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IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF PUERTO RICO

UNITED STATES OF AMERICA,

Plaintiff

v.

[1] JORGE GOMEZ-GONZALEZ, a.k.a

Jorge Cara de Truck, et al.,

Defendants.

CRIMINAL NO. 11-241 (DRD)

UNITED STATES' MOTION FOR CAUTIONARY NOTICE

TO THE HONORABLE COURT:

COMES NOW, plaintiff, the United States of America, through its undersigned attorneys,

and respectfully states and prays as follows:

1. On or about June 27, 2011, a Federal Grand Jury returned an indictment charging violations

of Title 21, United States Code, Sections 841 and 846; and Title 18, United States Code, Section

1956(h), among others. Pursuant to Title 21, United States Code, Section 853, upon conviction of

an offense in violation of Title 21, United States Code, Sections 841 and 846 (charged in Counts One

through Four of the Indictment), the defendants shall forfeit to the United States, any property

constituting, or derived from, proceeds obtained, directly or indirectly, as a result of said violations

any property used, or intended to be used, in any manner or part, to commit, or to facilitate the

commission of the aid violations, including but not limited to the following: a sum of money of at

least Twenty Million Dollars ($20,000,000.00) in United States currency, representing the mount of

proceeds obtained as a result of the offenses charged.

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

cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited

Case 3:11-cr-00241-DRD-CVR Document 1021 Filed 01/26/12 Page 1 of 9


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Motion for Cautionary Notice

Criminal No. 11-241 (DRD)

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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, including

but not limited to:

1). One Urban lot, together with its building, appurtenances, improvements, fixtures,

attachments and easements, located at La Perla Rural Community, San Juan, Puerto Rico, more

particularly described as:

URBAN: Lot market with the number D-8 in the inscription plans of La Perla RuralCommunity, at La Perla Ward of the Municipality of San Juan, with a superficial area

of 108.74 square meters. Bounding on the NORTH, with Lucila Silva Street of the

Community; on the SOUTH, with an alley; on the EAST, with Lot No. D-7 of the

Community; and on the WEST, with Lot No. D-9 of the Community.

Property No. 4509, recorded at page 111 of volume 171 of San Juan. Registry of Property, First

Section of San Juan, Puerto Rico.

Registered Owner: Julio Serrano Pagn and his wife Carmen Raquel Gonzlez.


attachments and easements, located at La Perla Project, San Juan, Puerto Rico, more particularly

described as:

URBAN: Lot market with the number D-9 in the inscription plans of La Perla Project

labeled CRUV-10-63, located at the Municipality of San Juan, Puerto Rico, with a

superficial area of 120.86 square meters. Bounding on the NORTH, with Lucila

Silva Street, on a distance of 9.35 meters; on the SOUTH, with Lot No. D-8 and with

an easement for the maintenance of the City Wall (SPN), on a distance of 2.75

meters and 6.64 meters; on the EAST, with Lot No. D-8 Lucila Silva Street, ondistances of 1.64 meters, 3.84 meters, 7.22 meters and 0.82 meter; and on the WEST,

with an alley, on a distance of 13.58 meters.



Registered Owner: Julio Serrano Pagn and his wife Carmen Raquel Gonzlez.



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described as:

URBAN: Lot market with the number 64 of block C in the inscription plans of La

Perla Project, labeled CRUV-10-63, located at the Municipality of San Juan, Puerto

Rico, with a superficial area of 77.65 square meters. Bounding on the NORTH, with

Lots C-63 and C-62, on a distance of 5.70 meters and 2.06 meters, respectively; on

the SOUTH, with an alley and Lucila Silva Street, on a distance of 0.79 meter and

6.73 meters, respectively; on the EAST, with Lot No. C-61, on a distance of 11.31

meters; and on the WEST, with an alley, on a distance of 7.69 meters and 3.17

meters.



Registered Owner: Esteban Dipini-Hernndez.



described as:

URBAN: Lot market with the number 46 of block C in the inscription plans of La

Perla Project, labeled CRUV-10-63, located at the Municipality of San Juan, Puerto

Rico, with a superficial area of 91.71 square meters. Bounding on the NORTH, with

Concepcin Silva Street, on a distance of 9.74 meters and 0.67 meters; on the

SOUTH, with Felisa Silva Street, on a distance of 10.09 meters; on the EAST, with

Lot No. C-46-A, on a distance of 8.60 meters; and on the WEST, with an alley, on

a distance of 9.01meters.



Registered Owner: Amrica Roln-Daz.



described as:



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URBAN: Lot market with the number E-4 in the inscription plans of La Perla Project,

labeled CRUV-10-63, located at the Municipality of San Juan, Puerto Rico, with a

superficial area of 84.07 square meters. Bounding on the NORTH, with alleys, on

a distance of 1.42 meters, 5.57 meters and 1.11 meters; on the SOUTH, with

Concepcin Silva Street, on a distance of 9.12 meters; on the EAST, with an alley,

on a distance of 3.54 meters and 7.50 meters; and on the WEST, with an alley, on a

distance of 6.25 meters, 2.30 meters and 2.38 meters.



