Case Document 2 Filed 03/05/15 Page?al of 13 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS STRICT COURT STRICT OF TE U.S- DI EASTERN DI XAS MAR [l 5 2015 DAVID MALAND, CLERK BEAUMONT DIVISION BY DEPUTY UNITED STATES OF AMERICA No. v. Judge [jg gd?'dd JOHN NEALY HOLT, (1) a/k/a John,? LESLIE DIANNE BARON, (2) a/k/a CHRISTOPHER DEAN INMAN, (3) LESLIE LEE INMAN, (4) a/k/a ERIC LAZARO CASTANEDA, (5) CARLOS EDUVIJIS ROSALES, (6) TRAVIS ALEJANDRO LYON, (7) a/k/a ?Turtle,? GILBERT GOMEZ, (8) a/k/a ?Gill,? a/k/a ?Beto,? JOSHUA LEE LANMAN, (9) ALBERT CARDENAS, JR., (10) BURTON PAUL DUPUY, (11) AMADO TOBAR, (12) JOSEPH LOUIS HENNING, (13) KENNETH SHELDRICK, (l4) LUIS FERNANDO GARCIA, (15) a/k/a ?Chino,? GERARDO CHAVEZ, (16) ALEX TREJO, (17) MICHAEL BROUGHTON, (18) SHAWN DEWAYNE KEY, (19) a/k/a ?Wolf,? TABER SHAWN PRICE, (20) a/k/a avi,? BRITANNY DANIELLE BECKHAM, (21) RICARDO CORTES LOZANO, (22) a/k/a ?Ricky,? PABLO HERNANDEZ, (23) THURMAN LEE CLEVENGER, (24) a/k/a Indictment Page 1 Case 1:15-cr-00019-TH . Document 2 Filed 03/05/15 Page ?2 of 13 PageID 3 INDICTMENT THE UNITED STATES GRAND JURY CHARGES: Count One Violation: 21 U.S.C. 846 (Conspiracy to Possess with the Intent to Distribute a Controlled Substance (Methamphetamine)). 1. That from on or about sometime in 2011, the exact date being unknown to the Grand Jury, and continuing thereafter until March 4, 2015, in the Eastern District of Texas and elsewhere, John Nealy Holt, a/k/a John,? Leslie Dianne Baron, a/k/a Christopher Dean Inman, Leslie Lee Inman, a/k/a Eric Lazaro Castaneda, Carlos Eduvijis Rosales, Travis Alejandro Lyon, a/k/a ?Turtle,? Gilbert Gomez, a/k/a ?Gill,? a/k/a ?Beto,? Joshua Lee Lanman, Albert Cardenas, Jr., Amado Tobar, Joseph Louis Henning, Kenneth Sheldrick, Luis Fernando Garcia, a/k/a ?Chino,? Gerardo Chavez, Alex Trejo, Michael Broughton, Shawn Dewayne Key, a/k/a ?Wolf,? Taber Shawn Price, a/k/a avi,? Britanny Danielle Beckham, Ricardo Cortes Lozano, a/k/a ?Ricky,? Pablo Hernandez, and Thurman Lee Clevenger, a/k/a defendants, knowingly and intentionally conspired and agreed with each other, and with persons known and unknown to the Grand Jury, to distribute and to possess with the intent to distribute a Schedule II controlled substance, namely, a mixture or substance containing a detectable amount of methamphetamine, in Violation of 21 U.S.C. 841(a)(1). Indictment Page 2 Case 1:15-cr-00019-TH Document 2 Filed 03/05/15 Page 3 of 13 PageID 4 QUANTITY OF METHAMPHETAMINE INVOLVED IN THE CONSPIRACY 2. With respect to the defendants John Nealy Holt, a/k/a John,? Leslie Dianne Baron, a/k/a Christopher Dean Inman, Leslie Lee Inman, a/k/a Eric Lazaro Castaneda, Carlos Eduvijis Rosales, Gilbert Gomez, a/k/a ?Gill,? a/k/a ?Beto,? Amado Tobar, Joseph Louis Henning, Kenneth Sheldrick, Luis Fernando Garcia, a/k/a ?Chino,? Gerardo Chavez, Alex Trejo, Shawn Dewayne Key, a/k/a ?Wolf,? Taber Shawn Price, a/k/a ?Javi,? and Pablo Hernandez, their conduct as members of the narcotics conspiracy charged in Count One, which includes the reasonably foreseeable conduct of other members of the narcotics conspiracy charged in Count One, involved ?ve hundred (500) grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, in Violation of 21 U.S.C. 3. With respect to the defendants Travis Alejandro Lyon, a/k/a ?Turtle,? Joshua Lee Lanman, and Thurman Lee Clevenger, a/k/a their conduct as members of the narcotics conspiracy charged in Count One, which includes the reasonably foreseeable conduct of other members of the narcotics conspiracy charged in Count One, involved ?fty (50) grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, in Violation of 21 U.S.C. 4. With respect to the defendants Albert Cardenas, Michael Broughton, Britanny Danielle Beckham, and Ricardo Cortes Lozano, a/k/a ?Ricky,? their conduct as members of the narcotics conspiracy charged in Count One, which includes the Indictment Page 3 Case 1:15-cr-00019-IH, Document 2 Filed 03/05/15 Page\4 of 13 PageID 5 reasonably foreseeable conduct of other members of the narcotics conspiracy charged in Count One, involved a quantity of a mixture and substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, in Violation of 21 U.S.C. Allin Violation of 21 U.S.C. 846. Count Two Violation: 18 U.S.C. 924(c)(1) (Possession of a Firearm in Furtherance of a Drug Traf?cking Crime) 5. That from on or about September 10, 2014, John Nealy Holt, a/k/a John,? and Leslie Dianne Baron, a/k/a defendants, did knowingly possessed ?rearms, to wit: one (1) Ruger, model Standard, .22 caliber pistol bearing serial number 11-47620, one (1) Berretta, model 92, 9mm caliber pistol bearing serial number BER268555, one (1) Remington Arms, model 11, 16 gauge shotgun bearing serial number 1501543, and one (1) Ruger Model M77 30-06 caliber ri?e bearing serial number 781-15128, in Houston, Texas, during and in ?n?therance of a drug traf?cking crime occurring in the Eastern District of Texas and elsewhere, as alleged in Count One of this indictment, for which they may be prosecuted in a court of the United States, namely, for a Violation of 21 U.S.C. 846, Conspiracy to Possess with the Intent to Distribute a Controlled Substance. All in Violation of 18 U.S.C. 924(c)(1) and 2. Indictment Page 4 Case Document 2 Filed 03/05/15 Page5 of 13 PageID 6 Count Three Violation: 18 U.S.C. 924(c)(1) (Possession of a Firearm in Furtherance of a Drug Traf?cking Crime) On or about September 10, 2014, Joshua Lee Lanman, defendant, knowingly possessed ?rearms, to wit: a. One (1) Mossberg, model 500, 12 Gauge shotgun, bearing serial number T5 10921 - One (1) Spring?eld, model XD45, .45 ACP caliber, semi-automatic, pistol, a bearing serial number Beretta, model PX4 Storm, .40 caliber, semi-automatic, pistol, bearing serial number Windham Weaponry Inc., model .223 caliber, semi-automatic, 'ri?e, bearing serial number Sig Sauer, model P226, 9mm caliber, semi-automatic, pistol, bearing serial number New Frontier Armory, LLC, model .223 caliber, semi-automatic, ri?e, bearing serial number Spring?eld Armory, model M1, 30 caliber, semi-automatic, ri?e, bearing serial number 2734966; Remington, model 700, .308 caliber, bolt-action, ri?e, bearing serial number RR145 Olympic Arms Inc., model PCR, .223 caliber, semi-automatic, ri?e, bearing serial number H317 1; Remington, model 1100, 12 gauge, semi-automatic, shotgun, bearing serial number Stag Arms, model Stag 15, .223 caliber, semi-automatic, pistol, bearing serial number 213388; Spring?eld Armory, model XD-45, 45 caliber, semi-automatic, pistol, bearing serial number Indictment Page 5 Case 1:15-cr-00019-TH Document 2 Filed 03/05/15 Page. 6 of 13 PageID 7 m. Sig Sauer, model 1911, 45 caliber, semi-automatic, pistol, bearing serial number n. Para Ordnance, model 1911 Black Ops Ltd., 45 caliber, semi-automatic, pistol, bearing serial number o. Windham Weaponry Inc., model 5.56 caliber, semi?automatic, pistol, bearing serial number WW03 5544; in Houston, Texas, during and in furtherance of a drug traf?cking crime occurring in the Eastern District of Texas and elsewhere, as alleged in Count One of this indictment, for I which he may be prosecuted in a court of the United States, namely, for a Violation of 21 U.S.C. 846, Conspiracy to Possess with the Intent to Distribute a Controlled Substance. A11 in violation of 18 U.S.C. 924(c)(1). Count Four Violation: 18 U.S.C. 1952(a)(3) (Using the Mail or Facility of Interstate Commerce to facilitate the interstate distribution of illegal narcotics) 7. On or about August 21, 2014, in the Eastern District of Texas and elsewhere, defendants, John Nealy Holt, a/k/a John,? and Burton Paul Dupuy used the mail, and other facilities in interstate commerce, with the intent to promote, manage, establish, carry on and facilitate the promotion, management, establishment and carrying on of an unlawful activity, that is, the possession with the intent to distribute a controlled substance in violation of 21 U.S.C. 841(a)(1), 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 such unlanul activity. In Violation of 18 U.S.C. 1952(a)(3) and 2. Indictment Page 6 Case 1:15-cr-00019-TH Document 2 Filed 03/05/15 Page?? of 13 PageID 8 NOTICE OF INTENTION TO SEEK CRIMINAL FORFEITURE