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E-FILED

Thursday, 03 October, 2019 12:07:39 PM
Clerk, U.S. District Court, ILCD

IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF ILLINOIS
AT PEORIA
UNITED STATES OF AMERICA,

)
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Plaintiff,
v.
EUGENE HAYWOOD, et al.,
Defendants.

Case No. 18-10036

GOVERNMENT’S SANTIAGO PROFFER

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TABLE OF CONTENTS
I.

INTRODUCTION………………………………………………………….

4

II.

GOVERNING LAW……………………………………………………….

5

A. Existence of and Membership in the Conspiracy…………………..

5

B. “In Furtherance of” the Conspiracy………………………………….

10

C. Alternative Bases for Admissibility of Statements…………………

12

1. A Defendant’s Own Statements…………………………………..

13

2. Non-Hearsay Statements………………………………………….

13

3. Statements Against Penal Interest………………………………..

14

SUMMARY OF THE CASE………………………………………………

16

A. The BOMB SQUAD……………………………………………………

17

B. The Investigation ……………………………………………………...

22

1. Cooperators………………………………………………….

22

2. Facebook and YouTube…………………………………….

24

3. Execution of Residential Search Warrants……………….

25

4. Overview of the Evidence………………………………….

26

STATEMENT OF FACTS/EVIDENTIARY SUPPORT OF
THE CHARGED CONSPIRACY…………………………………………

30

A. Cooperating Gang Member and Cooperating
Witness Testimony…………………………………………………….

30

III.

IV.

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B. Consensually Recorded Conversations……………………………...

46

C. Facebook Posts and Facebook Messenger Conversations…………

56

D. The Acts of Violence…………………………………………………...

69

V.

COCONSPIRATOR STATEMENTS……………………………………

109

VI.

CONCLUSION……………………………………………………………... 112

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The United States of America, by its undersigned counsel, hereby submits
the following proffer of evidence as to the admission at trial of coconspirator
statements pursuant to FED. R. EVID. 104(a) and 801(d)(2)(E) and United States v.
Santiago, 582 F.2d 1128 (7th Cir. 1978), against the defendants in the abovecaptioned cause.
I.

INTRODUCTION
In this submission, the government describes the law governing

coconspirator statements, outlines some of its evidence establishing the charged
conspiracy, and sets forth some of the coconspirator statements for which a pretrial
ruling by the Court is requested, in accordance with Santiago, 582 F.2d at 1130-31,
and established practice in this Circuit. See United States v. Alviar, 573 F.3d 526, 540
(7th Cir. 2009); United States v. Harris, 585 F.3d 394, 398, 400 (7th Cir. 2009).
This submission does not detail all of the government’s evidence that would
go to show the existence of the racketeering conspiracy or all of the coconspirator
statements that were made in furtherance of the racketeering. Rather, this
submission highlights for the Court certain evidence sufficient to establish the
existence of the racketeering conspiracy and the participation of the
coconspirators. As a result, this submission does not list all of the government’s
evidence and witnesses, nor does it provide all of the evidence that will be
presented by identified witnesses. Finally, by presenting statements attributed to
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particular witnesses, the government is not committing to call each of the
witnesses for each of the statements attributed.
II.

GOVERNING LAW

Federal Rule of Evidence 801(d)(2)(E) provides that a “statement” is not
hearsay if it “is offered against a party” and is “a statement by a coconspirator of
a party during the course and in furtherance of the conspiracy.” Admission of such
coconspirator statements against a defendant is proper where the government
establishes by a preponderance of the evidence that: (1) a conspiracy existed; (2)
the defendant and the declarant were members of the conspiracy; and (3) the
statements were made during the course and in furtherance of the conspiracy.
United States v. Cruz-Rea, 626 F.3d 929, 937 (7th Cir. 2010). 1
A.

Existence of and Membership in the Conspiracy

In accord with United States v. Santiago, 582 F.2d 1128 (7th Cir. 1978), this
Court must determine whether statements by the defendants’ coconspirator will
be admissible at trial under Federal Rule of Evidence 801(d)(2)(E). In making this
determination, this Court must decide “if it is more likely than not that the
declarant and the defendant were members of a conspiracy when the hearsay

No Sixth Amendment confrontation issues arise by the use of a non-testifying coconspirator=s
statements, offered for their truth against a defendant because they are not testimonial. United
States v. Nicksion, 628 F.3d 368, 374 (7th Cir. 2010) (citing Davis v. Washington, 547 U.S. 813, 823-24
(2006) and Crawford v. Washington, 541 U.S. 36 (2004)); see also United States v. Hargrove, 508 F.3d
445, 448-49 (7th Cir. 2007) (coconspirator statements are neither hearsay nor testimonial).
1

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statement was made, and that the statement was in furtherance of the
conspiracy ….” Id. at 1143 (quoting United States v. Petrozziello, 548 F.2d 20, 23 (1st
Cir. 1977)); see also United States v. Hoover, 246 F.3d 1054, 1060 (7th Cir. 2001). If this
Court determines the statements are admissible, the jury may consider them for
any purpose. United States v. Thompson, 944 F.2d 1331, 1345 (7th Cir. 1991).
Under Santiago, the government must make a preliminary offer of evidence
to show: (1) a conspiracy existed; (2) the defendant and declarant were members
of the conspiracy; and (3) the statements sought to be admitted were made during
and in furtherance of the conspiracy. Santiago, 582 F.2d at 1134-35; see also, e.g.,
United States v. Alviar, 573 F.3d 526, 540 (7th Cir. 2009). According to Bourjaily v.
United States, 483 U.S. 171, 176-81 (1987), the court can consider the statements in
question (the statements to be admitted) to determine whether the three Santiago
criteria have been met.
Seventh Circuit cases construing Bourjaily have held that properly admitted
hearsay, including statements admitted under the coconspirator exception to the
hearsay rule (Fed. R. Evid.801(d)(2)(E)), may be used to prove what another person
did or said that may demonstrate their membership in the conspiracy. United States
v. Loscalzo, 18 F.3d 374, 383 (7th Cir. 1994) (“[W]hile only the defendant’s acts or
statements could be used to prove that defendant’s membership in a conspiracy,
evidence of that defendant’s acts or statements may be provided by the statements
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of co-conspirators.”); United States v. Martinez de Ortiz, 907 F.2d 629, 633 (7th Cir.
1990) (en banc).
While this Court may consider the proffered statements themselves as
evidence of both the existence of a conspiracy and the defendants’ participation in
it, United States v. Bourjaily, 483 U.S. 171, 178, 180 (1987); United States v. Harris, 585
F.3d 394, 398-99 (7th Cir. 2009), the contents of the proffered statements alone are
not sufficient to establish the existence of a conspiracy and a defendant’s
participation. There must also be some supporting evidence or facts corroborating
the existence of the conspiracy and a defendant’s participation. Harris, 585 F.3d at
398-99. The evidence showing the existence of a conspiracy and a defendant’s
membership in it may be either direct or circumstantial. See United States v. Johnson,
592 F.3d 749, 754-55 (7th Cir. 2010); United States v. Irorere, 228 F.3d 816, 823 (7th
Cir. 2000). 2
There is no requirement, under Rule 801(d)(2)(E), that the government

The coconspirator statement rule does not apply when a statement is not being offered for the
truth of the matter asserted. Accordingly, statements by coconspirators may be admitted against
a defendant, without establishing the Bourjaily factual predicates set forth above, when such
statements are offered to show, for instance, the existence, the illegality, or the nature or scope of
the charged conspiracy. See United States v. Guyton, 36 F.3d 655, 658 (7th Cir. 1994) (statement that
defendant was out of cocaine was not hearsay because it showed membership in a conspiracy);
United States v. Herrera-Medina, 853 F.2d 564, 565-66 (7th Cir. 1988) (addressing “war stories”
about the drug trade); United States v. Van Daal Wyk, 840 F.2d 494, 497-98 (7th Cir. 1988)
(statements had non-hearsay value to establish knowledge of and membership in conspiracy);
United States v. Tuchow, 768 F.2d 855, 867-69 (7th Cir. 1985) (pre-conspiracy statements admissible
to set scope of anticipated conspiracy).

2

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establish all elements of a conspiracy, such as a meeting of the minds and an overt
act. United States v. Coe, 718 F.2d 830, 835 (7th Cir. 1983); United States v. Gil, 604
F.2d 546, 548-50 (7th Cir. 1979). The government need only establish the existence
of a joint venture for an illegal purpose (or for a legal purpose using illegal means)
and participation in the joint venture by the defendant and the maker of the
statement at issue (as well as that the statement was in furtherance of the venture).
“[I]t makes no difference whether the declarant or any other ‘partner in crime’
could actually be tried, convicted and punished for the crime of conspiracy.” Gil,
604 F.2d at 549-550; see also Coe, 718 F.2d at 835.
While there is thus a distinction between conspiracy law and admissibility
under Rule 801(d)(2)(E), certain principles of general conspiracy law are relevant
to the Rule 801(d)(2)(E) inquiries. For instance, “[a] conspiracy may exist even if a
conspirator does not agree to commit or facilitate each and every part of the
substantive offense.” Salinas v. United States, 522 U.S. 52, 63 (1997); see also United
States v. Longstreet, 567 F.3d 911, 919 (7th Cir. 2009); United States v. Jones, 275 F.3d
648, 652 (7th Cir. 2001). The government need not prove that a defendant knew
each and every detail of the conspiracy or played more than a minor role in the
conspiracy. United States v. Curtis, 324 F.3d 501, 506 (7th Cir. 2003). Further, a
defendant joins a criminal conspiracy if he agrees with another person to one or
more of the common objectives of the conspiracy; it is immaterial whether the
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defendant knows, has met, or has agreed with every coconspirator. Longstreet, 567
F.3d at 919; Jones, 275 F.3d at 652.
A defendant (or other declarant) may be found to have participated in a
conspiracy even if he joined or terminated his relationship with other conspirators
at different times than another defendant or coconspirator. United States v. Noble,
754 F.2d 1324, 1329 (7th Cir. 1985); see also United States v. Handlin, 366 F.3d 584,
590 (7th Cir. 2004) (“it is irrelevant when the defendant joined the conspiracy so
long as he joined it at some point”). Under Rule 801(d)(2)(E), a coconspirator’s
statement is admissible against conspirators who join the conspiracy after the
statement is made. United States v. Sophie, 900 F.2d 1064, 1074 (7th Cir. 1990). A
coconspirator who has become inactive or less active in the conspiracy
nevertheless is liable for his coconspirators’ further statements unless he openly
disavows the conspiracy or reports it to the police. See United States v. Feldman, 825
F.2d 124, 129 (7th Cir. 1987).
The government is not required to prove the identity of the declarant; nor
must the declarant’s identity be confirmed in the statement itself. See United States
v. Bolivar, 532 F.3d 599, 604-05 (7th Cir. 2008). Rather, the government need only
prove (from the statement, the context and/or other evidence) that the declarant
was in fact a coconspirator. Id.

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B.

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“In Furtherance of” the Conspiracy

In determining whether a statement was made “in furtherance” of the
conspiracy, courts evaluate the statement in the context in which it was made and
look for a reasonable basis upon which to conclude that the statement furthered
the conspiracy. See Cruz-Rea, 626 F.3d at 937; United States v. Johnson, 200 F.3d 529,
533 (7th Cir. 2000). Under the reasonable basis standard, a statement may be
susceptible to alternative interpretations and still be “in furtherance” of the
conspiracy. Cruz-Rea, 626 F.3d at 937-38. The “coconspirator’s statement need not
have been made exclusively, or even primarily, to further the conspiracy” in order
to be admissible under the coconspirator exception. Id. at 937 (quotations and
citations omitted). That statements were made to a government cooperating
witness or undercover agent does not bar admission of statements otherwise “in
furtherance” of the conspiracy. United States v. Mahkimetas, 991 F.2d 379, 383 (7th
Cir. 1993); see also United States v. Ayala, 601 F.3d 256, 268 (4th Cir. 2010).
“Courts have found a wide range of statements to satisfy the ‘in furtherance’
requirement.” United States v. Cozzo, 2004 WL 1151630 *2-3 (N.D. Ill. 2004)
(collecting cases). In general, a statement that is “part of the information flow
between conspirators intended to help each perform his role” satisfies the “in
furtherance” requirement. United States v. Alviar, 573 F.3d 526, 545 (7th Cir. 2009)
(quotations and citations omitted). See also United States v. Gajo, 290 F.3d 922, 929
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(7th Cir. 2002). These include statements made:
•

to conduct or help to conduct the business of the scheme, United States
v. Cox, 923 F.2d 519, 527 (7th Cir. 1991); see also United States v. Johnson,
200
F.3d
529,
533
(7th
Cir.
2000); 3

•

to recruit potential coconspirators, Cruz-Rea, 626 F.3d at 937-38; United
States v. Haynes, 582 F.3d 686, 705 (7th Cir. 2009), abrogated on other
grounds by United States v. Vizcarra, 668 F.3d 516 (7th Cir. 2012);

•

to identify other members of the conspiracy and their roles, Alviar, 573
F.3d at 545;

•

to plan or to review a coconspirator’s exploits, United States v. Molt,
772 F.2d 366, 369 (7th Cir. 1985);

•

as an assurance that a coconspirator can be trusted to perform his role,
United States v. Sophie, 900 F.2d 1064, 1073-74 (7th Cir. 1990); see also
United States v. Bustamante, 493 F.3d 879, 890-91 (7th Cir. 2007);

•

to inform and update others about the current status of the conspiracy
or a conspiracy’s progress (including failures), United States v. Rea, 621
F.3d 595, 605 (7th Cir. 2010); Alviar, 573 F.3d at 545;

•

to control damage to an ongoing conspiracy, United States v. Johnson,
200 F.3d 529, 533 (7th Cir. 2000); United States v. Molinaro, 877 F.2d
1341, 1343-44 (7th Cir. 1989); United States v. Van Daal Wyk, 840 F.2d
494, 499 (7th Cir. 1988);

•

to conceal a conspiracy where ongoing concealment is a purpose of
the conspiracy, Gajo, 290 F.3d at 928-29; United States v. Kaden, 819 F.2d
813, 820 (7th Cir. 1987); see also United States v. Maloney, 71 F.3d 645,
659-60 (7th Cir. 1995);

Statements that prompt the listener to act in a manner that facilitates the carrying out of the
conspiracy are also made “in furtherance” of the conspiracy. See United States v. Monus, 128 F.3d
376, 392 (6th Cir. 1997).

