The following is adapted from a draft indictment of George Bush prepared by former DEA agent Celerino Castillo and the editors of Executive Intelligence Review.  All the evidence contained in this draft indictment has been thoroughly documented.  Most of it has been taken either from the Kerry Report of the Senate Foreign Relations Committee, or the Final Report on Iran-Contra.




Racketeering 18 USC § 1961et seq.
Conspiracy to Import Narcotics 21 USC §§ 952 & 963
Continuing Criminal Enterprise 21 USC § 848
Conspiracy To Obstruct Justice 18 USC § 1503
Conspiracy To Obstruct Congress 18 USC § 1505


1.  At all times relevant to this Indictment, there existed an Enterprise, within the meaning of Title 18, USC, Section 1961 (4), that is, a group of individuals associated in fact which utilized the official positions of defendant GEORGE HERBERT WALKER BUSH in the Government of the United States of American to facilitate the transfer, importation, and distribution of large quantities of illegal narcotics within the United States.

2.  The members of the Enterprise consisted of the defendant herein named and others, including international drug traffickers, who utilized the Enterprise and the official positions of GEORGE HERBERT WALKER BUSH, DONALD P. GREGG, and OLIVER L. NORTH to facilitate their narcotics and money-laundering operations.


1.  From January 1981 to January 1989, George Bush was Vice President of the United States, and from January 1989 to January 1993, Bush was President of the United States.

2. Beginning in 1981 and up until 1989, while he was Vice President of the United States, Bush assumed extraordinary power over U.S. intelligence and covert operations.  This was done through a series of Executives Orders and National Security Decision Directives (NSDDs) signed by President Ronald Reagan.

3.  On Dec. 14, 1981, President Reagan signed NSDD-3 on “Crisis Management,” which designated the Vice President chairman of the Special Situation Group (SSG), responsible for crisis management.

4.  On January 12, 1982, President Reagan signed NSDD-2, which reaffirmed the existence of various interagency groups to deal with intelligence and covert operations.  Under the interpretation of this document promoted by Bush, the SSG superseded and pre-empted the powers of the National Security Council in areas of “crisis management,” which encompassed covert operations and counter-terrorism.

5.  On Jan. 28, 1982, Bush was put in charge of the South Florida Task Force on drugs.

6.  On May 14, 1982, a standing Crisis Pre-Planning Group (CPPG 1 and 2) was established under the SSG.  The SSG-CPPG, under Bush, was given responsibility for any area in which a “potential crisis” could emerge, and was charged with developing “preemptive policy options” for dealing with such a potential crisis.

7.  On April 10, 1982, NSDD-30, on “Managing Terrorist Incidents,” was issued, giving the Vice President control over the convening of the SSG, and creating the “Terrorist Incident Working Group” (TIWG) to support the SSG.

8.  On March 23, 1983, Bush took charge of the National Narcotics Border Interdiction System (NNBIS).

9.  In July 1985, the Vice President’s Terrorism Task Force was created, headed by Bush.

10.  In Feb. 1986, the Terrorism Task Force issued its report, creating the Operations Sub-Group, officially a sub-group of the TIWG, and also creating a permanent counter-terrorism office located in the NSC staff, headed by Oliver North, but ultimately controlled and directed by Bush.

11.  In August 1986, Bush became the chief of “Operation Alliance,” an anti-narcotics effort to be conducted in cooperation with Mexico.

Thus from Dec. 1981 to August 1986, Bush had consolidated his control over virtually aspect of U.S. covert operations, as well as every agency dealing with drug interdiction.  Never before in peacetime in our country’s history had one man assumed as much power as Bush exercised while Vice President.


1.  In 1982, the first in a series of "Boland Amendments" was passed by the U.S. Congress sharply curtailing the available funding from the U.S. government to the Nicaraguan Contras (hereafter "The Contras").  To make up for this loss of funding, defendant BUSH entered into an agreement with the Columbian drug cartels to exhange guns for drugs.  The proceeds of the drug sales in turn were used to secretly fund the Contras.  In order to accomplish this, the Enterprise, through its vast connections, made arrangements to make the cocaine it received for guns affordable and readily available to the ghettos across America.  This would come in the form of "rock," which is more commonly known as crack cocaine.


1.  In the summer of 1981, Norwin Meneses and Oscar Blandon traveled to Honduras to meet with contra leader Enrique Bermudez, and Bermudez instructed Meneses and Blandon to establish a funding mechanism for the Contras on the West Coast of the United States.

