants herein,

did knowingly and intentionally possess with intent to distribute a controlled substance, that is: in excess of one thousand pounds of marijuana, a Schedule I controlled substance, in violation of Title 21, United States Code, Section 841 (a) (1), and Title 18, United States Code, Section 2.
 

1. Paragraphs 1 through 4 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. From on or about August 16, 1980, until on or about November 17, 1980, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein,

used and caused to be used facilities in interstate and foreign commerce, including the telephone, and traveled and caused others to travel in interstate and foreign commerce between the Southern District of Florida, Colombia, Cuba and elsewhere, with the intent to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of an unlawful activity, said unlawful activity being a business enterprise involving controlled substances, in violation of Title 21, United States Code, Sections 841, 952, 955 and 955a, and thereafter performed, attempted to perform, and caused to be performed acts to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of the aforesaid unlawful activity.

3. The defendants herein,

did use and cause to be used facilities in interstate and foreign commerce and did travel and cause travel in interstate and foreign commerce, as charged in paragraph 2, above, and more fully set forth and charged herein as follows:

a. On or about August 16, 1980, the exact date being unknown to the Grand Jury, the defendant, JAIME GUILLOT-LARA, in Nassau, the Bahamas, did telephone the defendant DAVID LORENZO PEREZ, JR., in Miami, the Southern District of Florida.

b. On or about August 17, 1980, the exact date being unknown to the Grand Jury, a private airplane did travel from the Southern District of Florida to Nassau, the Bahamas, did pick up the defendant JAIME GUILLOT-LARA, and did return to the Southern District of Florida.

c. Between August and October, 1980, the exact date being unknown to the Grand Jury, a vessel bearing at varying times the names "Biviana" and "Coral," carrying a cargo of methaqualone tablets which was destined for the Southern District of Florida by way of Cuba, did depart from Colombia.

d. On or about October 20, 1980, the exact date being unknown to the Grand Jury, the defendants JOSE DOMINGO MARTINEZ-VALDEZ, a/k/a Jose Luis Martinez, JORGE LLERENA, and CORNELIO RAMOS-VALLADARES, a/k/a El Cori, and others, both known and unknown to the Grand Jury, traveled from Miami, the Southern District of Florida, en route to Guincho Key, in the vicinity of the north coast of Cuba.

e. On or about October 24, 1980, the exact date being unknown to the Grand Jury, the defendant DAVID LORENZO PEREZ, JR., and another, known to the Grand Jury, did travel from Miami in the-Southern District of Florida to Bimini, the Bahamas.

f. On or about October 29, 1980, the exact date being unknown to the Grand Jury, the defendant DAVID LORENZO PEREZ, JR., in Nassau, the Bahamas, did make a telephone call to Miami, the Southern District of Florida.

g. On or about October 30, 1980, the exact date being unknown to the Grand Jury, DAVID LORENZO PEREZ, JR., did receive a telephone call in Nassau, the Bahamas, from Miami, the Southern District of Florida.

h. In or about the month of November, 1980, the exact date being unknown to the Grand Jury, the defendants DAVID LORENZO PEREZ, JR., HECTOR GONZALEZ-QUINONES, a/k/a Frank Bonilla, and JOSE RAFAEL MARTINEZ, a/k/a Pepe Gato, and others, both known and unknown to the Grand Jury, did travel in the vessel "Lazy Lady" to Paredon Grande, Cuba, and did rendezvous with the vessel "Biviana," a/k/a "Coral," for the purpose of receiving and transporting in excess of five million methaqualone tablets destined for the Southern District of Florida.

In violation of Title 18, United States Code, Sections 1952 and 2.

1 Paragraphs 1 through 4 of Count I are realleged herein as if fully set forth, and are incorporated herein by reference.

2. From on or about November 20, 1980, until on or about December 15, 1980, the exact dates being unknown to the Grand Jury, in the Southern District of Florida and elsewhere, the defendants herein,

used and caused to be used facilities in interstate and foreign commerce, and traveled and caused others to travel in interstate and foreign commerce between the Southern District of Florida, Colombia, Cuba and elsewhere, with the intent to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of an unlawful activity, said unlawful activity being a business enterprise involving controlled substances, in violation of Title 21, United States Code, Sections 841, 952, 955 and 955a, and thereafter performed, attempted to perform, and caused to be performed acts to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of the aforesaid unlawful activity.

2. The defendants herein,

did use and cause to be used facilities in interstate and foreign commerce and did travel and cause travel in interstate a foreign commerce, as charged in paragraph 2, above, and more fully set forth and charged herein as follows:

a. In or about the last two weeks of November, 1980, the exact date being unknown to the Grand Jury, the defendants JOSE DOMINGO MARTINEZ-VALDEZ, a/k/a Jose Luis Martinez, JORGE FELIPE LLERENA-DELGADO, and others, both known and unknown to the Grand Jury, did travel aboard the United States vessel "K.D." from Key West in the Southern District of Florida to Guincho Key in the vicinity of the north coast of Cuba.

b. In or about the last two weeks of November, 1980, the exact date being unknown to the Grand Jury, the United States vessel "K.D." did travel and was caused to travel from the vicinity of Guincho Key to Key West in the Southern District of Florida.

c. On or about November 26, 1980, the exact date being unknown to the Grand Jury, a speedboat did travel and was caused to travel from Miami in the Southern District of Florida to Bimini, the Bahamas, and to return to Haulover Beach Inlet, Miami, in the Southern District of Florida.

d. On or about December 1, 1980, the exact date being unknown to the Grand Jury, the defendant ALBERTO CORTEZ did receive and store Homestead in the Southern District of Florida a quantity of marijuana transported from Colombia by way of Cuba to the Southern District of Florida

In violation of Title 18, United States Code, Sections 1952 and 2.

                                                                                                                                    Ernest Sanchez
                                                                                                                                    FOREPERSON

STANLEY MARCUS
UNITED STATES ATTORNEY

RICHARD D. GREGORIE
ASSISTANT U. S. ATTORNEY