CJF/JMW USAO2008R00860

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v. ERIC BROWN, a/k/a “E,” a/k/a “EB,” RAY OLIVIS, a/k/a “Ronnie Hargrove,” a/k/a “Uncle Ray,” a/k/a “Unc,” a/k/a “Ray Ray,” DEITRA DAVENPORT, a/k/a “Sister D,” RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a “Uncle Rudy,” KEVIN GLASSCHO, a/k/a “KG,” CASSANDRA ADAMS, ZACHARY NORMAN, a/k/a “Zack,” ALICIA SIMMONS, TODD DUNCAN, a/k/a “Donnie,” KIMBERLY McINTOSH, a/k/a “Kim McCintosh,” a/k/a “Sister Kim” a/k/a “Sis,” a/k/a “Kimberly Jones,” DUCONZE CHAMBERS, a/k/a “Ducon,” a/k/a “Dookie,” DAVON McFADDEN, a/k/a “Ben,” JAMES HARRIED, a/k/a “Smiley,” * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * FILED UNDER SEAL

CRIMINAL NO. WDQ 09-183 (Conspiracy to Participate in a Racketeering Enterprise, 18 U.S.C. § 1962(d); Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances, 21 U.S.C. § 846; Conspiracy to Launder Monetary Instruments, 18 U.S.C. § 1956(h); Conspiracy to Interfere with Commerce by Robbery, 18 U.S.C. § 1951; Possession of a Firearm in Furtherance of a Crime of Violence, 18 U.S.C. § 924(c); Possession of a Firearm by a Felon, 18 U.S.C. § 922(g); Possession of a Firearm in Furtherance of a Drug Trafficking Offense; 18 U.S.C. § 924(c); Aiding and Abetting, 18 U.S.C. § 2)

ERIK USHRY, a/k/a “E,” Defendants,

* * * * * ******* SUPERCEDING INDICTMENT COUNT ONE

(Conspiracy to Participate in Racketeering Activity) The Grand Jury for the District of Maryland charges that: Introduction 1. The Black Guerilla Family (“BGF”), also known as the “Black Family,” the “Family” or the “Black Vanguard,” is a nationwide gang operating in prison facilities and major cities throughout the United States. Founded in California in the 1960s and introduced into the Maryland correctional system in the mid 1990s, BGF is now one of the most powerful gangs in the state. Although traditionally a prison-based gang, BGF in Maryland is increasingly active and well organized on the streets of Baltimore City, Maryland. 2. At all times relevant to this Indictment, BGF factions existed in various prison facilities in Maryland, including, among others, North Branch Correctional Institution (“NBCI”), Western Correctional Institution (“WCI”), Eastern Correctional Institution (“ECI”), Roxbury Correctional Institution, Maryland Correctional Institution – Jessup (“MCI-J”), Maryland Correctional Institution – Hagerstown, Baltimore City Correctional Center (“BCCC”), and Metropolitan Transition Center (“MTC”), Baltimore City Detention Center (“BCDC”). 3. At all times relevant to this Indictment, BGF factions existed throughout Baltimore City. 4. At all times relevant to this Indictment, BGF leaders, collectively known as the 2

“Supreme Bush,” directed the activities of BGF members in Maryland. Reflecting the paramilitary nature of the BGF, the “Supreme Bush” was organized according to a strict rank structure which included a Supreme Commander, Lieutenant Commander and Ministers of Justice, Defense, Finance, Intelligence and Education. Within each correctional institution and neighborhood of Baltimore City in which BGF had established a presence, a local organizational structure was put in place. These so-called “Bubble Regimes” mirrored the structure of the Supreme Bush and so included its own Commander, Lieutenant Commander and various ministers. The commander of each “Bubble Regime” was appointed by, and reported to, the Supreme Bush. 5. At all times relevant to this Indictment, BGF members were required to follow a strict code of conduct. BGF members who failed to adhere to this code were subjected to various forms of discipline, to include physical violence. 6. At all times relevant to this Indictment, BGF members were expected to recruit new members (known as “Seeds”) into BGF and familiarize those new members with the history, doctrine and code of conduct of the organization. 7. At all times relevant to this Indictment, BGF members engaged in various criminal activities on the streets of Baltimore City, including, but not limited to, drug-trafficking, extortion, robbery, bribery and money laundering, retaliation against witnesses and obstruction of justice. 8. At all times relevant to this Indictment, BGF members engaged in various criminal activities inside the Maryland Correctional System, including but not limited to, drugtrafficking, extortion, robbery, bribery and money laundering, retaliation against witnesses and obstruction of justice.

