Case 1:14-cr-00387-MKB Document 47 Filed 07/09/14 Page 1 of 5 PageID #: 66

TJS:EDP
F.#2014R00236
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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-X

UNITED STATES OF AMERICA
INDICTMENT
- against -

Cl14

SHU YONG YANG,
JIABIN JIANG,
JUN FENG,
HAN WOON NG and
RONG WEI YANG,

367

(T. 18, U.S.C., §§' 922(a)(l)(A),
924(a)(l)(D), 924(d), 2 and 3551 et~.;
T. 21, U.S.C., §§ 841(b)(l)(A)(viii),
841(b)(l)(C), 846, 853(a) and 853(p); T.
28, U.S.C., § 2461(c))

Defendants.

BRODlE, J.
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-

-X

LEVY, M.J.

THE GRAND JURY CHARGES:
COUNT ONE
(Dealing in Firearms)
1.

In or about and between February 2014 and June 2014, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants SHU YONG YANG and llA BIN llANG, not being licensed importers, licensed
manufacturers or licensed dealers in firearms, did knowingly and willfully engage in the
business of dealing in firearms.
(Title 18, United States Code, Sections 922(a)(l)(A), 924(a)(l)(D), 2 and 3551
et seq.)

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COUNT TWO
(Conspiracy to Distribute and Possess with Intent to Distribute Methamphetamine)
2.

In or about and between July 2013 and June 2014, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants SHU YONG YANG, JIA BIN JIANG, JUN FENG, HAN WOON NG and RONG
WEI YANG, together with others, did knowingly and intentionally conspire to distribute and
possess with intent to distribute a controlled substance, which offense involved
methamphetamine, its salts, isomers, and salts of its isomers, a Schedule II controlled
substance, contrary to Title 21, United States Code, Section 841(a)(l).
3.

With respect to the defendants SHU YONG YANG, JIA BIN JIANG

and RONG WEI YANG, the amount of methamphetamine, its salts, isomers, and salts of its
isomers involved in the conspiracy attributable to them as a result of their own conduct, and
the conduct of other conspirators reasonably foreseeable to them, was 50 grams or more of
methamphetamine, its salts, isomers, and salts of its isomers.
(Title 21, United States Code, Sections 846, 841(b)(l)(A)(viii) and
841(b)(l)(C); Title 18, United States Code, Section 3551 et seq.)
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNT ONE
4.

The United States hereby gives notice to the defendants charged in

Count One that, upon their conviction of the offense charged, the government will seek
forfeiture in accordance with Title 18, United States Code, Section 924(d) and Title 28, United
States Code, Section 2461 (c), which require any person convicted of such offense to forfeit

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any firearm or ammunition involved in or used in any knowing violation of section
922(a)(l)(A), including but not limited to a Star 9mm pistol with serial number 1790588.
5.

If any of the above-described forfeitable property, as a result of any act

or omission of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendants up to the value of the forfeitable
property described in this forfeiture allegation.
(Title 18, United States Code, Section 924(d); Title 21, United States Code,
Section 853(p); Title 28, United States Code, Section 2461(c))
CRIMINAL FORFEITURE ALLEGATION
AS TO COUNT TWO
6.

The United States hereby gives notice to the defendants charged in

Count Two that, upon their conviction of the offense charged, the government will seek
forfeiture in accordance with Title 21, United States Code, Section 853(a), which requires any
person convicted of such offense to forfeit any property constituting, or derived from, proceeds

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obtained, directly or indirectly, as a result of such offense, and any property used, or intended
to be used, in any manner or part, to commit, or to facilitate the commission of such offense.
7.

If any of the above-described forfeitable property, as a result of any act

or omission of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendants up to the value of the forfeitable
property described in this forfeiture allegation.
(Title 21, United States Code, Sections 853(a) and 853(p))

chra& £ ~

LORETTA E. LYNCH
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK

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F. #2014R00236
FORMDBD-34
JUN. 85

No.

UNITED STATES DISTRICT COURT
EASTERN District ofNEW YORK
CRIMINAL DIVISION

THE UNITED STATES OF AMERICA
vs.

SHU YONG YANG, TIA BIN flANG, JUN FENG, HAN WOON NG
and RONG WEI YANG,
Defendants.

INDICTMENT
(T. 18, U.S.C. §§ 922(a)(l)(A), 924(d), 924(a)(l)(D), 2 and 3551 et~.;
T. 21, U.S.C., §§ 841(a)(l), 841(b)(l)(A)(viii), 841(b)(l)(C), 846, 853(a)
and 853(0); T- 28, U.S.C., § 2461(c))

-~~~-----p;;,p.;;;,
Filed in open court this _________________ day,

of ____________ A.D. 20 ____ _

Clerk

&U$ ____________________________________ _
Erik D. Paulsen, Assistant U.S. Attorney (718) 254-6135

i

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CR14

387

F.#2014R00236
INFORMATION SHEET

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

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1.

Title of Case: United States v. SHU YONG YANG, JIA BIN JIJ\NG,,:~
JUN FENG, HAN WOON NG and RONG WEI YANS-1

2.

Related Magistrate Docket Number(s): 14-M-529

3.

Arrest Date: June 11, 2014

4.

Nature of offense(s): (X)
( )

5.

Related Cases - Title and Docket Nos. NIA

6.

Projected Length of Trial:

BROD 't:' J .
1

Felony
Misdemeanor

r

LEVY, M.J.

Less than 6 weeks
More than 6 weeks

(X)

( )

7.

County in which crime was allegedly committed (Pursuant to Rule 50.l(d)
of the Local E.D.N.Y. Division of Business Rules): Queens, Brooklyn

8.

Was any aspect of the investigation, inquiry
and prosecution giving rise to the case pending
or initiated before March 10, 2012? 1

( ) Yes

(X) No

9.

Has this indictment been ordered sealed?

( ) Yes

(X) No

10.

Have arrest warrants been ordered?

( ) Yes

(X) No

11.

Capital count included?

() Yes

(X) No

LORETTA E. LYNCH
UNITED STATES ATTORNEY

By:

k----Assistant U.S. Attorney
718-254-6135

Rev. 10/04112
1

Judge Brodie will not accept cases that were initiated before March 10, 2012.

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