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FILED 



2012 JUH -6 PM 3:28 

clerk u.s. district court 

CENTRAL D1ST. OF CALIF. 
LOS ANGELES 

3':': : 



UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
September 2011 Grand Jury 



UNITED STATES OF AMERICA, 

Plaintiff, 
v. 

RAULDEL SANDOVAL, 

aka "Raudel Sandoval," 
aka "Lil Gumby, " 

Defendant . 



noC W 4 ? 005 41 

INDICTMENT 

[21 U.S.C. § 846: Conspiracy 
to Distribute Me thamphe famine ; 
21 U.S.C. §§ 841 (a) (1) , 
841 (b) (1) (B) (viii) : 
Distribution of 
Methamphetamine] 



The Grand Jury charges : 

COUNT ONE 
[21 U.S.C. §§ 846] 
A. OBJECT OF THE CONSPIRACY 

Beginning on a date unknown, and continuing to on or about 
May 16, 2012, in Los Angeles County, within the Central District 
of California, and elsewhere, defendant RAULDEL SANDOVAL, also 
known as ("aka") "Raudel Sandoval," aka "Lil Gumby" ("SANDOVAL"), 
and others known and unknown to the Grand Jury, conspired and 
agreed with each other to knowingly and intentionally distribute 
SL: VOCS 



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at least 50 grams of methamphetamine , a schedule II controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a) (1) and 841(b) (1) (A) (viii) . 

B. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE 
ACCOMPLISHED 

The object of the conspiracy was to be accomplished, in 
substance, as follows: 

1. Defendant SANDOVAL would offer to sell methamphetamine 
to a prospective buyer. 

2 . Defendant SANDOVAL would negotiate the price for the 
methamphetamine with the prospective buyer. 

3 . Defendant SANDOVAL would arrange for the sale of the 
methamphetamine to take place at certain locations. 

4 . Defendant SANDOVAL would obtain the methamphetamine from 
his source of supply for methamphetamine. 

5. Defendant SANDOVAL would deliver the methamphetamine to 
the buyer. 

6. Defendant SANDOVAl would accept payment for the 
methamphetamine from the buyer. 

C. OVERT ACTS 

In furtherance of the conspiracy and to accomplish the 
object of the conspiracy, defendant SANDOVAL, and others known 
and unknown to the Grand Jury, committed various overt acts, on 
or about the following dates, within the Central District of 
California, and elsewhere, including, but not limited to, the 
following: 

1. On March 4, 2010, defendant SANDOVAL sold approximately 
one ounce of methamphetamine to a confidential government 

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informant ("CI") . 

2. On March 4, 2010, using coded language, defendant 
SANDOVAL told the CI that SANDOVAL could obtain approximately 
three or four ounces of additional methamphetamine to sell to the 
CI . 

3. On March 16, 2010, using coded language in a telephone 
conversation, defendant SANDOVAL told the CI that he needed to 
contact his source of supply regarding the sale of additional 
methamphetamine to the CI . 

4. On March 16, 2010, using coded language in a telephone 
conversation, defendant SANDOVAL told the CI that he was going to 
try to obtain four ounces of methamphetamine to sell to the CI. 

5. On March 16, 2010, using coded language in a telephone 
conversation, defendant SANDOVAL told the CI that if the CI did 
not like the methamphetamine provided by SANDOVAL, SANDOVAL'S 
supplier, an unindicted co-conspirator, would return the CI's 
money. 

6. On March 16, 2010, using coded language in a telephone 
conversation, defendant SANDOVAL told the CI that he could only 
get two ounces of methamphetamine, but that SANDOVAL was ready to 
do the deal at that time . 



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COUNT TWO 



[21 U.S.C. § 841(a)(1), 841 (b) ( 1 ) (B) ( viii ) ] 
On or about March 4, 2010, in Los Angeles County, within the 
Central District of California, defendant RAULDEL SANDOVAL, also 
known as ("aka") "Raudel Sandoval," aka "Lil Gumby, " knowingly 
and intentionally distributed at least 5 grains, that is, 
approximately 27.4 grams, of methamphetamine , a schedule II 
controlled substance. 



ROBERT E. DUGDALE 

Assistant United States Attorney 
Chief, Criminal Division 



ELIZABETH R. YANG 

Assistant United States Attorney 

Chief, Violent & Organized Crime Section 



CHRISTOPHER BRUNWIN 

Assistant United States Attorney 

Deputy Chief, Violent & Organized Crime Section 



SARAH LEVITT 

Assistant United States Attorney 
Violent & Organized Crime Section 



A TRUE BILL 




ANDRE BIROTTE JR. 
United States Attorney 




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