UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO UNITED STATES OF AMERICA, SRRICTMENT Plaintiff, CRIMINAL NO. 23333 MAY. v. VIOLATIONS: 18US.C. $1001 [1] BRYAN XAVIER PEREZ HERNANDEZ, 18 U.S.C. § 2251 [2] MELANIE CRUZ CLIVILLES, 21US.C. § 841 ee Defendant. 21 U.S.C. § 846, ip en 21US.C.§859 2023527 png ———— THE GRAND JURY CHARGES: COUNT ONE Exploi Production of CI FIVE COUNTS & FORFEITURE ALLEGATION jon Material, Attempt (Title 18, United States Code, Section 2251) On or about August 3, 2023, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] BRYAN XAVIER PEREZ HERNANDEZ, the defendant herein, did knowingly employ, use, persuade, induce, entice, and coerce a minor, that is, a 13 year-old female G.L.C.C., and attempted to do so, to engage in sexually explicit conduct for the purpose of producing any visual depiction of such conduct, and the visual depiction was produced and transmitted using materials that have been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer. All in violation of Title 18, United States Code, Sections 2251(a) and (e).couNT Two Possession with the Intent to Distribute and Di bution of a Controlled Substance (Title 21, United States Code, Section 841(a)) From in or about July, 2023, through on or about August 4, 2023, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] BRYAN XAVIER PEREZ HERNANDEZ, the defendant herein, did knowingly and intentionally possess with intent to distribute and distribute a mixture or substance containing a detectable amount of cocaine, a Schedule II Controlled Substance, in violation of 21, United States Code, Section 841(a)(1) and ODO). COUNT THREE Conspiracy to Distribute Controlled Substances (Title 21, United States Code, Section 846) From in or about July, 2023, through on or about August 4, 2023, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] BRYAN XAVIER PEREZ HERNANDEZ, the defendant herein did knowingly and intentionally combine, conspire and agree with other persons unknown to the Grand Jury, to commit the following offenses against the United States: to possess with the intent to distribute and distribute a detectable amount of cocaine, a Schedule II Controlled Substance, in violation of Title 21, United States Code, § 841(a)(1), (b\(1Me) and 846.COUNT FOUR Distribution of a Controlled Substance to a Person Under Twenty-One (Title 21, United States Code. Section 859) From in or about July, 2023, through on or about August 4, 2023, in the District of Puerto Rico, and within the jurisdiction of this Court, [1] BRYAN XAVIER PEREZ HERNANDEZ, the defendant herein, who was at least eighteen years of age, knowingly and intentionally distributed a detectable amount of cocaine, a Schedule II Controlled Substance, to G.L.C.C., a person under twenty-one years of age. In violation of Title 21, United States Code, § 841(a)(1), (b)(1)(C) and 859.COUNT FIVE False Statement (Title 18, United States Code. Section 1001) On or about August 4, 2023, in the District of Puerto Rico, and within the jurisdiction of this Court, [2] MELANIE CRUZ CLIVILLES, the defendant herein, did willfully and knowingly make a materially false, fictitious, and fraudulent statement and representation in a matter within the jurisdiction of the executive branch of the Government of the United States. by falsely stating to a Task Force Officer of the United States Department of Homeland Security Investigations that defendant first met [1] BRYAN XAVIER PEREZ HERNANDEZ at the hospital on August 4, 2023, where [1] BRYAN XAVIER PEREZ HERNANDEZ arrived with defendant’s deceased daughter G.L.C.C. The statement and representation was false because, as she then and there knew, [2] MELANIE CRUZ CLIVILLES, had met [1] BRYAN XAVIER PEREZ HERNANDEZ at the latest in July of 2023, and had been with him during a meeting on August 3, 2023. In violation of Title 18, United States Code, Section 1001.FORFEITURE ALLEGATION The allegations of Count One this Indictment are re-alleged as if fully set forth herein, for the purpose of alleging forfeiture pursuant to Title 18, United States Code, Section 2253. If convicted of the offense set forth above, BRYAN XAVIER PEREZ HERNANDEZ, the defendant herein, shall forfeit to the United States, any and all materials or property used or intended to be used in the possession and production of child pornography, including but not limited to: a black Samsung Galaxy A33 5G. All pursuant to Title 18, United States Code, Section 2253. W. STEPHEN MULDROW TRU United States Attorney Foreperson Date:_9] 9/2023 Immigration Unit