Indictment — U.S. v. Ricardo Robles, No. 3:21-cr-01549 (W.D. Tex.)
Summary
An Indictment against Ricardo Robles in the U.S. District Court for the Western District of Texas, El Paso Division, Case 3:21-cr-01549, Document 3, filed 09/15/21. Count One charges conspiracy to commit wire fraud (18 U.S.C. § 1343 and 1349) from on or about July 22, 2010 to on or about March 20, 2018. It alleges that Robles, employed by an El Paso, Texas business called the "Company", used sham companies to inflate the cost of goods bought by the Company and diverted a portion of the payments to a corporation called the "Pass-Through". Counts Two through Twenty-One charge wire fraud (18 U.S.C. § 1343), listing receiving bank, sham company, date and amount for each transfer. A Notice of Government's Demand for Forfeiture seeks a money judgment and substitute assets.
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“Indictment — U.S. v. Ricardo Robles, No. 3:21-cr-01549 (W.D. Tex.).”
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Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 1 of 6
JUDGE DAVID BRtOHES
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
F LE D I
EL PASO DIVISION Qrr
I ) ZO21
CLERJ UsSTRICT COURT
WESTERN D7RICT
UNITED STATES OF AMERICA, OF TEXfiS
CRIMINAL NO.
Plaintiff,
S V A 1 V.11
V.
INDICTMENT
RICARDO ROBLES, CT 1: 18 USC § 1343 & 1349,
Conspiracy to Commit Wire Fraud
Defendant.
CTS 2-21: 18 USC § 1343, Wire Fraud
Notice of Government's Demandfor
Forftiture
COUNTONEEP 21 CR1549
(18 U.S.C. § 1343 & 1349)
(Conspiracy to Commit Wire Fraud)
INTRODUCTION
At all times relevant to this Indictment:
1. Defendant, RICARDO ROBLES, was employed by an El Paso, Texas business,
hereinafter, the "Company" between 2005 and March 20, 2018.
2. As part of his employment with the Company, defendant, RICARDO ROBLES, was
responsible for arranging purchases of goods from various suppliers that the Company
would then resell for a profit. RICARDO ROBLES negotiated prices with the suppliers
and was often the sole contact between the Company and its suppliers.
3. "Bank A" is a financial institution located in Omaha, Nebraska. "Bank B" is a financial
institution located in El Paso, Texas. "Bank C" is a financial institution located in El Paso,
Texas. "Bank D" is a financial institution located in El Paso, Texas.
THE CONSPIRACY
Beginning on or about July 22, 2010 and continuing to and including on or about March 20,
2018, in the Western District of Texas and elsewhere, the defendant,
Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 2 of 6
RICARDO ROBLES
combined, conspired, confederated and agreed with others known and unknown to the Grand Jury
to commit an offense, that is to knowingly devise and attempt to devise a scheme and artifice to
defraud and to obtain money and property by means of material false and fraudulent pretenses,
representations and promises, both by affirmative acts and by deceitful concealment of material
facts, and the defendant and uncharged co-conspirators did transmit and caused to be transmitted
by means of wire communication in interstate commerce certain writings, signals and sounds,
including wire transfers of funds from accounts owned and controlled by the Company held at
Bank A to accounts owned and controlled by sham companies held at Banks B, C and D.
Scheme and Artifice to Defraud
In furtherance of the conspiracy to defraud and to further the objectives of the conspiracy, it was
part of the scheme and artifice to defraud that:
1. Defendant, RICARDO ROBLES, on or about July 22,2010, by himself or through a third
party, registered a corporation, hereinafter the "Pass-Through", that he used to further his
unlawful scheme.
2. Defendant, RICARJJO ROBLES, with the assistance of his co-conspirators, created
numerous sham companies which he used to inflate the cost of goods to the Company.
3. Defendant, RICARDO ROBLES, with the assistance of his co-conspirators, arranged for
the sham companies to purchase goods from suppliers and then, through his employment
with the Company, arranged for the Company to purchase those same goods at an inflated
price.
4. Defendant, RICARDO ROBLES, then arranged for payment to be made by the Company
to the sham companies, after which he would then divert a portion of those payments to
the Pass-Through for his own personal use. These payments were made from accounts
owned and controlled by the Company located at Bank A to accounts owned and controlled
by the sham companies at Banks B, C and D;
5. Defendant, RICARDO ROBLES, concealed from the Company his involvement in
arranging for the purchase of the goods by the sham companies and concealed from the
Company his personal and business relationships with the purported owners of the sham
companies.
Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 3 of 6
All in violation of Title 18, United States Code, Sections 1343 and 1349.
COUNTS TWO THROUGH TWENTY-ONE
(18 U.S.C. § 1343)
(Wire Fraud)
The Introduction and the Scheme and Artifice to Defraud alleged in Count One of this
Indictment are incorporated by reference in their entirety as if fully re-alleged herein.
