Case Information
*1 25-CR-20096-BLOOM/ELFENBEIN CASE NO. __________ _ 21 u.s.c. § 963 21 U.S.C. § 952(a) 21 u.s.c. § 846 21 U.S.C. § 84l(a)(l) 21 u.s.c. § 853 21 u.s.c. § UNITED STATES OF AMERICA
vs.
LAZARO TRUJILLO VITON,
a/k/a "Cuba,"
GIANFRANCO GUILLIANI,
a/k/a "Williams Spencer Guilliani," a/k/a "Hollywood," and
RAFAEL LEONIDAS CUELLO,
a/k/a "Lolo,"
Defendants.
------------------ I
INDICTMENT
The Grand Jury charges that:
COUNT 1 Beginning at least as early as in or around May 2020, and continuing through in and around November 2022, the exact dates being unknown to the Grand Jury, in Miami-Dade County, in the Southern District of Florida, and in the country of the Dominican Republic, and elsewhere, the defendants,
LAZARO TRUJILLO VITON, a/k/a "Cuba," GIANFRANCO GUILLIANI, a/k/a "Williams Spencer Guilliani," a/k/a "Hollywood," and RAFAEL LEONIDAS CUELLO, a/k/a "Lolo," *2 did knowingly and willfully combine, conspire, confederate, and agree with each other and with other persons known and unknown to the Grand Jury, to import into the United States, from a place outside thereof, a controlled substance, in violation of Title 21 , United States Code, Section 952( a) ; all in violation of Title 21 , United States Code, Section 963.
It is further alleged that the controlled substance involved in the conspiracy attributable to the defendants as a result of their own conduct, and the conduct of other conspirators reasonably foreseeable to them, is five (5) kilograms or more of a mixture and substance containing a detectable amount of cocaine, a Schedule II controlled substance, in violation of Title 21 , United States Code, Section 960(b )( 1 )(B)(ii).
COUNT2 Beginning at least as early as in or around May 2020, and continuing through in and around November 2022, the exact dates being unknown to the Grand Jury, in Miami-Dade County, in the Southern District of Florida, and in the country of the Dominican Republic, and elsewhere, the defendants,
LAZARO TRUJILLO VITON, a/k/a "Cuba," GIANFRANCO GUILLIANI, a/k/a "Williams Spencer Guilliani," a/k/a "Hollywood," and RAFAEL LEONIDAS CUELLO, a/k/a "Lolo," did knowingly and willfully combine, conspire, confederate, and agree with each other and with other persons known and unknown to the Grand Jury, to distribute and possess with intent to distribute a controlled substance, in violation of Title 21 , United States Code, Section 841 ( a)(l ); *3 all in violation of Title 21 , United States Code, Section 846.
It is further alleged that the controlled substance involved in the conspiracy attributable to the defendants as a result of their own conduct, and the conduct of other conspirators reasonably foreseeable to them, is five (5) kilograms or more of a mixture and substance containing a detectable amount of cocaine, a Schedule II controlled substance, in violation of Title 21 , United States Code, Section 841(b)(l)(A)(ii).
FORFEITURE ALLEGATIONS 1. The allegations of this Indictment are hereby re-alleged and by this reference fully incorporated herein for the purpose of alleging forfeiture to the United States of America of certain property in which the defendants, LAZARO TRUJILLO VITON, a/k/a "Cuba," GIANFRANCO GUILLIANI, a/k/a "Williams Spencer Guilliani," a/k/a "Hollywood," and RAFAEL LEONIDAS CUELLO, a/k/a "Lolo," have an interest.
2. Upon conviction of a violation of Title 21 , United States Code, Sections 846 and/or 963 , as alleged in this Indictment, the defendants shall forfeit to the United States any property constituting, or derived from , any proceeds obtained, directly or indirectly, as a result of such offense, and any property that was used or intended to be used, in any manner or part, to commit or to facilitate the commission of such offense, pursuant to Title 21 , United States Code, Section 853.
