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Full Text of Indictment Against Noriega, Others With PM-Noriega

January 5, 1990 GMT

MIAMI (AP) _ Here is the text of the indictment against deposed Panamanian dictator Manuel Antonio Noriega and 15 co-defendants in U.S. District Court, Southern District of Florida:

UNITED STATES OF AMERICA

v.

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

PABLO ESCOBAR-GAVIRIA

LUIS DEL CID

ROBERTO STEINER

FRANCISCO CHAVEZ-GIL

DAVID RODRIGO ORTIZ-HERMIDA

AMET PAREDES

RICARDO BILONICK

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LUIS FERNANDO ESCOBAR-OCHOA

BRIAN ALDEN DAVIDOW

HERMAN VELEZ

WILLIAM SALDARRIAGA

EDUARDO PARDO

DANIEL MIRANDA

JAIME GOMEZ

The Grand Jury charges that:

COUNT ONE

The Enterprise

1. At all times relevant to this Indictment, there existed an Enterprise, within the meaning of Title 18, United States Code, Section 1961(4), that is, a group of individuals associated in fact which utilized the official positions of the defendant MANUEL ANTONIO NORIEGA in the Republic of Panama to facilitate the manufacture and transportation of large quantities of cocaine destined for the United States and to launder narcotics proceeds.

2. The members of the Enterprise consisted of the defendants herein and others, including Panamanian military and civilian associates of MANUEL ANTONIO NORIEGA and international drug traffickers who purchased from MANUEL ANTONIO NORIEGA the use of his official positions and influence to assist and protect their narcotics and money laundering operations.

Roles in the Enterprise

3. MANUEL ANTONIO NORIEGA was and is a high ranking officer in the military forces of the Republic of Panama. MANUEL ANTONIO NORIEGA exploited his positions to obtain substantial personal profit by offering narcotics traffickers the safe use of the Republic of Panama as a location for transshipment of multi-hundred kilogram loads of cocaine destined for the United States; by permitting the shipment of ether and acetone in and through Panama; by allowing and protecting laboratory facilities for the manufacture of cocaine; by providing a safe haven for international narcotics traffickers; and by allowing the deposit of millions of dollars of narcotics proceeds in Panamanian banks.

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a. NORIEGA’s Official Positions: Through the use of his military positions, as set forth below, MANUEL ANTONIO NORIEGA was able to expand and formalize his control over military, intelligence, law enforcement operations and other essential government functions in Panama.

(i) From at least as early as mid-1973, prior to the time period covered by the charges herein, through approximately August 1983, MANUEL ANTONIO NORIEGA wasa Chief of the G-2, which was the intelligence branch of the National Guard of Panama.

(ii) On March 8, 1982, eight months after the deatah of General Omar Torrijos, the Military Leader of Panama, the principal military officers of Panama, including MANUEL ANTONIO NORIEGA, entered into an agreement setting forth the succession of control over the military and government functions of Panama.

(iii) In August 1983, MANUEL ANTONIO NORIEGA became Commander-in-Chief of the National Guard.

(iv) On or about September 29, 1983, the Defense Forces of the Republic of Panama was formed by Law No. 20 of the Republic of Panama which formally placed the National Guard, other Panamanian military and police forces, the Immigration Department and other critical functions, including the issuance of passports, regulation of civilian aircraft, and Canal matters, under its administration and control. MANUEL ANTONIO NORIEGA, with the rank of General, became Commander-in-Chief of the Defense Forces of the Republic of Panama.

b. NORIEGA’s Association with the Medellin Cartel and Other Narcotics Traffickers: MANUEL ANTONIO NORIEGA utilized his official positions to provide protection for international criminal narcotics traffickers, including an organization based in Medellin, Colombia, South America known by various names, including ″The Medellin Cartel″ (hereinafter ″Cartel″), which consisted of controlling members of major Colombian cocaine manufacturing and distribution organizations. The Cartel operated to coordinate and consolidate the production, distribution and importation of cocaine into the United States. Through the Cartel, major Colombian cocaine traffickers were able to pool resources, including raw materials, cocaine conversion laboratories, aircraft, vessels, transportation facilities, distribution networks and cocaine to facilitate international narcotics trafficking. Cartel representatives sold cocaine and collected proceeds from illegal narcotics sales in a clandestine international market, which included the United States and Panama. In furtherance of its international drug trafficking business, the Cartel sought to obtain secure locations in Panama to conduct its operations and store its illegal proceeds.

