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Pg ID 3137

Exhibit 1
1. Cocaine Sonny Ft. Berenzo & Block – “Murda”
In this music video, co-defendant Corey Bailey, a/k/a “Sonny,” co-defendant Billy
Arnold, a/k/a “Berenzo” or “Killa,” and deceased SMB Member Devon McClure,
a/k/a “Block,” rap the lyrics while co-defendant Michael Rogers, a/k/a “Smoke,” and
co-defendant Donnell Hendrix, a/k/a “Jig,” appear and participate in the video.
The video starts with a scene of a vacant house that is sprayed painted with “Welcome
to the RedZone.” The video then cuts to a close-up of Rogers, and then back to
McClure who is standing in front the house making a shooting action towards the
camera with the words “where I come from, little n…, they murda.” McClure raps
about the SMB enterprise’s purpose and goals including trafficking in narcotics and
using violence and murder to intimidate witnesses and enemies. During segments of
the video, McClure holds what appears to be multiple firearms. He raps that, “I drop
you just like I drop four,” which refers to the gang sign of four upside-down fingers
disrespecting rival gangs. He explains that “55” are killers and drug dealers, which refers
to the older members of SMB. Arnold raps that he and his associates have a “choppa
a piece,” a “choppa” being street slang for AK-47 rifles and how “Berenzo murders
n….”. Bailey then raps that “We don’t get down to snitchin’, don’t need no murda
witness….If a nigga start snitchin’ guarantee he be missing,” directly addressing witness
intimidation.
The rap lyrics in this video match up with real life events, including the fact that SMB
Enterprise members have been arrested and charged with gun possession, murder, and
witness intimidation. See Indictment. The video shows the participants’ gang affiliation
including (1) discussing the RedZone and 4820Die, which is the SMB Enterprise’s
territory; (2) showing a vacant house with “Welcome to the RedZone” written on it; (3)
referring to “55,” a subset of SMB; and (4) wearing red clothing and a ski mask that
says “SMB.” Most importantly, is at the end of his verse, McClure sings about a funeral
of someone SMB killed and the grieving mother crying, “why’d they do my baby like
that, my baby like that.” The government will present evidence that shortly after the
attempted murders and shooting on May 10, 2015 (Mother’s Day), Arnold texted
numerous SMB members, including Quincy Graham and Diondre Fitzpatrick,
encouraging them to post those rap lines on the rival gang’s social media. The
government will argue that assist in identifying Arnold as the shooter that day as he
looked for revenge for the murder of McClure who was killed ten days earlier.

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Pg ID 3138

2. Cocaine Sonny ft. HardWork Jig & Berenzo – “I Hust”
In this music video, co-defendant Corey Bailey, a/k/a “Sonny,” co-defendant Billy
Arnold, a/k/a “Berenzo” or “Killa,” and co-defendant Donnell Hendrix, a/k/a “Jig,”
rap the lyrics, and co-defendants Arlandis Shy, Steven Arthur, Diondre Fitzpatrick, and
Michael Rogers, along with other SMB associates, appear and participate in the video.
The video shows how the SMB enterprise conducts its narcotics trafficking and protects
its business and wealth with violence. During the video, a “customer,” played in the
video by Rogers, comes in and buys a bottle from Hendrix who is sitting with a digital
scale and items packaged like the sale of narcotics in front of him. While this is
occurring, Hendrix raps “I hustle.” Hendrix explains that he used to sell heroin and 8balls and never took a day off. But, now, he is looking “like a boss,” rapping about how
he has moved up in the drug trade. He explains how now he sells heroin raw and he
has a brand new home. He raps that his trade is so big that “the Feds” are on him. The
government will also present evidence from witnesses that “hustle” or “hustling” means
making money via drug dealing or other criminal activity. Defendant Arnold appears
in the video with what appears to be a firearm in his waistband and explains how he
has different guns and clips, showing the threat of violence. Bailey also sings about
“freeing Sosa” or Devon Patterson from incarceration.
The rap lyrics and scenes in the video match up with real life events including that SMB
members have been arrested and indicted for drug trafficking in various types of
narcotics from heroin to pills and that SMB members have been indicted for possession
of many different types of guns from small handguns to assault rifles. See Indictment.
The video shows evidence of the participant’s gang affiliation including (1) discussing
“55,” the SMB subset; (2) wearing red clothing; (3) wearing a ski mask with SMB written
on it; and (4) 4820Die written on the album, referring to SMB territory.
3. HardWork Jig – “Welcome to HOB City Intro”
This music video includes co-defendant Donell Hendrix, a/k/a “Jig” rapping lyrics with
co-defendants Eugene Fisher, Jerome Gooch, Derrick Kennedy, and other SMB
enterprise associates appearing and participating in the video. The video discusses the
SMB enterprise’s drug trade, wealth, violence, and witness intimidation. Hendrix raps
about how the drug trade has changed, stating “Its getting hard to find dope…so flippin
pills… Selling lean (codeine mixture) by the pint.” The video shows an abundance of
cash and how they protect that wealth with guns. Many different types of guns are
shown in the video by different SMB members and associates. The video also explains
how SMB member “Bleek,” “turned snitch” which is against “the rules.”

