Case Document 22 PHILLIP United States Attorney GRANT B. RABENN ROSS PEARSON Assistant United States Attorneys 2500 Tulare Street, Suite 4401 Fresno, CA 93 721 Telephone: (559) 497?4000 Facsimile: (559) 497-4099 Attorneys for Plaintiff United States of America Filed 08/17/17 Page 1.3m AUG 2017 ISTRICTCOURT CLERK TOP-CALIFORNIA TV (21.3.5111 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CASE NO- 1: 1 0 188-110 5mg; Plaintiff, VIOLATIONS: . I 21 U.S.C. 846 and 841(a)(1), 841(b)(1)(B) v. 7 Conspiracy to Manufacture, Distribute, and Possess - with the Intent to Distribute a Controlled Substance; WILLIAM JAMES FARBER- 21 U.S.C. 841(a)(1), 841(b)(1)(D) and 18 U.S.C. aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTINSEN, MICHAEL ANGELO PALMA, MICHELE PICKERELL, and . AYSAL MUSTAFA ALKHAYAT, Defendants. 2 Distribution of a Controlled Substance, and Aiding and Abetting; 18 1956(h) Conspiracy to Launder Money; 21 U.S.C. 853 and 18 982(a)(1) Criminal Forfeiture . INDICTMENT GENERAL ALLEGATIONS At all relevant times herein: 1. The Silk Road, Pandora, and AlphaBay were dark web marketplaces facilitating the sale of illegal goods, including controlled substances. On these sites, thousands of vendors sold controlled substances throughout the world, including in the Eastern'District of California. The Silk Road, Pandora, and AlphaBay existed on the dark web, meaning they were accessible only through The Onion Router network, which anonymized the Internet Protocol addresses of their underlying servers. The use of Tor also made it dif?cult to identify the true physical locations of the webSites?s INDICTMENT 1 10 11 12 13 ?14COUNT ONE: Case Document 22 Filed-08/17/17 Page20f6 administratOrs, moderators, and users. - 2.7 I ?PureFireMeds? was a vendor of narcotics on The Silk Road and Pandora. The narcotics sold by PureFireMeds included oxycodone, hydrocodone, 'psilocybin, MDMA, lysergic acid diethylamide (LSD), Xan?ax, and Ketamine. I 3. ?HumboltharmsI? was a vendor of marijuana on AlphaBay. Humboltharms was one of the largest vendors on AlphaBay, completing more than 78,000 orders on the site. 4. IDefendants?WILLIAM JAMES FARBER, aka f?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTINSEN, MICHAEL ANGELO PALMA, MICHELE PICKERELL, and FAYSAL MUSTAFA ALKHAYAT were reSponsible for the operations of PureFireMeds and Humboltharms on the dark web marketplaces The Silk Road, Pandora, and AlphaBay. [21 U.S.C. 846 and 84l(b)(1)(B) - ConspiraCy to Manufacture, Distribute,,and Possess with Intent to Distribute a Controlled Substance] The Grand Jury charges: WILLIAM JAMES FARBER aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTINSEN, MICHAEL ANGELO PALMA, MICHELE PICKERELL, and FAYSAL MUSTAFA ALKHAYAT, defendants herein, as follows: 5. Paragraphs 1 through 4 are incorporated by reference as fully set forth herein. 6. Beginning on a?date no later- than in or around August 201.3,and continuing to in or around May 2017, in the Counties of Fresno and Kern, within the State and Eastern District of Califomia, and elsewhere, defendants WILLIAM JAMES FARBER, aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MICHAEL ANGELO PALMA, MICHELE PICKERELL, and FAYSAL MUSTAFA ALKHAYAT, through the dark web marketplaces The Silk Road, Pandora, and AlphaBay under the monikers PureFireMeds and Humboltharms, did knowingly INDICTMENT Case Document 22 Filed 08/17/17 Page 3 of 6 and intentionally conspire among themselves and with other persons, known and unknown to the Grand Jury, to manufacture, distribute, and possess with intent to distribute a controlled substance, to wit: marijuana, lysergic acid diethylamide (LSD), MDMA, and psilocybin, all Schedule I controlled substances; cocaine, oxycodone, hydrocodone, all Schedule II controlled substances; and Ketamine, a Schedule controlled substance, all in violation of Title 21, United. States Code, Sections 846 and 84l(a)(1), 7. his further alleged that the above offense involved one hundred or more kilograms of a mikture of substances containing a detectable amount of marijuana or onehundred or more marijuana plants and that these quantities were knoWn to and reasonably foreseeable by all of the charged defendants. COUNT TWO: [21 U.S.C. 841(a)(1), and 18 U.S.C. 2 Distribution ofa Controlled Substance, and Aiding and Abetting] . The Grand Jury further ?charges: I 4 WILLIAM JAMES - .aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTINSEN, MICHAEL ANGELO PALMA, MICHELE PICKERELL, and FAYSAL MUSTAFA ALKHAYAT, defendants herein, as follows: i 8. Paragraphs 1 through 4 are incorporated by reference as fully set forth herein. 