Doc 812 Filed 01/03/4575 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED STATES OF AMERICA V. D-1 BILLY ARNOLD, a/k/a ?B-Man,? ?Berenzo,? D-2 STEVEN ARTHUR JR., a/k/a ?Steve?O" D-3 EUGENE FISHER, a/k/a ?Fist? D-4 COREY BAILEY, a/k/a ?Sonny,? ?Cocaine Sonny? D-5 QUINCY GRAHAM, a/k/a' ?Dub,? D-6 ROBERT BROWN II a/k/a D-7 JEROME GOOCH _a/k/a ?Rome,? ?Dada? D-8 MICHAEL ROGERS a/k/a ?Smoke,? ?Ace? D-9 DERRICK KENNEDY a/k/a ?Dip? D-1O DEVON PATTERSON a/k/a ?Duck,? ?Sosa? CHRISTOPHER OWENS a/k/a ?Baby ?Cee? D-12 JEFFERY ADAMS a/k/a ?Brick,? ?Product? ARLANDIS SHY II a/k/a ?Grymee,? ANTHONY LOVEJOY a/k/a (ID NO. 15-20652 HON. GEORGE CARAM STEEH 18 U.S.C. 1962(d); 18 U.S.C. 1959(a)(1); 18 U.S.C. 1959(a)(3); 18 U.S.C. 1959(a)(5); 18 U.S.C. 924(0); 18 U.S.C. 922(g)(1); 18 U.S.C. 2 v.9: Doc 812 D-15 DIONDRE FITZPATRICK a/k/a ?D-Nice? - D-16 JAMES ROBINSON a/k/a ?Wick? D-17 DONELL HENDRIX a/k/a ?Jig? MATLEAH SCOTT a/k/a ?Thang D-19 KEITHON PORTER a/k/a JEFFAUN ADAMS a/k/a ?J-Rock? D-21 MARTEZ HICKS a/k/a ?Rayful? Filed 01/03/4576 SIXTH SUPERSEDING THE GRAND JURY CHARGES: COUNT ONE 18 U.S.C. 1962(d) RICO Conspiracy D-2 D-3 D-5 D-7 BILLY ARNOLD STEVEN ARTHUR JR. EUGENE FISHER COREY BAILEY QUINCY GRAHAM ROBERT BROWN JEROME GOOCH MICHAEL ROGERS D-9 DERRICK KENNEDY D-1O DEVON PATTERSON D-11 CHRISTOPHER OWENS D-12 JEFFERY ADAMS D-13 ARLANDIS SHY II D-14 ANTHONY LOVEJOY DIONDRE FITZPATRICK Doc 812 Filed 01/03/4577 JAMES ROBINSON D-17 DONELL HENDRIX D-19 KEITHON PORTER D-20 JEFFAUN ADAMS D-21 MARTEZ HICKS The Enterprise 1. The Seven Mile Bloods, commonly referred to as, and hereinafter referred to as, is a street gang that operates primarin on the east side of Detroit, Eastern District of Michigan, specifically the area in and around Gratiot Avenue to the west, Kelly Road to the east, Eight Mile to the north, and Seven Mile to the south. SMB members have claimed this area as their territory and refer to it as the ?Red Zone.? The main streets in the area that the SMB conduct many of their illegal narcotics trafficking are Lappin, Coram, Novara, Liberal, Manning, and Tacoma. This particular area of Detroit?s zip code in 748205, which SMB members change into ?4-8-2?O-Die? in many of their rap lyrics. 2. The SMB consists of the SMB, older individuals involved in the gang, and Hobsquad, a distinct set affiliated with the SMB. Initially, the Hobsquad was known as SMB Juniors and consisted of younger, school- aged minors from this neighborhood. The SMB Juniors changed their name to Hobsquad in honor of SMB member, lhab Maslamani, who was convicted of the homicide of Matthew Landry in 2010. 3 Doc 812 Filed 01/03/4578 3. SMB and Hobsquad members utilize a variety of unifying marks, manners, and identifiers, including ?gang signs,? clothing, and tattoos that are specific to the organization. A common symbol is the five?pointed star, a hand sign with all five fingers, or a crown with five points which represents the fact that the SMB belong to the ?People Nation,? an alliance of various street gangs including the Bloods, Vice Lords, Latin Kings, and Latin Counts. - This alliance is in direct conflict with'the ?Folk Nation,? an alliance of various street gangs including the Gangster Disciples and the Crips. The SMB also identify themselves with the number ?55? and sometimes refer to themselves as ?55 Crew" or ?55 Grinch.? SMB members will also identify themselves with the number ?762? which stands for the numbers on a keypad that a person would push to type out SMB and ?19 13 2? which represents the numerical order in the alphabet for SMB. Members will often tattoo themselves with these gang symbols. Many of the SMB symbols, clothing, and sayings attempt to differentiate themselves from or disrespect their rivals. The SMB colors are predominately red which the gang members signify by wearing red clothing, hats, and bandanas. 4. SMB members and associates regularly use social networking websites such as Facebook, lnstagram, Twitter, and YouTube, to post photographs, videos, and statements that identify and highlight their DOC #7812 Filed 01/03/4579 affiliation with the enterprise, as well as their gang-related accomplishments, thereby glorifying and perpetuating SMB. SMB is also heavily involved in the rap music scene. SMB members regularly post videos of their rap music and discuss their gang affiliation and accomplishments via rap. SMB has a close relationship with ?Hard Work Entertainment.? 5. The enterprise makes its money predominately through the sale and distribution of controlled substances, including cocaine, heroin, marijuana, codeine promethazine, and various prescription pills. SMB members sell these controlled substances within the ?Red Zone,? outside of vacant houses known as ?trap houses.? Within the time frame of the charged enterprise, higher-ranking SMB members would often sell on the same block of Manning Street sharing workers and firearms to distribute and protect their narcotics. SMB members also travel to West Virginia, Ohio, Kentucky, and other states to sell controlled substances. 6. The SMB is currently in an active gang war with analliance of other gangs operating on Detroit?s east side including, but not limited to: Hustle Boys, East Warren, Six Mile Chedda Ave., Gutta Boys, Maxout 220, BossHogs,? and Hustle Hard. While the rivalries between these gangs has existed for some time, the murder of D.P. on July 14, 2014 by SMB members exacerbated the tension between the gangs and led to the alliance of the Doc 812 Filed 01/03/4580 other east side gangs against the SMB. Since July 2014, these rivals are violently attacking one another and have posted respective ?hit lists? on social media. The shooting of RC. on May 1, 2015, as further described in Counts Ten through Twelve, was committed on the same day that SMB enterprise member A was killed and was a vengence shooting in this gang war. The Enterprise 7. At all times relevant to this Count of the Sixth Superseding Indictment, in the Eastern District Of Michigan, and elsewhere, the SMB, including its leadership, members, and associates constituted an enterprise, as defined by Title 18, United States Code, Section 1961 (4), that is, a group of individuals associated in fact, that was engaged in, and the activities of which affected, interstate and foreign commerce. The enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise. At various times relevant to this Indictment, BILLY ARNOLD, STEVEN ARTHUR JR., EUGENE FISHER, COREY BAILEY, QUINCY GRAHAM, ROBERT BROWN, JEROME GOOCH, MICHAEL ROGERS, DERRICK KENNEDY, DEVON PATTERSON, CHRISTOPHER OWENS, JEFFERY ADAMS, ARLANDIS SHY II, ANTHONY LOVEJOY, DIONDRE FITZPATRICK, Doc 812 Filed 01/03/4581 JAMES ROBINSON, DONELL HENDRIX, KEITHON PORTER, JEFFAUN ADAMS, MARTEZ HICKS, and others, were members and associates of the Seven Mile Bloods. Purposes of the Enterprise 8. The purposes of the enterprise included the following: a. Maximizing profits for enterprise members from a variety of illegal activity; b. Preserving and protecting the power, territory, and profits of the enterprise through the use of intimidation and violence, including assaults and threats of violence; 0. Promoting and enhancing the enterprise and its members? and associates? activities; d. Keeping victims in fear of the enterprise and in fear of its members and associates through threats of violence and violence. Manner and Means of the Enterprise I 9. The manner and means used by the enterprise to further the goals of the enterprise and achieve its purposes included, but was not limited to, the following: a. Members of the enterprise and their associates committed, conspired, attempted and threatened to commit acts of violence including DOC 812 Filed 01/03/4582 acts involving murder and assaults with dangerOus weapons to protect and expand the enterprise?s criminal operations. b. Members of the enterprise and their associates promoted a climate of fear through violence and threats of violence. c. Members of the enterprise and their associates used and threatened to use physical violence against various individuals. d. Members Ofthe enterprise and their associates distributed controlled