Criminal Forfeiture Pursuant to 21 U.S.C. 88 853 and 881 Upon conviction of the controlled substance offense alleged in Count One of this indictment, John Nealy Holt, a/k/a John,? Leslie Dianne Baron, a/k/a Christopher Dean Inman, Leslie Lee Inman, a/k/a Eric Lazaro Castaneda, Carlos Eduvijis Rosales, Travis Alejandro Lyon, a/k/a ?Turtle,? Gilbert Gomez, a/k/a ?Gill,? a/k/a ?Beto,? Joshua Lee Lanman, Albert Cardenas, Jr., Amado Tobar, Joseph Louis Henning, Kenneth Sheldrick, Luis Fernando Garcia, a/k/a ?Chino,? Gerardo Chavez, Alex Trejo, Michael Broughton, Shawn Dewayne Key, a/k/a ?Wolf,? Taber Shawn Price, a/k/a avi,? Britanny Danielle Beckham, Ricardo Cortes Lozano, a/k/a ?Ricky,? Pablo Hernandez, and Thurman Lee Clevenger, a/k/a defendants, shall forfeit to the United States pursuant to 21 U.S.C. 853, any property constituting, or derived from, proceeds obtained directly, or indirectly, as a result of the said violation, and any property used, or intended to be used in any manner or part, to commit or to facilitate the commission of the said violation, including but not limited to the following: MONEY JUDGMENT A sum of money equal to two million ?ve hundred thousand dollars ($2,500,000) in United States currency, representing the amount of proceeds obtained as a result of the offense alleged in Count One, conspiracy to distribute and to possess with the intent to distribute a Schedule II controlled substance, namely, a mixture or substance containing a detectable amount of methamphetamine, for which the defendants are jointly and severally liable. If any of the above-described forfeitable property, as a result of any act or omission of the defendant(s): Indictment Page 7 Case Document2 Filed 03/05/15 Pagex8?of 13 Page D#: 9 cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; (0) has been placed beyond the jurisdiction of the court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without dif?culty. It is the intent of the United States, pursuant to 21 U.S.C. 853(p), to seek forfeiture of any other property of said defendants up to the value of the forfeitable property described above. By virtue of the commission of the felony offense charged in this indictment by the defendants any and all interest the defendants have in the above-described properties is vested in the United States and hereby forfeited to the United States pursuant to 21 U.S.C. 853 and/or 881. Criminal Forfeiture Pursuant to 18 U.S.C. 924(d) and 28 U.S.C. 2461(c) As the result of committing the felony offenses alleged in Counts Two and Three of this indictment, John Nealy Holt, a/k/a John,? Leslie Dianne Baron, a/k/a and Joshua Lee Lanman, defendants, shall forfeit to the United States, pursuant to 18 U.S.C. 924(d) and 28 U.S.C. 2461(c), all ?rearms and ammunition involved in the offense, including but not limited to the following, to-wit: a. One (1) Ruger, model Standard, .22 caliber pistol bearing serial number 11- 47620; b. One (1) Berretta, model 92, 9mm caliber pistol bearing serial number Indictment Page 8 Case 1:15-cr-00019-TH, Document 2 Filed 03/05/15 Page 9 of 13 PageID 10 0. One (1) Remington Arms, model 11, 16 gauge shotgun bearing serial number 1501543; (1. One (1) Ruger Model M77 30?06 caliber ri?e bearing serial number 781- 15128Mossberg, model 500, 12 Gauge shotgun, bearing serial number T5 10921; e. One (1) Spring?eld, model XD45, .45 ACP caliber, semi-automatic, pistol, bearing serial number f. One (1) Beretta, model PX4 Storm, .40 caliber, semi-automatic, pistol, bearing serial number g. One (1) Windham Weaponry Inc., model .223 caliber, semi- automatic, ri?e, bearing serial number h. One (1) Sig Sauer, model P226, 9mm caliber, semi-automatic, pistol, bearing serial number i. One (1) New Frontier Armory, LLC, model LW-IS, .223 caliber, semi- automatic, ri?e, bearing serial number j. One (1) Spring?eld Armory, model M1, 30 caliber, semi-automatic, ri?e, bearing serial number 2734966; k. One (1) Remington, model 700, .308 caliber, bolt?action, ri?e, bearing serial number 1. One (1) Olympic Arms Inc., model PCR, .223 caliber, semi-automatic, ri?e, bearing