4. PABLO ESCOBAR-GAVIRIA and GUSTAVO DEJESUS GAVIRIA-RIVERO, among others, were leaders of the Cartel. Floyd Carlton-Cacerez assisted in obtaining MANUEL ANTONIO NORIEGA’s authorization for Cartel operations in Panama. Floyd Carlton-Cacerez flew drugs from Colombia to Panama and money from the United States to Panama for the Cartel under the protection of MANUEL ANTONIO NORIEGA. After the murder in 1984 of Rodrigo Lara-Bonilla, the Minister of Justice of Colombia, Cartel leaders, incuding PABLO ESCOBAR-GAVIRIA, GUSTAVO DEJESUS GAVIRIA-RIVERO, Jorge Ochoa-Vasquez and Fabio Ochoa-Vasquez, utilized Panama for the conduct of Cartel operations and as refuge from increased law enforcement activity in the Republic of Colombia.

5. LUIS DEL CID was a member of the National Guard and the Defense Forces of the Republic of Panama. He acted as liaison, courier and emissary for MANUEL ANTONIO NORIEGA in his transactions with drug traffickers. At various times, he arranged for the transportation of payments to NORIEGA from the traffickers, including the Cartel.

6. AMET PAREDES is the son of General Ruben Dario Paredes, former military commander of the National Guard of Panama. AMET PAREDES, along with his now deceased brother, Ruben Dario Paredes-Jimenez, smuggled cocaine from Panama to the United States utilizing their connections with MANUEL ANTONIO NORIEGA and NORIEGA’s now deceased partner, Cesar Rodriguez, to obtain protection for their activities. In March 1986, co-conspirators Ruben Dario Paredes-Jimenez and Cesar Rodriguez traveled from Panama to Medellin, Colombia, to make arrangements for the Cartel to acquire a load of cocaine. On or before March 19, 1986, they were murdered in Medellin, Colombia.

7. RICARDO BILONICK is a Panamanian civilian who was a part-owner of Inair Airlines, a Panamanian cargo airline used to ship cocaine for the Cartel from Panama to the United States. BILONICK maintained a close personal relationship with NORIEGA. BILONICK acted as NORIEGA’s representative in several meetings with narcotics traffickers.

8. BRIAN ALDEN DAVIDOW was a cocaine distributor based in Miami, Florida, who worked with Cesar Rodriguez, Ruben Dario Paredes-Jimenez and others. BRIAN ALDEN DAVIDOW met with MANUEL ANTONIO NORIEGA and others in Panama to arrange for secure transportation of cocaine destined for the Southern District of Florida.

9. FRANCISCO CHAVEZ-GIL made the initial arrangements for Floyd Carlton- Cacerez to meet with Cartel members PABLO ESCOBAR-GAVIRIA and GUSTAVO DEJESUS GAVIRIA-RIVERO to arrange for protection by MANUEL ANTONIO NORIEGA of cocaine shipments from Colombia to Panama.

10. DAVID RODRIGO ORTIZ-HERMIDA and ROBERTO STEINER were pilots who transported cocaine for the Cartel.

11. EDUARDO PARDO and DANIEL MIRANDA were pilots who worked for Cesar Rodriquez and Floyd Carlton-Cacerez and transported money from the United States to Panama.

12. HERMAN VELEZ, WILLIAM SALDARRIAGA, JAIME GOMEZ and LUIS FERNANDO ESCOBAR-OCHOA were Colombian cocaine traffickers.

Purpose and Objects of the Enterprise

13. By utilizing his official positions, MANUEL ANTONIO NORIEGA and trusted associates were able to assure drug traffickers that Panamanian military, customs and law enforcement personnel would not interfere with their operations in Panama as long as substantial fees were paid to MANUEL ANTONIO NORIEGA;

a. Protection of Cocaine Shipments: Members of the Cartel and other independent narcotics traffickers, with the assistance of Floyd Carlton- Cacerez, RICARDO BILONICK, Boris Olarte-Morales, Cesar Rodriquez and others, paid substantial fees to MANUEL ANTONIO NORIEGA to protect cocaine shipments transported from Colombia through Panama to the United States. The cocaine was delivered to secure airstrips in Panama for transshipment.

b. Protection and Assistance in Manufacturing Cocaine: MANUEL ANTONIO NORIEGA arranged for the transshipment and sale of ether and acetone, precursor chemicals used in the manufacture of cocaine hydrochloride, a Schedule II narcotic controlled substance, to members of the Cartel including such chemicals previously seized by Panamanian authorities. Further, MANUEL ANTONIO NORIEGA agreed to permit the Cartel to establish and supply a cocaine laboratory in Darien Province, Panama, and to allow shipments of ether and acetone to enter Panama from the United States and Europe.

c. Protection of Narcotics Traffickers: In the spring of 1984, members of the Cartel and other cocaine traffickers fled Colombia as a result of increased law enforcement activities in that country. MANUEL ANTONIO NORIEGA agreed to permit members of the Cartel and others to continue their narcotics business within the borders of Panama and to notify them if and when any law enforcement action was to be taken against them.