3

9. At all times relevant to this Indictment, members of BGF arranged for the smuggling of narcotics, cellular telephones, tobacco, food and other contraband prohibited by correctional facility regulations into Maryland correctional facilities. 10. At all times relevant to this Indictment, members of BGF recruited and paid employees of prison facilities, including corrections officers, to assist BGF and its members in the smuggling of contraband, the collection of intelligence and in the concealment of BGF’s criminal activities. 11. At all times relevant to this Indictment, BGF members, with the assistance of corrections officers and employees, engaged in an extortion scheme by which prison inmates were required to pay for “protection.” Inmates who refused to pay for such “protection” were targeted for violence by members of BGF. 12. At all times relevant to this Indictment, BGF members used the funds procured through drug trafficking, extortion, and the sale of contraband to enrich themselves and to further the activities of the organization, including, but not limited to drug-trafficking. 13. At all times relevant to this Indictment, BGF protected and broadened their control of the Baltimore City drug trade through violence and intimidation. 14. At all times relevant to this Indictment, BGF protected and broadened their control of the underground “prison economy” in Maryland correctional facilities through violence and intimidation. 15. At all times relevant to this Indictment, the following defendants were members or associates of BGF: ERIC BROWN, a/k/a "E," a/k/a "EB," RAY OLIVIS, a/k/a "Ronnie Hargrove," a/k/a "Uncle Ray," a/k/a "Unc," a/k/a "Ray Ray," DEITRA DAVENPORT, a/k/a "Sister D," RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a

4

"Uncle Rudy," ZACHARY NORMAN, a/k/a "Zack," KEVIN GLASSCHO, a/k/a "KG," ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a "Kim McCintosh," a/k/a "Sister Kim," a/k/a "Sis," a/k/a "Kimberly Jones," DUCONZE CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," DAVON McFADDEN, a/k/a "Ben," JAMES HARRIED, a/k/a "Smiley," and ERIK USHRY, a/k/a "E." The Racketeering Enterprise 16. BGF, including its 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 fact that engaged in, and the activities of which affected, interstate and foreign commerce. The enterprise constituted an ongoing organization whose members functioned as a continuing unit for the common purpose of achieving the objectives of the enterprise. Purposes of the Enterprise 17. The purposes of the enterprise included the following: a. Preserving and protecting the power, territory and profits of the enterprise through the use of violence, threats of violence, intimidation, extortion, armed robbery, money laundering, bribery, and narcotics trafficking; b. Promoting and enhancing the enterprise and its members’ and associates’ activities through the use of violence, threats of violence, intimidation, extortion, armed robberies, money laundering, bribery, and narcotics trafficking, retaliation against witnesses and obstruction of justice; c. Keeping victims and potential victims in fear of the enterprise and in fear of its members and associates, through violence and threats of violence;

5

d. Generating financial profits for the furtherance of the enterprise in Maryland; e. Providing financial support and information to gang members, including those who were incarcerated for committing acts of violence or other offenses; and f. Providing assistance to other gang members who committed crimes for and on behalf of the gang in order to hinder, obstruct and prevent law enforcement officers from identifying the offender, apprehending the offender and trying and punishing the offender. The Racketeering Conspiracy 18. Beginning on a date unknown to the Grand Jury, but at least in or about 2006, and continuing through the date of this Indictment, in the District of Maryland and elsewhere, the defendants, ERIC BROWN, a/k/a “E,” a/k/a “EB,” RAY OLIVIS, a/k/a “Ronnie Hargrove,” a/k/a “Uncle Ray,” a/k/a “Unc,” a/k/a “Ray Ray,” DEITRA DAVENPORT, a/k/a “Sister D,” RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a “Uncle Rudy,” KEVIN GLASSCHO, a/k/a “KG,” ZACHARY NORMAN, a/k/a “Zack,” ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a "Kim McCintosh," a/k/a "Sister Kim," a/k/a "Sis," 6

a/k/a "Kimberly Jones," DUCONZE CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," DAVON McFADDEN, a/k/a "Ben," JAMES HARRIED, a/k/a "Smiley," ERIK USHRY, a/k/a "E," each being a person employed by and associated with BGF, an enterprise engaged in, and the activities of which affected, interstate and foreign commerce, together with others known and unknown to the Grand Jury, did knowingly and intentionally conspire to conduct and participate, directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity, as defined in Sections 1961(1) and (5) of Title 18, United States Code, which pattern of racketeering activity consisted of multiple acts involving narcotics trafficking, indictable under 21 U.S.C. §§ 841 and 846; multiple acts involving robbery in violation of Maryland Criminal Law Code Section 3-402 and the Common Law of Maryland, extortion, in violation of Maryland Criminal Law Code Section 3-701, and bribery in violation of Maryland Criminal Law Code Section 9-201; and multiple acts indictable under 18 U.S.C. § 1513 (retaliation against a witness or an informant); 18 U.S.C. § 1956(h) (money laundering); and 18 U.S.C. § 1951 (interference with commerce by robbery). 19. It was part of the conspiracy that each defendant agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise. Manner and Means of the Conspiracy 20. Among the manner and means by which the defendants and others conducted and participated in the conduct of the conspiracy were the following:

7

a. BGF members and associates distributed controlled substances, including heroin to customers in the Baltimore area. b. BGF members and associates smuggled controlled substances, including heroin, to incarcerated BGF members for distribution within Maryland prison facilities. c. BGF members and associates smuggled tobacco, cellular telephones, food and other contraband to incarcerated BGF members for distribution within Maryland prison facilities. d. Corrections officers and other employees, including ALICIA SIMMONS and others, assisted incarcerated BGF members in smuggling drugs and other contraband into prison facilities, often in exchange for money and other compensation. e. BGF members used the proceeds of extortion, and the sale of narcotics and contraband to enrich themselves and to further the activities of the organization, to include narcotics trafficking. f. BGF members laundered the proceeds of their illicit activities through the use of pre-paid debit cards (commonly referred to as “Green Dot Cards”), gift cards and other means. g. BGF members used violence and the threat of violence to coerce incarcerated persons to pay protection money to BGF. h. BGF members committed and caused to be committed acts of violence in furtherance of the gang’s activities, to include robberies of drug dealers and others, assaults of rival gang members and individuals suspected of cooperating with law enforcement, and assaults of fellow BGF members for violations of BGF rules and protocols.

8

i. BGF members used contraband cellular telephones in prison facilities to coordinate the smuggling of contraband into the prison facilities; to notify one another about gang members who were arrested or incarcerated; to discuss police interactions with gang members; to share with one another the identities of individuals who may be cooperating with law enforcement and propose actions to be taken against those individuals; and to intimidate potential witnesses. j. BGF members and associates conducted counter-surveillance of law enforcement officers in an attempt to prevent law enforcement officers from detecting their illegal activities. k. BGF members and associates kept and maintained firearms to protect themselves, to protect BGF assets (e.g., narcotics and the proceeds of BGF’s criminal activities), and to commit acts of violence when necessary to protect or further the interests of the gang. Overt Acts 21. In or about October 2006 to November 2006, ERIC BROWN ordered the assault of a BGF member in retaliation for an unpaid debt owed to BGF. 22. In 2007, Corrections Officers at the Maryland Correctional Institution, Jessup (“MCI-J”) smuggled narcotics, including heroin, to BGF members at the facility. BGF members then sold the narcotics and a percentage of the proceeds of the sale of these narcotics were then contributed to the BGF’s central “treasury” at the facility. In return for smuggling contraband into the facility, Corrections Officers received either cash or pre-paid debit cards from BGF members. 23. In 2007, ALICIA SIMMONS, a Corrections Officer, regularly smuggled narcotics to known BGF members incarcerated at MCI-J. In return for smuggling the contraband

9

into the facility, SIMMONS received cash and pre-paid debit cards. 24. In 2007, ALICIA SIMMONS, a Corrections Officer, smuggled a cellular telephone to a BGF members incarcerated at MCI-J. In return for smuggling the contraband into the facility, SIMMONS received cash and pre-paid debit cards. 25. Between in or about September 2007 and October 2007, RAY OLIVIS transferred approximately $1,185.00 into a pre-paid debit card account. These funds represented, at least in part, the proceeds of the BGF’s illegal activities, to include extortion and drug trafficking. 26. Between in or about 2008 and 2009, Corrections Officers smuggled marijuana to BGF members incarcerated at the Baltimore City Detention Center (“BCDC”). BGF members then sold the marijuana and a percentage of the proceeds of the sales of that marijuana were contributed to the BGF “treasury” at the facility. 27. Between in or about 2008 and 2009, Corrections Officers smuggled cell phones and alcohol into BCDC at the direction of BGF members. In return for smuggling contraband into the facility, guards received either cash or pre-paid debit cards from BGF members. 28. Between in or about April 2008 and December 2008, ERIC BROWN transferred approximately $3,035.00 into a pre-paid debit card account. These funds represented, at least in part, the proceeds of the BGF’s illegal activities, to include extortion and drug trafficking. 29. Between in or about April 2008 and May 2008, DEITRA DAVENPORT transferred approximately $1,020.00 into a pre-paid debit card account. These funds represented, at least in part, the proceeds of the BGF’s illegal activities, to include extortion and

