Indictment For Columbia Bloods Gang Investigation July 11 2012

3:12-cr-00S13-CRI 'SEALED* Date Filed 06/21112 Entry Number 3 *SEALED*
of 100
UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION
UNITED STATES OF AMERICA )
)
vs. )
)
DAVID ANDREA JENKINS )
all<la Arma G )
aII<Ia Dread )
TITUS WILL BOWMAN )
aII<Ia TI )
TORREAN ANTWON SIMS )
aII<Ia Slim )
aII<Ia Arsonist )
ANDRE JAMEL CUMMINGS )
aII<Ia Ore )
CRAIG XAVIER ALSTON )
a/k/a CK )
DARRELL ANTONIO ALSTON )
aII<Ia Hell Rell )
NICHOLAS JASON WRIGHT )
alkla Tater Head )
STEWART JAMAUL STROMAN )
a/k/a Stew )
BRANDON DESHAWN HAWKINS, SR. )
alk/a Shelgun )
all<la Gun )
STEVEN BENJAMIN BRADLEY )
aII<Ia Red Boy )
NATHANIELJAMAL FARMER )
alk/a Gucci )
DAVANTE HENRY CHRISTOPHER LANE)
a/k/a UI D )
TASHANDA NICOLE PARKER )
aII<Ia Big Mama )
aII<Ia Big Mama Blood )
JARIUS OCTAVIS JONES )
a/k/a Buck )
)
Criminal No. '3: 120-513
18 U.S.C. 922(g)(l)
18 U.S.C. 922(n)
18 U.S.C. 924(aX1XD)
18 U.S.C. 924(c)
18 U.S.C. 924(cX')(A)(ii)
18 U.S.C. 924(cX' ) ( A ) ( " ~
18 U.S.C. 1001(a)
18 U.S.C. 1343
18 U.S.C. 1349
18 U.S.C. 1591(a)
18 U.S.C. 1591(b)
18 U.S.C. 1591(b)(2)
18 U.S.C. 1591(c)
18 U.S.C. 1959(aXl)
18 U.S.C. 1959(.)(3)
18 U.S.C. 1959(a)(6)
18 U.S.C. 1951(a)
18 U.S.C. 1952(a)(3)
18 U.S.C. 1962(d)
18 U.S.C. 2421
18 U.S.C. 2422(a)
18 U.S.C. 924(d)
18 U.S.C. 981(a)(I)(C)
18 U.S.C. 1594(d)
18 U.S.C. 1963(a)
18 U.S.C. 2428
18 U.S.C. 2
21 U.S.C. 802(32)
21 U.S.C. 813
21 U.S.C. 841 (a)(I)
21 U.S.C. 841(b)(I)(A)
21 U.S.C. 841 (b)(I)(C)
21 U.S.C. 841(b)(I)(D)
21 U.S.C. 643(b)
Page 1
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED*
of 100
BERNARD KENTRELL BREElAND, JR. )
all<Ja Bneezy )
CALVIN JAMES HALL )
alkJa Kebo )
KENNETH ROYCOnOy )
alkJa Fish )
all<Ja Koppo )
atkJa Kapone )
EDMOND lEVY, JR. )
all<Ja Southside )
ALEX RUSSELL ANDERSON )
all<Ja Black )
ANTWAIN EMANUEL BRISBON )
all<Ja Tweeze )
all<Ja Twan G )
SHANTANE SIMMONS )
all<Ja Shantane l. Craft )
ODELL MARTIN, JR. )
all<Ja Teazy )
KARISH MALI BROWN )
all<Ja KB )
JAMES E, LONDON )
afkJa Prince )
a/kJa Rockaroni )
MICHAEL ANTONIO TAYLOR )
afkJa Puncho )
SHONTA MARIE HARRISON )
aJ"t<ia Ta j
TAMEKA DANIELLE SMITH )
afkJa Meka )
CHRISTEN MICHelLE SPENCER )
JOSHUA ALEXANDER Kin )
atkJa Melro )
TYRONE LEWIS )
a/kJa Ty Ty )
MICHAEL OSHAY LONG )
afkJa Killer )
FRANK HENDERSON, III )
HASSAAN R. BROWN )
all<Ja Hossy )
)
2
2t U.S.C. 846
2t U.S.C. 860
21 U.S.C. 853
21 U.S.C. 881
28 U.S.C. 2461(c)
INDICTMENT
Page 2
3:12-cr-OOS13-CRI 'SEALED'
Date Filed 06/21/12 Entry Number 3 'SEALED*
of 100
DEGREGORY REAVES
alkJa Junior
DAMEON ANTONIO BURGESS
DAION ALI BOWERS
RONDA BAKER
TEVIN DESHANE RAMSEY
aJk1a P.T.
DEFENDANTS
COJ.lHU.
THE GRANO JURY CHARGES:
lntrqduction
1. In the early 1970's, -The Bk>ods Street Gang was formed in Los Angeles,
California. The gang was initially comprised of seven individual street gangs who
unified as The Bloods, and expanded across the United States during the "crack
n
cocaine epidemic of the 1980's.
2. The Bloods Street Gang is comprised of individual units or sets, each
identified or affiliated wilJ1 a certain street, neighborhood. or geographic area. Each
of the sets however all maintain common tattoos. communication codes, language,
graffiti markings, and are identified by wearing the color red. Additionally. Bloods
mainlain a long-term and often lethal rivalry with the Crips gang, among others,
whose signature color is blue.
J
Page 3
3:12-cr-OOS13-CRI *SEALED*
Date Filed 06/21112 Entry Number 3 *SEALED*
of 100
3. On July 16, 1993, a1the George Machen Center on the eastside
of Rlkers Island Prison, the MUnited Blood Nation" (USN), a single Blood entity, was
created at the direction of Omsr "Original Gangster Mack- Portee and his partner
Leonard "Dead Eye" McKenzie, both inmates on Rikers Island. Portee and
McKenzie decided that the Bloods sets should unite in order to protect themselves
from ""The Almighty Latin King Nation", the largest prison gang in the New York
prison system. All the Blood sets or gangs who unified under the UBNlBloods Street
Gang were anowed to keep their original set names, to wit:
a. "Nine Trey Gangs1ers" (formed in 1993),
b, "One Eight Trey's",
c. "Mad Stone Villains.
d, "Valentine Bloods",
e. "Gangsta Killa Bloods" (GKB),
f. "Hij Squad Brims",
g. "Blood Stone Villains",
h. Money. Murder",
These Original sets were formed based upon their affiliation with certaIn
sheels, nciylloorhoods, arEas, or toccol gang:;. l\s thccc members wefe
from prison, the UBNIBloods Street Gang philosophy spread across the streets of
New Yorl<.
4. Once the UBN/Bloods Street Gang spread from the prisons to the streets,
Ihe members devised code names In order to avoid Identification by law
enforcemenl For instance, the "Nine Trey's" became known as the "Billy Bad
Asses". The "Gangsta Kilta Bloods" also became known as the "G-Shine",
4
Page 4;
3:12-cr-00513-CRI "SEALED"
Date Filed 06/21/12 Entry Number 3 "SEALED"
of 100
s. The UBNIBIoods SIreel Gang has since spread across the east coastoflhe
United States; however, the ultimate authority lor gang decisions Is still maintained
in New York and the New Yor1< prison system. described by UBNIBloods SIreet
Gang members as "up lop". The gang maintains a strict hierarchy or chai n of
command. Although called by different names, such as "the rims, the
structure", and "the empire structure", the rules are strictly enforced through the
chain 01 command. or UBN/Bloods Street Gang leadernhip. The UBN/Bloods SIreet
Gang leadership includes a national council rthe Council" ). Council members are
selected from the leaders of the larger sets such as ..
6. All sets of the UBNlBloods SIreel Gang organization are governed by a
common set of rutes. The rules were originally wrillen by USN founders Ornar
Portee and Leonard McKenzie.
Examples of the rules are:
a. descriptions of how the Individual gang member is to operate;
b. the specifics of wearing the color red (for instance, a red bandana
must always be worn on the right side 01 the body);
c. that the rutes, codes and 'lessons must be studied and
memorized; and
d. that you do not snltch'! or cooperate with law enforcement.
7. The rules also set forth the specifics of communi calion. The most common
and accepted methods of communication are: kites, phones, contraband cell
phones, text messaging, visitation, face to face meetings, and word of mouth. Kites
5
Page 5
Date Filed 06/21/12 Entry Number 3 *SEALED*
of 100
are letters within and outside of prison; however. the kite must be delivered by a
person of high rank or someone who would have direct access to the sender.
Inmates have access to telephones in prison and it is not uncommon for inmates to
receive contraband cell phones In prison which they use for gang communications.
8. The Bloods created a unique system of codes and hand signals they use
to communicate with each other. These codes and hand signals were initially
established to allow members of the Bloods Street Gang to communicate with each
other in a way that hid the nature of their communication from law enforcement. rival
gangs and prison officials.
Some of the most commonly used words by members of the USN/Bloods
Street Gang operating in various parts of the country are:
a.
b.
d.
"damu" which means blood in the African language Swahili,
"wood" or "Inglewood" 10 descri be gang knowledge (rules, codes
and gang structure),
toconnore loyslt'f and affi!i::Hon Ie the USN (th2 U8N
was East side of Rikers Island); and
Suu Wuu" whlch means -Bloods rule-. A greetmg of suu WtJU"
Is returned with the greeting of -Wuu
like their counterparts in other areas, Bloods in Columbi a, South Carolina,
use coded language to communicate with each other, including but not limited to, the
words and phrases described above. When speaking to each other, Bloods in .
Columbia will not use the letter "e" because the word "Cops" begins with that letter.
G
Page 6
of 100
Therefore, Bloods replace the leUer ~ c " with the letter "b" when speaking to each
other. For instance, a Blood would say "ball me
M
rather than "call me." The Bloods
In Columbia also have code words they use to conceal their speech. For instance,
"triple" stands for a gun; "50" stands for police; "1 -2" is a crack cocaine customer;
-lick: and "fox" refers to a robbery; "G's up" 51ands for "Gangslers Up"; "Michael
Jordan" stands for a .223 caliber assault (ine, -Baby Love" is a reference 10 money;
and "wisdom" stands for crack cocaine. The Bfoods in Columbia also use a
sophisticated cipher system when speaking to each other and they want to conceal
the true nature or the conversation. This code equates certaIn words with numbers
as shown below. For Instance. if a Blood member wants to purchase $150 of crack
cocaine, he would say, "I need knovAedge power cypher on the wisdom." During
court aulhorized intercepts in 2006 targeting Ihe USN/Bloods Streel Gang in
Columbia. S.C., agents broke these codes with the help of a confidential source.
The numeric cipher code is as follows:
Q Cypher
1-Knowledge
2 Wisdom
3-Understanding
4-Culture
5-Power
6-Equalily
7-God
8-BIII
980rn
1 O-Knowledge Cypher
1
Page 7
3:12-cr-OOS13-CRI *SEALED* . Date Filed 06/21/12 Entry Number 3 *SEALED*
of 100
9. The Bloods Street Gang also created a system of rules and regulations
governing lis memoorship and initiation process. These regulations establish a
hierarchical membership structure. For example, a member who has founded a set
of Ihe Bloods is called a -Godrather." Other titles of respect within the Bloods Streel
Gang include, but are not limited fa: "Original Gangsta" or "OG": "Superior": and
"General." Additionally, the rules governing initi ation into the Bloods sometimes
require those seekIng membership to commi t acts of violence.
10. A "nine" refers to a gang meeting and is the method by which the
en1erprise, or a set" or local level gang, is governed. A is caUed by the
highest ranking member of the sel or his designee. Membership dues are calleel ed
at the "nine", These dues are col lected for the benefit of the set and the UBN/BloOds
Street Gang organization. The money is used to assist members who have been
arrested and their families.
11. In order to become a USN/Bloods Street Gang member. you must be
introduced by an existing gang member. Prospecti ve members are
(physically beaten for 31 seconds by gang members) and provided with a copy of the
rut es which must be memorized. AU gang members are required to put in work"
meaning they must carry oul the activities of their set on behalf of the organization.
"Pulling in work" can mean commilting robberies, selling drugs, conducting
shootings, administering beatings, or other activities, legal or illegal, whi ch produce
income for the UBN/Bloods Street Gang.
8
Page 8
of 100
12. While gang members can be identified by wearing the color red in some
fashion. tattoos are also an important method of identification. Common
USN/Sloods Sireet Gang tattoos are:
a. lhe leHers "m.o.b." (member of bloods);
b. a five pointed slar (to represent the five paints of knowledge
within the organization: life, love, loyalty, obedience, and respect
andlor love, truth, justice, freedom and peace);
C. three circular brands which fann a triangle, commonly known in
the organization as -dog paws which represents the
USN/Bloods Street Gang;
d. the lerters "GKS" (Gang st. Kill. Blood). and various dog talloos.
References to dogs, particularly bull dogs, are common within the enterprise.
13. The UBN/Bloods Street Gang leadership in New York sanctions or
approves individual stale USN/Bloods Street Gang sets. If members of a sanctioned
or authorized set attempt tQ break away (rom the USN/Bloods Street Gang
organization, they will be punished by the organization.
14. In t998, James Powell.aIkIa Munchle, came to Columbia, South Carolina,
from New York. Powell was the leader of a Gangsta Killa Bloods (GKB) set in
Westbury, NY, In 1998 or 1999, Powell, along with his superior in the gang.
Woodland (TNU). and some other GKB members "beal in", or inducted, other
individuals and Powell was responsible for making up Ihe rank structure or the GKB
in COlumbia. Powell also taught Bloods to new members and this
knowledge" was eventually passed to Delendant DAVIO ANDREA JENKINS, alk/a
9
Page 9
10 of 100
Anna G, alkla Dread. As noted earlier. GKB set is now known as
15. In 2006 and 2007, an FBI investigaHon in Columbia and New York
targeting Ihe Bloods Street Gang resulted in the conviction of over 24 gang members
and associates, induding gang leaders Defendant TORREAN ANTWON SIMS, alkJa
Slim, aJkIa Arsonist, and James Powell, a/kJa Munchie. However, Defendant
TORREAN ANTWON SIMS, alkJa Slim, alkla Arsonist, has continued to be involved
in the management of the gang both during his prison term and after his recent
release from federal prison. Most of the Bloods sets operating in Columbia are
members of the G-ShinB set. Given the local predominance of the GShine set here,
the Blood sets operating in COlumbia are currently under the direction and
leadership of Defendan!s TITUS WILL BOWMAN, alkJa TI and TORREAN
ANTWON SIMS, alkJa Slim, alkJa Arsonist, the current local leaders of the G-Shin.
set in Columbia, who in turn report directly to Defendant DAVIDANDREAJENKINS,
a/kJa Arma G, alkJa Dread, a native of Columbia who currently resides in the Los
Angeles, California area. Defendan! DAVID ANDREA JENKINS, alk/a Arma G,
a/kJa Dread, provides guidance and leadership for all Blood sets operating in the
state of South Carollna, and he in turn reports to Daryl Wilkinson, alkJa OG Powerful,
lhrough Wilkinson's girlfriend, Samantha Williams. alk/a Samantha Wilkinson. alkJa
Lady Sam. Daryl Wilkinson, alkla OG Powerful, is (1) a member Council; (2)
the national leader of the G-Shine set of the UBN/Bloods Street Gang; and (3)
currently incarceraled in the Southport Correctional Facility in Chemung County,
10
Page
11 of 100
New York. Both Daryl Wilkinson, aIkIa OG Powerful, and Samantha Williams, alkla
Samantha Wilkinson, a/kJa Lady Sam, are currently under Indictment in the Western
District of North Carolina. Both are charged with racketeering conspiracy in said
indictment and both are unindicted conspirators herein.
16. During Ihe period of this conspiracy, UBN/Bloods Street Gang sel
members 1n Columbia from and Tree Top Piru created and mainlained a
hierarchical membership structure. At all limes relevant to this indictment.
Defendants DAVID ANDREA JENKINS, aIkIa Arma G, aIkIa Dread, TITUS WILL
BOWMAN, aIkIa TI and TORREAN ANTWON SIMS, aIkIa Slim, alkla were
the primary leaders ofthe UBN/Bloods Sireel Gang in Soulh Carolina. Defendanls
DAVID ANDREA JENKINS, alkla Arma G, a/kla Dread, TITUS Will BOWMAN.
aIkIa TI and TORREAN ANTWON SIMS, alkla Slim, aik/a Arsonist. managed.
promoted and furthereslabllshed the criminal enterprise and lower ranking members
furthered their directives.
