10 ul 12 13 14 15 16 W 18 19 20 21 2 23 ” DANIEL G. BOGDEN United States Attorney JAMES E. KELLER. Assistant United States Attorney 100 West Liberty Street, Suite 600 Reno, Nevada $9501 (775) 784-5438 UNITED STATES OF AMERICA, Plaintiff, v. ROBERT GENE RAND, RICHARD WINSTON WEST II, alk/a Richie West, OMAR AHSAN AHMAD, JOSHUA ROSS GREEN, CLINT MITCHELL BLOODWORTH, KATHLEEN GRIFFIN, RYAN DANIEL SMITH, ALAN RUSSEL MARTINEZ, and BRADEN KYLE RILEY, Defendants, FILED APR 27 2016 IsTRATE JUDGE USigHRGT OF NEVADA ay. DEPUTY UNITED STATES DISTRICT COURT. DISTRICT OF NEVADA Case No. :/(9- MS-00 le4| VAG, COMPLAINT FOR VIOLATIONS OF: 21 U.S.C. §§ 841(a)(1), 841(b)(1)(C), and 846; 21 CFR § 1306.04 — Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Count 1) 21 US.C. § 848 — Continuing Criminal Enterprise (Count 2) 2D US.C. §§ 841()(1) and 841) Os 21 CER § 1306.04 — Distribution of a Controlled Substance Resulting in Death (Count 3) 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(C) — Distribution of a Controlled Substance (Counts 4, 5, and 6) 21 U.S.C. § 843(b) ~ Illegal Use of a Communication Facility (Count 7) 18 USC, § 2 ~ Aiding and Abetting (Counts 2 through 7) BEFORE the Honorable Valerie P. Cooke, United States Magistrate Judge, Reno, Nevada, the undersigned complainant being first duly swom states:10 iL 12 2B 14 15 16 7 18 19 20 21 22 23 24 COUNT ONE (Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances — 21 U.S.C. §§ 841(a)(1), 841(b)(1)(C), and 846; 21 CER § 1306.04) Beginning on an unknown date, but not later than on or about September 30, 2015, and continuing to on or about April 28, 2016, in the District of Nevada, and elsewhere, ROBERT GENE RAND, RICHARD WINSTON WEST II, a/k/a Richie West, OMAR AHSAN AHMAD, JOSHUA ROSS GREEN, CLINT MITCHELL BLOODWORTH, KATHLEEN GRIFFIN, RYAN DANIEL SMITH, ALAN RUSSEL MARTINEZ, and BRADEN KYLE RILEY, defendants herein, knowingly and intentionally combined, conspired, confederated and agreed together and with each other, and with other persons known and unknown, to distribute and possess with intent to distribute controlled substances, such as oxycodone, a Schedule II controlled substance, which were prescribed not for a legitimate medical purpose and by an individual practitioner not acting in the usual course of his professional practice, in violation of Title 21, United States Code, Sections 841(a)(1), 841(6)(1X(C), and 846; and Title 21, Code of Federal Regulations (“CFR”), Section 1306.04 COUNT TWO (Continuing Criminal Enterprise — 21 U.S.C. § 848) Beginning on an unknown date, but not later than on or about September 30, 2015, and continuing to on or about April 28, 2016, in the District of Nevada, and elsewhere, ROBERT GENE RAND, and RICHARD WINSTON WEST II, a/k/a Richie West, defendants herein, did unlawfully, knowingly and intentionally engage in a continuing criminal enterprise in that they unlawfully, knowingly and intentionally violated Title 21, United States Code,10 ul 12 13 14 15 16 7 18. 19 20 21 22 24 Sections 841(a)(1), 841(b)(1)(C), 843(b), and 846; and Title 21, Code of Federal Regulations, Section 1306.04, which violations include, but are not limited to, the violation alleged in Count 1 — Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances; and the substantive violations alleged in Count 3 ~ Distribution of a Controlled Substance Resulting in Death, Count 4 — Distribution of a Controlled Substance, Count 5 ~ Distribution of a Controlled Substance, Count 6 — Distribution of| a Controlled Substance, and Count 7 ~ Illegal Use of # Communication Facility, which Counts are realleged and incorporated herein by reference as though fully set forth in this Count, and which| violations were part of a continuing series of violations of the Controlled Substances Act, Title 