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Pg ID 3139

The video depicts real life events. Defendant Hendrix explains the connection between
Ihab Maslamani and the SMB enterprise, rapping that “first Hab caught a body and he
made the news.” The video then proceeds to show actual news footage of the guilty
verdict. The video talks about how “Drop” was killed and shows the actual memorial
site that is in the RedZone containing items in Drop’s remembrance. Defendant
Hendrix raps about how the television show “Gangland” came to the RedZone and did
a segment on SMB. Along with these events, the video shows the participants’ gang
affiliation including (1) wearing red clothing; (2) talking about the RedZone and
showing the intersection of Coram and Crusade streets; (3) rapping about 7-6-2 as the
street code; (4) conducting gang hand signals; and (5) showing that all of these
Defendants are linked to the SMB enterprise and each other.
4. HardWork Jig – “I’m Working”
This music video has co-defendant Donnell Hendrix, a/k/a “Jig,” rapping lyrics with
co-defendants Billy Arnold, Corey Bailey and Derrick Kennedy appearing and
participating in the video. Hendrix raps about the “work” that the SMB enterprise does
which is sell drugs to make money and use violence to protect it. He acknowledges that
their group is “organized.” He raps that “organized crime in my hood will get you
paid… so breaking any rule in my hood will get you sprayed.” He talks about how for
“every transaction I break a K,” or $1,000. He explains how the tattoos connect the
gang, “Im a RedZone nigga and my tattoos show it.” The video actually portrays how
a drug transaction occurs, co-defendant Kennedy picks up a package behind an
abandoned trap house and delivers it to the driver of a vehicle. In addition, the video
further shows the participants’ gang affiliation including (1) referencing “55,” a subset
of SMB; (2) showing Rex and Novara streets, which are in SMB territory; and (3)
wearing red clothing.
5. HardWork Jig ft. Cocaine Sonny – “OG”
In this music video, co-defendants Donnell Hendrix, a/k/a “Jig” and Corey Bailey,
a/k/a “Sonny,” are rapping the lyrics while co-defendant Michael Rogers and other
SMB Enterprise associates appear and participate in the video. Hendrix raps about the
purpose of the SMB enterprise which is to protect its members and drug business by
using violence, and stopping witnesses from talking to law enforcement. Hendrix raps
that, “We still roll by the same rules….” and “In my neighborhood I am an OG.” He
explains that he and Sonny have “been thuggin,” he and Block (deceased member
Devon McClure) be “ridin,” and he and Killa (co-defendant Billy Arnold) were the first
of the members to do prison time. Talking about trouble with rival gangs, Hendrix
raps, “fuck peace.” Bailey then raps that he has a gun and he is going to use it. He
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Pg ID 3140

explains about how he beat a murder charge – “aint nobody seen but they all heard
it…not guilty was the damn verdict.” He says, “this gangsta shit is in my bloodline.”
Both Defendants talk about keeping silent. Hendrix exclaims, “I went to jail for my
partner before and I kept it silent.” He tells the audience who are watching the video
to “keep it silent.”
These rap lyrics match up with real events including Hendrix and Arnold serving prison
time, and that Bailey was found not guilty of murder. The video shows the participants’
gang affiliation including (1) referring to “55,” a subset of the SMB Enterprise; (2)
showing the intersection of Boulder and Manning which the SMB Enterprise claims as
part of their territory; (3) wearing red, the gang’s color, and doing hand signals with four
fingers down which represents disrespect to a rival gang; and (4) showing off close-ups
of some of the members’ tattoos which include “RedZone” tattoos, the area the SMB
Enterprise claims. In addition, the video shows the wealth of the SMB Enterprise
members by flashing cash and diamond earrings. The video explains that the money
“keep on piling.”
6. Ro Da Great ft. ADA Skippo – “Bleek”
In this track, co-defendant Robert Brown, a/k/a “RO,” raps the lyrics. There is no
video, but an album cover that states, amongst other things, “Betrayal Stop Bleekin.”
“Bleek” was the nickname of a SMB enterprise member who several members believed
to be cooperating with the police. Brown raps about some of the enterprise’s goals –
fear and violence – explaining they are going to kill snitches, “your little homie got shot
up and you did nothing.” Brown also raps about not being afraid of law enforcement
explaining that he doesn’t care about phone taps or when the Feds came to the house,
“if I see an Op Imma gun them down.”
7. Ro Da Great ft. Good Jet, Product – “Not Runnin From Shit”
In this rap track, co-defendants Robert Brown, a/k/a “RO,” and Jeffery Adams, a/k/a
“Product,” rap the lyrics, and there is no video. This rap track discusses the SMB
enterprise’s violence, with lyrics such as “not running from shit…My 40 got a 30,”
referring to .40 caliber firearms with a 30 round magazine. Brown sings that different
people “tried to set us up,” but he warns of retaliation, “from a block away I had your
face in a scope.” This rap track explains the SMB enterprise is not fake, rapping “this
game’s no gimmicks.” This rap track discusses the indicia of gang affiliation including
“55” and the “RedZone.” This track also addresses hierarchy, “Redzone… I’m the
CEO.”