17. At all limes relevant to this indictment, the (ollowing Defendants were
members andlor associates or the USN/Bloods Street Gang:
DAVID ANDREA JENKINS, alkJa Arma G, alkJa Dread, TITUS WilL
BOWMAN, aIkIa n, TORREAN ANTWON SIMS, aikla Slim, aIkIa Arsonisl, ANDRE
JAMEL CUMMINGS. alkl. Ore, CRAIG XAVIER ALSTON, alkla CK, DARRElL
ANTONIO ALSTON, alkJa Hell Rell , NICHOLAS JASON WRIGHT, alkla TaterHead,
STEWART JAMAUL STROMAN, alkla Stew, BRANDON DESHAWN HAWKINS.
II
Page
12 of 100
SR., alkJa Shotgun, al'K/a Gun, STEVEN BENJAMIN BRAOLEY, alkla Red Boy,
NATHANIEL JAMAL FARMER, alkJa Gucci, DAVANTE HENRY CHRISTOPHER
LANE, alkla Lil D, TASHANDA NICOLE PARKER, alkla Big Mama, alkJa Big Mama
Blood, JAR IUS OCTAVIS JONES, alkJa Buck, BERNARDKENTRELL BREELAND,
JR., alkJa Bneezy, CALVIN JAMES HALL, alkJa Kebo, KENNETH ROY COTTOY,
alkla Fish, alkJa Kappo, alkJ. Kapone, EDMOND LEVY, JR. , alkl. Southside, ALEX
RUSSELL ANDERSON. alkJa Black, ANTWAIN EMANUEL BRISBON, alkJa
Tweeze, alkJa Twan G, SHANTANE SIMMONS, alkJa Shanlane L. Craft, ODELL
MARTIN, JR., alkJa Teazy, KARISH MALI BROWN, alkJa KB, JAMES E. LONDON,
aMa Prince. alkJa Rackaroni, MICHAEL ANTONIO TAYLOR, alkJa Puncho,
SHONTA MARIE HARRISON alkJa Ta, TAMEKA DAN1ELLE SMITH, alkJa Meka,
CHRISTEN MICHELLE SPENCER, JOSHUA ALEXANDER KITT, alkla Melro,
TYRONE LEWIS, alkla Ty Ty, MICHAEL OSHAY LONG, alkla Killer, FRANK
HENDERSON 111, HASSAAN R. BROWN, alkJa Hassy, DEGREGORY REAVES,
alkJa Junior, and DAMEON ANTONIO BURGESS;
18. At all times relevant to thi s Indictment, UBN/Bloods Street Gang members
in South Carolina and elsewhere engaged in criminal activity, Including but not
limited to murder, attempted murder, aggravated assault, kidnapping, attempted
kidnapping. robbery, aNempted robbery, drug trafficking, illegal firearms use and
possession, wire Fraud, prostitutton and conspiracy to commit those crimes.
UBNlBloods Street Gang members committed criminal acts to gain membershipand
12
Page
3:12-cr-00S13-CRI *SEALED*
13 of 100
committed acts of vIolence to maintain membership and discipline within the gang
and against others who were not members or affiliates of the gang. A USN/Bloods
Street Gang member's ability to earn money for lhe organization through the
commissIon of illegal acts, as well as his or her facility with UBNlBloods Street Gang
or wisdom, helps to determine whether a member is promoted 10 a
position of leadership Within the USN/Bloods Street Gang and its sets.
19. At various times during the period covered by this Indictment, USN/Bloods
Street Gang members met in order to, among other things, initiate new members,
issue sanctions for failure to follow the rules or other real or perceived violations,
plan future violence and report on business related to the gang enterprise, included
but not limited to a discussion of crimes to be committed in furtherance of the
enterprise, including criminal acts of violence. drug trafficking, and other activities.
THE RACKETEERING ENTERPRISE
20. The UBN/Bloods Street Gang. including ils leadership. members and
associates. constituted an "Enterprise- as defined in Section 1961(4) of TItle 18.
United States Code, that is, a group Of individuals associated in facl . The Enterprise
constituted an ongoing organization, whose members functioned as a continuing unit
for the common purpose of achieving the objedives and purposes of the Enterprise
The Enterpri se was engaged in. and its activilies affectod. interstate and foreign
commerce.
II
Page
14 of 100
PURPOSES OF THE ENTERPRISE
21 . TI1e purposes of the Enterprise include the following:
a. Preserving and protecting the power, territory, and profits of the
Enterprise through the use of intimidation, armed robberies, violence,
threats of vimence, narcotics trafficking. wire fraud and prostitution;
b. Promoting and enhancing the Enterprise and its members' and
associates' activities, both in and oul of prison, through ihe use of
intimidation. violence, threats of violence. narcotics trafficking. wire
fraud, and prostitution:
c. Generating financial profits for the benefit, and in furtherance of,
the Enterprise:
d. Providing financi al support and information to gang members,
including those who were incarcerated for committing acts of vialence
and other offenses. and;
e. Providing assi stance to other gang members who committed c r i ~ e s
for and onbehalf of Ihe gang.
THE RACKETEERING CONSPIRACY
22. Beginning at a time unknown to Grand Jury, but from at least as early as
1999 and continuing to on or about the date or this Indictment, in the District of South
Carolina and elsewhere, Ihe Oefendanls OAVID ANDREA JENKINS, alkla Arma G,
14
Page
3:12-cr-00513-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED*
15 of 100
a1k1a Dread, TITUS WILL BOWMAN, a1k1. TI, TORREAN ANTWON SIMS, a/kia
Slim, alkl. Arsonisl, ANDRE JAMEL CUMMINGS, .lkIa Ore, CRAIG XAVIER
ALSTON, alkia CK, DARRELL ANTONIO ALSTON, alkia Hell Rell, NICHOLAS
JASON WRIGHT, a1k1a Tater Head, STEWART JAMAUL STROMAN, a1k1a Slew,
BRANDON DESHAWN HAWKINS, SR., alkia Sholgun, a1k1. Gun, STEVEN
BENJAMIN BRADLEY, a1k1a Red Boy, NATHANIELJAMAL FARMER, a1k1a Gucci ,
DAVANTE HENRY CHRISTOPHER LANE, a1k1a UI 0, TASHANDA NICOLE
PARKER, a1k1. Big Mama, a1k1a Big Mama Blood, JAR IUS OCTAVIS JONES, ./kia
Buck, BERNARD KENTRELL BREELAND, JR., .lkIa Bneezy, CALVIN JAMES
HALL, a1k1. Kebo, KENNETH ROY COTlOY, a1k1a Fish, a1k1a Koppo, a1k1a
K.pone, EDMOND LEVY, JR" aIkIa Southside, ALEX RUSSELLANDERSON, a1k1a
Black, ANTWAIN EMANUEL BRISBON, aIkI. Tweeze, aIkIa Twan G, SHANTANE
SIMMONS, alkla Shan lane L. Craft, ODELL MARTIN, JR., alicia Teazy, KARISH
MALI BROWN, a/k/a KB, JAMES E, LONDON, a/kJa Prince, alkla Rockaroni,
MICHAEL ANTONIO TAYLOR, a/kJa Puncho, SHONTA MARIE HARRISON a/kia
Ta, TAMEKA DANIELLE SMITH, a/kIa Meka, CHRISTEN MICHELLE SPENCER,
JOSHUA ALEXANDER Km, aIkIa Melro, TYRONE LEWIS, a1k1a TyTy, MICHAEL
OSHAY LONG, a1k1a Killer, FRANK HENDERSON III, HASSAAN R. BROWN, a/kia
Hossy, DEGREGORY REAVES, a/kia Junior, and DAMEON ANTONIO BURGESS,
each being a person employed by and asscx::iated with the Uniled Blood Nation
rUBW, also referred to as the Bloods Street Gang) an Enterprise engaged in, and
15
Page
16 of 100
the activities of which affected interstate and (oreign commerce, together with
various unlndicted co-conspirators, and othen> known and unknown to the grand
jury, did knowingly and intentionally conspire to conduct and participate, dlreclly and
indirectly. in the conduct or the affairs of the enterprise through a paUem of
racketeering activity, as defined in 18 U.S.C. 1961(1) and including racketeering
activity for which the maximum penalty includes life imprisonment, consisting of
multiple acts Involving state offenses chargeable under the following:
South Carolina State Law:
a. Murder, in violation of the Code of Laws of South Carolina (S.C. Code)
Sections16-3-10, 16-3-29;
b. Distribution. Possession with Intent to Distribute and Trafficking In
Controlled Substances, In violation of S.C. Code Sections 44-53-370
and 375;
c. Robbery. in violation of South Carolina common law and S.C. Code
Sections 16-11-325 and 1611-330;
d. Kidnapping, in violation of the Code of Laws of South Carolina (S.C.
Code) Section 16-3910.
Federal Law
a. Multiple acts involving the felonious distribution, r e c e i p ~ concealment,
buying, selling and otherwise dealing in controlled substances.
including cocaine, cocaine base (commonly known as crack- cocaine).
marijuana, heroin and other controlled substances, in violation of 21
U.S.C. Sections 841 and 846;
b. Multiple acts indictable under the follewing provisions of Title 18, United
States Code:
16
Page
17 of 100
1. Section 1343 (relating to wire fraud);
2. Sec1ions 1503 and 1512 (relating to obstruction of justice and
witness tampering);
3 Section 1591 (relating to se< trafficking);
4. Section t 951 (relating to interference with commerce by robbery
and extortion);
5. Section 1952 (relating to interstate travel in aid of racketeering):
and
6. Sections 242t and 2422 (relating to inte"'tate transportation for
prostnution).
MANNER AND MEANS OF THE CONSPIRACY
23. 11 was part ofthe conspiracy that each defendant agreed that a conspirator
would commit at least two acts constituting racketeering activity In the conduct of the
affairs of the Enterprise.
24. It was a further part of the conspiracy that the defendants, as gang
members of the UBN/Bloods Street enterprise, would regularly meet as required
with other UBN/Bloods Street Gang membe", to discuss. among other things,
initialion of new members, "knowledge- being given to new members, collection of
dues, acts of violence and other crimes commilted by gang members against rival
gang members and others; to notiFy one another about gang members who were
arrested or incarcerated; to discuss the disciplining of USN/Bloods Street Gang
members; to discuss police interactions with gang members: to share with one
17
Page
3:12-cr-00513-CRI *SEALED*
Date Fi led 06/21/12 Entry Number 3 *SEALED*
18 of 100
another the identities of individuals who may be cooperating with law enforcement
and propose actions to be taken against lhose individuals; to plan and agree upon
the commission offuture crimes. including but not limited to murders, robberies, drug
trafficking, assaults, fraudulent offenses, and prostitution: the means 10 cover up
these crimes: and to enforce and reinforce gang rules.
25. \I was a further part of the conspiracy that the defendants and other
members and associates of USN/Bloods Street Gang maintained and circulated a
collection of firearms for use In criminal adivity by UBNIB100ds Street Gang
members.
26. It was a further part of the conspi racy that the defendants and other
members and associates of the USN/Bloods Street Gang enterprise distributed
controlled substances, including cocaine base (commonly known as ' crack"
cocaine). cocaine, heroin, marijuana and other Schedule I controUed substances and
used the proceeds of those drug transactions to help finance the gang's illegal
activities.
27. It was a further part of the conspiracy that the defendants and other
members of the USN/Bloods Street Gang enterprise committed acts of attempted
<felioor.Jte, premeditated and willful murder. aggravated assaults, and other acts of
violence against rival gang members and imposed discipline within the U BN/Bloods
Street Gang enterprise itself.
28. It was a further part of the conspiracy that the defendants and other
18
Page
19 of 100
members and associates of the UBNfBloods Street Gang enterprise in multiple
locations inside and outside of South Carolina maintained written documents and
names and telephone numbers of members.
29. It Vias a further part of Ihe conspiracy Ihal the defendanls and other
members of the USN/Bloods Street Gang enterprise were required to pay
membership dues, which varied significantly among sets. Dues were used to pay
for commissary, defense counsel. firearms, bail, and other needs of the members
of the UBN/Bloods Sireel Gang enterprise.
30. It was a further part of the conspiracy that some defendants and other
members committed armed robberies and armed home invasions in order to
generate proceeds to support the enterpri se.
31 . It was further a part of the conspIracy that some defendants used the
services of an associate of the enterprise, DAION All BOWERS (named as a
defendant in Counls 103-115 of this Indiclmenl) 10 electronically file false and
fraudulent income tax returns to generate illegal income.
32. It Vias further a part of the enterprise that, in order to obtain illegal profits,
defendants and other affiliates of the enterprise used interstate facilities and caused
the interstate transportation of persons to engage in commercial sex acts (commonly
known as prostitution) and used al least one minor in said commercial sex venture.
33. It ViaS a further part of the conspiracy that defendants and other members
and associates of the UBNIBloods Sireet Gang enterprise concealed their criminal
l ~
Page
20 of 100
activities and obstructed justice, including by threatening and tampering with
witnesses.
Overt
In furtherance of the conspiracy and to achieve the objectives thereof, the
conspirators performed and caused to be pelfofmed a hosl of overt acts in the
District of South carolina and elsewhere. induding acts charged In Counts 2-102
and 104-134. In addition to those acts charged as substantive counts, Ule
conspirators performed the other acts, including, but not limited to the following overt
acts, among others, in the District of South Carolina and elsewhere:
1. On or about September II, 2002, in the District of South Carolina, the
Defendant, MICHAEL ANTONIO TAYLOR, all<Ja Puncho, used a firearm to
commit an armed robbery/home invasion.
2. On or about November 29. 2002, in the District of South Carolina, the
Defendant. TORREAN ANTWON SIMS, all<Ja Slim, alkJa Arsonist. led and
directed a group of Bloods locommita driveby shooting at 1013 North Kings
Way, Building H. Columbia with the intent to shool a member of a rival gang.
3. III or around 2003, in the ;.:[ South Carolina, the Defendant.
TORREAN ANTWON SIMS, all<Ja Slim, alkJa Arsonist, led a group of Bloods,
including Defendants STEVEN BENJAMIN BRADLEY, all<Ja Red Boy and
ODELL MARTIN. JR.. aJkJa Teazy, to the Broad River Terrace apartment
complex in Columbia to commIt a retaliatory shooting.
4. On or about March 2, 2004, in the DistClct of South Carolina, the Defendant
ALEX RUSSELL ANDERSON, atWa Block, and unlndicted coconspirator M.F.
possessed with intent to distribute and distri buted cocaine.
5. On or about February 23, 2005, in the District of South Carolina, the
Defendant ODELL MARTIN JR., BlkJa Toazy, aided and abelted by another
person, illegally possessed a firearm and also ill egally possessed a quantity
or cocai ne with the intent to distribute.
2U
Page
21 of 100
6. On orabout July 14, 2005, in the District of South Carolina, the Defendants.
STEVEN BENJAMIN BRADLEY, al'rJa Red Boy, NATHANIEL JAMAL
FARMER, a/kla Gucci, KENNETH ROY COnOY, a/kla Fish, alk1a Kappa,
a/kIa Kappene, and ODELL MARTIN JR., a/kIa Teazy, aided and aberted by
others, used a motel room on Piney Grove Road in Columbia as a distribution
center for the sale of various drugs, Including cocaine, " c r a c k ~ cocaine and
marijuana.
7. On or about August 24, 2005, in the District of South Carolina, the
Defendant, ANTWAIN EMANUEL BRtSBON, al'rJa Tweeze, a/kIa Twan G,
aided and abetled by others Illegally possessed "crack" cocaine with the inlent
10 distribute il
8. On or about November 5, 2005, In the DislI1ci of South Carolina, Ihe
Defendanl, TITUS WILL BOWMAN, a/kIa TI and unlndicted co-consplrator
J.F. shot another individual
9. On or about June 4, 2006, In Ihe DlslI1ct of South Carolina, the Defendant,
NATHANIEL JAMAL FARMER, a/kIa Gucci, assaulted another person with
the intent to commit serious bodily injury to that person.
10. On or about June 7,2006. in the Distnct of South Carolina, the Defendant.
TITUS WILL BOWMAN, al'rJa TI, illegally a possessed a firearm and also
illegally possessed a quantity of marijuana with intent to distribute.
11. On or about October 5, 2006, in the District of Soulh Carolina, the
Defendant, NATHANIELJAMAL FARMER, a/kla Gucci , aided and abelled by
another person fired shots at another individual.
12. On or about October 9, 2006, in the District of South Carolina, Ihe
Defendant, ALEX RUSSELL ANDERSON, a/kIa Black, threatened 10 kill two
individuals and pointed a firearm at sakj victims.