3

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•

to reassure or calm the listener regarding the progress or stability of
the scheme, Sophie, 900 F.2d at 1073; Garlington v. O=Leary, 879 F.2d
277, 284 (7th Cir. 1989);

•

to report conspirators’ status and in turn receive assurances of
assistance from coconspirators, United States v. Prieto, 549 F.3d 513
(7th Cir. 2008);

•

“describing the purpose, method or criminality of the conspiracy,”
United States v. Ashman, 979 F.2d 469, 489 (7th Cir. 1992);

•

statements to outsiders “to serve as a salesmanship technique to
enhance his position in the eyes of [the outsider] and give confidence
about the ability of the organization,” United States v. Stephenson, 53
F.3d 836, 845 (7th Cir. 1995); United States v. Curtis, 37 F.3d 301, 308
(7th Cir. 1994).

Finally, it has long been the rule that any statement made by a conspirator
during and in furtherance of a conspiracy is admissible against all coconspirators.
Beeson v. United States, 90 F.2d 720 (7th Cir. 1937); United States v. Lindemann, 85
F.3d 1232, 1238 (7th Cir. 1996); see also United States v. Rivera, 136 F. App’x 925, 926
(7th Cir. 2005) (“Whether any other conspirator heard (or, in this instance, saw)
that statement is irrelevant; agency, not knowledge, is the theory of
admissibility.”).
C.

Alternative Bases for Admissibility of Statements

Various statements made during the course of a conspiracy are
independently admissible and do not require a Rule 801(d)(2)(E) analysis. A
defendant’s own statements, for example, are admissible against him pursuant to
Rule 801(d)(2)(A), without reference to the coconspirator statement rule.
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1.

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A Defendant’s Own Statements

A defendant’s own admissions are relevant to establish the factual
predicates for the admission of coconspirator statements against him. See United
States v. Godinez, 110 F.3d 448, 455 (7th Cir. 1997). Many statements described
herein and sought to be admitted against the defendants are independently
admissible and do not require a Rule 801(d)(2)(E) analysis. A defendant’s own
admissions, for example, are admissible against him pursuant to Fed. R. Evid.
801(d)(2)(A), without reliance on the coconspirator-statement rule. 4 See United
States v. Maholias, 985 F.2d 869, 877 (7th Cir. 1993). Additionally, a defendant’s own
admissions are relevant to establishing the factual predicates for the admission of
coconspirator statements against him. See United States v. Potts, 840 F.2d 368, 37172 (7th Cir. 1987).
2.

Non-Hearsay Statements

The coconspirator statement rule is not implicated where the relevant verbal
declaration is not a “statement” within the meaning of Rule 801(a), that is, not an
“assertion” subject to verification. An example would be an order or a suggestion.
See United States v. Tuchow, 768 F.2d 855, 868 n.18 (7th Cir. 1985). This is because a
“statement” is defined as “an oral or written assertion” or “nonverbal conduct of

Rule 801(d)(2)(A) provides in pertinent part that a “statement” is not hearsay if “[t]he statement
is offered against a party and is … the party’s own statement, in either an individual or a
representative capacity.”

4

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a person, if it is intended by the person as an assertion.” Fed. R. Evid. 801(a). Thus,
a statement which is incapable of verification, such as an order or a mere
suggestion, is not hearsay and does not invoke a Rule 801(d)(2)(E) analysis. See
Tuchow, 768 F.2d at 868.
Finally, the coconspirator statement rule does not apply when a statement
is not being offered for the truth of the matter asserted, and thus does not
constitute “hearsay” as defined by Rule 801(c). 5 Accordingly, statements by
alleged coconspirators may be admitted against a defendant, without establishing
the Bourjaily factual predicates set forth above, when such statements are offered
simply to show, for instance, the existence, the illegality, or the nature or scope of
the charged conspiracy. Gajo, 290 F.3d at 929-30; see also United States v. HerreraMedina, 853 F.2d 564, 565-66 (7th Cir. 1988); Van Daal Wyk, 840 F.2d at 497-98;
Tuchow, 768 F.2d at 867-69.
3.

Statements Against Penal Interest

Under Federal Rule of Evidence 804(b)(3), a hearsay statement is admissible
if (1) the declarant is unavailable; (2) the statement was against the declarant’s
penal interest at the time it was made; and (3) corroborating circumstances exist
indicating that the statement is trustworthy. See United States v. Lewis, 641 F.3d 773,
Federal Rule of Evidence 801(c) defines hearsay as “a statement, other than one made by the
declarant while testifying at the trial or hearing, offered in evidence to prove the truth of the
matter asserted.”

5

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783 (7th Cir. 2011). When determining whether a statement is against penal
interest, each portion of a proffered out-of-court statement is examined to
determine whether it subjected the declarant to criminal liability. United States v.
Westmoreland, 240 F.3d 618, 626 (7th Cir. 2001). A statement may satisfy this
requirement if it would be probative at trial against the declarant. United States v.
Nagib, 56 F.3d 798, 804 (7th Cir. 1995). Applying this standard, the Seventh Circuit
has held that a declarant’s inculpatory statements made to friends and
acquaintances about crimes committed by the declarant and his associates are
admissible. See, e.g. United States v. Hamilton, 19 F.3d 350, 357 (7th Cir. 1994)
(holding that a jailhouse conversation between two codefendants which
incriminated a third codefendant but was also inculpatory of the first two codefendants was admissible against the third codefendant); United States v. Curry,
977 F.2d 1042, 1056 (7th Cir. 1992) (affirming the district court’s decision to allow
a co-defendant’s inculpatory statement which also incriminated the defendant
because it was not made in an attempt to curry favor with law enforcement, but
was made to an acquaintance).
Such statements against penal interest are admissible against non-declarant
defendants. See United States v. Volpendesto, 746 F.3d 273, 288 (7th Cir.) cert. denied
sub nom. Sarno v. United States, 135 S. Ct. 382 (2014) and cert. denied sub nom. Polchan
v. United States, 135 S. Ct. 383 (2014); United States v. Watson, 525 F.3d 583, 587-88
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(7th Cir. 2008); United States v. Hamilton, 19 F.3d 350, 356 (7th Cir. 1994). See also
United States v. Smalls, 605 F.3d 765, 773-81 (10th Cir. 2010). 6
III.

SUMMARY OF THE CASE

At trial, the government’s evidence will establish that all of the defendants
conspired with one another and others to conduct and participate in the affairs of
the Bomb Squad, an enterprise, through a pattern of racketeering consisting of the
trafficking in controlled substances, arson, robbery, murder, attempt murder, and
intimidation of witnesses. In addition to racketeering acts, Count One, RICO
conspiracy in violation of 18 U.S.C. § 1962(d), alleges the commission of certain
overt acts by members of the Bomb Squad, including acts of gun possession and
incidents of possession and distribution of controlled substances. The predicate
acts and overt acts demonstrate conspiratorial agreement, participation in the
conspiracy, and knowledge of the conspiracy’s objectives. In total, there are fortytwo (42) separate acts alleged in the indictment. Because those acts are all evidence
of the same charged conspiracy, the government will prove up each of those acts
at trial in this case.
This section sets forth an overview of the Bomb Squad and a history of this
investigation.

There is no Confrontation Clause problem since “[a] statement unwittingly made to a
confidential informant and recorded by the government is not ‘testimonial’ for Confrontation
Clause purposes.” Watson, 525 F.3d at 589.

6

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A. The BOMB SQUAD
The Bomb Squad is a violent local street gang located on the south end of
Peoria, Illinois. Bomb Squad members also identify themselves within smaller
cliques of members, or “sets,” named 2300 (Twenty-Three Hundred or “2-3”),
Magnolia, Dub-H, BTTE (Brothers to the End), Squad Up, Family First, Marco
Movement, GTS (Geek Team Squad), Rock Block, Moneygang, and Boosie Gang.
Although the Indictment charges the defendants with conducting in the affairs of
the Bomb Squad from approximately 2013 to the present, the Bomb Squad street
gang was formed as early as 2009. Bomb Squad turf includes the area between
Garden Street (northern border), Adams Street (southern border), Western
Avenue (eastern border), and Laramie Street (western border). The Harrison
Homes housing facilities are located within Bomb Squad territory. 7 Bomb Squad
territory is located in Peoria Police District 4 and is covered by ShotSpotter Zone
1. 8

Harrison Homes is Section 8 housing (Section 8 of the Housing Act of 1937 (42 U.S.C. § 1437f))
located on Peoria’s far South Side. Harrison Homes was originally developed in the 1930’s and
currently consists of approximately 158 apartments on 31 acres.

7

ShotSpotter is a gunshot detection system that uses acoustic sensors to detect and convey the
location of gunfire to law enforcement. There are two ShotSpotter zones in Peoria. Zone 1, which
covers an area on the south end that includes BOMB SQUAD territory and portions of the turf of
rival gang, “Zone 4”, went live on November 19, 2013. Zone 2, which covers and area on the east
bluff and the turf of rival gangs, “Moe Block” and ‘Sic Movement” went live on May 21, 2015.

8

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Several members of Bomb Squad have been murdered by gunfire, including
the following:
• Monterrius DILLARD, a.k.a. “Bull” – On November 13, 2011, at age 21,
body located in a vacant lot on Martin Street with multiple gunshot wounds.

• Robreco KING, a.k.a. “Reco,” a.k.a. “Suave” – On June 18, 2012, at age 23,
died from gunshot wounds sustained after leaving Club Apollo.

• Raheem WILSON, a.k.a. “Boosie” – On February 9, 2017, at age 23, died
from gunshot wound to the right hip.
• Jamon LEWIS, a.k.a. “J-Money” – On January 15, 2017, at age 22, died from
gunshot wound to the head sustained during the course of a robbery.

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Bomb Squad members frequently pay homage to deceased members of the
gang. They post images on Facebook of deceased members to mark the
anniversary of their deaths; they create shirts with images of deceased members
and slogans to honor their membership in the gang (i.e. “RIP Bull”, “Bull World”,
“Reco World”, “Boosie Gang”, “RIP Bull On Chestuh”); and they obtain tattoos
that pay tribute to deceased members.

Bomb Squad members also pay tribute to associates of Bomb Squad who
were murdered by gunfire within Bomb Squad territory, including the following:
• Tyrone JONES, a.k.a. “Rocky” – On January 19, 2015, at age 17, died from
gunshot wounds when a car with four individuals fired into a group of
people on S. Griswold Street.
• Demarco IRBY, a.k.a. “Marco” – On September 8, 2015, at age 15, died from
a gunshot wound while at a residence on Starr Street.
• Edward MOORE, a.k.a. “Fester” - On December 11, 2016, at age 22, died
from gunshot wound sustained while walking from the Harrison Homes
through Griswold liquors parking lot.

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BOMB SQUAD members also frequently wear gang paraphernalia shirts
and post images on social media in support of fellow members that have been
prosecuted for firearms offenses and violent crimes:
• Charles Smith, a.k.a. “Mad Maxx” a.ka. “Mano” – in 2013, Smith (at age 16)
was sentenced to 30 years in prison for killing Michael Robinson during a
botched robbery on Starr Street in Bomb Squad territory.

The following sample images were located during a search of Facebook
accounts of several Bomb Squad gang members pursuant to a federal search
warrant:

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The rival gangs to the Bomb Squad are referred to as “opps”, an
abbreviation for “opposition” gang members. Bomb Squad opps are primarily Sic
Movement, Moe Block and Zone 4. Bomb Squad members have no respect for opps
and shoot them or assault them whenever they see them. Opps are not allowed in
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Bomb Squad territory and are to be killed if they are caught driving through Bomb
Squad turf or “lackin” (not carrying a gun). Bomb Squad members commit “opp
slides” which means they go into opp territory to find and shoot opps. Bomb
Squad members frequently taunt opps on social media, including on Facebook
posts and in rap songs posted on YouTube.
The following example is a Facebook post by defendant, Lance Washington:

The following example is a Facebook post by defendant, Raevaughn Rogers:

B. The Investigation
1. Cooperators
This investigation began in June 2017 when the Bureau of Alcohol, Tobacco,
Firearms, and Explosives (“ATF”) and the Peoria Police Department (“PPD”)
recruited Bomb Squad gang member CGM-1 as a confidential informant
(hereinafter “CGM-1”). At that time, CGM-1 had been a member of the gang for
several years. CGM-1 was interviewed extensively and provided details regarding
the Bomb Squad, including but not limited to identification of gang members,