substances and transported and distributed proceeds from the sale of controlled substances. The Racketeerinq Conspiracy 10. Beginning on a date unknown, but starting no later than the year 2003, and continuing to the date of this Sixth Superseding Indictment, in the Eastern District of Michigan and elsewhere, BILLY ARNOLD STEVEN ARTHUR JR. EUGENE FISHER COREY BAILEY . QUINCY GRAHAM ROBERT BROWN JEROME GOOCH MICHAEL ROGERS DERRICK KENNEDY DEVON PATTERSON CHRISTOPHER OWENS JEFFERY ADAMS ARLANDIS SHY II ANTHONY LOVEJOY Doc 812 Filed 01/03/4583 DIONDRE FITZPATRICK JAMES ROBINSON DONELL HENDRIX KEITHON PORTER JEFFAUN ADAMS - MARTEZ HICKS and other persons not named in this Sixth Superseding Indictment, being persons associated with the SMB, which enterprise is described more fully in Paragraphs 1 through 9 above, which was engaged in, and the activities of which affected, interstate and foreign commerce, did knowingly, willfully and unlawfully combine, conspire, confederate, and agree with one another to violate Title 18, United States Code, Section 1962(0); that is, to conduct and participate, directly and indirectly, in the conduct of the affairs of said enterprise through a pattern of racketeering activity, as defined in Title 18, United States Code, Section 1961(1) and (5), consisting of multiple: a. Threats and acts involving murder, in violation of Michigan Compiled Laws, Sections 750.83, and 767.39; b. Threats and acts involving robbery, in violation of Michigan Compiled Laws, Sections 750.529, 750.92, and 767.39;land c. Offenses involving conspiracy to distribute and distribution of controlled substances in violation of Title 21, United States Code, Sections 841 and 846; DOC 812 Filed 01/03/4584 d. Acts indictable under Title 18, United States Code, Section 1512 (witness intimidation). 11. It was. part of the conspiracy that defendants, BILLY ARNOLD, STEVEN ARTHUR JR., EUGENE FISHER, COREY BAILEY, QUINCY GRAHAM, ROBERT BROWN, JEROME GOOCH, MICHAEL ROGERS, DERRICK KENNEDY, DEVON PATTERSON, CHRISTOPHER OWENS, JEFFERY ADAMS, ARLANDIS SHY II, ANTHONY LOVEJOY, DIONDRE FITZPATRICK, JAMES ROBINSON, DONELL HENDRIX, KEITHON PORTER, JEFFAUN ADAMS, MARTEZ HICKS, and others, known and unknown to the grand jury, agreed that a conspirator would commit at least two acts of racketeering in the conduct of the affairs of the enterprise. Overt Acts In furtherance of the conspiracy, and to affect the object and purposes thereof, the defendants, and others known and unknown to the grand jury, committed various overt acts, including but not limited to the following: (1) On or about August 15, 2016, DERRICK KENNEDY was arrested with 265 oxycodone pills, $2,151, and a phone in possession in Quincy, West Virginia. 10 DOC 812 Filed 01/03/4585 (2) On or about July 13, 2016, JAMES ROBINSON was present at 15715 Coram Street, Detroit in a residence where six firearms, methamphetamine, Xanax, cocaine, and marijuana were found. (3) On or about December 15, 2015, a rap video entitled ?HardWork Jig ft Cocaine Sonny was published on YouTube. (4) On or about November 10, 2015, JEFFERY ADAMS posted on his Facebook status, ?Riding around getin my up arm strong from liftin techs up pussy nigga throw you setsup I dare a nigga disrespect us REDZONE data da Bhive no we not tryna 5ease fire gripin tools like sum new pliers steaming niggaz kus we keep irons (5) On or about November 3, 2015, ROBERT BROWN posted on his Facebook status, ?#Zonelife? and ?#Manningboyz 100 years.? (6) On or about October 14, 2015, ROBERT BROWN posted a picture of himself on Facebook flashing a ?55? gang sign with the title, ?Rip Whites Rip Block.? 1 (7) On or about October 2, 2015, JEFFERY ADAMS posted on his Facebook status that a certain SMB enterprise member was a ?federal informant.? 11 Doc 812 Filed 01/03/4586 (8) On or about October 2, 2015, EUGENE FISHER posted a picture on his Facebook status with the comment, ?The Feds just took my ar that my bro holding.? (9) On or about September 28, 2015, JEFFERY ADAMS posted on his Facebook status, ?Bro ah home 955d bond money on de*k #Free' DaBadGuyz.? (10) On or about September 26, 2015, BILLY ARNOLD and STEVEN ARTHUR JR. were arrested in possession of a Bushmaster .223 caliber rifle. (11) On or about September 26, 2015, an unindicted SMB enterprise member was arrested in possession of a P89 Ruger 9mm handgun in a car being driven by ARLANDIS SHY and which included JEFFAUN ADAMS and another SMB enterprise member. (12) On or about September 26, 2015, BILLY ARNOLD texted EUGENE FISHER that need to get in yo crib and grab my hook ups.? (13) On or about July 27, 2015, JEFFERY ADAMS posted on his Facebook status, ?Its 10 different gangs in 1 goup an yaII still kant fuk wit us #42k 19 132.? A (14) On or about July 5, 2015, and DIONDRE FITZPATRICK were found in Harper Woods, Michigan passed out in a car 12 DOC 812 Filed 01/03/4587 'with a loaded .40 caliber Smith Wesson handgun between legs. I (.15) On or about June 18, 2015, BILLY ARNOLD, JAMES . ROBINSON, KEITHON PORTER, and others were at 20075 Westphalia Street, Detroit, Michigan, 3 location where police found cocaine, marijuana, 53 ecstasy pills, two digital scales, empty ziplock bags, cellular phones, and ammunition. I (16) On or about June 7, 2015, DC. and AB. were shot in Roseville, Michigan by ARNOLD and JAMES ROBINSON. (17) On or about May 26, 2015, BILLY ARNOLD and DERRICK KENNEDY sent numerous text messages to each other in reference to a narcotics transaction. (18) On or about May 15, 2015, BILLY ARNOLD and DERRICK KENNEDY sent numerous text messages to each other in reference to a narcotics transaction. (19) On or about May 10, 2015, BILLY ARNOLD sent a number of text messages to QUINCY GRAHAM, DIONDRE and DERRICK KENNEDY in reference to posting a rap video online. 13 Doc 812 Filed 01/03/4588 (20) On or about May 10, 2015, in Detroit, Michigan, BILLY ARNOLD, ROBERT BROWN, and others shot over sixty rounds of ammunition at a car containing D.P., DC, and J.G. (21) On or about May 9, 2015, BILLY ARNOLD sent a text message to ROBERT BROWN that stated, ?Man I just hope you strap I?m tired of loosing niggaz because niggaz don?t be strapped and in they own worlds real shit dawg,? to whiCh ROBERT BROWN replied, ?Dbow do.? 7 (22), On or about May 9, 2015, BILLY ARNOLD sent a text message to DERRICK KENNEDY that stated, ?Dawg I aint trying to hear shit dawg I gotta nigga gone sell me a ar for 7 and it?s a nigga now wit a choppa too we getting both igot to get back down the way get my shot dip don?t play wit me right now man I know we always talking shit but this block and I?m ready to die right now.? i (23) On or about May 9, 2015, BILLY ARNOLD and DERRICK KENNEDY sent numerous text messages to each other in reference to a narcotics transaction until they finally agreed to meet at EUGENE house. I (24) On or about May 8, 2015, BILLY ARNOLD sent MATLEAH SCOTT a text message that stated, should here bout it.? 14 Doc 812 Filed 01/03/4589 (25) On or about May 8, 2015, D.R.-1 was killed, M.W. was shOt in the neck, hand, and chest, and D.R.-2 was shot in the head by BILLY ARNOLD, KEITHON PORTER, and ARLANDIS SHY in Detroit, Michigan. (26) On or about May 2, 2015, BILLY ARNOLD sent a text message to MATLEAH SCOTT that stated, can?t talk to sis I don?t even care for I living that?s everything heard about dropping after we lost him I was on it and I?m not stopping to everybody dies everybody girls niggaz it don?t matter It?s ova that wasn?t nothing yesterday it?s many more I?ve yall just know I got yall forever.? On or about May 2015, BILLY ARNOLD sent text messages to ROBERT BROWN that stated, got in a shoot out last night dub left me? 1 and bullet pierce my hoodie.? (28) On or about May 1, 2015, RC. was shot multiple times by BILLY ARNOLD and KEITHON PORTER in Detroit, Michigan. (29) On or about April 11, 2015, ROBERT BROWN and other SMB enterprise members assaulted D.T. and took shoes, cell phone, and other property. 1 (30) On or about April 1, 2015, ROBERT BROWN posted a picture of marijuana on Facebook with the title, ?Face time I got hate when y?all ready FB friends and family.? 