[This space intentionally left blank.] *4 All pursuant to Title 21 , United States Code, Sections 853 and 970. A TRUE BILL UNITED STATES ATTORNEY
~ D. C-/2_
KEVIN D. GERARDE
ASSIST ANT UNITED ST A TES ATTORNEY *5 PENALTY SHEET Defendant's Name: LAZARO TRUJILLO VITON, a/k/a "Cuba"
Case No: __________________ _____ _ _____ _ _ Count #: 1
Conspiracy to unlawfully import cocaine into the United States
Title 21, United States Code, Sections 963 and 952(a)
* Max. Term of Imprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
*Max.Fine: $10,000,000.00
Count #: 2
Conspiracy to distribute and possess with intent to distribute cocaine
Title 21, United States Code, Sections 846 and 841(a)(l)
*Max.Term of Imprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
* Max. Fine: $10,000,000.00
*Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable.
PENALTY SHEET Defendant's Name: GIANFRANCO GUILLIANI, a/k/a "Williams Spencer Guilliani,"
a/k/a "Hollywood" Case No: ________________ _ ______ ______ _ _ Count #: 1
Conspiracy to unlawfully import cocaine into the United States
Title 21, United States Code, Sections 963 and 952(a)
*Max.Term oflmprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
*Max.Fine: $10,000,000.00
Count #:2
Conspiracy to distribute and possess with intent to distribute cocaine
Title 21, United States Code, Sections 846 and 84 l(a)(l)
* Max. Term of Imprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
* Max. Fine: $10,000,000.00
*Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable.
PENALTY SHEET Defendant's Name: RAFAEL LEONIDAS CUELLO, a/k/a "Lolo" Case No: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Count#: 1
Conspiracy to unlawfully import cocaine into the United States
Title 21, United States Code, Sections 963 and 952(a)
* Max. Term of Imprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
*Max.Fine: $10,000,000.00
Count#:2
Conspiracy to distribute and possess with intent to distribute cocaine
Title 21, United States Code, Sections 846 and 84 l(a)(l)
* Max. Term of Imprisonment: Life
* Mandatory Min. Term of Imprisonment: Ten years
* Max. Supervised Release: at least five years to life
* Max. Fine: $10,000,000.00
*Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable. *8 25-CR-20096-BLOOM/ELFENBEIN CASE NO.: __ __ __ ___ __ __ _
UNITED STATES OF AMERICA v.
CERTIFICATE OF TRIAL ATTORNEY LAZARO TRUJILLO VITON , et al. , Superseding Case Information: I
----------::------:-------- Defendants. New Defendant(s) (Yes or No) __ Number of New Defendants __ Court Division (select one) Total number of new counts __ (]Miami □ Key West □ FTP □ FTL □ WPB
I do hereby certify that:
I. I have carefully considered the allegations of the Indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/Information attached hereto. 2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, 28 U.S.C. §3161 . 3. Interpreter: (Yes or No) Yes
List language and/or dialect:_S.._p_an_i_sh ____ _ This case will take 8 days for the parties to try.
4.
5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one) I D Oto 5 days □ Petty II 10 6 to 10 days □ Minor III D 11 to 20 days D Misdemeanor
IV D 21 to 60 days GI Felony
V D 61 days and over 6. Has this case been previously filed in this District Court? (Yes or No) No - -
If yes, Judge ___ ________ Case No. ______________ _ _ _ _ 7. Has a complaint been filed in this matter? (Yes or No) No - -
Ifyes, Judge _ __ _ __ _ ___ _ Magistrate Case No. _____________ _ 8. Does this case relate to a previously filed matter in this District Court? (Yes or No)No - -
Ifyes, Judge ___________ Case No. ________________ _ _ 9. Defendant(s) in federal custody as of _______________ ______ _ _ _ 10. Defendant(s) in state custody as of ________________________ _ 11. Rule 20 from the _____ District of ______ _
12. Is this a potential death penalty case? (Yes or No) No - -
13. Does this case originate from a matter pending in the Central Region of the U.S. Attorney ' s Office
prior to October 3, 2019 (Mag. Judge Jared M. Strauss)? (Yes or No) No - -
14. Did this matter involve the participation of or consultation with Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? _N_o_ 15. Did this matter involve the participation of or consultation with Magistrate Judge Marty Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024?No - -
16. Did this matter involve the participation of or consultation with Magistrate Judge Ellen F. D ' Angelo
during her tenure at the U.S. Attorney ' s Office, which concluded on October 7, 2024? Yes
By: 2A-- D. c:;:: e ~
Kevin D. Gerarde Assistant United States Attorney FLBarNo.