Case 1:17-cr-00047-SB Document 653 Filed 11/14/22 Page 1 of 14 PageID #: 9630
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
v. )
)
OMAR MORALES COLON, ) Criminal Action Nos. 17-47-SB-1
)
)
Defendant. )
THE UNITED STATES’S RESPONSE TO DEFENDANT OMAR
COLON’S SENTENCING MEMORANDUM
Omar Colon trafficked large amounts of dangerous drugs for decades, interrupted only by
prison stints. Over time, the level of sophistication of his drug trafficking and the methods he used
to hide his money and acquire wealth evolved, but fundamentally a few things have remained
constant. He is a career criminal. He ran a drug enterprise. He used intimidation to keep control
over rivals and would-be cooperators. He obstructed justice, and made a mockery of the court
process, at every stage to keep himself from facing consequences for his life of crime. His sentencing
guidelines recommend a life sentence – indeed, his offense level is so high that it is off the sentencing
guidelines table. Mr. Colon’s criminal behavior and his personal history and characteristics do not
warrant a variance below the recommended guideline range. The government requests that the Court
sentence Mr. Colon to life in prison. While the government recognizes the gravity of such a
recommendation, Mr. Colon’s lifetime of criminal behavior warrants a lifetime in prison. 1
1. Omar Morales Colon Was The Biggest Cocaine Trafficker in Delaware
Over the course of years, Mr. Colon built an empire by importing kilograms of cocaine into
Delaware for sale to drug-addicted residents of our state. While Delaware has seen other large
cocaine seizures over the last several decades, the scale of Mr. Colon’s cocaine trafficking and its
1
As it does in every case, the government is filing a Sealed Attachment A to this sentencing
memorandum.
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long-term nature puts him in a class by himself. The government has reviewed materials for other
significant cocaine traffickers sentenced by this Court, and none of those defendants had a higher
drug weight attributable to him at sentencing.
Mr. Colon used the money he made by selling dangerous substances to purchase numerous
real estate properties, cars, and jet skis. Even when he had built up enough of a real estate portfolio
to perhaps make a living from rent and mortgage payments, he was not content to stop selling drugs.
His greed led him to a parking lot at the Red Roof Inn in May 2017 where he was finally arrested and
the process of bringing him to justice began.
The Court is well acquainted with the facts of this case, having presided over the July 2022
trial. The government will not belabor its review of the nature and circumstances of Mr. Colon’s
crimes. His large-scale drug trafficking lasted for many years. He used a network of fellow drug
dealers to help him move his drugs and enlisted the help of unwitting assistants to turn his drug money
into real estate assets.
Mr. Colon involved his family and friends in his criminal organization – including his
daughter Karina. While she was still a teenager, Karina Colon was depositing large amounts of cash
into her bank accounts and buying cashier’s checks. While she was still in college, she purchased
real estate in her name using laundered funds. Mr. Colon put Karina at risk of being criminally
charged as a co-conspirator in this case by asking her to launder his money.
Many defendants come before the Court for bad decisions they made over the course of a
particular day, or a few days, or up to a few months. Even short-term bad decisions can have
catastrophic consequences, as in the case of Mr. Colon’s proposed comparators, the co-defendant in
the matter of United States v. Bacon, et al, 18-cr-75-JDW, whose violent acts caused the death of an
innocent woman and the grievous injury of a little boy. But there is something uniquely troubling
about a defendant who, over the course of years, regularly engages in criminality day in and day out.
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A defendant who was already jailed once for his crimes, but reoffended quickly and escalated his
conduct. A defendant who achieved enough success and enough skill to step away from a criminal
lifestyle, but who persisted in a life of crime because of a desire for money and power. Such a
defendant provides little hope of rehabilitation, particularly where – as here – the defendant is
remorseless and refuses to accept responsibility.
