Free Redacted Document - District Court of Delaware - Delaware

. Case 1 :07-cr-00120-SLR Document 13 Filed O9/O4/2007 Page 1 of 3 g
IN THE UNITED STATES DISTRICT COURT . .- _ p
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
. )
Plaintifi )
_ )
v. ) _ .
) Criminal Action No. 07- / pg UN}4
JANIE REYES-MARINO and )
MANLIO YOVANI ) D J “"* ‘
MARTINEZ-RODRIGUEZ, ) . EI F ‘j D
) - UID - tm Jr L
. Defendants. )
''`; INDICTMENT
The Grand J ury for the District cf Delaware charges that:
I COUNT ONE
On or about August 5, 2007, in the State and District of Delaware and elsewhere, Defendant
Janie Reyes-Marino and Manlio Yovani Martinez Rodriguez, knowing and in reckless disregard ef
the fact that aliens had come to, entered and remained in the United States in violation of law, did
transport and move said aliens within the United States by means of transportation and otherwise
in furtherance of such violation of law, and did so for the purpose of commercial advantage and
private financial gain. _
All in violation of Title 8, United States Code, Sections l324(a)(l)(A)(ii) & (a)(l)(B)(i), and _
Title 18, United States Code, Section 2. ..-..-.... - T 2 _
I 1 -.., .9 -
Ii$EP · 4 2007 I
us. aIi€iI{ilIéI: -`-r E I I
D‘$I"*‘@l-?i.Q?;Yi:lI’ 1- `

Case 1 :07-cr-00120-SLR Document 13 Filed O9/O4/2007 Page 2 of 3 l
I I COUNT TWO
On or about March 2000, within the Southern District of California, the defendant, Manlio
Yovani Martinez-Rodriguez, who was then and there an alien, did knowingly and unlawfully enter 3
the United States nom Mexico, at a point near Calexico, Califomia, which said time and place was
then and there other than as designated by immigration officials ofthe United States for the entrance
of immigrants into the United States, in violation of Title 8, United States Code, Section l325(a)(l).
NOTICE OF FORFEITURE
Upon conviction of the offenses alleged in Count One of this Indictment, Defendants Janie
Reyes-Marino and Manlio Yovani Martinez·Rodriguez shall forfeit to the United States pursuant to `
l8 U.S.C. § 982(a)(6), 8 U.S.C. § l324(b), and 28 U.S.C. § 246l(c), all conveyances used in the _
commission ofthe violation; all property, real and personal, that constitutes or is derived from or is \
traceable to proceeds obtained directly sg indirectly from the commission of the offense; and all
property, real or personal, that was used to facilitate, or was intended to be used to facilitate the
commission of the offense, including, but not limited to, $2,802 in United States currency.
If any of the above-described forfeitable property, as a result of any act or omission of the
defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold
to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the court; (d) has
been substantially diminished in value; or (e) has been eornmingled with other property which cannot
be divided without difficulty; it is the intent ofthe United States, pursuant tol 8 U.S .C. § 982(b) and
21 U.S.C. § 853(p), to seek forfeiture of any other property of said defendant up to the value ofthe .
forfeitable property described above.
2

, Case 1 :07-cr-00120-SLR Document 13 Filed O9/O4/2007 Page 3 of 3
i All pursuant to 18 U.S.C. § 982(a)(6) & (b), 21 U.S.C. § 85303), 8 U.S.C. § 1324, 28 U.S.C.
§ 2461(c), and Fed. R. Crim. P. 32.2. _
_ A TRUE BILL:
_ Forhgersép _
A COL F. CO OLLY ‘
TA \ s ·~ RNEY
t
ii t•‘ it
gawn t· ede · -
Assist :· United St · Attorney
Dated: September 4, 2007 _

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