2.  During 1981, Meneses and Blandon imported and sold over 2000 pounds of cocaine in California.

3.  During 1983, Blandon, Meneses, and others began to sell and distribute crack cocaine in Los Angeles, derived from cocaine imported from Colombia via El Salvador and Costa Rica.  Much of this cocaine was flown into the U.S. by Marcos Aquado, operating from Ilopango air base in El Salvador.

4.  On or about March 6, 1984, George Morales was indicted for drug smuggling.  A few weeks after that, Morales met with certain Contra leaders in south Florida, Popo Chomorro and Octaviano Ceasar, whom he identified as CIA agents.  They told Morales they would help him with his legal problems if he helped them with weapons and explosives and other items.  The Contra leaders agreed to supply Morales with drugs, which he would sell then purchase supplies for the Contras.

5.  In March 1984, Barry Seal, who had been rejected as an informant by local agencies, traveled to Washington to the offices of the Vice President’s Task Force on Drugs.  The Task Force directed the DEA to retain Seal as an informant and to allow him to keep his property and assets, and to allow him to continue to smuggle drugs from Central America into Louisiana and Arkansas, among other places.

6.  During the summer of 1984, Barry Seal met representatives of the Colombian drug cartel in Miami, and traveled with them to Mena, Arkansas, to show them the facilities used by Seal for smuggling narcotics and maintaining and disguising his aircraft.

7.  On May 12, 1984, Oliver North wrote in his note book:
 “...contract indicates Gustavo is involved w/drugs.”

8.  In June 1984, Meneses attended a fund-raising meeting with Calero in San Francisco.

9.  In the summer of 1984, North asked Richard Secord to assist Calero in purchasing arms for the Contras.

10.  In the summer of 1984, North spoke with his courier, Robert Owen, and asked him to meet regularly with Calero to discuss the Contra’s needs, to deliver intelligence to the Contras, and to supply them with money.

11.  On June 26, 1984, North wrote in his notebook:
“Call from Owen—John Hull—protection ...
John now has ‘private army of 75-100’—  Cubans involved in drug—up to 100 more Cubans expected.”

12.  In or around July of 1984, Morales purchased weapons in Florida and loaded them on an airplane in Florida.  The plane returned within a few days with a load of narcotics, which Morales sold and gave the money to the Contras.

13.  In or around July of 1984, for the second time, Morales purchased weapons in Florida and loaded them on an airplane in Florida.  The plane returned within a few days with a load of narcotics, with Morales sold and gave the money to the Contras.

14.  During or around June or July of 1984, Morales placed a telephone call to Gary Betzner and asked him to come to Florida.  Morales and Betzner then met in Florida to discuss flying weapons to the Contras and flying drugs back.

15.  In or around July 1984, Betzner flew a planeload of weapons, including an M-60 machine gun, M-16 rifles, and C-4 plastic explosives from Ft. Lauderdale, Florida, to the ranch of John Hull in Costa Rica.  At the Hull ranch, the weapons and explosives were unloaded, and then 17 duffel bags of cocaine and 5 or 6 boxes of cocaine were loaded on the plane in the presence of Hull, which Betzner brought back to Lakeland, Florida.

16.  About ten days later, Betzner flew a planeload of small arms from Morales’s hanger at Opa-Locka Airport in Florida to Los Llanos, adjacent to the Hull ranch, in Costa Rica.  The arms were offloaded in the presence of Hull and then 15 to 17 dufflebags of cocaine, about 500 kilograms, were loaded on the plane for Betzner to take back to Florida.

17.  On July 20, 1984, North wrote in his notebook:
“Call from Clarridge:—Alfredo Cesar Re Drugs-Borge/
Owen leave Hull alone [deletions] Los Brasiles Air
Field—Owen off Hull.”

18.  In or around July 1984, through January 1986, at the suggestion of Marcos Aguado, Morales trained pilots at Opa-Locka Airport in Florida to fly weapons to the Contras in Central America and to transport drugs back into the United States.

19.  Between July 1984 and January 1986, on at least eight occasions, Morales directed pilots to fly to the Hull ranch in Costa Rica to deliver weapons to the Contras, and to bring drugs back into the United States.

20.  On July 23, 1984, North wrote in his notebook:
“Call from Rob Owen—call from John Hull.”

21.  From late 1984 up through late 1986, John Hull received a payment of $10,000 per month from Adolfo Calero, at the direction of Oliver North.

22.  In or around November 1984, Morales purchased more weapons in south Miami and loaded them on an airplane at Ft. Lauderdale, Fl.  The plane returned within a few days with a load of narcotics, which Morales sold and gave the money to the Contras.

23.  On or about October 1, 1984, Morales transferred a McDonnell-Douglas DC-3 aircraft, also known as a C-47, to Marcos Aguado for the Contras.

