Case 1:17-cr-00159-AT-JKL Document 1 Filed 05/03/17 Page 1 of 6

ORIGINA

f ILED IN CHAMBERS
U.S.D.C.-Atlanta

I N T H E U N I T E D STATES DISTRICT C O U R T

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MAY 0 3 2017

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James N. Hattgn, ci^rk

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FOR T H E N O R T H E R N DISTRICT O F GEORGIA
A T L A N T A DIVISION

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U N I T E D STATES OE A M E R I C A

Criminal Indictment

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No.iS l ? C l 0 i 5 9

W I L L I A M JACKSON A N D
GERREN JOHNSON

UNDERSEAL
T H E G R A N D JURY C H A R G E S T H A T :

Count One
Beginning from on or about February 1,2013, and continuing to on or about
April 17,2014, in the Northern District of Georgia and elsewhere, the defendants,
WILLIAM JACKSON and GERREN JOHNSON, with each other and with others
known and unknown, did willfully combine, conspire, confederate, and agree to
engage in business of dealing in firearms without a license, in violation of Title
18, United States Code, § 922(a)(1)(A).
The Manner and Means
The conspirators would and did use the following manner and means, among
others, to accomplish the objects of the conspiracy:
a. At all times relevant to the indictment, defendant Jackson and defendant
Johnson, along with others known and unknown, acquired firearms through
private sales.
b. At all times relevant to the indictment, the acquired firearms were
subsequently posted for sale on the websites Black Market Reloaded ("BMR")

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and Agora Market, which were TOR websites that were designed to make it
difficult to identify the persons who accessed those sites. The firearms were
specifically posted on vendor pages bearing the profile names CherryFlavor and
CherryFlavor_2, respectively.
c. Interested buyers would send a message to the vendor, CherryFlavor or
CherryFlavor_2, indicating the firearm they wanted to purchase.
d. The buyers, who all resided outside the United States, paid for the firearms
using Bitcoins, a cryptocurrency which makes the transactions difficult to trace to
the parties involved.
e. The defendants, aided and abetted by each other and other known persons,
concealed the firearms in electronic items and mailed them to buyers abroad
using the United States Post Office. These packages were shipped to various
countries, to include Australia, Austria, Belgium, Canada, Denmark, France,
Germany, the Netherlands, Sweden, and the United Kingdom.
Overt Acts
To further the objectives of the conspiracy, and to accomplish its goals, the
following overt acts, among others, were committed in the Northern District of
Georgia and elsewhere:
a. On or about February 1,2013, defendant Johnson purchased from a local
seller an Armitage International, Model Scarab Skorpion, 9mm pistol, SN#
00643.
b. On or about March 12,2013, the Skorpion pistol referenced in paragraph a
was recovered in the Netherlands. The buyer, who was located in the
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Netherlands, advised that the buyer purchased the firearm from BMR
vendor CherryFlavor.
c. On or about May 4,2013, defendant Jackson purchased a Zastava, Model
CZ, 9mm pistol, SN# 96378.
d. On or about May 27, 2013, BMR vendor CherryFlavor sold a Zastava pistol
to a buyer located in Australia.
e. On or about June 1,2013, Australian agents intercepted a package that they
subsequently searched. During the search, the agents found the Zastava
pistol, bearing SN# 96378, hidden inside a karaoke machine.
f. On or about June 18, 2013, the Australian buyer of the Zastava pistol,
referenced in paragraphs c, d, and e, advised that he purchased the firearm
from BMR vendor CherryFlavor.
g. On or about November 6, 2013, defendant Johnson purchased from a local
seller a Cobray, Model M-11 Georgia Commemorative, 9mm pistol.
h. On or about November 8,2013, BMR vendor CherryFlavor posted a
Cobray pistol for sale.
i. On or about April 1, 2014, defendant Johnson purchased from a local seller
a Glock, Model 17 Gen 4,9mm pistol, SN# WMX221.
j.

On or about April 2, 2014, Agora vendor CherryFlavor_2 sold a Glock,
Model 17 Gen 4,9mm pistol to a buyer located in France.

k. On or about April 2, 2014, a Postal Inspector intercepted a box at the U.S.
Post Office in Lithonia, Georgia after a known co-conspirator delivered it
for shipment abroad. During a subsequent search of that box, agents
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located a Glock, Model 17 Gen 4, 9mm pistol, SN# WMX221, hidden inside
a speaker. The recipient address listed on the intercepted package was
Sebbagh Alexandre, Post Restante, La Poste, Allee Andre Bemoist, 77410
Claye-Souilly, France.
All in violation of Title 18, United States Code, § 371.
Count Two
On or about May 28, 2013, in the Northern District of Georgia, the defendant
WILLIAM JACKSON, aided and abetted by others known, did fraudulently and
knowingly export and send from the United States merchandise, articles and
objects, that being a Zastava, Model CZ, 9mm firearm, contrary to the laws and
regulations of the United States, in that the firearm was not declared to a contract
and common carrier, in violation of Title 18, United States Code, § 922(e), all in
violation of Title 18, United States Code, §§ 554 and 2.
Count Three
On or about April 2, 2014, in the Northern District of Georgia, the defendant
GERREN JOHNSON, aided and abetted by others known, did fraudulently and
knowingly export and send from the United States merchandise, articles and
objects, that being a Glock, Model 17 Gen 4, 9mm firearm, contrary to the laws
and regulations of the United States, in that the firearm was not declared to a
contract and common carrier, in violation of Title 18, United States Code,
§ 922(e), all in violation of Title 18, United States Code, §§ 554 and 2.

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Forfeiture Provision
Upon conviction of the offense alleged in the Indictment, the defendants,
WILLIAM JACKSON and GERREN JOHNSON, shall forfeit to the United States
pursuant to 18 U.S.C. § 924 (d) and 28 U.S.C. § 2461(c), all firearms and
ammunition involved in the commission of the offense, including, but limited to,
the following:
a. Glock, Model 17 Gen 4, 9mm pistol, SN# WMX221;
b. Armitage, Model Scarab Skorpion, 9mm pistol, SN# 00643;
c. Zastava, Model CZ, 9mm pistol, SN# 96378; and
d. Cobray, Model M-11 Georgia Commemorative, 9mm pistol.
If any of the above-described forfeitable property, as a result of any act or
omission of the defendant(s):
(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 21 U.S.C. § 853(p) as incorporated

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by 28 U . S . C . § 2461(c) to seek forfeiture of any other property of said defendants
up to the value of the forfeitable property described above.
A

JOHN A . HORN

United States Attorney

TRACIA M . KING

Assistant

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United States

Attorney

Georgia Bar No. 421380

STEPHANIE GABAYVSMIT

Georgia Bar No. 663519
600 U.S. Courthouse
75 Ted Turner Drive S W
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

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BILL