1. No category

Case 1:11-cr-20582-JEM Document 36 Entered on FLSD Docket 12/17/2014 Page 1 of 3
UNITED STATES DISTR ICT CO URT
SO UTH ERN DISTRICT O F FLORIDA
CaseN o.11-CR-20582-M ARTlN EZ
UNITED STATES O F AM ERICA
VS.
M ARLLOR Y CH ACO N R O SSELL,
Defendant.
/
FA CTUAL PRO FFER
lf this matter were to proceed to trial,the Govem m entwould prove the follow ing facts
beyond a reasonable doubt. The Parties agree thatthese facts,which do not includc al1facts
known to the Govem m entand theD efendantare suffk ientto prove theguiltofthe Defendantof
theabove-referenced lndictment'
.
As a result of information provided by severalcoopcrating sources,Drug Enforcem ent
Adm inistration agents began investigating the drug trafficking activities of defendant
M ARLLORY CHACON ROSSELL (hereinafter ttCHACON'). According to multiple
cooperating defendants and/or confidentialsources,CHACON wasa prom inentdrug traftk ker
who wasresponsible forcoordinating the receipt purchase,transportand distribution ofm ulti-ton
quantities ofcocaine in Honduras,Guatem ala and M exico,with a finaldestination ofthe United
States. ln addition,CH ACON also laundered m illionsin U .S.currency,derived from the sale of
cocaineshipm ents,from CentralAm erica to Colom biaand Panam a.
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Case 1:11-cr-20582-JEM Document 36 Entered on FLSD Docket 12/17/2014 Page 2 of 3
During thc cooperation ofaDEA CS (CS-l),in latc2010,CS-I attended a mceting at
CHACON 'Sresidencein GuatemalaCity. Thism eetinp which wasaudio and video recorded by
During the m eeting, CHACON was asked by a Colom bian source to provide her
traftk king infrastrtzcture in Honduras for the receipt of an 800 kilogram cocaine shipm ent.
CHACON w asseen and heard on video using two cellulartelephonesto coordinate thercceiptof
the shipm ent. CHACON gave instructions on the phonc asto the specificationsforthe airstrip,
how m uch fuelnecded to beprovidedsand furtherinstructed to have ttlwos Caracoles,''the group
thatwasto bercceivingthe load on bchalfofCHACON in Honduras,ready to receivein two days.
A lso during thismeeting,CHACON and CS-Idiscussed how manykilosshewould begetling and
whatthe price would be so she could be ready to pay in full. CHACON furtherstated thatshe
purchased a Cessna Caravan capableoftransporting approxim ately 2 tonsofcocaine.
ln approxim ately 2008 or 2009,agents received inform ation from various CSs,thatthe
CHACON organized the receiptoftwo cocaine shipm entsofover 1,200 kilogram seach. These
shipm ents were received in Honduras by the Caracolcs on behalf of CHACON and then
transported to Guatcm ala forfurtherdistribution to aM exican cartel.
AnotherCS (CS-2),and formerassociate ofCHACON,stated thatCS-2participated in
three separate air shipm ents with CHA CON prior to his/her cooperation. ln these air loads,
CHACON notonly provided the infrastructure forthe receiptofthe shipm ents in Honduras but
also owned kilograms in the loads. ln approxim ately N ovem ber2010,which w asto be the last
load w ith CS-2,CHACON purchased approxim ately 300 kilogram softhe load.
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o
Case 1:11-cr-20582-JEM Document 36 Entered on FLSD Docket 12/17/2014 Page 3 of 3
ln addition, during the tim e fram e that CS-2 dcalt w ith CHACON, she laundered
approximately$4million isU.S.currencyin dl'ugproceedsfortheCSfrom GuatemalatoPanama.
W IFREDO A .FERRER
UNITED STATES ATTORN EY
Date:tz-le+okt1.
By:
M ONIQUE BOTERO
A SSISTANT UNITED STATES ATTORNEY
oatc: /J -/z -//
By:
BoNxIE KLAPPER,EsQ.
ATTORXEY yoR DEFENDANT
1certify thatthe abovefactualprofferwastranslated to m e into Spanish and thatthe facts
conoined therein are true and correctto the bestofmy know lcdge.
Date: lJ-ll- tq
By: A /
Defendant
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ROSSELL