24.  In late 1984, Morales met with Chammoro and other Contra leaders who discussed the activities of North courier Rob Owen.

25. On or about December 20, 1984, Morales met at a hotel in Costa Rica with Contra leaders Popo Chammoro, Octaviano Cesar, Commandante Tito, and Carlo Prado, to discuss the shipment of illegal narcotics into the United States.

26.  In mid-December, 1984, Owen, Hull, Calero, Enrique Bermudez, and others met in Miami at the home of Calero.

27.  On or about December 21, 1984, Felix Rodriguez met with Donald Gregg and North and discussed how to provide supplies to the Contras.

28. Shortly after the December 21 meeting, Gregg reported to George Bush that Rodriguez wanted to go to El Salvador, and that Gregg was going to introduce Rodriguez to other U.S. government officials involved with Central America.  Bush said “Fine.”

29.  On January 14, 1985, North wrote in his notebook:
 “Rob Owen—John Hull—no drug connection—Believes.”

30.  During Jan. 1985 Rodriguez met with Owen at the Key Bridge Marriot Hotel in Rosslyn, Virginia.  Following this meeting, Owen wrote a two-page letter to North, discussing his meeting with Rodriguez and Rodriguez’s projects.

31.  On January 22, 1985, Bush, Gregg, and Rodriguez met at Bush’s office in the Old Executive Office Building.

32.  Two days later, on January 24, 1985, Rodriguez met with General Adolfo Blandon, the Salvadoran military chief of staff, and on January 30, 1985, Rodriguez met with General Bustillo, commander of the Salvadoran Air Force.  Bustillo agreed that Rodriguez could stay at Ilopango Military Air Base outside of San Salvador.

33.  On Feb. 15, 1985, Rodriguez met with Ambassador Pickering and Col. James Steele, the commander of the U.S. Military Group in El Salvador.

34.  On Feb. 19, 1985, Rodriguez met with Gregg to report on the process of his activities at Ilopango, and then Rodriguez also met with North.

35.  In late Feb. or early March of 1985, Owen traveled to Costa Rica at the request of North to meet with Contra groups.

36.  In March 1985, Hull states that he has a friend at the National Security Council who puts $10,000 a month in a Miami bank account for him.

37.  In mid-March, 1985, Rodriguez relocated to Ilopango air base.

38.  On or about April 20, 1985, Rodriguez wrote to Gregg, stating: “Don, I thank you and the Vice President [Bush] for supporting me.  Without your help I could not have made it here.”

39.  On April 29, 1985, Gregg wrote to Col. Steele thanking Steele for his assistance to Rodriguez.

40.  On June 5, 1985, Gregg, Rodriguez, and Steele met at the Key Bridge Marriot Hotel in Rosslyn, Virginia.

41.  On or about June 3, 1985, Owen traveled to California with Calero to meet with Meneses.

42.  On or about June 7, 1985, Calero and Owen met to conclude purchase of weapons for the Contras, after a telephone call from North.

43.  In the summer of 1985, North and other members of the Restricted Interagency Group (RIG - a body established under NSDD-2) met and decided to open up a Southern Front for the Contras in Costa Rica.

44.  On June 28, 1985, North, Secord, former CIA officers Thomas Clines and Raphael Quintero, Calero, and Enrique Bermudez met in Miami.  North told Calero and Bermudez that they must work with him and Secord to build a viable Southern Front.

45.  On July 12, 1985, North wrote in his notebook:
 “$14 million to finance came from drugs.”

46.  On August 9, 1985, North wrote in his notebook:
 “DC-6 which is being used for run out of
 New Orleans is probably being used for
drug runs into the U.S.”

47.  On August 10, 1985, North wrote in his notebook:
 “Southern Front . . . John Hull to arrange for
[deleted] training....”
and also:
“Mtg w/A.C.—name of DEA person in New Orleans
re bust on Mario/DC-6.”

48.  In August 1985 Congress appropriated $27 million in “humanitarian” assistance for the Contras, and President Reagan established the Nicaraguan Humanitarian Assistance Office (NHAO).  In September 1985, North urged Ambassador Robert Duemling, the director of NHAO, to hire North’s courier Owen for the NHAO.  Duemling at first refused, but North and the RIG pressured Duemling to hire Owen.

49.  On September 10, 1985, North wrote in his notebook:
“1630 Mtg w/ Jim Steele/Don Gregg
Talked to Blandon [...]
Says Bermudez was prepared
 to devote a special ops unit
 astride FMLN log lines.
Introduced by Wally GresheimbackslashLitton
Calero/Bermudez visit to
Ilopango to estab.
log support./maint. [...]”

