CLERR STRICT IN THE UNITED STATESDISTRICT COURE 13:5 . FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION UNITED STATES OF AMERICA 3 I I) CLEWWOZW v. i FILED UNDER SEAL i I JOSHUA DAVID LANE (1) NO. 3: - CRAIGGIBSON WILBUR (2) aka ?Wheezy? MARICELLA NICOLE SEGOVIANO I3) DAYTONKANDERSEN (4) aka ?Popeye? I DONALD FRANKLIN WILLIAMS (5) TANYA LYNN SCROGGINS (6) aka ?Tanya Burns? MATTHEW RANDALL AGAN (7) . JUSTIN RAY MONROE (8) MIRIAM HERRERA (9) RALPH JAY ADAMS I10) aka ?Evil? . 7 HEATHER MICHELLE BERNHAGEN (l l) ANDRIA BOUCHER (12) . WILLIAM DOUGLAS BOURNE (13) JERRY (14) PRISCELLA MARIECASTANEDA I15) SARAH MARIE CHAMBERLAIN (16) aka ?Sarah Marie Hammons? ANTHONY RAY CHAMBERLAIN I17) aka ?Big Ant? . JOSHUA LYNN CLAYTON (18) aka ?Joker? I AMBER CHERIE COOK (19) STEPHENBRADLEY COOK (20) - Third Superseding Indictment Page 1 Supersedes Indictment returned on March 6, 2018 7 The ?rst nine defendants-were previously indicted; the following 48 are listed in alphabetical Order, as opposed to culpability or'hierarchy. JERRY DEWAYNE COX (21) SHAWN ALLEN DAVIS (22) aka ?Suicide? BILLY JOE DUKE (23) ALEXANDRA NICHOLE DYER (24) aka ?NaNa? VINCENT DANIEL FANUS (25) AMANDA MARIE GALLIPPO (26) FOREST GEFFERT (27) aka ?Diamond? TYLER JACOB GEHRKE (28) aka ?Greedy? ERIC PHILLIP GROSS (29) JEFFREY SCOTT HATFIELD (30) JOHN PAUL HENDERSON (31) .L aka . . ELISSA SEGOVIA HERRERA (32) RANDI MICHELLE JACKSON (33) JASON JAIME (34) GARRY CODY JONES (35) ADAM TYLER LAMBERT (3 6) CHRISTOPHER DEAN LANCASTER (37) JASON DAVON LAURENSON (3 8) JERRY WAYNE LUNSFORD (39) aka ?Looney?? . FRANCISCO JACOBO MAESTAS (40) aka ?Freaky? ARTHUR MARIN JR. (41) DERRICK SHAWN MCCOY (42) aka ?Taz? ASHLEY RENEE MERRITT (43) JUSTIN MARK NELSON (44) aka ?Animal? Third Superseding Indictment Page 2 FILED UNDER SEAL JORGE ALBERTO NEVAREZ (4 ASHLEY NICOLE NORRIS (46) . KRISTEN BLAZE (47) I aka ?Purple? FILED UNDER SEAL MICHELLE MARIE PACE (4 8) JOSIAH DAVID PHILLIPS (49) I LAWRENCE BRYCE PROBECK (50) GARY WAYNE RATLIFF (51) aka ?Bama? - COREY EVAN aka ?Face? - BAILEY WAYNE SANDERS (53) RENE SOLIS (54) JEFFREY DAVID STALEY (55) NGHIA PHUOC TRAN (5 6) JOSE LUIZ ZAVALA 7) aka ?Wicho? THIRD. SUPERSEDING INDICTMENT The United States Grand Jury charges: - - Introduction 1. At all times relevant to the Third Superseding Indictment, the defendants were members Of, associated With, or performed drug transactions with various White supremacists organizations or individuals, including the ?Aryan Circle,? the ?Aryan Brotherhood of Texas,? the ?Aryan Brotherhood,? the ?Pecker'woods,? the ?Soldiers of Aryan Culture,? and the ?Dirty White Boys,? and engaged in 'a conspiracy to distribute . methamphetamine and other illegal narcotics throughOut the Northern District of Texas and elSeWhere'. Certain defendants used firearms and physical violence'to further their drug traf?cking activities. - Third Superseding Indictment Page 3 - Criminal Organization's . 2. . The _?Aryan'Circle?iwas a white supremacist gang based primarily in Texas. The Aryan-Circle prison gang formed when certain ABT members splintered off to form What they believed was a more ideol'ogicallypure group. Aryan Circle members believed in the complete separation, of the races. The Aryan Circle was also an organized 'crime A A group, but, in recent years, its white supremacy ideology often took a backseat to traditional criminal ventures, such as drug-dealing. 3. The ?Aryan Brotherhood of Texas? (ABT) was a-White supremacist gang . I based in Texas. The ABT originated in Texas prisons in the 1980s. The ABT offered protection to Caucasian inmates if they oined the gang. Over time, the ABT expanded and maintained a presence, outside of prisons. ABT members referred to, the gang as the ?l?familyfi The ABT was also an organized crime. group that put its ?business? interests ahead Of ideology in recent years. These business interests often take theformof criminal ventures, including drug-dealing. 