Case: Doc #2 1 Filed: 08/17/18 1 of 83. PageID 1 IN THE UNITED STATES DISTRICT COURT 1 . 8 FOR THE NORTHERN DISTRICT OF OHIO . i" EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, a Title 21, Sections 331(a), FUJING ZHENG, 333(b)(7), 35 841 aka, GORDON HN, V. 1 aka, MR. JIN, 846, 848, 853, aka, GORDON ZHENG, 952(a), 959(a), 960(a)(1) and (3), aka, JTNXINXIN, 963, and 970, aka, FU JIN ZHENG, Title 18, Sections 1956(a)(2), aka, DENG GAO, and 2, GUANGHUA ZHENG, United States Code aka, GUANG HUA ZHENG, Defendants. . COUNT 1 (Conspiracy to Manufacture, Distribute, and Possess with the Intent to Distribute Controlled Substances and Controlled Substance Analogues Resulting in Death, 21 U.S.C. 841(a)(1), all in Violation of21 U.S.C. 846) The Grand Jury charges: From on or about January 1, 2008 to the Present, the exact dates unknown to the Grand Jury, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON JIN, aka IVIR. JIN, aka GORDON ZHENG, aka INXINXIN aka FU ING ZHENG, aka DENG GUANGHUA ZHENG, aka GUANG HUA Guangfu Guifeng Songyan Longbao Qinghua Y., aka Jason Yen; Leroy (individuals whose names are known to the Grand Jury); Global United Biotechnology; Global United Holdings; Global Biotech, Inc.; Global Holdings, Inc.; Top Lab Global Golden Chemicals; Cambridge Chemicals; Wonda Science; OneChem; Case: Doc#: 1 Filed: 08/17/18 2 of 83. PageID 2 ChemCloud; Daniel Lab; and Shanghai Pharmaceutical Company 1 (named but not indicted herein), Bin Wang (indicted in case number and others known and unknown to the Grand Jury (hereinafter, the Drug Trafficking Organization? or ?the Organization? and also known as the Drug Traf?cking Organization?), did knowingly, and intentionally combine, conspire, confederate, and agree with each other to manufacture, distribute, and possess with the intent to distribute mixtures and substances containing a detectable amount of the following controlled substance analogues, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, and controlled substances, including the following: A. 100 grams or more of Acetyl Fentanyl, a Schedule I controlled substance analogue until July 17, 2015, and a Schedule I controlled substance thereafter; B. Carfentanil, a Schedule II controlled substance; C. Furanyl Fentanyl (F a Schedule I controlled substance analogue until November 29, 2016, and a Schedule I controlled substance thereafter; D. 4?Fluoroisobutyrfentanyl a Schedule I controlled substance analogue until May 3, 2017, and a Schedule I controlled substance thereafter; E. Methoxyacetyl Fentanyl, a Schedule I controlled substance analogue until October 26, 2017, and a Schedule I controlled substance thereafter; F. (Pink Heroin), a Schedule I controlled substance analogue until Noyember 14, 2016, and a ScheduleI controlled substance thereafter; G. U-48 800, a Schedule I controlled substance analogue; H. (Flakka), a Schedule I controlled substance analogue; I. Dibutylone, a Schedule I controlled substance; Case: Doc #2 1 Filed: 08/17/18 3 of 83. PageID 3 J. I (BK-EDBP or Ephylone), a Schedule I controlled substance analogue; K. Alpha-Pyrrolidinopentiophenone (Alpha PVP or A-PVP), a Schedule I controlled substance; . L. Ethylone), a Schedule I controlled substance; M. FUB-AMB, a Schedule I controlled substance analogue until NoVember 3, 2017, and a Schedule I controlled substance thereafter; N. a Schedule I controlled substance analogue until April 10, 2017, and a Schedule I controlled substance thereafter; 0. 4-Methyl?Alpha?PHP (NIPHP), a Schedule I controlled substance analogue; P. a Schedule I controlled substance analogue I until March 7, 2014, and a Schedule I controlled substance thereafter; 3,4?Methylenedioxyarnphetamine (MDA), a Schedule I controlled substance; R. (4-MMC or Mephedrone); a Schedule I controlled substance; S. Methylone, a Schedule I controlled substance; T. Methedrone, a Schedule I controlled substance analogue; U. (MDPV), a Schedule I controlled substance; V. 5F-AKB48, a Schedule I controlled substance analogue until April 10, 2017, and a Schedule I controlled substance thereafter; W. BK-MBDB (Butylone), a Schedule I controlled substance; Case: Doc #2 1 Filed: 08/17/18 4 of 83. Page D#: 4 X. (XLR11), a Schedule 1 controlled substance analogue until May 16, 2013, and a Schedule I controlled substance thereafter; Y. Pentedrone, a Schedule I controlled substance analogue until March 7, 2014, and a Schedule 1 controlled substance thereafter; Z. a Schedule I controlled substance analogue until April 10, 2017, and a Schedule I controlled substance thereafter; AA. a Schedule I controlled substance analogue until April 10, 2017, and a Schedule 1 controlled substance thereafter; BB. MMB- CHMICA, a Schedule I controlled substance analogue until July 10, 2018, and a Schedule I controlled substance thereafter, and CC. Methoxetamine (MXE), a Schedule 1 controlled substance analogue. DD. a Schedule I controlled substance analogue until January 30, 2015, and a ScheduleI controlled substance thereafter; EE. a Schedule 1 controlled substance analogue until February 5, 2016, and a Schedule I controlled substance thereafter; 1' FF. MAM-2201, a Schedule I controlled substance analogue; GG. a Schedule I controlled substance analogue until July 10, 2018, and a Schedule I controlled substance thereafter; 1 HH. 6-EAPB, a Schedule I controlled substance analogue; II. 3-FPM, a Schedule I controlled substance analogue; and JJ. a Schedule I controlled substance analogue. In Violation of Title 21, United States Code, Sections 802(32), 813, 841(a)(1), and case: Doc #2 1. Filed: 08/17/18 5 of 83. PagelD 5 MANNER AND MEANS OF THE CONSPIRACY 2. It was part of the conspiracy that: a. The ZHENG Drug Traf?cking Organization created, maintained, and controlled companies in China. whose purpose was to engage in drug traf?cking, smuggling, and money laundering. These companies include Global United Biotechnology, Global United Holdings, Global Biotech, Inc., Global Holdings, Inc., Global RC, Top Lab RC, and Golden Chemicals. The Organization did not of?cially register all of these companies. The purpose of these companies was to act as a front, concealing the real identities of the individuals and companies engaged in the criminal enterprise. b. A The ZHENG Drug Traf?cking Organization created, maintained, and controlled Shanghai Pharmaceutical Company 1 (a company whose name is known to the Grand Jury) in Shanghai, China. The purpose of Shanghai Pharmaceutical Company 1 was to act as the legitimate face of the drug traf?cking organization and a location from which the co-conspirators created, manufactured, and prepared narcotics for mass distribution around the world. Shanghai Pharmaceutical Company 1 listed one of email addresses as a point of contact on its website: c. The ZHENG Drug Traf?cking Organization touted its ability as a large- scale narcotics manufacturer to distribute ?over 16 tonnes of chemicals every month? from ?our own laboratory? and nearly any chemical on a bespoke basis in any quantity.? The Organization primarily specialized in the production for mass distribution of three types of narcotics: opioids, including fentanyl, fentanyl analogues, and other opioids; cathinones (commonly referred to by terms such as ?bath salts,? ?Hakka,? and ?gravel?); and cannabinoids (commonly referred to by terms such as and Case: Doc #2 1 Filed: 08/17/18 6 of 83. PageID 6 ?Spice?). Many of these drugs are associated with overdose deaths. Some are associated with causing irreversible physiological damage from non-fatal overdoses. d. Through chemical expertise, the ZHENG Drug Trafficking Organization manufactured new and oftentimes deadly analogues of opioids, pharmaceuticals, cathinones, and other controlled substances. The Organization called this process ?custom Throughout the course of the conspiracy, the Organization had manufactured and I distributed over 250 types of narcotics. e. The ZHENG Drug Traf?cking Organization manufactured counterfeit pills for mass distribution from China into the United States and around the world, adulterating trademarked and other pharmaceuticals with narcotics, including those that had a reasonable probability of causing serious adverse health consequences or death. f. The ZHENG Drug Traf?cking Organization also created, maintained, and controlled foreign web sites as online storefronts for the controlled substances that the Organization created, manufactured, and distributed. These websites included and On these websites, the co? conspirators advertised the following: i. Controlled substances and controlled substance analogues for sale, with the Organization?s website boasting that the Organization distributed over ?16 tonnes a month? of illicit chemicals and had the ability to make ?any quantity of desired chemicals for immediate . distribution.? ii. Guaranteed delivery of products, including ?100% deliver[y] and reshipment of products if package got seized by customs,? its ability to Case: Doc #2 1 Filed: 08/17/18 7 of 83. PageID 7 g. iv. 3) CC ship ?worldwide to Australia, Europe, Asia, and Africa, special ways to [ship narcotics] to USA, Russia, Europe and other countries,? and ?warehouses available in USA and Europe? for reshipment of controlled substances in the destination countries as a means of bypassing customs at the border. ?Custom a process through which the ZHENG Drug Traf?cking Organization used its chemical expertise to create ?every possible chemical to meet the needs of [its] customers,? including ?many other products than the ones found on [its] website.? Secured lines of communication for customers to contact the Organization, including end-to?end platforms like WhatsApp and ProtonMail. In order to maximize their global customer base, the ZHENG Drug Traf?cking Organization regularly maintained and updated mirror websites of advertising their narcotics for sale in over 35 languages. These languages included Arabic, Bengali, Catalan, Croatian, Danish, Dutch, Estonian, Farsi, Finnish, French, Gaelic (Irish), Greek, Haitian Creole, Hebrew, Hindi, Hmong, Hungarian, Icelandic, Indonesian, Italian, Japanese, Korean, Lithuanian, Malay, Maltese, Norwegian, Polish, Portuguese, Romanian, Russian, Serbian, Slovenian, Spanish, Turkish, Ukrainian, Urdu, Uzbek, and Vietnamese. h. The ZHENG Drug Trafficking Organization also created, maintained, and controlled vendor accounts on various foreign?hosted ?trading? websites for the purpose of advertising and distributing controlled substances. These websites included TradeKey, China Quality Lighting, TradeIndia, and TradeLead. Case: Doc #2 1 Filed: 08/17/18 8 of 83. PageID 8 i. The ZHENG Drug Trafficking Organization not only passively advertised to customers on these websites, but also actively solicited sales of controlled substances, including through sending private messages on the ?trading? websites to individuals who it believed may be interested in purchasing narcotics. j. The ZHENG Drug Traf?cking Organization additionally communicated with current and prospective customers through email accounts. These included MagicChemical@hotmail.com; goldenchemical@live.com; 350765 6950@qq.com; and Sales@globalrc.net. On these accounts, the Organization referred to the account user as The Organization also used WhatsApp, Skype, and other communicatiOn platforms to speak with its customers. When communicating with customers, the Organization consistently referred to itself in the plural as ?we? and k. FUJTN ZHENG used the moniker and ultimately on the Organization?s websites, its vendor accounts, andpvarious email accounts to advertise and communicate with customers. The ZHENG Drug Trafficking Organization also used the moniker as a form of branding, letting customers know that they arebuying from the same supplier despite a change in website, email account, or underlying company name. l. The ZHENG Drug Traf?cking Organization also made periodic updates to its websites and account pages as a means of mass communication to apprise customers of narcotics available for sale, order protocols, shipping issues, and business logistics. m. The ZHENG Drug Traf?cking Organization took numerous steps in an attempt to conceal its ?activities and the identities of its members from law enforcement. These steps included: Case: Doc #2 1 Filed: 08/17/18 9 of 83. PageID 9 ii. iv. vi. Vii. 1'1. Communicating through secure private messaging, including ProtonMail, an end-to?end email service; WhatsApp, an end?to?end messaging service; and WeChat, a Chinese web communications platform that is beyond the reach of US. legal process; Maintaining web sites and trade service accounts abroad and outside the reach of US. legal process; Accessing the internet through Virtual Private Networks Periodically changing its email addresses and front company names; Using aliases such as and Utilizing front and shell companies in the United States, China, and around the world; and Incorporating its criminal organizations such?as Global United Biotechnology, in the British Virgin Islands (BVI) and other Similar locations. BVl?s laws prevents the identification of owners, directors, and shareholders of companies incorporated in BVI and similarly forbids the disclosure of corporate tax and banking information. From its base of operations in China, the ZHENG Drug Traf?cking Organization communicated with drug customers, received drug proceeds, and/or shipped narcotics to over 25 countries, including: i. ii. iv. 