50.  On Sept. 20, 1985, North wrote a letter to Rodriguez, requesting Rodriguez to become the liaison between the government of El Salvador and the North-Secord Contra resupply operation.  At the top of the letter North wrote in capital letters: “AFTER READING THIS PLEASE DESTROY IT.”

51.  On October 1, 1985, North wrote in his notebook:
 “Don Gregg: Maximo Gomez 27-31-59,”
which was Rodriguez’s telephone number in El Salvador.

52.  Also on October 1, 1985, Ambassador Duemling, the director of the NHAO, wrote the following notes:
“(North) can use—  Mr. Green said to call—  Maximo Gomez
273159 in San Salvador
Will airlift the stuff from Salvador.”

53.  On October 17, 1985, Rodriguez and North met in Washington, D.C.

54.  In December 1985, North and Alan Friers, the chief of the CIA’s Central American Task Force, traveled to Honduras and El Salvador to convince local officials to permit NHAO shipments to be transshipped from the United States to Ilopango air base in El Salvador, and on to Honduras.

55.  Beginning on or about Jan. 9, 1986, and continuing through August 1986, the Nicaraguan Humanitarian Assistance Office (NHAO) made the following payments to companies owned and operated by narcotics traffickers:
SETCO, for air transport service— $185,294.25.
DIACSA, for airplane engine parts— $41,120.90.
VORTEX— $317,425.17.

56.  Vortex was owned by Michael Palmer, a drug-trafficker who became an informant for the DEA, while at the same time making his aircraft available to the NHAO for “humanitarian” shipments to the Contras.  Subsequently, an indictment against him for marijuana smuggling was dropped as “not being in the interests of the United States.”

57.  In Jan. 1986, Rodriguez met with Richard Gadd, as associate of Secord in Secord’s airlift operation.

58.  On or about Jan. 14, 1986, Bush traveled to Guatemala.  During a reception at the U.S. Embassy, DEA Agent Celerino Castillo identified himself to Vice President Bush as a DEA agent conducting international narcotics investigations, and told Bush there was something funny going on at Ilopango.  Bush refused to listen to Castillo, and walked away.

59.  On or about Jan. 19. 1986, at the direction of Bush and Gregg, Bush’s deputy national security advisor Samuel Watson traveled to Ilopango and met with Rodriguez to be briefed on the operations taking place there.

60.  On Feb. 4, 1986, Watson wrote a memorandum to Bush, which was channeled through Gregg, reporting on his findings in El Salvador and Honduras.  Gregg wrote on the top of Watson’s memorandum:  “Good report from Sam.”

61.  Gregg underlined a portion of the Feb. 4 Watson memorandum to Bush which discussed the lack of logistical support for the Contras, and wrote in the margin: “Felix agrees with this—It is a major shortcoming.”

62.  On Feb. 27, 1986, North wrote in his notebook:
 “Mtg w/Lew Tambs—DEA auction A/C seized as
 drug runners.—$250-260K fee.”

63.  On April 16, 1986, Rodriguez called the Office of the Vice President to request a meeting with Bush.  A secretary in Bush’s office wrote: “Felix Rodriguez . . . [t]o brief the Vice President on the status of the war in El Salvador and resupply of the Contras.”

64.  On April 20, 1986, North, Secord, Rodriguez and Contra military commander Enrique Bermudez met at Ilopango air base in El Salvador.

65.  On the evening of April 30, Rodriguez and Sam Watson met for drinks at a Washington restaurant.

66.  On May 1, 1986, Rodriguez met with Bush, Gregg and Watson in Bush’s office in Washington.  During the meeting, North joined the meeting along with Ambassador Edward Corr.

67.  On May 6, 1986, Watson sent a memorandum to Bush concerning the Contras, and Gregg wrote a note with it, which stated:
“A sober analysis of the Sandinistas’ hold on power.
The means suggested to counter this hold will not
be enough.  The central point is that Contra actions +
internal political opposition need to be coordinated.
Felix says we are doing nothing to direct the Contra

68.  Following the meeting with Bush, Rodriguez returned to El Salvador and during May 1986 met with Robert Dutton, who had replaced Richard Gadd as the principal supervisor of Secord’s resupply operation.  Rodriguez told Dutton that he, Rodriguez, had a very close relationship with Bush and a number of Bush’s people.

69.  On or about May 9, 1986, following a meeting with FBI official Oliver “Buck” Revell, North met with FBI agents and asks them to investigate various persons who are raising allegations about drugs and the Contras, including Jack Terrell and Senator John Kerry.