4f The Aryan Brotherhood, which Was sometimes referred to. as-the ?Brand,? was a White supremacist organization believed to have formed in prisons in California in the 19605. The Aryan Brotherhood is believed to have had up to 20,000 members, both inside and outside of prison. There was no connection between the Aryan Brotherhood . A and the ABT in terms of origination or leadership. Members of the Aryan Brotherhood are ofteninvolved in the distribution of illegal narcotics. - 5. i The term ?Beckerwood? was often used to describe an individual who, although not as member, shared a white supremacist ideology or aligned his or herself, Third Superseding Indictment Page4 with Other white supremacist organizations, such as the Aryan Circle or ABT. Individuals often resisted or denied membership with those groups because con?rmed or documented . membership typically resulted in administrative segregation within the Texas Department of Criminal Justice or other prison systems. This was typically viewed by prisoners as a less desirable way in Which to serve prison time.~ Nonetheless, these individuals sought to indicate where their alliances resided through their identi?cation as a ?Peckerwood.? A. Members were often referred to collectively as ?Peelierwoods? or the ?Wood Pile?. Female members were often referred to as ?Featheeroods.? Other white supremacist . organizations, Such as the Aryan Circle or ABT also often referred to their members as ?PeckerwoOds? or ?Woods?; Despite their alliances with other. white supremacists, their white Supremacy ideology of Peckerwoods often takes a-backseat to traditional criminal ventures, such as drug-dealings 6. The Soldiers of Aryan'Culture was a white supremacist gang formed in Utah in the mid-19908. Members often tattooed the initials S.A.C. on their face or neck. The code of conduct required members to attack individuals they believe to be ?snitches.? . Members of the Soldiers of Aryan Culture are often involved in the distribution of illegal] 7 narcotics. . 7. . The ?Dirty White Boys? is a criminal organization, which originated in the Federal Bureau of Prisons in 1985 and ste'msfrom the name of a prison softball team. The Dirty? White Boys gang is closely associated with the ABT and other White supremacy organizations. The Dirty White Boys gang was involved in the distribution of illegal narcotics. Third Superseding Indictment Page 5 Despite their differenees, the Aryan Circle, - ABT, Aryan Brotherhood, Peckerwoods, Soldiers of Aryan Culture, and the Dirty White Boys often collaborate with each other and with Mexican gangs and cartels for purposes of drug distribution or other illegal ventures. 9. 7' Puro Tango Blast or Tango Blast is the? term used to describe a? group A-of criminal street and prison?gangs that were based in Texas. Members'were predominantly Hispanic, and each regional group was called a ?tango.? Tango. Blast had-a relaxed . membership requirement and little to no detectable leadership hierarchy. Tango Blast members do not have to followiorders, attend organizational meetings, or pay other Tango members to be active; they also do. not have to participate in any gang activities when they are out .of prisdn. Tango'Blast members are often involved in the distribution of illegal narcotics. A Defendants At all times relevant. to this "Third Snperseding Indictment: . 