United States Attorney 'Case W. SCOTT MELANIE L. ALSWORTH LAUREL J. MONTOYA Assistant United States Attorneys 2500 Tulare Street, Suite 4401 Fresno, CA 93721 Telephone: (559) 497-4098 Facsimile: (559) 497-4099 Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CASE NOPlaintiff, VIOLATIONS: 21 U.S.C. 846, V. 841(a)(1) Conspiracy to Distribute and - Possess with Intent to Distribute a ALECIA TRAPPS, - Controlled Substances JIMMY BRANTLEY, (Methamphetamine, Heroin); and 18 CARMEN CONEJO, U.S.C. 924(d)(1), 21 U.S.C. 853(a), ERNEST WESTLEY, and 28 U.S.C. 2461(c) - Criminal SHEENA TAYLOR, and . Forfeiture Allegation JOSEPH VASQUEZ, JR., Defendants. COUNT ONE: [21 U.S.C. 846, 841(a)(1) Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Methamphetamine, Heroin)] The grand jury charges: THAT ALECIA TRAPPS, JIMMY BRANTLEY, CARMEN CONEJO, ERNEST WESTLEY, SHEENA TAYLOR, and JOSEPH VASQUEZ, JR., defendants herein, beginning at a time unknown to the grand jury but not later than January 1, 2015 and continuing to on or about April 11 2018, in the Counties of Stanislaus and Sacramento, State and Eastern District of California, and elsewhere, did knowingly and intentionally'agree with-each other- 1 Indictment Case Document 1 Filed 04/05/18 Page 2 of 3 and other individuals known and unknown to the Grand Jury, to distribute and possess with intent to distribute controlled substance, to, wit: methamphetamine, a Schedule II controlled substance, and heroin, a Schedule I controlled substance, in violation of Title 21, United States Code, 846 and 841(a)(1). The drug quantity attributable to Alecia Trapps, immy Brantley, Carmen Conejo, Ernest Westley, Sheena Taylor and Joseph Vasquez, Jr. 1350 grams or more of methamphetamine and 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, all in violation of Title 21, United States. Code, 846, 841(a)(1) and The drug quantity attributable to Alecia Trapps, Jimmy Brantley, and Ernest Westley is 100 grams or more of a mixture or substance containing a detectable amount of heroin, all in violation of Title 21, United States Code, 846, 841(a)(1) and I i . FORFEITURE ALLEGATION: [18 U.S.C. 924(d)(1), 21 U.S.C. 853(a), 28 U.S.C. 2461 Criminal Forfeiture] The allegations in this indictment are hereby realleged and incorporated by reference for the purpose of alleging forfeiture. Upon conviction of one or more of the offenses alleged as Counts One through Five, and Seven through Nine of this Indictment, the defendant(s) shall forfeit to the United States pursuant to 21 U.S.C. 853, all property constituting, or derived from, proceeds obtained, directly or indirectly, as a result of the said violation and any property used, or intended to be used, in any manner or part, to commit, 'or to facilitate the commission of the said violation. I Upon conviction of one or more of the offenses alleged as Count Six of this Indictment, the- defendant(s) shall forfeit to the United States pursuant to 18 U.S.C. 924(d)(1) and 28 U.S.C. 2461, all property involved in or used in? any knowing violation of 18 U.S.C. 922. If any property subject to forfeiture as a result of the offenses alleged in the Indictment: 1) cannot be located upon exercise of due diligence; . (2) has been transferred or sold to, or deposited with, a third person; (3) has been placed beyond jurisdiction of the Court; 2 Indictment Case Document 1 Filed 04/05/18 Page 3 of 3 (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without dif?culty; it is the intent of the United States pursuant to 21 U.S.C. 853(p), as incorporated by 28 U.S.C. 2461(c), to seek forfeiture of any other property of said defendant(s) up to the value of the property subject to forfeiture. MCGREGOR W. SCOTT United States Attorney KIRK E. SHERRIFF, Assistant US. Attorney Chief, Fresno Of?ce Indictment A TRUE BILL. Slanaum on ?le FOREPERSON 'Case Document 1-1 Filed 04/05/18 Page 1 of 13 Eastern District of California Criminal Division THE UNITED STATES OF AMERICA VS. ALECIA TRAPPSDAD BAM JIMMY