d. Negotiations and Dispute Settlement: MANUEL ANTONIO NORIEGA directly and through intermediaries negotiated with narcotics traffickers. Failure to make adequate payment to, or the failure to obtain the prior approval of, MANUEL ANTONIO NORIEGA for narcotics operations resulted in the seizure of drugs or other retaliatory measures by MANUEL ANTONIO NORIEGA. In 1984, a dispute developed between members of the Medellin Cartel and MANUEL ANTONIO NORIEGA over the seizure of a cocaine laboratory in Darien Province, Panama, despite payment by members of the Cartel to MANUEL ANTONIO NORIEGA for protection of the laboratory. This dispute was mediated by Fidel Castro, Cuban head of State, in meetings with MANUEL ANTONIO NORIEGA and others in Havana, Cuba.

e. Protection of Shipments of Narcotics Proceeds From the Southern District of Florida to Panama: Cesar Rodriquez, Floyd Carlton-Cacerez and others transported large shipments of United States currency from the Southern District of Florida to Panama. MANUEL ANTONIO NORIEGA assured the safe passage of hundreds of thousands of dollars of narcotics proceeds into Panamanian banks and arranged for the drug proceeds to be flown into Panama without interference by Panamanian customs or law enforcement authorities at civilian and military airfields.

The Racketeering Conspiracy

14. From in or about the fall of 1981 to on or about March 21, 1986, in the Southern District of Florida, and elsewhere, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

LUIS DEL CID

FRANCISCO CHAVEZ-GIL

DAVID RODRIGO ORTIZ-HERMIDA

AMET PAREDES

RICARDO BILONICK

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BRIAN ALDEN DAVIDOW

and others known and unknown to the Grand Jury, including Pablo Escobar- Gaviria and Jorge Ochoa-Vasquez, named as co-conspirators but not co- defendants in this count, being members of, employed by or associated with the Enterpise as more fully described in paragraphs 1 through 13 of this Count, which Enterprise was engaged in and the activities of which affected interstate and foreign commerce in the United States, did unlawfully, willfully and knowingly combine, conspire, confederate and agree with each other to conduct and participate, directly and indirectly, in the conduct of the affairs of the Enterprise through a pattern of racketeering activity as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), as described in paragraphs 15 and 16 of this count, in violation of Title 18, United States Code, Section 1962(c).

The Pattern of Racketeering Activity

15. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defendants conducted and participated in the affairs of the Enterprise, consisted of: a) the manufacture of a controlled substance, to wit, cocaine, a Schedule II narcotic controlled substance, with the knowledge that it would be unlawfully imported into the United States, in violation of Title 21, United States Code, Section 959, and conspiracy to do so, in violation of Title 21, United States Code, Section 963; b) the importation of cocaine into the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952 and conspiracy to do so, in violation of Title 21, United States Code, Section 963; c) the distribution of cocaine with the knowledge that it would be imported into the United States, in violation of Title 21, United States Code, Section 959, and conspiracy to do so, in violation of Title 21, United States Code, Section 963; d) travel and causing travel, use and causing the use of facilities in interstate and foreign commerce in furtherance of a narcotics enterprise, in violation of Title 18, United States Code, Section 1952.

Acts of Racketeering

16. The defendants agreed to conduct and participate, directly and indirectly, in the conduct of the affairs of the Enterprise through a pattern of racketeering activity as follows:

Acts of Racketeering Involving the Manufacture of Controlled Substances in Violation of Title 21, United States Code, Section 959.

A. From in or about December 1983 to on or about March 10, 1984, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

and

AMET PAREDES

did knowingly and intentionally aid and abet members of the Cartel and others known and unknown to the Grand Jury to manufacture and cause to be manufactured multi-ton quantities of cocaine, a Schedule II narcotic controlled substance, in a location known as ″Tranquilandia″ in the Llanos region of Colombia, South America, intending that such cocaine be unlawfully imported into the Southern District of Florida, and elsewhere in the United States, in violation of Title 21, United States Code, Section 959, and Title 18, United States Code, Section 2.

B. In or about May 1984 the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

and

RICARDO BILONICK

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together with Pablo Escobar-Gaviria and others known and unknown to the Grand Jury did knowingly and intentionally attempt to manufacture and aid and abet the manufacture of cocaine, a Schedule II narcotic controlled substance, in a location approximately 60 miles southeast of LaPalma in the Province of Darien, Panama, intending that such cocaine be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Sections 959 and 963 and Title 18, United States Code, Section 2.

Acts of Racketeering involving the importation and distribution of a Controlled Substance knowing that such substance would be unlawfully imported into the United States in violation of Title 21, United States Code, Sections 952, 959 and 963.