15 Doc 812 Filed 01/03/4590 (31) On or about March 3, 2015, ROBERT BROWN posted on his Facebook status, THE 5 I LOVE ALL MY NIGGAS I WILL RIDE AND DIE 4 ALL MY NIGGAS THIS IS TO ALL MY NIGGAS WE ANIT LOSING NO MORE BROTHERS EVERY BODY SQUAD IN COMMENT FOR AKA WHITE BOY JASON RIH 5 20 YEARS BLOOD (32) On or about March 2, 2015, JEFFERY ADAMS posted on his Facebook status, WAR READY AT ALL TIME5 #000 #Gang." (33) On or about February 27, 2015, JEFFERY ADAMS posted on his Facebook status, KOURT PRE55 ON DA 5TREET5 IF NOT #55 #000 OR 5HIT (34) On or about February 17, 2015, EUGENE FISHER posted on his Facebook status, ?love 2 my partners on lock down! Rip 2 my niggas thats no longer around! Yall my I?m so strong, if it was? nt 4 yall probably been long gone! 18?3 SMB RED ZONE to which SMB enterprise member commented, bitch we still p0pin Bitch (35) On or about January 30, 2015, EUGENE FISHER posted on his Facebook status, ?My nigga BLOCK beat his case 2day! I hit the snitching ass lil nigga in his mouth and almost went 2 jail at Frank Murphy. The nigga was still trying 2 snitch after I hit him in his shit, some niggas never learn! Guess he got it hones from his snitching ass.? 16 Doc 812 Filed 01/03/4591 (36) On or about January 23, 2015, JEFFERY ADAMS posted a picture of himself and JEFFUAN ADAMS each holding a gun on Facebook with the following title ?Buck Buck red dot a nigga #Gang.? (37) On or about January 10, 2015, JEFFERY ADAMSposted on his Facebook status, LITE A I I (38) On or about December 28, 2014, JEFFERY ADAMS posted a picture of four handguns on Facebook with the following title?42k we killin everything dey stand foe.? (39) On or about November 28, 2014, JEFFERY ADAMS posted a picture of controlled substances on Facebook with the following (title on deck.? (40) On or about September 22, 2014, JEROME GOOCH and QUINCY GRAHAM were found in an apartment in Charleston, West Virginia that contained approximately 330 Oxycontin pills,la loaded .45 caliber Glock handgun, and U.S.,currency. (41) On or about August 28, 2014, JEROME GOOCH was arrested with $1,680 in his possession in Charleston, West Virginia. (42) On or about July 28,2014, a rap album entitled ?Betrayal: Stop Bleekin? was posted on YouTube by ROBERT BROWN, under the name of 17 DOC 812 Filed 01/03/4592 Da Great,? with rap songs performed by BROWN, BAILEY, and HENDRIX. (43) On or about July 22, 2014, COREY BAILEY was arrested in the area of 15621 Novara Street, Detroit, Michigan with a loaded .40 caliber Smith Wesson handgun and a loaded SKS rifle. (44) On or about July 14, 2014, in Detroit, Michigan, BILLY ARNOLD and COREY BAILEY shot at a car containing D.P., M.D.-1, M.D.-2, and CC. (45) On or about July 14, 2014, DP. was killed and M.D.-1 was shot I in the chest by BILLY ARNOLD and COREY BAILEY in Detroit, Michigan. (46) On or about or about June 15, 2014, ROBERT BROWN posted a picture of himselfand another SMB enterprise memberflashing a ?55? gang sign on Facebook. (47) On or about March 21, 2014, JEFFERY ADAMS posted on his Facebook status, got 402 left.? (48) On or about February 21, 2014, a rap video entitled SONNY FT BERENZO BLOCK was published on YouTube. (49) On or about November 22', 2013, a rap video entitled ?Cocaine Sonny ft. HardWork Jig Berenzo Hust" was publiShed on YouTube. (50) On or about November 7, 2013, a rap video entitled ?Cocaine I Sonny ft. Berenzo was published on YouTube. 18 Doc 812 Filed 01/03/4593 (51) On or about September 16, 2013, JEFFERY ADAMS posted on his Facebook status, ?Its seem like everybody SMB or HOBSQUAD beef wit niggaz always tellin da police (hustleboyz) been snitchin (220) snitchin got paper work on dem (maxout) snitchin on da news I guess SMB da last real niggaz left (52) LEFT (53) On or about July 24, 2013, JEROME GOOCH was arrested with $3,127, ninety oxycodone pills, and a loaded .45 caliber handgun in Detroit, Michigan. (54) On or about May 7, 2013, an unindicted SMB enterprise member posted on JEFFERY ADAMS Facebook account, ?Deyjust bossed up I been doing my thang I earned my stripes out here im like tuff da game eastside yung niggas da mission to get paid we still wype Niggas out da chedda gangs 7mile blood or should I go by da codename.? (55) On or about March 8, 2013, a rap video entitled ?HardWork Jig Welcome To HOB City intro? was published on YouTube. (56) On or about February 23, 2013, FITZPATRICK, SMB enterprise member A, SMB enterprise member D, and other SMB enterprise - members and associates, were stopped in a white BMW limousine from 19 DOC 812 Filed 01/03/184594 which four loaded firearms, one unloaded'firearm, and US. currency was recovered. (57) On or about December 30, 2012, JEFFERY ADAMS posted a picture of himself identifying himself as KING Product" with the following title so its. fuck niggaz (58) On or about October 23, 2012, JEFFERY ADAMS posted on his Facebook-status, ?Public Service S.M.B. we dont fuck wit teameast new skool hustlebumz 220 we not cool its on site when niggaz we put in 2 much work 2 let da streetz down its not beef its personal so nigga better strap dey seat beltz on an hope dey have a safe On or about October 22, 2012, JEFFERY ADAMS posted on his Facebook status, I got 64 lines of purple ACTAVIS wit da seal not none of dat stepd on water down shit team eastside talkin (60) on or about September 4, 2012, QUINCY GRAHAM was found in Dunbar, West Virginia in an apartment where approximately $11,335 was found under the kitchen sink and an additional $4,760 was found in a black duffel bag in a bedroom. 20 Doc 812 Filed 01/03/4595 (61) On or about August 18, 2012, COREY BAILEY was arrested at 14711 Tacoma Street, Detroit, Michigan with cocaine base (crack cocaine) and heroin. (62) On or about August 8, 2012, a rap video entitled ?HardWorkJig I HWE Shout to Smoke? was posted on YouTube. (63) On or about May 12, 2012, JEROME GOOCHreturned a rental car to Hertz Rental Car in Charleston, West Virginia. (64) On or about March 12, 2012, JEFFERY ADAMS posted on his Facebook status, ?Had 100 line of ACTAVIS dat shit almost gone I think its like 56 left hmu dey goin fast tell peezy we gone match him 16?s bum ass nigga SMB (65) On or about February 8, 2012, COREY BAILEY was arrested in A Charleston, West Virginia with approximately $2,930 and 53 oxymorphone pills. (66) On or about February 8, 2012, COREY BAILEY provided false identification to law enforcement in Charleston, West Virginia. (67) On or about September 9,2011, EUGENE FISHER was arrested with cocaine and marijuana in front of 15864 Manning, Detroit, Michigan. 21 DOC 812 Filed 01/03/4596 (68) On or about January 20, 2011, DEVON PATTERSON and others were found in an apartment in Dunbar, West Virginia with approximately 288 oxymorphone pills, a firearm, and US. currency. (69) On or about October 11, 2010, MICHAEL ROGERS, DEVON PATTERSON, and others were found at 14524 Manning Street, Detroit, Michigan with marijuana and US. currency. (70) On or about August '25, 2010, MICHAEL ROGERS and CHRISTOPHER OWENS were together in Charleston, West Virginia. (71) On or about November 6, 2009, COREY BAILEY was arrested in Charleston, West Virginia after tossing two bags of marijuana, approximately 53 Xanax pills, and cocaine to the ground. (72) On or about November 6, 2009, COREY BAILEY provided false identification to law enforcement in Charleston, West Virginia. (73) On or about October 27, 2009, COREY BAILEY was in Charleston, West Virginia with SMB enterprise member A. (74) On or about October 27, BAILEY provided false identification to law enforcement in Charleston, West Virginia. (75) On or about October 21, 2009, R.C.-1 was shot and killed and R.C.-2 was shot in the chest by COREY BAILEY and another. 