13. On or about October 13, 2006, In the District of South Carolina, Ihe
Defendant, ALEX RUSSELL ANDERSON, al'rJa Black, attempted to shoot
another individual .
14. On or about November 1, 2006, In the District of Soulh Carolina, the
Defendant, TORREAN ANTWON SIMS, al'rJa Slim, al'<1a Arsonisl, called
unindicted coconspirator T.P. to discuss T.P.'s collection of money from a
drug debt and both used coded language to discuss their drug business.
21
Page
22 of 100
15. On or aliout November 26, 2006, In the Oistrict of South Carolina, the
Defendant, TORREAN ANTWON SIMS, aIkla Slim, aIkla Arsonist, called
unindicted co-conspirator T.P. to discuss the commission of a violent act by
another member of the UBN/Bloods Streel Gang.
16. On or about November 26, 2006, In the District o[ South Carolina, the
Derendant, TORREAN ANTWON SIMS, alkla Slim, aIkla Arsonist, called
unindicted co-conspirator T.P. and, using coded language, discussed Sims'
use of a gun in a nightclub.
17. On or about November 28, 2006, in the District of South Carolina, the
Defendant. ANDRE JAMEL CUMMINGS, a/kJa Ore and unindicted c0-
conspirator T.P" using coded language, discussed a sale of cocaine.
1 B. On or about November 28, 2006, in the Dislrict of Soulh Carolina, the
Defendant. JARIUS OCTAVIS JONES, aIkla Buck, called unindicted co-
conspirator T.P. to discuss obtaining drugs for Defendant STEWART
JAMAUL STROMAN, alkla Stew.
19. On or about November 30, 2006, in the Dislrlct of South Carolina, Ihe
Defendant, TORREAN ANTWON SIMS, alkla Slim, alkJa Arsonist and
unindicted coconspirator T.P. , using coded language, discussed a sale of
-crack- cocaine. .
20. On or aboul December 2, 20OS, the Defendant, ANDRE JAMEl
CUMMINGS, a/kIa Ore and unindicted co-conspirator T.P., using coded
language, discussed a sale of ucrack" cocaine by T.P. to Defendanls ANDRE
.!!'.MEl alkJa Drs and JAr ...1J!..UL STROMAN, a!k!a
Slew.
21. On or about December 3, 2006, in the District of South Carol ina, the
Defendant, ANDRE JAMEL CUMMINGS, aIkla Ore, using Defendanl
STEWART JAMAUL STROMAN's, a/k1a Stew, phone, contacted unindicted
co-conspirator T.P. to obtain more crack" cocaine.
22. On or about December 8, 2006, in the District of South Carolina, the
Defendant, FRANK HENDERSON III, possessed a quanlity of cocaine base,
(commonty known as cocaine) with the intent .to distribute said drugs.
12
Page
23 of 100
Oelendant, STEWART JAMAUL STROMAN, a/kIa Stew. called unlndicted c0-
conspirator"T P. M to discuss a drug deal.
24. On or about December 23, 2006, in the Oislrict 01 Soulh Carolina, the
Delendant, STEWART JAMAULSTROMAN, alk/a Stew, called unindicted co-
conspirator -T.P,- to discuss a drug deal.
25. On or about December 24, 2006, In the District 01 South Carolina, the
Delendant, KARISH MALI BROWN, alkl. KB, fired. number of shots at a
group of individuals.
Defendant, TORREAN ANTWON SIMS, alkla Slim, alkla Arsonist, called an
associate to discuss the robbery of a drug dealer.
27. On or about December 30. 2006. in the District of South Carolina,
Defendants, DAVID ANDREA JENKINS, a/kIa Arm. G, alkJa Dread, and
TORREAN ANTWON SIMS, a/kIa Slim, a/kIa Arsonist, used a telephone to
discuss USN/Bloods Street Gang business.
28. On or about December 31 , 2006, in the District of South Carolina,
Defendant, JARIUS OCTAVIS JONES, a/kIa Buck, called Defendant
TORREAN ANTWON SIMS, alkJa Slim, a/kIa Arsonist, to warn SIMS about
police presence.
29. On or about January 10, 2007, in Ihe District of South Carolina, the
Defendants, DAVID ANDREA JENKINS, alkla Arma G, alkia Dread, and
TORREAN ANTWON SIMS, a/kIa Slim, alkla Monist. used a telephone to
discuss 8 robbery.
30. On Qr about January 2, 2007, In the ~ i s t r i c t of South Carolina, Defendant.
TORREAN ANTWON SIMS, a/kia Slim, alkla Monist, and FRANK
HENDERSON, III, using a telephone, discussed the robberyofa drug dealer.
31. On or about January 3, 2007, in the District of Soulh Carolina, Ihe
Defendant. TORREAN ANTWON SIMS, alkJa Slim, aikia Arsonist, used a
telephone 10 arrange a drug deal.
32. On or about January 4, 2007, in the District of South Carolina, the
Defendants, TORREAN ANTWON SIMS, a/kIa Slim, a/kI. Arsonist, and
23
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21112 Entry Number 3 'SEALED*
24 of 100
FRANK HENOERSON, III, used a tetephone to discuss the robbery of a drug
dealer.
33, On or about January 9, 2007, in the Olstrict of South Carol ina, the
Defendants, TORREAN ANTWON SIMS, a/kJa Slim, a/kJa Arsonist and
TASHANDA NICOLE PARKER, a/kJa Big Mama, a/kJa Big Mama Blood and
unindlcted co-conspirator G.M. used a telephone to discuss having PARKER
hold and store firearms for the USN/Bloods Street Gang.
34. On or about JanlJary 9, 2007, in the Distrid of South Carolina, the
Defendants, TORREAN ANTWON SIMS, a/kJa Slim, a/kla Arsonist and
FRANK HENDERSON, III, used a telephone to discuss the robbery of a drug
dealer.
35. On or about January 10, 2007, in the District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, a/kJa Slim, a/kJa Arsonist, used a
telephone to discuss the actions of minors who were members of the
UBNIBtoods Street Gang.
36. On or about January 11 . 2007, in the District of Soulh Carolina, the
Defendant. TORREAN ANTWON SI MS, alkJa Slim, a/kIa Arsonist. used a
telephone to discuss a planned robbery.
37. On or about January 12. 2007, in the Dislrict of South Carolina, the
Defendants, TORREAN ANTWON SIMS, a/kJa Slim, alkla Arsonist and
FRANK HENDERSON,II I, used a telephone to discuss a drug deal.
38. . ..,u;::ry 20, 2007, in the of South C3iOlina. 1:'19
Defendants TORREAN ANTWON SIMS, alkla Slim, a/k/a Arsonist, MICHAEL
OSHAY LONG, alkla Killer and unindicted co-conspirator G.M. used a
lelephone to discuss a drug deal involving LONG and Defendant TASHANDA
NICOLE PARKER, alkla Big Mama, a/k/a Big Mama Blood.
39. On or about January 26, 2007, In the District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, alkJa Slim, alkla Arsoni st, using
coded language, provided Defendant DAVID ANDREA JENKINS, a/kJaArma
G. a/kla Dread. with a phone number for unlndicted coconspirator James
Powell a/kJa Munchie.
40. On or about January 26, 2007, in the Dislrict of South Carolina, the
Defendant, TORREAN ANTWON SIMS, a/kIa Slim, alkla Arsonist. used a
24
Page
25 of 100
telephone to call a UBNlBtoods Street Gang member in New York to discuss
gang business.
41. On or about January 26, 2007, in the District of South Carolina. the
Defendant, TORREAN ANTWON SIMS, a/kla Slim, alkla Arsonist, called
unindicted coconspirator J.F. to discuss a gang meeting.
42. On or about June 7, 2007, in Ihe District of South Carolina, Ihe
Defendants, NICHOLAS JASON WRIGHT, alkla Tater Head, SHANTANE
SI MMONS, alkla Shantane L. Cran, and KARISH MALI BROWN, alkla KB,
illegally possessed a firearm and also possessed a quantity of cocaine base
(commonly knovm as "crack- cocaine) with the intent to distribute.
43. On or about June 24, 2007, in the District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, aJ'rJa Slim, aJ'rJa Arsonist, attempted
to obstruct iustice by writing a letter 10 J.F. attempting to persuade J.F. to
provide false informalion and testimony to law enforcement officials.
44. On or about August 6, 2007, in the District of South Carolina, the
Defendanls, TYRONE LEWIS, aJ'rJa Ty Ty and MICHAEL OS HAY LONG,
aJkJa Killer. using firearms, murdered a member of a rival gang.
45. On or aboul August 25, 2007, In Ihe District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, aJ'rJa Slim, alkla Arsonist, attempted
to obstruct justice by writing a letter to G.M. atlempting to persuade G.M. to
provide false informalion and testimony to law enforcement officials.
46. On or about September 15, 2008, in the District of South Carolina, the
Defendants, ANTWAIN EMANUEL BRISBON, alkia Tweeze, aJ'rJa Twan G
and TASHANDA NICOLE PARKER, aJ'rJa 81g Mama, aJ'rJa Big Mama Blood,
converted powder cocaine imo cocaine base (commonly known as crack"
cocaine) by cooking approximately 1 0 ounces of cocaine in the kitchen of
BRISBON's apartment .
47. On or about September 29, 2008, In Ihe District of South Carolina, the
Defendant, BRANDON DESHAWN HAWKINS, SR., alkla Shotgun, alk/a
Gun, assaulted a victim while committing a robbery al1529 Ka1hleen Drive,
Columbia, South Carolina.
2S
Page
26 of 100
48. On or about April 7, 2009, in the District of South Carolina, the Defendant,
NATHANIEL JAMAL FARMER, a/ltJa Gucci, possessed cocaine base
(commonly known as cocaine) wilh intent to distribute.
49. On or about July 1, 2009,'in the District ot South Carolina, the Defendants,
NATHANIEL JAMAL FARMER, a/kIa Gucci and ODEll MARTIN, JR., a/kIa
Teazy, possessed cocaine base (commonly known as cocaine) with
intent to distribute.
50. On or about February 23, 2011, in the District of South Carolina, the
Defendant, KARISH MAU BROWN, a/kIa KB, pointed a firearm at another
person and threatened to shoot said victim.
51. On or about March 16,2011, in the District of South Carolina, the
Defendant, EDMOND LEVY JR.. alk/a Southside, possessed marijuana with
intent to distribute.
52, On or about March 23. 2011, in the District of South Carolina, the
Defendants, TrrUS WILL BOWMAN, a/kIa TI. and DARRELL ANTONIO
ALSTON, a/kJa Hell Rell, used a telephone to discuss thei r plan to have
USN/Bloods Street Gang members conduct a series of armed robberies
involving home invasions.
53. On or about April 8, 201 I , in the District of South Carolina, the
Defendants, TrrUS WILL BOWMAN, a/kIa TI, CRAIG XAVIER ALSTON,
a/kIa CK, DARRELL ANTONIO ALSTON, a/kJa Hell Rell, BRANDON
DESHAWN HAWKINS, SR., alkJa Shotgun, a/kIa Gun, and KENNETH ROY
COTTOY, aJ'rJa a!kla afk!a Kappone. discussed their 10
have UBN/Bloods Street Gang members commit an act of vtolence. During
the di scussions, BOWMAN illegally possessed and handled a firearm.
54. On or about April 14, 201 1, in the District of South Carolina, the
Defendant, lYRONE LEWIS, a/kIa 'Ty Ty', called Defendant TITUS WILL
BOWMAN, a/kJa TI , to discuss communications between Defendant
NICHOLAS JASON WRIGHT, alkla Tater Head, and a person who lEWIS
believes to be an informant. LEWIS told BOWMAN thai he (LEWIS) intended
to rob and kill the suspected informant when he (LEWIS) was released from
state prison and BOWMAN should not be telling the suspected informant
about LEWIS' Intentions.
26
Page
27 of 100
55. On or about Aprtl 24. 2011. in the Dislrict of SouU, Carohna, the
Defendant, TYRONE LEWIS, a!Kla TV Ty, called Defendant TITUS WilL
BOWtMN, alk/a TI, to discuss LEWIS' plans to retaliate against a suspected
informant. LEWIS also discussed his concerns that Defendant NICHOLAS
WRIGHT, a/kJa Tater Head, was spreading "false propaganda" about him,
thai WRIGHT was a potenlial rat" and that LEWIS Inlended to assault
WRIGHT when he (LEWIS) was released from prison.
56. On or aboul April 26, 2011, in the Districl of South Caroltna, Ihe
Defendanl, TYRONE LEWIS, a/1<Ja TV TV, called Defendant TITUS WILL
BOWrvtAN, aJkJa TI, and the two discussed tampering with and altering
evidence in a criminal case.
57. On May I, 2011. in the Dislrict 01 South Carolina, the Defendanl
TYRONE LEWIS, a/1<Ja TV Ty, called Defendant DAVANTE HENRY
CHRISTOPHER LANE, alk/a Lil 0, to discuss Defendant TITUS WILL
OOWMAN's, a/1<Ja TI, performance as a leader of Ihe USN/Sloods Sireet
Gang and LEWIS' stalus in the gang.
58. On or about May 10, 2011 , in the District of South Carolina, the
Defendanl JAMES E. LONDON, alkJa Prince, a/1<Ja Rockaroni, directed a
prostitute. in his employ to assault and rob another person and -break that
bttch for my money."
59. On or about May 1 0, 2011, In the District of South Carolina, the
Defendant, DAVANTE HENRY CHRISTOPHER LANE, a/1<Ja Lil 0 called
Defendant JAMES E. LONDON. alkJa Prince, a/kJa Rockaroni, to discuss their
prostitution business and an upcoming trip to further that business. LANE lold
LONDON that he was concerned because he wanted to take some drugs on
the trip, wanted a prostitute to carry the drugs in a body cavity and was
worried about the size of the package containing the drugs. LONDON lold
LANE that he would show LANE how to pack the drugs tightly In tlte shape of
a pool ball so the drugs could be carried ~ j a i l house status:
60. On or about May 12, 2011, in the District of South Carolina, the
Defendant, TITUS WILL BOWMAN. alkla TI, called TORREAN ANTWON
SIMS, alk/a Slim, aIkla Arsonist, for the purposes of scheduling a meeting to
discuss the Columbia operations of the USN/Bloods Street Gang.
61 . On or about May 15, 2011, in the District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, alkla Slim, alkJa Arsonisl, called
27
Page
Date Filed 06/21112 Entry Number 3 SEALED*
28 of 100
TITUS Wtll BOWMAN, all<Ja Tt, and both, using coded tanguage, discussed
gang activities and the conduct of Defendant ANDRE JAMEl CUMMtNGS,
alkJa Ore.
62. On or about May 19, 2011, in the District of South Carotina, the
Oefendant, TORREAN ANTWON StMS, all<Ja Stim, all<Ja Arsonist, called
TITUS Wtll BOWMAN, all<Ja Tt , for the purposes of coordinating a meeting
between UBNlBloods Slteet Gang Members in Columbia and members 01
other UBN/Bloods Street Gang sets,
63. On or about May 20, 2011, In the District of South Carotina, the
Defendants TrrUS WilL BOWMAN, alkJa TI. CRAIG XAVIER ALSTON, all<Ja
CK and DARRELL ANTONIO ALSTON, all<Ja Hell. Rell, and other members
01 the UBN/Bloods Slreet Gang lraveled from Columbia, South Carolina, to
North, South Carolina, for a gang meeting as arranged by Defendant
TORREAN ANTWON SIMS, all<Ja Slim, all<Ja Arsonist.
64. On or about May 23, 2011, In the District of South Carolina, lhe
Defendants, TITUS WILL SOWMAN, alkJa TI and STEWART JAMAUL
STROMAN. a/kJa Stew, discussed a planned robbery of a group of drug
dealers.
65. On or about May 26, 2011 , in the Di strict of South Carolina, the
Defendant, TORREAN ANTWON SI MS, all<Ja Slim, all<Ja Arsonist, called
Defendant TITUS WILL BOWMAN, alkJa TI, to discuss USN/Bloods Street
Gang business and SIMS' desire to arrange 3 personal meeting because
SIMS was concerned that his phone W3S tapped.
66, On or about May 28, 2011, in the District of South Carolina, the
Oelendants, ANDRE JAMEL CUMMINGS, all<Ja Dre and STEPHEN
BENJAMIN BRADLEY, alkJa Red Boy, robbed another individual.
67. On or about May 29, 2011, in the District of South Carolina, the
Delendant, TORREAN ANTWON SIMS, all<Ja Slim, a/kJa Arsonist, laid
DefendantANDREJAMEL CUMMINGS, all<Ja Dre, that CUMMINGS needed
to pay SIMS some "baby love" Irom the proceeds of the robbery on May 28,
2011.