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Pg ID 3141

8. Ro Da Great – “Intro”
In this rap track, co-defendant Robert Brown, a/k/a “RO,” and others SMB associates
rap the lyrics and there is no video. Brown identifies indicia of gang affiliation including
talk about the two groups of the SMB Enterprise – “Hobsquad,” and “55.” He then
goes on to explain that people should “Stop Bleekin,” which the SMB enterprise refers
to as snitching. He raps that “if I killed your brother...please don’t remind
me….snitches got the Feds right behind me.” Brown raps that he does not snitch
whether he gets shot, loses money, or the “Feds hit the hotel.” This rap track also
addresses the SMB enterprise’s movement in other states, which is alleged in the
Indictment, as he raps about how he travels “in and out of state.”
9. Ro Da Great ft. Berenzo, Lee Ferg – “Welcome to the Streets”
In this rap track, co-defendants Robert Brown, a/k/a “RO,” Billy Arnold, a/k/a
“Berenzo” or “Killa,” and a SMB associate Lee Ferg rap the lyrics, but there is no video.
The song discusses how they conduct the drug trade. They work seven days a week,
rapping “bitch im in the streets…ridin 7 days of week.” They talk about how much
they make from drug sales, “make enough block to feed your whole block…I could
make 10 racks off a couple blocks.”
The rap track discusses a specific incident when one of them was robbed, “I hate it
when dem niggas walk up in my crib…that was Christmas… and like the Grinch they
hit my shit.” But, he goes on to explain how he protects his stash with a gun, “2-4-7
keep that work on the block… 2-4-7 never slipping keep my glock.” He explains that
“think they did something cause they got me popped…had me jumping out the window
I didn’t even drop.”
The rap tracks talks about the hierarchy of the drug trade and that the SMB enterprise
teaches their members, “7 mile blood nigga taught to slug niggas” and explains that “we
got teenagers who do ours.” The rap track discusses the violence against witnesses,
rapping “glock tucked to make sure no witness when I get popped up.”
10. 4shoMagcom Presents – “55 Dubb”
In this music video, co-defendants Billy Arnold, Quincy Graham, a/k/a “Dubb,”
Jerome Gooch, Corey Bailey, Arlandis Shy, Derrick Kennedy, and other SMB associates
appear in this rap video, which is shot at a strip club. Graham, amongst others, is seen
on stage throwing cash. The song explains how when the SMB members need to buy
new things they make and sell drugs, stating “whip it up… in da kitchen,” referring to
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Pg ID 3142

cooking crack cocaine. This video shows the wealth that comes from the enterprise’s
activities. While the SMB members are throwing cash, they are describing their designer
clothes and cars. The rap also discusses how the SMB enterprise protects its wealth
with a “choppa…full automatic,” referring to an automatic firearm.
At the end of the video, the rap track shows what appears to be a back room at the strip
club with females and some SMB members hanging out while a money counter
processes piles of money. An unknown person in the video yells out that there is
“$68,000” in the room. This video shows the participants’ gang affiliation including (1)
wearing red clothes; (2) referencing “55;” and (3) even the strippers wearing SMB
insignia.
11. THESTING – “55 Dubb Greatest Show on Earth 5”
Co-defendants Billy Arnold, Quincy Graham, a/k/a Dubb,” Jerome Gooch, Corey
Bailey, Arlandis Shy, and Derrick Kennedy, among other SMB associates appear in this
rap video which is shot at what looks like the same strip club as above. Graham is seen
on stage during the rap throwing cash. The rap lyrics describe a variety of nicknames
for drugs and paraphernalia, and chants “…money….money… money….get more
money.” The song refers to the drug trade, stating that they have “clientele” and “got
20 traps,” which refers to houses used to store drugs. The rap lyrics talk about how
much money the enterprise makes, “50g’s in my pillow case,” calling it “pill money.” It
also talks about how the enterprise protects itself and its money with guns, “trigger
happy.” Towards the end of the video one rapper states that “pray to God that I beat
this case…start trial in a couple weeks…shot a nigga like 40 times… had to wrap his
body in a couple sheets.” The video shows the participants’ gang affiliation throughout
the video including (1) wearing red clothing; (2) referencing “55;” (3) making hand
signals; and (4) stating “shout out to my blood niggas.”

 

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