BRANTLEY, CARMEN . - ERNEST WESTLEY, SHEENA TAYLOR, and JOSEPH VASQUEZ, JR. I I I 21 U.S.C. 846, 841(a)(1) Conspiracy to Distribute and Possess with Intent to Distribute a Controlled Substances (Methamphetamine, Heroin); and 18 U.S.C. 924(d)(1), 21 U.S.C. 853(a), and 28 U.S.C. 2461(0) Criminal Forfeiture Allegation A true bill, lreman. Filed in open court this day of GPO 863 525 A0 257 (Rev. Case DOCI 9/92 ES: SAB conflict in USAO (before 01/01/13) iment 1-1 Filed 04/05/18 Page 2 of 13 YES: SKO conflict in USAO (Before 4/12/10) PER '3 use 3170 BY DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT El COMPLAINT INFORMATION OFFENSE CHARG ED PLEASE SEE INDICTMENT Place of offense County of Stanislaus INDICTM ENT 'Petty Minor. Cl Misdemeanor Felony U.S.C. Citation Please see Indictment EDCA Name of District Court, and/or Judge/Magistrate Judge Location _(City) PROCEEDING Name of Complainant Agency, or Person Title, if any) FBI I SA Brian Huberty person is awaiting trial in another Federal or State Court, give name of court this person/proceeding is transferred from another district per Cl 20 21 40. Show District this is a reprosecution of charges previously dismissed which - were dismissed on motion of: SHOW El U.S. Att?y Defense DOCKET NO. this prosecution relates to a pending case involving this same defendant El prior proceedings or appearance(s) before U.S. Magistrate Judge 'regarding this defendant were mk?ggls?gig INEO recorded under Name and Of?ce of Person Furnishing Information on Sara Thomas - Name ofAsst. U.S. Att?y (if assigned) THIS FORM U.S. Att?y Other U.S. Agency i MELANIE L. ALSWORTH FORFEITURE ALLEGATION I Fresno, CA DEFENDANT U.S. vs. TRAPPS Address Birth Male Date El Female LOptional unless ajuvenile) DEFENDANT Alien . (ifapplicableCUSTODY Has not been arrested, pending outcome of this proceeding '7 I If not detained, give date any prior- 5ummons was served on above charges Is a Fugitive IS IN CUSTODY On this charge On another conviction Awaiting trial on other charges DIED If answer to (6) is ?Yes,? show name of institution Yes If ?Yes,? Has detainer give date d? _een 16 No ?led . Mo Day DATE OF ARREST . Or . . . if Arresting Agency Warrant were not Federal MO. DATE TRANSFERRED To U.S. CUSTODY Is on Bail or Release from (show District) [Fed?l State l?l Year Day Year This report amends A0 257 previously submitted ADDITIONAL INFORMATION OR COMMENTS Penalties: See Penalty Slip. Please Issue No Bail Warrant Case Document 1-1 Filed 04/05/18 Page 3 of 13 COUNT ONE: VIOLATION: - PENALTY: VIOLATION: PENALTY: PENALTY SLIP -- INDICTMENT nr/ AUS Initial ALECIA TRAPPS 21 U.S.C. and Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Methamphetamine) 10 year mandatory minimum Life maximum $10,000,000 Fine 5 yrs. supervised release $100 special assessment 2-1 U.S.C. and - Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances [Heroin] 5 year mandatory minimum 40 yr. maximum $5,000,000 Fine 4 yrs. supervised release $100 special assessment FORFEITURE ALLEGATION: 21 U.S.C. 853 As stated in Indictment A0 257 Case 9/92 ES: SAIB conflict in USAO (before 01/01/13) ment 1-1 Filed 04/05/18 Page 4 of 13 as: SKO conflict in USAO (Before 4/12/10) PER 18 USC- 3170 BY COMPLAINT INFORMATION El SUPERSEDING: Case No. OFFENSE CHARGED PLEASE SEE Place of offense County of Stanislaus TNDICTMENT Petty Minor El Misdemeanor Felony U.S.C. Citation Please see Indictment EDCA DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT Name of District Court, and/or Judge/Magistrate Judge Location (City) PROCEEDING FBI ISA Brian Huberty of court 20 El 21 El 40. this is a reprosecution of charges previously dismiSSed which were dismissed on motion of: A U.S. Att?y El Defense this prosecution relates to a pending case involving this same defendant prior proceedings or appearance(s) before U.S. Magistrate Judge regarding this defendant were recorded under Name of Complainant Agency, or Person Title, if any) person is awaiting trial in another Federal or