C. In or about December 1982 the defendants:

MANUEL ANTONIO NORIEGA

LUIS DEL CID

and

DAVID RODRIGO ORTIZ-HERMIDA

together with Pablo Escobar-Gaviria and others known and unknown to the Grand Jury did knowingly and intentionally distribute and aid in the distribution of approximately 400 kilograms of cocaine, a Schedule II narcotic controlled substance, from Colombia to Panama knowing that such cocaine would be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

D. In or about May 1983 the defendants:

MANUEL ANTONIO NORIEGA

and

GUSTAVO DEJESUS GAVIRIA-RIVERO

together with Pablo Escobar-Gaviria and others known and unknown to the Grand Jury did knowingly and intentionally distribute and aid in the distribution of approximately 400 kilograms of cocaine, a Schedule II narcotic controlled substance, from Colombia to Panama knowing that such cocaine would be imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

E. In or about January 1984 the defendants:

MANUEL ANTONIA NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

and

LUIS DEL CID together with Pablo Escobar-Gaviria, Robert Steiner and others known and unknown to the Grand Jury did knowingly and intentionally distribute and aid in the distribution of approximately 400 kilograms of cocaine, a Schedule II narcotic controlled substance, from Colombia to Panama knowing that such cocaine would be imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

F. In or about June 1984, within the Southern District of Florida and elsewhere, the defendants:

GUSTAVO DEJESUS GAVIRIA-RIVERO

and

RICARDO BILONICK and others known and unknown to the Grand Jury did knowingly and intentionally import and aid and abet others in the importation of approximately 2,141 pounds of cocaine, a Schedule II narcotic controlled substance, from Colombia through Panama to Miami, Florida, in violation of Title 21, United States Code, Section 952 and Title 18, United States Code, Section 2.

G. From in or about December 1985 through on or about March 21, 1986, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

AMET PAREDES

and

BRIAN ALDEN DAVIDOW and others known and unknown to the Grand Jury including William Saldarriaga, Luis Fernando Escobar-Ochoa, Herman Valdez, Jaime Gomez, Cesar Rodriguez and Ruben Dario Paredes-Jimenez, knowingly and intentionally did combine, conspire, confederate and agree with each other and with other persons known and unknown to the Grand Jury, to commit offenses against the United States, that is:

(i) To distribute cocaine, a Schedule II narcotic controlled substance, intending that such cocaine be unlawfully imported into the United States, in violation of Title 21, United States Code, Section 959; and

(ii) To import cocaine, a Schedule II narcotic controlled substance, into the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952.

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

Acts of Racketeering Involving Interstate and Foreign Travel to Further a Narcotics Enterprise

On or about the dates set forth below, according to racketeering act, in the Southern District of Florida, and elsewhere, the defendants, as set forth below, and persons known and unknown to the Grand Jury, knowingly and willfully did travel and cause travel, and use and cause to be used facilities in interstate and foreign commerce with intent to promote, manage, establish, and carry on, and facilitate the promotion, management, establishment and carrying on of an unlawful activity, that is, a business enterprise involving cocaine, a Schedule II narcotic controlled substance, in violation of Title 21, United States Code, Sections 952, 959 and 963, and thereafter did perform, attempt to perform and cause to be performed acts to promote, manage, establish, and carry on, and facilitate the promotion, management, establishment, and carrying on of said unlawful activity:

Racketeering Act H.

Defendants

MANUEL ANTONIO NORIEGA, Pablo Escobar-Gaviria, Eduardo Pardo

Travel

Airplane flight of Eduardo Pardo from the Southern District of Florida to Panama with $685,000

Approximate Date

January 1983

Racketeering Act I.

Defendants

GUSTAVO DEJESUS GAVIRIA-RIVERO, Eduardo Pardo, Daniel Miranda

Travel

Flight of Eduardo Pardo and Daniel Miranda with $800,000 from Fort Lauderdale, Florida, to Panama

Approximate Date

May 1983

Racketeering Act J.

Defendants

MANUEL ANTONIO NORIEGA

Travel

Flight of Tony Aizprua from Fort Lauderdale, Florida, to Panama

Approximate Date

May 1984

Racketeering Act K.

Defendants

MANUEL ANTONIO NORIEGA

Travel

Flight from New York, New York, to Havana, Cuba

Approximate Date

June 27, 1984

All in violation of Title 18, United States Code, Sections 1952 (a) (3) and 2.