10

drug trafficking. 30. Between in or about July 2008 and April 2009, a Corrections Officer affiliated with BGF transferred approximately $750.00 into a pre-paid debit card account. These funds represented, at least in part, payments by BGF members to the Corrections Officer for assistance in facilitating the gang’s activities. 31. Between in or about October 2008 and May 2009, a Corrections Officer affiliated with BGF transferred approximately $1,615.00 into a pre-paid debit card account. These funds represented, at least in part, payments by BGF members to the Corrections Officer for assistance in facilitating the gang’s activities. 32. Between in or about November 2008 and February 2009, RAINBOW WILLIAMS transferred approximately $2,185.00 into a pre-paid debit card account. These funds represented, at least in part, the proceeds of the BGF’s illegal activities, to include extortion and drug trafficking. 33. On or about November 18, 2008, during an intercepted phone conversation, a BGF member at NBCI asked ERIC BROWN to arrange for a female courier to smuggle contraband into NBCI. 34. Between in or about January 2009 and March 2009, a Corrections Officer affiliated with BGF, smuggled contraband to BGF members at MTC. This contraband was either used by BGF members or sold to other inmates and the proceeds used to further BGF activities. 35. Between in or about October 2008 and March 2009, a Corrections Officer affiliated with BGF, smuggled contraband to BGF members inside of Maryland correctional facilities. This contraband was either used by BGF members or sold to other inmates and the

11

proceeds used to further BGF activities. 36. Between in or about January 2009 and March 2009, ERIC BROWN directed a Corrections Officer affiliated with BGF to smuggle heroin to BGF members at MTC. 37. In or about January 2009 to April 2009, ERIC BROWN extorted a fellow inmate for protection from violence at the hands of BGF members. 38. Between in or about January 2009 to April 2009, ERIC BROWN assaulted an inmate who failed to make a timely extortion payment to BGF. 39. In February 2009, during an intercepted phone conversation, ERIC BROWN directed DEITRA DAVENPORT to deliver “five cans” of suspected contraband to RAINBOW WILLIAMS who would, in turn, have the contraband smuggled into MTC. BROWN also instructed DAVENPORT to give WILLIAMS $300 for payment to a corrections employee who was helping BGF smuggle contraband into the prison. 40. On or about February 23, 2009, ERIC BROWN provided $50.00 to a Corrections Officer affiliated with BGF via pre-paid debit card. 41. On or about February 24, 2009, during an intercepted phone conversation, ERIC BROWN requested that a correctional employee affiliated with BGF smuggle contraband into MTC. 42. On or about February 25, 2009, during an intercepted phone conversation, ERIC BROWN directed RAINBOW WILLIAMS to deliver suspected narcotics to a Corrections Officer affiliated with BGF so that the Corrections Officer could smuggle the narcotics into MTC. 43. On or about February 27, 2009, during an intercepted phone conversation, a Corrections Officer affiliated with BGF informed ERIC BROWN that she had spent the money

12

loaded onto her pre-paid debit card. 44. In or about March 2009, a Corrections Officer affiliated with BGF attempted to smuggle two cell phones into MTC on behalf of ERIC BROWN. 45. On or about March 1, 2009, during an intercepted phone conversation with another BGF member, ERIC BROWN explained that RAINBOW WILLIAMS had attempted to smuggle contraband into BROWN at MTC via a pair of tennis shoes but that the attempt had been discovered by corrections officials. 46. On or about March 1, 2009, during an intercepted phone conversation, KEVIN GLASSCHO told ERIC BROWN that GLASSCHO and GLASSCHO’s wife, CASSANDRA ADAMS, had spent the previous day distributing drugs to GLASSCHO’S customers. 47. In or about March 2009 to April 2009, KEVIN GLASSCHO provided heroin to BGF members in various Maryland correctional institutions. 48. On or about March 8, 2009, during an intercepted phone conversation, a Corrections Officer affiliated with BGF explained to ERIC BROWN, that she had smuggled a cellphone battery to an inmate and that the inmate wanted to contact BROWN. 49. On or about March 8, 2009, during an intercepted phone conversation, ERIC BROWN and a federal inmate discussed the fact that ALICIA SIMMONS, a Corrections Officer, was smuggling contraband into the prisoners at the MCAC. The federal inmate asked BROWN to speak to SIMMONS about smuggling contraband into the facility on behalf of the inmate. 50. On or about March 9, 2009, during an intercepted phone conversation, ERIC BROWN directed a Corrections Officer affiliated with BGF to smuggle contraband into