'The United States; Australia; Belarus; Brazil; Case: Doc #2 1 Filed: 08/17/18 10 of 83. PageID 10 vi. vii. iX. xi. Xii. i Xiv. XV. xvii. XX. XXii. XXiv. XXV. XXVL Cambodia; Canada; Cyprus; France; Germany; Kazakhstan; Lithuania; Maldives; Mauritius; Netherlands; New Zealand; Poland; Portugal; Russia; South Africa; Spain; Sweden; Switzerland; Thailand; Taiwan; Tonga; Turkey; Ukraine; and 10 Case: Doc #2 1 Filed: 08/17/18 11 of 83. PageID 11 0. Organization communicated With drug customers, received drug proceeds, and/or shipped The United Kingdom. In the United States, speci?cally, the ZHENG Drug Traf?cking narcotics to over 35 states, including: i. ii. iV. Vi. Vii. iX. Xi. Xii. XV. XVii. Alabama; Arizona; Arkansas; California; Colorado; Florida; Georgia; Illinois; Indiana; Iowa; Kansas; Kentucky; Louisiana; Maine; Maryland; Massachusetts; Michigan; Minnesota; Mississippi; 11 Case: Doc #2 1 Filed: 08/17/18 12 of 83. XX. XXii. XXV. . p, corporate records, and/or ?nancial holdings in the following countries: i. ii. Missouri; Nevada; New Hampshire; New Jersey; New Mexico; New York; North Carolina; Ohio; Oklahoma; South Carolina; South Dakota; Tennessee; Texas; Virginia; Washington, West Virginia; and Wisconsin. PageID 12 The ZHENG Drug Traf?cking Organization also maintained operations, The People?s Republic of China (including. Hong Kong); The British Virgin Islands; Japan; Case: Doc #2 1 Filed: 08/17/18 13 of 83. PageID 13 iv. The Marshall Islands; V. Poland; . Vi. Tonga; vii. The United Kingdom; and The United States. q. The ZHENG Drug Traf?cking Organization employed a variety of methods to smuggle or otherwise traf?c narcotics from China to destination countries such as the United States. These methods included: i. False manifesting of narcotics as non?controlled chemicals; ii. Using freight forwarders, thereby hiding that the Organization?s companies were the origin point for the narcotics; Concealing narcotics within bulk freight containing legal goods; and iv. Using re?shippers in the destination countries. I. One technique was to have co-conspirators form or otherwise use companies in the destination countries for the purpose of re?shipping narcotics within the destination country. The ZHENG Drug Traf?cking Organization would ship bulk quantities of narcotics to the re?shipping companies, often through shell companies or freight forwarders in China. The re?shipping Companies would receive the bulk shipments of narcotics, separate them into individual parcels for each narcotics customer, and then re-distribute the drugs within the destination country. In doing so, the Traf?cking Organization largely avoided detection by customs. s. For instance, the ZHENG Drug Traf?cking Organization used chemical companies run by its co-conspirator Bin Wang in both China and the United States to smuggle l3 Case: Doc #2 1 Filed: 08/17/18 14 of 83. PageID 14 narcotics past both countries? customs agents. These companies Cambridge Chemicals, Wonda Science, OneChem, Daniel Lab, and ChemCloud had separate articles of incorporation and/or of?ces in both the United States and China. The ZHENG Drug Traf?cking Organization had its narcotics shipments hidden within bulk freight shipments sent between the Chinese and United States of?ces of these chemical companies. Employees at these companies created false manifests for these narcotics or otherwise hid them in the bulk chemical shipments. t. The ZHENG Drug Traf?cking Organization maintained properties in the United States for the purpose of distributing controlled substances. These properties included the of?ce address of Cambridge Chemicals, Wonda Science, OneChem, and ChemCloud in the United States: 5 Walnut Hill Park, Unit 13 in Woburn, Massachusetts. u. The ZHENG Drug Traf?cking Organization laundered its criminal proceeds through a variety of means. These laundering techniques included: i. Utilized digital currency (such as Bitcoin) to conceal and disguise the nature, location, source, ownership and control of the drug proceeds; ii. Maintained and controlled digital currency addresses that were used by drug traf?ckers and co-conspirators to make payments for narcotics; Utilized digital currency exchanges to convert drug traf?cking proceeds into of?cial ?at currency; iV. Misrepresented fund transfers and directed customers to misrepresent fund transfers in order to conceal and disguise the nature, location, source, ownership and control of the drug proceeds; V. Structured transactions to avoid ?nancial institution reporting and recordkeeping requirements; 14 Case: Doc #2 1 Filed: 08/17/18 15 of 83. PageID 15 vi. Transmitted drug proceeds into and out of bank accounts in Hong Kong and elsewhere, with the purpose of 'obfuscating the nature of the proceeds; and vii. Bypassed Chinese restrictions and reporting requirements on ?at currency entering and leaving the People?s Republic of China through the use of co? conspirators who received drug payments through money transmitting businesses (including Money Transfer Company 1, Money Transfer Company 2, and Skrill) on behalf of the FUJING ZHENG, GUANGHUA ZHENG, and other members of the conspiracy. These 00? conspirators include, Guangfu Z., Guifeng C., Songyan J., Longbao Z, and others. V. The People?s Republic of China imposed strict identi?cation laws for monetary transfers and transmissions, particularly those going into and out of its country. These laws required FUJING ZHENG and GUANGHUA ZHENG to provide their real identities from time to time when straw recipients were unavailable. The Organization later instructed drug traffickers and co-conspirators to pay them in and acquired; accounts with numerous exchanges outside of China to eXChange into fiat currency like the US. dollar. These exchanges, however, had Strict Know Your Customer legal requirements, forcing both FUJTN ZHENG and GUANGHUA ZHENG to provide their real identities, including their Chinese passports, in order to use their services. I w. Defendants FUJTN ZHENG and GUANGHUA ZHENG managed and controlled the ZHENG Drug Traf?cking Organization. Each had largely separate roles within the conspiracy. 15 Case: Doc #2 1 Filed: 08/17/18 16 of 83. PageID 16 X. Defendant UJING ZHENG managed and controlled Shanghai Pharmaceutical Company 1 and used its facilities for manufacturing and producing the narcotics that the ZHENG Drug Trafficking Organization distributed around the world. In this role, he primarily used the alias and the email address FUJIN ZHENG also managed foreign trading and customer relations for the Organization?s global network of drug trafficking clients and co-conspirators. In this role, he primarily used the alias As GORDON IIN, FUJIN ZHENG used email addresses such as MagicChemicals@hotmail.com, goldenchemical@live.com, sales@globalrc.com, as well as WhatsAPP, QQ, WeChat, and China-based telephone numbers to communicate with drug traf?ckers. FUJIN ZHENG additionally handled negotiations with third party re-shippers, which the Organization used to mask its connection to the narcotics packages in case law enforcement or customs intercepted the drug parcels. When interacting with co?conspirators handling re?shipments, FUJIN ZHENG often used the aliases or y. Defendant GUANGHUA ZHENG, FUJING father, managed the financial and money laundering side of the ZHENG Drug Traf?cking Organization. GUANGHUA ZHENG used various bank accounts around the world, and particularly in Hong Kong, to launder drug proceeds. The Organization also ensured that drug traf?ckers were instructed to misstate the purpose of drug payments to the ZHENG Drug Trafficking Organization for wire transfers and money orders. For example, the drug traffickers were instructed to state that the purpose of the wire transfers was for ?tuition? or ?family maintenance.? In doing so, GUANGHUA financial transactions violated financial reporting requirements in China and numerous destination countries. GUANGHUA ZHENG l6 Case: Doc #2 1 Filed: 08/17/18 17 of 83. PageID 17 additionally used such as BitCoin and exchanges to launder drug proceeds. ACTS IN FURTHERANCE OF THE CONSPIRACY 3. In furtherance thereof, and to effect and conceal the existence of the conspiracy, the Defendants and others performed acts in the Northern District 'of Ohio and elsewhere, including, but not limited to, the following: 4. On April 8, 2009, the ZHENG Drug Trafficking Organization posted advertisements for controlled substances and controlled substance analogues, such as Methedrone, 4-FMP, MDPV, and Butylone, on its website Under ?Privacy Notice,? the Organization stated, ?GlobalRC stores only the information provided by the customers that render the delivery possible of purchased merchandise. All information provided is stored on secure servers.? Under ?Shipping and Returns,? the Organization stated, ?GlobalRC delivers worldwide. All products are packed in discreet unmarked envelopes and sent by mail.? The website had versions for multiple languages, including English, German, and Spanish. 5. On or about June 3, 2011, the ZHENG Drug Traf?cking Organization distributed approximately two kilograms of methedrone that was sent to a drug trafficker in Minnesota. 6. On February 29, 2012, an American drug traf?cker emailed the ZHENG Drug Traf?cking Organization?s email account MagicChemical@hotmail.com, requesting $4,000 worth of narcotics. The Organization responded using the moniker on MagicChemical@hotmail.com, ?We ship big quantity to US each month, we have a lot of experience in it . we guarantee delivery, in case seized by customs, we re?ship free, The Organization also provided its expertise on how best to bypass customs, advising, you have address in Eastern US state, that would be best, cos New York customs is easiest to pass.? 17 Case: Doc #2 1 Filed: 08/17/18 18 of 83. PageID 18 7. On August 1, 2012, the ZHENG Drug Traf?cking Organization distributed kilogram amounts of 4-MEC to a drug traf?cker operating in and around Austin, Texas. The ZHENG Drug Traf?cking Organization initially communicated with the drug traf?ckers through its vendor accounts on tradekeycom and EC21.com. . 8. On March 2, 2013, the ZHENG Drug Traf?cking Organization distributed approximately 2.5 kilograms of Methylone to a drug traf?cker in Minnesota using the email account MagicChemical@hotmail.com. The Organization instructed the drug traf?cker to structure its payments to avoid reporting requirements in Money Transfer Company 1, asking ?can you divide into [Money Transfer Company 1] money? For example, 5,875 2900 2975. Do not exceed 3000 Under federal law, ?nancial institutions have recordkeeping requirements for all transactions in the amount of $3,000 or more. 9. On March 8, 2013, the ZHENG Drug Traf?cking Organization used the email account MagicChemical@hotmail.com to provide the following bank account information to undercover law enforcement ordering Bene?ciary Name: Global United Biotechnology Inc. Account Number: 787? [redacted]- -883 Bene?ciary Bank Name: Hang Seng Bank Limited Bene?ciary Bank Address. 83 Des Voeux Road Central, Hong Kong Chips No. - [redacted]522 . Swift Code: [redacted]KHH Company Address: Quastisky Building, PO. Box 4389, Road Town, Tortola, British Virgin Islands 10, On or about March 16 and 25, 2013, the ZHENG Drug Traf?cking Organization distributed approximately 12 kilograms of 4-MEC that were sent to multiple addresses in the i United Kingdom. 11. On March 26, 2013, the ZHENG Drug Traf?cking Organization used its email account, MagicChemical@hotmail.com, to respond to a drug traf?cker expressing concern about 18 Case: Doc #2 1 Filed: 08/17/18 19 of 83. PageID 19 customs intercepting the drug packages containing three kilograms of Methylene. The Organization explained that it will mislabel the products to reduce the chance that customs will inspect it, falsely labeling the contents of three drug parcels as ?sebacic acid,? ?hydrogen peroxide resin,? and ?azelaic acid,? respectively. 12. On or about April 11, 2013, the ZHENG Drug Traf?cking Organization distributed approximately two packages each containing one kilogram of Methylone that were sent to two addresses in the greater London area in the United Kingdom. 13. After the United Kingdom apprehended its UK?based co-conspirators, the ZHENG Drug Traf?cking Organization changed some of its communication methods, including changing its email address to goldenchemical@live.com, its website to and its Skype address to Gordon] inChina. 14. On April 11, 2014, the ZHENG Drug Trafficking Organization posted the following statement on its new website, ?We are professional Pentylone manufacturer in China, a lot of US and Europe customers purchase big quantity from us. All chemicals we sell arelbest quality and competitive price. Generally, we will ship by DHL UPS Fedex or EMS, special way to USA and Russia, we guarantee package can pass your customs.? It also listed 19 other drugs that the Organization professionally manufactured and had available for immediate sale.? 15. On July 3, 2014, FUJIN ZHENG sent an email from his personal email account, to the ZHENG Drug Traf?cking Organization?s email address goldenchemical@live.com. In the email, UJIN ZHENG attached an excel spreadsheet containing?a drug ledger that listed some of the Organization?s drug sales in the last few months. 19 Case: Doc #2 1 Filed: 08/17/18 20 of 83.- PagelD 20 The ledger included the customer email address, date of drug distribution, type of drug, and amount paid in US dollars. 16. On November 14, 2014, undercover law enforcement received an email from the ZHENG Drug Traf?cking Organization via goldenchemical@live.com explaining that the Organization has experience in international drug traf?cking and smuggling dating back to at least 2008: We are professional Methylone manufacturer in China, our products are all best quality, pic of merchandise is in the attachment, a lot of US and Europe customers purchase largely from us every month. We are trade pro+ member of ec2l since 2008, our business license and all informations [sic] are veri?ed by ec2l. browse our webs: goldenrc2008.en.ec21.com . Generally, we ship merchandise by EMS and special way to USA, we have a lot of experience in shipping, we use aluminum foil bag to wrap, we will declare it as other chemical name, and we will offer a series of certi?cates, packages we sent can go through customs Safely, we guarantee package can pass customs, in case seized by customs, we re-iship free. Generally, payment we'accept is wire transfer to our company bank account. Besides, we also can accept [Money Transfer Company tell me how many quantity of Methylone you wanna buy? Do you wanna have a sample order? Regards, Gordon 17. On December 18, 2014, the ZHENG Drug Traf?cking Organization posted over 45 narcotics for sale on its EC21 vendor page, listing Global United Biotechnology as the underlying company and as the point of contact. 18. On January 31, 2015, the ZHENG Drug Traf?cking Organization used its email account goldenchemical@live.com to respond to a drug traf?cker seeking bulk shipments of A- PVP: 2.0 Case: Doc #2 1 Filed: 08/17/18 21 of 83. PageID 21 OK, I will ship 2.4kg a?pvp pink to the address. The package of EA09175725 with 1.42.5kg ethylene yellow get seized by customs, we will reship 1.425kg to you, still ship to the original address below: Recipient name: [redacted] Add: [redacted] Jacksonville, FL 32208 USA Tel: [redacted] 5592 I Right? Regards, Gordon The ZHENG Drug Traf?cking Organization distributed these narcotics shortly thereafter. 19. On February 15, 2015, Leroy S., a drug trafficker operating in the Northern District of Ohio, emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live;com with the subject, ?Acetylfentanyl.? In the email, Leroy S. stated, ?to whom it may concern I would like to purchase Acetylfentanyl. if possible can you send me prices as well as information on where I can send the money too [sic]. I also would like to no [sic] how long would it take to receive if I purchased Monday.? 20. On February 16, 2015, the ZHENG Drug Traf?cking Organization responded to Leroy S. using the email account goldenchemical@live.com: Dear Sir We are professional acetylfentanyl manufacturer in China, our products are all best quality, a lot of US and Europe customers purchase largely from us every month. Our web is Price of 1kg acetylfentanyl is $6,800 USD, be noted that the price we offer including shipping cost. 21 Case: Doc #2 1 Filed: 08/17/18 22 of 83. PageID 22 Generally, payment we accept is wire transfer to our company bank account. Besides, we also can accept [Money Transfer Company 1] and skrill tell me how many quantity you wanna buy? Do you wanna have a sample order? Where are you from? Regards, Gordon 21. On'February 17, 2015, after Leroy S. stated that he wanted to buy acetyl fentanyl but had concerns about the pricing and potential for law enforcement seizure, the ZHENG Drug Trafficking Organization responded using the email account goldenchemical@live.com: 500g 100g Generally, we ship merchandise by EMS and special way to USA, we have a lot of experience in shipping, we use aluminum foil bag to wrap, we will declare it as other chemical name, and we will offer a series of certi?cates, packages we sent can go through customs safely, we guarantee package can pass customs, in case seized by customs, we re-ship free, our service is best. If you buy l[]kilo, we will divide into 2 packages to ship. When will you order it? Do you wanna buy 100g or 500g? How do you, transfer money? i Regards, Gordon 22. On February 18, 2015, Leroy S. responded Via email, stating, want to place my order on or about the 23rd i would prefer the kg to be split sseparatly [sic] but can you please send me the info to ship it too iprefer [Money Transfer Company 1] but. If no better let me no [know].? 