22 DOC 812 Filed 01/03/4597 (76) On or about October 13, 2009, JAMES ROBINSON was present at 14475 Lappin Street, Detroit, Michigan, alocation where police found twenty ziplock bags of marijuana, a digital scale, packaging materials, and $666. I (77) On or about May 15, 2009, SMB enterprise member was arrested in Charleston, West Virginia. (78) On or about April 2, 2009, ARLANDIS SHY was arrested with marijuana and Oxycontin pills in Charleston, West Virginia. (79) On or about March 4, 2009, ROBERT BROWN and SMB enterprise member were together in Charleston, West Virginia. (80) On or about January 30, 2009, ROBERT BROWN, JEFFREY ADAMS, and SMB enterprise member were together in Charleston, West Virginia. (81) On or about January 30, 2009, ROBERT BROWN had $3,164 and two Greyhound bus tickets from Detroit, Michigan to Charleston, West Virginia in his possession. (82) On or about January 30, 2009,. JEFFREY ADAMS had marijuana, baggies of cocaine base (crack cocaine), and US. currency in his possession in Charleston, West Virginia. 23 Doc 812 Filed 01/03/4598 (83) On or about January 16, 2009, SMB enterprise member and ARLANDIS SHY were found in an apartment in Charleston, West Virginia with drug packaging, marijuana, and US. currency. (84) On or about December 10, 2008, ROBERT BROWN, JEFFERY ADAMS, STEVEN ARTHUR, JR., and others were found at 14110 Eastburn Street, Detroit, Michigan with marijuana, a handgun, and US. currency. (85) On or about October 30, 2008, SMB enterprise member was in Charleston, West Virginia. (86) On or about July 29, 2008, ARLANDIS SHY and other SMB enterprise members or associates were found in the area of Tacoma and Queen Streets, Detroit, Michigan with heroin, cocaine base (crack cocaine), and US. currency. (87) On or about April 26, 2008, QUINCY GRAHAM, STEVEN ARTHUR, JR., and SMB enterprise member were found at 14164 Manning Street, Detroit, Michigan with heroin, cocaine, marijuana, a digital scale, packaging material, and US. currency. (88) On or about November 28, 2007, DIONDRE FITZPATRICK, JEFFAUN ADAMS, and other SMB enterprise members and associates were found in a vacant house at 14754 Manning Street, Detroit, Michigan 24 Doc 812 Filed 01/03/4599 with cocaine, marijuana, packaging materials, a digital scale, and US. currency. (89) On or about November 4, 2007, DIONDRE FITZPATRICK was found in front of 14781 Manning Street, Detroit, Michigan with marijuana. (90) On or about October 15, 2007, MICHAEL ROGERS and others were found in front of 14782 Manning Street, Detroit Michigan with packaging material and a digital scale. (91) On or about September 27, 2007, ANTHONY LOVEJOY, JEFFERY ADAMS, DIONDRE FITZPATRICK, and JEFFAUN ADAMS were found in a vacant house at 14754 Manning Street, Detroit, Michigan with marijuana, packaging materials, a digital scale, and US. currency. (92) On or about September 19, 2007, JAMES ROBINSON was arrested near 15895 N0vara Street, Detroit with a firearm. (93) On or about September 5, 2007, JEFFERY ADAMS and SMB enterprise were found together at 14815 Manning Street, Detroit, Michigan with marijuana, cocaine, and US. currency. (94) On or about August 30, 2007, COREY BAILEY was arrested at 14560 Manning Street, Detroit, Michigan with cocaine base (crack cocaine). 25 DOC 812 Filed 01/03/4600 (95) On or about April 13, 2007, COREY BAILEY was arrested at 14177 Collingham Street, Detroit, Michigan with cocaine base (crack cocaine), marijuana, and a shotgun. (96) On or about December 4, 2006, QUINCY GRAHAM, DEVON PATTERSON, DIONDRE FITZPATRICK, and others were found at 14791 Manning Street, Detroit, Michigan, with heroin, marijuana, and US. currency. (97) On or about June 7, 2006, CM. was shot and killed by ROBERT BROWN. (98) On or about May 31, 2006, QUINCY GRAHAM, ROBERT BROWN, and EUGENE FISHER were together at 14791 Manning, Detroit, Michigan. (99) On or about May 10, 2006, SMB enterprise member possessed 1,236 grams of marijuana and a 9 mm Hi-Point handgun in Charleston, West Virginia. (100) On or about March 31, 2006, COREY BAILEY and other unidentified SMB enterprise members and associates made threats to the residents of 14717 Tacoma Street, Detroit, Michigan. (101)On or about December 3, 2005, CHRISTOPHER OWENS, ANTHONY LOVEJOY, and others were found at 14790 Liberal Street, Detroit, Michigan with cocaine and US. currency. 26 Doc 812 Filed 01/03/4601 (102)On or about May 5, 2005, DEVON COREY BAILEY, ANTHONY LOVEJOY, and others were found at 14518 Manning Street, Detroit, Michigan with marijuana, cocaine, packaging material, and US. currency. (103) On or about December 1, 2004, ANTHONY LOVEJOY and COREY BAILEY were found together at 14787 Tacoma Street, Detroit, Michigan with cocaine base (crack cocaine), packaging, and US. currency. (104) On or about July 23, 2004, COREY BAILEY was arrested near 14501 Gratiot Avenue, Detroit, Michigan with marijuana. (105) On or about September 9, 2003, DEVON PATTERSON, ROBERT BROWN, ANTHONY LOVEJOY, and others were found in the vicinity of Manningand Monarch Streets, Detroit, Michigan with cocaine, marijuana, and US. currency. (106) On or about April 19, 2011, STEVEN ARTHUR JR. and MARTEZ HICKS were found in a hotel room in Charleston, West Virginia, with'a quantity of marijuana, prescription pills, and US. currency. (107) On or about April 19, 2011, MARTEZ HICKS provided false identification to law enforcement in Charleston, West Virginia. (108) On or about July 30, 2012, MARTEZ HICKS and STEVEN ARTHUR JR were present in Charleston, West Virginia. 27? DOC 812 Filed 01/03/4602 (109) On or about July 30, 2012, MARTEZ HICKS provided false identification to law enforcement in Charleston, West Virginia. (110) On or about October 5, 2012, MARTEZ HICKS sold to another individual in Charleston, West Virginia a quantity of Oxycodone pills. (111) On or about December 4, 2012, MARTEZ HICKS was arrested with enterprise member F, and two other individuals inside of 14486 Maddelein Street, Detroit, Michigan, with a quantity of marijuana, and US. currency. (112) On or about March 9, 2013, MARTEZ HICKS was found in a car in the vicinity of Rex and East State Fair Streets, Detroit Michigan, with a loaded firearm. I (113) On or about March 9, 2013, MARTEZ HICKS proVided false identification to law enforcement in Detroit, Michigan. (114) On or about February 18, 2016, MARTEZ HICKS posted to his Facebook account a picture depicting him and QUINCY GRAHAM holding US. currency. (115) On or about July 1, 2016, a picture was posted onto another enterprise member?s Facebook account depicting JEFFAUN ADAMS making a gang sign associated with SMB. 28 DOC 812 Filed 01/03/4603 (116) On or about July 8, 2016, MARTEZ HICKS was present with DONNELL HENDRIX, enterprise member F, other SMB enterprise members, and other individuals in the vicinity of 16121 Manning Street, Detroit, Michigan. I (117) On or about May 17, 2017, MARTEZ HICKS was present with another SMB enterprise member?in the vicinity of 14800 Tacoma Street, Detroit, Michigan. (118) On or about September 1, 2017, JEFFAUN ADAMS posted to his Facebook account, can?t believe this rat ass nigga Steveo man they, found the weak link.? Notice of Acts with Enhanced Sentencinq 1. On or about June 7, 2006, in the Eastern District of Michigan, enterprise'member ROBERT BROWN did commit an act involving murder, that is, murdering C.M., perpetrated by means of lying in wait, or any other willful, deliberate, and premeditated killing, all in violation of Michigan Compiled Laws, Sections 2. On or about October 21, 2009, in the Eastern District of Michigan, enterprise member COREY BAILEY, aided and abetted by others known and unknown to the grand jury, did commit an act involving murder, that is, murdering perpetrated by means of lying in 29 DOC 812 Filed 01/03/4604 wait, or any other willful, deliberate, and premeditated killing, all in violation of Michigan Compiled Laws, Section 3. On or about October 21, 2009, in the Eastern District of Michigan, enterprise member COREY BAILEY, aided and abetted by others known and unknown to the grand jury, did commit anact involving murder, that is, assaulting R.C.-2 with intent to commit murder, all in violation of Michigan Compiled Laws,? Sections 750.83 and 767.39. 4. On or about July 14, 2014, in the Eastern District of Michigan, enterprise members BILLY ARNOLD and COREY BAILEY, aided and abetted by each other and by others known and unknown to the grand jury, did commit an act involving murder, that is, murdering D.P., perpetrated by means of lying in wait, or any other willful, deliberate, and premeditated killing, all in violation of Michigan Compiled Laws, Sections 750.31.6(1) and 767.39. 