10. Up to seventeen of the aboVe listed. defendants, including. Andria Dolores - Beecher, Sarah Marie Chamberlain, Anthony Ray Chamberlain, Jerry Dewayne Cox, Shawn Allen Davis, Vincent Daniel Fanus, Amanda Marie Gallippo, Forest Geffert, Tyler Jacob Gehrke, Eric Phillip Gross, John Paul Henderson, Jason Jaime, Christopher Dean Lancaster, Justin Mark Nelson, Kristin Blaze O?Meara, Lawrence Bryce Probeck, and Corey Evan-Robeson, weremembers or close associates Of the Aryan Circle. Third Superseding Indictment Page 6 11. Up to seven of ?the above liSted defendants, including Ralph Jay Adams, Joshua Clayton, Billy Joe Duke, Garry Cod-y Jones, Jerry'Wayne Lunsford, Derrick Shawn McCoy, and Bailey Wayne Sanders, were members or close-associates of the ABT. 12. Up to four of the above listed defendants, including James Dayton . Anderson, Tanya scrOggins, Craig Gibson Wilbur, Donald. Franklin Williams, were members Or close associates of the Aryan Brotherhood. - 13.- Up to three of/t'he? above listed defendants, including Randi Michelle Jackson, Joshua David Lane, and Ashley Renee Merritt, were members or close assoCiates of the Soldiers of Aryan Culture. 14. A Up to two ofthe above listed defendants, including Jason Davon Laurenson and Ashley Nicole Norris were members or close associates of the Peckerwoodsthe above listed defendants, including Gary Wayne Ratliff, was a member or close associate of the Dirty White Boysthe above listed defendants, including Heather Michelle Bernhagen, Jerry Cardenas, Jr., Alexandra Nichole Dyer, Franeisco Jacobo Maestas, Arthur Marin, Jr., and Jose Luiz Zavala were members or close associates of Tango Blast. Third Superseding?lndictment Page 7 Count One Conspiracy to Commit Kidnapping [Violation of 18 U. S. C. ?1201(17. The allegations contained in paragraphs 1 through 16 are realleged andfully incorporated herein. 18. In or about January 2018? and February 2018, in the Dallas Division of the Northern District of Texas and elsewhere, the defendants, Ralph Jay Adams, Justin Mark Nelson, Jerry Wayne Lunsford, and'Amanda Gallippo knowingly and willfully did combine, conspire, and agree with each other and with other persons both known and unknown to the Grand Jury to commit kidnapping, that is to seize, con?ne, kidnap, and '8 hold an individual, known to the Grand Jury as ?Victim for some purpose and benefit, that is to obtain meney or drugs that the defendants believed was in the custody or control of Victim A, and the defendants did use instrumentalities of interstate commerce, to wit: (1) a ?rearm, and (2) cellular telephones,? in committing and in furtherance of the . commission of this offense." Obiects of the Conspiracy p19. The object of the conspiracy to kidnap Victim A because certain defendants (Adams and Lunsford) believed Victim A had stolen drug proceeds that these defendants believed belonged to them. Nelson had actually stolen these proceeds and engaged in the kidnapping of Victim A to convince others that Victim A had stolen these funds, as opposed to Nelson. Third Superseding Indictment Page 8 A Manner and Means of the Conspiracy 20. ?It, was part of the conspiracy that the defendants held Victim A against his Will. I i 21. It vvas part of the conspiracy that the defendants threatened and used actual physical force against Victim A. if 22. I It Was part of the conspiracy thatcertain defendants ordered Victim A to be . i killed. it Overt Acts in Furtherance of the Conspiracy 23. Nelson negotiated 'a transaction involving $600 vvorth of methamphetamine with Adams and Ilunsford. I i 24. i Victim A was assigned by Adams and. Lunsford to pick up the methamphetamine from Nelson and deliver the agreed upon money. Victim A traveled to 622 Autumn Leaves Trail in Grand Prairie, Texas for this purpose. 