UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FILHD

AU60a2010g,il

UNITED STATES OF AMERICA

V.

SASAN ESKAFYAN,

also known as'Alex," and

MARIO HURTADO-MEZA

COUNT ONE

The SPECIAL NOVEMBER 2019 GRAND JURY charges:

Beginning on or about March 7,2019, and continuing until on or about July 4,

20!9, at Chicago, in the Northern District of Illinois, Eastern Division, and elsewhere,

SASAN ESKAFYAN, also known as "A1ex," and

MARIO HURTADO-MEZA,

defendants herein, did conspire with each other, with Individual A, and with others

known and unknown to the Grand Jury, to knowingly and intentionally possess with

intent to distribute and distribute a controlled substance, namely, fi.ve kilograms or

more of a mixture and substance containing a detectable amount of cocaine, a

Schedule II Controlled Substance, and a quantity of a mixture and substance

containing a detectable amount of fentanyl (N-phenyl-N-1 [1-(2-phenylethyl).4-

piperidinyl] propanamide), a Schedule II Controlled Substance, in violation of Titte

21, United States Code, Section 8a1(a)(1);

In violation of Title 21, United States Code, Section 846.

No.

Violations: Title 18, United States Code,

Sections 1956(a)(2)(BX, and (h); Title

21, United States Code, Section 846

JUDGE NORGLE

UNDER SEAL

Maglstrate Judge McShain

20CR 458

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COUNT TWO

The SPECIAL NOVEMBER 2OLg GRAND JURY further charges:

Beginning on or about March 15, 20L9, and continuing until on or about July

4, 2OLg, at Chicago, in the Northern District of Illinois, Eastern Division, and

elsewhere,

SASAN ESKAFYAN, also known as "AIex," and

MARIO HURTADO-MEZA,

defendants herein, d.id. conspire with each other, with Individua1 A, and with others

known and unknown to the Grand Jury, to commit an offense in violation of Title 18,

United States Code, Section 1956, namely, to transport and attempt to transport

monetary instruments and funds, that is, approximately $52g,2g5 in U.S. Currency,

from a place in the United States, that is, Chicago, Illinois, to a place outside the

United States, that is, Mexico, knowing that the monetary instruments and funds

involved in the transportation represented the proceeds of some form of unlawful

acJivity and knowing that such trarisportation was designed in whole or in part to

conceal and disguise the nature, location, source, ownership, and control of the

proceeds of specified unlawful activity, that is, the felonious buying and selling and

otherwise dealing in a controlled substance, in violation of Title 18, United States

Code, Section 1956(a)(2)(B)(i);

In violation of Title l-8, United States Code, Section 1g56(h).

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COUNT THREE

The SPECIAL NOVEMBER IOLLGRA.ND JURY further charges:

On or about April 3, 2019, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SASAN ESKAFYAN, also known as "ALex," and

MARIO IIURTADO-MEZA,

defendants herein, did attempt to transport monetary instruments and funds, that

is, approximately $52g,2g5in U.S. Currency, from a place in the United States, that

is, Chicago, Illinois , to a place outside the United States, that is, Mexico, knowing

that the monetar5r instruments and funds involved in the transportation represented

the proceeds of some form of unlawful activity and knowing that such transportation

was designed in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of specified unlawful activity, that is, the

felonious buying and selling and otherwise dealing in a controlled. substance;

In violation of Tit1e 18, United States Code, Sections 1956(a)(2)@)(i) and2.

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F'ORFEITURE ALLEGATION

The SPECIAL NOVEMBER 2OLg GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 21, United States Code,

Section 846, as pet forth in this Indictment, defendants SASAN ESKAFYAN and

MARIO HURTADO-MEZA shall forfeit to the United States of America alny property

which constitutes and. is derived from proceeds obtained., directly and indirectly, as a

result of the offense; and any property used, and intended to be used, in any manner

and part, to commit and facilitate commission of the offense, as provided in Title 21,

United States Code, Section 853(a).

2. Upon conviction of an offense in violation of Title 18, United States Cod"e,

Section 1956, as set forth in this Ind.ictment, defend,ants SASAN ESKAFYAN and

MARIO HURTADO-MEZA shatl forfeit to the United States of America any property

involved in such offense, and any property traceable to such property, as provided in

Title 18, United States Code, Section 982(a)(1).

3. The property to be forfeited includes, but is not limited to, the following

specific property:

i. approximately $529,295 in U.S. Currency seized by law

enforcement from the area of the 2800 block of W. Diversey Avenue in Chicago,

Illinois, or about April 3, 2019; and

ii. approximately $10,000 in U.S. Currency seized by law

enforcement from the area of the 2900 block of S. Cicero Avenue in Chicago, Illinois,

on or about April 24,20L9.

4. If any of the property described above, as a result of any act or omission

4

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by a defendant: cannot be located upon the exercise of due diligence; has been

transferred. or sold to, or deposited with, a third party; has been placed beyond the

jurisdiction of the Court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without difficulty, the

United States of America shall be entitled to forfeiture of substitute property, as

provided in Title 21, United Statbs Code, Section 853(p).

A TRUE BILL:

FOREPERSON

Signed by Erika Csicsila on behalf of the

UNITED STATES A.TTORNEY

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