Overt Acts

17. In futherance of the aforesaid conspiracy and to effect the objects thereof, in the Southern District of Florida and elsewhere, one or more of the defendants committed and caused to be committed one or more of the following overt acts, among others:

a) In or about October 1982, Floyd Carlton-Cacerez, a pilot based in Panama, and FRANCISCO CHAVEZ-GIL traveled from Panama City, Panama, to Medellin, Colombia, and met with Pablo Escobar-Gaviria and GUSTAVO DEJESUS GAVIRIA-RIVERO.

b) In or about October 1982, Floyd Carlton-Cacerez met with MANUEL ANTONIO NORIEGA at one of NORIEGA’s homes located in La Playita, San Francisco area of Panama City to discuss payment and the method of operation for the transshipment of cocaine through Panama.

c) In or about October 1982, subsequent to overt act (b), Floyd Carlton- Cacerez met with Pablo Escobar-Gaviria and GUSTAVO DEJESUS GAVIRIA-RIVERO in Medellin, Colombia, to discuss landing sites in Panama and payment for protection of cocaine shipments from Colombia through Panama.

d) In or about October or November 1982, subsequent to overt act (c), MANUEL ANTONIO NORIEGA, during an airplane flight with Floyd Carlton-Cacere z, demanded payment of $100,000 to protect cocaine transshipped from Colombia through Panama.

e) In or about November 1982, Floyd Carlton-Cacerez was trained to fly a Piper Cheyenne aircraft by DAVID RODRIGO ORTIZ-HERMIDA at the direction of Pablo Escobar-Gaviria in order to later transport loads of cocaine to Panama.

f) In or about November 1982, Floyd Carlton-Cacerez and DAVID RODRIGO ORTIZ-HERMIDA flew an airplane carrying an unidentified cargo contained in duffle bags from El Cafital airstip in Colombia to Calzada Larga airstrip in the Republic of Panama.

g) In or about November 1982, Floyd Carlton-Cacerez was given a handwritten note from Pablo Escobar-Gaviria directing payment of $220,000 in U.S. currency in Panama to be split $100,000 for MANUEL ANTONIO NORIEGA and $120,000 for Floyd Carlton-Cacerez.

h) In or about November 1982, Floyd Carlton-Cacerez received $220,000 in U.S. currency from Erik E. Guerra in Panama City, Panama.

i) In or about November 1982, Floyd Carlton-Cacerez telephoned MANUEL ANTONIO NORIEGA who dispatched Captain LUIS DEL CID to receive $100,000 in U.S. currency from Floyd Carlton-Cacerez at Padilla Airport, Panama.

j) In or about early December 1982, Floyd Carlton-Cacerez met with Pablo Escobar-Gaviria in Medellin, Colombia, to discuss a shipment of cocaine from Colombia to Panama.

k) In or about early December 1982, Floyd Carlton-Cacerez met with MANUEL ANTONIO NORIEGA in Panama to discuss the details of a shipment of cocaine through Panama at which time MANUEL ANTONIO NORIEGA demanded that $150,000 be paid in advance for the protection.

l) In or about December 1982, subsequent to overt act (k), Erik E. Guerra and a man known only as Robrto delivered $150,000 in U.S. currency to Floyd Carlton-Cacerez at Padilla Airport in Panama City, Panama. Floyd Carlton- Cacerez, at the direction of MANUEL ANTONIO NORIEGA, delivered the $150,000 to Captain Pasqual Gonzalez at Explosivos Nacionales (National Explosives), a government office in Panama City.

m) In or about December 1982, subsequent to overt act (l), Floyd Carlton- Cacerez, accompanied by DAVID RODRIGO ORTIZ-HERMIDA, flew an airplane carrying approximately 400 kilograms of cocaine from Pablo Escobar Gaviria’s ranch, Hacienda Napoles, in Colombia to Calzada Larga airstrip in Panama.

n) In or about early January 1983, Floyd Carlton-Cacerez met with MANUEL ANTONIO NORIEGA to inform him that he was going to fly to the United States on behalf of Pablo Escobar-Gaviria to purchase a Lear Jet to be used to fly narcotics proceeds from the United States to Panama.

o) In January 1983, Floyd Carlton-Cacerez flew from Panama City, Panama to Miami, Florida to buy a Lear Jet for Pablo Escobar-Gaviria and met with Cesar Rodriguez.

p) In early 1983, Cesar Rodriguez and Floyd Carlton-Cacerez sent Eduardo Pardo, Teofilo Watson and Daniel Miranda to learn to fly the Lear Jet purchased for Pablo Escobar-Gaviria in order to fly narcotics proceeds from Miami, Florida to Panama.

q) In or about February 1983, Floyd Carlton-Cacerez directed Eduardo Pardo to fly $685,000 in U.S. currency from the Southern District of Florida to Panama to finance the purchase of refitting of a Lear Jet 25, tail number N281R.

r) In or about early May 1983, Eduardo Pardo and Daniel Miranda flew $800,000 in U.S. currency from the Southern District of Florida to Panama at the direction of GUSTAVO DEJESUS GAVIRIA-RIVERO.

s) In or about the Spring of 1983, Floyd Carlton-Cacerez met with Pablo Escobar-Gaviria, GUSTAVO DEJESUS GAVIRIA-RIVERO, Jorge Ochoa, Fabio Ochoa, and RICARDO BILONICK in Colombia.