13

MTC. The Corrections Officer told BROWN, “Okay I’m going to work on that today.” 51. On or about March 13, 2009, during an intercepted phone conversation, ERIC BROWN, RANDOLPH EDISON, RAY OLIVIS, and ZACHARY NORMAN, discussed an attempted commercial robbery to have been committed by EDISON, NORMAN and another individual. NORMAN, OLIVIS and EDISON discussed retaliating against a suspected informant whose cooperation with law enforcement thwarted the attempted robbery. OLIVIS promised to deal with the informant, telling NORMAN “We need to know where [the informant] at. I’ll be on top of all of it.” During the same conversation, ZACHARY NORMAN and RAY OLIVIS discussed plans to assault an inmate suspected of being involved in the murder of NORMAN’s brother. OLIVIS told NORMAN, “Alright Bear, I’m already on top of that man.” 52. On or about March 18, 2009, during an intercepted phone conversation, KEVIN GLASSCHO instructed CASSANDRA ADAMS to return home so that she could help GLASSCHO count the proceeds of the day’s drug transactions. 53. On or about March 21, 2009, during an intercepted phone conversation, KEVIN GLASSCHO and CASSANDRA ADAMS discussed structuring the deposits of the proceeds of narcotics sales in order to evade detection by law enforcement. 54. On or about March 24, 2009, during an intercepted phone conversation, ERIC BROWN and another BGF member arranged for the delivery of contraband to an unidentified individual outside of MTC who would then deliver the contraband to BROWN inside of the prison. 55. Between on or about March 28, 2009 and April 14, 2009, $2,250.00 was transferred into a pre-paid debit card account registered to KEVIN GLASSCHO and

14

CASSANDRA ADAMS. These funds represented, at least in part, the proceeds of drug trafficking. 56. In April 2009, during an intercepted phone conversation, ERIC BROWN and DEITRA DAVENPORT discussed the smuggling of food, alcohol and cigars to BGF members at MTC. 57. Between on or about April 1, 2009 and April 10, 2009, $2,000.00 was transferred into a pre-paid debit card account registered to CASSANDRA ADAMS. These funds represented, at least in part, the proceeds of drug trafficking by BGF and its associates. 58. On or about April 2, 2009, during an intercepted phone conversation, an unidentified individual discussed paying KEVIN GLASSCHO for drugs via a pre-paid debit card. 59. On or about April 5, 2009, during an intercepted phone conversation, RAY OLIVIS, RAINBOW WILLIAMS and several other BGF members conducted a conference call in which OLIVIS discussed day-to-day operations, violations of BGF protocols and sanctions that should be ordered against members who had violated those protocols. 60. On or about April 9, 2009, during an intercepted phone conversation, RAINBOW WILLIAMS arranged for the purchase of a quantity of drugs from an another individual. 61. On or about April 13, 2009, RAINBOW WILLIAMS organized a meeting of over 100 BGF members at Druid Hill Park in Baltimore. Attendees of the meeting possessed, among other things, a firearm, BGF related promotional literature, BGF t-shirts emblazoned with the slogan, "Revolution is the Only Solution," and a document listing BGF members who have violated BGF rules and the sanctions imposed for those violations.

15

62. On or about April 15, 2009, RAINBOW WILLIAMS possessed thirty-eight rounds of .357 ammunition, as well as BGF promotional literature, manuals and lessons plans. 63. On or about April 15, 2009, KEVIN GLASSCHO and CASSANDRA ADAMS possessed, at their home, BGF promotional materials, correspondence with incarcerated individuals, a large sum of United States currency and a Taurus 9mm pistol. 64. On or about April 15, 2009, KEVIN GLASSCHO possessed, at a stash location, approximately one hundred grams of heroin. GLASSCHO possessed the heroin with the intent to distribute it. 65. On or about December 15, 2009, KIMBERLY McINTOSH sold five grams of heroin to a fellow BGF member for $400.00. 66. On or about December 15, 2009, LAMONT CROOKS provided 20 grams of heroin to ERIK USHRY and one gram of heroin to KIMBERLY McINTOSH. 67. On or about December 21, 2009, KIMBERLY McINTOSH sold a quantity of heroin to a fellow BGF member for $800.00. 68. On or about December 28, 2009, during an intercepted telephone conversation, DUCONZE CHAMBERS admitted that he was selling heroin for TODD DUNCAN. 69. On or about February 8, 2010, during an intercepted telephone conversation, DUCONZE CHAMBERS offered to assist another individual in finding a new source of cocaine. 70. On or about February 17, 2010, during an intercepted telephone conversation, TODD DUNCAN and another individual discussed a drug debt owed to DUNCAN. 71. On or about February 18, 2010, during an intercepted telephone conversation,