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information about initiation, leadership and ranking, geographical turf, rival
gangs and rival gang territory, meetings, trap houses, drug and gun activity,
specific acts of violence, gang signs, slang, and gang practices. The ATF and PPD
subsequently recruited two additional Bomb Squad members to act as informants
(hereinafter “CGM-2” and “CGM-4”). CGM-2 and CGM-4 were also interviewed
extensively regarding history and characteristics of the Bomb Squad, including
specific acts of violence committed by the gang.
The ATF and PPD used CGM-1, CGM-2, and CGM-4 to conduct three types
of investigatory work. First, ATF and PPD used the cooperators to make recorded
purchases of firearms and narcotics (powder cocaine, crack cocaine, heroin,
ecstasy, marijuana) from members of the Bomb Squad. Second, ATF and PPD used
the cooperators to attend meetings with Bomb Squad members and record
conversations with Bomb Squad members about gang activities, including
narcotics transactions and acts of violence against rival gang members. Third, the
ATF and PPD used the cooperators to obtain intelligence, admissions, and coconspirator statements from Bomb Squad members.
As the case progressed, the government developed additional cooperating
witnesses who are members of the gang or closely associated with the gang. As
with the CGM-1, CGM-2, and CGM-4, the ATF and PPD obtained historical
information about the Bomb Squad from the additional cooperators and further,
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used some of the cooperators in proactive investigatory work, including firearm
and narcotics purchases and recorded overhears of conversations with Bomb
Squad members.
2. Facebook and YouTube
Law enforcement also tracked open-source social media like Facebook and
Snapchat for Bomb Squad-related postings and executed electronic search
warrants on the Facebook accounts of thirteen Bomb Squad members named in
the indictment. The social media accounts are laden with images of drugs,
firearms, gang signs, gang tattoos, graffiti, gang-related clothing, group photos,
homages to former gang members, and memes discouraging snitching.
Law enforcement has also obtained and preserved a significant number of
rap videos produced by Bomb Squad members and posted on YouTube. In the
videos, Bomb Squad members brandish handguns and assault rifles, drugs, and
large amounts of cash. The cooperators will testify that the guns and drugs in the
videos are, in fact, real guns and drugs. The recurring themes in the songs relate
to selling drugs, committing burglaries, shooting the opposition gangs, calling out
snitches, using “shorties” (up-and coming juvenile gang members) to conduct
assassination missions in rival territory, and general intimidation by displaying
firearms and rapping about particular calibers of weapons and high capacity
magazines. In the videos, the participants frequently chant the words “Squad” and
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“Two-Three”, referring to Bomb Squad and the 2300 Block of Starr Street in Bomb
Squad territory, respectively.
3. Execution of Residential Search Warrants
Law enforcement obtained and executed a number of residential search
warrants in the course of this investigation as well. In July 2017 a search was
conducted on a residence frequented by Bomb Squad members that yielded crack
cocaine packaged for sale, a digital scale, cannabis, and firearm ammunition.
In August 2017 the search of a Bomb Squad member’s residence yielded
crack cocaine packaged for sale, digital scales, shirts bearing gang-related slogans,
a funeral program for Raheem Wilson, a.k.a. “Boosie,” and a Glock 17 9mm caliber
handgun with a 30 round magazine.
Finally, in September 2017, law enforcement executed a federal search
warrant on apartment #190 in the Harrison Homes, a known trap house and
common place for narcotics distribution by Bomb Squad members. The search
yielded four handguns, ammunition, 2-way radios, scales, and baggies commonly
used for drug packaging.
C. Overview of the Evidence
At trial, the government intends to introduce the following types of
evidence in proving the existence of the RICO conspiracy and the acts committed
in furtherance thereof, as well as in support of the additional substantive counts
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in the indictment: (1) cooperating gang member testimony, (2) testimony from
cooperating

witness/associates

of

the

Bomb

Squad,

(3)

testimony

of

civilians/victims, (4) certified prior convictions, (5) ballistic evidence, (6)
ShotSpotter gunshot detection and location service data, (7) physical evidence
recovered from the scenes of murders, attempt murders, and attempt arsons, (8)
private home and business surveillance camera videos/images (9) law
enforcement officer testimony relating to investigations of murders, attempt
murders, and attempt arsons, (10) images and videos posted on Facebook and
other social media, (11) Facebook Messenger messages, (12) YouTube videos, (13)
recorded phone calls between cooperators and Bomb Squad members (14)
recordings by cooperators from drug and gun purchases and meetings with Bomb
Squad

members,

(15)

guns

and

drugs,

and

(16)

gang-related

paraphernalia/apparel.
The government will establish, through cooperating witnesses and the proof
of overt acts, that the Bomb Squad is a local violent street gang. The Bomb Squad,
and its smaller cliques or “sets” have hand signs which they exhibit to either fellow
gang members or rivals. These hand signs include, but are not limited to, gestures
representing “Bomb Squad”, “Family First”, “Marco Movement”, “Boosie Gang”,
“Harrison Homes (Dub-H)”, “Magnolia (2300)”, “2-3”, and “Geek Team Squad”.
The Bomb Squad also uses the “Die 4 (Cracking 4s)” hand sign as a sign of
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disrespect to any gang that represents the number 4, including the Peoria street
gang, Zone 4. The Bomb Squad also uses the “Die 5” hand sign to disrespect rivals
it considers to be allies of the “People Nation” gangs who use the 5 pointed star as
one of their main symbols.
The evidence will show that the Bomb Squad has a set of rules. These rules
include but are not limited to the following:
• Members are not allowed to cooperate with law enforcement.
• Members need to “post up” in their gang neighborhood.
• Members need to shoot on sight any rival gang members whenever
they see them.
• Stealing or robbing other members of the gang is not allowed.
• Associating in any way with the opps is not allowed.
• Gang members must report shootings they do against the opps so
everyone else can be on alert for retaliation shootings in Bomb Squad
territory.
The cooperating witnesses, recorded overhears, social media images and
text of conversations, and rap videos will form the backbone of this RICO
prosecution. Among other things, this evidence will establish the enterprise, the
interstate nexus, and the predicate objectives of the Bomb Squad. Those objectives
include (a) preserving and protecting the power, territory and profits of the
enterprise through the use of intimidation, violence, threats of violence, murder,
attempt murder, and assaults; (b) promoting and enhancing the enterprise and the
activities of its members and associates; (c) providing assistance to members and
associates who committed crimes for and on behalf of the gang; (d) using resources
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of the enterprise to settle personal grievances and vendettas, including asking and
expecting members and associates of the enterprise to carry out acts of violence;
(e) confronting and retaliating against rival gangs and persons who were
perceived as hostile to the enterprise through the use of intimidation, violence,
threats of violence and assault; (f) enriching the members and associates of the
enterprise through, among other things, the distribution and sale of narcotics; and
(f) protecting the enterprise and its members and associates from detection and
prosecution by law enforcement authorities through acts of intimidation and
violence against potential witnesses to crimes committed by members of the
enterprise.
In practice, these predicate objectives translated into murders, attempt
murders, shootings, assaults, robberies, arson, and witness intimidation
committed by the defendants. These acts will be proven through eyewitness
testimony,

cooperating

witnesses,

recorded

co-conspirator

statements,

surveillance video, ShotSpotter corroboration, and ballistics.
The eyewitness testimony will consist primarily of time, place, and manner
witnesses. The eyewitness and cooperating defendant testimony will be
corroborated by Facebook messenger conversations and posts as well as physical
evidence. Finally, data from ShotSpotter, including time, date, location, and audio

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of gunshot incidents will be utilized to corroborate twelve of the shooting
incidents alleged in the indictment.
In addition, ballistic evidence will be used to directly link Bomb Squad
members to charged shootings. For example, Overt Act (v) in Count One alleges
that on March 4, 2017, a juvenile Bomb Squad member shot at rival gang member,
Victim L, in rival gang territory on E. Republic. The juvenile referenced in Overt
Act (v) is defendant Raevaughn Rogers. 9 On March 10, 2017, Rogers was arrested
for possessing a stolen .40 caliber handgun. At trial, the government will establish
that .40 caliber shell casings collected from the scene of the shooting in Overt Act
(v) on March 4, 2017, were fired from the firearm found in Rogers’ possession on
March 10, 2017. Rogers pleaded guilty to possessing the stolen .40 caliber firearm.
As another example, Overt Act (z) and Count Twenty-Six allege that on May
2, 2017, defendant Lloyd Dotson attempted to murder a rival gang member by
shooting at him on E. Wilson Street, striking Victim Q with a bullet as Victim Q
entered the rival gang member’s car. At trial, the government will present
evidence that approximately three months later, on August 15, 2017, law
enforcement executed a search warrant at Dotson’s residence and located crack
cocaine packaged for sale and gang paraphernalia. See Overt Act (ii). Prior to the

Defendant ROGERS turned eighteen on July 21, 2017, approximately 11 months prior to being
indicted in this case.

9

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search, officers observed Dotson leave the residence with a backpack and travel to
another location where he was later taken into custody outside of an apartment.
Inside the apartment, officers located a 9mm pistol inside of a backpack. The
government will establish that 9mm shell casings collected from the scene of the
shooting of Victim Q on May 2, 2017, were fired from the same firearm found in
the backpack when Dotson was arrested on August 15, 2017.
IV.

STATEMENT OF FACTS/EVIDENTIARY SUPPORT OF THE
CHARGED CONSPIRACY

The following summary provides an evidentiary basis for the requisite
elements of the charge conspiracy. In general, the evidence is divided into four
sections: (a) cooperating gang member and cooperating witness testimony 10; (b)
consensually recorded conversations; (c) Facebook posts and Facebook Messenger
conversations; (d) and evidence establishing the various violent acts and unlawful
weapons possession that the government intends to prove at trial.
A. Cooperating Gang Member and Cooperating Witness
Testimony
At trial, the government expects to present the testimony of six cooperating
Bomb Squad members (which are referred to as Cooperating Gang Member __ “
or “CGM__”) and at least two Cooperating Witness/Co-Conspirators (“CW-__”).
“Cooperating gang members” include charged and uncharged co-conspirators that are
members of the Bomb Squad. “Cooperating witnesses” includes defendants under indictment or
serving a term of imprisonment who are co-conspirator associates of Bomb Squad, but not
members of the gang, i.e. drug sources.
10

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The statements summarized below are based principally on the prior statements
of these coconspirators to law enforcement. Because almost all of these statements
are quite extensive and detailed, and because the number of coconspirators,
charged and uncharged, in the conspiracy is quite large, this Santiago proffer is
necessarily just a summary of the more detailed statements provided to the
defense in discovery.
In general, the cooperating witnesses’ testimony will focus on 11 main areas:
(1) how the cooperator was recruited into the gang; (2) the gang’s structure,
leadership, and overall membership; (3) attendance at and issues discussed at
gang meetings, including planned violence against rival gang members; (4) the
sharing of firearms; (5) the use of drug and gun stash houses; (6) placing money
on fellow gang members books while they are in jail; (7) their involvement in and
being a witness to murder attempt murders committed by members of the Bomb
Squad against rival gang members; (8) conversations before, during, and after acts
of violence against rival gang members or persons believed to be rival gang
members; (9) the manner and means by which the Bomb Squad concealed and
attempted to conceal their involvement in acts of violence, including the use of
“hype-rentals” (trading drugs for the use of an addicts vehicle) and monitoring
police radios in order to detect police presence and responses to shootings and

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other criminal activities carried out by the Bomb Squad; (10) gang related symbols,
hand signs, jargon, and communication; (11) drug trafficking by the Bomb Squad.
Each of the cooperating gang members and cooperating witnesses will
testify to some or all of the above areas, as well as identifying each of the
defendants as Bomb Squad members.
1. Cooperating Gang Member 1 (“CGM-1”)
CGM-1 may testify about his activities as a Bomb Squad gang member and
the following general areas:
• CGM-1 has been a Bomb Squad member since the age of 13;
• The Bomb Squad is a street gang from Peoria’s south end, specifically
including the housing project, Harrison Homes, called the “Dub H”;
• Bomb Squad is a spinoff gang from Dub H;
• Bomb Squad territory is made up of the area between Laramie Street
(west border), Adams Street (south border), Western Avenue (east
border), and a little north of Garden Street (north border).
• The northern border of Bomb Squad territory doesn’t extend as far
north as it used to because Zone 4 has moved west across Western
Avenue into far northeastern Bomb Squad territory on streets like
Proctor and Ann;
• Bomb Squad and its subsets have a slow initiation process; a potential
gang member must first hang around the gang (usually as a juvenile)
and be known to an associate or a “shorty”; as a shorty or hangaround does more and more shootings and/or robberies they begin
to gain more credibility with gang members;

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• After a period of time and the commission of violent acts, current
gang members begin to accept an associate as a low ranking member;
• Bomb Squad (and their subsets) utilize an informal ranking system;
• Members increase in rank as they gain street credibility;
• Street credibility is somewhat gained by having money acquired from
burglaries or selling drugs, but it is primarily gained by committing
shootings and robberies;
• Murdering a top target of a rival gang can increase rank very quickly;
• Serving prison time for a violent act and subsequently being released
also gives a gang member’s rank a big increase;
• “Magnolia Block” is a subset of Bomb Squad;
• GGM-1 is a Bomb Squad member and part of the Magnolia Block
subset;
• Raheem Wilson, a.k.a. “Boosie” was murdered in February of 2017;
• Raheem WILSON used to be the “shot caller” (leader) for Bomb
Squad;
• Wilson started talking about forming the subset, Magnolia Block, in
2008, and put it into place in 2010;
• Magnolia Block’s primary focus was committing robberies of Peoria’s
largest drug dealers;
• Bomb Squad has numerous members who are known within the gang
as the shooters;
• Bomb Squad primarily acquires firearms by purchasing them “on the
street” in cities outside of Peoria or by Bomb Squad members

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committing residential burglaries within the Peoria metropolitan
area;
• Bomb Squad has conducted regular gang meetings for years;
• Raheem WILSON held regular meetings until he was murdered;
• Bomb Squad meetings can be called by members who have earned
respect from other members;
• Meetings take place in a park, a yard, or inside a residence;
• Common meeting topics include ending internal fighting,
distribution of firearms to the shooters, drug trafficking, acquiring
trap houses, and acts of violence that need to be carried out against
rival gang members;
• Other gangs are referred to as rivals and “opps” because they battle
for territory, drug distribution, and respect;
• “Opps” are commonly shot at, robbed, and disrespected on Facebook;
• “Opps” are not permitted in Bomb Squad territory, and Bomb Squad
members know they are not permitted in “opp” territory;
• Bomb Squad’s main “opps” are SIC Movement, Zone 4, and Moe
Block;
• SIC Movement is primarily located near the Linn/Richmond
intersection and on California Avenue;
• Moe Block is primarily located on the East Bluff;
• Zone 4 is primarily located east of Western Avenue;
• “Opps” are regularly shot at by Bomb Squad members when they are
seen in Bomb Squad territory;

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• Bomb Squad members regularly do “opp slides” which means
driving into “opp” territory to do a drive by shooting of rival gang
member or their residence;
• Violence against “opps” is done to gain additional status/rank within
Bomb Squad and to scare the “opps” from coming into their territory
and thus interfering with drug distribution;
• “Opps” known to have large amounts of drugs are commonly sought
out to be robbed of their drugs and money;
• Gang members are to report any major shooting or homicide to gang
leadership so everyone is made aware that the “opps” will be
retaliating and can take necessary precautions;
• “Hitting licks” refers to burglaries or robberies carried out by gang
members;
• “Hitting a stain” can also refer to burglaries or robberies carried out
by gang members;
• Money, drugs, and guns are often shared after burglaries or robberies
are carried out by gang members;
• Distribution of money, drugs, and guns after burglaries and robberies
often turns into arguments and disagreements;
• Members often put money together to pay for bonds or provide
commissary of higher ranking or respected members who are in
custody;
• Bomb Squad does not have a specific ranking system, but members
know who has more authority and respect than other inferior
members;
• Authority and rank are earned by committing acts of violence against
rival gangs;