t) Sometime between March and May of 1983, Floyd Carlton-Carcerez met with Pablo Escobar-Gaviria regarding another transshipment of cocaine from Colombia through Panama.

u) Subsequent to over act (t), Floyd Carlton-Cacerez had a conversation with MANUEL ANTONIO NORIEGA in which conversation NORIEGA advised Carlton- Cacere z to delay the next cocaine shipment due to military exercises being conducted in Panama.

v) Subsequent to overt act (u), Floyd Carlton-Cacerez met with MANUEL ANTONIO NORIEGA at Padilla Airport in Panama City, Panama and NORIEGA told Carlton-Cacerez that in order to transship another cocaine load through Panama, NORIEGA must be paid $150,000 in advance.

w) Subsequent to overt act (v), Floyd Carlton-Cacerez received $150,000 in U.S. currency in Panama from Erik Guerra at the direction of Pablo Escobar- Gaviria and GUSTAVO DEJESUS GAVIRIA-RIVERO.

x) Subsequent to overt act (w), Floyd Carlton-Cacerez, at the direction of MANUEL ANTONIO NORIEGA, delivered $150,000 in U.S. currency to Major Pasqual Gonzalez at the officers of Explosivos Nacional (National Explosives).

y) Subsequent to overt act (x), Floyd Carlton-Cacerez, along with John Jairo-Naranjo flew approximately 400 kilograms of cocaine from El Cafital airstrip in Colombia to Coronado airstrip on the Pacific coast of Panama.

z) In or about December 1983, Floyd Carlton-Cacerez met with MANUEL ANTONIO NORIEGA in Panama concerning the price to be charged for the next cocaine shipment from Colombia through Panama.

aa) Subsequent to overt act (z), Floyd Carlton-Cacerez, at the direction of MANUEL ANTONIO NORIEGA, delivered $200,000 in U.S. currency to LUIS DEL CID at the military headquarters of the Defense Forces of the Republic of Panama in Panama City.

bb) In or about late December 1983 or January 1984, Floyd Carlton-Cacerez and Roberto Steiner flew approximately 400 kilograms of cocaine from Pablo Escobar Gaviria’s farm, Hacienda Napoles, in Colombia to Coronado airstrip in Panama.

cc) In or about early 1984, Boris Olarte-Morales met with AMET PAREDES and MANUEL ANTONIO NORIEGA in Panama and discussed the sale of 500 drums of ether and acetone which had been seized by NORIEGA and the Defense Forces of the Republic of Panama.

dd) In or about early 1984, Boris Olarte-Morales met with Pablo Escobar- Gaviria and GUSTAVO DEJESUS GAVIRIA-RIVERO in Medellin, Colombia to agree upon the purchase of the 500 barrels of ether and acetone.

ee) In or about early 1984, Otalvaro Cabrera-Medina, a/k/a Manuel Cabrera- Medina supplied a DC-6 airplane to transport ether and acetone from Panama to Colombia.

ff) In or about early 1984, Boris Olarte-Morales delivered $250,000 in U.S. currency to MANUEL ANTONIO NORIEGA in Panama.

gg) In or about early 1984, soldiers of the Defense Forces of the Republic of Panama delivered 500 barrels of ether and acetone to a DC-6 airplane at the Ticumin Military Air Force Base in Panama. The ether and acetone were loaded onboard the DC-6 aircraft and flown to Colombia.

hh) In or about the Spring of 1984, Boris Olarte-Morales met with Jorge Ochoa-Vasquez, GUSTAVO DEJESUS GAVIRIA-RIVERO and others in Panama and discussed payments to MANUEL ANTONIO NORIEGA to protect their cocaine operations in Panama.

ii) In or about the Spring of 1984, Boris Olarte-Morales and RICARDO BILONICK a/k/a Ricky, met with MANUEL ANTONIO NORIEGA in Panama City, Panama.

jj) In or about the Spring of 1984, Boris Olarte-Morales delivered approximately $4,000,000 to MANUEL ANTONIO NORIEGA in Panama City, Panama.

kk) In or about May or June 1984, Floyd Carlton-Cacerez met with GUSTAVO DEJESUS GAVIRIA-RIVERO in Panama City, Panama and discussed transporting a shipment of cocaine from Colombia to Panama.

ll) In or about May of 1984, Teofilo Watson and other pilots flew approximately 1,400 kilograms of cocaine from Colombia to the Coronado Airstrip in Panama.

mm) On or about June 15, 1984, 2,141 pounds of cocaine were flown on Inair Airlines from Panama to Miami, Florida.

oo) On or about June 29, 1984, MANUEL ANTONIO NORIEGA met with Fidel Castro in Havana, Cuba to negotiate a settlement of the disagreement between MANUEL ANTONIO NORIEGA and members of the Cartel concerning the protection of Cartel cocaine operations in Panama.