16

an unidentified individual asked DUCONZE CHAMBERS if he knew of a Corrections Officer that would assist in the smuggling of contraband into the Brockbridge Correctional Facility, a Maryland correctional facility. CHAMBERS told the individual that he knew a corrections officer that would be of assistance. 72. On or about February 20, 2010, during an intercepted telephone conversation, JAMES HARRIED was overheard directing an associate to sell a quantity of narcotics. 73. On or about March 2, 2010, during an intercepted telephone conversation, JERMAIN DAVIS and TODD DUNCAN discussed DAVIS’s role in selling narcotics for DUNCAN and DAVIS’s near arrest by the Baltimore Police Department for drug trafficking. 74. On or about March 2, 2010, during an intercepted telephone conversation, TODD DUNCAN and DAVON McFADDEN discussed whether McFADDEN was going to participate in a drug transaction with an associate of DUNCAN. 75. On or about March 5, 2010, during an intercepted telephone conversation, DAVON McFADDEN called TODD DUNCAN to warn him that law enforcement was in the vicinity of Biddle Street and Greenmount Avenue, an area where McFADDEN was selling narcotics. 76. On or about March 5, 2010, during an intercepted telephone conversation, DAVON McFADDEN informed TODD DUNCAN that an associate named “Trap” had been arrested shortly after obtaining narcotics from McFADDEN. 77. On or about March 5, 2010, during an intercepted telephone conversation, JERMAIN DAVIS told TODD DUNCAN that DAVIS had been processing narcotics provided by DUNCAN, but that the quality of the drugs was poor. DAVIS then recommended adding a new quantity of higher quality narcotics in order to improve the marketability of the finished

17

product. 78. On or about March 6, 2010, during an intercepted telephone conversation, TODD DUNCAN and another individual discussed a commercial robbery and auto theft committed by the individual. During the conversation, DUNCAN demanded that he be provided with a “cut” of the proceeds. 79. On or about March 7, 2010, during an intercepted telephone conversation, TODD DUNCAN asked JERMAIN DAVIS to meet him at KIMBERLY McINTOSH’s home and provide DUNCAN with empty gelatin capsules for packaging heroin. 80. On or about March 8, 2010, during an intercepted telephone conversation, TODD DUNCAN instructed JERMAIN DAVIS to recover a quantity of drugs from KIMBERLY McINTOSH’s residence and deliver the drugs to DUNCAN. DAVIS was then intercepted explaining to McINTOSH that DUNCAN needed the drugs stored at McINTOSH’s home. 81. On or about March 8, 2010, during an intercepted telephone conversation, TODD DUNCAN and KIMBERLY McINTOSH discussed the quality of a recent supply of heroin that DUNCAN and McINTOSH had received and processed. 82. On or about March 8, 2010, during an intercepted telephone conversation, TODD DUNCAN and KIMBERLY McINTOSH discussed DUNCAN selling heroin to McINTOSH and DAVON McFADDEN. 83. On or about March 9, 2010, during an intercepted telephone conversation, JERMAIN DAVIS informed DUCONZE CHAMBERS that DAVIS was selling 300 to 400 units of heroin on behalf of TODD DUNCAN per day. DAVIS further informed CHAMBERS that DUNCAN was providing low quality heroin for processing and sale and that DAVIS had to

18

mix DUNCAN’s drugs with higher quality drugs he was receiving from another source in order to improve the marketability of the heroin. 84. On or about March 9, 2010, during an intercepted telephone conversation, TODD DUNCAN directed JON BRICE to test the quality of heroin provided by DUNCAN. In an intercepted phone conversation a short time later, BRICE informed DUNCAN that the quality of the heroin was high. 85. On or about March 19, 2010, during an intercepted phone conversation, TODD DUNCAN directed RONALD SCOTT to retrieve drug packaging paraphernalia from KIMBERLY McINTOSH’s home and deliver it to DUNCAN. 86. On or about March 19, 2010, during an intercepted telephone conversation, TODD DUNCAN told JON BRICE that he needed access to BRICE’s home so that he could mix and package a quantity of heroin. 87. On or about March 21, 2010, during an intercepted telephone conversation, KIMBERLY McINTOSH was overheard discussing her plan to have each BGF commander raise $3,000 from his subordinates and transfer those funds to BGF’s central “treasury.” 88. On or about March 21, 2010, during an intercepted telephone conversation, JAMES HARRIED and DUCONZE CHAMBERS discussed attending a meeting of BGF members at KIMBERLY McINTOSH’s residence. 89. On or about March 19, 2010, during an intercepted telephone conversation, TODD DUNCAN and JAMES HARRIED discussed collecting dues from fellow BGF members in order to post the bail for an incarcerated member. These dues were paid, at least in part, with the proceeds of BGF narcotics trafficking. 90. On or about March 22, 2010, during an intercepted telephone conversation,

