Case 1:12-cr-00191-AJT Document 6

Filed 05/24/12 Page 1 of 8 PageID# 13

IN THE UNITED STATES DISTRICT COURT FO

EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA
v,

Criminal No.
Ct. 1:

l:12-cr

-ML
1951

18 U.S.C.

(Hobbs Act Conspiracy)

TASHEIK ASHANTI CHAMPEAN,

a/k/a:

Ashanti Champean

Ct.

2:

18 U.S.C.

2 & 924(c)&

(j)

Douglas A. Howell
Defendant

(Using Firearm in Crime of Violence Causing Death)

Ct. 3: 18 U.S.C. 2 & 922(g)
(Possession of Ammunition

by Prohibited Person)
INDICTMENT

May 2012 Term - At Alexandria

THE GRAND JURY CHARGES THAT:
Count 1

(Hobbs Act Conspiracy)

On or about May 17, 2010,

in Fairfax County,

Virginia, in the Eastern District of Virginia and

elsewhere, TASHEIK ASHANTI CHAMPEAN, a/k/a: Ashanti

Champean and Douglas A. Howell ("CHAMPEAN"), the

defendant herein, knowingly and unlawfully combined,

conspired, confederated and agreed together with Reynard Lazaro Prather ("Prather") and John Doe #1 and

with others both known and unknown to this grand jury

to knowingly and unlawfully obstruct, delay and affect

Case 1:12-cr-00191-AJT Document 6

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commerce by robbery in violation of Title 18, United

States Code, Section 1951.
MANNER AND MEANS OF THE CONSPIRACY

PURPOSE.

The purpose of the conspiracy was to obtain money

constituting the proceeds of check cashing facilities
located in the Eastern District of Virginia by armed

robbery of their owner, "D.B.", who the co-conspirators

believed kept those proceeds in his home. The manner

and means by which this purpose was carried out included the following:
1. It was part of the conspiracy that CHAMPEAN

and John Doe #1 planned the robbery with information

provided by John Doe #1.

2. It was further part of the conspiracy that

the co-conspirators would and did use firearms in

furtherance of their plan to rob "D.B.".

3.

It was further part of the conspiracy that

the co-conspirators would and did use cellular telephones to coordinate their execution of the robbery
plan.

4.

It was further part of the conspiracy that

the co-conspirators would and did possess a taser and flex cuffs to be used in the planning and execution of
the robbery.

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OVERT ACTS

In furtherance of the aforementioned conspiracy

and to effect the objects thereof, the defendants

performed the following overt acts in the Eastern

District of Virginia and elsewhere: 1. On or about May 17, 2010, CHAMPEAN and

Prather met in Prince George's County, Maryland, and

drove to a shopping center in Virginia, during which
drive, CHAMPEAN enlisted Prather in the plan to rob
"D.B.".

2.

On or about that same date,

John Doe #1 drove

CHAMPEAN and Prather to the vicinity of "D.B.'s"

residence, located on Compton Road, Centreville,

Virginia, and dropped them off.

3. On or about that same date, somewhere between

Prince George's County, Maryland,

and Centreville,

Virginia, CHAMPEAN gave Prather a duffel bag containing

a loaded semiautomatic pistol.
4. On or about that same date, CHAMPEAN and

Prather entered "D.B.'s" residence through an open garage door to await his return to the residence.
5. On or about that same date, while waiting in Prather,

the garage, CHAMPEAN told Prather that he,

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would be responsible for restraining "D.B.'s" younger

son, while he, CHAMPEAN robbed "D.B."

(In violation of Title 18, United States Code, Section

1951.)

Case 1:12-cr-00191-AJT Document 6

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Count 2

(Using Firearm in Crime of Violence)

THE GRAND JURY CHARGES FURTHER THAT:

On or about May 17, 2010,

in Fairfax County,

Virginia, in the Eastern District of Virginia, TASHEIK

ASHANTI CHAMPEAN, a/k/a: Ashanti Champean and Douglas A. Howell, the defendant herein, did knowingly and

unlawfully use and carry a firearm, to-wit: a semiautomatic pistol during and in relation to a crime
of violence for which he may be prosecuted in a court
of the United States, to-wit: conspiracy to interfere in violation of Title 18,
as set forth in Count

with commerce by robbery,

United States Code,

Section 1951,

1 of this indictment,

which description of said crime

of violence is realleged and incorporated by reference

as if set forth in full herein, and in the course of did cause the

the commission of the instant offense,

death of a person through the use of a firearm, killing is a murder as defined in Title 18,
States Code, Section 1111,

which

United
with

in that the defendant,

malice aforethought,

unlawfully caused the death of willfully, deliberately

Jose Rivera Rosales Cardona,

and with premeditation.
(In violation of Title 18,

United States Code,

Sections

2 and 924(c) (1) (A) (iii)

& (j).)

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Count 3

(Possession of Ammunition by Prohibited Person)

THE GRAND JURY CHARGES FURTHER THAT:

On or about May 17, 2010,

in Fairfax County,

Virginia, in the Eastern District of Virginia, TASHEIK

ASHANTI CHAMPEAN,
A. Howell,

a/k/a: Ashanti Champean and Douglas

having been convicted

the defendant herein,

in Kings County Supreme Court, Kings County, New York,

of Criminal Possession Loaded Firearm-3rd Degree,
Criminal Case No. 9566-91, on June 10, 1992, a crime

that was punishable by imprisonment for a term

exceeding one year, did knowingly and unlawfully

possess in and affecting commerce ammunition, to wit:

seven rounds of .45 caliber ammunition, such ammunition

having been shipped and transported in interstate and

foreign commerce. (In violation of Title 18, 2 and 922(g) .) United States Code, Sections

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NOTICE OF SPECIAL FINDINGS

a.

The allegations of this indictment are hereby

realleged as if fully set forth herein and incorporated

by reference.
b. The defendant TASHEIK ASHANTI CHAMPEAN, a/k/a:

Ashanti Champean and Douglas A. Howell: (1) was 18 years of age or older at the time
of the offense;

(2)
Cardona

intentionally killed Jose Ramiro Rosales

3591(a)(2)(A));

(18 U.S.C.

(3)

intentionally inflicted serious bodily

injury that resulted in the death of Jose Ramiro

Rosales Cardona (18 U.S.C. 3591(a)(2)(B));

(4) intentionally participated in an act,

contemplating that the life of a person would be taken or intending that lethal force would be used in
connection with a person, other than one of the

participants in the offense, and Jose Ramiro Rosales

Cardona died as a direct result of such act (18 U.S.C.

3591(a) (2) (C));

(5)

intentionally and specifically engaged in

knowing that the act created a other than one of the

an act of violence,

grave risk of death to a person,

participants in the offense,

such that participation in

the act constituted a reckless disregard for human life

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and Jose Ramiro Rosales Cardona died as a direct result

of the act (18 U.S.C. 3591(a)(2)(D));

(6) in the commission of the offense, or in

escaping apprehension for the violation of the offense,

knowingly created a grave risk of death to one or more

persons in addition to the victim of the offense. (18

U.S.C. 3592(c) (5)); and

(7) committed the offense as consideration

for the receipt, or in expectation of the receipt, of

anything of pecuniary value. (18 U.S.C. 3592(c)(8)).

A TRUE BILL:

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Neil H.

MacBride

United States Attorney

Michael E. Rich/Zachary Terwilliger

Assistant United States Attorneys