23. On February 25, 2015, Leroy S. emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live.com: 22 Case: Doc #2 1 Filed: 08/17/18 23 of 83. PageID 23 im going to send [Money Transfer Company 1] tranfers [sic] today for 500 grams i would like my oder [sic] split 250/250 to 2 diffrent [sic] addresses due to [Money Transfer Company wanting more identi?cation. over 2999 ill probably do 2600 and 800 is that ok with you. and though 250 seems like a lot [sic] to mail at one time but if its better to do 100 at a time let me no but once i receive [sic] tracking i will place another order for 500. The next day, the Organization responded, ?Ok, 250/250 to 2 different addreses [sic] is OK. 2600 and 800 is also 24. On March 2, 2015, the ZHENG Drug Trafficking Organization advertised that it is a ?professional? narcotics manufacturer in China on its website It guaranteed that it had the means of bypassing customs in foreign countries: .. a lot of US and Europe customers purchase big quantity from us All chemicals we sell are best quality and competitive price. Generally, we will ship by EMS DHL FedeX or UPS, special way to Russia, UK and USA, we guarantee package can pass customs.? The Organization also advertised that ?if you want new products, we can make it for you[] and keep secret.? 25.] On March 13, 2015, the. ZHENG Drug Trafficking Organization responded to Leroy S. using the email account goldenchemical@live.com, know you?ve already received packages [of acetyl fentanyl], is everything The next day, Leroy S. responded, I just did a transfer to you for $900.00 im going to do a larger transaction tommorow [sic] and another one monday it will be for 5 00 grams that i want sent to 4 addresses the for the 900 is [redacted]0092 from [redacted] jackson please email me to let me no [sic] the price you will offer me. 1 will send addresses once you recieve [sic] my payments 26. On March 15, 2015, the ZHENG Drug Trafficking Organization emailed Leroy S. using the goldenchemical@live.com email account, ?_?Price of 500g acetylfentanyl is $3,500 USD, when will you transfer $2,600 USD left. Sending to 4 different addresses is OK for us. tell me which name you transfer to? 23 Case: Doc #2 1 Filed: 08/17/18 24 of 83. PageID 24 27. On March 16, 2015 after Leroy S. indicated that he had the wrong name for the Money Transfer Company 1 transfer for the acetyl fentanyl payment, the ZHENG Drug Traf?cking Organization emailed Leroy S. using the goldenchemical@live.com email account, stating (emphasis in original): Our [Money Transfer Company 1] name is FUJING ZHENG, our [Money Transfer Company 1] informations [sic] are below: First name: FUJTNG Last name: ZHENG COuntry: China Price of 500g of acetylfentanyl is $3,600 USD, cOst of acetylfentanyl is very high, my friend, your pro?t is higher too much than us, our product?s quality is best. 28. On March 17, 2015, Leroy S. emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live.com, explaining that he got his refund from another vendor and will send the money the following day. After Leroy S. sent the funds to ZHENG, the Organization distributed the acetyl fentanyl. 29. The ZHENG Drug Traf?cking Organization?s distribution of acetyl fentanyl, a controlled substance analogue of fentanyl, to Leroy S. resulted in the death of TR, an individual whose identity is known to the Grand Jury, in Akron, Ohio, on or about March 21, 2015. 30. Drug Traf?cking Organization?s distribution of acetyl fentanyl, a controlled substance analogue of fentanyl, to Leroy S. also resulted in the death of CD, an individual whose identity is known to the Grand Jury, in Akron, Ohio, on or about March 28, 20 5 . 31. On May 29, 2015, Ohio law enforcement, acting in an undercover capacity, emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live.com through an 24 Case: Doc #2 1 Filed: 08/17/18 25 of 83. PageID 25 undercover email account, expressing an interest in purchasing a ?large amount? of acetyl fentanyl. The Organization responded on May 30, 2015: We are professional acetylfentanyl manufacturer in China, our products are all best quality, a lot of US and Europe customers purchase largely from us every month. Our web is Generally, we ship merchandise by EMS and special way to USA, we have a lot of experience in shipping, we use aluminum foil bag to wrap, we will declare it as other chemical name, and we will offer a series of certi?cates, packages we sent can go through customs safely, we guarantee package can pass customs, in case seized by customs, we re?ship free. Our service is best. Generally, payments we accept are Bitcoin, bank wire transfer, [Money Transfer Company [Money Transfer Company P18 tell me how many quantity you wanna buy from us? Do you wanna have a sample order? Regards, Gordon . 32. On May 30, 2015, undercover local law enforcement in the Northern District of Ohio emailed the ZHENG Drug Trafficking Organization at Dear Gordon, lam interested in purchasing 10 grams of acetylfentanyl. Upon arrival if the quality is to our standards I anticipate making larger purchases from you in the future. . Please email me the price for 10 grams and [Money Transfer Company 1] information. 33. On May 31, 2015 the ZHENG Drug Traf?cking Organization responded to law enforcement using the goldenchemical@live.com email account: cost of 10g sample is $150 USD, our [Money Transfer Company 1] inforrnations are below: First name: Guangfu Last name: Z[redacted] ?25 Case: Doc #2 1 Filed: 08/17/18 26 of 83. PageID 26 Country: China tell me MTCN, 100% right sender?s name (?rst name.last name), amount and country after you transfer money. also tell me 100% right and detailed address, recipient name and telephone number for shipping. Regards, Gordon 34. On June 5, 2015 the ZHENG Drug Traf?cking Organization distributed 10 grams of acetyl fentanyl to the undercover local law enforcement, with it arriving in the Northern District of Ohio on June 15, 2015. 35. On July 1, 2015 the ZHENG Drug Traf?cking Organization advertised on its website that it is a ?professional chemical manufacturer in China? and that ?a lot of US and European customers purchase huge quantity from us The Organization listed over 40 narcotics for sale, in addition to its custom It noted that for all parcels going to Russia and European countries, we guarantee package can pass customs.? It also stated that it accepted payment in Bitcoins. 36. On August 14, 2015, the ZHENG Drug Traf?cking Organization distributed narcotics to a drug traf?cker operating in Denver, Colorado. The Organization instructed the drug re-distributor to send money to the following individuals for the narcotics sales: GUANGHUA ZHENG ([redacted]/ 5 China Identi?cation Number [redacted]1616; ROOM 503 NO 168 CAO YANG ER CUN PUTUO ROOM 503 NO 168 CAO YANG ER CUN PUTUO, Shanghai, China. Guifeng C[redacted], China Identi?cation Number [redacted]; ROOM503 NO 168 CAOYANGERCUN SHANGHAI ROOM 503 NO 168 CAOYANGERCUN SHANGHAI, Shanghai, China The drug parcel also contained a piece of paper with the following payment information: 26 Case: Doc #2 1 Filed: 08/17/18 27 of 83. PageID 27 ZHENG FUJIN China Merchants Bank Hong Kong Branch [redacted] 6721 [redacted]KHH Bank of America Tower 12 Harcourt RD Central Hong Kong, China 37. On October 6, 2015, the ZHENG Drug Traf?cking Organization posted a blog on BlogSpot under the username entitled, MDEA Sell BK-MDEA I Buy is a Schedule I controlled substance. In the post, the Organization explained that ?Global United Biotechnology Inc. is a leading pharmaceutical company. Located in Shanghai and Jiangsu province [and] registered in British Virgin Islands.? It then explained that BK-MDEA is ?a stimulant, and of the phenethylamine, amphetamine? that ?has same effects like Noting the chemical?s strength, the ZHENG Drug Traf?cking Organization stated, recent times, the chemical has been studied in death case investigations.? It then linked to the Website globalrccom, inviting readers to ?please visit your website today.? 38. . On October 22, 2015, the ZHENG Drug Traf?cking Organization advertised its narcotics by posting a comment on the blog post, - What supplements do you give Kai?? In the post, a father living in Australia discussed the dif?culties of ?nding the proper nutritional I supplements for his autistic son. In one of the comments, the ZHENG Drug Traf?cking Organization posted the following advertisement: Global united biotechnology inc. offering many chemicals worldwide for legal use like manufacturing unit who are making medicine and have the right in state or country. See our product alpha-pvp and a-pvp and its details. sell alpha?PVP ?27 Case: Doc #2 1 Filed: 08/17/18 28 of 83. PageID 28 The comment contained a link to buying A-PVP, a highly potent and dangerous ?bath salt? with no known medical use, from 39. On November 7, 2015 the ZHENG Drug Traf?cking Organization advertised on its website the sale of over a dozen chemicals, listing goldenchemical@live.com as the contact email address and GordonJinChina as the Skype address. 40. On November 23, 2015 the ZHENG Drug Traf?cking Organization posted on its website ?We are professional AMB-FUBINACA manufacturer in China, a lot of US and European customers purchase big quantity from us All chemicals we sell are best quality. Generally, we "will ship chemicals by EMS DHL Fedex or UPS, special way to USA, Russia. and European countries, we guarantee package can pass customs.? The Organization stated that, if customs somehow seized the items, ?we will reship free.? Payment options included, ?[Money Transfer Company Bank wire transfer, Bitcoin and [Money Transfer Company It also explained, you want new products, we can do custom for you and keep secret.? The Organization listed over a dozen other drugs that it professionally manufactured in China. 41. On December 6, 2015, FUJIN ZHENG sent a test email from an email account af?liated with his front company, Shanghai Pharmaceutical Company 1 to his personal email account. 42. I On or about December 7, 2015, the ZHENG Drug Traf?cking Organization posted an advertisement on one of its EC21 vendor pages, stating that it delivers ?to all 50 USA states? and ?also ship[s] worldwide to Australia, Europe, Asia, and Africa.? 28 Case: Doc #2 1 Filed: 08/17/18 29 of 83. PageID 29 1 43. On February 23, 2016, and on March 29, 2016, the ZHENG Drug Traf?cking Organization advertised its narcotics by posting two comments on a blog post. The original March 6, 2015 blog post ?Case Report Pentedrone and Alpha?PVP Associated Death? was written by a forensic toxicologist. The blog detailed how a 28-year?old Polish drug user overdosed while using alpha-PVP (commonly referred to as including how the drug user suffered ?pulmonary edema? and ?chronic changes in the heart.? The ZHENG Drug Traf?cking Organization posted the following two comments in reply: Thankx for Sharing this Nice blo You May follow alpha?PVP to Buy this. Global united biotechnology inc. offering many chemicals worldwide for legal use like manufacturing unit who are making medicine and have the right in state or country. See our product alpha?pvp and a?pvp and its details. buy alpha?PVP Both of the comments included a link that redirected the reader to purchase from GoldenRC.com, the same drug tied to the overdose death reported in the blog. The ZHENG Drug Traf?cking Organization sold A-PVP in the United States and Poland at that time. 44. On March 29, 2016, FUJING ZHENG received a contract for services relating to his front company, Shanghai Pharmaceutical Company 1, at his personal email account, zhen gfuj in g@ [redacted] .cn. 45. On June 15, 2016, the ZHENG Drug Traf?cking Organization distributed over 800 grams of (?pink heroin?) that Was being sent to a drug traf?cker in Washington. The Organization attempted to smuggle the narcotics in parcels sent from Cambridge Chemicals? of?ce in China. 46. On June 6, 2016, the ZHENG Drug Traf?cking Organization emailed a Russian drug traf?cker operating in and around Vladivostok City, Russia using its 29 Case: Doc #2 1 Filed: 08/17/18 30 of 83. PageID 30 email account. In the email, the Organization explained how it circumvents China?s ban on certain chemicals by creating ?legal substitutesz? Since l.Oct 2015, a lot of chemical havebeen banned in China, now we can offer their legal substitutes, their effect and potency are almost as before, they all have good feedback, we sell them in big quantity every month now, prices are almost as before, they are below: Substitutes of ethylone and Methylone are Substitutes of alpha-PVP are Substitutes of ab-fubinaca are (powder), adb?fubinaca(powder) Substitutes of ab-chminaca are mmb?chminaca(powder) Substitutes of MAM-2201 are Substitutes of acetylfentanyl are furanylfentanyl(powder) Substitutes of 4?cec and 3-cec are Substitute of is 6-EAPB(powder) Substitute Of pentedrone is Substitutes of are browse our web to know more details about them. If you are interested [in] them, we can offer samples. Now we have better customized shipping way to your country compared to last year, packages we sent can go through customs safely, we will reship free in case package get seized by customs, our service is best. Besides, we also can offer custom service now, you just offer CAS number, IUPAC or picture of chemical structure to us. If you have anything else about the business, feel free to contact us. Regards, Gordon 30 Case: Doc #2 1 Filed: 08/17/18 31 of 83. PageID 31 47. On June 27, 2016, the ZHENG Drug Traf?cking Organization emailed a customer requesting a quote for a fentanyl analogue, stating, ?10g sample of 4? ?uoroisobutyrfentanyl is $100 USD, when will you order? How do you pay?? 48. On August 26, 2016, undercover law enforcement inquired on the website ww.ec21.com, requesting a reliable supplier of with ?good purity and discreet shipping.? RC is shorthand for ?research chemicals,? coded language referring to narcotics. That same day, responded using the email account goldenchemical@live.com, stating: We are professional research chemicals manufacturer in China, our products are all best quality, alot of US and European customers purchase largely from us every month. tell me which products you wanna buy? Regards, Gordon 49. On September 4, 2016, the ZHENG Drug Traf?cking Organization responded using goldenchemical@live.com to a drug customer in Florida ordering 4FPHP and MPBP, stating, I give you another name to transfer by [Money Transfer Company it?s below: First name: FUJIN Last name: ZHENG Country: CHINA 50. On September 8, 2016, a drug traf?cker emailed ZHENG Drug Traf?cking Organization at goldenchemical@live.com, asking why there was a signi?cant delay in the narcotics shipment. The Organization responded the next day, explaining that they ?color? the narcotics chemicals, thereby tricking Chinese of?cials and making it ?easier to pass customs.? 31 Case: Doc #2 1 Filed: 08/17/18 32 of 83. PageID 32 51. On September 13, 2016, the ZHENG Drug Traf?cking Organization responded using goldenchemical@live.com to a drug traf?cker in Poland seeking 20 kilograms of narcotics. The Organization provided payment information for the transaction. 