25. I Nelson obtained the money from Victim A but did not give Victim the agreed upon drugs in eachange. Instead, Nelson stole themoney. I 26. Defendants Adams and Luns?ford' demanded an explanation from Victim A regarding the money/methamphetamine. VictimA' explained that he had not received the money from Defendant Nelson. Adams, Lunsford, and others traveled to 622 Autumn Leaves Trail to confront Nelson. I 27. . Once there, Nelson identi?ed himself as a member of the Aryan. Circle and Adams and Lunsford identi?ed themselves as members of the ABT. Nelson falsely, but convincingly, claimed that Victim A had stolen the money from Adams and Lunsford. . Third Superseding Indictment Page 9 28. Adams, Lunsford, Nelson, and iGallippo who were all present at 622 Autumn Leaves Trail then held Victim A against his'will and would-not allow him to leave that location. i 29. During this period, Adams pointed a pistol at Victim A?s head. 30. 1' During this period, Lunsford threatened to kill Victim A. -. 31. During this period, Nelson used a black hatchet to chop off a portion of Victim A?s left index finger: I 32. During this period, Gallippo hit Victim A With a large Wooden ohj ect on the back of Victim A?s head in attempt to render Victim A'unc-onscious. l' 33. Victim A was held by these defendants for several days against his will. 34. Adams and Lunsford agreed that Nelson Would take Victim A to another location and kill Victim A. . Nelson did not go through with the killing and instead eventually let Victim A go. i A A A All inviolaz?ionof18 use. [1.5.059 1201 . . Third Superseding Indi?tment Page 10 Conspiracy to Possess With Intent to Distribute a Controlled Substance . [Violation of21 35. _The allegations contained in paragraphs 1 through 34 are realleged and fully incorporated herein. I I A The: Conspiracy 36. A Between in or about October 2015, and in?or about April. 2018, in the Dallas Division of the Northern District of Texas and elsewhere, the defendants, Joshua David . Lane, Craig Gibson Wilbur, Maricella Nicole Segoviano, James Dayton Andersen, . Donald Franklin Williams, Tanya. Scroggins, .Mat'theW Randall-Agan, Justin Ray Monroe, Miriam Herrera, Ralph Jay Adams, Heather Michelle Bernhagen, William Douglas Bourne, . Jerry Cardenas, Jr., ,P?riscella Marie Castaneda, Sarah Marie Chamberlain, AnthOny Ray Chamberlain, Joshua Clayton, Amber Cherie Cook, Stephen. Bradley Cook, Jerry Dewayne Cox, Shawn Allen Davis, Billy Joe Duke, Alexandra Nichole Dyer, Vincent Daniel Fanus, Amanda Marie Gallippo, Forest Geffert, Tyler Jacob Gehrke, Eric Phillip Gross, Jeffrey Scott Hatfield, John Paul Henderson, Elissa Segov1a Herrera, Randi Michelle Jackson, Jason Jaime, Garry Cody Jones, Adam Tyler Lambert, Christopher Dean Lancaster, Jason Daron Laurenson, erryilwayne Lunsford, Francisco Jacobo Maestas, Arthur ?Mari?n, Jr., Derrick Shawn McCoy, AShley Renee Merritt, Justin Mark Nelson, Jorge Alberto Nevarez, Ashley Nicole Norris,-Kiristin Blaze O?Meara, Michelle Marie Pace, Lawrence Bryce Probeck, 'Gary WayneRatliff, Bailey Sanders, Rene Solis, Jeffrey QDavid Staley, 'Nghia Phuoc Tran, and Jose Luiz Zavala knowingly and intentionally Third Snperseding Indictment Page 11 combined, conspired, confederated and agreed together and with each other, and with other persons known and unknown to the Grand Jury, to possess with intent-to distribute 500 grams or more" of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II-controlled substance, in Violation violation of21 use. ?