From the moment of his arrest, Mr. Colon lied, manipulated, and most importantly, displayed
no remorse. He was, of course, within his rights not to speak to law enforcement at all. But he did,
and he chose to lie, pinning the drugs that were seized on that day on someone else and implying that
some sort of urgent problem would occur if agents did not listen to Mr. Colon. He asked cooperators
to perpetuate his false stories that the drugs belonged to someone else and that perhaps the money
was a ransom. Shortly after his arrest, he came in for a proffer and told a different story, admitting
in the process that he had in fact received three prior deliveries of cocaine from California and that
he used drug money to purchase properties.
And then he spent the next several years using every possible method available to him to
prevent the District of Delaware from adjudicating this case: getting assigned attorneys, creating
disagreements with them because he wanted to put on an unethical false defense, 2 and then firing
them and seeking new counsel and continuance after continuance. Cooperators had to sit in pretrial
custody for years, anxiously awaiting their trial testimony. Over the course of years, the government
lost at least four potential testifiers, which was almost certainly Mr. Colon’s grand plan. On July 27,
2
Mr. Colon’s money laundering defense centered on his false claim that he had inherited money
after the murder of his father. He chose not to take the witness stand to make that claim, but rather
endeavored to place the unsupported idea of the inheritance before the jury in his capacity as pro se
advocate. He attempted to put an unauthenticated document into evidence, and to have his brother
testify to parrot Mr. Colon’s hearsay statements about his inheritance. Had he been represented by
counsel, counsel would likely have advised him that the document and Marcelino Colon’s
testimony were inadmissible. By representing himself, Mr. Colon was able to suggest defenses to
the jury for which he had no substantiation without the fear of taking the stand and subjecting
himself to perjury charges.
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2022, his plan failed, and he was finally convicted of the final counts of the Second Superseding
Indictment.
2. Omar Colon is Not a Non-Violent Drug Offender
Mr. Colon endeavors to portray himself as a non-violent person who is worthy of mercy. But
the drug business is a dangerous one. Drug dealers like Mr. Colon associate themselves with other
criminals. Their business is a cash one where robberies and double-crossing are commonplace.
Drug dealers are commonly violent or at least threaten violence to intimidate people in an effort to
avoid being robbed and prevent their associates from cooperating with police. And Mr. Colon is no
exception. While he has no prior convictions for violent crimes, and the government did not allege
any specific acts of violence in connection with the crimes charged in the Second Superseding
Indictment, to frame Mr. Colon as a non-violent drug and money laundering defendant ignores
important evidence gathered by law enforcement.
First, Mr. Colon’s conversations on the wiretap reveal that, like many drug dealers, he held a
particular animosity towards cooperators and was prepared to use violence if necessary to prevent
people from betraying him. Mr. Colon threatened Josue Torres, his drug customer, because he
believed Mr. Torres was cooperating against him. As the trial testimony revealed, in early January
2017, Mr. Torres was arrested by the DEA for heroin charges. He denied any drug relationship with
Mr. Colon, despite having had wiretapped calls in which he told people that “Omar” was going to be
delivering something to him. Mr. Torres was released a few hours after his arrest. One of the first
things he did after his release was to urgently request a meeting with Mr. Colon – a meeting that
occurred on Marshall Street in Wilmington at one of Mr. Colon’s properties. Mr. Torres’s arrest and
decision to talk to the police was the subject of a lot of discussion by Mr. Colon. On March 24, 2017,
on a call with Ms. Martinez, Mr. Colon threatened to come after Mr. Torres’s family should Mr.
Torres agree to testify:
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COLON: [U/I] We were gossiping about some stuff there.
MARTINEZ: Uh-hum, uh-hum.
COLON: We are gathering information, information, information.
MARTINEZ: Of course, as it should be.
COLON: I have to be ready in case that fucker says that I used to
work with him or something like that... I already have all of
the information from where, and everything... and how and
everything.
MARTINEZ: With all of the details.
COLON: For sure, so when we confront him, he will run away.
MARTINEZ: So it will bite him in the ass.
...
COLON: He will have to prove it. But if that guy is going to send me
to jail with lies, if he points his finger at me in me in court,
I will go after his children, I will go after all of his family,
everyone. It is fucked up if you put an innocent man in
jail who has nothing to do with you, that’s fucked up, you
know what I mean?
MARTINEZ: Definitely...
...