70.  On June 3, 1986, North met with FBI agents and demanded to know why no action had been taken against Senator Kerry because of his allegations against North.

71.  On July 17, 1986, North drafted a memorandum describing Jack Terrell as a “terrorist threat,” and stating that FBI official Oliver Revell and the Operations Sub-Group/Terrorist Incident Working Group (OSG/TIWG) were meeting to discuss how to deal with Terrell, who was being used as a source for news media stories on the Contras and drug-running.

72.  On June 25, 1986, Rodriguez met with North and Robert Dutton in Washington at the Old Executive Office Building.  North complained to Rodriguez of security violations.  Rodriguez told North: “This could be worse than Watergate.  It could destroy the President of the United States.”

73.  Immediately after the meeting with North, Rodriguez went to the office of Bush and had a discussion with Watson.

74.  On August 8, 1986, Rodriguez met with Gregg in Washington to discuss the activities at Ilopango and accusations that Rodriguez had stolen an airplane.

75.  On or about August 8, 1986, Hull wrote a letter to the United States Attorney in Miami, and Senators Richard Lugar and Warren Rudman, accusing Senator Kerry’s staff of engaging in misconduct and bribing witnesses.

76.  On August 12, 1986, Gregg called a meeting of various U.S. government officials to discuss the Contra resupply operation.  One of the participants, Robert Earl, took notes which include the following:
 “Ilopango [classified information withheld from notes]
 not 1st choice
 Felix claims working w/ VP blessing for CIA.”

77.  On October 5, 1986, upon learning that the C-123 plane involved in the resupply effort had been shot down over Nicaragua, Rodriguez placed a telephone call to the office of Bush.  Unable to reach Bush or Gregg, Rodriguez then called Gregg’s assistant Sam Watson to warn him about the situation.

78.  On October 15 and 24, 1986, North made entries in his notebook which indicated that he was closely monitoring the investigation being conducted by the Senate Foreign Relations Committee and Senator Kerry.

79.  On November 21, 1986, North made additional entries in his notebook concerning information regarding Secord provided to Senator Kerry by a private investigator.

80.  Throughout 1987 and 1988, William Weld, who had become Assistant Attorney General in charge of the Criminal Division of the Justice Department in the summer of 1986, prevented the Kerry subcommittee of the Senate Foreign Relations committee from obtaining access to records and witnesses.

81.  On or about March 5, 1986, after learning that Jack Terrell, a former associate of the Enterprise, was giving information about the activities of the Enterprise to law enforcement agencies and the news media, Secord assigned a “security officer” to investigate Terrell.

82.  On or after March 24, 1986, North improperly obtained an investigative report written by FBI special agent George Kiszynski concerning a Miami investigation of the Contras and drug trafficking.

83.  On or about April 7, 1986, Owen wrote a letter to North containing secret and privileged information concerning the investigation of the Contras and drug-trafficking, being conducted by the United States Attorney in the Southern District of Florida.

84.  On or about May 5, 1986, following a story on National Public Radio about the Contras and drug-trafficking, North together with FBI official Oliver Revell and others decided to use the Operations Sub-Group of the Terrorist Incident Working Group (OSG/TIWG) to harass and intimidate and root out critics of their activities.

85.  On June 1, 1986, a spokesman for the United States Department of Justice falsely stated that the FBI and DEA have “run down each and every one” of the allegations regarding gunrunning, murder plots, drug trafficking, and corruption connected to the Contras, and have found “no credible or substantive evidence warranting prosecution of Contra leaders.”  The spokesman further described the allegations as those of “disgruntled people with an ax to grind.”

86.  On June 25, 1986, Rodriguez met with North and Robert Dutton in Washington at the Old Executive Office Building.  North complained to Rodriguez of security violations.  Rodriguez to North: “This could be worse than Watergate.  It could destroy the President of the United States.”

87.  On November 21, 1986, North and others shredded large numbers of documents in his offices at the National Security Council.

88.  Throughout 1987 and 1988, William Weld, who had become Assistant Attorney General in charge of the Criminal Division of the Justice Department in the summer of 1986, prevented the Justice Department, the FBI and the DEA from investigating and prosecuting members of the Enterprise and their associates.

89.  Between 1986 and continuing up through at least 1989, Bush and others quashed at least six investigations of drug-trafficking and money-laundering in and around Mena, Arkansas.

90.  In December of 1992, President Bush pardoned major figures in the Iran-Contra scandal, thus ensuring that the real crimes of the Enterprise - cocaine trafficking - would never be brought out into the light of day.


Foreman Of The Grand Jury