serial number m. One (1) Remington, model 1100, 12 gauge, semi-automatic, shotgun, bearing serial number n. One (1) Stag Arms, model Stag 15, .223 caliber, semi-automatic, pistol, bearing serial number 2133 88; One (1) Spring?eld Armory, model XD-45, 45 caliber, semi-automatic, pistol, bearing serial number p. One (1) Sig Sauer, model 1911, 45 caliber, semi-automatic, pistol, bearing serial number q. One (1) Para Ordnance, model 1911 Black Ops Ltd., 45 caliber, semi- automatic, pistol, bearing serial number Indictment Page 9 Case Document 2 Filed 03/05/15 Pagelo of 13 PageID 11 r. One (1) Windham Weaponry Inc., model WW-IS, 5.56 caliber, semi-automatic, I pistol, bearing serial number WW03 5544; s. all associated magazine clips, and t. all associated rounds of ammunition. A TRUE BILL C, AT GRAND JURY FOREPERSON JOHN M. BALES UNITED STATES ATTORNEY 8W Am 5, 2o]; BAYLOR WORTHAM Date Assistant United States Attorney Indictment Page 10 Case Document 2 Filed 03/05/15 Page 11 of 13 PageID 12 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS BEAUMONT DIVISION UNITED STATES OF AMERICA No. v. Judge JOHN NEALY HOLT, (1) a/k/a John,? LESLIE DIANNE BARON, (2) a/k/a CHRISTOPHER DEAN INMAN, (3) LESLIE (4) a/k/a ERIC LAZARO CASTANEDA, (5) CARLOS EDUVIJIS ROSALES, (6) TRAVIS ALEJANDRO LYON, (7) a?da ?Turtle,? GILBERT GOMEZ, (8) a/k/a ?Gill,? a/k/a? ?Beto,? JOSHUA LEE LANMAN, (9) ALBERT CARDENAS, JR., (10) BURTON PAUL DUPUY, (11) AMADO TOBAR, (12) JOSEPH LOUIS HENNIN G, (1 3) KENNETH SI-IELDRICK, (14) LUIS FERNANDO GARCIA, (15) a/k/a ?Chino,? GERARDO CHAVEZ, (16) ALEX TREJO, (17) MICHAEL BROUGHTON, (18) SHAWN DEWAYNE KEY, (19) a/k/a ?Wolf,? TABER SHAWN PRICE, (20) a/k/a avi,? BRITANNY DANIELLE BECKHAM, (21) RICARDO CORTES LOZANO, (22) a/k/a ?Ricky,? PABLO HERNANDEZ, (23) THURMAN LEE CLEVENGER, (24) a/k/a Notice of Penalty Page 1 Case 1:15-cr-00019-TH-. Document 2 Filed 03/05/15 Page 12 of 13 PageID 13 Violation: Penalty: Special Assessment: Violation: Penal?: NOTICE OF PENALTY Count One 21 U.S.C. 841(b) and 846 (Methamphetamine) If 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine - imprisonment of not less than 10 years, but not more than life, a ?ne not to exceed $10 million (or twice any pecuniary gain to the defendant or loss to any victim), or both - supervised release of at least 5 years, but not more than life; If 50 grams or more,-but less than 500 grams of a mixture or substance containing a detectable amount of methamphetamine - imprisonment of not less than 5 years, but not more than 40 years, a ?ne not to exceed $5 million (or twice any pecuniary gain to the defendant or loss to any victim), or both, and supervised release of at least 4 years, but not more than life; If less than 50 grams of a mixture or substance containing a detectable amount of methamphetamine - not more than 20 years imprisonment, a ?ne not to exceed $1 million (or twice any pecuniary gain to the defendant or loss to any victim), or both, and supervised release of at least 3 years, but not more than life. 100.00 Counts Two and Three 18 U.S.C. 924(c) Imprisonment of not less than 5 years, unless the ?rearm is brandished, in which case the minimum is 7 years, or unless the ?rearm is discharged, in which case the minimum sentence is 10 years, which must be served consecutively to any other term of imprisonment, a ?ne not to exceed $250,000.00, or both; and supervised release of not more than ?ve (5) years. In the case of a second or subsequent conviction, imprisonment of not less than 25 years which must be served consecutively to any other term of imprisonment, a ?ne not to Notice of Penalty Page 2 Case 1:15-cr-00019-TH; Document 2 Filed 03/05/15 Page 13 of 13 PageID 14 exceed $250,000, or both; and supervised release of not more than ?ve (5) years. Special Assessment: 100.00 Count Four Violation: 18 U.S.C. 1952(a)(3) Penalty: A term of imprisonment not to exceed ?ve (5) years, a ?ne not to exceed $250,000 (or twice any pecuniary gain to the defendant or loss to any Victim), or both - supervised release of not more than 3 years; Special Assessment: 100.00 Notice of Penalty Page 3