
United States. The co-conspirators then knowingly transferred money between one another in an
effort to conceal the origin of the payments.
4.
CC-1, CC-2, CC-3, CC-4, and CC-5, all persons known to the Grand Jury, were co- conspirators with KILMAR ARMANDO ABREGO GARCIA, all were citizens of El Salvador, and all were not United States citizens. CC-6, also a person known to the Grand Jury, was a citizen of Guatemala and not a United States citizen.
5.
KILMAR ARMANDO ABREGO GARCIA was a citizen of El Salvador, was
not a United States citizen, and was living in the United States. KILMAR ARMANDO ABREGO GARCIA was also a member and associate of the transnational criminal organization, La Mara Salvatrucha, otherwise known and hereinafter referred to as MS-13.
6.
MS-13 was a criminal enterprise engaged in, among other activities, acts and threats involving murder, extortion, narcotics trafficking, firearms trafficking, alien smuggling, and money laundering. MS-13 operated throughout North and Central America, including in El Salvador, Guatemala, Mexico, the United States, including in Texas, Maryland, New York, Tennessee, and elsewhere.
7.
KILMAR ARMANDO ABREGO GARCIA, as detailed further below, used his status in MS-13 to further his criminal activity. Over the course of the conspiracy, the co- conspirators knowingly and unlawfully transported thousands of undocumented aliens who had no authorization to be present in the United States, and many of whom were MS-13 members and associates. The co-conspirators also worked with transnational criminal organizations in Mexico to transport undocumented aliens through Mexico and into the United States.
2
Case 3:25-cr-00115 Document 3 Filed 05/21/25 Page 2 of 10 PageID #: 4
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