See Exhibit A, Transcript for call 2814. Mr. Colon’s statements on the phone with Ms. Martinez
were not harmless, nor were they isolated. The urgency with which Mr. Torres sought a meeting
with Mr. Colon implies that Mr. Torres himself was concerned that Mr. Colon would be suspicious
of his arrest and release. Mr. Colon is an intimidating figure. The government experienced that
first-hand, as potential cooperators ultimately declined to testify at trial out of a fear of Mr. Colon.
Second, the government uncovered evidence that a violent crime happened at one of Mr.
Colon’s properties. A murder or significant shooting injury occurred at a property on Dorothy Drive
in Bear, Delaware that Mr. Colon used for drug meetings. That property was rented by Zemi
Construction. Trial Tr. July 19, 2022, pp. 225:20-227:6. When the lease ended in February 2017,
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the landlord sent Mr. Colon a letter saying that she was withholding the security deposit due to bullet
holes in the walls and a large amount of blood on the floor. See Exhibit B, letter from landlord.
There is no evidence of who committed that apparently violent crime. But the evidence at trial
showed that Mr. Colon was the tenant of that home, and that Mr. Colon used a number of his
properties for his drug business. For example, 614 Rogers Avenue in Aston, which was occupied by
a tenant, was clearly tied to the drug conspiracy given the presence of oxygen tanks and packaging
materials identical to those used by Mr. Colon’s California suppliers, hundreds of thousands of
dollars, and guns.
Third, Mr. Colon admitted to using violence in his post-arrest statement when he said that he
“put [someone] in a coma” for bringing police attention onto Mr. Colon. At that point in the
statement, the agents were challenging Mr. Colon’s assertion that he only sold marijuana. Mr. Colon
responded as follows:
All these things that you have heard about me selling coke -- I ain't selling no coke.
The day they broke into that shop and they found those 600 grams in there, I let a
guy use that shop. And I put that dude in a coma, because he put that there. He put
me in there. And I was trying to call him, because they want to arrest me. That
shit wasn't even mine…
See Sealed Exhibit C, Transcript of Mr. Colon’s Post-arrest Statement, at p. 7. While the
government has no independent way of verifying that Mr. Colon attacked someone for possessing
cocaine in one of his “shops,” the story lines up with an arrest that occurred in 2012. On November
2, 2012, one of Colon’s trial witnesses, Moises Morales, was arrested. See Exhibit D, redacted report
of seizure. A search warrant was executed that day at a garage located at 5 Carpenter Street in
Wilmington – a property owned by Zemi 3, and tied to Colon and Morales during a Wilmington Police
Department (“WPD”) investigation. During a search of the garage, WPD found over a half-kilogram
of cocaine, a Ty-vek suit, kilogram presses, and digital scales. See Exh. D at p. 3.
3
Trial Tr. July 20, 2022, at p. 91:15-18, referencing government Exhibit 604 at p. 51.
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Mr. Colon’s words matter in these contexts. He either actually uses violence to retaliate
against people who cross him, or he tells people that he is violent in order to intimidate them. Either
way, the above instances cast doubt on any argument that Mr. Colon was a nonviolent drug dealer.
And it supports the imposition of a guideline sentence of life.
3. A Life Sentence is Consistent with Sentences for Other Defendants in this District
The government is unaware of a defendant in the District of Delaware whose drug weight was
higher than Mr. Colon’s. A few defendants who were kilogram-level cocaine dealers have received
lengthy sentences worth discussing, but none had guidelines of life.
Bruce Stewart was sentenced to life in prison in 2005. See Docket Number 02-cr-00062
(MN). The Court found that he was responsible for 48 kilograms of cocaine; he was not charged
with money laundering. His guideline range was 360-life. His sentence was recently reaffirmed by
Judge Maryellen Noreika, who denied a compassionate release motion, noting that his history of
violence supported the life sentence imposed.
In a money laundering and drug case, Eric Blackmon was sentenced to 235 months
incarceration. See Docket Number 06-cr-109 (LPS). His guidelines range was 188-235 months,
which was based on a drug weight calculation of between 50-150 kilograms.
