Case 4:25-cr-00030 Document 25 Filed on 04/08/25 in TXSD Page 1 of 4
United States Courts
Sealed Southern District of Texas
Public and unofficial staff access FILED
to this instrument are
April 08, 2025
prohibited by court order UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk of Court
HOUSTON DIVISION
UNITED STATES OF AMERICA §
§
v. §
§ Criminal No. 4:25-cr-00030-S1
GIOVANNI VICENTE MOSQUERA SERRANO §
aka Jhovanni San Vicente §
aka El Viejo §
JOSE ENRIQUE MARTINEZ FLORES §
aka Chuqui
SEALED
SUPERSEDING INDICTMENT
THE GRAND JURY CHARGES:
COUNT ONE
(International Cocaine Distribution Conspiracy)
Beginning in May 2024, the exact date being unknown to the Grand Jury, and continuing
thereafter until the return of this Indictment, in the countries of Colombia, Venezuela and within
the extraterritorial jurisdiction of the United States of America, the defendants
GIOVANNI VICENTE MOSQUERA SERRANO
aka Jhovanni San Vicente
aka El Viejo
and
JOSE ENRIQUE MARTINEZ FLORES
aka Chuqui
did knowingly and intentionally conspire and agree together and with other persons known and
unknown to the Grand Jury to manufacture and distribute 5 kilograms or more of a mixture and
substance containing a detectable amount of cocaine, a Schedule II controlled substance, intending,
knowing, and having reasonable cause to believe that such substance would be unlawfully
imported into the United States of America.
In violation of Title 21, United States Code, Sections 963, 959(a), 960(a)(3) and 960
(b)(1)(B).
Case 4:25-cr-00030 Document 25 Filed on 04/08/25 in TXSD Page 2 of 4
COUNT TWO
(International Cocaine Distribution)
On or about November 6, 2024, in the country of Colombia and within the extraterritorial
jurisdiction of the United States of America, defendants
GIOVANNI VICENTE MOSQUERA SERRANO
aka Jhovanni San Vicente
aka El Viejo
and
JOSE ENRIQUE MARTINEZ FLORES
aka Chuqui
did knowingly and intentionally manufacture and distribute a controlled substance, intending,
knowing, and having reasonable cause to believe that such substance would be unlawfully
imported into the United States of America. The controlled substance involved was more than 5
kilograms, that is, approximately 10 kilograms of a mixture or substance containing a detectable
amount of cocaine, a Schedule II controlled substance.
In violation of Title 21, United States Code, Sections 959(a), 960(a)(3), 960(b)(1)(B), and
Title 18, United States Code, Section 2.
COUNT THREE
(Providing Material Support to a Foreign Terrorist Organization Conspiracy)
From on or about February 20, 2025, and continuing thereafter until the return of this
Indictment, in the Southern District of Texas, and elsewhere including the countries of Colombia
and Venezuela within the extraterritorial jurisdiction of the United States of America, the
defendants
GIOVANNI VICENTE MOSQUERA SERRANO
aka Jhovanni San Vicente
aka El Viejo
and
JOSE ENRIQUE MARTINEZ FLORES
aka Chuqui
and others known and unknown to the Grand Jury did conspire to provide “material support or
Case 4:25-cr-00030 Document 25 Filed on 04/08/25 in TXSD Page 3 of 4
resources,” as that term is defined in Title 18, United States Code, Section 2339A(b), namely,
personnel (including themselves) and services, to a foreign terrorist organization namely, Tren de
Aragua (“TdA”), which at all relevant times was designated by the United States Secretary of State
as a foreign terrorist organization pursuant to Section 219 of the Immigration and Nationality Act,
knowing that TdA was a designated foreign terrorist organization, and that TdA engages and has
engaged in terrorist activity, and that TdA engages and has engaged in terrorism.
In violation of Title 18, United States Code, Section 2339B.
COUNT FOUR
(Providing and Attempting to Provide Material Support to a Foreign Terrorist Organization)
From on or about February 20, 2025, and continuing thereafter until the return of this
Indictment, in the Southern District of Texas, and elsewhere including the countries of Colombia
and Venezuela within the extraterritorial jurisdiction of the United States of America, the
defendants
GIOVANNI VICENTE MOSQUERA SERRANO
aka Jhovanni San Vicente
aka El Viejo
and
JOSE ENRIQUE MARTINEZ FLORES
aka Chuqui
provided and attempted to provide “material support or resources,” as that term is defined in Title
18, United States Code, Section 2339A(b), namely, personnel (including themselves) and services,
to a foreign terrorist organization namely, TdA, which at all relevant times was designated by the
United States Secretary of State as a foreign terrorist organization pursuant to Section 219 of the
Immigration and Nationality Act, knowing that TdA was a designated foreign terrorist
organization, and that TdA engages and has engaged in terrorist activity, and that TdA engages
and has engaged in terrorism.
In violation of Title 18, United States Code, Sections 2339B and 2.
Case 4:25-cr-00030 Document 25 Filed on 04/08/25 in TXSD Page 4 of 4
COUNT FIVE
(International Cocaine Distribution)
On or about March 5, 2025, in the countries of Colombia, Venezuela and within the
extraterritorial jurisdiction of the United States of America, the defendants
GIOVANNI VICENTE MOSQUERA SERRANO
aka Jhovanni San Vicente
aka El Viejo
and
JOSE ENRIQUE MARTINEZ FLORES
aka Chuqui
did knowingly and intentionally manufacture and distribute a controlled substance, intending,
knowing, and having reasonable cause to believe that such substance would be unlawfully
imported into the United States of America. The controlled substance involved was more than 5
kilograms, that is, approximately 14 kilograms of a mixture or substance containing a detectable
amount of cocaine, a Schedule II controlled substance.
In violation of Title 21, United States Code, Sections 959(a), 960(a)(3), 960(b)(1)(B), and
Title 18, United States Code, Section 2.
A TRUE BILL
Original Signature on File
FOREPERSON
NICHOLAS J. GANJEI
UNITED STATES ATTORNEY
Anibal J. Alaniz
Assistant United States Attorney
Casey N. MacDonald
Assistant United States Attorney
__________________________________
David C. Smith
Deputy Director
Joint Task Force Vulcan
Department of Justice
