Updated

U.S. prosecutors say their evidence against notorious Mexican drug lord Joaquin "El Chapo" Guzman (wah-KEEN' ehl CHAH'-poh gooz-MAHN') includes killings, torture, kidnappings, prison breaks and even an attempt to smuggle seven tons of cocaine in cans of jalapenos.

According to The New York Times , a government memo filed Tuesday also says there's evidence that Guzman was involved in a 1992 drug-gang shootout at a Puerto Vallarta, Mexico, nightclub that left six people dead.

Guzman's lawyer, Eduardo Balarezo, said he was reviewing the memo and would "respond in due course."

The Brooklyn conspiracy trial starts in September.

On Monday, the defense requested the criminal histories of drug lords, couriers, enforcers and accountants that prosecutors may put on the stand.

The list includes about 40 witnesses. Some might be allowed to testify under aliases.