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• Bomb Squad takes credit for the murders of Deven Lee, a.k.a.
“Smoka” and Aubrae Harper, a.k.a. “Wop” (considered to be
members of Moe Block), Eric Brown, a.k.a. “Greedy” (considered to
be Zone 4), and Tyran Chester, a.k.a. “Sticks” (considered to be a drug
dealer from Chicago).
• The need to murder Demoney Coleman (Moe Block) was regularly
discussed in Bomb Squad meetings;
• Bomb Squad believes that members of Moe Block killed Edward
Moore, a.k.a. “Fester” in Bomb Squad territory in retaliation for Bomb
Squad killing Deven Lee, a.k.a. “Smoka”;
• CGM-1 has committed numerous shootings on behalf of Bomb Squad;
• Prior to being murdered, Raheem Wilson, a.k.a. “Boosie” was in
charge of all robberies and “drug rips”;
• If a high ranking member of Bomb Squad doesn’t want to carry a gun,
he will have a lower ranking member accompany him and carry a gun
for protection;
• Raheem Wilson, a.k.a. “Boosie” had defendant Kenwan Crowe
accompany him when Wilson was murdered; Wilson did not have a
gun but Crowe did; Wilson exited the residence to walk to a vehicle,
but Kenwan Crowe stayed inside the residence with a girl when
Wilson was shot and killed;
• Bomb Squad uses the word “wody” (pronounced “whoa-dee”) to
identify themselves to each other as Bomb Squad; Raheem Wilson,
a.k.a. “Boosie” implemented the use of the word “wody” as an
identifier to provide protection from rival gang members;
• If a group of Bomb Squad members is having a meeting or socializing
in a park or at a residence when an unknown vehicle passes more than
once they will yell “wody” at the vehicle when it passes for the second
time; if the vehicle is occupied by black males and does not yell
“wody” in return to identify themselves as Bomb Squad, then a Bomb
Squad shooter will open fire on the vehicle if it passes a third time;
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• Bomb Squad uses trap houses to store guns it possess and distribute
controlled substances;
• Bomb Squad has a specific handshake; Magnolia has a separate
handshake;
• CGM-1 is known as one of the shooters within the Bomb Squad;
• Bomb Squad members commit acts of violence in relation to “beefs”
with rival gangs and to defend drug trafficking territory;
• Bomb Squad has utilized two-way radios to notify other members
when law enforcement or rival gang members are nearby;
• In 2017, Bomb Squad was having cookouts that served as gang
meetings and referred to them as “hood day”
• Higher ranking members of the gang would spend thousands of
dollars on food and alcohol to host “hood day”;
• The September 11th “hood day” is held on the birthday of the
murdered Bomb Squad member, Monterrius Dillard, a.k.a. “Bull”; the
occasion is also used to remember Demarco Irby, a.k.a. “Marco” who
died from a gunshot wound at a residence on Starr Street on
September 8, 2015 (at age 15);
• In 2017, Bomb Squad members would “post up” at the store on Starr
Street, the liquor store on Griswold, and in the Harrison Homes
housing project; the three locations were utilized for selling drugs
because they were spread out throughout Bomb Squad territory and
gang members would be able to detect any rival gang members
coming into their turf;
• As a Bomb Squad member, CGM-1 sold, and helped fellow gang
members sell narcotics (including, but not limited to, marijuana);
• CGM-1 possessed firearms in Bomb Squad gang territory;
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• CGM-1 held firearms for fellow gang members;
•

CGM-1 loaned firearms to fellow gang members or associates;

• On multiple occasions the CGM-1 shot at rival gang members in rival
gang territory, including but not limited to, a shooting on Proctor
Street in 2016;
• On multiple occasions CGM-1 shot at rival gang members in Bomb
Squad territory, including but not limited to, a shooting at rival gang
members on Nevada Street in 2017 and an occasion where the CGM1 shot at a truck driving near Trewyn School because he believed that
the passengers were members of Zone 4 street gang;
• On an occasion in 2017, CGM-1 assisted another Bomb Squad member
by allowing him to hide at CGM-1’s house after the fellow gang
member shot and killed a prospective drug customer in the Harrison
Homes.
2. Cooperating Gang Member 2 (“CGM-2”)
CGM-2 will reiterate much of what CGM-1 states about the general history
and activities of the Bomb Squad. Additionally, he may testify about his activities
as a Bomb Squad gang member and the following general areas:
• CGM-2 has been a Bomb Squad member since 2011;
• CGM-2 possessed firearms in Bomb Squad gang territory;
• CGM-2 held firearms for fellow gang members;
•

CGM-2 loaned firearms to fellow gang members or associates;

• CGM-2 sold drugs or assisted another gang member by selling drugs
for him;
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• In 2016, CGM-2 shot at a car on Arago Street in Bomb Squad territory
because he believed it was occupied by rival gang members.
• In 2016, CGM-2 was present when fellow Bomb Squad members shot
at a vehicle occupied by two females on Arago Street because they
believed the vehicle was occupied by rival gang members.
• In 2017, CGM-2 was present with Bomb Squad members in the
Harrison Homes while waiting for a pre-arranged drug transaction to
occur. After arrival of the customer, other Bomb Squad members met
with the customer behind a building. The customer then, however,
fled and was shot by a Bomb Squad member.
• Bomb Squad’s main “opps” are SIC Movement, Zone 4, and Moe
Block
• Bomb Squad claims credit for the murders of Deven Lee, a.k.a.
“Smoka” and Aubrae Harper, a.k.a. “Wop” (considered to be
members of Moe Block), Eric Brown, a.k.a. “Greedy” (considered to
be Zone 4), and Tyran Chester, a.k.a. “Sticks” (considered to be a drug
dealer from Chicago).
• CGM-2 shot at Demoney Coleman in 2016 but did not hit him; Bomb
Squad has shot at Demoney Coleman in the East Bluff on numerous
occasions;
• Older Bomb Squad members distribute firearms to younger members
at meetings.
3. Cooperating Gang Member 3 (“CGM-3”)
CGM-3 will reiterate much of what CGM-1 states about the general history
and activities of the Bomb Squad. Additionally, he may testify about his activities
as a Bomb Squad gang member and the following general areas:
• CGM-3 has been a Bomb Squad member since approximately age 13;

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• CGM-3 possessed firearms in Bomb Squad gang territory;
• CGM-3 held firearms for fellow gang members;
•

CGM-3 loaned firearms to fellow gang members or associates;

• As a Bomb Squad member, CGM-3 sold, and helped fellow gang
members sell narcotics (including crack cocaine and marijuana);
• CGM-3 has committed a robbery with another Bomb Squad member;
• On several occasions between 2013 and 2017, CGM-3 shot at members
of the rival gang, Sic Movement;
• In April 2016, CGM-3 and other Bomb Squad members shot at a
vehicle they believed to be occupied by rival gang members on S.
Stanley Street in Bomb Squad territory. The car then crashed and two
occupants got out and ran. After the shooting, CGM-3 and others
went to the CGM-3’s house to stash the firearms that were used;
• In May 2016, CGM-3 shot a male multiple times outside Club LA in
Peoria, Illinois;
• To join Bomb Squad, an associate needs to bring something to the
table, like a willingness to be a shooter, or a drug dealer, or a good
fighter, or able to obtain good intel on the “opps”;
• In 2017, the subset of Bomb Squad known as “2300” was in charge of
Bomb Squad;
• SIC Movement, Moe Block, and Zone 4 are the main “opps” of Bomb
Squad;
• Who Bomb Squad is at war with, who they should be looking out for,
who they should be shooting at, what their targets are driving, where
their targets live and work, stake out plans, who will shoot, and who
will sell drugs are all discussed at Bomb Squad meetings in the form
of BBQs;
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• When the police have a strong presence in the “southend” of Peoria
it’s a good time for Bomb Squad to go to “opps” territory and shoot
“opps”;
• Bomb Squad acquire firearms through burglaries and females with
FOID cards;
• Rank is achieved by “going all the way in the paint” in whatever
specialty you bring to the table (shooting, drug dealing, intel,
robberies, burglaries, etc.);
• “Hustlers” gain rank by selling a lot of drugs and making a lot of
money;
• “Shooters” gain rank by doing a lot of shootings;
• Fighters are expected to assault “opps” if they see them in clubs;
• Another way to gain rank is by doing a lot of time in prison without
snitching;
• Committing murders against “opps” increases rank a lot;
• Shooting a “big hitter” from the “opps” will also increase your rank a
lot;
• A member can gain some rank by burglaries, robberies, and provided
information about “opps”, but rank is mostly attained by selling
drugs and doing shootings
• The main post up locations for members are the store on Starr Street,
the store on Griswold Street, the park across from the store on
Griswold Street, at Starr and Arago, and at Starr and Humboldt;
• Hustlers and shooters post up to sell drugs;
• Drugs and guns will always be at the post up spots, but the
contraband will not always be kept on people;
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• Drugs and guns are often kept in bags or trash cans at post up spots,
but sometimes members keep the drugs and guns on their persons;
• Members feel comfortable having the guns near them and not on
them because “opps” usually pass by at least once before committing
a shooting so there will be time to retrieve the gun’
• Members are supposed to report any big shootings they do against
the “opps” so everyone else can be on the lookout for potential
retaliation;
• Raheem Wilson, a.k.a. “Booise” used to “squash” problems for Bomb
Squad;
• If members wouldn’t verbally “squash” a problem, WILSON would
provide each member involved in the “beef” with a gun and told them
to shoot it out to settle it;
• Usually the weaker member would back down and “squash” the
issue after Wilson started passing guns out;
• Money and drugs are sometimes given to members who are expected
to use it to make more money and then pay back their loan;
• Guns are passed out, but if you get it “bumped off” you are supposed
to replace it;
• The most successful drug dealers within the gang pay shooters and
give money to other guys below them;
• If you are given money but aren’t doing anything with it to turn it
into more money (use it for transportation to commit burglaries or
robberies or use it to acquire and sell drugs) you will be cut off;
• Proceeds are distributed after “big licks”, and everyone benefits from
it;
• Money is also used to try to take care of higher ranking members who
are incarcerated.
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4. Cooperating Gang Member 4 (“CGM-4”)
CGM-4 will reiterate much of what CGM-1 states about the general history
and activities of the Bomb Squad. Additionally, he may testify about his activities
as a Bomb Squad gang member and the following general areas:
• CGM-4 is a member of Bomb Squad and the subset 2300;
• The “shot callers” (leaders) of the Bomb Squad are the members that
have the most money;
• The current shot callers distribute cannabis, cocaine, and heroin;
• For a Bomb Squad member to increase in rank, they have to put in
work by fighting, shooting, or obtaining money;
• In order to be in the Bomb Squad, a member had to demonstrate their
worth by committing robbery, distributing narcotics, or committing
shootings;
• Bomb Squad has trap houses where firearms and drugs are stored and
where meetings are conducted; trap houses are exclusive to Bomb
Squad member – other persons are not allowed;
• Bomb Squad has meetings to address issues at hand; higher ranking,
older members order younger members how to handle situations
involving rival gang members, internal beefs, and law enforcement;
• Prior to being murdered in 2017, Raheem Wilson, a.k.a. “Boosie”
would conduct meetings on a regular basis;
• Bomb Squad members pool their money to post bond on behalf of
gang members who are arrested and awaiting trial;
• Higher ranking members of Bomb Squad make money selling
narcotics and direct younger members to commit criminal acts for
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them on behalf of the gang; the younger gang members are motivated
to conduct the criminal acts in order to gain rank in the gang.
5.

Cooperating Gang Member 5 (“CGM-5”)

CGM-5 will reiterate much of what CGM-1 states about the general history
and activities of the Bomb Squad. Additionally, he may testify about his activities
as a Bomb Squad gang member and the following general areas:
• CGM-5 has been a Bomb Squad member since approximately age 13;
• CGM-5 possessed firearms in Bomb Squad gang territory;
• CGM-5 held firearms for fellow gang members;
•

CGM-5 loaned firearms to fellow gang members or associates;