68. On or about May 29, 20t I , in the District of South Carolina, the
Defendant, TORREAN ANTWON SIMS, alkJa Slim, all<Ja Arsonist, told
Oelendant ANDRE JAMEL CUMMINGS, a/k/a Ore, that CUMMINGS needed
Page
Date Filed 06/21/12 Entry Number 3 'SEALED*
29 of 100
to advise UBN/Bloods Street Gang members in Columbia that they needed
to pay SIMS some "baby love- and from the proceeds of their Illegal
activities.
69. On or aboul June 6, 2011, in the District of Soulh Carolina, in the District
of South Carolina, the Defendanls, NICHOLAS JASON WRIGHT, aIkIa Taler
Head and STEWART JAMAULSTROMAN, ali<Ja Stew, robbed and assaulted
a rival gang member.
70. On orabaut June 6, 2011, in the DisLrict of South Carolina. the Defendant ,
TORREAN ANTWON SIMS, aIkIa Slim, alkJa Arsonist, called Defendant
ANDRE JAMEL CUMMINGS, alkla Dre, to discuss UBNlBloods Street Gang
business and CUMMINGS discussed the need 10 have lower ranking
members pay -homage".
11. On 0( about June 9. 2011 in the District of South Carolina, the
Defendants, TITUS WILL BOWMAN, ali<Ja Ti l NICHOLAS JASON WRIGHT,
aIkIa TaterHead and STEWART JAMAULSTROMAN, alkla Stew, discussed
WRIGHT'S ptan to shoot a person who WRIGHT believed had verbally
"disrespecled" WRIGHT.
72. On or aboulJune 9,201 t in the District of South Carolina, the Defendanl,
TORREAN ANTWON SIMS, aIkIa Slim. alkJa Arsonist, used a telephone 10
brag about his past use of guns and his involvement in shoolings and further
told Delendants DARRELL ANTONIO ALSTON, aIkIa Hell Rell , Ihal he
(SIMS), ALSTON and Defendant TITUS WILL BOWMAN, alkJa TI, needed to
meet 10 discuss discipline, the activilies of other gang members, and the fl aw
of -Baby to certain gang members.
73. On or aboul June 11, 2011, in Ihe Dislrict of South Carolina, the
Defendanl, TITUS WILL BOWMAN, alkJa n, called TAMEKA DANI ELLE
SMITH, a/kIa Meka, in an effort to ascertain the localion of a UBNlBloods
Sireel Gang member Defendant CHRISTEN MICHELLE SPENCER who was
allegedly improperly associating with a rival gang.
Defendant, TITUS WILL BOWMAN, aIkIa TI. called Defendanl HASSAAN R.
BROWN, a/kJa Hos.y, 10 discuss BOWMAN'S plan to harm members of a
rival gang as well as Defendant CHRISTEN MICHELLE SPENCER.
Page
3:12-cr-OOS13-CRI *SEALED'
30 of 100
75. On or about June 11. 2011. in the District of South Caroflna. the
Defendant. TITUS WILL BOWMAN, al'rJa Tt, called Defendant BRANDON
DES HAWN HAWKINS. SR.. al'rJa Shotgun. al'rJa Gun. to give HAWKINS the
-green light- to murder members of a rival gang.
76. On or about June 11. 2011. in the District of South Carolina, the
Defendants. TITUS WILL BOWMAN. a/KIa TI and SHANTANE SIMMONS.
alkJa Shantane L Craft, discussed their plan to assautt Defendant CHRISTEN
MICHELLE SPENCER
77. On or about June 11.2011, in Ihe District of South Carolina, the
Defendant. TORREAN ANTWON SIMS. al'rJa Slim. alkla Arsonist . called
Defendant TITUS WILL BOWMAN, alkla n. to discuss how to manage the
UBNfBloods Street Gang. and how to use violence and other means to gain
respect in the streets and that BOWMAN needed to look at the bigger picture.
78. On or about June 12. 2011. in the District of South Carolina. the
Defendant JOSHUA ALEXANDER Km, al'rJa Metro. called DAVANTE
HENRY CHRtSTOPHER LANE, al'rJa Lit 0 and told LANE that he (KITT) had
just robbed a drug dealer and needed some assistance in selling a pound of
marijuana.
79. On or about June 12, 2011 , in the District of South Carolina. the
Defendant. TITUS WILL BOWMAN, alki TI. called Defendant TORREAN
ANTWON SIMS, a/kIa Slim, alkJa Arsonist. to discuss the shooting of
Defendant HASSAAN R BROWN. alk/a Hossy, and SIMS cautioned
BOWMAN regarding using the telephone to discuss gang business.
80. On or about June 14. 2011, in the District of South Carolina. the
Defendants, ANDRE JAMEL CUMMINGS, alkJa Ore and NtCHOLAS JASON
WRIGHT. a/k/a Tater Head. di scussed their concerns that an Informant had
infiltrated the USN/ Bloods Street Gang and WRIGHT further indicated his
intention to Identify and harm the alleged informant
81. On or about June 14, 2011. in the District of South Carolina, the
Defendants, TITUS WILL BOWMAN, alkla TI and NICHOLAS JASON
WRIGHT. alkla Tater Head, discussed their concerns that an informant had
infiltrated the UBN/Bloods Street Gang and BOWMAN offered to supply
WRIGHT wilh a firearm.
30
Page
31 of 100
Defendants, ANDRE JAMEL CUMMINGS, a/kla Ore, and STEVEN
BENJAMIN BRADLEY. aI'KIa Red Boy. discussed a planned home Invasion.
83. On or about June 19, 2011 , In the District of South Carolina, un/ndictcd
co-conspirator Samantha Williams called Defendant DAVID ANDREA
JENKINS, aJkIa Arma G, aJkIa Dread, 10 pass on advice from unlndicted co-
conspirator Daryl Wilkinson, a/k/a OG Powerful. concerning UBNlBfoods
Street Gang operations, leadership and actllilties. Samantha Williams told
JENKINS that Wilkinson would not bless JENKINS's request to kill or harm
another member of the UBNlBloods Street Gang, and that Wilkinson wanted
JENKINS and the other member to work out their differences and/or fly to
New York and meet with Wilkinson in prison.
Defendants, TITUS WILL BOWMAN, aJkIa TI. CRAIG XAVIER ALSTON,
alkla CK, DARRELL ANTONIO ALSTON, alkla Hell Rell, NICHOLAS JASON
WRIGHT, aJkIa Tater Head, and STEWART JAMAUL STROMAN, aJkIa Stew,
used telephones to discuss their plan to order drugs from a drug dealer and
then rob said drug dealer.
Defendant, DAVID ANDREA JENKINS, aJkIa Anna G, alkla Dread, called
Defendant JARIUS OCTAVIS JONES, alkla Buck, to discuss new
UBNIBIoods Street Gang "wisdom" to be provided to in full to Defendant
TORREAN ANTWON SIMS, alkla Slim, alkJa Arsonist and in part to other
USN/Bloods Street Gang members if! Columbia.
86. On or about June 23, 2011, in the Dtstrict of South Carolina, the
Defendant, DAVID ANDREA JENKINS, aJkIa Alma G, aJkIa Dread, used a
telephone to give advice and counsel to Defendant JARIUS OCTAVIS
JONES' alkla Buck, sisler concerning her involvement in the G ~ S h i n e sel of
the UBN/Bloods Street Gang.
87. On oraboutJuly 10, 2011, in Ihe DistrictofSoulh Carolina, the Defendant,
DAVID ANDREA JENKINS, aJkIa Arma G, alkla Dread, used a telephone to
discuss his concerns about the associations between active USN/Bloods
Street Gang members in COlumbia and Blood Street Gang members who
were due 10 be released from prison and who had previously cooperated with
the Federal Bureau of Investigation. JENKINS indicated that he did not want
to associate with any "snltches and was pleased that Defendant TORREAN
31
Page
3:12-cr-OOS13-CRI 'SEALED*
Date Filed 06/21/12 Entry Number 3 *SEALED'
32 of 100
ANTWON SiMS, aJkJa Slim. a1kJa Arsonist, had refused to cooperate with law
enforcement and that SIMS controlled the activities other UBN/Bloods Street
Gang members housed with SIMS in federal prison.
88. On oraboutJuly 16,2011, in the District of South Carolina, the Defendant,
DAVID ANDREA JENKINS, aI'KIa Arma G, alk/a Dread, called Defendant
JARIUS OCTAVIS JONES, aI'KIa Buck, and provided directives concerning
the initiation of new UBNIBJoods Street Gang members in Soulh Carolina.
89, On or about September 19, 201 1, in the District of South Carolina, the
Defendant, ANTWAIN EMANUEL BRISBON, alkla Tweeze, alk/a Twan G,
threatened another person with bodily harm in an attempt to persuade that
person to claim responsibility for the cocaine base (commonly known as
"crack- cocaine) seized from BRISBON on December 14,2010,
All in violation of TItle 18, United States Code, Section 1962(d) and
1963(a).
32
Page
3: 12-cr-OOS13-CRI *SEALED* Date Fil ed 06/21112 Entry Number 3 *SEALED* Page
33 of 100
VIOLENT CRIMES IN AID OF
RACKETEERING
(VICAR)
Counts 2 through 9
33
3:12-cr-OOS13-CRI'SEALED'
Date Filed 06/21/12 Entry Number 3 'SEALED'
34 of 100
COUNT2
THE GRANO JURY FURTHER CHARGES:
1. The allegations made in Paragraphs 1-19 of Count 1 of this Indictment are
hereby realleged and incorporated by reference herein.
2. The defendants charged betow, together with all other defendants cha'lled
in Count 1 of thi s Indictment, were members and associates of the USN/Bloods
Street Gang, a criminal organization whose members and associates engaged in
various criminal activities, including but nol limited to: (1) narcotics trafficking: (2)
crimes of violence including but not limited 10 murder, kidnaping. armed robbery,
and aggravated assault: (3) wire fraud; and (4) offenses involving prostitution.
3. This criminal organization, the UBNlBloods Street Gang. including its
leadership, membership and associates, constituted an enterprise as defined in Title
18, United States Code. Section t 959(b)(2), that is, a group of Individuals associated
USN/Bloods Street Gang enterpri se constituted an ongoing organization whose
members functioned as a continuing unit for a common purpose of achieving the
objectives of the enterprise.
4. The above-named enterprise, through its members and associates.
eng.ged In racketeering activity as defined in Tille 18, United States Code, Sections
1959(b)(1) and t 961(1), namely acls involving:
34
Page
3:12-cr-00513-CRI *SEALED* Date Fi led 06/21112 Entry Number 3 *SEALED*
35 of 100
South Carolina Slate Law:
a. Murder. in viola lion or Ihe Code of Laws of Soulh Carolina (S.C.
Code) Sectlonsl6-3-10. 16-3-29;
b. Distribution, Possession with Intent to Distribute and Trafficking
in Controlled Substances, In violation of S.C. Code Sections 44-
53-370 and 375;
c. Robbery, in violation of South Carolina common law and S.C.
Code Sections 16-11-325 and 16-11-330;
Federal Law
a, The felonious distribution, receipt, concealment, buying, selling
and otherwise dealing in conlJolJed substances, including
cocaine, cocaine base (commonly known as "'crack- cocaine),
man luana, heroin and other controlled substances, in violation of
21 U.S.C. Sections 841 and 846;
b. Multiple acts indictable under the following provisions of Title 18,
United States Code including:
1. Sections 1503 and 1512 (relating to obstruction of justice
and witness tampering);
2. Section 1951 (relating to interference with commerce by
robbery and extortfon).
5. That on or about November 25, 2009, in the District of South Carolina. the
Defendants. DARRELL ANTONIO ALSTON. a/kla Hell Roll , and TEVIN DESHANE
RAMSEY, aIkIa P.T., as principals, aiders and abettors and as coparticipants in
jointly undertaken criminal activity. for the purpose or maintaining and
positions in the UBN. also known as the Bloods Street Gang, an enlerprise engaged
:;5
Page
36 of 100
in racketeering activity, did commit and attempt to commit an assault on another
person using a dangerous weapon, that is. a firearm. said assault also constituting
assault and battery wi th intent to kill in violation ofSoulh Carolina Code Sections 16-
3-620 and 16-3-210;
2.
In violalion otTilie 18, Uniled States Code, Sections 1959(a)(3) and (a)(6) and
COUNT 3
THE GRAND JURY FURTHER CHARGES:
1. The allegations made in Paragraphs 1-19 of Count 1 of thi s Indictment and
Paragraphs 1-4 of Count 2 of this Indictment are hereby real!eged and incorporated
by reference herein.
2. That on or about March 7, 2010, in the District 01 South Carolina, the
Delendant. TITUS WILL BOWMAN, all<la TI, lor the purpose 01 maintaining and
increasing position in the USN, also known as the Bloods Street Gang. an enterprise
engaged in racketeering activity. did commit and attempt to commit an assault on
another person using a dangerous weapon, that is, 3 firearm, resulting in serious
bodily injury, said assault also constituting assault and ba1tery of a high and
aggravated nature in violation of South Carolina Code Section 17-25-30 (common
law);
In v;olat;on ofTilie 18, United Slates Code, Sections 1959(a)(3) and (a)(6) and
2.
36
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21112 Entry Number 3 *SEALED*
37 of 100
1. The allegations made in Paragraphs 1-19 01 Count 1 01 this Indictment and
Paragraphs 1-4 of Count 2 of this Indictment are hereby realleged and incorporated
2. That on or about March 9, 2010, in the District of South Carotina, the
Defendants, TITUS WILL BOWMAN aIkla TI. and DEGREGORY REAVES, alkla
Junior, as principals, aiders and abettors and as co-participants In joi.nUy undertaken
criminal activity. for the purpose of maintaining and Increasing positions in the USN I
also knO\,'m as the Bloods Street Gang, an enterprise engaged in racketeering
activity. did commit and attempt to commit an assault on another person lIsing a
dangerous weapon, that is. a firearm, said assault also constituting assault and
battery with intent to kill in violation of South Carolina Code Sections 163-620;
In violation otTilie 18, United States Code, Sections 1959(a)(3)and (a)(6)and
2.
)7
Page
38 of 100
COUNTS
1. The allegations made in Paragraphs 1-19 of Count 1 of this Indictment and
2. That on or about March 10,2010, in the District of South Carolina, the
Defendants, SHANTANE SIMMONS. aIkIa Shantane L Craft. and CHRISTEN
MICHELLE SPENCER. as prinCipals. aiders and abettors and as co-participants in
organized criminal activity. tor the purpose of maintaining and increasing positions
in the UBN, also known as the Bloods Street Gang, an enterprise engaged in
racketeering activity, did commit and auempt to commit an assault on another
person using a dangerous weapon, that Is, a beer bottle. resulting in serious bodily
injury, said assault also constituting assault and battery of a high and aggravated
nature in violation of South Carolina Code Section 17p25-30 (common law);
If'; Vi ulu!::.m ofTinc 13, Uniled SICi tes Coda. Section3 19S9(a}(3) cmd laKe} and
2.
38
Page
39 of 100
1. The allegation. made In Count 1 of this Indictment and Paragraphs 1-4 of
Count 2 of this Indictment are hereby realleged and incorporated by reference
herein.
2. That on or about June 20, 2010, in the District of South Carolina. the
Defendants, TITUS WILL BOWMAN, a1kJa TI. CRAIG XAVIER ALSTON, a1kJa CK
and BRANDON DESHAWN HAWKINS, SR., a1kJa Shotgun, a1kJa Gun, as
principals, aiders and abettors and as coparticipanls In organized criminal activity.
for the purpose of maintaining and Increasing posilions in the UBN, also known as
the Bloods Street Gang. an enterprise engaged In racketeering activity, did commit
and attempt to commit an assault on another person using a dangerous weapon,
that is, a firearm, said assault also constituting attempted murder and assault and
battery in the first degree In violation of South Carolina Code Sections 16-3-29 and
16-3-600;
In violation of Tille 18, Uniled Stales Code, Sections 1959(a)(3) and (a)(6) and
2.
.1Q
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 'SEALED*
40 of 100
COUNT?
1. The allegations made in Paragraphs 1-19 of Count 1 of this Indiclmentand
2. That on or about July 22, 2010, in the District of South Carolina, the
Defendant, JOSHUA ALEXANDER KITT, alkla Metro, for the purpose of maintaining
and increasing position in the UBN, also known as the Bloods Street Gang, an
enterprise engaged in racketeering activity, did commit and attempt to commit an
assault on another person using a dangerous weapon, that is, a firearm, said assaurt
also constituting attempted murder and assault and battery in the first degree in
vialalion of South CaroHna Code Sections 163-2,9 and 16,3..600:
:i"i 13, UniteU St.;res Code, SecliOi'i5 "I SS9(a}(3) ana (a)(G) and
2.