19

TODD DUNCAN informed DAVON McFADDEN that JERMAIN DAVIS had been arrested after law enforcement raided DAVIS’s home. McFADDEN reported that he had recently given drugs to DAVIS. 91. On or about March 27, 2010, during an intercepted telephone conversation, DAVON McFADDEN was overheard directing DUCONZE CHAMBERS to collect $25.00 from each BGF member under CHAMBERS’s command. McFADDEN informed CHAMBERS that McFADDEN would collect the money and forward the funds to BGF’s central “treasury.” 92. On or about March 27, 2010, during an intercepted telephone conversation, JAMES HARRIED informed TODD DUNCAN that DAVON McFADDEN had collected membership dues from BGF members and that he, HARRIED, would deliver a written record of which BGF members had paid their fees to KIMBERLY McINTOSH. These dues were paid, at least in part, with the proceeds of BGF narcotics trafficking. 93. On or about March 29, 2010, during an intercepted telephone conversation, TODD DUNCAN and another BGF member discussed the identification by law enforcement of KIMBERLY McINTOSH as a high-ranking BGF member and the danger that McINTOSH would pose to the organization if she decided to cooperate with law enforcement. 94. On or about April 12, 2010, DAVON McFADDEN possessed handwritten records of drug transactions, several gelatin capsules of heroin and $2,536.00 in U.S. currency. 95. On or about April 12, 2010, KIMBERLY McINTOSH possessed at her place of work, a ballistic vest (body armor) as well as letters to BGF members, BGF promotional literature and BGF administrative paperwork. 96. On or about April 12, 2010, KIMBERLY McINTOSH possessed at her

20

home, located at 1120 Homewood Avenue, Baltimore, Maryland, letters to BGF members, BGF promotional literature, and BGF administrative paperwork.

NOTICE OF SPECIAL SENTENCING FACTORS Beginning in or about 2006, and continuing through and including the date of this indictment, both dates being approximate and inclusive, within the District of Maryland and elsewhere, the defendants, ERIC BROWN, a/k/a "E," a/k/a "EB," RAY OLIVIS, a/k/a "Ronnie Hargrove," a/k/a "Uncle Ray," a/k/a "Unc," a/k/a "Ray Ray," DEITRA DAVENPORT, a/k/a "Sister D," RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a "Uncle Rudy," ZACHARY NORMAN, a/k/a "Zack," KEVIN GLASSCHO, a/k/a "KG," ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a "Kim McCintosh," a/k/a "Sister Kim," a/k/a "Sis," a/k/a "Kimberly Jones," DUCONZE CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," DAVON McFADDEN, a/k/a "Ben," JAMES HARRIED, a/k/a "Smiley," and ERIK USHRY, a/k/a "E," knowingly and intentionally conspired to distribute and possess with the intent to distribute one kilogram or more of a mixture or substance containing a detectable amount of heroin, a Schedule I controlled dangerous substance in violation of Title 21, United States Code, Sections 846 and 841(a)(1) and (b)(1)(A). 18 U.S.C. § 1962

21

COUNT TWO (Conspiracy to Distribute and Possess with the Intent to Distribute Controlled Substances) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are re-

alleged and incorporated by reference as though fully set forth herein. 2. Beginning on a date unknown to the Grand Jury, but at least in or about

2006 through the date of this Indictment, in the District of Maryland and elsewhere, the defendants, ERIC BROWN, a/k/a “E,” a/k/a “EB,” RAY OLIVIS, a/k/a “Ronnie Hargrove,” a/k/a “Uncle Ray,” a/k/a “Unc,” a/k/a “Ray Ray,” DEITRA DAVENPORT, a/k/a “Sister D,” RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a “Uncle Rudy,” ZACHARY NORMAN, a/k/a “Zack” KEVIN GLASSCHO, a/k/a “KG,” CASSANDRA ADAMS, ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a "Kim McCintosh," a/k/a "Sister Kim," a/k/a "Sis," a/k/a "Kimberly Jones," DUCONZE CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," 22

DAVON McFADDEN, a/k/a "Ben," JAMES HARRIED, a/k/a "Smiley," ERIK USHRY, a/k/a "E," did knowingly and intentionally combine, conspire, confederate, and agree with each other and with others known and unknown to the Grand Jury to distribute and possess with intent to distribute one kilogram or more of a mixture or substance containing a detectable amount of heroin, a Schedule I controlled substance, in violation of Title 21, United States Code, Section 841(a)(1). 21 U.S.C. § 846