-846-and 18 use. 2. I A I A Manner and Means of the Conspiracy . During the conspiracy as alleged herein, it was part of the conspiracy that one or more of the defendants and conspirators would: A 1 3-7; Arrange for the acquisition of methamphetamine from persons both known and unknown tothe Grand Jury. - A I 38. Arrange forthe distribution and delivery of methamphetamine to persons I both known and unknown to the Grand Jury. A 39. Utilize stash . houses and other loCations to store quantities of A methamphetamine intermediaries and brokers to negotiate the acquisition, price, delivery, i and payment for quantities of methamphetamine, . i I 41. Sell or purchase methamphetamine from one another or for other persons known and unknown to the Grand Jury. A 42. Utilize cellular telephones to discuss, negotiate, and facilitate drug- transactions. Third Superseding Indictment? Page 12 43. Each of the conspirators listed herein was linked to one another either directly or through another Conspirator. Certain acted as hubs for narcotics traf?cking; supplying methaniphetamine to numerous other conspirators. 44.. Certain conspirators did not know the identity of all Of the other conspirators and did not know all of the details or all of the activities tindertaken by Other conspirators. There wasno forrnal agreement entered into by the conspirators, instead, the?conspir'ators entered into the conspiracy through their actions and drug transactions; All in violation of 2] US. C: 53 846,. the panaltyfor which isfound at - 21 Third Superseding Indictment Page 13 Counts Three through Fifty Possession of a Controlled Substance with Intent to Distribute [Violation of 21 U.S.C. 841(a)(1) and and 18 U.S.C. 2] 45. The allegations contained in paragraphs 1 through 44 are realleged and fully incorporated herein. 46. - On or about the dates listed below, in the Dallas Division of the Northern District of Texas and elsewhere, the defendants listed below, knowingly possessed with intent to distribute a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, in violation of 21 USC. 841 and and 18 U.S.C. 2. 3 Joshua David Lane November 27, 2017 4 Craig Gibson Wilbur July 11, 2017 I 5 James Dayton Andersen September 27, 2017 6 Maricella'Nicole Segoviano July 11, 2017 7 Donald Franklin Williams December 30, 2017 . 8 Tanya Scroggins September 27, 2017 9 Justin Ray Monroe Jan. Feb. 2018 10 Miriam Herrera February 6, 2018 1 1 1 Heather Michelle Bernhagen January 28, 2016 12 William Douglas Bourne August 24, 2017 13 Jerry Cardenas, Jr. November 17, 2017 14 Priscella Marie Castaneda December 7, 2017 15 Sarah Marie Chamberlain January 24, 2018 16 1 Anthony Ray Chamberlain January 24, 201 8 17? Joshua Clayton Jan. 2016 to Dec. 2016 18 Stephen Bradley Cook June 20, 2017 19 Jerry Dewayne Cox Dec. 2017 Jan. 2018 20 Shawn Allen Davis October 1, 2017 Third Superseding Indictment Page 14 21 Billy Joe Duke Feb. 016 to Oct. 2016 22? Alexandra Nichole Dyer an. to Oct. 2017 23 Vincent Daniel Fanus Jan. Feb. 2018 7 24 Amanda Marie Gallippo Jan. 2018 25 Forrest Geffert April'6, 2018 26 . Tyler Jacob Gehrke May 24, 2017? 27 Eric Phillip Gross March 20, 2018 28 Jeffrey Scott Hat?eld June 20, 201-7 29 John PaulHenderson Jan. 2018 30. Elissa Segovia Herrera August 30, 2017 31 Randi Michelle Jackson April 2017 to Dec. 2017 32 Jason Jaime May& June2017 33 Garry Cody Jone?s January 28, 2016 34 Adam, Tyler Lambert February 6, 2018 - 3 5 Christopher Dean Lancaster February 24, 2017 36 Jason Davon Laurenson May June 2017 37 Francisco Jacobo Maestas July 2015 to April 2018 3 8 i Arthur Marin, Jr. November 2, 2017 39 Derrick Shawn McCoy October 7, 2015 40 . Ashley Renee Merritt July 2017 to Nov. 2017 41 Justin Mark Nelson Mar. 2016 to Mar. 2018 42 Jorge Alberto Nevarez. Nov. 2015 to Mar. 2016 43 Ashley Nicole Nerris June 2017 to Feb. 2018 44 Kristin Blaze O?Meara October 26, 2.017 45 Michelle Marie Pace Mar. 2018 46 Lawrence Bryce Probeck Jan. 2018 to Mar. 2018 47 Gary Wayne Ratliff November 1, 2015 48 Bailey Sanders Jan. 2016 to Nov. 2017 49 e?'rey David Staley January 3 2018 5 0 Aug. 2017 Nghia'Phuoc Tran Third Superseding Indictment Page '15 Count Fifty-One Possession of a Firearm by a Felon [Violation of 18 U. C. 922(g)(l) and 924(a)(2)] 47. The allegations contained in paragraphs 1 through 46 are realleged and fully incorporated herein. 