• CGM-5 sold, and helped fellow gang members sell narcotics
(including, but not limited to, crack cocaine);
• On multiple occasions CGM-5 shot at rival gang members in rival
gang territory; On multiple occasions CGM-5 shot at rival gang
members in Bomb Squad territory;
6. Cooperating Gang Member 6 (“CGM-6”)
CGM-6 will reiterate much of what CGM-1 states about the general history
and activities of the Bomb Squad. Additionally, he may testify about his activities
as a Bomb Squad gang member and the following general areas:
• CGM-6 has been a Bomb Squad member since approximately 2013;
• CGM-6 possessed firearms in Bomb Squad gang territory;
• CGM-6 held firearms for fellow gang members;
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• CGM-6 participated in a Bomb Squad residential burglary with the
specific purpose of obtaining firearms for use by the gang;
• CGM-6 provided firearms to fellow gang members.
7. Cooperating Witness/Co-Conspirator 1 (“CW-1”)
CW-1 may testify about his illegal activities as it relates to the Bomb Squad:
• CW-1 supplied distribution quantities of controlled substances to
Bomb Squad members during the time period alleged in the
indictment;
• Raheem Wilson, a.k.a. “Boosie” told CW-1 that in order to have the
right to sell controlled substances in Bomb Squad territory, CW-1 had
to deal exclusively with Bomb Squad;
• Raheem Wilson, a.k.a. “Boosie” told CW-1 that CW-1 would have to
face consequences if he supplied drugs to anyone outside of Bomb
Squad;
• CW-1 has personal knowledge about Bomb Squad’s use of trap
houses to store controlled substances and firearms;
• Bomb Squad members would speak openly with CW-1 about acts of
gun violence committed by the gang and provided CW-1 with details
surrounding specific shootings;
• CW-1 personally witnessed acts of gun violence committed by Bomb
Squad members;
8. Cooperating Witness/Co-Conspirator 2 (“CW-2”)
CW-1 may testify about his illegal activities as it relates to the Bomb Squad:
• CW-2 supplied distribution quantities of controlled substances to
Bomb Squad members during the time period alleged in the
indictment;
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• CW-2 personally witnessed acts of gun violence committed by Bomb
Squad members.
B. Consensually Recorded Conversations
Consensually recorded conversations obtained during the course of the
investigation substantiate the existence of the alleged RICO conspiracy.
1. July 20, 2017 Video Purchase of Crack Cocaine from Terry Moss
On July 20, 2017, CGM-1 contacted Terry Moss a.k.a. “Lil Man,” on
Facebook Messenger in the presence of law enforcement officers. Moss instructed
CGM-1 to drive to the Cityscape Apartments. Moss walked to CGM-1’s vehicle
and got into the front passenger seat. A dark colored vehicle arrived and parked a
few spots away. Moss exited and walked to the dark colored vehicle and made
contact with the front passenger, then returned to CGM-1’s driver-side window
and provided CGM-1 with an “8-ball” of crack in exchange for $180. CGM-1 stated
that defendant Lloyd Dotson was the passenger in the dark colored vehicle.
On the audiovisual recording of this controlled buy, Moss can be heard
stating that Dotson was his source. Moss also stated that “mother (expletive)” had
sent him to a location on guys the night prior (referring to rival gang members).
CGM-1 stated that he knew the rival gang members had been out and about and
that CGM-1 kept hearing about a location on Richmond Street. Moss told CGM-1
that the Richmond location that CGM-1 was hearing about was located at
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Richmond and Linn Street by the carwash on Knoxville Avenue. CGM-1 stated
that he had been past that house before when defendant Torieuanno White, a.k.a.
“T.A.” had driven him past the area. CGM-1 stated that it looked like a hard
location to get ahold of guys (meaning shoot opposing gang members). Moss
disagreed and said that it wasn’t a hard location because you could “blow them
down” and then just run one stop light and get right on the highway. Moss then
provided CGM-1 with the address of the opposition gang members and stated that
they could go past it after dark.
2. August 2, 2017 Video Purchase of Firearm from Jahlin Wilson
On August 2, 2017, CGM-1 contacted Jahlin Wilson, a.k.a. “B.D.” on
Facebook Messenger in the presence of law enforcement officers. Wilson stated
that he was in the Harrison Homes and that he had a firearm for CGM-1. During
a recorded transaction, Wilson entered a vehicle with CGM-1 and sold CGM-1 a
.32 caliber for $250. CGM-1 was aware that Wilson had originally obtained the
firearm from another Bomb Squad member for $200. CGM-1 told Wilson that
CGM-1 knew that Wilson had “taxed” him. Wilson stated that he needed to tax
everyone at that time because he had bills to pay. CGM-1 will testify that Wilson
should not have been charging extra money for the firearm since they are both
Bomb Squad members, and CGM-1 wanted Wilson to know that CGM-1 knew
that Wilson had raised the price on the firearm.
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3. August 8, 2017 and August 9, 2017 Recordings Regarding Residential
Burglary and Theft of a Safe Containing Firearms
CGM-1 will testify that on August 8, 2017, defendant Sherman Williams,
a.k.a. “Shady” was in the Harrison Homes asking if anyone had a dolly that he
could borrow. Williams told CGM-1 that he had burglarized a house with a few
guys and that the house contained a large safe that they were unable to remove
from the home. Williams stated he was going to take other guys back to the house
to get the safe. Williams then took defendant Kenwan Crowe, Antquint Cox, and
another other Bomb Squad member with him back to the residence in a van owned
by “Dion.”
CGM-1 was told by unindicted coconspirator, Antquint Cox, that that they
successfully removed the safe, opened it, and it contained it least 9 firearms. CGM1 was also told that the safe was cleaned with bleach, wiped it down, and dumped
it in Zone 4 gang territory so that police would think Zone 4 members committed
the burglary.
On August 8, 2017, Antquint Cox asked CGM-1 to pick him up and help
Cox transport Cox’s share of firearms stolen from the safe burglary. CGM-1 drove
to the Harrison Homes and picked up Antquint Cox and Cox’s brother. Portions
of the conversation were recorded by an overhear device worn by CGM-1. On the
recording, Cox can be heard saying “Kenwan” (defendant Crowe) got a .38. Cox
also references a “500”, mentions a .357 falling out of something, and says that
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defendant Sherman Williams, a.k.a. “Shady” kept a .357 and that another Bomb
Squad member kept and “AR” (AR-15 rifle).
During the recording, CGM-1 and Cox traveled to the trap house on W.
Malone Street and met with defendants Sherman Williams, Mytrez Flora, Kenwan
Crowe, and unindicted coconspirators. Shortly after they arrived, CGM-1 and
most of the others left because the landlord arrived at the home. CGM-1, Antquint
Cox, Kenwan Crowe and Sherman Williams all left in the same vehicle. During the
ride, Cox can be heard saying that he wants to get them (guns) out because they
belong to them as well. Cox complains, saying that some guys (the current
leadership) are too thirsty and are taking their stuff. All four individuals traveled
back to the parking lot of the Harrison Homes and waited for clearance to go back
to the trap house on Malone Street. The audiovisual recording device lost power
and stopped working while CGM-1, Cox, Crowe, and Williams were waiting in
the Harrison Homes.
CGM-1 was later told by Cox that no firearms were going to be moved until
the current leadership gave approval. Cox told CGM-1 that he was upset because
he felt the current gang leadership was going to keep his share of the firearms from
the burglary. The burglary and disagreement over distribution of the firearms is
further evidenced by the following Facebook Messenger conversation between

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Antquint Cox (Facebook account “Jack Emm Preacher”) and Sherman Williams
(Facebook account “Shady ArealHeistheadd Thadyy”): 11

On August 9, 2017, CGM-1 placed a recorded call to Antquint Cox and asked
Cox if he had talked to Sherman Williams about a second planned burglary. Cox
indicated that he had talked to “Shady” on “the book” (referring to Facebook).
During the call, Cox indicated that he had not seen the safe targeted for the second
burglary, but indicated that “Kenwan” (Crowe) had seen it.

The Facebook timestamps are in Coordinated Universal Time (“UTC”). Coordinated Universal
Time is 5 hours ahead of Central Daylight Time, or 6 hours ahead of Central Standard Time.
11

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4. April 9, 2018 Recording of Conversation Between CGM-3, Roberico
Alston, and Jermontay Brock
Count One of the indictment alleges that “[o]n or about April 8, 2018,
Kentrevion Watkins, a.k.a. “Tutu,” provided a juvenile Bomb Squad member with
Kenwan Crowe’s handgun which the juvenile used to shoot and kill Anthony
Polnitz and Nasjay Murry.” R.443 at 18; Count One, ¶12(pp).
At trial CGM-3 will testify that when the homicides occurred, he was
working as an informant for the Bureau of Alcohol, Tobacco, Firearms, and
Explosives (“ATF”). CGM-3 will testify that two days prior to the homicides, he
spoke with defendant Rogers who stated that he had access to firearms and that
he was going to kill an “opp” within 15 days. Rogers did not specify who he
planned to kill. CGM-3 conveyed this information to his ATF handler on April 6,
2018.
On April 8, 2018, and after the homicides, CGM-3 received a Facebook
Messenger message from Jermontay Brock. The message was sent from Brock’s
account handle, “OC RockBlock” 12. Brock told CGM-3 that he needed to talk to
CGM-3 immediately and that it was important. CGM-3 traveled to Brock’s
residence on Millman Street in Peoria. Brock exited his house and entered into

The government will also introduce evidence that nine hours after the double-homicide,
Jermontay Brock sent defendant Raevaughn Rogers a Facebook Messenger message, stating
“Shoot Shoot Shoot”, followed by a smiley face emoji.
12

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CGM-3’s vehicle. Brock then told CGM-3 that he shot and killed two people earlier
that same day at the party near Bradley University. After meeting with Brock,
CGM-3 met with his ATF handler and summarized his conversation with Brock.
CGM-3 stated that Brock said he used Kenwan Crowe’s gun to commit the
shooting; that Crowe’s gun had a 30 round magazine; that Brock said he shot the
“opp” in the head; that he also shot and killed the female victim; that Brock stated
that defendant Kentrevion Watkins took the gun after the shooting. CGM-3’s
initial conversation with Brock was not recorded.
On April 9, 2018, CGM-3 met with Jermontay Brock again. This time,
however, law enforcement equipped CGM-3 with a recording device that
captured the conversation between CGM-3, Brock, and another individual. On the
recording, Brock talks about taking “the 30” (pistol with 30 round magazine) into
the party. CGM-3 asked Brock if a particular person had witnessed him “smoke
the nigga.” Brock stated, “when I smoked the nigga folk, it was so packed in that
bitch that you gotta get through.” CGM-3 told Brock that he shouldn’t have shot
the female and Brock stated that he shot at Polnitz head twice and the second one
went through and hit the female. CGM-3 told Brock that Kenwan Crowe shouldn’t
have given Brock the gun to do the shooting in front of a crowd like he did. Brock
stated that he didn’t know the female would get hit; that the female was at the
wrong party on the wrong night and “it wasn’t my fault that bitch went through
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his thin-ass head.” Brock states on the recording that, “Tutu” (defendant
Kentrevion Watkins) gave him the gun 13 to do the shooting. 14 Brock also stated
that Watkins didn’t take the gun back, but said that “we” put it up because there
was blood all over it. CGM-3 told Brock that he couldn’t believe they didn’t give
Brock another gun to carry, and Brock stated that defendant Mytrez Flora was
going to give him a gun.
In addition to other evidence, the government will introduce Facebook
messenger conversations between Rogers, Watkins, and others from night of the
homicides. The evidence will show that approximately 18 minutes prior to the
shooting, defendant Rogers sent a Facebook message to Kentrevion Watkins
telling him to “[s]lide in” (come into the party). Watkins responded by asking,
“why…I ain’t got no bread” (no money to pay the cover charge). Rogers then told
Watkins, “[a]in’t nun of us pay or get searched.” Watkins then asked if the party

At trial, the government will present evidence that on April 12, 2018, a Glock 22 .40 caliber
handgun with a 30 round magazine was discovered by a citizen on the 2900 block of Nebraska in
Peoria. The gun was in a plastic bag along the side of the roadway. Test shots fired from the
firearm match .40 caliber fired cartridge casings from the scene of the double-homicide.

13

The government tendered a video in discovery, from the Facebook account of Raevaughn
Rogers, depicting defendants Raevaughn Rogers, Lance Washington, and Kentrevion Watkins
pointing firearms at the recording device. The video was posted on March 22, 2018, only
seventeen days prior to the murders. The words, “Squad Members on 15” (Bomb Squad going
after rival gang, Zone 4) appear on the screen. CGM-5 will testify that he recognizes the Glock
pistol with a 30 round clip brandished by Kentrevion Watkins in this video as Kenwan Crowe’s
firearm – the weapon used to murder Polnitz and Murry.

14

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was really good, asking “[i]t’s bussin[?]” and Rogers responded, “Yea”. Rogers
sent Watkins a thumbs up emoji.
Facebook records also reflect that twenty minutes after the homicides,
defendant Kenwan Crowe’s girlfriend sent a Facebook Messenger message to
defendant Rogers, asking him, “[w]here tf is Kenwan [Crowe]…tell him to call me
now.” Rogers responded by stating, “[f]inna come”, indicating that he/they were
heading to a location. Crowe’s girlfriend responded, “[g]o there now who all with
y’all” (who is with you). Rogers responded by indicating that he was with
defendant Crowe, stating, “Me & him.”
In addition to content about the Murry and Polnitz homicides, the April 9,
2018 overhear recording contains conversation between CGM-3 and unindicted
gang member, Roberico Alston, that is highly relevant to the history of the Bomb
Squad enterprise and its various subsets, including the origin of the subset, “Marco
Movement.” On the recording, Alston states that “Marco” (Demarco Irby) was
killed inside of Alston’s house. Alston stated that “J-Money” (deceased gang
member, Jamon Lewis) killed “Marco” but it wasn’t intentional. Alston stated that
he wiped the prints off of the gun that killed Marco because he didn’t want Lewis
to go to jail for it. Alston stated on the recording that Lewis took care of Alston
every time he “hit a lick” because Lewis knew that Alston was the reason he wasn’t
in jail for killing Marco. Alston also stated that he lied to the police and told him
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he was watching YouTube and that when he looked up after hearing the shot,
Marco and the gun were already on the ground. Alston stated that, after Marco
was killed, he was afraid to be around Raheem Wilson, a.k.a. “Boosie” and other
Bomb Squad members. Alston stated that Kenwan Crowe and another gang
member got guns for him to protect himself from the rest of the gang.
On the recording, Alston discussed how the Marco Movement honors the
loss of Demarcus Irby. Alston also discussed the murder of Tyrone Jones, a.k.a.
“Rocky,” indicating that he was killed by a group of Bomb Squad rivals in a car
“sliding” in Bomb Squad territory. Alston tells CGM-3 that Alston and another
Bomb Squad member were the first ones to be out doing retaliatory shootings after
“Rocky” was murdered. Alston stated that Kenwan Crowe joined in with him to
conduct retaliatory shootings. Alston stated that he provided the gun to Kenwan
Crowe and got “the assist” the first time that Crowe did a shooting where someone
got hit.
During the conversation, Alston told CGM-3 that he just received a
Facebook Message from Jermontay Brock (prior to Brock entering the
conversation) with a picture of someone named “CJ” on it. Alston then called
Brock and Brock stated that “CJ” was going around telling everyone that Brock
killed Nasjay Murry and Anthony Polnitz. CGM-3 then picked up Brock and Brock
started talking about “CJ,” telling Alston and CGM-3 that “CJ” was there when it
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all happened. Brock stated that he was going to kill “CJ” and his girl, but later
stated he would just kill “CJ” and then have sex with his girl instead. Brock stated
that it needed to be done soon because there was no way of knowing who “CJ”
was telling about what he witnessed. CGM-3 stated on the recording that he
couldn’t believe they didn’t give Brock another gun to carry, and Brock stated that
Mytrez Flora was going to give him a gun.
C. Facebook Posts and Facebook Messenger Conversations
Facebook posts and Facebook Messenger conversations obtained during the
course of the investigation substantiate the existence of the alleged RICO
conspiracy. At trial, the government will present Facebook Messenger
conversations that demonstrate the acquisition, sale, and distribution of firearms
by Bomb Squad members on Facebook Messenger. Examples of such
conversations are as follows:

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• Kenwan Crowe (Facebook account, “Tony Romo”) conversation on
January 10, 2016:

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• Sherman Williams (Facebook account, “Shady ArealHeistheadd
Thadyy”) conversation on January 19, 2016:

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• Sherman Williams conversation on April 30, 2017:

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• Kenwan Crowe conversation on April 5, 2017:

• Kenwan Crowe conversation on July 6, 2017:

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• Sherman Williams conversation on September 3, 2017:

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• Ezra Johnson conversation on October 26, 2017:

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• Torieuanno White conversation on February 26, 2018:

Facebook Messenger conversations and posts also support the existence of
the Bomb Squad enterprise. For example, following the murder of Bomb Squad
leader Raheem Wilson, ak.a. “Boosie”on February 10, 2017, the following
messages were exchanged between defendants Kenwan Crowe (Facebook account
“Tony Romo”), Terry Moss, Raevaughn Rogers (Facebook account “Lul Poppi
L’s”), Keith Gregory (Facebook account “Kilo Get Em Gone”), and an unindicted
coconspirator:

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Also on the date Wilson was murdered, defendant Ezra Johnson posted the
following image on Facebook, depicting Wilson (second from right), defendant
Ezra Johnson (far left), defendant Eugene Haywood (center), and others, notably
wearing the same fisherman style hats that Bomb Squad members wore when they
committed a home invasion just days prior to the Tyrann Chester murder and
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during the murder of Eric Brown in Zone 4 territory. In the text that accompanied
the Facebook post, Ezra Johnson wrote, in part, “Boosie…yu was Chief folks yu
run dis bitch…I swear Boosie we gon ride yu already kno…we got dis…RIP
CHIEF BOOSIE MAGNOLIA 4eva we gon ride.”

In the days following Wilson’s murder, several defendants posted text and
images on Facebook, including posts by defendant Raevaughn Rogers wherein he
stated, “Man you made ways for a lot of Niggas out here my Nigga…Niggas don’t
kno the half” and “Boosie in da grave, [unindicted Bomb Squad member] in a cell,
but I promise we gonna hold it down em” (while displaying the hand sign for
“2300”.
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In the same month, defendant Crowe posted an image of himself with
defendant Andre Neal-Ford, bearing the text, “Loyalty, Loyalty, Loyalty, Loyalty,
Loyalty, Loyalty, #Family First.” Defendant Neal-Ford subsequently posted the
following image of himself with defendant, Eugene Haywood, and text bearing
the phrase, “My Niggas Is Savage Our Life is the Same.”

In 2017, Neal-Ford posted and image of himself in front of the Harrison
Homes, displaying the “Family First” hand sign, with accompanying text that
read, “They Gone Respect Me Like Charles Smith- Free BigBro,” referring to
Charles Smith, a.k.a. “Mano” a.k.a. “Mad Maxx” who is serving a 30 year term of
imprisonment the murder he committed on Starr Street.

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The following image of Raheem Wilson with defendant Mytrez Flora was
posted on the Facebook account of Kenwan Crowe in August 2017 and was
accompanied by the text, “RIP Boosie I miss you bro-23-CutBoys!!”:

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Facebook Messenger conversations and posts by the defendants also
demonstrate the existence of gang rivalry and Bomb Squad members’ disdain for
the “opps”: For example:
• On April 19, 2015, defendant Lance Washington posted:

• On June 17, 2015, Washington discussed how rival gang member,
Malik Everett 15 had been shot:

• On February 26, 2016, defendant Sherman Williams posted:

22 year-old Malik Everett was shot and killed in the Taft homes on June 3, 2018. At the time,
Everett lived in Zone 4 territory on Ketelle Street in Peoria, the same street where Eric Brown was
murdered.
15

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D. The Acts of Violence
This section sets forth various acts the government intends to prove up as
part of the conspiracy. The acts are set forth in chronological order and provide (1)
a short factual summary which sets forth some of the evidence the government
intends submit to prove the act occurred and link it to the Bomb Squad, and (2) a
short description of the proposed witnesses’ testimony. 16 This section does not
include every act about which the government intends to elicit testimony or
introduce evidence. As discussed above, the cooperating gang members will
testify to other violent acts committed by Bomb Squad gang members during the
course of this conspiracy. Likewise, the government intends to introduce evidence
of prior predicate offenses to which defendants entered guilty pleas, and evidence
of gun and drug sales and the illegal possession of firearms and controlled
substances by various defendants.
(1) Murder of Eric Brown June 23, 2013 (Overt Act (a))
On June 23, 2013, Eric Brown, a.k.a “Greedy,” an associate of the rival gang
Zone 4, was shot in the heart with a .22 caliber bullet by Eugene HAYWOOD,
a.k.a., “Nunu,” while at 1830 W. Kettelle St., in Zone 4 territory. Brown did not die

As it is outside the scope and purpose of this pleading, this section does not detail the additional
evidence the government will introduce to prove the acts referenced herein, i.e., eyewitness
testimony, law enforcement testimony, expert testimony, ballistics, photographs, maps,
surveillance video; firearms, ammunition, and other physical evidence. Further, the Facebook
media referenced herein represents only a small sample of the social media the government
intends to introduce at trial.

16

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immediately. He was taken to the hospital and, while on the gurney, told police
that he did not know who shot him. He stated that he was standing on the
sidewalk on Kettelle Street when a black male in a black t-shirt with short hair shot
him and then ran east toward Western Avenue, into Bomb Squad territory. The
bullet hit Brown’s left forearm and went into his left side, striking his heart. This
incident is documented as Peoria Police Department incident 13-13617.
Police reviewed surveillance camera footage from a nearby business and
saw at approximately 4:17 PM what appeared to be a black male in a dark colored
shirt and light colored longer shorts appear in camera view from the odd side alley
of Kettelle. The subject walks up the east side of 1831 Kettelle, a vacant home. After
the male disappears from view behind the side of the house, a few moments later
the video shows a group of 3-4 people outside of 1830 Kettelle on the porch scatter
and run. A male then comes back out from the side of 1831 Kettelle into view.
Another male who appears to be a black male in a dark shirt and medium colored
pants wearing a light colored safari hat can be seen riding a bike out of the alley
headed westbound. The male in the safari hat is on a bicycle and crosses over
Western Avenue and out of view of the camera. Another male then then appears
in the alley, on what appears to be a mountain bike, dark in color with light colored
front forks and heads westbound, also crossing Western Avenue and out of screen
shot. This male is wearing a dark colored t-shirt and longer light colored shorts.
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CGM-2 will testify that on the day of the murder he was at a house on Arago
with several other Bomb Squad members, including but not limited to, Mytrez
FLORA, Ezra JOHNSON, Torieuanno A. WHITE, Dominick L. Wilson, Zarmere
Barnes, and Raheem D. Wilson, a.k.a. “Boosie.” CGM-2 will state that HAYWOOD
came to the house and was looking for a gun because he had been cutting through
the “Zone” (Zone 4 territory) when was chased. HAYWOOD asked Raheem
Wilson, a.k.a. “Boosie,” for a gun. The only person that had a gun at the time was
Zarmere Barnes, who gave his .22 to HAYWOOD. CGM-2 stated that he saw
Barnes give the gun to HAYWOOD and heard Wilson tell Ezra JOHNSON to go
with HAYWOOD. CGM-2 stated that he knew HAYWOOD rode a bike during the
shooting and returned to the house afterward. He stated that Zarmere Barnes
buried the gun after it was used, but later unburied it. Barnes then kept the gun
until it was located at Dominick Wilson’s apartment by Police. HAYWOOD has
talked openly with other Bomb Squad members, including CGM-2, about the
homicide.
CGM-3 was locked up in the Illinois Department of Corrections, Shawnee,
in 2013 and 2014, with HAYWOOD. When they were incarcerated together,
HAYWOOD spoke openly about the murder of Eric Brown. HAYWOOD spoke
about riding his bike and used a .22 caliber gun to kill “Greedy.” HAYWOOD told
him that he shot Brown because he was from the “Zone” (Zone 4 territory).
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CGM-1 will testify that after the murder of Brown, both CGM-1 and
HAYWOOD were inmates together at the Peoria County jail. HAYWOOD
informed CGM-1 that he had shot and killed Brown. Haywood said he had
possession of a “deuce deuce” (.22 Caliber gun). HAYWOOD took his sister's bike
to the 1800 block of Kettelle where he located the party. HAYWOOD began to fire
rounds at the front of the house porch area where Brown was located. After the
shooting, he fled the area on the bike. CGM-1 will stated that, after the murder,
Bomb Squad members began to get shot at in retaliation. CMG-1 reported he was
shot at three or more times following the murder of Brown.
CGM-4 will state that HAYWOOD has spoken openly about the murder of
Brown. CGM-4 will state that HAYWOOD talked about how he came up on the
side of a house where he began shooting at Brown who was standing on a front
porch.
CGM-5 will testify that HAYWOOD has personally discussed the murder
of Eric Brown with CGM-5 and admitted that he was the shooter. HAYWOOD
told CGM-5 that HAYWOOD was chased prior to the murder by John Moore and
other Zone 4 gang members.
CGM-6 will also testify that HAYWOOD bragged to CGM-6 that he had
killed “Greedy” (Eric Brown).

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CW-1 will also testify that Haywood personally told him that he had killed
Eric Brown. Further, Ezra JOHNSON has told CW-1 that he was with HAYWOOD
when HAYWOOD killed brown.
(2) Tyrann Chester Murder July 15, 2013 (Overt Act (c))
On July 15, 2013, Tyrann Chester died from a single gunshot wound to the
head sustained while riding in the backseat of a vehicle rented by Antonio Scott,
a.k.a. “Wootie” and driven by Terrance Burnside, a.k.a. “Peanut.” Days prior to
the shooting, numerous Bomb Squad members committed a home invasion at
Scott’s residence on Kneer St., fueling a series of shootings in Bomb Squad
territory. Then-leader of the Bomb Squad, Raheem Wilson, a.k.a. “Boosie”,
declared war on Scott and his associate and instructed all known shooters to be
“on point.” The shooting took place in Bomb Squad territory at Stanley and
Humboldt Street. This incident is documented as Peoria Police Department
incident 13-15131.
At approximately 1:37 a.m., Peoria County Sheriff Deputy Nathan Adams
was on duty and traveling eastbound on Humboldt Street in Bomb Squad
territory. Deputy Adams was in the area in response to a call of shots fired. Near
the intersection of Humboldt Street and Griswold Street, Deputy Adams observed
a black male standing approximately one block east (in the direction of his travel)
at the intersection of Humboldt and Stanley. Deputy Adams observed that the
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subject was approximately 6’00 tall with a slim build, had dreadlock-style hair,
and was wearing all black clothing. Deputy Adams observed the subject firing a
handgun. Deputy Adams saw the muzzle flash from the discharge of the weapon
and heard the gunshots. The subject, later identified as defendant Mytrez FLORA,
saw the squad car approaching and took off running.
Within several minutes of the shooting, Deputy Adams saw defendants
Mytrez FLORA, Eugene HAYWOOD, and Lloyd DOTSON running from an area
west of the shooting. Deputy Adams yelled, “stop, police,” but the defendants
continued to run southwest across Humboldt Street and back behind the second
house from the intersection of Humboldt and Griswold. Deputy Adams pursued
the defendants around the house and detained them as they attempted to make
entry into the home from an enclosed porch on the rear of the residence.
Following a physical struggle with Deputy Adams, Mytrez FLORA was
detained and found to be in possession of a .22 caliber pistol. The gun was located
in his waistband. A second firearm, a Smith & Wesson 9mm with a defaced serial
number, was located on the ground near the porch. A magazine was inserted in
the handgun – no cartridges were in the firearm or the magazine. Lloyd
DOTSON’s fingerprints were found on the magazine.
Less than a mile away, and within twenty minutes of the shooting, Officers
of Peoria Police located the deceased body of Tyrann Chester in the backseat of an
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abandoned vehicle. The vehicle had a single bullet hole to the passenger side rear
window. Tyrann Chester had a pass-through bullet wound to his head. A single
fired bullet was located in the front driver’s side footing area. No firearms,
ammunition, or spent casings were located in the vehicle.
In a post-arrest interview, HAYWOOD admitted that he had been in
possession of a handgun, had fired it earlier in the night, and had thrown the gun
when the group was chased by the police. The firearm possessed by HAYWOOD
was never recovered.
In his post-arrest interview, DOTSON consented to giving a DNA sample
and a gunshot residue test. DOTSON admitted to possessing a black 9mm
handgun and admitted to throwing the gun in the backyard of the house where he
was detained by Deputy Adams. DOTSON also admitted to firing the gun at one
point that night but claimed that he never shot at a vehicle. As indicated above,
DOTSON’s fingerprints were on the magazine of the 9mm firearm. Notably,
forensic testing revealed that shell casings from DOTSON’s 9mm matched 9mm
shell casings located at a shooting on N. Missouri Avenue two months earlier,
where the residence of a rival gang member had been struck by gunfire.
Ultimately, FLORA, HAYWOOD, and DOTSON were each charged with,
and pled guilty to, the offense of unlawful possession of a weapon by a felon.