Brian Wilson was sentenced to 252 months incarceration, which was a variance below the
guideline range of 292-365 months. See Docket Number 16-cr-0093 (MN). But Mr. Wilson was
sentenced for his role in distributing five kilograms in cocaine, and he was not charged with any
money laundering offenses. Mr. Colon is responsible for about thirty times more cocaine.
Andre Huggins was sentenced to 20 years in prison for cocaine offenses and money
laundering. See Docket Number 03-cr-0091 (SLR). That 20-year sentence was the mandatory
minimum attributable to him. His guideline range was 188-235 months. The government argued
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that he was responsible for 16 kilograms of cocaine. His sentence was commuted by President
Obama.
Given that Mr. Colon’s drug and money laundering conspiracies were more extensive than
any of the other defendants listed above, a life sentence would be consistent with prior sentences
given by judges in the District of Delaware.
4. Mr. Colon’s Objections to the Presentence Report are Unavailing but
Inconsequential
Mr. Colon takes issue with the drug weight included in his base offense level calculation, and
with the application of a few enhancements. The trial evidence supports an even higher drug weight
than that included in the Presentence Report of Investigation (“PSR”), and the evidence also supports
the application of the enhancements. Even if some of Mr. Colon’s arguments had merit, he would
still be subject to guidelines of life.
a. The Appropriate Drug Weight Attributable to Mr. Colon is Actually Higher than
Calculated
Mr. Colon objected to the drug calculation for the drug and money laundering offenses in the
PSR, arguing that the 77 kilograms of cocaine used in the calculation of converted drug weight was
inconsistent with witness testimony at trial. PSR at ¶ 49. When it comes to the cocaine conspiracy,
77 kilograms is the correct metric – that is the weight that testifying witness Roque Valdez said Mr.
Colon received from December 2016-May 2017. The calculation in Paragraph 49, which adds 77
kilograms of cocaine to the marijuana seized, is the appropriate calculation for Count One.
But the offense level for the Count One drug conspiracy does not drive the ultimate sentencing
guideline range. That is because Mr. Colon’s Count Five money laundering offense level is higher
than the Count One drug conspiracy offense level, and the offenses group. His money laundering
offense level is calculated based on a cross-reference to the underlying offense – that is, a conspiracy
to distribute and manufacture cocaine and marijuana from 2009-2017. PSR at ¶ 61. The drug
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conspiracy underlying the Count Five money laundering conspiracy is significantly broader in time
than the cocaine conspiracy in Count One.
As for the calculation of the base offense level for the money laundering cross-reference, Mr.
Colon is correct that that the converted drug weight included in the PSR is inconsistent with the trial
testimony – the witnesses actually testified to substantially more than 77 kilograms of cocaine. The
calculation in the PSR ignores the testimony of Ivan Prieto. Mr. Prieto testified at the July 2022 trial
that he brought Mr. Colon a total of between 80 and 100 kilograms of cocaine between 2009-10 and
2011-12. (Trial Tr. July 8, 2022 at pp. 13, 38, 42), and that on one occasion he sold Colon two
pounds of methamphetamine (Trial Tr. July 8, 2022 at p. 37). And as much as Mr. Colon would like
the Court to disbelieve Mr. Prieto, his testimony is corroborated by the fact that during that time
frame, large amounts of otherwise unexplained cash were flowing through bank accounts belonging
to Mr. Colon, his company, or his family members.
Those drug amounts should increase the offense level calculation to 48 in Paragraph 61 for
purposes of the money laundering cross-reference. §2S1.1(a)(1). 4 Because that offense level is
well above the maximum of 43, the additional drug weight does not change the guidelines analysis.
