Superseding Criminal Information — United States v. Chirag Patel and Antonio Gonzalez, III

Summary

A sealed superseding criminal information, Document 6, filed 04/14/22, Criminal No. M-22-501-S1, in the Southern District of Texas, McAllen Division, against Chirag Patel and Antonio Gonzalez, III. Count One charges Chirag Patel, on or about March 8, 2019, with using a cellular phone as a facility in interstate and foreign commerce with intent to promote an unlawful activity, namely money laundering, in violation of Title 18, United States Code, Section 1952(a)(3). Count Two charges Antonio Gonzalez, III, on or about January 18, 2018, with the unlawful activity named as bribery, under the same Section 1952(a)(3). A notice of forfeiture to Chirag Patel refers to at least $143,567.47, in United States currency. The signature block names Jennifer B. Lowery, United States Attorney.

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Case 7:22-cr-00501 Document6 Filed on 04/14/22 in TXSD Page 1 of 3

United States Distri
Southern District of Ton

| yg, FILED
UNITED STATES DISTRICT COURT cap
SOUTHERN DISTRICT OF TEXAS f R14 2022 .° 7
McALLEN DIVISION 7
Nathan Ochsner, Clerk
UNITED STATES OF AMERICA §
§
V. § Criminal No. M-22-501-S1
§
CHIRAG PATEL §
ANTONIO GONZALEZ, III §

SEALED SUPERSEDING CRIMINAL INFORMATION

THE UNITED STATES ATTORNEY CHARGES:

COUNT ONE

On or about March 8, 2019, in the Southern District of Texas, the Defendant
CHIRAG PATEL

knowingly and willfully did use and cause to be used a facility in interstate and foreign commerce
namely a cellular phone, with the intent to promote, manage, establish, carry on, and facilitate the
promotion, management, establishment, and carrying on of an unlawful activity, namely money
laundering, contrary to Title 18, United States Code, Section 1956 and thereafter performed and
attempted to perform an act to promote, manage, establish and carry on, and to facilitate the
promotion, management, establishment and carrying on of the above unlawful activity.

In violation of Title 18, United States Code, Section 1952(a)(3).

COUNT TWO

On or about January 18, 2018, in the Southern District of Texas, the Defendant
ANTONIO GONZALEZ, IIT
knowingly and willfully did use and cause to be used a facility in interstate and foreign commerce
namely a cellular phone, with the intent to promote, manage, establish, carry on, and facilitate the

promotion, management, establishment, and carrying on of an unlawful activity, namely bribery,
Case 7:22-cr-00501 Document6 Filed on 04/14/22 in TXSD Page 2 of 3

contrary to Title 18, United States Code, Section 666 and Texas Penal Code § 36.02 and thereafter
performed and attempted to perform an act to promote, manage, establish and carry on, and to
facilitate the promotion, management, establishment and carrying on of the above unlawful
activity.

In violation of Title 18, United States Code, Section 1952(a)(3).

NOTICE OF FORFEITURE

Pursuant to Title 28, United States Code, Section 2461(c) and Title 18, United States Code

Section 981(a)(1)(C), the United States gives notice to defendant,
CHIRAG PATEL

that in the event of conviction, the United States intends to seek forfeiture of all property, real or
personal, constituting, or derived from, any proceeds the person obtained directly or indirectly, as
a result of such violation.

The property subject to forfeiture for the offense charged in the Criminal Information
includes, but is not limited to, the following property: at least $143,567.47 in United States
currency. |

Money Judgment

Defendant, Chirag Patel, is notified that upon conviction, a monetary judgment may be imposed
equal to the total value of the property subject to forfeiture.

Substitute Assets

Defendant, Chirag Patel, is notified that in the event that property subject to forfeiture, as a result
of any act or omission of defendant,
(A) cannot be located upon the exercise of due diligence;

(B) has been transferred or sold to, or deposited with, a third party;
Case 7:22-cr-00501 Document6 Filed on 04/14/22 in TXSD Page 3 of 3

(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 that cannot be divided without difficulty,
it is the intent of the United States to seek forfeiture of any other property of the defendant up to
the total: value of such property pursuant to Title 21, United States Code, Section 853(p),
incorporated by reference in Title 28, United States Code, Section 2461(c).

JENNIFER B. LOWERY
UNITED STATES ATTORNEY

ZO SISTANT UNI S ATTORNEY _


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