21, United States Code, Section 801, et seg., undertaken by defendants ROBERT GENE RAND and RICHARD WINSTON WEST II, a/k/a Richie West, in concert with at least five other persons with| respect to whom ROBERT GENE RAND and RICHARD WINSTON WEST II, a/k/a Richie West, occupied positions of organizer, supervisor, and any position of management, and from which such continuing series of violations the defendants obtained substantial income and resources; all in violation of Title 21, United States Code, Section 848; and Title 18, United States Code, Section 2. COUNT THREE (Distribution of a Controlled Substance Resulting in Death — 21 U.S.C. $§ 841(a)(1) and 841(b)(1)(C); 21 CFR § 1306.04) Beginning at an unknown date, but not later than on or about September 30, 2015, in the District of Nevada, ROBERT GENE RAND, defendant herein, knowingly and intentionally distributed a controlled substance, to wit: by issuing a prescription of oxycodone, a Schedule II controlled substance, to an individual whose name bears the initials M. Y., prescribed not for a legitimate medical purpose and by an individual practitioner not acting in the usual course of his professional practice, with the use of that oxycodone resulting in the death of an individual whose name bears the initials M. Y., in violation of Title 21, United States Code,10 ul 2 1B 14 15 16 7 18 19 20 21 2 23 24 Sections 841(a)(1) and 841(b)(1)(C); Title 21, Code of Federal Regulations, Section 1306.04; and Title 18, United States Code, Section 2. COUNT FOUR (Distribution of a Controlled Substance - 21 U.S.C. §§ 841(a)(1) and 841(b)(1)(C)) On or about November 13, 2015, in the District of Nevada, RICHARD WINSTON WEST I, a/k/a Richie West, defendant herein, knowingly and intentionally distributed a controlled substance, namely oxycodone, a| Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C); and Title 18, United States Code, Section 2. COUNT FIVE (Distribution of a Controlled Substance ~ 21 U.S.C. §§ 841(a)(1) and 841(b)(1XC)) On or about December 3, 2015, in the District of Nevada, RICHARD WINSTON WEST I, alk/a Richie West, defendant herein, knowingly and intentionally distributed a controlled substance, namely oxycodone, 2) Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C); and Title 18, United States Code, Section 2. COUNT SIX (Distribution of a Controlled Substance — 21 U.S.C. §§ 841(a}(1) and 841(b)(1)(C)) (On or about March 16, 2016, in the District of Nevada, RICHARD WINSTON WEST II, ak/a Richie West, defendant herein, knowingly and intentionally distributed a controlled substance, namely oxycodone, a| Schedule 11 controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C); and Title 18, United States Code, Section 2. uw10 u 12 13 14 16 7 18 19 20 21 22 23 24 (Ulegal Use of a Communication Facility ~ 21 U.S.C. § 843(b)) Beginning on an unknown date, but not later than on or about March 9, 2016, and continuing to on or about April 28, 2016, in the District of Nevada, and elsewhere, ROBERT GENE RAND, RICHARD WINSTON WEST I, a/k/a Richie West, OMAR AHSAN AHMAD, JOSHUA ROSS GREEN, CLINT MITCHELL BLOODWORTH, KATHLEEN GRIFFIN, RYAN DANIEL SMITH, ALAN RUSSEL MARTINEZ, and BRADEN KYLE RILEY, knowingly and intentionally used a communication device, namely, a cellular telephone, in facilitating the commission of any act or acts constituting a felony under 21 U.S.C. §§ 841(a)(1) and 846; that is, the offense set forth in Count One of this Criminal Complaint, incorporated fully by reference herein; in violation of Title 21, United States Code, Section 843(b); and Title 18, United States Code, Section 2. Complainant as a Special Agent with the Drug Enforcement Administration states there is probable cause to arrest the above-named defendants as set forth in the attached affidavit. We ww a Ww we