Nevertheless, the Court should overrule Mr. Colon’s objection.
b. Omar Colon Maintained Numerous Premises for Drug Purposes
The maintaining a premises guideline should clearly apply. PSR at ¶¶ 50-52. Mr. Colon
used properties that he owned and storage units that he rented to manufacture, distribute, and store
controlled substances. The Application Notes to Subsection (b)(12) of §2D.1.1 instruct that the
4
Adding in (conservatively) 80 kilograms of cocaine (CDW 16,000 kilograms) and the two pounds
of methamphetamine (CDW 1,792 kilograms), the converted drug weight becomes 33,192 CDW
kilograms, which represents an offense level 36. Together with the enhancements in §2B1.1(b)(12)
and §2B1.1(b)(16), the offense level becomes 40 for the drug conspiracy; that is, the “offense level
for the underlying offense from which the laundered funds were derived.” Adding on the various
enhancements that apply in Paragraphs 61-71, the total offense level should be 48.
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enhancement applies to a defendant who knowingly maintains a premises (such as a building, room
or enclosure) to manufacture, distribute or store a controlled substance. The drug purpose need not
be the primary purpose for which those properties were owned or rented – as the Application Note
says, it must be “one of the defendant’s primary or principal uses for this premises.”
Mr. Colon maintained a premises on Marshall Street in Wilmington to provide his suppliers
with a “safe garage” in which they could remove Mr. Colon’s kilograms of cocaine from oxygen
tanks and weld the cash Mr. Colon provided them inside the tanks. Mr. Colon’s offer of a “safe
garage” was memorialized in text messages he sent to his California supplier Mohamed Aviles-
Camberos before one of the trips. See Exh. 117c at p. 4, line 146, attached hereto as Exhibit E,
admitted in Trial Tr. July 19, 2022 at 400:9-10.
Mr. Colon also used other properties he owned or rented to conduct drug transactions (for
example, a drug meeting with Prieto took place at one of Colon’s properties on Linkwood Avenue).
Mr. Colon’s property at Rogers Avenue was clearly also used in the conspiracy, as agents found a
significant amount of money hidden in a vehicle in that residence’s garage. PSR at ¶ 41. The house
was being used to store oxygen tanks that were identical to the ones used in the cocaine conspiracy.
Id. Mr. Colon also controlled storage units – rented in family members’ names – in which he stored
bulk marijuana, cash and a kilogram press used for processing cocaine. PSR at ¶ 39.
But most obviously, he was using his marital home to manufacture and store marijuana. PSR
at ¶ 40. Mr. Colon will likely point to the fact that he was acquitted of the “manufacturing marijuana
plants” count and will ask that the Court ignore the clear evidence that he had a marijuana grow
operation beneath his home. The jury’s acquittal on the very specific allegation that the defendant
manufactured one or more marijuana plants – an allegation that the defendant argued the government
could not prove because the pots in the bunker admittedly did not include plant material – is not
dispositive here. “[A] jury’s verdict of acquittal does not prevent the sentencing court from
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considering conduct underlying the acquitted charge so long as that conduct has been proved by a
preponderance of the evidence.” United States v. Watts, 519 U.S. 148, 157 (1997). Here, the
presence of sophisticated grow equipment, including lights, a ventilation system, irrigation, and
numerous pots, coupled with the harvested marijuana found in the home and in a storage unit, should
be sufficient for the Court to find by a preponderance that the defendant manufactured and stored
marijuana in his home. The enhancement should apply.
c. Mr. Colon was a Leader in his Drug and Money Laundering Conspiracies
Mr. Colon was an organizer or leader both as to the drug counts and the money laundering
counts. Because the money laundering counts drive the guideline range, the Court should make a
specific finding at sentencing that the leadership enhancement should apply as to the money counts.
However, by a preponderance of the evidence, the enhancement should apply for the drug counts as
well.
Mr. Colon is subject to a four-level enhancement pursuant to §3B1.1 if he was an organizer
or leader of a criminal activity that involved five or more participants or was otherwise extensive.
Mr. Colon’s Count I cocaine conspiracy clearly involved (at a minimum) five or more participants,
including but not limited to Mr. Colon, Ms. Martinez, Mr. Valdez, Mr. Aviles-Camberos, and Mr.
Colon’s customers Josue Torres, William Briscoe, and Devin Hackett.
Mr. Colon was a leader of the Count I cocaine conspiracy. He decided where Mr. Aviles-
Camberos and Mr. Valdez would go to unload the drugs, he set prices for his customers, he collected
money from them, and on at least one occasion he sent Ms. Martinez to pick up money from his
customers. He also enlisted the help of others to aid in hiding his drug money, which is part and
parcel of a drug conspiracy.