State Court, give name El this personlproceeding is transferred from another district per Show District SHOW DOCKET NO. MAGISTRATE JUDGE CASE NO. Name and Of?ce of Person Furnishing Information on Sara Thomas THIS FORM U.S. Att?y: Att?y (if assigned) Other U.S. Agency ALLEGATION NameOfASSl' IMELANIE L. ALSWORTH Fresno, CA U.S. vs. BRANTLEY Address Birth CI Male Date Female wptional unless ajuvenile) DEFENDANT Alien (if applicable) IS NOT IN CUSTODY If not detained, give date any prior Is a Fugitive 3) Is on Bail or Release from (show District) IS IN CUSTODY On this charge On another conviction 4) DD 6) Awaiting trial on other charges Fed?l If answer to (6) is ?Yes,? show name of institution 1) Has not been arrested, pending outcome of this proceeding State summons was served on above charges Yes If ?Yes,? l-Ias detamer ?v been ?led? g1 a No ?led I I Mo. Day Year DATE OF ARREST Or . . . ifArresting Agency Warrant were not Federal Mo. Day Year DATE TRANSFERRED To U.S. CUSTODY This report amends A0 257 previously submitted ADDITIONAL INFORMATION OR COMMENTS Penalties: See Penalty Slip. Please Issue No Bail Warrant Case Document 1-1 Filed 04/05/18 Page 5 of 13 DEFENDANT: COUNT ONE: VIOLATION: PENALTY: VIOLATION: PENALTY: PENALTY SLIP -- INDICTMENT LJ Initial . BRANTLEY 21 U.S.C. 841(a)(1) and Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Methamphetamine) 10 year mandatory minimum Life maximum $10,000,000 Fine 5 yrs. supervised release $100 special assessment 21 U.S.C. and - Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances [Heroin] 5 year mandatory minimum 40 yr. maximum $5,000,000 Fine 4 yrs. supervised release $100 special assessment FORFEITURE ALLEGATION: 21 U.S.C. 853 As stated in Indictment A0257 Case Document 1-1 Filed 04/05/18 Page 6 of 13 (Rev. SAB conflict in USAO (before 01/01/13) EYES: SKO con?ict in USAO (Before 4/12/10) PER 18 USC. 3170 BY COMPLAINT INFORMATION INDICTMENT OFFENSE CHARGED PLEASE SEE INDICTMENT Petty Cl Minor Cl Misdemeanor Felony Place of offense U.S.C. Citation County of Stanislaus . Please see Indictment Name of District Court, and/or udge/ Magistrate Judge Location DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT EDCA . City) PROCEEDING Name of Complainant Agency, or Person Title, if any) FBI I SA Brian Huberty [1 person is awaiting trial in another Federal or State Court, give name of court this person/proceeding is transferred from another district per I 20 21 40. Show District I this is a reprosecution of charges I previously dismissed which were dismissed on motionof: SHOW Cl U.S. Att?y El Defense DOCKET NO. this prosecution relates to a pending case involving this same defendant prior proceedings or appearance(s) before U.S. Magistrate Judge MAGISTRATE regarding this defendant were recorded under JUDGE CASE NO. Name and Of?ce of Person Furnishing Information on Sara Thomas THIS FORM U.S. Att?y Other U.S. Agency Name of Asst. U.S. My (ifassigned) . MELANIE L. ALSWORTH I ALLEGATION Fresno, CA DEFENDANT US: vs. CONEJO Address 5 Birth Cl Male Cl Alien Date . . - El Female (If applicable) LOptional unless a juvenile) DEFENDANT CUSTODY Has not been arrested, pending outcome of this proceeding If not detained, give date any prior summons was served on above charges . Is a Fugitive Is on Bail or Release from (show District) IS IN CUSTODY On this charge On ano?ier conviction Awaiting trial on other charges Fed?l IE State If answer to (6) is ?Yes,? show name of institution Yes - If ?Yes,? Has detainer . been ?led? gm ate No ?led I Day Year ARREST Or . if Arresting Agency Warrant were not Federal Mo DATE OF . I Mo'. . Day Year DATE TRANSFERRED T0 U.S. CUSTODY This report amends A0 257 previously submitted I ADDITIONAL INFORMATION OR COMMENTS Penalties: See Penalty Slip. Please Issue No Bail Warrant Case Document 1-1 ?led 04/05/18 Page 7 of 13 PENALTY SLIP -- INDICTMENT DEFENDANT: CARMEN CONEIO COUNT ONE: VIOLATION: 21 U.S.C. 841(a)(1) and 4 Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Methamphetamine) PENALTY: 