5. On or about July 14, 2014, in the Eastern District of Michigan, enterprise members BILLY ARNOLD and COREY BAILEY, aided and abetted by each other and by others known and unknown to the grand jury, did commit an act involving murder, that is, assaulting M.D.-1, M.D.-2, and CO with intent?to commit murder, all in violation ?of Michigan Compiled Laws, Sections 750.83 and 767.39. 30 Doc 812 Filed 01/03/4605 6. On or about May 1, 2015, in the Eastern District of Michigan, enterprise member BILLY ARNOLD and KEITHON PORTER, aided and abetted by others known and unknown to the grand jury, did commit an act involving murder, that is, assaulting R.C.-3 with intent to commit murder, all in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. 7. On or about May 8, 2015, in the Eastern District of Michigan, enterprise member BILLY ARNOLD, KEITHON PORTER, and ARLANDIS SHY, aided and abetted by others known and unknown to the grand jury, did commit an act involving murder, that is, murdering D.R.-1, perpetrated by means of lying in wait, or any other willful, deliberate, and premeditated killing, all in violation of Michigan Compiled Laws, Sections 750.3160) and 767.39. 8. On or about May 8, 2015, in the Eastern District of Michigan, enterprise member BILLY ARNOLD, KEITHON PORTER, and ARLANDIS SHY, aided and abetted by others known and unknown to the grand jury, did commit an act involving murder, that' is, assaulting M.W., D.R.-2, and JR. with intent to commit murder, all in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. 31 Doc 812 Filed 01/03/18 Pg 32 of 70 Pg ID.4606 9. On or about May 10, 2015, in the Eastern District of Michigan, enterprise member BILLY ARNOLD, ROBERT BROWN, and EUGENE FISHER, aided and abetted by each other and by others known and unknown to the grand jury, did commit an act involving murder, that is, assaulting D.P., DC, and J.G. with intent to commit murder, all in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. 10. On or about June 7, 2015, in the Eastern District of Michigan, enterprise members BILLY ARNOLD and JAMES ROBINSON, aided and abetted by others known and unknown to the grand jury, did commit an act involving murder, that is, assaulting DC. with intent to commit murder, all in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. 11. Between or about July 14, 2014 through about September 26, 2015, in the Eastern District of Michigan, enterprise members BILLY ARNOLD, STEVEN ARTHUR JR., EUGENE FISHER, COREY BAILEY, QUINCY GRAHAM, ROBERT BROWN, JEROME GOOCH, MICHAEL ROGERS, DERRICK KENNEDY, DEVON PATTERSON, JEFFERY ADAMS, ARLANDIS II, ANTHONY LOVEJOY, JAMES ROBINSON, DONELL HENDRIX, 32 DOC 812 Filed 01/03/4607 and KEITHON PORTER did commit an act involving murder, that is, conspiring to assault rival gang members with intent to commit murder, all in violation of Michigan Compiled Laws, Sections 750.83 and 750.157a. All in violation of 18 U.S.C. 1962(d). COUNT TWO 18 U.S.C. 1959(a)(1) Murder in Aid of Racketeering D-6 ROBERT BROWN 1. At all times relevant to this Sixth Superseding Indictment, there existed an?enterprise, the SMB as more fully described in Paragraphs One through Nine of Count One of this Sixth Superseding Indictment, which are re-alleged and incorporated by reference as though set forth fully herein. The SMB, including its leadership, members and associates constituted an enterprise as defined in Title 18, United States Code, Section 1959(b)(2), that is, a group of individuals associated in fact that was engaged in, and the activities of which affected, interstate and foreign commerce. The enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives of the enterprise. 33 Doc 812 Filed 01/03/4608 2. At all times relevant to this Sixth Superseding Indictment, the above-described enterprise, the SMB, through its members and associates, engaged in racketeering activity as defined by Sections 1959(b)(1) and. 1961(1) of Title 18, United States Code, namely acts involving murder and robbery in violation of Michigan State Law, offenses involving dealing in controlled substances indictable under 21 U.S.C. 841 and 846, and acts indictable under 18 USC. 1512 (witness intimidation). 3. On or about June 7, 2006, in the Eastern District of Michigan, Southern Division, ROBERT BROWN did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully murder in Iviolation of Michigan- Compiled Laws, Sections - All in violation of Title 18, United States Code, Section 1959(a)(1). 18 U.S.C. 924(c); 924(j) Use of Firearm in Furtherance of a Crime of Violence CausingDeath D-6 ROBERT BROWN 1. Paragraphs One - Nine of Count One are re-alleged herein as if fully incorporated in this Count. 2. On or about June 7, 2006, in the Eastern District ofMichigan, VSouthern Division, ROBERT BROWN did knowingly, intentionally, and 34 DOC 812 Filed 01/03/4609 unlawfully carry and use a firearm, and caused the death of a person, to wit: the murder of CM, during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, murder in aid of racketeering; in violation of Title 18, United States Code, Sections 924(c) and 924(j). COUNT FOUR 18 U.S.C. 1959(a)(1); 2 Murder in Aid of Racketeering D-1 BILLY ARNOLD COREY BAILEY 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this-Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other'and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully murder in violation of Michigan Compiled Laws, Sections 750.316(1) and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(1) and 35 DOC 812 Filed 01/03/4610 COUNT 18 U.S.C. 924(c); 9240); 2 Use of Firearm in Furtherance of a Crime of Violence Causing Death BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One - Nine of Count One are re-alleged herein as if_ fully incorporated in this Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did knowingly, intentionally, and unlawfully carry and use a firearm, and caused the death of a person, to wit: the murder of D.P., during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, murder in aid of racketeering; in violation of Title 18, United States Code, Sections 924(c); 9240); and 2. COUNT SIX 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One Two'of Count Two are re-alleged herein as if fully incorporated in this Count. 36 Doc 812 Filed 01/03/4611 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan CompiledLaws, Sections 750.83 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(5) and COUNT SEVEN 18 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or aboUt July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known 1 and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering 37 DOC 812 Filed 01/03/4612 activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Section 750.83 and 767.39. 'All in violationof Title 18, United States Code, SeCtions 1959(a)(5) and COUNT EIGHT 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One Two of Count Two are re?alleged herein as if fully incorporated in this Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position inthe SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Section 750.83 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(5) and 38 DOC 812 Filed 01/03/4613 COUNT NINE 18 U.S.C. 2? Assault with a Dangerous Weapon in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and-increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault M.D.-1 with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT TEN 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 39 Doc 812 Filed 01/03/4614 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand iury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault M.D.