40
Page
41 of 100
COUNT 8
1. The allegations made in Paragraphs 1-19 of Count 1 oftl1is Indiclmentand
Paragraphs 1-4 of Counl2 of this Indictment are hereby realleged and incorporated
by reterence herein. The scope of the racketeering activity engaged in by the
members and associates ofthe USN/Bloods Street Gang expanded during the time
period alleged in Count 1 and. as of 201 1. the enterprise (through its members and
associates) was also engaged In racketeering actrvlty that included acts indictable
under. (a) 18 U.S.C. Section1343 (related to wire fraud) : (b) 18 U.S.C. Section1591
(related to sex trafficking): (c) 18 U.S.C. SecUon 1952 (relating to interstate travel in
aid of racketeering): and (d) 18 U.S.C. Sections 242 1 and 2422 (related to interstate
transportation for prostilution).
2. That on or about May 9, 2011 in the District of South Carolina, the
Ddefendants, TITUS WILL BOWMAN. afkJa II. cRAIG XAVI ER ALSTON, afkla CK,
DARRELL ANTONIO ALSTON, a/kJa Hell Rell, and TAMEKA DANIELLE SMITH.
afkla Meka, as principals, alders and abeHors and as co-participants in jointly
undertaken criminal activity. for the purpose of maintaining and increasing position
in the USN. also known as the Bloods Street Gang, an enterprise engaged in
racketeering activity. did attempt and conspire to kill and murder two persons Wl lh
malice aforethought, in violation of South Carolina Code Sections 16-3-10, 16-3-29
and 16-17-410.
In vielation ofTitie 18, United States Code, Sections 1959(a)(5) and 2.
~ I
Page
42 of 100
COUNT9
1. The allegations made In Paragraphs 1-19 of Count 1 of this Indictmenl,
Paragraphs 1-4 of Count 2 of Ihis Indictment and Paragraph 1 of Count 8 of this
Indictment are hereby realleged and incorporated by reference herein.
2. That on or about March 16, 2012, in the District of Soulh Carolina, the
defendant, JOSHUA ALEXANDER Kin, aJkJa Metro, as a principal, aider and
abettor and as a co-participant in jointly undertaken criminal activity. for the purpose
of maintaining and increasing position in lhe UBN, also known as the Bloods Street
Gang, an enterprise engaged in racketeering activity, did kidnap another person with
the intent to force and coerce that person to commit a commercial sex aCI. in
violation of South Carolina Code Seclion 16-3-910;
In .... iolation cf Title 18. Uiiitad States Code, Sections 19b9(a}{1) and 2.
42
Page
3:12-cr-00513-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED* Page
43 of 100
OFFENSES RELATING TO
DRUG DEALING AND
DISTRIBUTION
(Title 21 Offenses)
Counts 10 through 83
43
3:12-cr-00513-CRI *SEALED* Date Filed 06/21112 Entry Number 3 *SEALED*
44 of 100
COUNI10
That beginning in or around 2003, and continuing thereafter, up to and
including the date ofthis Indictment, in the District of South Carolina and elsewhere,
the Defendants, DAVID ANOREA JENKINS, aIkIa Arma G, aIkIa Dread, TIIUS
WILL BOWMAN, aIkIa II, ANDRE JAMELCUMMINGS, aIkIa Dre, CRAIG XAVIER
ALSTON, aIkIa CK, DARRELL ANTONtO ALSTON, aIkIa Hell Rell , NICHOLAS
JASON WRIGHI, aIkIa Tater Head, STEWART JAMAUl STROMAN, alkla Stew,
NATHANIEL JAMAL FARMER, alkla Gucci, DAVANTE HENRY CHRISTOPHER
LANE, aIkIa Lil D, TASHANDA NICOLE PARKER, alkla Big Mama, aIkIa Big Mama
Blood, JARIUS OCTAVIS JONES, alkla Buck, CALVIN JAMES 11ALL, alkla Kebo,
KENNETH ROY COIIOY, afkla Fish, aIkIa Koppo, aIkIa Kapone, EDMOND LEVY,
JR., aIkIa Southside, ALEX RUSSELL ANDERSON, aIkIa Black, ANIWAIN
EMANUEL BRISBON, .Ikl. T w e e ~ e , afkl. Twan G, ODELL MARTIN, JR., alkla
Teazy, and KARISH MALI BROWN, aIkIa KB, knowingly and intentionally did
combine, conspire, agree and have tacit understanding with each other and others,
both knovm and unknown to the grand jury, to knowingly, intentionally, and
unlawfulfy possess with intent to distribute cocaine base (commonly known as
"crac"''' cocaine). a Schedule II controlled SUbstance. said conspiracy involving 280
grams or more of a mixture and substance containing a detectable amount of
cocaine base, in violati on of 1111e 21, United States Code, Sections 841(a)(1) and

Page
B41(b)(1)(A);
45 of 100
All in violation of Title 21, United Stales Code, Section 846.
COUNTS 11-18
Thai on or about the dates set forth below. in the District of South Carolina,
the Defendants named below. as principals, aiders and abettors and as co-
participants in jointly undertaken criminal activity. knowingly, intentionally and
unlawfully did possess with intent to distribute a quantity of cocaine base (commonly
knovm as "crack" cocaine), a Schedule II controlled substance;
kQ.!,illI DEFENDANTlS) QAIJ;
11 NATHANIEL JAMAL FARMER 04/0712009
13 STEWART JAMAUL STROMAN 11/0112010
14 CALVIN JAMES HALL 03/24/2011
16 KARISH MALI BROWN 06/0112011
17 CRAIG XAVIER ALSTON 0610312011
' 5
Page
3:12-cr-OOS13-CRI 'SEALED' Date Filed 06/21/12 Entry Number 3 'SEALED'
46 of 100
18
TITUS WILL BOWMAN
CRAIG XAVIER ALSTON
DARRELL ANTONIO ALSTON
06/1612011
In vlolaHon of Tille 21, United Slates Code, Sections 841(3)(1) and
841 (b)(l)(C) and Title 18, United States Code, Section 2.
46
Page '
47 of 100
COUNTS 19 - 20
That on or about the dates set forth below, in the District of South Carolina.
the Defendants named below, as prinCipals, aiders and abettors and as
participants in jointly undertaken criminal knowingly and inlentionally did
possess with intent to distribute a quantIty of cocaine base (commonly known as
cocaine), a Schedule II controlled substance, in violation or Title 21 , United
States Code, Section 841 (a), within 1,000 feet of the real property comprising of
Pinehurst Park, said park including a public playground;
19
20
DEFENDANT!SI
ANTWAIN EMANUEL BRISBON
TASHANDA NICOLE PARKER
ANTWAIN EMANUEL BRISBON
0911512008
12114/2010
All invioiationornUe2 1, United States Code, Sections 841(a)(1)and860 and
Title 18, United States Code, Section 2.
Page
3:12-cr-OOS13-CRI 'SEALED' Date Filed 06/21112 Entry Number 3 'SEALED'
48 of 100
COUNTS 21 - 27
That on or about the dates set forth below, in the District of South Carolina,
the Oefendants named below, as prtnclpals, alders and abettors and as co-
participants in joinUy undertaken criminal activity. knowingly, intentionall y and
unlawfully did possess With intent to distribute and did distribute a quantity of cocaine
base (commonly known as "crackw cocaine), a Schedule II controlled substance;
l<Ql.lliI DEfENDANT/S)
.MIf
22 NATHANIEL JAMAL FARMER 03101/201 1
23 DAVANTE HENRY CHRISTOPHER LANE 04/13/2011
24 DAVANTE HENRY CHRISTOPHER LANE 04/1412011
25 DAVANTE HENRY CHRISTOPHER LANE 041261?01 1
26 TAMEKA DANIELLE SMITH 06/0712011
27 DAVANTE HENRY CHRISTOPHER LANE 06/10/2010
MICHAEL ANTONIO TAYLOR
In violation of Title 21, United States Code, Sections 641(a)(1) and
641 (b)(1)(C) and Tille 18, Uniled Slates Code, Section 2.
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED* Page
49 of 100
COUNTS 28 - 32
That on or about Ihe dates set forth below, in the District of South Carolina,
the Defendants named below. as principals, aiders and abettors and as co-
participants in jointly undertaken criminal activity, knowingly and intentionally did
possess with intent to distribute and did distribute a quantity of cocaine base
(commonly known as ~ c r a c k cocaine). a Schedule II controlled substance, in
violalion ofTitie 21, Uniled Siaies Code, Section 841(a), within 1,000 feel oflhe real
property comprising or a housing complex including a protected location, that is, a
playground;
COUNT DEfENOANT{51 DATE LOCATION
28 TITUS WILL BOWMAN 02104/2011 River Oaks Apts.
29 NATHANIEL JAMAL FARMER 02/0412011 Park Apartments
30 NATHANIEL JAMAL FARMER 0310212011 Park Apartments
31 TITUS WILL BOWMAN 03/0212011 River Oaks Apts.
32 TIIIJS WILL BOWMAN 03/2812011 River Oaks Apts.
All in violation o{ Title 21, United States Code, Sections 841 (a)(1).
841 (b)( 1 )(C) and 860.
4'1
50 of 100
Page
COUNTS3LAQ
That on or about the dates set forth below, in the District of South Carolina,
the Defendants named below, as principals, aiders and abettors, and as 0()-
part;cipants in jointty undertaken criminal activity, knowingly, intentionally and
unlawfully did possess with intent to dlstnbute a quantity or man) uana, a Schedule
I controlled substance;
COUNT PEEENDANTm QAIf
33 STEWARTJAMAULSTROMAN 0612312009
34 TITUS WILL BOWMAN 0411112011
SHONTA MARIE HARRISON
3G DAVANTE HFNRY CHR!STOPHER LANE 04/30.12011
37 CHRtSTEN MICHELLE SPENCER 05/1912011
38 HASSAAN R. BROWN 0512712011
DAMEON ANTONIO BURGESS
50
51 of 100
TASHANOA NICOLE PARKER
In violation of Tille 21, United Slates Code, Sections 841(a)(I) and
841(b)(I)(D) and Title 18, United States Code, Section 2.
COUNT 41
That on or about June 1, 2011 , in the District of South Carolina, the
Defendants, OAVANTE HENRY CHRISTOPHER LANE, aMa Lil D, TASHANDA
NICOLE PARKER, alk/a Big Mama, aMa Big Mama Blood, and DAMEON
ANTONIO BURGESS, knowingly, intentionally, and unlawfully did possess with
intent to dishibute a quantity of tablets containing 1-(4.Fuoropheny1) piperazine
(pFPP)(analog of N-Benzylplperazine), 5-Methoxy-N,N-diisopropyltryptamine (5-
MeO-DIPT), CI and 3,4-Methylenedioxypyrovalerone (MDPV), all Schedule I
conlroJled substances;
In violation ofTilie 21, Uniled States Code, Soctions 802(32), 8t3, 841(a)(I)
and 841(b)(I)(C).
51
Page
52 of 100
COUJ:lT 42
That on or about June 2, 2011, in lhe ~ i s t r i c t of South Carolina, the
Defendant, ANDRE JAMEL CUMMINGS, alkJa Ore, knowingly, intentionally, and
unlawfulty did possess with intent to distribute a quantity of tablets containing 1-(4-
Fuorophenyf) piperazine (pFPP)(analog of N-Benzylpiperazine), 5-Methoxy-N,N-
diisopropyftryptamine (5-MeO-DIPT), CI and 3.4-Methyfenedioxypyrovalerone
(MDPy), all Schedule I controlled substances;
In violation olTItie 21, United States Code, Sections 802(32), 813, 841(aXl)
and 841(b)(I )(C).
52
Page
53 of 100
COUNT43
That on or about June 17,2011, in the District of South Carolina, the
Defendants, DAVANTE HENRY CHRISTOPHER LANE. aMa lil D, and
TASHANDA NICOLE PARKER, all<Ja Big Mama. all<Ja Big Mama Blood. knowingly,
intenlionally, and u n l a ~ l J l l y did possess with intent to distribute a quantity of tablets
containing 1-(4-Fuorophenyt) piperazine (pFPP)(analog of N-Benzylpiperazine), 5-
Methoxy-N,N-diisopropyllryptamlne (5-MeO- DIPTJ. CI and 3,4-
Melhylenedioxypyrovalerone (MDPV), all Schedule I controlled substances:
In violalion ofTilie 21, United States Code. Sections 802(32). 813. 841(a)(1)
and 841 (b)(1 )(C).
5;
Page
3:12-cr-00513-CRI *SEALED'
54 of 100
COUNTS 44 -I!!
TtiE GRANO JURY FURTHER CHARGES:
That on or about the dales set forth below, in the District of South Carolina and
elsewhere, the Defendanls li sted below, as principals, aiders and abeno(s and co-
participants injointJy undertaken criminal activity, knowingfy and intentionally did use
a communication facility, that is, a telephone, to facilitate the commission of a felony,
under lhe Conlrolled Substances Acl, 10 wit: (a) conspiracy to distribute and possess
with intent to distribute controlled substances: and (b) possession with intent to
distribute and distribution of controlled substances, said controlled substances
including: (l)cocaine and cocaine base (commonly known as -crack- cocaine) , both
Schedule II controlled substances; and (2) marijuana and heroin, both Schedule I
controlled substances; In violation of Title 21, United States Code Sections
il41(.j(1jand 846:

44 EDMOND LEVY, JR.
45 EOMOND LEVY, JR.
46 CALVIN JAMES HALL
47 NATHANIEL JAMAL FARMER
48 NATHANIEL JAMAL FARMER
49 NATHANI EL JAMAL FARMER
54
RATE
09/2212008
0912312008
03124/2011
03125/2011
0312712011
04/0112011
Page
55 of 100
50
51
52
53
54
55
56
57
58
TITUS WILL BOWMAN 0411112011
TITUS WILL BOWMAN 0411912011
OARRELL ANTONIO ALSTON
TITUS WILL BOWMAN 04124/2011
DAVANTE HENRY CHRISTOPHER LANE 0412512011
KENNETH ROY Conoy
ANDRE JAMEL CUMMINGS
DAVANTE HENRY CHRISTOPHER LANE
CRAIG XAVIER ALSTON
TITUS WILL BOWMAN
TITUS WILL BOWMAN
0510312011
05106/2011
05/0612011
59 DAVANTE HENRY CHRISTOPHER LANE 0510712011
JARIUS OCTAVIS JONES
61 TITUS WILL BOWMAN
CHRISTEN MICHELLE SPENCER
5S
0511912011
Page
56 of 100
62 TITUS Will BOWMAN 0512512011
TAMEKA OANIELLE SMITH
TAMEKA OANIELLE SMITH
HASSAAN R. BROWN
66 KARISH MALI BROWN 0610112011
67 KARISH MALI BROWN 0610112011
ALEX RUSSELL ANDERSON
68 CRAIG XAVIER ALSTON 06/0312011
STEWART JAMAUL STROMAN
69 JOSHUA ALEXANDER Kin 06/0312011
DAVANTE HENRY CHRISTOPHER lANE
TITUS W!LL 8u'.!VMAN
72 KARISH MALI BROWN 06/0412011
74 TITUS WILL BOWMAN 06107/2011
TAMEKA DANI ELLE SMITH
56
Page
57 of 100
76 JOSHUA ALEXANDER KITI 0611212011
DAVANTE HENRY CHRISTOPHER LANE
77 KARI SH MALI BROWN 06/1312011
NICHOLAS JASON WRIGHT
KARISH MALI BROWN
ANDRE JAMEL CUMMINGS
81 CHRISTEN MICHELLE SPENCER 0611812011
TITUS WILL BOWMAN
All in viola lion of Tille 21 , United States Code, Sedion 843(b) and Title 18.
United Slates Code, Seclion 2.