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At trial, CGM-1 will testify that Bomb Squad knew Tyrann Chester to be a
drug supplier from Chicago. CGM-1 will testify Tryann Chester associated with a
group in Peoria that included “Wootie” (Antonio Scott) and “Stackhouse” and
Bomb Squad had robbed them on multiple occasions. CGM-1 will state that
Raheem Wilson, a.k.a. “Boosie” had warned Bomb Squad members to be careful
because Wootie’s group was riding around the south end looking for them. On the
day of Chester’s murder, Mytrez FLORA told CGM-1 that Wootie’s group had
shot at Bomb Squad the previous night. Bomb Squad members were on high alert
and all carrying guns on the night of the Chester murder. Bomb Squad members
were on foot and spread out at the direction of Raheem Wilson. Armed shooters
were looking for Wootie’s group to drive through the south end looking for Bomb
Squad. CGM-1 will testify that, after the murder, Mytrez FLORA was happy and
told CGM-1 that they had killed Wootie’s supplier. Mytrez FLORA and Eugene
HAYWOOD both told CGM-1 that they fired shots at Chester. FLORA and
HAYWOOD stated that DOTSON also shot at Chester, but then threw his gun
down and ran away. Raheem Wilson also told CGM-1 that everyone who was
there took shots at Chester when he was murdered.
CGM-1 will also testify that Eugene HAYWOOD talked to him about the
Chester murder. HAYWOOD told CGM-1 at the Peoria County Jail that

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HAYWOOD, Lloyd DOTSON, Mytrez FLORA and Raheem Wilson were all
shooters when Chester was murdered.
CGM-2 will testify that he was previously incarcerated with Mytrez FLORA
after the Chester murder occurred and that FLORA told CGM-2 that FLORA,
HAYWOOD, and DOTSON were all involved. CGM-2 will testify that FLORA
said they shot “Sticks” (Tyrann Chester) in the head.
CGM-3 will testify that he was previously incarcerated with Eugene
HAYWOOD and that HAYWOOD spoke openly about the homicide of Tyrann
Chester. HAYWOOD told CGM-3 that he was walking with Raheem Wilson,
Lloyd DOTSON, and Mytrez FLORA when he saw a truck with “Nut” (Terrance
Burnside) in it. HAYWOOD claimed that he was shooting at the vehicle and that
he knew that someone got hit. CGM-3 will state that HAYWOOD said someone
from inside the car was shooting back with an “AK” (assault rifle).
CGM-4 will testify that they talked to Mytrez FLORA and Raheem Wilson
about the shooting of Tyrann Chester. CGM-4 will state that Raheem Wilson,
Lloyd DOTSON, Mytrez FLORA, and another Bomb Squad member had robbed
the guy from Chicago (Chester). CGM-4 will testify that Mytrez FLORA admitted
he was shooter along with Eugene HAYWOOD in the shooting death of Chester.
CGM-5 will testify that Mytrez FLORA has told CGM-5 that he was part of
the shooting and fired a weapon when Tyrann Chester was murdered. FLORA
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told CGM-5 that Lloyd DOTSON, Eugene HAYWOOD, and another Bomb Squad
member also fire weapons. FLORA told CGM-5 that he believes the other Bomb
Squad member fired the fatal bullet. The other Bomb Squad member was the one
that got away after the shooting. FLORA also told CGM-5 that FLORA
participated in a home invasion prior to the murder that contributed to the feud
that led to Chester’s murder.
CW-1 will testify that Tyrann Chester was known as a drug mule/source of
supply from Chicago for another drug dealer in the south end of Peoria known as
“Fat Man.” Defendant Ezra JOHNSON reported to Raheem WILSON that Fat Man
was making a lot of money and selling drugs in Bomb Squad territory. Raheem
Wilson decided to rob Fat Man and organized a home invasion robbery conducted
by Wilson and other Bomb Squad members. Ezra JOHNSON served as the lookout
for the robbery. This robbery resulted in several shootouts between Bomb Squad
and Fat Man’s drug dealing associates. Mytrez FLORA told CW-1 that Eugene
HAYWOOD, Mytrez FLORA, Lloyd DOTSON, and another Bomb Squad member
were involved in the murder of Tyrann Chester. FLORA told CW-1 that DOTSON
lied to the police and didn’t tell officers that the other Bomb Squad member was
involved in the shooting. FLORA told CW-1 that FLORA, DOTSON, HAYWOOD,
and the other Bomb Squad member all fired guns at the vehicle. FLORA told CW1 that HAYWOOD shot a .38, DOTSON shot a 9mm, and FLORA shot a .22 caliber.
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(3) Shooting: February 6, 2015 (Overt Act (e))
On February 6, 2015, Eugene HAYWOOD shot a firearm at a male driving
a truck in Bomb Squad territory and then passed the gun off to another Bomb
Squad member, Brian C. Tyler, to dispose of the firearm before the police arrived.
HAYWOOD was on crutches at the time. The government intends to prove up this
shooting through eyewitness testimony and certified prior convictions. In Peoria
County Case No. 15-CF-98 Eugene HAYWOOD pled guilty to unlawful use of a
weapon by a felon in that, on February 6, 2015, he possessed a handgun at a time
when he was on parole or mandatory supervised release from the Illinois
Department of Corrections pursuant to his felony conviction for the offense of
aggravated unlawful use of a weapon in Peoria County Case No. 13-CF-699; in
Peoria County Case No. 15 CM 416, Brian C. Tyler pled guilty to unlawful contact
with a street gang member in that, on February 6, 2015, he had direct contact with
a street gang member (Eugene HAYWOOD) at the 1700 Block of S. Stanley, and
had been released from the Illinois Department of Corrections on a condition of
parole or mandatory supervised released that he refrain from direct or indirect
contact with a street gang member or members.
(4) Shooting: August 24, 2015 (Overt Act (f)) (Counts 2 & 3)
On or about August 24, 2015, Torieuanno WHITE, a.k.a. “T.A.,” and CGM2 conspired to shoot rival gang member, Victim A, at a party on California Street
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in rival gang territory. This shooting was documented in Peoria Police Department
investigation 15-17185. CGM-2 will testify that he was at a party with Torieuanno
WHITE on California Avenue. CGM-2 and WHITE saw a rival gang member from
Moe Block. CGM-6 later arrived with a firearm. WHITE already had a firearm.
CGM-2 and WHITE shot at Victim A. ShotSpotter confirms that at 10:54 PM on
August 24, 2015, multiple shots were fired at 1813 N. California Avenue.
(5) Shooting: Fall 2015 (Overt Act (h)) (Counts 4 & 5)
On or about Fall 2015, Sherman WILLIAMS, a.k.a. “Shady,” attempted to
murder rival gang member (Zone 4), Kamry Harris (Victim B), when he shot at
Harris as he sat on his front porch near the intersection of Proctor and
Westmoreland in Zone 4 territory. CGM-3 will testify that he was present with
Orlando Laney and WILLIAMS. CGM-3 will testify that WILLIAMS shot at Harris
and then all three BOMB SQUAD members ran back to WILLIAMS’s aunt’s house
on Griswold house.
Notably, on January 10, 2018, Kamry Harris was murdered in Bomb Squad
territory when he was shot, execution style, as he sat in his vehicle while it was
being repaired by David Babcock, a 72 year-old resident of the area. After
murdering Harris, the shooter turned to Babcock and shot him in the face. Babcock
remained in critical condition until he perished from his injuries on September 27,
2018.
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(6) Shooting: January 3, 2016 (Overt Act (i)) (Counts 6 & 7)
On or about January 3, 2016, Torieuanno WHITE, a.k.a. “T.A.,” and
Quintarius Reynolds 17 shot Victim C and Victim D as they sat in a car parked in
the driveway of 1506 S. Arago Street in Bomb Squad territory. WHITE and
Reynolds shot the vehicle because they believed the passengers were “opps.” This
shooting was documented in Peoria Police Department investigation 16-178.
CGM-2 will testify that he was walking with Torieuanno WHITE and
Quintarius Reynolds when a car drove by with what they thought were “opps” in
it. CGM-2 witnessed WHITE and Reynolds shoot into the car. CGM-3 will state
that they later found out that two uninvolved females were in the car, and that no
“opps” were in the car. Afterward, CGM-2 talked to CGM-1 about the shooting
and told CGM-1 that WHITE was a shooter. After being shot, Victim C told officers
that she saw two black males shooting. ShotSpotter confirms that at 2:22 PM,
multiple shots were fired at 1503 S. Arago Street.
Images of gunshot wounds sustained by Victim C and Victim D have been
tendered in discovery.

Quintarius Reynolds, a.k.a. “Smooky”, a Bomb Squad gang member, was convicted of
aggravated battery with a firearm, attempted armed robbery, and unlawful possession of firearm
in 2017. His projected parole date is in April 2034.
17

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(7) Shooting: March 6, 2016 (Overt Act (j))
On or about March 6, 2016, Kenwan CROWE (under age 18 at the time)
attempted to murder rival gang member (Moe Block), Victim E, when he shot him
on MacQueen Street in rival gang territory. This shooting was documented in
Peoria Police Department investigation 16-4545.
CGM-2 will testify that he was in a vehicle with Kenwan CROWE and
Orlando Alexander. CROWE exited the vehicle and shot at one particular rival
gang member, but instead hit rival gang member Victim E (Moe Block) in the
upper portion of his back. CGM-3 will testify that CROWE shot with a Hi-Point
.40 caliber pistol. Physical evidence collected at the scene includes, but is not
limited to, .40 caliber casings. ShotSpotter confirms that at 1:14 AM, multiple shots
at 1021 W. MacQueen Avenue. Images of Victim E with a bullet wound to his back
have been tendered in discovery.
(8) Shooting: Spring 2016 (Overt Act (k)) (Counts 8 & 9)
On or about Spring of 2016, Kenwan CROWE (under age 18 at the time) and
Jahlin WILSON, a.k.a. “BD,” attempted to murder Victim F and Victim G when
they shot at them in rival gang territory.
CGM-3 that he drove Kenwan CROWE and Jahlin WILSON at the direction
of Jovan MCCREE to shoot at rival gang members. MCCREE ordered the shooting

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to direct police attention from Bomb Squad territory to rival gang territory to
further drug trafficking by Bomb Squad.
(9) Robbery: 2016 (Overt Act l)
CGM-2 will testify that he was a participant in an armed robbery of two
individuals in Bomb Squad territory, along with defendants Keith GREGORY,
a.k.a. “Kilo”, Torieuanno WHITE, a.k.a. “T.A.”, and Quintarius Reynolds. CGM-2
will testify that the gang members walked past two Caucasian males that offered
to sell them cannabis. CGM-2 will testify that White wanted to rob the males; that
Keith Gregory held the victims at gunpoint while Quintarius Reynolds took a
bottle of alcohol, a phone, and some cannabis from them.
(10) Shooting: May 7, 2016 (Overt Act (m)) (Counts 10 & 11)
On or about May 7, 2016, Andre NEAL-FORD, a.k.a. “Monkey Man,” shot
at a vehicle he believed to be occupied by rival gang members (Victim H) driving
near the intersection of Arago Street and Humboldt Street in Bomb Squad
territory.

This shooting was documented in Peoria Police Department

investigation 16-9079.
CGM-1 will testify that during the summer of 2016, CGM-1, Andre NEALFORD, Kenwan CROWE, and two additional Bomb Squad members were posted
up on Arago and Humboldt. One gang member had a .357 caliber firearm, and
NEAL-FORD had a .40 caliber firearm. A vehicle drove by and Kenwan CROWE
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said there were Moe Block members in the car. One gang member was handling
with his .357 and accidentally fired a round near CGM-1’s face so they scattered
and waited for the police to clear out of the area. A short while later, the same
group met back up at Arago and Humboldt. CROWE told NEAL-FORD to give
him the .40 because NEAL-FORD wasn't a real shooter. NEAL-FORD kept the
firearm and said he was a shooter. The same “opp” car came by a second time, and
CROWE told NEAL-FORD to “blow at it”. NEAL-FORD fired multiple shots at
the car. Another gang member also fired a few rounds at the car. The shots were
fired from in front of a red house on Arago and the car was struck by gunfire.
ShotSpotter confirms that at 3:25 AM, multiple gun shots were fired at 1410 S.
Arago Street.
(11) Shooting: May 12, 2016 (Overt Act (n)) (Counts 12 & 13)
On or about May 12, 2016, Jahlin WILSON, a.k.a. “BD,” shot Victim I during
a dice game because he believed Victim I was dealing drugs in Bomb Squad
territory and not sharing the proceeds. This shooting was documented in Peoria
Police Department investigation 16-9550. CGM-2 witnessed Jahlin WILSON shoot
Victim I at the dice game. CGM-2 will describe WILSON’s clothing, the firearm
used in the shooting, and the place on the body where Victim I was shot. CGM-2
will testify that Richardson was selling a lot of drugs in the south end and making
a lot of money.
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CGM-3 will testify that Jahlin WILSON told CGM-3 that he shot Victim I at
a dice game in 2016.
CGM-5 will testify that Jahlin WILSON told CGM-3 that he shot Victim I at
a dice game in 2016. WILSON described the gun that he used to CGM-5 and told
CGM-5 what he did with the gun after the shooting. CGM-5 had previously seen
the firearm and is aware of its unique features.
(12) Shooting: June 13, 2016 (Overt Act (o)) (Counts 14 & 15)
On or about June 13, 2016, Jovan MCCREE, a.k.a. “Vano,” shot a .308 caliber
rifle at a car he believed to be occupied by rival gang members driving on Arago
Street in Bomb Squad territory. One of the bullets passed through the wall of a
residence and struck an eleven-year old girl, Victim J, in the leg. This shooting was
documented in Peoria Police Department investigation 16-12262.
CGM-5 will testify that he was present at the residence where the shooting
occurred but was inside at the time and did not personally observe the shooting.
MCCREE later told CGM-5 that MCCREE fired the .308 rifle that struck the little
girl in her home on Arago. CGM-5 will testify that Raheem Wilson, a.k.a. “Boosie”
was also present for the shooting and later told CGM-5 the details the day after the
incident, including the fact that Bomb Squad was “posted up” and waiting for the
car to come down Arago Street because Jahlin WILSON had been chased by rival
gang members in his vehicle.
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Shotspotter confirms that at 4:43 AM, multiple shots were fired at 1414 and
1417 S. Arago Street. ShotSpotter data will show that the first shots were fired from
the area in front of a house that CGM-5, CGM-3, and CGM-1 will indicate was a
Bomb Squad trap house. Shell casings from a .308 were located around the
premises of the trap house, including on the driveway where ShotSpotter geolocated the first round of shots. The .308 rifle MCCREE used in the shooting was
recovered under the porch of a neighboring house.
CGM-3 will testify that he is familiar with the .308 rifle used by MCCREE
and that CGM-3 had test fired the weapon on previous occasion to ensure that it
was functional before Bomb Squad relied on it to defend the trap house from rival
gang members.
Images of Victim J with a bullet wound to her leg have been tendered in
discovery.
(13) Shooting: July 10, 2016 (Overt Act (q)) (Counts 16 & 17)
On or about July 10, 2016, Lance WASHINGTON shot Victim K, a rival gang
member (Moe Block), after Victim K and another rival gang member left Club
Status in the early morning hours. Washington, Kenwan CROWE (under age 18 at
the time), and another Bomb Squad member conducted a stakeout near the club
and waited for the Moe Block members to exit. WASHINGTON shot first and hit