Beginning on or before September 16, 2016 and continuing to and including on or about
March 13, 2018, that is, on or about the dates alleged below, in the Western District of Texas, and
elsewhere, defendant,
RICARDO ROBLES,
did devise and attempt to devise a scheme and artifice to defraud and to obtain money and property
from his employer, the Company, by means of material false and fraudulent pretenses,
representations and promises, both by affirmative acts and by deceitful concealment of material
facts, and for the purpose of executing the scheme described above, and attempting to do so, the
defendant caused to be transmitted by means of wire communication in interstate commerce
certain writings, signals and sounds described below for each count, each transmission constituting
a separate count:
COUNT RECEIVING BANK SHAM COMPANY DATE AMOUNT
NUMBER ACCT. RECEIVING
(CT. ) TRANSFER
CT.# 2 Bank C Sham Company 1 September $15,163.00
16, 2016
CT.# 3 Bank C Sham Company 1 September $13,409.60
23, 2016
CT.# 4 Bank C Sham Company 1 September $12,367.60
30, 2016
Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 4 of 6
CT.# 5 Bank D Sham Company 2 October $11,433.50
14, 2016
CT.# 6 Bank C Sham Company 1 October $29,650.50
21, 2016
CT.# 7 Bank D Sham Company 2 October $11,452.75
21, 2016
CT.# 8 Bank D Sham Company 2 October $11,424.50
28, 2016
CT.# 9 Bank D Sham Company 2 November $11,418.75
4,2016
CT.# 10 Bank C Sham Company 1 December $12,245.00
16, 2016
CT.# 11 Bank C Sham Company 3 August 4, $22,385.60
2017
CT.# 12 BankC Sham Company 3 September $23,351.80
14, 2017
CT.# 13 Bank C Sham Company 3 November $35,999.47
16, 2017
CT.# 14 Bank C Sham Company 3 November $20,922.20
30, 2017
CT.# 15 Bank B Sham Company 4 December $64,495.45
21, 2017
CT.# 16 Bank B Sham Company 4 February $45,767.10
1, 2018
CT.# 17 Bank B Sham Company 4 February $53,950.72
8, 2018
CT.# 18 Bank C Sham Company 3 February $21,603.18
15, 2018
CT.# 19 Bank B Sham Company 4 March 1, $48,195.37
2018
CT.# 20 Bank B Sham Company 4 March 8, $49,465.81
2018
CT..# 21 Bank D Sham Company 2 March 13, $14,297.60
2018
All in violation of Title 18 United States Code, Section 1343.
Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 5 of 6
NOTICE OF GOVERNMENT'S DEMAND FOR FORFEITURE
jSee Fed. R. Crim. P. 32.2]
I.
Wire Fraud & Conspiracy to Commit Wire Fraud Violations and Forfeiture Statutes
[Title 18 U.S.C. § 1343, 1349, subject to forfeiture pursuant to Title 18 U.S.C.
§ 981(a)(1)(C), as made applicable to criminal forfeiture by Title 28 U.S.C. 2461(c)]
As a result of the criminal violations set forth in Counts One through Twenty-One, the
United States of America gives notice to Defendant RICARDO ROBLES of its intent to seek the
forfeiture of certain properties upon conviction and pursuant to FED. R. CRIM. P. 32.2 and Title 18
U.S.C. § 981(a)(l)(C), as made applicable to criminal forfeiture by Title 28 U.S.C.
§ 2461(c).
Title 18 U.S.C. § 98l(a)(l)(C) states in pertinent part:
Title 18 U.S.C. § 981. Civil Forfeiture
(a)( 1) The following property is subject to forfeiture to the United States:
(C) Any property, real or personal, which constitutes or is derived from proceeds
traceable to a violation. . . of this title or any offense constituting "specified unlawful
activity" (as defined in section 1956(c)(7) of this title), or a conspiracy to commit
such offense.
Wire Fraud is an offense constituting "specified unlawful activity" as defined in section
1 956(c)(7).
This Notice of Demand of Forfeiture includes but is not limited to the property described
in Paragraph III.
III.
Money Judgment
A sum of money that represents the proceeds which constitute or are derived from
proceeds traceable to the violations set forth in the Indictment for which Defendant RICARDO
ROBLES is liable.
Substitute Assets
If any of the above properties, as a result of any act or omission of the Defendant:
a. cannot be located upon the exercise of due diligence;
Case 3:21-cr-01549-DB Document 3 Filed 09/15/21 Page 6 of 6
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be subdivided without
difficulty;
it is the intent of the United States to seek forfeiture, pursuant to Title 21 U.S.C. § 853(p) and Fed.
R. Crim. P. 32.2, of any other property (substitute assets) of the Defendant up to the value of the
forfeitable properties.
A TRUE BILL
ORIGINAL SIGNATURE
REDACTED PURSUANT TO
E-GOVERNMENT ACT OF 2002
FOREPERSON OF THE GRAND JURY
ASHLEY C. HOFF
UNITED STATES ATTORNEY
By:
Ass stant United States Attorney
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