51
Page
3:12-cr-00513-CRI *SEALED* Date Fil ed 06/21/12 Entry Number 3 *SEALED* Page
58 of 100
ARMED ROBBERIES AFFECTING
INTERSTATE COMMERCE
(Hobbs Act)
3:12-cr-00513-CRI 'SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED*
59 of 100
COUNT 82
THE GRAND JURY FURTHER CHARGES'
Thai on or aboul May 23, 2011 , in lhe Dislricl or South Carolina, Ihe
Derendanls, TITUS WILL BOWMAN, a/k1a TI, ANDRE JAMEL CUMMINGS, aJkIa
Ore, NICHOLAS JASON WRIGHT, aJkIa Tater Head, STEWART JAMUAL
STROMAN, a/k1a Stew, and CALVI N JAMES HALL, aJkIa Kebo, as principals, aiders
and abettors ,;md as co--participants in jointly undertaken criminal activity, knowingly
and unlawfully did attempt to obstruct, delay and affect interstate commerce and the
movement of articles and commodities in such commerce by robbery. in that the
Defendants did attempl to use al leasl one firearm 10 unlawfully take property
consisting of money and controlled substances belonging to an individual and
individuals engaged in illegal drug trafficking, from the persons and presence of said
drug trafficker(s) against their will by means of adual and threatened force, violence,
and fear of injury, immediate and future, to their persons;
In violation of Tille 18. United States Code, Sections 1951(a) and 2.
59
Page
60 of 100
COUNT 83
That on or about June 20. 2011. in the District of South Carolina. the
Defendants. TITUS WILL BOWMAN, a1kJa TI. CRAIG XAVIER ALSTON, alkJa CK.
DARRELL ANTONIO ALSTON, alkJa Hell Rell, and NICHOLAS JASON WRIGHT,
alkl3 Tater Head. as principals, aiders and abettors and as co-participants in jolnlly
undertaken criminal activity, knowingly and unlawfully did obstrud, delay. affect. and
attempt to affect interstate commerce and the movement or articles and oommodiUes
in such commerce by robbery. in thal the Defendants used al least one firearm to
unlawfully take property consisting of money and controlled substances belonging
10, and from an individual and individuals engaged in illegal drug Irafflcking, from the
persons and presence of said drug trafficker(s) against their will by means of actual
and threatened force. violence, and fear of injury, immediate and future, to their
persons;
In violation of Title 18. United States Code. Sections 1951(a) and 2,
60
Page
61 of 100
INTERSTATE TRAVEL IN AID OF
RACKETEERING (ITAR), THE
MANN ACT AND OTHER
OFFENSES RELATED TO
PROSTITUTION AND SEX
TRAFFICKI NG
61

Page
62 of 100
COUNT 84
That on or about April 18, 2011, in the District of South Carolina and
elsewhere, Ihe Defendant, JAMES E. LONDON. alk/a Prince. alk/a Rockaroni, as
a principal, aider and abettor, and as a co-participant in jointly undertaken criminal
activity. used a facility in interstate commerce, namely a personal computer with
internet access, and did travel from the state of Georgia to the stale of Soulh
Carolina 10 promote, manage establish. carry on and radlitate the promotion,
management. establishment of unlawful activities, that is. prostitution. in violation of
federal law and the laws of the states of South Carolina and Georgia, and thereafter
performed and attempted 10 perform an act to promote. manage, establish, and carry
on, and to racilitate the promotion, management, establishment and carrying on, of
the aforesaid illegal activities;
In violation ofnUe 18, Uniled Siaies Code. Section 1952(a)(3) and 2.
62
63 of 100
COUNT 85
THe GRANO JURY FURTHER CHARGES.
That between May 2,2011, and May 5, 2011, in the District or South Carolina
and elsewhere, the Defendant, JAMES E. LONDON, aJkJa Prince, alkJa Rockaronl,
- --
as a principal, aider and abettor, and as a co-partidpant in jointly undertaken
criminal activity. used a facility in interstate commerce, namelya personal computer
with internet access, and did travel from the State of South Carolina to the State of
North Carolina to promote, manage, establish, carry on and to facilitate the
promotion, management and establishment of unlawful activities, that is, prostitution,
in violation of federal law and the laws of the slates of South CarOlina and North
Carolina, and thereafter performed and attempted to perform an act to promote,
manage. establish, and carry on, and to facilitate the promotion, management,
establishment and carrying on of, the aforesaid illegal activities;
In violation orntle 1B, Unlled States Code, Section 1952(a)(3) and 2.
6)
Page
64 of 100
COUNT.86
Thatonor about May 7. 201 1, in the Districtof South Carolina and elsewhere,
the Defendant, JAMES E. LONDON, aJkia Prince, aIkla Rock.,onl, as a principal,
aider and abettor, and as a co-partidpant in jointly undertaken criminal activity, used
a facility in interstate commerce, namely a personal computer with internet access,
and did travel from the State of North Carolina to the Stale of South Carolina to
promote, manage, establish, carry on and facilitate the promotion, management and
establishment ofunrawful activities. that is prostitution, in violation of federal law and
the laws of the states of South Carolina and North Carolina. and thereafter
performed and altempled to perform an act to promote, manage. establish, and carry
on, and to facilitate the promotion, management, establishment and carrying on of,
the aforesaid illegal activities:
In violation of Title 18, United States Code, Section 1952(a)(3) and 2.
64
Page
65 of 100
COUNT 87
That on or about May 10, 2011, in the District of South Carolina and
elsewhere, the Oefendants, OAVANTE HENRY CHRISTOPHER LANE, alkla lila,
JAMES E. LONOON, a/kla Prince, alkla Rockaroni, and TYRONE LEWiS, a/kla Ty
Ty. as principals, aiders and abettors, and as co-participants in joinUy undertaKen
criminal activity, used a facihty in interstate commerce, namely a personal computer
with internet access, to promote, manage, establish, carry on and faclhtate the
promotion. management and establishment of unlaYlful activities, that is {1}
prosHtution, in violation of (ederallaw and the IaViS of the State of South Carolina.
and (2) possession with Intent to distnbufe and distribution of narcotics and
controlled substances, in violation of federa! law, and thereafter performed and
attempted to perform an acl to promote, manage. establish, and carry on, and to
facilitate the promotion, management, establi shment and carrying on of. the
aforesaid illegal activities;
in violation otTitie 18, United Slates Code, Sections1952(a)(3) and 2.
Page
66 of 100
COUNT 88
That on or about May 11, 2011, in the District of South Carolina and
elsewhere, the Defendants, OAVANTE HENRY CHRISTOPHER LANE. aMa UI D.
and JAMES E. LONDON, atk/a Prince, aM. Rock.roni. as principals. aiders and
abeHors, and as co-participants in joinUy undertaken criminal activity. used a facility
in interstate commerce, namely a personal computer with internet access, to
promote, manage, establish, canyon and facilitate the promotion. management and
establi shment of unlawful activities, that is (1) prostitution, in violation of federal law
and the laws of the State of South Carolina, and (2) possessIon with intent to
distnbute and distribution of narcotics and controlled substances, in violation of
federal law, and thereafter performed and attempted 10 perform an act to promote.
manage, establish. and carry on, and to facilitate the promotion, management,
establishment and carrying on, of the aforesaid illegal activities;
In vlolalion of Tille 18. Uniled Siaies Code, Seclions1952(a)(3) and 2.
(,(,
Page
3:12-cr-00513-CRI *SEALED* Date Fi led 06/21/12 Entry Number 3 *SEALED*
67 of 100
COUNTB9
That on or about June 9, 2011 , in the District of South Carolina and
elsewhere, the Defendant, JAMES E. LONDON, a/l<Ja Prince, a/l<Ja Rockaroni, as
a principal , aider and abettor, and as a co-participant in jointly undertaken criminal
activity. used a fadlity in Interstate commerce, namely a personal computer with
internet access, and did travel rrom the State of South Carolina to the State of
Florida, 10 promote. manage, establish. carry on and facilitate the promotion,
management and establishment of unlawful activities, that is, prostitution, in violation
of federal law and the laws of the states of South Carolina and Florida, and
ttlereaner performed and attempted to perform an act to promote, manage,
establish, and carry on, and to facilitate the promotion, management, establishment
and carrying on of, the aforesaid illegal activities:
/n vio/allon ofTilie 18, United States Code, Section1952(a)(3),
67
Page
68 of 100
COUNT 90
That on or about November IS, 2011, in the District of South Carolina and
elsewhere, the Defendant, STEWART JAMAUL STROMAN, aJkJa Stew, as a
principal, aider and abettor. and as a co-participant in jOintly t)ndertaken criminal
activity, used a facility in interstate commerce, namely a personal computer with
internet access, to promote, manage, establish, carry on and facilitate the promotion,
management and estabfishmentof unlawful activities, that is prostitution, in violation
of federal law and the laws of the states of South Carolina and Georgia, and
thereafter performed and attempted to pcrtorrn an act to promote, manage,
and carrying on of, the aroresaid illegal activities;
It: .... ic!:::f,on of Tit! c 18,. Ur::tcd State::' Cede, Sccti::m1!l52(Cl )(3t
68
Page
69 of 100
COUNT91
THE GRANO JURY FURTHER CHARGES
That on or about November 18. 2011, In Ihe District of Soulh Carolina and
elsewhere, the Defendant, STEWART JAMAUL STROMAN, a/kla Stew, as a
principal, aider and abettor, and as a coparticipant in jointly undertaken criminal
activity, used a facility in Interstate commerce, namely a personal computer with
internet access, to promote, manage establish, carry on and facilitate the promotion.
management, establishmenlof unlawful activities, that 1$ prostItution, in violation of
federal law and the laws of the slates of South Carolina and Georgia, aoo thereafter
performed and attempted to perfor", an act to promote, manage, establish, and carry
on, and to facilitate the promolion, management, establishment and carrying on of,
the aforesaid illegal activities;
tn violation of Title 18, United States Code, Section19S2(a)(3).
Page
3:12-cr-OOS13-CRI'SEALED'
70 of 100
COUNT92
That on or about November 19, 2011. In the District of South Carolina and
elsewhere, the O.rendant, STEWART JAMAUL STROMAN, alkla Stew, as a
principal , aider and abettor, and as a in organized criminal activity,
used a faality in interstate commerce, namely a personaJ computer with internet
access, to promote, manage. establish. carry on and faCilitate the promotion,
management and establishment of unlawful activities. that is prostitution, in viofation
of federal law and the laws of the slates of South Carolina and Georgia. and
thereafter performed and attempted to perform an act to promote. manage,
and carrying on of, the aforesaid illegal activities;
In violation otTilie 1S, Unih'!Ci Code, SecHcn1952(<:l )(3).
70
Page
71 of 100
That between in or around early Spring, 2011 and late Fall, 2011, in the
District of South Carolina and elsewhere, the Oefendants, STEWART JAMAUL
STROMAN, a/kJa Stew, and JOSHUA ALEXANDER KITT, a/kJa Metro, as principals,
aiders and abettors. and as co-participants in jointly-undertaken crfminal activity, did
knowingly, in and affecting interslate commerce, recruit. entice, harbor. transport.
provide and obtain a minor for the purpose of causing said minor to engage in a
commercial sex act, having had reasonable opportunity to observe said minor and
with knowledge and in reckless disregard 01 the fact that said minor had not obtained
the age of 18 years:
In violation of Tilie 18, United Stales Code, Sections 1591(a)(1), 1591(b)(2),
1591 (c) and 2,
71
Page
72 of 100
COUNT94
The allegaUons contained in Count 93 above are realleged and incorporated
by reference as If fully set forth herein,
Between on or about early Spring, 2011 and late Fall, 2011, In the Distriel of
South Carolina and elsewhere, the Defendants STEWART JAMAUL STROMAN,
alk/a Stew and JOSHUA ALEXANDER KITT, alk/a Metro, as principals, aiders and
abettors. and as co-participants in jointly-undertaken criminal activity, did benefit
financially and by receiving things of value, from participation In a venture involving
the use of a minor in interstate commerce to perform a commercial sex acl. saId
venture being more fully described in Count 93 above, with know/edge and in
reckless disregard of the fact that said minor had not obtained the age of 18 years:
In cfTi!!e 13, I' rtltprl r.n:!r:: , Sec:loiis1591 (a)(2). 1591 (b)(2)
and 2,
7Z
Page
73 of 100
~ O U N T S 95 - 98
Thai on or about the dates sel forth below, in the District of South Carolina
and elsewhere, the Defendants named below, as a principals, alders and abettors,
- - - ~
and as a co-participants in jointly undertaken criminal activity, did transport another
person in interstate commerce for the purposes of prostitution, that Is, with the intent
to cause that Individual 10 engage in sexual acti vi ty for money_
gwttI DEFENDANT QATIi
95 JAMES E. LONDON 04/1812011
98 JAMES E. LONOON 06/0912011
In violation of Ti lle 1 S, United States Code, Section 2421.
73
Page
74 of 100
COUNTS 99 -1 Q2
That on or about U,e dates set rorth below, in the District of South Carolina
and elsewhere, the Defendants named below, did knowingly persuade, induce,
entice and coerce an individual to travel in interstate and foreign commerce to
engage in prostitution and a sexual activity for which said person can be charged
with a criminal offense;
COUNT DEFENDANT QAIE
In violation of TItle 18, United States Code Section, 2422(a)
74
Page
3:12-cr-00513-CRI *SEALED* Date Fil ed 06/21/12 Entry Number 3 *SEALED* Page
75 of 100
TRANSMISSION_AND
SUBMISSION OF FRAUDULENT OF
FALSE TAX RETURNS THROUGH
THE INTERNET
(Wire Fraud)
75
Date Fil ed 06/21/12 Entry Number 3 *SEALED*
76 of 100
COUNT 103
Beginning in or around early 2009, and continuing up to and induding the date
Of this Indictment. in the District of South Carolina and elsewhere. the Defendants.
IITUS WILL BOWMAN, a/kla II, CRAIG XAVIER AlSTON, alkla CK, DARRELL
ANTONIO AlSTON, aIkIa Hell Rell, DAVANTE HENRY CHRISTOPHER LANE,
aIkIa Lil D, TASHANDA NICOLE PARKER, alkla Big Mama, aIkIa Big Mama Blood,
KARISH MALI BROWN, alkla KB, MICHAEL ANTONIO TAYLOR, alkJa Puncho,
SHONTA MARIE HARRISON, aIkIa Ta, RONDA BAKER and DAlON All BOWERS,
knOwingly and intentionally did combine, conspire, agree and have tacit
underslcmding with each other and wi th others, both known and unknown to the
grand jury. to use and cause the use of inters tale wire transmissions to electronically
fife false and fraudulent federal income tax returns in furtherance and execution of
a scheme and artifice to defraud in order to obtain money and prnrerty in t h ~ ferm
of improper lax refunds by means or raise and fraudulent pretenses, representations
and promises, In violation of TItle 1 B, United States Code, Section 1343;
All in violation or TiUe 18, United States Code, Section 1349.
76
Page
77 of 100
COUNTS 104 - 115
1. The Grand Jury realleges and incorporales by reference the allegations
contained in Count 1 of this Indictment and also real1eges and incorporales by
reference l)1e charges made in Count 103 above.
2. On or about the dates set forth below, in the District of South Carolina and
elsewhere, the Defendants named below, as principals, aiders and abettors and as
co-participants in jainlly undertaken criminal activity. for the purpose of executing a
scheme and artifICe to defraud and to obtain money by false and fraudulent
pretenses through the electronic filing of false and fraudulent federal tax
relums with the Internal Revenue Service knowingly transmitted and caused to be
transmitted said fraudulent lax relums in interstate commerce by means of wire
communications from South Carolina to the Internal Revenue Service as set forth
below:
COIlliI
104
105
DAION ALI BOWERS
OAION ALiBOWERS
77
E-FILING QAT!;.
02122/2011
0312112011
Page
3:12-cr-00S13-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED-
78 of 100
106 DAION AU BOWERS 03127/2011
RONDA BAKER
107 DAION ALI BOWERS 04/0712011
TITUS WILL BOWMAN
lOB DAION All BOWERS 04/1312011
109 DAION All BOWERS 04/1612011
KARISH MALI BROWN
110 DAION AU BOWERS 05/2512011
DAVANTE H. C. LANE
111 DAION All BOWERS 06/04/2011
CRAIG XAVIER ALSTON
112 DAION ALI BOWERS 06/ 101201 1
113 DAION AU BOWERS 06/30/2011
114 DAION All BOWERS 06130/2011
CRAIG XAVIER ALSTON
115 DAlON ALI BOWERS 07/0612011
In Violation of Trlle 18, United States Code. SecUon 1343 and 2.
7H
Page
79 of 100
FEDERAL FIREARMS
OFFENSES
7 ~
80 of 100
COUNT 116
Thalon or about March 7. 2010. in the District of South Carolina, the
Defendan!. TITUS WILL BOWMAN, a/kIa II, as a principal, aider and abetlor and
as a co-participant in jointly undertaken criminal activity, knowingly did possess a
firearm in furtherance of a crime of violence which is prosecutable In a court of the
United States and in the course of committing thi s violation, the Defendant did
discharge the fi rearm;
In violalion otTilie 18, United States Code, Sections 924{c), 924{cX1XA){iii)
and 2.