10 year mandatory minimum Life maximum $10,000,000 Fine 5 yrs. supervised release $100 special assessment .FORFEITURE ALLEGATION: 21 U.S.C. 853 As stated in Indictment A0257 Case Doc ment 1-1 Filed 04/05/18 Page 8 of 13 (Rev. SAB con?ict in USAO (before 01/01/13) YES: conflict in USAO (Before 4/12/10) PER 18 USC- 3 I70 DEFENDANT INFORNIATION RELATIVE TO A CRIMINAL ACTION IN US. DISTRICT COURT BY COMPLAINT INFORMATION INDICTMENT El OFFENSE CHARGED SEE INDICTMENT I Petty . Minor Misdemeanor Felony Place of offense U.S.C. Citation Please see Indictment COunty of Stanislaus Name of District Court, and/or Judge/Magistrate Judge Location (City) EDCA 1 Fresno, CA PROCEEDING Name of Complainant Agency, or Person Title, ifany) i FBI SA Brian Huberty- - i person is awaiting trial in another Federal or State Court, give name of court El this personfproceeding is transferred from another district per 20 El 2] El 40. Show District this is a reprosccution of charges previously dismissed which were dismissed on motion of: SHOW I3 U.S. Att?y Ij Defense. DOCKET NO. this prosecution relates to a pending case involving this same defendant Ij prior proceedings 'or appearance(s) before US. Magistrate Judge 1 . . MAGISTRATE regarding this defendant were . recorded under JUDGE CASE Name and Of?ce of Person Furnishing Information on Sara Thomas THIS FORM i U.S.Att?y OtherU.S.Agency MELANIE L. ALSWORTH ORF EITURE ALLEGATION I OR COMMENTS Penalties: See Penalty Slip. Please Issue No Bail Warrant Addr DEFENDANT US. vs. CSS Birth . CI Male El Alien Date . Cl Female (ifapplicable) ?ptional unless ajuvenile) DEFENDANT IS NOT IN CUSTODY Has not been arrested, pending outcome of this proceeding If not detained, give date any prior summons was served on above charges . 2) Is a Fugitive 3) Is on Bail or Release from (show'District) IS IN CUSTODY 4) On this charge 5) On another conviction 6) Awaiting trial on other charges Fed?l State If answer to (6) is ?Yes,? Show name of institution If ?Yes,? Has detainer es . been ?led? . Ewe a a No ?led Mo Day Year DATE OF ARREST I Or . . . if Arresting Agency Warrantwere not Federal Mo. Day Year DATE TRANSFERRED TO US. CUSTODY lj This report amends A0 257 previously submitted Case Document 1-1 Filed 04/05/18 Page 9 of 13 DEFENDANT: COUNT ONE: VIOLATION: PENALTY: VIOLATION: PENALTY: PENALTY SLIP -- INDICTMENT AU Initial ERNEST WESTLEY 21 U.S.C. 841(a](1] and Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Methamphetamine) 10 year mandatory minimum Life maximum $10,000,000 Fine 5 yrs. supervised release $100 special assessment 21 U.S.C. and Conspiracy'to Distribute and Possess with Intent to Distribute Controlled Substances (Heroin) 5 year mandatory minimum 40 yr. maximum $5,000,000 Fine 4 yrs. superyised release $100 special assessment FORFEITURE ALLEGATION: 21 U.S.C. 853 As stated in Indictment A0257 Case ment 1-1 Filed 04/05/18 Page 10 of 13 SAB con?ict in USAO (before 01/01/13) ES: SKO conflict in USAO (Before 4/12/10) PER 18 U.S.C. 3170 DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT DY El I El INFORMATION INDICTMENT Name of District Court, and/or Judge/Magistrate Judge Location (City) SUPERSEDING: Case No. EDCA . OFFENSE CHARGED Fresno, CA PLEASE SEE INDICTMENT Petty DEFENDANT U.S. vs. I a Minor - . ISHEENA TAYLOR El Misdemeanor Address I Felony . Birth El Male El Alien Place of offense U.S.C. Citation Date County of Stanislaus Please see Indictment - El Female (if applicable) (Optional unless ajuvenile) PROCEEDING Name of Complainant Agency, or Person Title, if any) - DEFENDANT FBI I SA Brian Huberty . 15 NOT IN CUSTODY I I 1) Has not been arrested, pending outcome of this proceeding If not detained, give date any prior . person is awaiting trial in another Federal or State Court, give name summons was served on above charges I I of court . 