1 52. On September 13, 2016, the ZHENG Drug Traf?cking Organization used goldenchemical@live.com to email a drug distributor, stating, ?It?s [sic] showed that is delivered online, but you told me that it?s [sic] get caught by police, tell me your thinking how to deal with i After the drug distributor told the Organization that he ?won?t risk my freedom trying to get it,? and the Organization agreed to re-ship it a different way, the customer con?rmed that he sent the payment for the narcotics to with additional identi?ers via Money Transfer Company 2. 5 3. On September 15, 2016, the ZHENG Drug Traf?cking Organization discussed bulk shipment of narcotics with a drug traf?cker in Singapore. 54. On September 16, 2016, the ZHENG Drug Traf?cking Organization distributed ADB-FUBINACA to a drug traf?cker operating in Russia after receiving payment in Bitcoin. 55 . On September 16, 2016, the ZHENG Drug Traf?cking Organization distributed to a drug traf?cker operating in the United Kingdom after receiving payment in Bitcoin. 5 6. On September 18, 2016, the ZHENG Drug Traf?cking Organization provided an Nuclear Magnetic Resonance Spectroscopy (NMR) an expert analytical examination to con?rm the purity of a drug to a drug traf?cker to demonstrate the purity and quality of the MPHP that he was purchasingNovember 21, 2016, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live.com, using Chemical Abstracts Service (CAS) numbers as code for narcotics: 32 Case: Doc #2 1 Filed: 08/17/18 33 of 83. PageID 33 To Gordon We recently settled accounts and parted ways with our former supplier for CAS 59708?52?0 [Carfentanil] and 3258?84?2 [Acetyl Fentanyl] due to purity and reliability issues. We have an urgent need to resume service as quickly as possible. Do you have CAS 59708-52?0, 3258-84-2 or even 121348?98-9 in stock? Please let us know The Organization respOnded the same day, stating: 59708?52-0 is carfentanyl, if we it for you, how many quantity you will buy? 325 8?84?2 is acetylfentanyl, it?s banned in China, we don?t offer it. 121348-98-9 is we can offer it, how many quantity you wanna buy? Regards, Gordon 58. From November 30 to December 7, 2016, the ZHENG Drug Traf?cking Organization discussed pricing, shipping, and terms with undercover law enforcement, ultimately deciding on a purchase of U-47700. When undercover law enforcement asked for payment information, the Organization provided GUANGHUA name as the recipient of the drug money: I Our [Money Transfer Company 2] information are below: First name: GUANGHUA Last name: ZHENG Country: China 59. On December 16, 2016, undercover law enforcement asked for the tracking information for the parcel containing the shipment. The ZHENG Drug Trafficking Organization responded, ?We ship package to warehouse in USA at first, then ship to you by FedEx? and provided the FedEx tracking number. The Organization was referring to Bin Wang?s warehouse in Wobum, Massachusetts. The ZHENG Drug Trafficking Organization used Bin Wang?s companies including Cambridge Chemicals, Wonda Science, OneChem, 33 Case: Doc #2 1 Filed: 08/17/18 34 of 83. PageID 34 Daniel Lab, and ChemCloud to smuggle narcotics into the United States and distribute them within the country. 60. On December 20, 2016, undercover law enforcement retrieved the parcel containing The Organization shipped the U-47700 in such a way that it appeared that it was a purely U.S. domestic shipment sent from Cambridge Chemicals at 5 Walnut Hill Park, Unit 13, Woburn, Massachusetts, 01801. 61. On anuary 2, 2017, a Florida drug traf?cker expressed concern to the ZHENG Drug Traf?cking Organization that customs was increasingly Seizing its drug parcels. The Organization responded using goldenchemical@live.com that it would no longer be a c-oncem: Now we have a new shipping way, package is sent to a warehouse in Boston at first, then shipping to you by FedEx, it?s safer, we will offer your address after package arrived in Boston. In case package get seized by customs, we will not offer your address to shipping company, nobody can find you, it also can be waive signature if you operate online, see pic below, is this OK with you? The Organization explained that it used Bin Wang?s companies in the Boston area to re-ship drugs in order to limit customs? interdiction and protects customers? infOrmation. 62. On January 10, 2017, Bin Wang, Qinghua Y., aka Jason Yen, X., and other employees of Wang?s companies communicated over the WeChat communication platform 1 regarding the ZHENG Drug Traf?cking Organization?s parcels. After reviewing the large numbers of customers receiving bulk chemical shipments from the ZHENG Drug Traf?cking Organization, Wang expressly informed his employees that these parcel deliveries were ?very risky? for them as they were ?prohibited by law.? . 63. On January 18, 2017, undercover law enforcement contacted FUJIN ZHENG at goldenchemical@live.com, asking for a list of their available products. That same day, UJTN ZHENG responded: 34 Case: Doc #2 1 Filed: 08/17/18 35 of 83. PageID 35 My friend, besides U-47700, during these time our hot sale products are Hexen, Ephylone, 4F-PHP, MPHP, Dibutylone and 4? CHIMINACA, 5F-ADB, eitzolam and 251-NB OH. Which products are you interested? Regards, Gordon Www. goldenrccom whats app +8618117528156 64. On January 23,2017, law enforcement purchased 50 grams of (?flakka?) from the ZHENG Drug Traf?cking Organization at goldenchemical@live.com to be sent to Ohio. On January 24, 2017, JIN responded with payment information: Our [Money Transfer Company 1] information are below: First name: Longbao Last name: Z[redacted] Country: China These information are enough to transfer mOney for you. Public holiday of China?spring festival already begin, it?s the most important festival in China, just like Christmas in USA, so we ship at about 6th Feb., is this OK with you? Regards, Gordon Whatsapp +86 18117528156 The Organization distributed the shortly afterwards around February 15, 2017 through Bin Wang?s front companies. 65. On February 12, 2017, Bin Wang, Qinghua Y., X., and other employees of Wang?s. companies communicated over a group WeChat regarding the ZHENG Drug Trafficking Organization?s parcels. explained that the Organization?s ?red powder dyes are all hazardous; I don?t care to submit them for testing.? ?Red powder dyes? and ?hazardous chemicals? were code for controlled substances. ?Testing? referred to submitting the chemicals 35 Case: Doc #2 1 Filed: 08/17/18 36 of 83. PageID 36 to Chinese customs for chemical analysis, which would have revealed the chemicals? true nature as narcotics. X. proposed a solution involving smuggling narcotics underneath legal chemicals: ?Why don?t I just take a risk this time? I?ll send the red one along with 750 grams of the whitish one, and I?ll place the red one underneath.? In response, Bin Wang suggested I smuggling them in certain types of bottles. X. responded that this was not possible due to their size. Bin Wang replied that from now on they will instead ?use a foil bag? and ?heat seal it and mark it as nitrogen sealedon the label.? Certain chemicals are transported in nitrogen sealed containers. For these chemicals, opening a nitrogen sealed bag would render them inert and thus valueless. Qinghua Y. responded to Wang?s suggestion, ?Yes. This way, they won?t check it.? After discussing how to accomplish this new packaging method, X. stated, ?Let Mr. JTN pack it in a bottle.? Qinghua Y. replied, ?Tell him at a later time.? X. concluded the conversation discussing how to mislabel the narcotics, reminding the others that ?previously Mr. dark?red colored product was sent out as Portland cement,? referring to the term they previously used to mislabel types of narcotics for the Organization. 1 66. On March 7, 2017, undercover law enforcement inquired about purchasing Dibutylone for re-distribution in Ohio. The ZHENG Drug Traf?cking Organization responded using goldenchemical@live.com: number] 17763-12?1 is Dibutylone, 1kg is $1,300 USD including shipping cost to USA, we will reship in case package get seized by customs, when will you order? Do you pay by bitcoin, [Money Transfer Company bank wire or [Money Transfer Company 1] this time? Please send reply to our new email later, it?s sales@globalrc.net. Regards, Gordon whatsapp +86 18117528156 36 Case: Doc #2 1 Filed: 08/17/18 37 of 83. PageID 37 Around this time, the Organization began recommending that its customers communicate with it through its sales@globalrc.net email account, which was hosted by ProtonMail in Switzerland. ProtonMail is an end?to?end email service. The Organization increasingly pressured its customers to contact it using this this end?to-end enerypted account going forward. 67. On March 8, 2017, the ZHENG Drug Trafficking Organization emailed undercover law enforcement with payment information for the Dibutylone purchase: 500g Dibutylone is $700 USD, our [Money Transfer Company 1] information are below: First name: Songyan Last name: [redacted] Country: China tell me MTCN, 100% right and detailed address, recipient name and telephone number for shipping. . We changed our email cos new email looks more formal, our websit [sic] is Regards, Gordon whatsapp +86 18117528156]] The ZHENG Drug Traf?cking Organization distributed the Dibutylone to the Ohio undercover law enforcement address on March 31, 2017 thr0ugh Bin Wang?s front companies. 68. On May 11, 2017, the ZHENG Drug Trafficking Organization attempted to distribute one kilogram of narcotics using Bin Wang?s front companies in Wobum, Massachusetts as a re-distribution point for drug traffickers in Florida and The parcel was shipped from Qinghua Y., who used his alias, Jason Yen: YEN, 509-2 Building C, Changzhou, Tianan City, China.? The?listed recipient for the parcel coming from China was the Organization?s narcotics redistribution point in the United States at that time 3. 37 Case: Doc #2 1 Filed: 08/17/18 38 of?83. PageID 38 ?Chemcloud, Inc., 5 Walnut Hill Park, Suite 13, Wobum, Massachusetts 01801.? The product. was mislabeled as a non?controlled chemical that acts as a ?re retardant. 69. On May 11, 2017, the ZHENG Drug Traf?cking Organization distributed one kilogram of 'It used Bin Wang?s front companies in Wobum, Massachusetts as a re? distribution point to send it to a drug customer in Lancaster, The parcel waslisted as coming from Qinghua Y.?s alias, Jason Yen: JASON YEN, 509?2 Building C, Changzhou, Tianan City, China to Chemcloud, Inc., 5 Walnut Hill Park, Suite 13, Wobum, Massachusetts 01801. 70. On May 1 1, 2017, the ZHENG Drug Traf?cking Organization distributed a drug parcel containing 4??methyl?alpha?PHP, 4??f1uoro-alpha-PHP, FUB-AMB, all narcotics. The drug parcels were addressed from Jason Yen, Qinghua Y.?s alias: YEN, 5 09?2 BLDG C, Changzhou Tianan CY, Changzhou, S, 213164, China, and addressed to WANG, CHEMCLOUD, INC, 5 Walnut Hill Park, Suite 13, Wobum, MA 01801, 617? 935-2742.? The supporting documentation the Organization provided falsely stated that the package contained a flame retardant compound. The drugs were labeled for reshipping to different individuals in different states. 71. On or about May 23, 2017, the ZHENG Drug Traf?cking Organization co? conspirators operating in MissOuri possessed withintent to distribute 145.4 kilograms of narcotics, as well as several ?rearms. The ZHENG Drug Traf?cking Organization used Bin Wang?s companies in Wobum, Massachusetts to smuggle the kilograms of narcotics into Missouri. 38 Case: Doc #2 1 Filed: 08/17/18 39 of 83. PageID 39 72. On or about June 5, 2017, the ZHENG Drug Traf?cking Organization distributed to an undercover law enforcement address in Ohio through Bin Wang?s front companies in Wobum, Massachusetts 73. On June 9, 2017, the ZHENG Drug Traf?cking Organization received an alert on its goldenchemical@live.com email account from its vendor page on TradeIndia.com for a buyer interested in purchasing bulk The buyer was interested in buying ?6-10 kg per month.? 74. On June 10, 2017, a drug customer in Maryland con?rmed that he sent payment for (a cathinone) to the following Money Transfer Company 2 account: [Money Transfer Company 2] Reference number is 75468889 Recipient: Guifeng C[redacted] 75. On June 12, 2017, a drug traf?cker emailed the ZHENG Drug Traf?cking Organization at goldenchemical@live.com, stating, ?Looking for something that is legal and doesn?t show up on drug screens in the US. Let me Know what you have that ?ts the criteria.? The next day, the Organization replied using goldenchemical@live.com, ?My friend, our website is tell me which products you wanna buy. Now We have warehouse in USA, we can ship to you from warehouse in USA. Please send reply to our new email later, it?s sales@globalrc.net.? 76. On July 6, 2017, undercover law enforcement emailed sales@globalrc.net and purchased ADB-FUBINACA from the ZHENG Drug Traf?cking Organization. When . requesting payment information, the ZHENG Drug Traf?cking Organization directed the undercover agent to wire money direCtly into GUANGHUA bank account, but to conceal the nature of the transaction: Please do not label the money is for buying adb?fubinaca when you transfer money, don?t label any chemical name, otherwise I worry the account will be cancelled. I 39 Case: Doc #2 1 Filed: 08/17/18 40 of 83. PageID 40 suggest that you label it as tuition fee or Family maintenance when transfer money, our bank information is below: Bene?ciary Name: ZHENG GUANGHUA Bank Name: China Merchants Bank Hong Kong Branch Account number: [redacted]1756 Swift code: [redacted]KHH Address: Bank of America Tower 12 Harcourt Road, Hong Kong The same China Merchants Bank Hong Kong Branch ending in 1756 to which instructed the undercover agent to wire druggmoney had signi?cant wire activity involving both FUJING and GUANGHUA Bank of China accounts located in China. Numerous clients and co?conspirators of the ZHENG Drug Traf?cking Organization were also instructed to send funds into GUANGHUA China Merchants Bank Hong Kong Branch account ending in X1756 for the purchase of narcotics. 77. On July 14, 2017, the ZHENG Drug Traf?cking Organization distributed Schedule I controlled substances and analogues Dibutylone, 4?Methyl?PHP (MPHP), and ADB- FUBTNACA It shipped the narcotics in bulk freight to Bin Wang front companies in Woburn, Massachusetts as a re? ?distribution point to send to drug customers in Alabama, Florida and Ohio, respectively. The parcel was listed as coming from Jason Yen, Qinghua Y.?s alias: YEN, CHEMCLOUD, Room 920, Changwu Road 888, iangsu, Changzhou 213164, China? and was addressed to Bin Wang at 5 Walnut Hill Park, Suite 13, Woburn, Massachusetts 01801. The products were mislabeled as a non-controlled chemical compound. The drugs were stored in heat?sealed foil bags addressed to individuals residingin separate states. In addition, the parcel contained printed waybills that falsely stated, ?This is to certify that . this chemical is not listed in Controlled Chemical Act in US. Yours sincerely, Sales Manager JASON YE 3? JASON YEN also signed a Toxic Substance Control Act (TSCA) form 40 Case: Doc#: 1 Filed: 08/17/18 41 of 83. Page D#: 41 dated July 12, 2017,. certifying thatf?all chemicals in this shipment are not subject to The package of was an undercover purchase destined fOr Ohio. 78. On July 14, 2017, Bin Wang learned that he was the target of a federal drug . traf?cking investigation while returning from China. On July 17, 2017, Wang distributed numerous ZHENG Drug Trafficking Organization parcels that had been stored at a warehouse at 5 Walnut Hill Park, Woburn, MA. On July 21, 2017, Wang attempted to leave the country and was arrested by law enforcement. 