COUNT 117
That on or about March 9, 2010, in the Dlstricl of South Carofina, the
Defendants, TITUS WILL BOWMAN, alkJa II, and DEGREGORY REAVES, a/kIa
Junior, as principals, aiders and abettors and as co-participants in jointly undertaken
criminal activity, knowingly did possess a fireann in furtherance of a crime of
vIolence which is prosecutable in a court of the United States and in the course of
committing this vi olation, (he Defendants did dischCJrge the firearm;
In violation of Tille 18, United States Code, Sections 924{c), 924 (c){1 )(A){iii)
and 2.
80
Page
81 of 100
That on or about June 20. 2010. in the ~ i s t r i c t of South Carolina, the
Defendants, TITUS WILL BOWMAN. alkJa Tr. CflA.lG XAVIER ALSTON. alkJa CK
and BRANDON OESHAWN HAWKINS, SR.. alkJa Shotgun. alkJa Gun. as
principals, aiders and abettors and asa co-participants injointJy undertaken criminal
activity, knowingty did possess a firearm in furtherance of a crime of violence which
Is prosecutable In a court of the United States, and in the course of committing this
violation, the Defendants did discharge the firearm;
In violation of TrUe 18, Uniled Stales Code, Sections 924(c). 924(c)(1 )(A)(iii)
and 2.
Page
82 of 100
That on or about July 22. 2010. irr the District of South Carolina, the
Defendant, JOSHUA ALEXANDER KITT, alkJa Melro, as a pri ncipat, aider and
abettor and as a co-participant in jointly undertaken criminal activity, knowingly did
possess a firearm in furtherance of a crime of violence which is prosecutable in a
court of the United States, and In Ihe course of committing this violation, the
Defendant did brandish the firearm;
In violation of ntle 18, Uniled Slales Code, Sections 924(c),
924(c)(1 )(A)(Ii)and 2.
COUNT 1 ~ . 9 .
That on or about December 14, 2010, in the District of South Carolina, the
Defendant, ANlWAIN EMANUEL BRISBON, alkJa Tweeze, a/k/a Twan G, as a
principal, aider and abettor and as a co-participant in Jointly undertaken c,;rrtinal
activity. knowingly did possess a frrearm in furtherance of drug 1raffJcking crimes
which are prosecutable in a court of the United States;
In violation of Titl e 18, United States Code, Sections 924(c) ar'KI 2.
82
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21/12 Entry Number 3 *SEALED'
83 of 100
COUNT121
That on or about March 31 . 2011 . in the District of South Carolina. the
Dj!tendanl NATHi\NIEL JIWAL FARMER. alkla Gugcl. a and
abettor and as a coparticipant in jointly undertaken criminal activity. knowingly did
possess a fireann in furtherance of drug trafficking crimes which are prosecutable
In a court of the United States;
In violation of ntle 18. United States Code. Sections 924(c) and 2.
i J
Page
84 of 100
COUNT 122
That on or about June 20. 2011, in the District of South Carolina, the
Defendants, TITUS WILL BOWMAN, a/kJa n, CRAIG XAVIER ALSTON, afkla CK,
DARREll ANTONIO ALSTON, alk/a Hell Rell, and NICHOLAS JASON WRIGHT,
a/kla Tater Head. as principals, aider, and abettors and as coMparticipants in jointly
undertaken criminal activity, knowingly did possess a firearm in furtherance of drug
trafficking crimes which are prosecutable in a court of the United States:
In violation ofIill. 18, United States Code, Sections 924(c) and 2,
84
Page
85 of 100
THE GRANO JURY FURTHER CHARGES;
That on or about the dates set forth below, in the District of South Carolina
and elsewhere, the Defendants listed below, having previously been convicted of a
crime by imprisonment for a term one year, knowingly did
possess in and affecting commerce, a firearm, which had been shipped and
transported in Interstate commerce;
COUNT OEfENDANTIS) QATt; FIREARMrs)
,23 STEVEN B. BRADLEY
021"120'0
Smith & Wesson 9 mm
,24 TITUS WilL BOWMAN 06/2312010 Glock 9mm
Smith & Wesson AO caliber
'25
STEVEN B. BRADLEY 0612712010 Smllh & Wesson 38 caliber
,26 TITUS WilL BOWMAN 03124120, , Tcdl 9
127 TflUS WILL BOVIMAN 0412912011 Glodo9mm
Ruger 9mm
,28 STEWART J. STROMAN 06109f201 1 AR 15 Assault Rifle
' 29
NICHOlAS J. WRIGHT 0510912011 AR 15 Assaul t Rifle
130 KARISH MALI BROWN 06/1412011 Moe 11
,3,
TITUS WILL BOWMAN 06118.'2011 Llama 45
An In violation of TIlle 18, United states Code. SectIons 922(g)( I ), 924(.,)(2) and 924(e),
85
(
Page
3:12-cr-OOS13-CRI *SEALED* Date Fi led 06/21/12 Entry Number 3 *SEALED*
86 of 100
Page
COUNT 132
THE GRAND JUIW FURTHER CHARGES:
That on or about June 14, 2011, in the District of South Carolina, the
Defendant, TITUS WILL BOWMAN, alkfa TI, having previously been convicted
of a crime punishable by imprisonment for a term exceeding one year, knowingly
did possess in and affecting commerce, Remington UMC .45 Auto and
Winchester Super X .45 Colt ammunition, which had been shipped and
transported in interstate commerce:
In viola lion of Tille 18, Uniled States Code, Seclions 922(g)(1), 924(a)(2)
and 924(e).
'6
87 of 100
COUjolT 133
That on or about June 14, 2011. In the District of South Carolina. the
Oerendant, DARRELb ANTONIO ALSTON, aIkIa Hell Rell, whowas Ihen under
indictment for a crime punishable ,for a term of more than one year, did willfully
receive and possess ammunition, that is, Remington UMC .45 Auto and
Winchester Super X .45 Colt ammunition, which had been shipped and
transported in interstate commerce;
In violation ofTiU. 18, United States Code, Sections 922(n), 924(a)(2) and
924(e),
87
88 of 100
FALSE STATEMENTS TO
FEDERAL LAW ENFORCEMENT
AGENTS
Count 134
88
3:12-cr-00513-CRI 'SEALED' Date Filed 06/21/12 Entry Number 3 'SEALED'
89 of 100
COUNT 134
1. The allegations contained in Counts 103 and 107 oflhis Indictment are hereby
realleged ancfincorporated-as-if fully set forth herein.
2. That on or about November 9. 2011. in the District of South Carolina, the
Defendant, TITUS WILL BOWMAN, a/kla TI, in a matter within the jurisdiction of the
executive branch of the government of the United Stales, knowingly did make
materially false. fictitious and fraudulent statements and representations, knowing
the same to be false, in that he made false statements to agents of the Intemal
Revenue Service-Criminal Investigations ( I R S ~ C I ) concerning his knowing
Involvemenl in the fraudulent electronIc filing of false rederal income lax relurns;
in vioiation of Title 18, Uniled States Code, Section l001(a).
89
Page
90 of 100
~ L SENTENCING ALLEGATIONS RELEVANT TO GOUNT 1
The Grand Jury Further A l l e g ~ s that the defendants named below are
subject to enhanced penalties If convicted of COlmt 1 based on the following:
(1) That beginning in or around 2003, and continuing thereafter, up to and
including the date of this indictment, in the District of South Carolina and elsewhere.
the Oefendants, DAVID ANDREA JENKINS, aMa Arma G, all<fa Dread, TITUS
WILL BOWMAN, all<fa TI, ANDRE JAMELCUMMINGS, all<fa Dre, CRAIG XAVIER
ALSTON, all<fa CK, DARRELL ANTONIO ALSTON, aMa Hell Rell, NICHOLAS
JASON WRIGHT, all<fa Tater Head, STEWART JAMAUL STROMAN, aMa Stew,
NATHANIEL JAMAL FARMER, all<fa Gucci, DAVANTE HENRY CHRISTOPHER
LANE, alkla Lil D, TASHANDA NICOLE PARKER, alkla Big Mama, all<fa Big Mama
Blood, JARIUS OCTAVIS JONES, aJkla Buck, CALVIN JAMES HALL, alkla Kebo,
KENNETH ROY COTTOY, aMa Fish, afkla Koppo, afkl. Kapone, EDMOND LEVY,
JR .. aJ'iJa Southside, ALEX RUSSell ANDERSOhl, aikia Black. AN I WAIN
EMANUEL BRISBON. all<fa Tweeze, .fkla Twan G, ODELL MARTIN, JR , .fkla
Teazy, and KARISH MALI BROWN, aMa KB. knowingly and intentionally did
combine. conspire. agree and have tacit understanding with each other and others,
both known and unknown to the grand jury, to knowingly. intentionally. and
unlawfully possess with intent to distribute cocaine base (commonty known as
-crack" cocaine), a Schedule II controlled substance, said conspiracy involving 280
grams or more of a mixlure and substance containing a de1ec1able amount of
90
Page
3:12-cr-OOS13-CRI *SEALED* Date Fi led 06/21/12 Entry Number 3 *SEALED*
91 of 100
cocaine base. in violation of Title 21. United States Code. Sections 841(a)(II.
841 (b)(I)(A) and 846.
(2) That on or about August 5, 2007, in the District of South Carolina, the
Defendants. TYRONE LEWIS. alWa Ty Ty and MICHAEL OSHAY LONG, alWa
Killer, committed an act involving murder in that, with malice aforethought, they killed
another person using firearms. in violation of Code of Laws of South Carolina (S.C.
Code) SectionsI6-3-10 and 113-3-29;
All in violation of nile 18, United States Code, Secllons 1962(d) and 1963(a).
91
Page
1. RACKETEERING:
92 of 100
FORFEITURE ALLEGATIONS
(A). The allegations contained in of Count 1 of this indictment are hereby
repeated, realleged, and incorporated by reference herein as though set fully
forth at length for the purpose of alleging forfeiture pursuant to the provisions
of Title 18, United States Code, Section 1963 and TIUe 28, United Slates
Code, Section 2461( c) . Pursuant to Rule 32.2, Fed. R. Crim. P., noUce is
hereby given to the defendants that the United States will seek forfeiture as
part of any sentence in accordance with Title 18. United States Code, Section
1963 in the event of any defendant's conviction under Count 1 of this
Indictment. Upon conviction of the offense set forth in Count 1, the
Defendants DAVID ANDREA JENKINS, alk/a Arma G, alkJa Dread. TITUS
WILL alkla TI , TORRA.N ANrv'VON SIMS, ai!'Ja !::i !:m, a!k!a
Arsonist, ANDRE JAMEL CUMMINGS, alkJa Ore, CRAIG XAVIER ALSTON,
alkla CK, DARRELL ANTONIO ALSTON, alkJa Hell Rell , NICHOLAS JASON
WRIGHT, 3II(/a Tatcr Head, STEWART JAMAUL STROMAN, alkJa Slew.
BRANDON DESHAWN HAWKINS, SR., alkla Shotgun, alkJa Gun, STEVEN
BENJAMIN BRADLEY, aMa Red Boy, NATHANIEL JAMAL FARMER, alkJa
Gucci , DAVANTE HENRY CHRISTOPHER LANE, aJkJa UI D, TASHANOA
NICOLE PARKER, alkla Big Mama, alkJa Big Mama Blood, JARIUS
Page
93 of 100
OCTAVIS JONES, all<fa Buck, BERNARD KENTRELL BREELAND, JR., alkla
Bneezy, CALVIN JAMES HALL, atkl. Kebo, KENNETH ROY COTTOY, all<fa
Fish, all<fa Kappa, all<fa Kapone, EDMOND LEVY. JR., all<fa Southside,
ALEX RUSSELLANDERSON, all<fa Blaci<,ANTWAIN EMANUEL BRISBON,
all<fa Tweeze, all<fa Twan G, SHANTANESIMMONS, all<fa Shantane L. Craft,
ODELL MARTIN, JR.. alkJa Teazy, KARISH MALI BROWN, all<fa KB, JAMES
E. LONDON, alkJa Prince, alkJa Rockaroni, MICHAEL ANTONIO TAYLOR,
alkJa Pundla, SHONTA MARIE HARRISON alkla Ta, TAMEKA DANIELLE
SMITH, all<fa Meka, CHRISTEN MICHELLE SPENCER, JOSHUA
ALEXANDER KITT, atkla Metro, TYRONE LEWIS, all<fa Ty Ty, MICHAEL
OSHAYLONG, alkJa Killer, FRANK HENDERSON 11.1 HASSAAN R. BROWN,
alkJa Hassy. DEGREGORY REAVES, a/kta Junior, and DAMEONANTONIO
BURGESS, shall forfeit to the United States the following property:
(1) Any interest acquired or maintained in violation of Section 1962,
which interests are subject to forfeiture to the United Stales
pursuant to Title 18, United States Code, Section1963{aX1):
(2) Any interest in, security of, claim against, or property or
contractual rights of any kind atfording a source of influence over the
enterprise described in Count 1 which was established, operated,
controlled, conducted and or participated In the conduct of, in
violation of section 1962: which interests are subject to forfeiture to
9)
Page
94 of 100
the United Siaies pursuant to Tille 16, United Stales Code, Section
1963(a)(2); and
(3) Any property constituting or -derived from proceeds obtained
direclly and indirectly from racketeering activity In violation of Title
18, United States Code, Section 1962, which interests are subject
to forfeiture to the United States pursuanllo nlle 1 B, United States
Code, Section 1963(.)(3);
(AI Proceeds/MoneY Judament:
(1) A sum of money equal to aU property the Oefendants obtained as a
result of the racketeering offenses charged in the Indictment pursuant to
18 U.S.C. Section 1963. The above-named defendants, and each of them.
are jointly and severally liable tor the forfeiture obligations as alleged
above.
2, DRUG-TRAFFICKING OFFENSES:
A. Upon conviction for one or more felony violations of Title 21 , United States
Code, Sections 841 (a)(l) and 846, as ch.rged in Counts 10 through 84 o!this
Indictment, the Defendants, DAVID ANDREA JENKINS, alkJa Arm. G, alkJa
Dread, TITUS WILL BOWMAN, alkJa n. TORREAN ANTWON SIMS, alkJa
Slim, alkJa Arsoni st,ANDRE JAMELCUMMINGS, alkl. Dre, CRAIG XAVIER
ALSTON, alkla CK. DARRELL ANTONIO ALSTON, alkla Hell Rell,
94
Page
3:12-cr-00513-CRI *SEALED* Date Fi led 06/21/12 Entry Number 3 *SEALED*
95 of 100
NICHOLAS JASON WRIGHT, alk/a Tater Head, STEWART JAMAUL
STROMAN, a/1<Ja Slew, BRANOON DESHAWN HAWKINS, SR., at"'a
Shotgun, aMa Gun, STEVEN BENJAMIN BRADLEY, a/1<Ja Red Boy,
NATHANIEL JAMAL FARMER, aM. Gucci, DAVANTE HENRY
CHRISTOPHER LANE, aMa Lil D, TASHANOA NICOLE PARKER, a/"'a Big
M'ma, al"'a- Big Mama Blood;-JARlt:JS- Oe-TAVIS JONES, a/"'a Buck,
BERNARD KENTRELL BREELAND, JR., a/1<Ja Bneezy, CALVIN JAMES
HALL, aMa Kebo, KENNETH ROY COTTOY, atk/a Fish, a/1<Ja Koppo, a/1<Ja
Kapone, EDMOND LEVY, JR" at"'a Southside, ALEX RUSSELL
ANDERSON, alk/a Black, ANWVAIN EMANUEL BRISBON, a/1<Ja Tweeze,
alkia Twan G, SHANTANE SIMMONS, atkJa Shantane L Cran, ODELL
MARTIN, JR., a/"'a Teazy, and KARISH MALI BROWN, at"'a KB, JAMES E_
LONDON, a/1<Ja Prince, at"'a Rockaroni, MICHAEL ANTONIO TAYLOR, a/1<Ja
Puncho, SHONTA MARIE HARRISON, a/1<Ja Ta, CI-IRISTEN MICHELLE
SPENCER, FRANK HENDERSON, III, JOSHUA ALEXANDER KITT, atkia
Melro, DAMEON ANTONIO BURGESS and HASSAAN R BROWN, alkia
Hossy, shall forfeil to the United States all of the Defendant's right , title and
interest in and to any property real and personal.