-2 with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT ELEVEN 18 U.S.C. 1959(a)(3); Assault with a Dangerous Weapon in Aid of Racketeering D-1 BILLY ARNOLD D-4 COREY BAILEY 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, COREY BAILEY, and others, known and unknown to the grand jury, aided and abetted by each other and others 40 Doc 812 Filed 01/03/4615 known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT TWELVE 18 U.S.C. 924(0); 2 Use and Carry of a Firearm During, and in Relation to, a Crime of Violence BILLY ARNOLD D-4 COREY BAILEY On or about July 14, 2014, in the Eastern District of Michigan, Southern Division, and elsewhere, BILLY ARNOLD, COREY and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did knowingly, intentionally, and unlawfully carry and use a firearm during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, attempted murder and assault with a dangerous weapon in aid of - racketeering, as alleged in Counts Six - Eleven, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(c) and 41 DOC 812 Filed 01/03/4616 COUNT THIRTEEN 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 1, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, KEITHON PORTER, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(5) and COUNT FOURTEEN 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering D-1 BILLY ARNOLD D-19 KEITHON PORTER 42 Doc 812 Filed 01/03/4617 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 1, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, KEITHON PORTER, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault R.C. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT FIFTEEN 18 U.S.C. 924(c); 2 Use and Carry of a Firearm During, and in Relation to, a Crime of Violence BILLY ARNOLD D-19 KEITHON PORTER On or about May 1, 2015, in the Eastern District of Michigan, Southern Division, and elsewhere, BILLY ARNOLD, KEITHON PORTER, and others, known and unknown to the grand jury, aided-and abetted by each other, did knowingly, intentionally, and unlawfully carry and use a firearm during and in relation to a crime of violence for which they may be prosecuted in a court of 43 Doc 812 Filed 01/03/4618 the United States, that is, attempted murder and assault with a dangerous weapon in aid of racketeering, as alleged in Counts Thirteen and Fourteen, and said firearm was discharged, in violation of Title 18, United States Code, I Sections 924(0) and 2. COUNT SIXTEEN 18 U.S.C. 1959(a)(1); 2 Murder in Aid of Racketeering D-1 BILLY ARNOLD D-13 ARLANDIS SHY MATLEAH SCOTT D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully murder in violation of Michigan Compiled Laws, Sections 750.316(1) and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(1) and 44 Doc 812 Filed 01/03/4619 COUNT SEVENTEEN 18 U.S.C. 924(0); 9240); 2 Use of Firearm in Furtherance of a Crime of Violence Causing Death D-1 BILLY ARNOLD ARLANDIS SHY D-18 MATLEAH SCOTT D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did knowingly, intentionally, and unlawfully carry and use a firearm, and caused the death of a person, to wit: the murder of during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, murder in aid of racketeering; in violation of Title 18, United States Code, Sections 924(0); 9240); and 2. COUNT EIGHTEEN 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-13 ARLANDIS SHY D-18 MATLEAH SCOTT D-19 KEITHON PORTER 45 DOC 812 Filed 01/03/4620 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. I 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, .aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly anduniawfully attempt to murder in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(5) and COUNT NINETEEN 18 U.S.C. 1959(a)(5)j 2 Attempted Murder in Aid of Racketeering D-?l BILLY ARNOLD D-13 ARLANDIS SHY D-18 MATLEAH SCOTT D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did, for the 46 Doc 812 Filed 01/03/4621 purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Sections 750.83 and 750.39. All in violation of Title 18, United States Code, Sections 1959(a)(5)and COUNT TWENTY 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-13 ARLANDIS SHY D-18 MATLEAH SCOTT D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern ARNOLD, ARLANDIS SHY, KEITON PORTHER, and MATLEAH SCOTT, aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. All in violatiOn of Title 18, United States Code, Sections 1959(a)(5) and 47 Doc 812 Filed 01/03/4622 COUNT TWENTY-ONE 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering 1 BILLY ARNOLD 13 ARLANDIS SHY 1 1 8 MATLEAH SCOTT 9 KEITHON PORTER D- D- D- D- 1. Paragraphs One Two of Count Two are re-aIIeged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault M.W. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT TWENTY-TWO 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering BILLY ARNOLD D-1 D-13 ARLANDIS SHY D-18 MATLEAH SCOTT 48 DOC 812 Filed 01/03/4623 D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault D.R.-2 with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT TWENTY-THREE 18 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering D-1 BILLY ARNOLD D-13 ARLANDIS SHY. D-18 MATLEAH SCOTT D-19 KEITHON PORTER 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 49 DOC 812 Filed 01/03/4624 2. On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, ARLANDIS SHY, KEITHON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault J.R. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT TWENTY-FOUR 18 U.S.C. 924(c); 2 Use and Carry of a Firearm During, and in Relation to, a Crime of Violence D-1 BILLY ARNOLD D-13 ARLANDIS SHY D-18 MATLEAH SCOTT D-19 KEITHON PORTER On or about May 8, 2015, in the Eastern District of Michigan, Southern Division, and elsewhere, BILLY ARNOLD, ARLANDIS SHY, KEITON PORTER, and MATLEAH SCOTT, aided and abetted by each other, did knowingly, intentionally, and unlawfully carry and use a firearm during and in relation to a crime of violence for which?they may be prosecuted in a court of the United States, that is, attempted murder and assault with a dangerous 5O DOC 812 Filed 01/03/4625 weapon in aid of racketeering, as alleged in Counts Eighteen Twenty- Three, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(c) and 2. COUNT TWENTY-FIVE 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-3 EUGENE FISHER D-6 ROBERT BROWN 1. Paragraphs One Two of Count Two are re?alleged herein as if fully incorporated in this Count. 2. On or about May 10, 2015, in the Eastern District Of Michigan, Southern Division, BILLY ARNOLD, EUGENE FISHER, and ROBERT BROWN, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt-to murder D.P., DC, and in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(5) and COUNT TWENTY-SIX 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering 51 DOC 812 Filed 01/03/4626 . BILLY ARNOLD D-3 EUGENE FISHER D-6 ROBERT BROWN 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about May 10, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, EUGENE FISHER, and ROBERT BROWN, aided and abetted by each other and others known and unknown- to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault D.P., DC, and J.G. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT 18 U.S.C. 924(0); 2 Use and Carry of a Firearm During, and in Relation to, a Crime of Violence D-1 BILLY ARNOLD D-3 EUGENE FISHER D-6 ROBERT BROWN On or about May 10, 2015, in the Eastern District of Michigan, Southern Division,and elsewhere, BILLY ARNOLD, EUGENE FISHER, and ROBERT 52 DOC 812 Filed 01/03/4627 BROWN, aided and abetted by each other and others known and unknown to the grand jury, did knowingly, intentionally, and unlawfully carry and use a firearm during and in relation to a crime of violence for which they may be prosecuted in a court of the ,United States, that is, attempted murder and assault with a dangerous weapon in aid of racketeering, as alleged in Counts Twenty-Five Twenty?Six, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(0) and 2. I COUNT TWENTY-EIGHT 18 U.S.C. 1959(a)(5); 2 Attempted Murder in Aid of Racketeering D-1 BILLY ARNOLD D-16 JAMES ROBINSON 1. Paragraphs One - Two of Count Two are re-alleged herein as if fully incorporated in this Count. 7 l2. On or about June 7, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD and JAMES ROBINSON, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder in violation of Michigan Compiled Laws, Sections 750.83 and 767.39. 53 DOC 812 Filed 01/03/4628 All in violation of Title 18, United States Code, Sections 1959(a)(5) and COUNT TWENTY-NINE 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering 1 BILLY ARNOLD 16 JAMES ROBINSON D- D- 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about June 7, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD and JAMES ROBINSON, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault DC. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and COUNT THIRTY 18 U.S.C. 1959(a)(3); 2 Assault with a Dangerous Weapon in Aid of Racketeering 54 DOC 812 Filed 01/03/4629 ?l BILLY ARNOLD 16 JAMES ROBINSON D- D- 1. Paragraphs One Two of Count Two are re-alleged herein as if fully incorporated in this Count. 2. On or about June 7, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD and JAMES ROBINSON, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the SMB, an enterprise engaged in racketeering activity, knowingly and unlawfully assault A.B. with a dangerous weapon; in violatiOn of Michigan Compiled Laws, Sections 750.82 and 767.39. I All in violation of Title 18, United States Code, Sections 1959(a)(3) and THIRTY-ONE 18 U.S.C. 924(0); 2 Use and Carry of a Firearm During, and in Relation to, a Crime of Violence D-1 BILLY ARNOLD D-16 JAMES ROBINSON On or about June 7, 2015, in the Eastern District of Michigan, Southern Division, and elsewhere, BILLY ARNOLD and JAMES ROBINSON, aided and abetted by each other and others known and unknown to the grand jury, 55 DOC 812 Filed 01/03/4630 did knowingly, intentionally, and unlawfully carry and use a firearm during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, attempted murder and assault with a dangerous weapon in aid of racketeering, as alleged in Counts Twenty?Eight Thirty, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(c) and 2. COUNT THIRTY-TWO 18 U.S.C. 924(c); 2 POssession of a Firearm in Furtherance of a Crime of Violence D-1 BILLY ARNOLD STEVEN ARTHUR JR. D-3 EUGENE FISHER D-4 COREY BAILEY D-5 QUINCY GRAHAM D-6 ROBERT BROWN D-7 JEROME GOOCH D-8 MICHAEL ROGERS DERRICK KENNEDY D-10 DEVON PATTERSON CHRISTOPHER OWENS D-12 JEFFERY ADAMS D-13 ARLANDIS SHY ANTHONY LOVEJOY D-15 DIONDRE FITZPATRICK D-16 JAMES ROBINSON D-17 DONELL HENDRIX KEITHON PORTER JEFFAUN ADAMS D-21 MARTEZ HICKS 56 DOC 812 Filed 01/03/4631 From in or about 2003, exact date being, approximate, and continuing to on or about the? date of this Indictment, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, STEVEN ARTHUR JR., EUGENE FISHER, COREY BAILEY, QUINCY GRAHAM, ROBERT BROWN, JEROME GOOCH, MICHAEL ROGERS, DERRICK KENNEDY, DEVON PATTERSON, CHRISTOPHER OWENS, JEFFERY ADAMS, ARLANDIS SHY ll, ANTHONY LOVEJOY, DIONDRE FITZPATRICK, JAMES ROBINSON, DONELL HENDRIX, KEITHON PORTER, JEFFAUN ADAMS, and MARTEZ HICKS did aid and abet each other and others known and unknown to the Grand Jury, and did knowingly, intentionally, and unlawfully possessed firearms in furtherance of a crime of violence for which they may be prosecuted in a court of the United States, that is, racketeering conspiracy as alleged in Count One; in violation of Title 18, United States Code, sections 2. COUNT THIRTY-THREE 18 U.S.C. 922(g)(1) FeIon in Possession of a Firearm D-1 BILLY ARNOLD STEVE ARTHUR JR. D-3 EUGENE FISHER On or about September 26, 2015, in the Eastern District of Michigan, Southern Division, BILLY ARNOLD, STEVE ARTHUR JR., and EUGENE 57 DOC 812 Filed 01/03/4632 FISHER, after having previously been convicted of at least one crime punishable by imprisonment for a term exceeding one year (felony offense), did knowingly and unlawfully possess a firearm: to wit, a Bushmaster .223 caliber rifle, Model serial number BFI468505, said firearm having previously traveled in interstate and/or foreign commerce, in violation of Title 18, United States Code, Section 922(g)(1). COUNT THIRTY-FOUR 18 U.S.C. 922(g)(1) FelOn in Possession of a Firearm or Ammunition D-3 EUGENE FISHER On or about November 12, 2015, in the Eastern District of Michigan, Southern Division, EUGENE FISHER, after having been previously convicted of at leaSt one crime punishable by imprisonment for a term exceeding one year (felony offense), did knowingly and unlawfully possess a firearm and assorted ammunition: to wit, a Ruger semiautomatic .45 caliber handgun, serial number 660-65661, said firearm having previously traveled in the interstate and or foreign-commerce, in violation of Title 18, United States Code, Section 922(g)(1). COUNT THIRTY-FIVE 18 U.S.C. 922(g)(1) Felon in Possession of a Firearm or Ammunition D-16 JAMES ROBINSON 58 DOC 812 Filed 01/03/4633 On or about July 13, 2016, in the Eastern District of Michigan, Southern Division, JAMES ROBINSON, after having been previously convicted of at, least one crime punishable-by imprisonment for a term exceeding one year (felony offense), did knowingly and unlawfully possess a firearm and assorted ammunition: to wit, a Davis Industries Model obliterated serial number, Winchester Model 37, 12 gauge shotgun, no serial number, Ruger Blackhawk, .357 Magnum caliber revolver, serial number 35-65080, and various ammunition, said firearms having previously traveled in the interstate and or foreign commerce, in violation of Title 18, United States Code, Section 922(g)(1). NOTICE OF SPECIAL FINDINGS PURSUANT TO TITLE 18, UNITED STATES CODE, SECTIONS 3591 AND 3592 1. The allegations set forth in Counts 1 through 35 are repeated and re?alleged as if set forth fully herein. 2. As to Counts 4, 5, 16, and 17, the defendant BILLY ARNOLD: was 18 years of age or older at the time of the offenses alleged in Counts 4, 5, 16, and 17; intentionally killed D.P. (Counts 4 and 5) and D.R.-1 (Counts 16 and 17) (18 U.S.C. intentionally inflicted serious bodily injury that 59 DOC 812 Filed 01/03/4634 resulted in the death of UP. (Counts 4 and 5) and D.R.-1 (Counts 16 and 17) (18 U.S.C. intentionally participated in an act, contemplating that the life of a person would be taken or intending that lethal force would be used in connection with a person, otherthan one of the participants in the offense, and DP. (Counts 4 and 5) and (Counts 16 and 17) died as a direct result of these acts (18 U.S.C. 3591 intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offense, such that the participation in the act constituted a reckless disregard for human life and (counts 4 and 5) and D.R.-1 (Counts 16 and 17) died as a direct result of the act (18 U.S.C. 3591 committed the offenses alleged in Counts 4, 5, 16, and 17 after having been previously convicted of a Federal or State offense punishable by a term of imprisonment of more than 1 year, involving the use or attempted or 60 Doc 812 Filed 01/03/4635 threatened use of a firearm (as defined in section 921) against another person (18 U.S.C. 3592(c)(2)); in committing the offenses in Counts 4,5, 16, and 17, knowingly created a grave risk of death to 1 or more persons in addition to D.P. (counts 4 and 5) and D.R.-1 (Counts 16 and 17); I committed the offensesalleged in Counts 16 and 17 after substantial planning and premeditation to cause the death of a person (18 U.S.C. and I in committing the offenses in Counts 4, 5, 16, and 17, intentionally killed and attempted to kill more than one person in a single criminal episode (18 U.S.C. 3592(c)(16)). 3. As to Counts 4 and 5, the defendant COREY BAILEY: was 18 years of age or older at the time of the offenses alleged in Counts 4 and 5; intentionally killed UP. (18 U.S.C. intentionally inflicted serious bodily injury that resulted in the death of D.P. (18 U.S.C. intentionally participated in an act, contemplating that 61 DOC 812 Filed 01/03/4636 the life of a person would be taken or intending that lethal force would be used in connection with a person, other than one of the participants in the offense, and DP. died as a direct result of these acts (18 U.S.C. 3591 intentionally and specifically engaged in an act of violence, knowing that the act created agrave risk of death to a person, other than one of the participants in the offense, such that the participation in the act constituted a reckless disregard for human life and DP. died as'a direct result of the act (18 U.S.C. 3591 and in committing the offenses in Counts 4 and 5, intentionally killed and attempted to kill more than one person in a single criminal episode (18 U.S.C. 3592(c)(16)). 