The Count V money laundering conspiracy also involved five or more participants, including
but not limited to the above listed drug conspirators (who were involved in the commission of the
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underlying specified unlawful activity and are therefore participants in the money laundering), as well
as Mr. Colon’s daughter Karina Colon, and the many people who purchased cashier’s checks for
Zemi, including Winston Rodriguez, Arlene Jorge, Aixa Figueroa, Janitza Figueroa, Joel Cardona,
Jimmy Lebron, Miledys Ramirez, Angelica Vidro, Santos Morales, Elijah Barnett, Maribel Quiles,
Marisol Cuevas, and Lesley Donato. 5 And Mr. Colon was clearly the leader of that conspiracy: he
set up the corporate structures that were critical to the conspiracy’s success, recruited the people who
bought cashier’s checks, and funded the purchase of properties with drug money.
Because the money laundering conspiracy offense level is ultimately higher than the drug
conspiracy offense, it drives the applicable guideline range. The Court should find that Mr. Colon
was a leader specifically as to the money laundering conspiracy.
d. Omar Colon Obstructed Justice
After Mr. Colon, Mr. Valdez, and Mr. Aviles-Camberos were arrested, all three gave proffer
interviews. Mr. Aviles-Camberos informed law enforcement that while all three defendants were
placed in the same pod in the Federal Detention Center, Mr. Colon had instructed Mr. Aviles-
Camberos to tell law enforcement that the kilograms seized on May 6, 2017 were intended for
someone who is referred to herein as Person 1. Mr. Colon also told Mr. Aviles-Camberos to say that
the previous trips to Delaware involved transportation of marijuana. Mr. Colon also implicated
Person 1 in his statements to law enforcement. Mr. Valdez also recalled a conversation inside the
Federal Detention Center after the group was arrested in which Mr. Colon and Mr. Aviles-Camberos
were trying to come up with a story to tell law enforcement. Given that Mr. Aviles-Camberos
5
The Application Note to §3B1.1 says that someone who is not criminally responsible for an offense
is not a “participant.” It is likely the case that some or most of the people who bought cashier’s
checks were unaware that they were helping Mr. Colon and Ms. Martinez launder money. However,
the Application Note also says that the involvement of unwitting people in an offense can lead a court
to conclude that the offense was “otherwise extensive,” and therefore a leader of such an offense is
subject to the same four-level enhancement.
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immediately told law enforcement that he had been asked to tell a false story, whereas Mr. Colon
stuck with that story, the evidence supports that it was in fact Mr. Colon’s idea to tell the false story
about Person 1.
Mr. Colon does not appear to dispute that he had the DEA’s pole camera removed from the
end of his driveway and either destroyed or disposed of it. That behavior also constitutes obstruction
of justice. The wiretap calls from the time period suggest Mr. Colon was well aware that the DEA
was investigating him. He removed the camera to obstruct the DEA’s investigation.
5. A Life Sentence is Consistent with All of the Goals of Sentencing
The Court is charged pursuant to Section 3553(a) with the lofty goal of meting out justice for
a particular defendant while also serving the important societal interests of deterring potential
criminal actors and protecting the public. The government does not take lightly its recommendation
that Mr. Colon be sentenced to life in prison. His conviction for an over seven-year criminal
conspiracy to launder the proceeds from the sale of over 150 kilograms of cocaine warrants a sentence
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of decades. But it is the other factors – his lack of remorse, the indicia of violence, his use of innocent
people and family members in his criminal actions, and the fact that his prior period of incarceration
left him undeterred, that show that Mr. Colon has no intention of turning his life around. He will be
a danger to the public for as long as he lives. Mr. Colon should be sentenced to life in prison.
Respectfully submitted,
DAVID C. WEISS
United States Attorney
/s/ Jennifer K. Welsh ________
Jennifer K. Welsh
Meredith Ruggles
Assistant United States Attorneys
Dated: November 14, 2022