(1) constituting. or derived from any proceeds the Defendants obtained.
directly or indirectly, as the result of such violations, and all property
traceable thereto;
9S
Page
Date Filed 06/21112 Entry Number 3 'SEALED'
96 of 100
(2) used or intended to be used, in any manner or part. t? commit or to
facilitate the commission of such violations; and,
(3) any firearm and ammunition (as defined in 18 U.S.C. Section 921) used
or intended to be used to facifitate the transportation, sale, receipt.
possession or concealment of controlled substances or any proceeds
traceable thereto.
The property subjecl 10 forfeijure pursuanl to 21 U.S.C. Sections 853 and 881
includes, but is not limited to, the following:
(A)E=edsJMooev Judgment.
(1) A sum of mooey equal 10 all property the Defendants obtained as a
result of the drug offenses charged in the Indictment, and all interest and
proceeds traceable thereto, for which the Defendants are jointly and
severally liable.
(2) Fjrearmslaffim!!nill2n:
a. Smith & Wesson Smm sei zed from STEVEN BENJAMIN BRADLEY
on 0211112010:
b. Glock 9mm seized from TITUS WILL BOWMAN on 0612312010:
c. Smith & Wesson.40 Caliber seized from TITUS WILL BOWMAN
on 0612312010:
9(,
Page
Date Fi led 06/21/12 Entry Number 3 *SEALED*
97 of 100
d. Smilh & Wesson .38 Caliber seized from STEVEN BENJAMIN
BRADLEY on 0612712010;
e. Tech 9 seized from TITUS WILL BOWMAN on 0312412011;
f. Glock 9mm seized from TITUS WILL BOWMAN on 04/291201 1;
g_ Ruger 9mm seized from TITUS WILL BOWMAN on 41291201 I ;
h. AR lSAssaull RiOe seized from STEWART JAMAUL STROMAN on
06109/2011;
I. AR 15 Assault Rifle seized from NICHOLAS JASON WRIGHT on
06/0912011,
j. Mac 11 seized from KARISH MALI BROWN on 06/1412011 ;
k. Llama AS seized from TITUS WILL BOWMAN on 06/1612011 ;
3. SPECIFIED UNLAWFUL ACTIVITIES:
A Hobbs Act Robbery/Attempted Robbery;
Upon conviction for one or more viola lions of ntle 18, United States Code,
Section 1951 (Hobbs Act) , as charged in Counls 83-84 of this Indictment, the
Defendants, TITUS WILL BOWMAN, alkJ. TI, ANDRE JAMEL CUMMINGS,
alkJa Ore, NICHOLAS JASON WRIGHT, alk/a Tater Head, STEWART
JAMUAL STROMAN, alkJa Stew, and CALVIN JAMES HALL. a/kla Kebo,
TORREAN ANTWON SIMS, alkla Slim, alkJ. Arsonist, CRAIG XAVIER
97
Page
98 of 100
ALSTON, all<Ja CK, DARRELL ANTONIO ALSTON, alkJa Hell Rell,
NICHOLAS JASON WRIGHT, all<Ja Tater Head, shall forfeit 10 the United
Siales, pursuant 10 nile 18 United States Code, Secti ons 981(a)(1)(C), and
n ile 28, Uniled Stales Code, Section 2461 (c), any property, real or personal,
which constitutes or is derived from any proceeds the Defendant obtained.
directly or indirectly, as the result of such violations, and any property
lraceable to such property.
B Wire E@ud:
Upon conviction for one or more violations of Title 18, United States Code.
Sections 1343 (Wire Fraud), and 1349 as charged in Counts 104-116 of this
Indiclmenl, lhe Defendants, TITUS WILL BOWMAN, all<Ja n, CRAIG XAVIER
ALSTON, all<Ja CK, DARRELL ANTONIO ALSTON, alkJa liell Rell ,
TASHANDA NICOLE PARKER, a/kJa Big Mama, all<Ja Big Mama Bloed,
KARISH MALI BROWN, all<Ja KB, MICHAEL ANTONIO TAYLOR. all<Ja
Puncho, SHONTA MARIE HARRISON, alkJa Ta, DAION All BOWERS,
RONDA BAKER, DAVANTE HENRY CHRISTOPHER LANE, and SHONTA
MARIE HARRISON shall forfeit to the United States, pursuanl to n ile 16
Uniled Si aies Code, Sections 981 (a)(1Xc), and Title 28, United States Code,
Secti on 2461(c), any property, real or personal, which constitutes or is derived
(rom any proceeds the Defendant obtained, directly or indirectly, as the result
of such violations, and any property traceable to such property.
98
Page
99 of 100
The property subject to forfeiture pursuant to 18 U.S.C. Section 981(a)(1)(C) and
28 U.S.C. Section 2461(c) includes, but is not limited to. the following:
(1) ProceedsIMoney Judgment
A sum of money equal to all proceeds the Defendants obtaIned
directly or indirectly as the result of the offenses charged in this
Superseding Indictment, or traceable to such property, for which the
Defendants are jointly and severally liable;
4. If any of the property described above as being subject to forfeiture, as a result
of any act or omission of the Derendant-
(1). Cannol be located upon the exercise of due diligence;
(2). Has been transferred or sold to, or deposited with, a third person:
(3). Has been placed beyond the jurisdiction of the court;
(4). Has been substantially diminished in value; or
(5). Has been commingled with other property which cannot be subdivided
without difficulty;
It is the intention of the United Stales, pursuant to Title 18, United Slates
Code, Section 1963(m) and 982(b)(1), incorporating Title 21, United Stal es Code,
Section 853(p), to seek forfeiture of any other property of the De(endants up to the
value of the forfeitable property;
99
Page
3:12-cr-OOS13-CRI *SEALED* Date Filed 06/21112 Entry Number 3 'SEALED*
100 of 100
Pursuant to Title 18, United States COde, Sections 924(d), 981 (a)(1 )(C), 1594,
1963(a), and 2428, Title 21, United States <Ade, Section. 853 and 881 and Title
28. United States Code, Section 2461 (c).
WILLIAM N. NETTLES (JORlMCMlWKW)
UNITED STATES ATIORNEY
100
Page '" . (
~
QJ
.D
E
::J
Z
C
~
c
W
N
M
~ M
N_
laO
OM
"D
QJ
RECORD OF GRAND JURY BALLOT
C/ 3:12(."...'5"/3
THE UNITED STATES V. DAVID ANDREA JENKINS, a/k/ a "Arma G", a / k / a "Dread",
ET AL .
(SEALED UNTIL FURTHER ORDER OF THE COURT)
3:12-cr-00513-CRI *SEALED* Date Filed 06/21/12 Entry Number 5 Page 1 of 5
u.s. v. David Andrea Jenkins, et. al.
Count 1
(Racketeering)
18 U.S.C. 1962(c): a maximum term of imprisonment of twenty (20) years, a fine of $250,000, a
term of supervised release of not more than three (3) years, plus a special assessment of$ IOO.OO.
Counts 2-7
(Violent Crimes in Aid of Racketeering)
18 U.S.C. I 959(a)(3): a maximum term of impri sonment of twenty (20) years, a fine of
$250,000, a term of supervised release of not more than three (3) years, plus a special assessment
of$ IOO.OO.
18 U.S.C. I 959(a)(6)(Attempt and Conspiracy): a maximum tern1 of imprisonment of three (3)
years, a fine of $250,000, a term of supervised release of not more than one ( I) year, plus a
special assessment of$ IOO.OO.
Count8
18 U.S.C. I 959(a)(5): a maximum term of imprisonment often (10) years, a fine of$250,OOO, a
term of supervised release of not more than three (3) years, plus a special assessment of $ 1 00.00.
Count 9
18 U.S.C. 1959(a)(I): a maximum term of life, a fine of$250,OOO, a term of supervised release
of not more than five (5) years, plus a specia l assessment of$ IOO.OO.
Count 10
(Conspiracy to DistributeIPWID Cocaine Base 280 Grams or More)
21 U.S.C. 841 (a)(I), (b)( I )(A) -in a case involving 280 grams or more of a mixture or substance
contai ning cocai ne base- a minimum term of imprisonment often ( 10 years and a maximum term
of li fe imprisonment, no probation, no parole, a fine of $10,000,000 and a term of supervised
release of at least five (5) years in addition to any term of imprisonment, plus a special
assessment of$1 00.
21 U.S.C. 841 (a)( I), (b)( 1 )(A) - in a case involving 280 grams or more of a mixture or substance
containing cocaine base and one prior felony drug conviction - a minimum tenn of imprisonment
of 20 years and a maximum tern1 of life imprisonment, no probation, no parole, a fine of
$20,000,000 and a term of supervised release of at least ten (10) years in addition to any term of
imprisonment, plus a special assessment of $100.
3:12-cr-00513-CRI *SEALED* Date Fi led 06/21/12 Entry Number 5 Page 2 of 5
2 1 U.S.C. 841 (a)(I), (b)(I)(A) - in a case involving 280 grams or more of a mixture or substance
containing cocai ne base and two or more prior felony drug convictions - a mandatory term of
life imprisonment, no probation, no parole, a fine of $20,000,000, a term of supervised release, if
any, of at least ten (10) years, plus a special assess ment of $1 00.
Counts 11-18, 21-27
(PWIDlDistribution of A Quantity of Cocaine Base)
2 1 U.S.C. 841(a)(I), (b)( I)(C) - in a case involving a quantity or substance or mi xture containing
cocaine base and no prior felony drug convictions - a term of imprisonment of twenty (20) years,
no probation if death or seri ous bodily injury results, no parole, a fine of $1,000,000 and a term
of supervised release of at least three (3) years in addit ion to any term of imprisonment, plus a
special assessment of $1 00.
21 U.S.C. 841(a)(I), (b)(I)(C) - in a case involving a quantity or substance or mixture containing
cocaine base and one or more prior felony drug convictions - a maximum term of imprisonment
of thirty (30) years, no probation if death or serious bodily injury results, no parole, a fine of
$2,000,000 and a term of supervised release of at least six (6) years in addition to any term of
imprisonment, plus a special assessment 0[$100.
Counts 19-20, 28-32
(pWID/Distribution of A Quantity of Cocaine Base W/in 1000 feet of park)
21 U.S.C. 860 - in a case involving a quantity or substance or mixture containing cocaine base
( I) Twice the maximum punishment authorized by section 841(b) for a first offense: a term of
impri sonment of forty (40) years and (2) at least twice any term of supervi sed release authorized
by section 841 (b) for a first offense: at least three (3) years. A fine of up to twice that authorized
by section 84 1 (b) of this title may be imposed in addition to any term of impri sonment
authorized by this subsection: $2,000,000.00.
Counts 33-40
(PWIDlDistribution of A Quantity of Marijuana)
2 1 U.S.c. 841 (b)(l)(D) - a maximum term of imprisonment of fi ve (5) years, a fine of $250,000,
a term of supervised release of not more than one ( I) year, plus a specia l assessment of$ IOO.OO.
2 1 U.S.C. 841 (b)( I )(D) - a maximum tenn of imprisonment of ten ( 10) years, a fine of $250,000,
a term of supervised release of not more than three (3) years, plus a special assessment of
$ 100.00.
3:12-cr-OOS13-CRI'SEALED' Date Filed 06/21112 Entry Number 5 Page 3 of 5
Counts 41-43
CPWIDlDistribution ofSchcdule I Pills)
21 U.S.C. 84 I (a)(I), (b)(I)(C) - in a case involving a quantity of Schedule J pills and no prior
felony drug convictions - a term of impri sonment of twenty (20) years, no probation if death or
serious bodily injury results, no parole, a fine of $1 ,000,000 and a term of supervi sed rel ease of
at least three (3) years in addition to any term of impri sonment, plus a special assessment of
$100.
21 U.S.C. 841 (a)(I), (b)(I)(C) - in a case involvi ng a quantity of Schedule I pills and one or
more prior felony drug convictions - a maximum term of imprisonment of thirty (30) years, no
probation if death or serious bodily injury results, no parole, a fine of $2,000,000 and a term of
supervi sed release of at least six (6) years in addition to any term of impri sonment, plus a special
assessment of $1 00.
Counts 44-81
(Use of a telepbone in narcotics trafficking)
21 U.S.C. 843 - in a case involving no prior felony convictions, a maximum term of
imprisonment of four (4) years, a fine of $250,000, a term of supervised release of not more than
one (I) year, plus a special assessment of$100.00.
21 U.S.C. 843 - in a case involving one prior felony conVictions, a maximum term of
impri sonment of eight (8) years, a fine of $250,000, a term of supervi sed release of not more
than three (3) years, plus a special assessment of$ IOO.OO.
Counts 82-83
(Hobbs Act Robbery)
18 U.S.C. 1951 - a maximum term of impri sonment of twenty (20) years, a fine of$250,000, a
term of supervised release of not more than three (3) years, plus a special assessment of $1 00.00.
Counts 84-92
(Interstate Travel in Aid of Racketccring)
18 U.S.C. I 952(a)(3) - a maximum term of imprisonmcnt of five (5) years, a fine of $250,000, a
term of supcrvised release of not more than one (I) year, plus a special assessment of $ 100.00.
Counts 93-94
(Enticing a Minor interstate commerce for purposes of prostitution)
18 U.S.C. 1591(a) 159 1(b) - a minimum term of impri sonment often (10) years and a maximum
term of impri sonment of life, a fine of$250,000, a telm of supervi sed release of three (3) to five
(5) years, plus a special assessment of$100.00.
3: 12-cr-00513-CR I *SEALED* Date Filed 06/21/12 Entry Number 5 Page 4 of 5
Counts 95-98
Transporting a person in interstate commerce to engage in prostitution
18 U.S.C. 242 1 - a maximum term of impri sonment often (10) years, a fine of$250,OOO, a term
of supervised release of not more than three (3) years, plus a special assessment of $100.00.
Counts 99-102
Enticing an individual to travel in interstate commerce to engage in prostitution
18 U.S.C. 242 1 - a maximum term of impri sonment of twenty (20) years, a fine of $250,000, a
term of supervised release of not more than three (3) years, plus a special assessment of $1 00.00.
Counts 103-115
Wire Fraud
18 U.S.C. 1343 and 1349 - a maximum term of imprisonment of twenty (20) years, a fine of
$250,000, a term of supervi sed release of not more than three (3) years, plus a special assessment
of$100.00.
Counts 116-122
(possession of a firearm in furtherance of drug trafficking)
18 U.S.C. 924(c)(l)(A)(i) - a term of imprisorunent of not less than five (5) years consecuti ve to
any other term of imprisonment, a maxi mum term of life imprisonment, ineligible for probation
or suspension of sentence during the term of imprisonment imposed herein, a fine of $250,000
and a term of supervi sed release of at least five (5) years in addition to any term of
impri sonment, plus a special assessment of$ IOO.OO.
18 U.S.c. 924(c)(l )(A)(ii ) - if the firearm is brandished, a tenn of impri sonment of not less than
seven (7) years consecutive to any other term of impri sonment, a maximum term of life
impri sonment, ineligible for probati on or suspension of sentence during the term of
impri sonment imposed herein , a fine of $250,000 and a temu of supervised release of at least five
(5) years in addition to any teml of impri sonment, plus a special assessment of$ IOO.OO.
18 USC 924(c)( 1 )(A)(iii) - if the firearm is di scharged, a temu of imprisonment of not less than
ten ( 10) years consecutive to any other term of impri sonment, a maximum term of life
imprisonment, ineli gible fo r probation or suspension of sentence during the temu of
imprisonment imposed herein, a fine of $250,000 and a term of supervised release of at least fi ve
(5) years in addit ion to any temu of imprisonment, plus a special assessment of $1 00.
3:12-cr-00513-CRI *SEALED* Date Fi led 06/21112 Entry Number 5 Page 5 of 5
Counts 123-133
(Felon In Possession of A Firearm Or Ammunition)
18 U.S.C.922(g) -A maximum term of impri sonment of len (l0) years, a fine of not more than
$2S0,000, a term of supervised release of up to three (3) years, plus a special assessment.
18 U.S.C. 924(e) - [fthe defendant has three or more prior felony convicti ons for violent felonies
or seri ous drug offenses, then he shall be subj ect to a penalty of a mandatory tenn of
impri sonment of fifteen ( IS) years, a fine of not more than $250,000, a term of supervised
release of up to three (3) years, plus a special assessment.
Count 134
False Statement
18 U.S. C. 100 I (a) - A maximum term of impri sonment of five (S) years, a fine of $2S0,000, a
term of supervised release of not more than one ( I) year, plus a special assessment f of $ 1 00.00.

Indictment For Columbia Bloods Gang Investigation July 11 2012

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Indictment For Columbia Bloods Gang Investigation July 11 2012

Uploaded by

Copyright:

Available Formats

3:12-cr-00S13-CRI 'SEALED* Date Filed 06/21112 Entry Number 3 SEALED

You might also like