pp) In or about early 1986, Ruben Dario Paredes-Jimenez sold the vessel ″Krill″, in Panama for the purpose of having the ″Krill″ used to transport a cocaine shipment from Colombia to the Southern District of Florida.

qq) On or about March 10, 1986, MANUEL ANTONIO NORIEGA, Ruben Dario Paredes-Jimenez, AMET PAREDES, Cesar Rodriguez, BRIAN ALDEN DAVIDOW, William Saldarriaga and others met at Cesar Rodriguez’ office in the Bank of Boston Building in Panama City, Panama to discuss the shipment of approximately 300 kilograms of cocaine aboard the vessel ″Krill.″

rr) On or about March 10, 1986, a large photo portrait of MANUEL ANTONIO NORIEGA was hung on the vessel ″Krill″ as security.

ss) In or about the middle of March 1986, in excess of 300 kilograms of cocaine were placed in secret compartments aboard the ″Krill″ for shipment to Miami, Florida.

All in violation of Title 18, United States Code, Section 1962(d).

COUNT II

The Enterprise

1. Each and every allegation contained in paragraphs 1 through 13 of Count I of this indictment is incorporated in Count II by reference as if fully set forth herein.

2. From in or about October 1981 to on or about March 21, 1986, in the Southern District of Florida, and elsewhere, the defendants,

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

AMET PAREDES

and

LUIS DEL CID

and other persons known and unknown to the Grand Jury, being members of, employed by and associated with the Enterprise, as more fully described in paragraphs 1 through 13 of Count I, knowingly and wilfully did conduct and participate, directly and indirectly, in the conduct of the affairs of the Enterprise, which was engaged in and the activities of which affected interstate and foreign commerce, through a pattern of racketeering activity.

The Pattern of Racketeering Activity

3. The pattern of racketeering activity, as defined in Title 18, United States Code, Sections 1961(1) and 1961(5), through which the defendants conducted and participated in the affairs of the Enterprise, consisted of: a) the manufacture of a controlled substance, to wit, cocaine, a Schedule II narcotic controlled substance, with the knowledge that it would be unlawfully imported into the United States, in violation of Title 21, United Sates Code, Section 959, and conspiracy to do so, in violation of Title 21, United States Code, Section 963; b) the importation of cocaine into the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952, and conspiracy to do so, in violation of Title 21, United States Code, Section 963; c) the distribution of a controlled substance, to wit, cocaine, a Schedule II narcotic controlled substance, with the knowledge that it would be imported into the United States, in violation of Title 21, United States Code, Section 959, and conspiracy to do so, in violation of Title 21, United States Code, Section 963; d) travel and causing travel, use and causing the use of facilities in interstate and foreign commerce in furtherance of a narcotics enterprise, in violation of Title 18, United States Code, Section 1952, the acts constituting said pattern of racketeering activity being those acts described in paragraph 16 of Count I of this Indictment, the allegations of which are incorporated in this Count II by reference, as if fully set forth herein.

All of the above in violation of Title 18, United States Code, Sections 1962(c) and 2.

COUNT III

From in or about October 1981 to in or about January 1984, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

PABLO ESCOBAR-GAVIRIA

LUIS DEL CID

ROBERTO STEINER

FRANCISCO CHAVEZ-GIL

and

DAVID RODRIGO ORTIZ-HERMIDA

knowingly and intentionally did combine, conspire, confederate and agree with each other and with other persons known and unknown to the Grand Jury, to commit offenses against the United States:

a) To distribute cocaine, a Schedule II narcotic controlled substance, knowingly that such cocaine would be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959.

b) To import cocaine, a Schedule II narcotic controlled substance, into the Southern District of Florida and elsewhere in the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952.

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

COUNT IV

In or about May 1983, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

and

PABLO ESCOBAR-GAVIRIA

and others known and unknown to the Grand Jury did knowingly and wilfully distribute and aid and abet the distribution of approximately 400 kilograms of cocaine, a Schedule II narcotic controlled substance, with the knowledge that such cocaine would be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

COUNT V

In or about January 1984, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

PABLO ESCOBAR-GAVIRIA

LUIS DEL CID

and

ROBERTO STEINER

and others known and unknown to the Grand Jury did knowingly and wilfully distribute and aid and abet the distribution of approximately 400 kilograms of cocaine, a Schedule II narcotic controlled substance, with the knowledge that such cocaine would be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

COUNT VI

From in or about September 1983 through on or about March 10, 1984, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

AMET PAREDES

and others known and unknown to the Grand Jury did aid and abet Pablo Escobar-Gaviria, Jorge Ochoa Vasquez, Fabio Ochoa-Vasquez, Juan David Ochoa- Vasquez and others in the manufacture of multi-ton quantities of cocaine, a Schedule II narcotic controlled substance, in a location known as ″Tranquilandia″ in the Llanos region of Colombia, South America, intending that such cocaine be unlawfully imported into the Southern District of Florida, and elsewhere in the United States, in violation of Title 21, United States Code, Section 959, and Title 18, United States Code, Section 2.