48. 'On or about the dates listed below, in the Dallas Division of the Nerthern District of Texas, the defendants listed below; having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly possess in and affeeting interstate commerce a ?rearm, as described below, all in violation of 18 U.S.C. 922(g)(1) and 924(a)(2). ?01101? About 7 'l Firearm . . . . . Bryco Arms Jennings Nine 9 51 ahD Jl 11,2017 031 avr 1ps - mm handgun serial 1392240 52 Christopher Dean February 24, 2017 Savage .22 callber revolver . Lancaster serial 45467 Francisco Jacobo Sun City/ Stevens 12 gauge 53 30,2015 v.7 Maestas - shotgun ser1a1#' 150507B Third Superseding Indictment Page 16 Count Fi ?Four Conspiracy to Possess with Intent to Distribute a Controlled Substance [Violation of 21 U.S.C. 846 and 18 U.S.C 2] 49. The-allegations contained in paragraphs 1 through 48 are realleged and fully incorporated herein; I 50. 9 In or about March 2017, in the Dallas Division of the Northern District of Texas and elsewhere, the defendants, Andria Dolores Boucher, 'Forrest Geffert, and Corey Evan Rebeson'knowingly and intentionally combined, conspired, confederated and agreed together and with each other, and with other persons known and unknown to the Grand .Jury, to pOSsess with. intent to distribute a mixture or substance containing a detectable amount of commonly known as 'or ?Pink,? a Schedule I controlled. substance, in Violation of 21 U.S.C. 841(a)(l) and All inviolation 846 and 18 U.S.C. 2.- Third Superseding Indictment Page? Count Fifty-Five . Possession with Intent to Distribute a Controlled Substance [Violation of 21 U. S. C. 7" 51. The allegations contained 1n paragraphs 1 through 50 are realleged and fully incorporated herein. I i i 52. Between in on or about May 2015 and in or about March 2016, in the Dallas . rDiViSlO? of the Northern District of Texas and elsewhere, the defendant, Jorge, Alberto Nevarez, knowingly possessed with intent to distribute a rnixture or substance containing I a detectable arnount of heroin, a Schedule I controlled substance. In Violation or21 U.S.C. 841(a)(1) a; Third Superseding Indictment Page 18 . Forfeiture Notice . - [2461 and 18 U. S. C. 924(d) and 21 U. S. C. ?853(a)] ?53. Upon conviction for Count One and/or Fifty One, pursuant to 18 USC 981(a)(1)(C) and 28 USC 2461 or 18 U. C. 924(d), and upon conviction for any of Counts Two through "F1fty and Count Fifty-Two, pursuant to 21 USC. 853(a), the defendants,'Joshua David Lane, Craig Gibson. Wilbur, Maricella Nicole Segoviano, James Dayton Andersen, Donald Franklin Williams, Tanya Scroggins, Matthew Randall Agan, Justin Ray Monroe, Miriam Herrera, Ralph Jay Adams, Heather Michelle Bernhagen, Andria Dolores Boucher, William Douglas Bourne, Jerry Cardenas, Jr., Priscella Marie Castaneda, Sarah-Marie Chamberlain, Anthony Ray Chamberlain, Joshua Clayton, Amber Cherie Cook, Stephen Bradley Cook, Jerry Dewayne Cox, Shawn Allen Davis, Billy Joe Duke Alexandra I Nichole Dyer, Vincent Daniel Fanns, Amanda Marie Gallippo,,Forrest Geffert, Tyler I .Jacob?Gehrke, Eric Paul Scott Hatfield, John Paul Henderson, Elissa I Segovia Herrera, Randi Michelle Jackson, Jaime, Garry Cody Jones, Adam 1 Tyler Lambert, Christopher Dean Lancaster, Jason Davon Laurenson, Jerry Wayne . Lunsford, Francisco Jacobo Maestas, Arthur Marin, Jr., Derrick Shawn McCoy, Ashley Renee Merritt-Justin Mark Nelson, Jorge Alberto Nevarez, Ashley Nicole . Norris, Kristin Blaze O?Meara, 'Michelle Marie Pace, Josiah David Phillips, Lawrence Bryce Probeck, Gary Wayne Ratliff, Corey Evan