79. On August 2, 2017, after undercover law enforcement emailed the ZHENG Drug Trafficking Organization at sales@globalrc.net to inquire as to the status of a drug package that Bin Wang and his companies were originally going to re-ship but that law enforcement had i seized. As an explanation for the non-delivery of the drug shipment from Bin Wang?s companies, the Organization indicated that the ?shipping company is still solving problems of edEx.? The Organization instead sent undercover law enforcement a ?replacement package? of ADB-FUBINACA Via a freight forwarder located in the Republic of Tonga. On August 24, 2017, after a US. federal judge ordered Wang?s pretrial detention, the Organization informed undercover law enforcement, ?sorry, we can not, ship by FedEx now, we ship by special way from Tonga, just same as last time, is this OK with you?? 80. On September 19, 2017, UJING ZHENG emailed an Asian Exchange from his personal email account, I have an account on [Asian Exchange]. my login name is zhengfujing@[redacted] .cn I'm a China resident, Can I withdraw USD to my bank account in Hongkong? Regards, 41 Case: Doc #2 1 Filed: 08/17/18 42 of 83. PageID 42 . GORDON The ZHENG Drug Trafficking Organization used the Asian Exchange account to obtain and launder drug proceeds. FUJING ZHENG received periodic emails from the Asian Exchange to his personal email account, updating him with payments and withdrawals made into the ZHENG Drug Traf?cking Organization criminal account. 1 81. On November 10, 2017, the ZHENG Drug Trafficking Organization updated its vendor page on the trade website to list over 30 controlled substances for sale. On the product page for U-47700, the Organization noted that ?investigated, toxicity levels of U-47700 for sale are extremely high.? The People?s Republic of China banned the manufacture and distribution of on June 19, 2017, several months before the Organization updates its list of narcotics for sale to include On the page, the Organization also claimed that it and the trade website had a valid internet content license ?by the Chinese Ministry? to operate the web page. 82. On or about December 1, 2017, the ZHENG Drug Traf?cking Organization updated its On the Site, the Organization described itself as a large- scale drug manufacturer, stating that it ?produces and sells more than 16 tonnes of chemicals every month? from ?our own laboratory.? The only chemicals listed on the website were narcotics. According to the Organization, its laboratory was able to nearly any chemical on a bespoke basis in any quantity.? The Organization also explained that it had small? and large?scale drug distributors (?retailers and wholesalers?) operating as part of its conspiracy around the world (emphasis added): Located in China, we are a leading pharmaceutical company, honored as the high- tech enterprise which engaged in researching, manufacturing and exporting 42 Case: Doc #2 1 Filed: 08/17/18 43 of 83. PageID 43 research chemicals, sedatives, active pharmaceutical ingredients (API) and other ?ne chemicals. We have our own laboratory so that we can research, and produce all our own production and perform quality control procedures. We produce and sell more than 16 tonnes of chemicals every month. Besides, we also can nearly any chemical on a bespoke basis in any quantity, what we need are chemical name, CAS number, IUPAC name or chart of chemical structure. 'We have developed many retailers and wholesalers in US and Europe during these years, their sales amount is constantly growing every month. Almost all our customers are loyal to cooperate us because they know that they have Wide range of best products, ?exible payment options, fast and insured delivery, secured and comfortable ordering process, prompt and effective customer - serv1ce. In addition, the Organization explained that it has advanced smuggling methods that complement its abilities as a large-scale manufacturer. These methods include ?warehouses? (reshipping locations) in multiple locations that makes drug shipments in destination countries appear to be purely domestic mailings: The best way to save time and money is to deal with a reliable company. Globalrcnet guarantees 100% deliver and reshipment of products if package got seized by customs. We ship the chemicals by EMS, USPS, TNT, DHL, Fedex, UPS and special ways to USA, Russia, Europe and other countries, there are WarehouSe available in USA and Europe, the delivery is to your door. The Organization also explained that it uses techniques to reduce the probability that law enforcement would ?nd narcotics in its packaging, stating, ?We understand that our customers require privacy, so special care is taken when packaging products.? It also offered special deals and expedited shipping for bulk narcotics purchase of 25 kilograms or more. 83. On December 4, 2017, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at Sales@globalrc.net regarding opioids it had for sale, ?I?ve heard, . good things about methoxyacetyl-fentanyl. What are your prices? Also do you have any reviews for GORDON IIN sent the following response: Myfriend, I suggest that you pay by [Money Transfer Company Bitcoin or OKPAY when you buy sample. We can accept [Money 43 Case: Doc #2 1 Filed: 08/17/18 44 of 83. PageID 44 Transfer Company Bitcoin, Bank wire transfer or OKPAY when formal order. Prices of 1kg are below: methoxyacetyl?fentanyl $5,500 USD $5,200 USD be noted that the price we offer including shipping cost. we have a lot of experience in shipping, packages we sent can go through customs safely, we guarantee that package can pass customs, we will reship free in case of package get seized by customs. What we offer is not only product, but also service behind the product. It?s very important for customer, if you don?t receive anythingafter you pay, it will make no sense Currently, payments we accept are Bitcoin, OKPAY [Money Transfer Company 2] and bank wire transfer. tell me how many quantity of each you wanna buy? Do you wanna have a sample order to try? Kind Regards, GORDON JIN globalrc. net WhatSApp: +86 18]] 7528156 84. On January 10, 2018, GUANGHUA ZHENG sent an email relating to an investment opportunity from his personal email account, zhengguanghua195 5@[redacted] .com, with an attachment. The attachment contained information relating to FUJIN ZHENG, including that FUJTN ZHENG owned a home worth more than $1.2 million US. dollars in China. 85. On January 14, 2018, the ZHENG Drug Trafficking Organization listed over a dozen narcotics for sale on ruglobalrcnet, a Russian language mirror of the Organization?s primary website, 86. On February 7, 2018, a foreign entity emailed FUJIN ZHENG and GUANGHUA ZHENG at their respective personal email accounts, asking for more information 44 Case: Doc #2 1 Filed: 08/17/18 45 of 83. PageID 45 about their ?nances. Earlier in the conversation, FUJING ZHENG and GUANGHUA ZHENG indicated to the foreign entity that they plan to move ?3 million? and ?2 million? in deposits, respectively, into the foreign entity?s account. 87. . On February 22, 2018, FUJING ZHENG spoke with an undercover law enforcement officer over the telephone regarding smuggling bulk shipments of narcotics into the United States. The conversation was in Mandarin, with undercover law enforcement dialing the number for listed on On the call, the undercover of?cer discussed ordering approximately 15 kilograms or more of potent opioid U-48800 and other dangerous controlled substance analogues a mOnth and having the Organization smuggle them into the United States. FUJING ZHENG described himself as and the ?manager for foreign trading? and explained that he handled all interactions with customers. FUJING ZHENG also noted that the Organization operated out of Taizhou, Jiangsu in China, which is near Shanghai. When undercover law enforcement mentioned that they would initially order 10 kilograms of U-488OO that the Organization would need to smuggle into Florida, FUJING ZHENG responded that 10 kilograms of per order is not a problem and that ?we have a route to Florida.? FUJING ZHENG also guaranteed that his chemical?s purity ?is 99.5% and up.? i 88. On March 11, 2018, after undercover law enforcement asked about payment methods for a proposed purchase of the ZHENG Drug Trafficking Organization replied, ?Yes, we have it in stock. Can you pay by Bitcoin or Litecoin? Bitcoin and Litecoin belong to currency, they are. anonymous, safe, fast and convenient. I recommend some website below to you, they need to register at ?rst, then just can transfer by Litecoin or Bitcoin.? 45 Case: Doc #2 .1 Filed: 08/17/18 46 of 83. PagelD 46 89. From on or about March 12, 2018 to on or about March 19, 2018, the ZHENG Drug Traf?cking Organization attempted to distribute over 50 packages containing kilogram quantities of narcotics across the United States. These packages were destined for individual customers across 23 states. 90. On March 16, 2018, after the parties agreed that undercover law enforcement would pay. for the 4-CL-PVP in Bitcoin, the ZHENG Drug Traf?cking Organization sent the following email containing the Bitcoin public key needed to ?nalize the transaction: . Our Bitcoin address is [redacted]PA1xX8A also tell me 100% right and detailed address, recipient name and telephone number for shipping. - Our WhatsApp number changed, new number is 852 62326317 Kind Regards, GORDON JTN WhatsApp: 852 62326317 91. The Bitcoin public key address [redacted]PA1xX8A related back to an account with a European Exchange. GUANGHUA ZHENG opened this account on October 5, 2017, listing his contact email address as I GUANGHUA birth year is 1955. As part of the European Exchange account creation process, GUANGHUA ZHENG provided a photograph of himself along with his valid People Republic of China?s passport. Within a short time in 2017, GUANGHUA ZHENG transferred $184,844.32 from his x1756 account into his European Exchange account. The x1756 account and the European Exchange are only two of numerous other bank accounts and 46 Case: Doc #2 1 Filed: 08/17/18 47 of 83. PageID 47 exchanges that GUANGHUA ZHENG used to launder drug proceeds for the ZHENG Drug?Traf?cking Organization 92. On March 9, 2018, GUANGHUA ZHENG responded to the European Exchange?s request for information responsive to its Know Your Customer, requirements. GUANGHUA ZHENG alleged that he only made $50,000 (US. dollars) a year in salary. Despite allegedly earning only $50,000 a year in income, GUANGHUA ZHENG informed the Exchange that he had over $1,000,000 in savings, planned to deposit approximately $1,000,000 per year into his European Exchange account going forward, and I withdraw approximately $700,000 per year from the Exchange account. GUANGHUA stated purpose for the monetary transfers was ?investing.? This was one of many exchange accounts used, by the Organization to launder funds. 93. in his response to the European Exchange, GUANGHUA ZHENG also provided his personal bank account information: - Bene?ciary Name: ZHENG GUANGHUA Bank Name: China Merchants Bank Hong Kong Branch Account number: [redacted] 1756 Swift Code [redacted]KHH Address: Bank of America Tower, 12 Harcourt Road, Central, Hong Kong The ZHENG Drug Traf?cking Organization previously had repeatedly instructed drug traffickers and undercover law enforcement to wire drug payments to GUANGHUA x1756 account at China Merchants Bank. 94. When the European Exchange had further questions based on his responses and requested additional documentation, GUANGHUA ZHENG threatened to 47 Case: Doc #2 1 Filed: 08/17/18 48 of 83. PageID 48 terminate his business with the exchange, stating, you don?t accept all documents I can offer, then 1 will not invest on [the European Exchange], just return my money.? 95. On March 23, 2018, undercover law enforcement transferred bitcoins to the ZHENG Drug Traf?cking Organization?s Bitcoin wallet as payment for the On April 12, 2018, the ZHENG Drug Traf?cking Organization distributed 500 grams of to an undercover law enforcement address in the Northern District of Ohio. 96. . On April 16, 2018, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at sales@globalrc.net about the Organization creating counterfeit Oxycodone pills that instead contained U-48800, a potent opioid. The email contained piCtures of the pills and asked if the Organization can ?make a custom order and press the to look like these tablets?? The Organization responded, ?If we press so for you, how many tablets will [you] buy from us?? 97. On April 18, 2018, FUJIN ZHENG sent an email from his personal email account, to info@TopLabRC.com, an email account associated with the ZHENG Drug Traf?cking Organization?s latest drug traf?cking website, In reference to the new website, FUJTN ZHENG emailed, ?this is very good.? 1 98. On April 19, 2018, law enforcement requested a quote from FUJIN ZHENG at sales@globalrc.net for two kilograms of Dibutylone. The ZHENG Drug Traf?cking Organization provided a quote shortly thereafter. Law enforcement then indicated it would pay in Bitcoin, asking for a Bitcoin address. On May 3, 2018, undercover law enforcement received the following reply from the Organization using sales@globalrc.net: 48 Case: Doc #2 1 Filed: 08/17/18 49 of 83. PageID 49 Our Bitcoin address is [redacted]F4uhiy inform me after you transfer money. also tell me 100% right and detailed address, recipient name and telephone number for shipping. Kind Regards, GORDON WhatsApp: 852 62326317 The Bitcoin address [redacted]F4uhiy associated to an Asian Exchange account that used the email address as a point of contact. 99. . On April 20, 2018, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at sales@globalrc.net, asking if the Organization could create Adderall pills that include the ?bath salt? Dibutylone. The Organization replied, ?we can do So, please tell . mehow many pills or tablets of each you want?? On April 22, 2018, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at sales@globalrc.net, ?how many tablets [of counterfeit Adderall] can you make with a kilogram of Dibutylone? What would the cost run us?? The Organization responded, ?We made pills for USA customers before. You need to tell me formula at ?rst, then I just can tell you that how many tablets we can make with a kilogram of Dibutylone.? 100. On April 23, 2018, FUJTNG ZHENG received a test email from the ZHENG Drug Traf?cking Organization?s new email account info@TopLabRC.com to his QQ email (35 07656950@qq.com) and his personal email account 101. On April 24, 2018, undercover law enforcement emailed the ZHENG Drug Traf?cking Organization at sales@globalrc.net, providing pictures of trademarked Adderall 20mg tablets and stating, ?We?d like you to make these up to look like Adderall 20?s.? Undercover law enforcement then provided the chemical formula and asked for the Organization 49 Case: Doc #2 1 Filed: 08/17/18 50 of 83. PageID 50 to ?replace the active ingredients with the Dibutylone.? In subsequent emails, undercover law enforcement emphasized, ?Again, these should look like exact copies of the tablet I sent to you? and ?theseshould look like Adderall 1R (immediate release) 20mg tablets, like in the photo.? On April 28, 2018, after con?rming the ?nal chemical formula for the counterfeit pills, the Organization stated that it could prepare ?50,000 pills? of Adderall laced with Dibutylone. On or about May 10, 2018, undercover law enforcement paid in Bitcoin to the ZHENG Drug Traf?cking Organization?s [redacted]F4uhiy Bitcoin wallet for the 50,000 ?Adderall? pills that i in fact contained Dibutylone. The Organization subsequently manufactured and imported the adulterate'd Adderall pills containing Dibutylone into the United States. 