9. From on or about ebruary'23, 2017 through on or about March 3, 2017, in the County of Fresno, within the State and. Eastern District of California, and elseWhere, defendants WILLIAM JAMES FARBER, aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTINSEN, MICHAEL ANGELO PALMA, MICHELEPICKERELL, and FAYSAL MUSTAFA ALKHAYAT, through the dark web marketplace AlphaBay under the moniker Humboltharms, did knowingly and intentionally distribute, and aid and abet the distribution of, a controlled substance, to INDICTMENT '20. Case Document 22 Filed 08/17/17 Page 4 ofi6 wit: marijuana, aIS'chedule I controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1), and Title ?18, United States Code, Section 2. . COUNT THREE: [1?8 U.S.C. 1956(h) Conspiracy to Launder'Mon'ey] The Grand Jury further charges: I WILLIAM JAMES. FARBER aka ?Bill Danzerian,? and BRYAN ANTHONY LEMONS, defendants herein, as follows: 10. Paragraphs 1 through 4 are incorporated by- reference as fully set forth herein. 1 1. Beginning on a date no later than in or around August 2013, and continuing through in or around May 2017, in the Counties of Fresno. and Kern, within the State and Eastern District of California and elsewhere, defendants WILLIAM JAMES FARBER aka ?Bill Danzerian,? and BRYAN I ANTHONY LEMONS, and others known and unknown to the Grand Jury, knowingly Combined, conspired, and agreed with each other and other persons known and unknown to the Grand Jury to commit an offense against the United States inviolation of Title 18, United States Code, Sections and 1957, to wit: to knowingly condUCt a ?nancial transaction affecting interstateand foreign commerce, which involved the proceeds of a speci?ed unlawful activity, to wit: distribution of a controlled substance, in violation of Title 21, Uni-ted States Code, Section 841(a)(1), knowing that the transaction was designed in whole or in part to conceal and disguise the nature, location, soUrce, ownership, and control of the proceeds of such speci?ed Unlawful activity, and that while conducting such ?nancial transactions, knew that the property involved in the ?nancial transaction represented the proceeds of some form of unlawful activity; and to knowingly engage in a monetary transaction involving'criminally derived property, through a ?nancial institution, affecting interstate'or foreign commerce, of a value greater than $10,000, such property having been derived from a speci?ed unlawful activity, to wit: the distribution of a controlled substance, in violation of Title 21, United States Code, Section 841 INDICTMENT 27' 28' Case Document 22 Filed 08/17/17 Page 5 of 6 FORFEITUREALLEGATION: [21 and18 Criminal Forfeiture] . 12. Upon conviction of one or more of the offenses alleged in Counts Oneand Tvvo, defendants WILLIAM JAMES FARBER aka ?Bill Danzerian,? BRYAN ANTHONY LEMONS, RYAN THOMAS MARTIN MICHAEL ANGELO PALMA, MICHELE PICKERELL, and A FAYSAL MUSTAFA ALKHAYAT shall forfeit to the United States pursuant to Title 21, Uni-ted States- Code, Section 853(a), any, property constituting or derived-from proceeds obtained, directly or I indirectly, as a result of such offenses, and any property used, or intended to be used, in any manner-or part, to commit or to facilitate the commission of the offenses, including but not limited to: a. Real property located at 805 W. Gabrielino Court, Altadena,lCalifornia, APN: 5863-023-044money equal to the total amount of proceeds obtained as a result of the offenses, or conspiracy to commit such offenses, for Which defendants are convicted. I I 13, Upon conviction of one or more of the offenses alleged in Count Three, defendants WILLIAM JAMES FARBER aka ?Bill Danzerian,? and BRYAN ANTHONY LEMONS shall forfeit to the United-States purSuant to Title 18, United States Code, Section 982(a)(1), all property, real or personal, involved in the offenses, and any property traceable thereto, or the criminal conduct or criminal scheme or conspiracy alleged in this Indictment. 14. If any property subject to forfeiture, as a result of the offenses alleged in Counts One - through Three of this Indictment, for which defendants are convicted: a. I 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; . - has been substantially diminished in value; or e. 1 has been commingled with other property vvhich cannot be divided withdut dif?culty; - I it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), and .27. 28 Case Document 22 Filed 08/17/17 Page 6 of6 Title .18, United States Code, Section 982(b)(1), to Seek forfeiture of any other property of defendant, up to the value of the property subj eat to forfeiture. A TRUE BILL. 7 Isl Slgnatura on file FOREPERSQN . PHILLIP-A. TALBERT United States Attorney KIHK E. SHERRIFF KIRK E. SHERRIFF Assistant United States Attorney Chief, Fresno Division INDICTMENT