Registered Owner: Alejandro Beaz-Rivera..



described as:

URBAN: Lot market with the number D-3 in the inscription plans of La Perla

Project, labeled CRUV-10-63, located at the Municipality of San Juan, Puerto Rico,

with a superficial area of 108.73 square meters. Bounding on the NORTH, with

Lucila Silva Street, on a distance of 10.28 meters; on the SOUTH, with maintenance

easement for the City Wall (SPN) and Lot No. D-2, on a distance of 8.22 meters

2.42 meters, respectively; on the EAST, with Lot No. D-2, on a distance of 2.65

meters and 8.30 meters; and on the WEST, with an alley, on a distance of 11.00meters.



Registered Owner: Soraya Santana-Melndez.



described as:

URBAN: Lot market with the number F-42 in the inscription plans of La Perla


with a superficial area of 111.58 square meters. Bounding on the NORTH, with Lot

F-43, on a distance of 9.40 meters; on the SOUTH, with a maintenance easement for

the City Wall (SPN), on a distance of 8.24 meters; on the EAST, with Lot No. F-46



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and F-42, on a distances of 1.94 meters, 2.30 meters, 4.29 meters and 5.28 meters;

and on the WEST, with a maintenance easement for the City Wall (SPN), on a

distance of 7.16 meters and 4.07 meters.



Registered Owner: Mercedes Caballero Reyes and his wife Angela Morales.



described as:

URBAN: Lot market with the number E-23 in the inscription plans of La Perla


with a superficial area of 81.52 square meters. Bounding on the NORTH, with a

Street with no name, on a distance of 8.83 meters; on the SOUTH, with Lucila Silva

Street, on a distance of 6.01 meters and 3.78 meters; on the EAST, with Lot No. E-

23-A, on a distances of 9.43 meters; and on the WEST, with an alley and Lucila Silva

Street, on a distance of 8.38 meters and 1.28 meters.



Registered Owners: Luis Lpez-Alomar and his wife Estrella Gonzlez-Monge.



described as:



with a superficial area of 58.07 square meters. Bounding on the NORTH, withaccess road of the Community; on the SOUTH, with access road of the Community;

on the EAST, with access road of the Community; and on the WEST, with Lot No.

E-34 of the Community.





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Concepcin Silva Street of the Community; on the SOUTH, with Felisa Silva Street

of the Community; on the EAST, with Lot No. C-49; and on the WEST, with an

alley.



Registered Owner: Teresa Nieves-Torres.



described as:

URBAN: Lot market with the number D-11-A in the inscription plans of La Perla



Community Street; on the SOUTH, with maintenance easement; on the EAST, with

Lot No. D-11 of the Community; and on the WEST, with Community Street.



Registered Owner: Carmen Melndez-Torres.



described as:



with a superficial area of 67.61 square meters. Bounding on the NORTH, with LotNo. E-16-A of the Community; on the SOUTH, (not included in the description); on

the EAST, with Lot No. E-1 of the Community; and on the WEST, with an alley.





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Registered Owner: Carmen Mara Robles-Gonzlez.


attachments and easements, located at La Perla Rural Community, San Juan, Puerto Rico, more

particularly described as:

URBAN: Lot market with the number A-25-A in the inscription plans of La Perla

Rural Community, located at the Municipality of San Juan, Puerto Rico, with a

superficial area of 64.32 square meters. Bounding on the NORTH, with Lot No. A-

25 of the Community; on the SOUTH, with a future street; on the EAST, with an

alley of the Community; and on the WEST, with an alley of the Community.

Property No. 5205, recorded at page 203 of volume 193 of San Juan. Registry of Property, FirstSection of San Juan, Puerto Rico.

Registered Owner: Khilsy Denise Aviles-Quiones.

3. Pursuant to Article 112 of the Mortgage and Property Registry Act of 1979, PR ST. T. 30

Section 2401(1), a cautionary notice may be requested by a person claiming in a lawsuit ownership

to real property or the constitution, declaration, modification or extinction of any recordable right

or one who files his claim in an action that affects a title to real property. The cautionary notice is

to be entered into the Puerto Rico Property Registry.

4. A cautionary notice can only be made by order of the court handed down at the request of a

legitimate party and by virtue of adequate documentation for prudent judicial discretion. See PR

ST. T. 30 Section 2402.

WHEREFORE, the United States of America respectfully moves this Honorable Court to

enter an order directing the Property Registrar for the pertinent divisions of the Commonwealth of

Puerto Rico Property Registry, to enter a cautionary notice over each of the property, giving notice

that these properties are subject to forfeiture pursuant to Title 21, United States Code, Section

853(p).



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RESPECTFULLY SUBMITTED.

In San Juan, Puerto Rico, this 26 day of January, 2012.th

ROSA EMILIA RODRIGUEZ-VELEZ

United States Attorney

/s/Myriam Y. Fernndez-Gonzlez

Myriam Y. Fernndez-Gonzlez

Assistant United States Attorney

Chief, Money Laundering and

Asset Forfeiture Unit

USDC # 218011

Torre Chardn, Suite 1201350 Carlos Chardn Street

Hato Rey, PR 00918

Tel. (787) 766-5656

Fax. (787) 771-4050

Email: [email protected]

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, I electronically filed the foregoing with the Clerk of the Court

using the CM/ECF system which will send notification of such filing to all parties.

RESPECTFULLY SUBMITTED,

In San Juan, Puerto Rico, this 26 , day of January, 2012.th

s/Myriam Y. Fernndez-Gonzlez

Myriam Y. Fernndez-Gonzlez

U.S.D.C. No. 218011

mailto:[email protected]:[email protected]

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