COUNT VII

From in or about May 1984 through the summer of 1984, the defendants:

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

PABLO ESCOBAR-GAVIRIA

and

RICARDO BILONICK

ADVERTISEMENT

knowingly and intentionally did combine, conspire, confederate and agree with each other and with other persons known and unknown to the Grand Jury, to commit offenses against the United States, that is:

(a) To manufacture cocaine, a Schedule II narcotic controlled substance, in Darien Province, Panama, intending that such cocaine be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959.

(b) To distribute cocaine, a Schedule II narcotic controlled substance, in Panama and Colombia intending that such cocaine be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959.

(c) To import cocaine, a Schedule II narcotic controlled substance, into the Southern District of Florida and elsewhere in the United States from a place outside thereof, in violation of Title 21, United States Code, Section 952;

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

COUNT VIII

From in or about May 1984 through June 15, 984, in the Southern District of Florida and elsewhere, the defendants:

GUSTAVO DEJESUS GAVIRIO-RIVERO

and

RICARDO BILONICK did import and aid and abet others in the importation of 2,141 pounds of cocaine from Colombia through Panama to Miami, in violation of Title 21, United States Code, Section 952 and Title 18, United States Code, Section 2.

COUNT IX

From in or about November 1985 through March 1986, in the Southern District of Florida and elsewhere, the defendants:

MANUEL ANTONIO NORIEGA

AMET PAREDES

LUIS FERNANDO ESCOBAR-OCHOA

BRIAN ALDEN DAVIDOW

HERMAN VELEZ

WILLIAM SALDARRIAGA

and

JAIME GOMEZ

along with Cesar Rodriguez and Ruben Dario Paredes-Jiminez, now deceased, knowingly and intentionally did combine, conspire, confederate and agree with each other and with other persons known and unknown to the Grand Jury, to commit offenses against the United States, that is:

(a) To distribute in excess of 322 kilograms of cocaine, a Schedule II narcotic controlled substance, intending that such cocaine be unlawfully imported into the United States aboard the vessel ″Krill,″ in violation of Title 21, United States Code, Section 959.

(b) To import in excess of 322 kilograms of cocaine, a Schedule II narcotic controlled substance, into the United States from a place outside thereof, aboard the vessel ″Krill,″ in violation of Title 21, United States Code, Section 952.

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

COUNT X

In or about March 1986 the defendants:

MANUEL ANTONIO NORIEGA

AMET PAREDES

LOUIS FERNANDO ESCOBAR-OCHOA

BRIAN ALDEN DAVIDOW

HERMAN VELEZ

WILLIAM SALDARRIAGA

and

JAIME GOMEZ

did knowingly and intentionally distribute and aid and abet the distribution of approximately 322 kilograms of cocaine, a Schedule II narctic controlled substance, intending that such cocaine be unlawfully imported into the Southern District of Florida and elsewhere in the United States, in violation of Title 21, United States Code, Section 959 and Title 18, United States Code, Section 2.

Travel Acts

COUNTS XI-XII

On or about the dates set forth below, according to Counts, in the Southern District of Florida and elsewhere, the defendants, as set forth below, and persons known and unknown to the Grand Jury, did knowingly and wilfully travel and cause travel, use and cause to be used facilities in interstate and foreign commerce with intent to promote, manage, establish and carry on, and facilitate the promotion, management, establishment and carrying on of an unlawful activity, that is, a business enterprise involving cocaine, a Schedule II narcotic controlled substance in violation of Title 21, United States Code, Sections 952, 959 and 963 and thereafter did perform, attempt to perform and cause to be performed acts to promote, manage, establish and carry on, and facilitate the promotion, management, establishment, and carrying on of said unlawful activity.

Count XI

Defendants

MANUEL ANTONIO NORIEGA

GUSTAVO DEJESUS GAVIRIA-RIVERO

EDUARDO PARDO

DANIEL MIRANDA

Travel

Flight of Eduardo Pardo and Daniel Miranda with $800,000 from Ft. Lauderdale, Florida to Panama

Approximate Date

May 1983

Count XII

Defendant

MANUEL ANTONIO NORIEGA

Travel

Flight of Tony Aizprua from Ft. Lauderdale, Florida to Panama

Approximate Date

May 1984

All in violation of Title 18, United States Code, Sections 1952(a)(3) and 2.

A TRUE BILL

(Signed)

Foreperson

Leon B. Kellner

United States Attorney

Richard D. Gregorie

Chief Assistant United States Attorney

Mark P. Schnapp

Assistant United States Attorney

Chief, Criminal Division