23

COUNT THREE (Conspiracy to Commit Money Laundering) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are

re-alleged and incorporated by reference as though fully set forth herein. 2. From at least September 2007 to the date of this Indictment, in the District

of Maryland and elsewhere, the defendants, ERIC BROWN, a/k/a “E,” a/k/a “EB,” RAY OLIVIS, a/k/a “Ronnie Hargrove,” a/k/a “Uncle Ray,” a/k/a “Unc,” a/k/a “Ray Ray,” DEITRA DAVENPORT, a/k/a “Sister D,” RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a “Uncle Rudy,” KEVIN GLASSCHO, a/k/a “KG,” CASSANDRA ADAMS, did knowingly and intentionally combine, conspire, confederate, and agree with each other and with others known and unknown to the Grand Jury to conduct and attempt to conduct financial transactions affecting interstate commerce, by transferring funds by wire or other means which in fact involved the proceeds of specified unlawful activities, that is, extortion, narcotics trafficking, and bribery knowing that the property involved in the financial transaction represented the proceeds of some form of unlawful activity and with the intent to conceal and promote the carrying on of the specified unlawful activities, to wit: extortion, narcotics trafficking, and bribery, in violation of Title 18 United States Code, Section 1956(a)(1). 24

18 U.S.C. § 1956(h)

25

COUNT FOUR (Conspiracy to Interfere with Commerce Through Robbery) The Grand Jury for the District of Maryland further charges that: 1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 2. On or about March 13, 2009, in the District of Maryland, the defendants, RANDOLPH EDISON, a/k/a “Uncle Rudy,” ZACHARY NORMAN, a/k/a “Zack,” did knowingly and willfully combine, conspire, confederate, and agree with each other and others known and unknown to obstruct, delay, and affect commerce and the movement of an article and commodity in commerce by robbery, as that term is defined in Title 18, United States Code, Section 1951(b)(1), by the unlawful taking of narcotics proceeds from the person and presence of victims. 18 U.S.C. § 1951

26

COUNT FIVE (Possession of a Firearm in Furtherance of a Crime of Violence) The Grand Jury for the District of Maryland further charges that: 1. Paragraph 1 to 17 and 20 to 96 of Count One of this Indictment is re-alleged and incorporated by reference as though fully set forth herein. 2. On or about March 13, 2009, in the District of Maryland, the defendants, RANDOLPH EDISON, a/k/a “Uncle Rudy,” ZACHARY NORMAN, a/k/a “Zack,” did knowingly possess a firearm in furtherance of a crime of violence for which they may be prosecuted in a court of the United States, that is, Conspiracy to Interfere with Commerce by Robbery, in violation of Title 18, United States Code, Section 1951, as set forth in Count Four of this Indictment. 18 U.S.C. § 924(c) 18 U.S.C. § 2

27

COUNT SIX (Possession of Ammunition by a Felon) The Grand Jury for the District of Maryland further charges that: On or about April 15, 2009, in the District of Maryland, the defendant, RAINBOW WILLIAMS, having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess ammunition, to wit: 38 rounds of .357 ammunition, in and affecting commerce. 18 U.S.C. § 922(g)(1)

28

COUNT SEVEN (Possession of a Firearm by a Felon) The Grand Jury for the District of Maryland further charges that: On or about April 15, 2009, in the District of Maryland, the defendant, KEVIN GLASSCHO, a/k/a “KG” having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess a firearm, to wit: one Taurus 9mm pistol with an obliterated serial number, in and affecting commerce. 18 U.S.C. § 922(g)(1)

29

COUNT EIGHT (Possession of a Firearm in Furtherance of a Drug Trafficking) The Grand Jury for the District of Maryland further charges that: 1. Paragraph 1 to 17 and 20 to 96 of Count One of this Indictment is re-alleged and incorporated by reference as though fully set forth herein. 2. On or about April 15, 2009, in the District of Maryland, the defendant, KEVIN GLASSCHO a/k/a “KG” did knowingly possess a firearm, to wit: one Taurus 9mm pistol with an obliterated serial number, in furtherance of a drug-trafficking crime for which he may be prosecuted in a court of the United States, to wit, conspiracy to distribute and possess with intent to distribute controlled substances, in violation of Title 21, United States Code, Section 846, as set forth in Count Two of this Indictment. 18 U.S.C. § 924(c)

Rod J. Rosenstein United States Attorney

A TRUE BILL:

Foreperson

Date

30

Sign up to vote on this title
UsefulNot useful