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ELIZABETH A. STRANGE F IL E D

Acting United Stat States Attorney ZIT NOV 21 PM 4: 05

Assistant US. Atorey CLERK US DISTRICT COURT

405 West Congress Suite 4800 DISTRICT OF ARIZONA
Tucson, Arizona 85701-5040
Felephone: (520) 620-7300
mail: adam.rossi2(

v
Atomeye for Plainti: ‘so

UNITED STATES DISTRICT COURT

United States of Americ, CR17-1791 Tuc!)

Plaintiff,
INDICTMENT

8 U.S.C. ele 1324(a ae
Charles Burton Foster, 8 usc. aA i
# rt Mlegal

(Conspirac
(Counts 1-4) Aine poe

Defendant.
8 Uses
8 Use. 132 zataN LOMO,
(Transportation oO
vr Profit)
Counts 2-4

liens

THE GRAND JURY CHARGES:
COUNT1

From a date unknown to on or about October 29, 2017, at or near Tucson, in the
District of Arizona, Charles Burton Foster,.did knowingly and intentionally combine,
conspire, confederate, and agree with various other persons known and unknown to the
grand jury, to transport and move Santos Cortez-Garcia, Simon Gavilan-Velazquez and
Noe Marin-Aguilera, illegal aliens, within the United States by means of transportation or
otherwise, in furtherance of such violation of law for the purpose of commercial advantage
or private financial gain, all in violation of Title 8, United States Code, Sections
1324(a)(1(A)(v)@), 1324(a)(1)(A)Gi) and 1324(a)(1)(B)().



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COUNT 2
On or about October 29, 2017, at or near Tucson, in the District of Arizona,
Charles Burton Foster, knowing and in reckless disregard of the fact that an alien, Santos
Cortez-Garcia, had come to, entered and remained in the United States in violation of
law, did transport and move said alien within the United States by means of
transportation or otherwise, in furtherance of such violation of law, and did so for the
purpose of commercial advantage and private financial gain, in violation of Title 8,

United States Code, Sections 1324(a)(1)(A)(ii) and 1324(a)(1)(B)(i).

COUNT 3
On or about October 29, 2017, at or near Tucson, in the District of Arizona,
Charles Burton Foster, knowing and in reckless disregard of the fact that an alien, Simon
Gavilan-Velazquez, had come to, entered and remained in the United States in violation
of law, did transport and move said alien within the United States by means of
transportation or otherwise, in furtherance of such violation of law, and did so for the
purpose of commercial advantage and private financial gain, in violation of Title 8,

United States Code, Sections 1324(a)(1)(A)(ii) and 1324(a)(1)(B)(i).

COUNT 4
On or about October 29, 2017, at or near Tucson, in the District of Arizona, Charles
Burton Foster, knowing and in reckless disregard of the fact that an alien, Noe Marin-
Aguilera, had come to, entered and remained in the United States in violation of law, did
transport and move said alien within the United States by means of transportation or
otherwise, in furtherance of such violation of law, and did so for the

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United States of America v. Charles Burton Foster
Indictment Page 2 of 3



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purpose of commercial advantage and private financial gain, in violation of Title 8,
United States Code, Sections 1324(a)(1)(A)(ii) and 1324(a)(1)(B)(i).

A TRUE BILL
Is]
Presiding Juror
ELIZABETH A. STRANGE
Acting United States Attorney
District of Arizona
/S/

REDACTED FOR

Assistant United States Attorney AUBLIC BISCLOSURE
Dated: _November 21, 2017 _

United States of America v. Charles Burton Foster
Indictment Page 3 of 3