DOC 1 Filed 12/03/UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN Judge: Murphy, Stephen J. United States of America, MJ: Patti, Anthony P, Filed: 12-03-2015 At 04:33 PM SEALED MATTER (NA) VIO: 21 U.S.C. 846 V. 21 U.S.C. 841(a)(1), 841(b)(1)(B)(Vii) ROMEL CASAB, 21 U.S.C. 856(a) '18 U.S.C. 922(g) Defendant. FORFEITURE: 21 U.S.C. 853 18 U.S.C. 924 INDICTMENT THE GRAND JURY CHARGES: (21 U.S.C. 846 and 21 U.S.C. 841(a)(1), 841(b)(1)(B)(Vii) - Conspiracy to Possess with Intent to Distribute and to Distribute Marijuana) ROMEL CASAB From in or about February 2009 and continuing to in or about May 201 1. said dates being approximate, in the Eastern District of Michigan and elsewhere, ROMEL CASAB and others known and unknown to the Grand Jury, did Page I of6 DOC 1 Filed 12/03/knowingly, intentionally and unlawfully combine, conspire, confederate and agree with one another to possess with intent to distribute and to distribute 100 kilograms or more of a mixture and substance containing a detectable amount of marijuana, and 100 or more marijuana plants regardless of weight. All in Violation of Title 21, United States Code, Sections 846, 841(a)(1), and 84l(b)(1)(B)(Vii), and Pinkerton V. United States, 328 US. 640 (1946) (co? conspirator liability). COUNT TWO (21 U.S.C. 856(a) Maintaining a Drug-Involved Premises) D?l ROMEL CASAB That in or around April 2011, in the Eastern District of Michigan, Southern Division, CASAB, the defendant herein, knowingly and intentionally opened and maintained a place at 29100 Northline Road, Romulus, Wayne County, Michigan for the purpose of manufacturing and distributing marijuana, a Schedule 1 controlled substance; and that federal agents found within the premises of 29100 Northline Road, Romulus, Wayne County, Michigan on or about April 12, 2011, marijuana grow equipment, including irrigation tubs, temperature and humidity controls, ballasts, and grow lights, along with forty and thirty-?ve one-hundredths Page 2 of 6 DOC 1 Filed 12/03/15 Pg 3 Of 7 Pg ID73 (40.35) gross kilograms of a mixture or substance containing marijuana and 374 marijuana plants; and that Defendant ROMEL CASAB collected at least twenty- thousand dollars in rent payments from a person or persons who were growing marijuana within the premises at 29100 Northline Road, Romulus, Wayne County, Michigan which were owned, operated, and/or controlled by Defendant ROMEL CASAB. All in violation of Title 21, United States Code, Section 856(3). COUNT THREE (18 U.S.C. 922(g) Prohibited Person in Possession of a Firearm) D-l ROMEL CASAB That on or about April 12, 2011, in the Eastern District of Michigan, Southern Division, ROMEL CASAB, the defendant herein, having previously been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess a ?rearm that was shipped and transported in interstate or foreign commerce, speci?cally: one 0.38 caliber Smith Wesson caliber Model Air Lite ?ve?shot revolver, bearing serial number CEU3 290, with three rounds of ammunition (three 0.38 special caliber Federal cartridges). All in violation of Title 18, United States Code, Section 922(g). Page 3 of 6 DOC 1 Filed 12/03/COUNT FOUR (18 U.S.C. 922(g) Prohibited Person in Possession of a Firearm) ROMEL CASAB That on or about April 12, 2011, in the Eastern District of Michigan, Southern Division, ROMEL CASAB, the defendant herein, having previously been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess a firearm that was shipped and transported in interstate or foreign commerce, speci?cally: one 9mm caliber Parabellum Smith Wesson Model 3913 ?Lady Smith? semi-automatic pistol bearing serial number VJ C93 88 with one 9mm Luger caliber Aquila cartridge and one loaded magazine containing six 9mm Luger caliber Companhia Brasileira de Cartuchos cartridges. All in violation of Title 18, United States Code, Section 922(g). CRIMINAL FORFEITURE ALLEGATIONS (21 U.S.C. 853(a), 18 use. {5 924(d)) 1. Upon conviction of one or more of the controlled substance violations of Title 21, United States Code, Sections 841, 846, or 8567 alleged in Counts One and/or Two of this Indictment, Defendant ROMEL CASAB shall forfeit to the Page 4 of 6 DOC 1 Filed 12/03/United States, pursuant to 21 U.S.C. 853(a): any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of such violations; and any property, real or personal, used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of such violations. 2. Upon conviction of one or more ?rearms offenses in violation of Title 18, United States Code, Sections 922(g), as charged in Counts Three or Four of this Indictment, Defendant ROMEL CASAB shall forfeit to the United States, pursuant- to Title 18, United States Code, Section 924(d), any ?rearm or ammunition involved in orused in the offense. Preperty subject to forfeiture includes, but is not limited to, the following: 1. one 0.38 caliber Smith Wesson caliber Model Air Lite ?ve-shot revolver, bearing serial number CEU3290, with three rounds of ammunition (three 0.38 special caliber Federal cartridges); and 2. one 9mm caliber Parabellum Smith Wesson Model 3913 f?Lady 1 Smith? semi-automatic pistol bearing serial number VJ C9388 with one 9mm Luger caliber Aquila cartridge and one loaded magazine containing six 9mm Luger caliber Companhia Brasileira de Cartuchos cartridges. Page 5 of 6 DOC 1 Filed 12/03/accordance with Title 21, United States Code, Section 853, Title 18, United States Code, Section 924(d) and Rule 32.2 of the Federal Rules of Criminal Procedure. THIS IS A TRUE BILL s/ Grand urV Foreperson GRAND JURY FOREPERSON BARBARA L. United States Attorney 5/ David M. Gardey David M. Gardey, Chief Drug Task Force Unit 8/ Rita E. Foley Rita Elizabeth Foley Assistant United States Attorney 211 W. Fort St., Suite 2001 Detroit, MI 48226 (313) 226-9520 rita.folev@usdoi.gov Michigan Bar No. P-5636l Dated: December 3, 2015 Page 6 of 6 DOC 1 Filed 12/03/United States District Court Criminal Case Ci Judge: Murphy, Stephen J. Eastern District of Michigan MJ: Patti, Anthony p_ Filed: 12?03-2015 At 04:33 PM SEALED MATTER (NA) NOTE: it is the responsibility of the Assistant US Attorney signing this form to Ct ReassignmenthecusaI InfOI-I'Imatio'h This matter was opened in the USAO prior to August 15, 2008 Companion Case Number: ComMion- Caseinformation'w This may be a Companion case based upon 57.10 Yes No Initials: Judge Assigned: Case Title: USA v. Romel CASAB County where offense occurred Wayne Oakland Check One: Felony . Misdemeanor Petty indictment] information no prior complaint. Indictment! information based upon prior complaint [Case number: indictment! information based upon 57.10 [Complete Superseding section below]. querseding Case Information Judge: Superseding to Case No: Ci Original case was terminated; no additional charges or defendants. El Corrects errors; no additional charges or defendants. Involves, for plea purposes, different charges or adds counts. El Embraces same subject matter but adds the additional defendants or charges below: Defendant name Charges Prior Complaint (if applicable] Please take notice that the below listed Assistant United States Attorney is the attorney of record for the above captioned case. December 3, 2015 iv Date Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, (2) the same or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases even though one of them may have already been terminated. 04113