RobeSon, Bailey Sanders, Rene Solis, Jeffrey David Staley, Nghia Phuoc Tran, and Jose rLu'iz? Zavala shali forfeit to the, United States of America all property, real or or-der?ived from, the I i \Third Supersed?ing Indictment Page 19 proceeds obtained, directly or indirectly, as a result of the respective offense; and any property, real or personal, used or intended to be used, in any manner or part, to commit or facilitate the commission of the respective offense. This speci?cally includes the following ?rearms: 1. a SKS RIFLE- Serial Number ZAPAP1001225 (asto Lane and Merritt); 2. a Beretta PX4 Storm-Serial Number PY6454O (as to Lane and Jackson); 3. a Sig Sauer P938 Serial Number 5213136556 (as to Lane and Jackson); 4. a Ruger SR 556 Serial Number 59126235 (as to Lane and Jackson); 5. - $10,788 seized from Segoviano on July 11, 2017(as to Wilbur and Segoviano); 6. a Fabrique Nationale Herstal (FNH) USA, Model FNX-45, 45 Caliber Pistol, Serial Number FX3U043781, seized from Andersen (as to Andersen and Williams); 7. a Glock, Model 19 Gen 4, 9mm Caliber Ri?e, Serial Number YZN534, seized from Andersen (as to Andersen and Williams); 8. a Glock, Model 19, 9mm Caliber Ri?e, Serial Number BCAY930 (as to Andersen and Williams), 9. a Bryco Arms Jennings Nine 9mm handgun serial #1392240 (213 to Wilbur and Segoviano); 10. a Glock 30? .45 caliber handgun serial (as to Wilbur and Segoviano); 11. a Ruger LCP .380 handgun serial #371412172 (as to Wilbur and Segoviano); 12. a Beretta .22 handgun serial (as to Wilbur and Segoviano); 13. a Taurus PT-22 .22 handgun, serial #34142 (as to Seroggins); 14. a Glock 42 .3 80 handgun, serial (as to Scroggins); 15. a New Frontier model serial ri?e (as to M. Herrera and Lambert); 16. a Smith and Wesson model #15-22 serial ri?e (as to M. Herrera and Lambert), Third Superseding Indictment Page 20 17. 118. 19. 20. 2133;. '34Winchester model 42 serial #143199 shotgun (as to M. Herrera and Lambert); a Sake model AV serial #595215 ri?e (as to M. Herrera and Lambert); a Asi-model PASIZ serial shotgun (as to M. Herrera and Lambert); a Norinco model SKS serial #25010180 ri?e (as to M. Herrera and Lambert); a Ruger model American 6903 serial #690?25945 ri?e (as to M. Herrera and Lambert); a American Tactical model .22LRHV serial lower ri?e receiver With a upper-ri?e receiver (as to M. Herrera and Lambert); $118,009.00 seized 02/06/2018 (as to M. Herrera and Lambert); $18,866.00 seized 02/06/2018 (as to Scroggins); $7,003.00 seized 02/06/2018 (as to Wilbur and Segoviano); a Forest camou?aged body armor (as to M. Herrera); a Primitivc?homemade suppressor (as to M. Herrera "and'LamberO; a Taurus model PT-22 serial AQE66728 (as to E. Herrera); . a Derringer model 750 Frontier serial #44804 handgun (as to E. Herrera); aBryco Jennings model 1722 Serial 1060486 (as to E. Herrera); a Savage .22 caliber revolver serial 45467 (as to Lancaster); I arMossb-erg 20 gauge shotgun with?no known serial number (as to-Laneaster); a Sig Sauer P522 pistol seriall# 30A00366 (as to Laurenson); a Sun'City/Stevens 12 gauge shotgun serial 150507B (as to-Maestas); a Colt Police PositiVe .38 Special handgun serial 30367R (as to Nevarez); a Ruger P95DC 9mm handgun serial 31122045 (as to O?Meara); a Bryco Arms Jennings Nine 9 mm handgun serial 1392240 (as to Phillips); and a Ruger .45 caliber pistol serial 660-26333 (as to Tran). . Third Superseding Indictment Page 21 A TRUE BILL FOREPERSON I ERIN NEALY COX UNITED STATES ATTORNEY ?y 1/7 P.J. MEITL . Assistant United States Attorney District of Colembia' Bar No. 502391 . Virginia Bar No. 73215 1100 Commerce Street Third Floor Dallas, Texas 75242-1699 Telephone: 214.659.8680 Facsimile: 214.659.8812 Email: philip.meit1@usd0j.gov Third Superseding Indictment Page 22 I