102. On or about May 18, 2018, the ZHENG Drug Traf?cking Organization advertised its ability to operate as a large?scale drug laboratory on the ?Custom page of its website, This advertisement was one of many the Organization made over several years touting its process of creating and manufacturing narcotics: GlObalrcnet has more than 7 years experience in providing custom in our laboratory. We work diligently to make every possible chemical to meet the needs of our customers. What this meansis that you can purchase many other products than the ones you found on our website. We will create custom?made products for you. The new product will satisfy your requirements. Our laboratory is equipped with latest technological innovations and all the necessary instruments and process vessels. We also have a large variety of chemicals. This allows of all kinds of chemical compounds even when no data about previous method or IP basis is available. We work out our own methodology and make the initial research. Our customers are not involved in this process as it can be very complex but will receive the ?nal product with their required parameters. 103. On May 18, 2018, underCOVer law enforcement transferred Bitcoins as payment to the ZHENG Drug Trafficking Organization?s [redacted]F4uhiy Bitcoin wallet for a two kilogram 50 Case: Doc #2 1 Filed: 08/17/18 51 of 83. PageID 51 shipment of Dibutylone. On June 6 and 14, 2018, the ZHENG Drug Traf?cking Organization distributed the two kilograms of Dibutylone into the Northern District of Ohio as part of an undercover purchase from ZHENG via sales@globalrc.net. 104. On June 27, 2018, the ZHENG Drug Traf?cking Organization advertised on its website, that it has developed expertise ?making pill or tablet of sedative.? 105. On June 28, 2018, law enforcement transferred Bitcoins as payment for the two kilograms of Dibutylone to the ZHENG Drug Traf?cking Organization?s [redacted]F4uhiy Bitcoin wallet. 106. On or about July 3, 2018, the ZHENG Drug Traf?cking Organization used its Tradeleadcom account page to advertise its expertise in manufacturing narcotics and smuggling them into countries around the world. On the account page, the Organization stated, ?We have our own laboratory so that we can research, and produce all our own production and perform quality control procedures. We produce and sell more than 16 tonnes of Chemicals every month. Besdies [sic], we also can nearly any chemical on a bespoke basis in any quantity.? 107. On or about July 15, 2018, the ZHENG Drug Traf?cking Organization maintained its vendor page on There, it stated that it had manufactured ?research chemical? and ?pharmaceutical chemical? since 2007. It stated that its ?main market? was ?worldwide.? The Organization also stated thatits ?total annual sales volume? was ?more than 100 million and that it employed more than 50 employees. 108. On July 16, 2018, the ZHENG Drug Traf?cking Organization updated its website globalrc.net. Under ?News,? the Organization posted, ?New Product 2-FDCK: After our unremitting efforts in researching, we can provide at present.? The Organization?s new 51 Case: Doc #2 1 Filed: 08/17/18 52 of 83. PagelD 52 site, TopLabRC.com, had the identical noti?cation posted in August 2018. The Organization described the product as ?a lesser?known novel dissociative substance of the class that produces dissociative, anesthetic, and hallucinogenic effects when administered.? 109. On July 27, 2018, undercover law enforcement emailed the ZHENG Drug Trafficking Organizationiat sales@globalrc.net, asking if the Organization would be willing to adulterate cancer drugs with cathinones tied to serious adverse health consequences and overdose deaths: While we?re waiting on our previous tablet delivery, could you do a ?custom price quote for us for more tablets? Would you make copies of either of the following tablets, substituting the active ingredients with BK-EDBP We can get you the exact formula, but we?re looking for a ballpark figure so we know how much BTC to obtain for the purchase. Tarceva 15 0mg Aflnitor 5mg The email contained pictures of the Mo drugs, with instructions to make it ?look like either of those tablets.? Tarceva? (Erlotinib) and Afinitor? (Everolimus) are both cancer treatment drugs. Tarceva treats lung and pancreatic cancer. A?nitor treats renal cancer and other tumors. Both cancer drugs are trademark protected in both the United States and China. The Organization responded, acknowledging that it was aware that it would be creating adulterated cancer drugs, ?we can make pills according to your requirement. But Tarceva and A?nitor all belong to anti?cancer drug.? Undercover law enforcement con?rmed that they Were cancer drugs and asked, ?Please let us know if you can do these or not, as we have to let a new buyer know soon.? The Organization responded, ?Do you mean that make pill of but shape of 52 Case: Doc #2 1 Filed: 08/17/18 53 of 83. PageID 53 pill look like in the picture you gave me?? UndercoVer law enforcement replied, ?exactly.? The Organization con?rmed that it would make the cancer drugs adulterated with deadly narcotics, ?yes, we can do so.? 110. On or about July 27, 2018, the ZHENG Drug Traf?cking Organization listed over 30 drugs on its website, The Organization included descriptions for these i drugs. Many of these descriptions included information regarding the Organization?s chemical expertise in (1) creating new drugs; and (2) bypassing China?s controlled substance list by creating near-identical analogues of substances that are otherwise illegal under Chinese law: 4-CDC is a kind of legal analogue of 4-CMC. It?s our new products, we don?t offer its chemical structure and other information about it because keeping the business secret. BD-EBDP . was developed in 19603 as one of stimulant agents. BK-EBDP for sale has become a quality replacement of Ethylone and Methylone. Numerous trials, tests and researches prove that the drug evokes reactions identical to results produced by ethylone. Among them there are desired effects and those that should better be avoided. MPHP Chemically, MPHP is better known as It is a close homologue of pyrovalerone (Centroton, 4-Methyl?B?keto-prolintane, ThymergiX, O-237l), differeing only in that it has been chain-lengthened. As its pyrrolidinyl, ketone and aryl groups remain in place, it retains pyrovalerone?s stimulant function. 2-NMC Those, who buy 2NMC must know that its action method'is really closely related to all the cathinones. The compound encourages the discharge of dopamine, yet inhibits the re?uptake of three elements: epinephrine, serotonin, norepinephrine in the brain, affecting the overall centralnervous system of a user. The chemical agent crosses almost all other membranes and successfully interacts with monoamine transporters. is known as 4?Chloroethcathinone or a relatively new replacement of 4? CMC, and an analogue of 4-MMC. 53 Case: Doc #2 1 Filed: 08/17/18 54 of 83. PageID 54 propan?l-one is its full chemical name. online is available on the market in form of and it acts like a stimulants, thus has identical effects, both expected and some of the adverse ones. U-48800 is a kind of legal analogue of 111. On or about July 30, 2018, the ZHENG Drug Trafficking Organization maintained mirror websites of in over 35 languages, ranging from Japanese to Creole. 1 112. On August 10, 2018, the ZHENG Drug Trafficking Organization emailed undercover law enforcement using its email account, sales@globalrc.net. The Organization informed undercover law enforcement that, it had created the counterfeit Adderall adulterated . with Dibutylone, a form of bath salts. 113. Throughout the conspiracy, the ZHENG Drug Trafficking Organization utilized Money Transfer Companies 1 and 2 to receive fundsifrom drug trafficking. Within the last few years, FUJING ZHENG and GUANGHUA ZHENG alone received over $1 million through money service business transfers directly to them through these companies. This amount does not include other accounts at Money Transfer Companies 1 and 2, other financial and digital currency services, and other co?conspirators used to obtain the drug proceeds. 114. From in Or about August 2017 shortly after law enforcement stopped Bin Wang?s operation to the ?ling of this indictment, the ZHENG Drug Trafficking Organization attempted to use other companies such as Shipping Company 1, a company whose name is known to the Grand Jury, to illegally import narcotics into the United States and re-ship them throughout the country while avoiding detection. In early 2018 alone, Shipping Company 1 was the return addressee and responsible for the postage on over 200 packages containing controlled substances and/ or controlled substance analogues. Furthermore, around this time, the ZHENG 54 Case: Doc #2 1 Filed: 08/17/18 55 of 83. PageID 55 Drug Traf?cking Organization used the services of Shanghai, Freight Forwarder 1, a company whose name is known to the Grand Jury, to import controlled substances and controlled substance analogues into the United States in coordination with the Organization and Shipping Company 1. A11 in violation of Title 21, United States Code, Section?846. ENHANCEMENT UNDER TITLE 2L UNITED STATES CODE, SECTIONS 841(b)(1)(Al and (Death Resulting from Use of?Controlled Substance Analogue) 115. i The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 1 16., On or about March 21, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG and GUANGHUA ZHENG did manufacture and distribute a mixture and substance containing a detectable amount of acetyl fentanyl, a Schedule 1 controlled substance analogue, which resulted in the death of TR, an individual whose identity is known to the Grand Jury, who ingested Defendants? acetyl fentanyl and fatally overdosed. 117. On or about March 28, 2015,- in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG and GUANGHUAJ ZHENG did manufacture and distribute amixture and substance containing a detectable amount of acetyl fentany1,.a Schedule 1 controlled substance analogue, which resulted in the death of CD, an individual whose identity is known to the Grand Jury, who ingested Defendants? acetyl fentanyl and fatally oVerdosed. 55 Case: Doc #2 1 Filed: 08/17/18 56 of 83. PageID 56 118. The deaths of TR. and CD. resulted from FUJING ZHENG and GUANGHUA manufacture and distribution of the mixtures and substances containing a detectable amount of acetyl fentanyl, as alleged in Count 1. A11 in Violation of the enhanced penalty provisions of Title 21, United States Code, Sections 841(b)(1)(A) and COUNT 2 (Conspiracy to Import Controlled Substances and Controlled Substance Analogues into the United States Resulting in Death, 21 U.S.C. 952(a), 960(a)(1), and all in violation of21 U.S.C. 963) The Grand Jury further charges: 119. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 120. From on or about January 1, 2008 to the Present, the exact dates unknown to the . Grand Jury, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON JIN, aka MR. JTN, aka GORDON ZHENG, aka JINXINXIN, aka ZHENG, aka DENG GUANGHUA ZHENG, aka GUANG HUA Guangfu Guifeng Songyan Longbao Qinghua Y., aka Jason Yen; Leroy Global United Biotechnology; Global United Holdings; Global Biotech, Inc; Global Holdings, Inc. Top Lab Global GOlden Chemicals; Cambridge Chemicals; Wonda Science; OneChem; ChemCloud; Daniel Lab; and Shanghai Pharmaceutical Company 1 (named but not indicted herein), Bin Wang (indictedin case number _1 and others known and unknown to the Grand Jury, did knowingly and intentionally combine, conspire, confederate, and agree with each other to import into the United States from any place outside thereof mixtures and substances containing a detectable amount of controlled substance analogues, as defined in?21 U.S.C. 802(32), intended for human consumption, as provided in 56 Case: Doc #2 1 Filed: 08/17/18 57 of 83. PageID 57 21 U.S.C. 813, and controlled substances listed in Count 1 of this indictment, which is re? alleged and incorporated by reference in this count, as though fully set forth herein. All in violation of Title 21, United States Code, Sections 802(32), 813, 952(a), 960(a)(1), and 963. ENHANCEMENT UNDER TITLE 21, UNITED STATES CODE, SECTIONS 960( 1) and (Death Resulting from Use of Controlled Substance Analogue) 121. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. - 122. On or about March 21, 2015, Defendants FUJIN ZHENG and GUANGHUA i ZHENG did import into the United States from the People?s Republic of China and elsewhere a mixture and substance containing a detectable amount of acetyl fentanyl, a Schedule I controlled substance analogue, which resulted in the death of TR, an individual whose identity is known to the Grand Jury, who ingested Defendants? acetyl fentanyl and fatally overdosed. 123. On or about March 28, 2015, Defendants ING ZHENG and GUANGHUA ZHENG did import into the United States from the People?s Republic of China and elsewhere a mixture and substance containing a detectable amount. Of acetyl fentanyl, a Schedule I controlled substance analogue, which resulted?in the death of CD, an individual whose identity is known to the Grand Jury, who ingested Defendants? acetyl fentanyl and fatally overdosed. 124. The deaths of TR. and CD. resulted from FUHN ZHENG and GUANGHUA importation into the United States of the mixtures and substances containing a detectable amount of acetyl fentanyl, as alleged in Count 2. All in Violation of the enhanced penalty provisions of Title 21, United States Code, Sections 960(b)(1) and 57' Case: Doc #2 1 Filed: 08/17/18 58 of 83. PageID 58 COUNT 3 (Conspiracy to Manufacture and Distribute Controlled Substances and Controlled Substance Analogues for Purpose of Unlawful Importation and Resulting in Death, 21 U.S.C. 959(a), 960(a)(3), and all in violation of21 U.S.C. 963) The Grand Jury further charges: 125. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count,as though fully set forth herein. 126. From?on or about January 1, 2008 to the Present, the exact dates unknown to the 1 Grand Jury, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON IN, aka MR. JIN, aka GORDON ZHENG, aka JINXINXIN, aka FU ZHENG, aka DENG GUANGHUA ZHENG, aka GUANG HUA Guangfu Guifeng Songyan Longbao Qinghua Y., aka Jason Yen; X. Leroy Global United Biotechnology; Global United Holdings; Global Biotech, Inc. Global Holdings, Inc.; Top Lab GlObal Golden Chemicals; Cambridge Chemicals; Wonda Science; OneChem; ChemCloud; Daniel Lab; and Shanghai Pharmaceutical Company 1 (named but not indicted herein), Bin Wang (indicted in case number and others known and unknown to the Grand Jury, did knowingly and intentionally combine, conspire, confederate, and agree to manufacture and distribute mixtures and substances containing a detectable amount of controlled substance analogues, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, and controlled substances listed in Count 1 of this indictment, which is re-alleged and incorporated by reference in this count, as though fully set forth herein, intending, knowing, and having reasonable cause to believe that these controlled substances and controlled substance analogues will be unlawfully imported into the United States. I 58 Case: Doc #2 1 Filed: 08/17/18 59 of 83. PageID 59 All in Violation of Title 21, United States Code, Sections 802(32), 813, 959(a), 960(a)(3), and 963. ENHANCEMENT UNDER TITLE 21. UNITED STATES CODE, SECTIONS 960(b)(1) and (MB) (Death Resulting from Use of Controlled Substance Analogue) 127. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 128. On or about March 21, 2015, in the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG and GUANGHUA ZHENG did manufacture and distribute a mixture and substance containing a detectable amount of acetyl fentanyl, a Schedule I controlled substance analogue, intending and knowing that it will be imported into the United States, which resulted in the death of TR, an individual whose identity is known to the Grand Jury, who ingested Defendants? acetyl fentanyl and fatally overdosed. 129. On or about March 28, 2015, in the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG and GUANGHUA ZHENG did manufacture and distribute a mixture and substance containing a detectable amount of acetyl fentanyl, a Schedule I controlled substance analogue, intending and knowing that it will be imported into the United States, which resulted in the death? of CD, an individual whose identity is known to the Grand Jury, who I ingested Defendants? acetyl fentanyl and fatally overdosed. 130. The deaths of TR. and CD. resulted from FUJING and GUANGHUA manufacture and distribution of the mixtures and substances containing a detectable amount of acetyl fentanyl, intending and knowing that they will be unlawfully imported into the United States, as alleged in Count 3. 59 Case: Doc #2 1 Filed: 08/17/18 60 of 83. PageID 60 All in violation of the enhanced penalty provisions of Title 21, United States Code, Sections 960(b)(1) and COUNT 4 (Continuing Criminal Enterprise, in violation of 21 U.S.C. 848(a) and The Grand Jury further charges: 131. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 1 132. From on: or'aboutJanuary l, 2008 to the Present, the exact dates unknown to the Grand Jury, in the Northern District of Ohio, Eastern Division, the People?sRepublic of China, and elsewhere, Defendants ING ZHENG, aka GORDON IN, aka lVfR. JIN, aka GORDON ZHENG, aka aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally engage in a Continuing Criminal Enterprise in that they violated Title 21, United States Code, Sections, 813, 84l(a)(l), 846, 952(a), 959(a), 960, and 963, including, but not limited to, the violations alleged in Counts 1?3 and 5?19 of this Indictment, which are incorporated herein by reference. The above-described violations were, and are, part of a continuing series of violations of those statutes. 133. These continuing series of violations were undertaken by FUJIN ZHENG and GUANGHUA ZHENG in concert with at least ?ve other persons with respect to Whom UJ IN ZHENG and GUANGHUA ZHENG both Occupied a position of organizer, a supervisory position, and, any other position of management, including, but not limited to, the following individuals: Guangfu Z., Guifeng C., Songyan ., Longbao Z., Qinghua Y., and X. 134. From this continuing series of violations, UJ ZHENG and GUANGHUA ZHANG obtained substantial income and resources. 60 Case: Doc #2 1 Filed: 08/17/18 61 of 83. PageID 61 All in violation of Title 21, United States Code, Sections 848(a) and COUNT 5 (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 135. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 136. On or about March 12, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJTN ZHENG, aka GORDON 1N, aka MR. 1N, aka GORDON ZHENG, aka JINXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl entanyl, a Schedule 1 controlled substance analogue, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 6 (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 137. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 138. On or about March 21, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON 61 Case: Doc #2 1 Filed: 08/17/18 62 0f 83. PageID 62 IN, aka MR. IN, aka GORDON ZHENG, aka aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown . to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl Fentanyl, a Schedule I controlled substance analogue, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. I COUNT 7 (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 139. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 140. 5 On or about March 28, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON JTN, aka JIN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl Fentanyl, a Schedule 1 controlled substance analogue, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in Violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. 62 Case: Doc #2 1 Filed: 08/17/18 63 of 83. PageID 63 COUNT 8 . (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: i 141. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 142. On or about April 2, 2015 in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJ ING ZHENG, aka GORDON aka MR. JTN, aka GORDON ZHENG, aka INXWXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others knowniand unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl Fentanyl, a Schedule 1 controlled substance analogue, as defined in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 9 (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 143. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 144. On or about April 3 and Continuing to on or about April 16, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJ IN ZHENG, aka GORDON IN, aka MR. IN, aka GORDON ZHENG, aka 63 Case: Doc #2 1 Filed: 08/17/18 64 of 83. PageID 64 aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl Fentanyl, a Schedule 51 controlled substance analogue, as defined in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in violation of Title 21 United States Code, Sections 959 and 960(a)l(3), and Title 18, United'States Code, Section 2.. i COUNT 10 (Manufacture and Distribution of Acetyl Fentanyl for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 145. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 146. On or about June 15, 2015, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants ZHENG, aka GORDON JIN, aka JTN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Acetyl Fentanyl, a Schedule I controlled substance analogue, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending and knowing that such substance will be unlawfully imported into the United States, in Violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. 64 Case: Doc #2 1 Filed: 08/17/18 65 of 83. PageID 65 COUNT 11 (Manufacture and Distribution of U-47700 for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: . i 147. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein; 148. On or about December 20, 2016, in the Northern District Of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON 1N, aka MR. JIN, aka GORDON ZHENG, aka JINXINXTN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixturezand substance containing a detectable amount of U-47700, a Schedule 1 controlled I substance, intending, knowing, and having reasonable cause. to believe that such substance will be unlawfully imported into the United States, in violation of Title 21,? United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 12 (Manufacture and Distribution of for Purpose of Unlawful Importation, in Violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 149. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 150. On or about February 15, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON I IN, aka JTN, aka GORDON ZHENG, aka aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA others known 65 Case: Doc 1 Filed: 08/17/181 66 of 83. PageID 66 and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of a Schedule 1 controlled substance analogue, as de?ned in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending, knowing, and having reasonable cause ,to believe that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959'and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 13 (Manufacture and Distribution of Dibutylone for-Purpose of Unlawful Importation, in Violation of2l U.S.C. 959 and 960(a)(l), and 18 U.S.C. 2) The Grand Jury further charges: 151. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 152. On or about March 31, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJIN ZHENG, aka GORDON JTN, aka MR. JIN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JING ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Dibutylone, a Schedule 1 controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be unlawfully imported into the United States, in Violation of Title 21, United States Code, Sections? 959 and Title 18, United States Code, Section 2. 66 Case: Doc #2 1 Filed: 08/17/18 67 of 83. PageID 67 COUNT 14 (Manufacture and Distribution of ADB-FUBINACA for Purpose of Unlanul Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 153. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. I 154. On or about June 5, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON JIN, aka MR. JIN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown, to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of ADB -FUBINACA, a Schedule I controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. i (Manufacture and Distribution of for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and18 U.S.C. 2) The Grand Jury further charges: 155. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 156. From on or July 6, 2017, and continuing to on or about July 21, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON JIN, aka MR. m, aka GORDON ZHENG, aka INXINXIN, aka FU ING ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka 67 Case: Doc #2 1 Filed: 08/17/18 68 of 83. PageID 68 GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of ADB -FUBINACA, a Schedule I controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be unlanully imported into the United States, in violation of Title 21, United States Code, Sections 95 9 and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 16 (Manufacture and Distribution of for Purpose of Unlawful Importation, in violation of2l U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 157. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 158. On. or about August 2, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJING ZHENG, aka GORDON JIN, aka MR. JTN, aka GORDON JTNXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of a Schedule 1 controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Seetions 959 and 960(a)(1), and Title 18, United States Code, Section 2., 68 Case: Doc #2 1 Filed: 08/17/18 69 of 83. PageID 69 COUNT 17 (Manufacture and Distribution of for Purpose of Unlawful Importation, in violation-of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 159. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 160. On or about April 12, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJIN ZHENG, aka GORDON IN, aka MR. JIN, aka GORDON ZHENG, aka JINXINXIN, aka JING ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of 4-CL-PVP, a Schedule 1 controlled substance analogue, as defined in 21 U.S.C. 802(32), intended for human consumption, as provided in 21 U.S.C. 813, intending, knowing, and having reasonable cause to believe that such substance will be unlawfully imported into the United States, in Violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. COUNT 18 (Manufacture and Distribution of Dibutylone for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) The Grand Jury further charges: 161. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference inthis count, as though fully set forth herein. . 162. On or about June 6, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON JIN, aka MR. JIN, aka GORDON ZHENG, aka JINXINXIN, aka JING ZHENG, aka DENG 69 Case: DOC 1 Filed: 08/17/18 70 of 83. PageID 7O GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Dibutylone, a Schedule I controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(3), and Title 18, United States Code, Section 2. i COUNT l9 1 (Manufacture and Distribution of Dibutylone for Purpose of Unlawful Importation, in violation of21 U.S.C. 959 and 960(a)(3), and 18 U.S.C. 2) i The Grand Jury further charges: 1 163. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein 164. On or about June 14, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON JIN, aka MR. JTN, aka GORDON ZHENG, aka JINXINXIN, aka FU ITN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the GrandiJury, did knowingly and intentionally manufacture and distribute a mixture and substance containing a detectable amount of Dibutylone, a Schedule 1 controlled substance, intending, knowing, and having reasonable cause to believe that such substance will be" unlawfully imported into the United States, in violation of Title 21, United States Code, Sections 959 and 960(a)(1), and Title 18, United States Code, Section 2. 70 Case: Doc #2 1 Filed: 08/17/18 71 of 83. PageID 71 COUNT 20 (Creating and Distributing a Counterfeit Substance, in violation of2l U.S.C. 841(a)(2), and 18 U.S.C. 2) 165. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 166. On or about August 10, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJTN ZHENG, aka GORDON JIN, aka JIN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JTN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally create and distribute a counterfeit substance, to wit: Defendants created and distributed. the controlled substance Dibutylone in the form of the pharmaceutical pill Adderall that, without authorization, bore the trademark, trade name, or other identifying mark, imprint, number, or device, or any likeness thereof, of a manufacturer, distributor, or dispenser other than the person or persons who in fact manufactured, distributed, or dispensed such substance and which thereby falsely purported or represented to be the product of, or to have been distributed by, such other manufacturer, distributor, or dispenser, all in violation of21 U.S.C. 84l(a)(2), and 18 U.S.C. 2. COUNT 21 (Knowing and Intentional Adulteration of Drugs, in violation of21 U.S.C. 331(a), 351(d), and 18 U.S.C. 2) The Grand Jury further charges: 167. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 168. On or about August 10, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON 71 Case: Doc #2 1 Filed: 08/17/18 72 of 83. PageID #1 72 JIN, aka MR. aka GORDON ZHENG, aka aka FU JINGZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, with the intent to defraud or mislead, did cause the introduction and delivery for introduction into interstate commerce of an adulterated drug containing any substance that has been substituted wholly or in part, and such adulteration has a reasonable probability of causing serious adverse health consequences or death to humans and animals: to wit, Defendants caused the introduction and delivery for introduction into interstate commerce Adderall pills that were in fact adulterated with Dibutylone, commonly referred to as ?bath salts,? a substance known to cause serious adverse health consequences and deaths in humans, in Violation of Title. 21, United States Code, 331(a), 333(a)(2), 351(d), and Title 18, United States Code, 2. COUNT 22 (Distributing Controlled Substances by Means of the Internet, in violation of21 U.S.C. 84l(h), and The Grand Jury further chargesz? 169. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 170. From on or about January 1, 2008 to the Present,_the exact dates unknown to the Grand Jury, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON JTN, aka MR. JIN, aka GORDON ZHENG, aka INXINXIN, aka JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally deliver, distribute, and dispense a controlled substance by means of the internet: to wit, ZHENG and GUANGHUA ZHENG used their websites 72 Case: Doc #2 1 Filed: 08/17/18 73 of 83. PageID 73 and vendor accounts on EC21, TradeKey, China Quality Lighting, TradeIndia, and TradeLead, email, Skype, WhatsApp, WeChat, and other communication applications to distribute controlled substances over the internet tocustomers, in violation of Title 21, United States Code, Sections 841(h), and COUNTS 23?38 (Advertising Controlled Substances Sales by Means of the Internet, in violation of 21 U.S.C. The Grand Jury further charges: 171. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 172. On or about the following dates, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJING ZHENG, aka GORDON W, aka MR. JIN, aka GORDON ZHENG, aka JTNXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUAN HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly and intentionally use the internet and cause the internet to be used, to advertise the sale of and to offer to sell, distribute, and dispense, a controlled substance where such sale, distribution, or dispensing is not authorized by law, in violation of Title 21, United States Code, Section 843 23 April 8, 2009 24 April 11, 2014 25 December 18, 2014 26 March 2, 2015 27 July 1, 2015 73 Case: Doc #2 1 Filed: 08/17/18 74 of 83. PageID 74 28 October 6, 2015 29 October 22, 2015 Comment on ?Stay at Home Dad? Blog 30 November 7, 2015 31 February 23, 2016 Comment on ?Forensic Toxicologist? Blog 32 March 29, 2016 Comment on ?Forensic Toxicologist? Blog 33 December 1, 2017 34 May 18, 2018 35 June 27, 2018 . 36 July 15, 2018 37 July 27, 2018 3 8 August 14, 2018 . (Money Laundering Conspiracy, in Violation of 18 U.S.C. 1956(h)) The Grand Jury further charges: 173. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully set forth herein. 174. From on or about January 1, 2008 to the Present, the exact dates unknown to the Grand Jury, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elseyvhere, Defendants FUJIN ZHENG, aka GORDON 1N, aka MR. JIN, aka GORDON ZHENG, aka JINXINXIN, aka FU JIN ZHENG, aka DENG GUANGHUA ZHENG, aka GUANG HUA ZHENG, Guangfu Guifeng C. Songyan Longbao Qinghua Y., aka Jason Yen; Leroy Global United Biotechnology; Global United Holdings; Global Biotech, Inc.; Global Holdings, Inc. Top Lab Global Golden Chemicals; Cambridge 74 Case: Doc #2 1 Filed: 08/17/18 75 of 83. PageID 75 Chemicals; Wonda Science; OneChem; ChemC-loud; Daniel Lab; and Shanghai Pharmaceutical Company 1 (named but not indicted herein), Bin Wang (indicted in case number and others known and unknown to the Grand Jury, did knowingly and intentionally combine, conspire, confederate, and agree to: a. Conduct and attempt to conduct ?nancial transactions affecting interstate and foreign commerce, which transactions involved the proceeds of specified unlawful activity, towit: illegal controlled substance and controlled substance analogue manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, conspiracy to commit the same, and any act or acts constituting a continuing criminal enterprise, in violation of Title 21, United States Code, Sections 802(32), 813, 84l(a)(1), 846, 848, 952, 959, 960, and 963, and knowing that the transactions were designed in whole and in part to conceal and disguise the location, source, ownership and control of the proceeds of said speci?ed unlawful activity, and while conducting and attempting to conduct such ?nancial transactions, knew that the property involved in the ?nancial transaction represented the proceeds of some form of unlawful activity, all in violation of Title 18, United States Code, Section and b. Transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, knowing that the monetary instrument and funds involved in the transportation, transmission and transfer represented the proceeds of some form of unlawful activity and knowing that such transportation, transmission and transfer was designed in whole and in part to conceal and 75 Case: Doc #2 1 Filed: 08/17/18 76 of 83. PageID 76 175. Organization: a. b. disguise the nature, location, source, ownership and control of the proceeds of the speci?ed unlawful activity, to wit: illegal controlled substance and controlled substance. analogue manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, conspiracy to commit the same, and any act or acts constituting a continuing criminal enterprise, in Violation of Title 21, United States Code, Sections 802(32), 813, 841(a)(1), 846, 848, 952, 959, 960, and 963,,a11 in Violation of Title 18, United States Code, Section . Transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, with the intent to promote the carrying on of specified unlawful activity, to wit: illegal controlled substance and controlled substance analogue manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, conspiracy to commit the same, and any act or acts constituting a continuing criminal enterprise, in Violation of Title 21, United States Code, Sections 802(32), 813, 84l(a)(1), 846, 848, 952, 959, 960, and 963, all in Violation of Title 18,? United States Code, Section l956(a)(2)(A). It was a part and object of the conspiracy that the ZHENG Drug Traf?cking Utilized digital currency (such as Bitcoin) to conceal and disguise the nature, location, source, ownership and control of the drug proceeds; Maintained and controlled digital currency addresses that were used by drug 76 Case: Doc #2 1 Filed: 08/17/18, 77 of 83. iPagelD 77 traf?ckers and co?conspirators to make payments for narcotics; c. Utilized digital currency exchanges to convert drug traf?cking proceeds into of?cial ?at currency; i d. Misrepresented fund transfers and directed customers to misrepresent fund transfers in order to conceal and disguise the nature, location, source, ownership and control of the drug proceeds; i e. Structured transactions to avoid ?nancial institution reporting and recordkeeping requirements; f. Transmitted drug proceeds into and out of bank accounts in Hong Kong and elsewhere, with the purpose of obfuscating the nature of the proceeds; and g. Bypassed Chinese restrictions and reporting requirements on ?at currency entering and leaving the People?s Republic of China through the use of co- conspirators who received drug payments through money transmitting businesses on behalf of the FUJIN ZHENG, GUANGHUA ZHENG, and other?members of the conspiracy. These co?conspirators include, Guangfu Z., Guifeng C., Songyan ., Longbao Z, and others. All in violation of Title 18, United States Code, Section 1956(h). (International Promotional Money Laundering, in Violation of 18 U.S.C. 195 and 2) The Grand Jury further charges: 176. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 177. On or about July 6, 2017, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, and elsewhere, Defendants FUJIN ZHENG, aka 77 Case: Doc#: 1 Filed: 08/17/18 78 of 83. PageID#: 78 GORDON IN, aka MR. JIN, aka GORDON ZHENG, aka JINXINXTN, aka FU JTN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, with the intent to promote the carrying on of speci?ed unlawful activity, to Wit: illegal controlled substance manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, and any act or acts constituting a continuing criminal enterprise, in Violation of Title '21, United States Code, Sections 802(32), 813, 841(a)(1), 846, 848, 952, 959, 960, and 963, all in Violation of Title 18, United States Code, Section l956(a)(2)(A) and 2. COUNT 41 . (International Promotional Money Laundering, in Violation of 18 U.S.C. 195 and 2) The Grand Jury further charges: 178. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 179. On or about March 23, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, and elsewhere, Defendants ZHENG, aka GORDON JIN, aka MR. aka GORDON ZHENG, aka aka HN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, with the intent to promote the carrying on of speci?ed unlawful activity, to wit: illegal controlled substance manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, and 78 Case: Doc #2 1 Filed: 08/17/18 79 of 83. PageID 79 any act or acts constituting a continuing criminal enterprise, in Violation of Title 21, United . States Code, Sections 802(32), 813, 841(a)(1), 846, 848, 952, 959, 960, and 963, all in Violation of Title 18, United States Code, Section 1956(a)(2)(A) and 2. . 9w (International Promotional Money Laundering, in Violation of 18 U.S.C. 195 and 2) The Grand Juryfurther charges: 180. The factual allegations in paragraphs 1 through 114 are re?alleged and incorporated by reference in this count, as though fully set forth herein. 181. On or about May 18, 2018, in. the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants FUJING ZHENG, aka GORDON JIN, aka MR. JTN, aka GORDON ZHENG, aka FU JTN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, Iwith the intent to promote the carrying on of speci?ed unlawful activity, to wit: illegal controlled substance manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, and any act or acts constituting a continuing criminal enterprise, in Violation of Title 21, United States Code, Sections 802(32), 813, 841(a)(1), 846, 848, 952, 959, 960, and 963, all in Violation of Title 18, United States Code, Section and 2. 79 Case: Doc#: 1 Filed: 08/17/18 80 of 83. Pagel?D 8O COUNT 43 (International Promotional Money Laundering, in violation of 18 U.S.C. 1956(a)(2)(A) and 2) The Grand Jury further charges: 182. The factual allegations in paragraphs 1 through 114 are re-alleged and incorporated by reference in this count, as though fully Set forth herein. 183. On or about June 28, 2018, in the Northern District of Ohio, Eastern Division, the People?s Republic of China, and elsewhere, Defendants UJ ING ZHENG, aka GORDON JIN, aka MR. JN, aka GORDON ZHENG, aka JINXINXIN, aka FU JIN ZHENG, aka DENG GAO, and GUANGHUA ZHENG, aka GUANG HUA ZHENG, and others known and unknown to the Grand Jury, did knowingly transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through a place outside the United States, with the intent to promote the carrying On of specified unlawful activity, to wit: illegal controlled substance manufacture, distribution, importation, manufacture and distribution for purpose of unlawful importation, and any act or acts constituting a continuing criminal enterprise, in violation of Title 21, United States Code, Sections 802(32), 813, 841(a)(1), 846, 848, 952, 959, 960,_and 963, all in Violation of Title 18, United States Code, Section l956(a)(2)(AJ and 2. FORFEITURE .The Grand Jury further charges: 184. The allegations contained in Counts 1?20 and Counts 22?38 of this Indictment are hereby re?alleged and incorporated by reference as if fully set forth herein for the purpose of alleging forfeiture pursuant to the provisions of 21 U.S.C. 853 and 21 U.S.C. 970. As a result of these offenses, FUJING ZHENG (aka GORDON JIN, aka MR. JIN, aka GORDON ZHENG, aka INXINXIN, aka FU JIN ZHENG, aka DENG GAO) and GUANGHUA 8O Case: Doc #2 1 Filed: 08/17/18 81 of 83. PageID 81 ZHENG (aka GUANG HUA ZHENG), the defendants herein, shall forfeit to the United States any and all property constituting, or derived from, any proceeds the defendants obtained, directly or indirectly, as the result of such offenses; and, any and all of the defendant?s property used or intended to be used, in any manner or part, to commit or to facilitate the commission of such offenses; including, but not limited to, the following: a. d. All Contents of China Merchants Bank Hong Kong Branch, Account number: Bene?ciary Name: ZHENG GUANGHUA, Swift Code: Bank Address: Bank of America Tower, 12 Harcourt Road, Central, Hong Kong. All Contents of China Merchants Bank Hong Kong Branch, Account number: Bene?ciary Name: ZHENG UJTNG, Swift Code: Bank Address: Bank of America Tower, 12 Harcourt Road, Central, Hong Kong. All contents of account described as follows: account in the (full) name of GUANGHUA Username: Account Type: Individual, E-mail: zhengfujing@[redacted] .cn, Status: Veri?ed, .Phone 1 75 ID Address: Room No. XX, Huochezhan Rd., Lane 118, iading, Shanghai, China 201802, Nationality: China. The deposit address associated with this user is as follows: BITCOIN (date Created: The'domain names globalrcnet, toplabrc.com, goldenrc.com, ar.plglobalrc.net, ar.ruglobalrc.net, fj.globalrc.net, af.plglobalrc.net, ba.ruglobalrc.net, 81 Case: Doc #2 1 Filed: 08/17/18 82 of 83. PagelD 82 ht.plglobalrc.net, sl.ruglobalrc.net, pt.plglobalrc.net, ruglobalrc.net, nl.plglobalrc.net, id_ruglobalrc.net, pk.plglobalrc.net, tr.plglobalrc.net, lt.ruglobalrc.net, gr.ruglobalrc.net, sria.ruglobalrc.net, otq.ruglobalrc.net, ua.plglobalrc.net, vko.ruglobalrc.net, mww.plglobalrc.net, dk.plglobalrc.net, ?.ruglobalrc.net, Vn.ruglobalrc.net, fr.plglobalrc.net, hu.ruglobalrc.net, it.ruglobalrc.net, plglobalrcnet, . yua.plglobalrc.net, mt.ruglobalrc.net, il.ruglobalrc.net, ja.plglobalrc.net, ee.plglobalrc.net, tlh.ruglobalrc.net, my.plglobalrc.net, se.ruglobalrc.net, and ro.plglobalrc.net. 185. The allegations contained in Counts 39-43 of this Indictment are hereby re- alleged and incorporated by reference as if fully set forth herein for the purpose of alleging forfeiture pursuant to the provisions of 18 U.S.C. 982(a)(1). As a result of these offenses, FUJING ZHENG (aka GORDON JIN, aka MR. JIN, aka GORDON ZHENG, aka JINXINXIN, aka FU ING ZHENG, aka DENG GAO) and GUANGHUA ZHENG (aka GUANG HUA ZHENG), the defendants herein, shall forfeit to the United States all property, real and personal, involved in such offenses, and all property traceable to such property; including, but not limited to, the following: a. All Contents of China Merchants Bank Hong Kong Branch, Account number: Bene?ciaryName: ZHENG GUANGHUA, Swift Code: Bank Address: Bank of America Tower, 12 Harcourt Road, Central, Hong Kong. b. All Contents of China Merchants Bank Hong Kong Branch, Account number: Bene?ciary Name: ZHENG FUJIN G, Swift Code: Bank Address: 2l/F, Bank of America Tower, 12 Harcourt Road, Central, Hong Kong. 82 Case: Doc~#: 1 Filed: 08/17/18 83 of 83. PagelD 83 c. A All contents of account described as follows: account in the (full) name of GUANGHUA Username: Account Type: Individual, E?mail: zhengfujing@[redacted] .cn, Status: Veri?ed, Phone ID: Address: Room No. XX, Huochezhan Rd, Lane 118, Jiading, Shanghai, China 201802, Nationality: China. The deposit address associated with this user is as follows: BITCOIN: (date created: d. The domain names globalrcnet, toplabrccom, goldenrccom, ar.plglobalrc.net, ar.ruglobalrc.net, ?globalrcnet, af.plglobalrc.net, ba.ruglobalrc.net, ht.plglobalrc.net, sl.ruglobalrc.net, pt.p1globalrc.net, ruglobalrcnet, nl.plglobalrc.net, id_ruglobalrc.net, pk.plglobalrc.net, tr.p1globalrc.net, 1t.ruglobalrc.net, gr.ruglobalrc.net, sriaQruglobalrcnet, otq.ruglobalrc.net, ua.plglobalrc.net,_ ko.ruglobalrc.net, -mww.p1globalrc.net, dk.plglobalrc.net, ?.ruglobalrc.net,? vn.ruglobalrc.net, fr.plglobalrc.net, plglobalrcnet, yua.plglobalrc.net, mt.ruglobalrc.net, il.ruglobalrc.net, japlglobalrcnet, ee.plglobalrc.net, tlh.rugloba1rc.net, my.plglobalrc.net, seruglobalrcnet, and ro.plglobalrc.net. Original document - Signatures on ?le with the Clerk of Courts, pursuant to the E?Government Act of 2002. 83