2) Is a Fugitive Bail or Release from (show District) this person/proceeding is transferred from another district per 40. Show I IS IN CUSTODY this is a reprosecution of charges 4) On this charge previously dismissed which 5) On another conviction were dismissed on motion of: SHOW 6) Awaiting trial on other charges I Fed?l . State U.S. Att?y El Defense DOCKET NO. lf answer to (6) is ?Yes,? show name of institution El this prosecution relates to a pending I case involving this same defendant I I prior proceedings or appearance(s) Yes If ?Yes,? us 'st I HanEta?ner (It I: 33 336%: cg: MAGISTRATE been ?led? - a assist, mm Mo Day Year DATE OF ARREST - Name and Of?ce of Person Or . . . if Arresting Agency Warrant were not Federal Furnishing Information on iSara Thomas Mo. Day Year THIS FORM . DATE TRANSFERRED - . TO U.S. CUSTODY U.S. Att?y Other U.S. Agency . Name of Asst. U.S. Att?y (if assigned) I ELAN I L- ALSWO RTH This report amends A0 257 previously submitted. .FORFEITURE ALLEGATION ADDITIONAL INFORMATION OR COMMENTS Penalties: See Penalty Slip. Please Issue No Warrant Case Document 1-1 Filed 04/05/18 Page 11 of 13 PENALTY SLIP -- INDICTMENT fl AUS Initial DEFENDANT: SHEENA TAYLOR ICOUNT ONE: VIOLATION: 21 U.S.C. 841[a)[1) and. Conspiracy to Distribute and Possess with Intent to Distribute Contrulled Substances (Methamphetamine) PENALTY: 10 year mandatory minimum Life maximum $10,000,000 Fine 5 yrs. supervised release $100 special assessment FORFEITURE ALLEGATION: 21 U.S.C. 353 As stated in Indictment A0 257 Case ent 1-1 Filed 04/05/18 Page 12 of 13 (RCV- SABgconflict in USAO (before 01/01/13) ES: SKO con?ict in USAO (Before 4/12/10) PER 18 U.S.C.-3170 DEFENDANT. INFORMATION RELATIVE TO A CRIMINAL ACTION IN U.S. DISTRICT COURT BY El COMPLAINT CI lN FORMATION INDICTMENT Name of District Court, and/or Judge/Magistrate Judge Location (City) SUPERSEDTNG: Case No. EDCA OFFENSE CHARGED Fresno, CA PLEASE SEEINDICTMENT Petty DEFENDANT U.S. VS. E, Mm, IJOSEPH VASQUEZ, JR. CI Misdemeanor Address I Felony . . Birth Male Alien Place of offense U.S.C. CItatlon Date . . - County of Stanislaus Please see IndiCtmem . Female (If applicable) (Optional unless ajuvenile) PROCEEDING - Name of Complainant Agency, or Person Title, if any) DEFENDANT FBI I SA Brian Huberty . '5 CUSTODY I I l) Has not been arrested, pending outcome of this proceeding . If not detained, give date any prior - person is awaiting tn'al in another Federal or State Court, give name summons was served on above charges I of court 2) Is a Fugitive I 3) El Is on Bail or Release from (show District) CI this person/proceeding is transferred from another district per I I 20 2] El 40. Show District I I IS IN CUSTODY this is a reprosecution Of charges 4) On this charge previously dismissed which 5) On another conviction were dismissed on motion of: SHOW 6) Awaiting trial on other charges I Fed?l State CI U.S. Att?y CI Defense DOCKET NO. If answer to (6) is ?Yes,? show name of institution CI this prosecution relates to a pending I case involving this same defendant I prior proceedings or appearance(s) Cl Yes if ?Yes,? before Ma istrate Jud Has detainer ive date . . MAGISTRATE been ?led? defendant were . JUDGE CASE NO . No ?led I I recorded under Mo. Day Year . . DATE OF . ARREST . Name and Of?ce of Person - . . Or . . . if Arresting Agency Warrant were not Federal Information on Sara Thomas 7 Mo. Day Year THIS FORM I I DATE TRANSFERRED - TO U.S. CUSTODY U.S. Att?y El Other U.S. Agency Name of Asst. U.S. . . Att'y (if assigned) I MELANIE L. ALSWQ RTH . . This report amends A0 257 previously submitted IIFORFEITURE ALLEGATION ADDITIONAL INFORMATION OR COMMENTS Penalties: See Penalty Slip. Please Issue No Bail Warrant Case Document 1-1 Filed 04/05/18 Page 13 Of 13 PENALTY SLIP -- AUS Initial DEFENDANT: IOSEPH IR. COUNT ONE: . VIOLATION: 21' use. 841(a)(1) and Conspiracy tO Distribute and Possess with Intent to Distribute Controlled - Substances (Methamphetamine) PENALTY: 10 year-mandatory minimum Life maximum - $10,000,000 Fine 5 yrs. supervised release $100 special assessment FORFEITURE ALLEGATION: '21 U.S.C. 853 As stated in Indictment