4. As to Counts 2 and 3, the defendant ROBERT BROWN II: was 18 years of age or older at the time of the offenses alleged in Counts 2 and 3; intentionally killed CM. (18 intentionally inflicted serious bodily injury that 62 DOC 812 Filed 01/03/4637 resulted in the death of CM. (18 U.S.C. intentionally participated in an act, contemplating that the life of a person would be taken or intending that lethal force would be used in connection with a person, otherthan one of the participants in the offense, and CM. died as a direct result of these acts (18 U.S.C. 3591 intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offense, such that the participation in the act constituted a reckless disregard for human life and CM. died as a direct result of the act (18 U.S.C. 3591 and in committing the offenses in Counts 2 and 3, intentionally killed and attempted to kill more than one person in a single criminal episode (18 U.S.C. 3592(c)(16)). 5. As to Counts 16 and 17, the defendant-ARLANDIS SHY: was 18 years of age or older at the time of the offenses alleged in Counts 16 and 17; 63 Doc 812 Filed 01/03/4638 intentionally killed D.R.-1 (18 U.S.C. intentionally inflicted serious bodily injury that resulted in the death of ,(18 U.S.C. 3591 intentionally participated in an act, contemplating that the life of a person would be taken or intending that lethal force would be used in connection with a person, otherthan one of the participants in the offense, and died as a direct result of these acts (18 U.S.C. 3591? intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants inthe offense, such that the participation in the act constituted a reckless disregard for human life and died as a direct result of the act (18 U.S.C. 3591 committed the offenses alleged in Counts 16 and 17 after substantial planning and premeditation to cause the death of a person (18 U.S.C. 3592(c)(9)); in committing the offenses in Counts 16 and' 17, 64 DOC 812 Filed 01/03/4639 intentionally killed and attempted to kill more than one person in a single criminal episode (18 U.S.C. 3592(c)(16)). 6. As to Counts16 and 17, the defendant KEITHON PORTER: was 18, years of age or older at the time of the offenses alleged in Counts 16 and 17; intentionally killed D.R.-1 (18 U.S.C. intentionally inflicted serious bodily injury that resulted in the death of D.R.-1 (18 U.S.C. 3591 intentionally participated in an act, contemplating that the life of a person would be taken or intending thatlethal force would be used in connection with a person, otherthan one of the participants in the offense, and D.R.-1 died as a direct result of these acts (18 U.S.C. 3591 intentionally and specifically engaged in an act of violence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offense, such that the participation in the act constituted a 65 Doc 812 Filed 01/03/4640 reckless disregard for human life and D.R.-1 died as a - direct result of the act (18 U.S.C. 3591 committed the offenses alleged in Counts 16 and 17 after having been previously convicted of two or more State or Federal offenses punishable by a term of imprisonment of more than 1 year, committed on different oCcasions, involvingthe distribution of a controlled substance; (18 U.S.C. 3592(c)(2)); committed the offenses alleged in Counts 16? and 17 after substantial planning and premeditation to cause the death of a person (18 U.S.C. 3592(c)(9)); and in committing the offenses in Counts 16 and 17, intentionally killed and attempted to kill more than one person in a single criminal episode (18 U.S.C. .3592(c)(16)). FORFEITURE ALLEGATIONS RICO FORFEITURE The allegations contained in Count One of this Sixth Superseding Indictmentare hereby repeated, re-alleged, and incorporated by reference herein as though fully set forth at length for the purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section 1963. 66 Doc 812 Filed 01/03/4641 Pursuant to Federal Rule of Criminal Procedure Rule 32.2, notice is hereby .given to the defendants that the United States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code, Section 1963 in the event of any defendant?s conviction under Counts One and Two of this Indictment. As a result of committing the offense charged in Count One of this Indictment, the defendants, BILLY ARNOLD, STEVEN ARTHUR JR., EUGENE FISHER, COREY BAILEY, QUINCY GRAHAM, ROBERT BROWN, JEROME GOOCH, MICHAEL ROGERS, DERRICK KENNEDY, DEVON PATTERSON, CHRISTOPHER OWENS, JEFFERY ADAMS, SHY II, ANTHONY LOVEJOY, DIONDRE FITZPATRICK, JAMES ROBINSON, DONELL HENDRIX, JEFFUAN ADAMS, and MARTEZ HICKS: 1. Have acquired and maintained interests in violation of a Title 18, United States Code, Section 1962, which interests are subject to forfeiture to the United States pursuant to Title 18, I United States Code, Section 1963(a)(1); and 2. Have property constituting and derived from proceeds obtained, directly and indirectly, from raCketeering activity, in violation of Title 18, United States Code, Section 1962, which - 67 DOC 812 Filed 01/03/4642 property is subject to forfeiture to the united States pursuant to Title 18, United States Code, Section 1963(a)(3). The interests of the defendants subject to forfeiture to the United States pursuant to Title 18, United States Code,? Section 1963(a)(1) and include but are not limited to, a sum that represents-the gross proceeds received by the defendants pursuant to their racketeering activities as charged in Count One of the Indictment during the relevant time period charged in the Indictment and all interests and proceeds traceable thereto. I 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 depositedwith, a third person; 0. 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 subdivided without difficulty; 68 DOC 812 Filed 01/03/4643 it is the intent of the United States, pursuant to Title 18, United States Code, Section 1963(m), to 'seek forfeiture of any other property of said defendants up to the value of the above forfeitable property. The above?named defendants, and each of them, are jointly and severally liable for the forfeiture obligations as alleged above. All pursuant to Title 18, United States Code, Section 1963. THIS IS A TRUE BILL Dated: January 3, 2018 Grand Jury Foreperson GRAND JURY FOREPERSON DANIEL L. LEMISCH ACTING UNITED STATES ATTORNEY Christooher Graveline Justin Wechsler CHRISTOPHER GRAVELINE JUSTIN WECHSLER Chief, Violent Organized Crime Unit Trial Attorney Assistant US. Attorney US. Department of Justice 211 W. Fort Street, #2001 justin.wechsler@usdoj.gov Detroit, Michigan 48226 (313) 226-9155 ls/ Julie Finocchiaro JULIE FINOCCHIARO Trial Attorney US. Department of Justice julie.finocchiaro@usdoj.gov 69 Doc 812 Filed 01/03/4644 United States District Court Criminal Case Cover Sheet case Number Eastern District of Michigan 15_cr_20652 NOTE: it is the responsibility of the Assistant U.S. Attorney signing this form to complete it accurately in all respects. information - Companion Case Number: This may be a companion case based upon 57.10 Judge Assigned: Cl Yes No nitia s[( Case Title: USA V. Billy Arnold, et, al. County where offense occurred Wayne Check One: Felony DMisdemeanor . UPetty indictment] information no prior complaint. lndictment/ Information based upon prior complaint [Case number: Indictment! Information based upon 57.10 [Complete Superseding section below]. Superseding to Case No: 15-cr?20652 Judge: George C. Steeh Corrects errors; no additional charges or defendants. Dlnvolves, for plea purposes, different charges or adds counts. Embraces same subject matter but adds the additional defendants or charges below: Defendant name Charges Prior Complaint (if applicable) 18 use. 3591 and 3592 Please take notice that the below listed Assistant United States Attorney is the attorney of record for the above captioned case. January 3, 2018 Date GRAVELINE Assistant United States Attorney 211 W. Fort Street, Suite 2001 Detroit, MI 48226-3277 Phone: 31 3-226?91 55 Fax; 313-226-5464 E-Mai address; Attorney Bar #1 1 Companion cases are matters in which it appears that (1) substantially similar evidence witl be offered at trial, or (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. . 5 1 6