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Victim K, then CROWE started shooting. This shooting was documented in Peoria
Police Department investigation 16-14747.
CGM-1 will testify that Lance WASHINGTON personally detailed the
shooting of Victim K to CGM-1. WASHINGTON said that a Bomb Squad member
saw Moe Block members, including Victim K, inside of a club. The Bomb Squad
member notified Kenwan CROWE and Lance WASHINGTON who then
conducted a stakeout near the club. When Victim K and the other Moe Block
member exited the club, WASHINGTON and CROWE shot at Victim K.
WASHINGTON told CGM-1 that he fired the first round and that Victim K started
to fall after that first round. WASHINGTON told CGM-1 that they came from New
Street and through the cut to do the shooting. CROWE told CGM-1 the same story
and confirmed that WASHINGTON fired first.
ShotSpotter confirms that at 3:16 AM on July 10, 2016, multiple shots were
fired at 417 S. McArthur Street. A Facebook post by Kenwan CROWE on July 10,
2016, stating “Me smoky Lance em at my crib” provides further evidence that
CROWE was with WASHINGTON on the day of the shooting. Further, three days
after the shooting, Lance WASHINGTON received a Facebook message from a
female who asked, “Uk john Dillinger” (are you ok, John Dillinger?), suggesting
that WASHINGTON was claiming credit for the shooting.
Images of Victim K with bullet wounds have been tendered in discovery.
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(14) Shooting: August 28, 2016 (Overt Act (s))
On August 28, 2016, the one-month anniversary of the murder of Moe Block
associate, Aubrae Harper, Raevaughn ROGERS, a.k.a. “Lil Poppi,”(under age 18
at the time) shot at rival gang member, Victim L, in rival gang territory (Moe Block)
on East Republic Street in Peoria, Illinois. This shooting was documented in Peoria
Police Department investigation 16-18989. ShotSpotter confirms that at 10:18 PM,
a gun battle ensued on East Republic Street in a residential neighborhood.
ShotSpotter data will show that the first shots were fired from an area just south
of the Aubrae Harper memorial.
In addition to eyewitness testimony, ShotSpotter data, and physical
evidence, the government will introduce social media of Bomb Squad members
that substantiates the existence of a gang rivalry between Bomb Squad and the
Moe Block street gang. For example, the government will introduce Facebook
video of defendant Raevaughn ROGERS, a.k.a. “Poppi” in Moe Block territory, at
a purported memorial site for Deven Lee, a.k.a. “Smoka”. In the video, ROGERS
walks on the memorial and shouts, “we on Smoka shit, nigga. Fuck Smoka” while
other males make machine gun noises. ROGERS continues to state, “Fuck Smoka”
and then states, “and fuck all the “opps” that’s rocking with him,” referring to
opposition gang members that are part of Moe Block.

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In another video from the same Facebook account, ROGERS video records
fellow Bomb Squad gang member, Rashaad Flora, modeling a custom sweatshirt
bearing the words “2300” and “Marco Movement”. The sweatshirt also bears the
phrase, “GET POP LIKE WOP” and “GET SMOKED LIKE SMOKA”, referring to
the murders of Aubrae Harper, a.k.a. “Wop” and Deven Lee, a.k.a. “Smoka”,
respectively. “Poppi” narrates in the video, reading the additional lettering on the
back of the sweatshirt, “#FTO” which means “Fuck the Opps” and “#MBK” which
means “Moe Block Killer”. The image below, also from Facebook, depicts
defendant Jahlin WILSON, defendant ROGERS, and Rashaad Flora. In the image,
Wilson is gesturing the hand sign for “Boosie Gang” while ROGERS and Flora are
making the “Magnolia Block” sign. In the image, Flora is wearing the sweatshirt
referenced above.

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(15) Shooting: November 24, 2016 (Overt Act (t)) (Counts 18 & 19)
On or about November 24, 2016, Kenwan CROWE, Andre NEAL-FORD,
a.k.a. “Monkey Man,” and other BOMB SQUAD members conspired and
attempted to murder Victim L (Moe Block) when they shot a Victim L’s home
during his family Thanksgiving gathering. Deven Lee, a.k.a. “Smoka” was
murdered several weeks later on December 10, 2016, both acts committed in rival
gang territory against Moe Block members. The November 24, 2016, shooting was
documented in Peoria Police Department investigation 16-25879. ShotSpotter
confirms that at 6:43 PM, multiple were fired shots at the pertinent location in a
residential neighborhood.

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CGM-2 will testify that that Kenwan CROWE, Quintarius Reynolds, Andre
NEAL-FORD, and Lance WASHINGTON went to rival gang member (Moe Block)
Victim L’s residence and shot it up. CGM-2 talked to CROWE, REYNOLDS,
NEAL-FORD, and WASHINGTON about the shooting. CGM-2 was told that they
saw Victim L running through the house and started shooting. CGM-1 was also
told that Rashaad Flora was present for the shooting, but CGM-1 did not discuss
the shooting with Flora. An eyewitness identified Rashaad Flora from Facebook
as one of the persons members involved in the shooting. Victim L said the people
in his house saw at least three additional people outside of his residence.
In addition to cooperating gang member testimony, eyewitness testimony,
and ShotSpotter data, the government will introduce social media images,
including the following:
• The following image sent from the account of Rashaad Flora to
defendant Kenwan Crowe on November 28, 2016 (four days after the
shooting in Overt Act (t)), depicting Flora gesturing the “Magnolia
Block” hand sign and Crowe with a high capacity firearm magazine
protruding from his left pant pocket. In the message immediately
preceding the image, Rashaad Flora asks Crowe, “what’s [Victim L’s]
sister on [Facebook]?:

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(16) Shooting: March 4, 2017 (Overt Act (v))
On or about March 4, 2017, Raevaughn ROGERS, a.k.a. “Lil Poppi,” (under
age 18 at the time) fired 10 shots towards persons on East Republic in an attempt
to kill Victim L (Moe Block). Just prior to the shooting, Victim was told that “opps”
were taking pictures at the school just across from the residence and posting them
on Facebook. Victim L then saw ROGERS and Rashaad FLORA walking toward
the residence. ROGERS fired several times at a resident who was standing on the
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front porch and then turned and shot at Victim L who was on the exterior of the
east side of the house. This shooting was documented in Peoria Police Department
investigation 17-4448. ShotSpotter confirms that at 2:55 PM, multiple shots were
fired at the pertinent location in a residential neighborhood. In addition to striking
the primary target residence, bullets also hit the neighbor’s house and passed
through the wall and into the living room.
A surveillance video obtained from Glen Oak grade school depicts two
black males running from the scene. The clothing worn by the males in the video
matches the description given to police by an eyewitness.

Additionally, a Facebook Messenger conversation between ROGERS and
Flora leading up the shooting corroborates the witnesses’ statements. On
Saturday, March 4, 2017, at 8:23 AM, Rashaad Flora sent ROGERS the following
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image of Flora holding a black and silver semi-automatic handgun with a thirtyround extended magazine.

As the afternoon approached Flora and ROGERS exchanged messages to
each other to coordinate a meeting, i.e. “is u walking?”, “Yhu passed da
courthouse?”, “nope”, “Damn better be pass da bus station.” Then at 1:29 PM,
Flora placed a phone call to Rogers that lasted 13 seconds. Approximately an hour
and 1/2 later, at 2:54 PM, the above referenced shooting at Victim L took place on
East Republic.
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(17) Shooting: March 24, 2017 (Overt Act (w)) (Counts 20 &21)
On or about March 24, 2017, Kenwan CROWE shot at Victim L (Moe Block),
in rival gang territory on Nebraska Street in Peoria, Illinois. This shooting was
documented in Peoria Police Department investigation 17-5958. On the day of the
shooting, Victim L (Moe Block) was in possession of a firearm and at a memorial
for murdered Moe Block member, Deven Lee, “a.k.a. “Smoka.” Victim L reported
that he carries a gun because he knows that Bomb Squad is trying to kill him. As
Victim L was walking away from the memorial, he noticed two males wearing
hoods. After noticing the males, Victim L heard shots being fired. Victim L
returned fire in the direction of the shooter. Victim L put his firearm underneath a
vehicle and then returned to Lee’s memorial. When Victim L went back to retrieve
his firearm, he was arrested by Peoria PD after removing it from under the vehicle.
CGM-2 will testify that Kenwan CROWE admitted to shooting at Victim L,
and further explained that Victim L returned fire. Bullet holes were located in a
vehicle and several houses.
(18) Shooting: April 9, 2017 (Overt Act (x)) (Counts 22 & 23)
On or about April 9, 2017, Jovan MCCREE, a.k.a. “Vano,” during an internal
gang conflict, shot at Victim M near Humboldt Street and Griswold Street in Bomb
Squad territory. This shooting was documented in Peoria Police Department

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investigation 17-7206. ShotSpotter confirms that at 1:38 AM, multiple shots were
fired at 2611 W. Humboldt.
GGM-3 will testify that he and Jovan MCCREE shot at Victim M during an
internal gang “beef”. CGM-3 and MCCREE located Victim sitting in a vehicle
located near the intersection of Griswold and Humboldt. CGM-3 and MCCREE
both shot at Victim M.
(19) Shooting: April 22, 2017 (Overt Act (y)) (Counts 24 & 25)
On or about April 22, 2017, Ezra JOHNSON, a.k.a. “Lil Wody,” shot at
Victim N, Victim O, and Victim P in rival gang territory. This shooting was
documented in Peoria Police Department investigation 17-8316. ShotSpotter
confirms that at 7:08 PM, multiple shots were fired on the 1500 Block of Kettelle
Street.
CGM-2 will testify that Bomb Squad members, including Ezra JOHNSON,
attempted to sneak up on Victim M and the others, leading to a shootout between
the Bomb Squad members and the rival gang. Ezra JOHNSON threw his gun
down as he ran away, and the rival gang members got the gun.
CGM-5 will testify that he was present with Johnson during the shooting.
CGM-5 will testify that he was with Johnson and defendant Mytrez FLORA at
Flora’s house on Starr Street. While at the house, another Bomb Squad member
arrived and reported that Zone 4 gang members had a party bus parked near the
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Proctor Center. GGM-5 and Johnson were then dropped off near the Proctor
Center. Mytrez FLORA provided a gun to Johnson; the gun belonged to Rashaad
Flora but Mytrez Flora was in possession of it at the time. CGM-5 and Johnson
then walked north to Ketelle Street and got on the opposite sides of an abandoned
residence. Johnson then shot several times at a party bus and rival gang members
standing near the bus, including Victims N, O, and P. CGM-5 observed Victim N
return fire. CGM-5 and Johnson then ran south after the shooting. CGM-5 later
hear that Johnson threw the firearm and that rival gang members retrieved it.
Victim K (see Overt Act (q)) later made a post on Facebook showing the firearm
and naming CGM-5 as being involved in the shooting.
(20) Shooting: May 2, 2017 (Overt Act (z)) (Counts 26 & 27)
On or about May 2, 2017, Lloyd DOTSON shot Victim Q in rival gang
territory (Moe Block/Sic Movement) on E. Wilson Street. This shooting was
documented in Peoria Police Department investigation 17-9188.
CGM-5 will testify that he was in the backseat of a vehicle driven by Lil’
Lloyd Dotson. Defendant Lloyd Dotson was the front seat passenger. CGM-5,
Dotson and DOTSON observed a rival gang member leaving the Circle K on
Knoxville Avenue. CGM-5, Dotson and DOTSON followed the gang member’s
vehicle. The vehicle pulled onto a side street off of Wisconsin Street a little south
of War Memorial Drive. Victim Q exited a residence and approached the rival gang
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member’s vehicle. Lil Lloyd Dotson drove past while defendant DOTSON shot at
the rival gang member. Victim Q was struck with a bullet that DOTSON fired. This
shooting took place early in 2017, after Raheem Wilson, a.ka. “Boosie” was
murdered in February of 2017. Bomb Squad believed that the rival gang member
targeted in the May 2, 2017 was responsible for Raheem Wilson’s murder. The May
2, 2017, shooting by Dotson on E. Wilson was a retaliation shooting. Dotson shot
Victim Q with the firearm that Raheem Wilson, a.k.a. “Boosie” had taken from a
rival gang member’s relative at the Brass Rail, a bar in Peoria.
Lloyd Dotson kept the firearm after shooting Victim Q in the back on May
2, 2017. Dotson later told CGM-5 that the police had recovered the firearm on a
separate incident. Indeed, at trial, the government will present evidence that
approximately three months later, on August 15, 2017, law enforcement executed
a search warrant at Dotson’s residence and located crack cocaine packaged for sale
and gang paraphernalia. See Overt Act (ii). Prior to the search, officers observed
Dotson leave the residence carrying a backpack and travel to an apartment in
another location where he was later taken into custody outside of the apartment.
Inside the apartment, officers located a 9mm pistol inside of a backpack. The
government will establish that 9mm shell casings collected from the scene of the
shooting of Victim Q on May 2, 2017, were fired from the same firearm found in
the backpack when Dotson was arrested on August 15, 2017.
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Images of a gunshot wound sustained by Victim Q have been tendered in
discovery.
(21) Shooting: May 9, 2017 (Overt Act (aa)) (Counts 28 & 29)
On or about May 9, 2017, Victim R was shot four times (arm, buttocks, midback, pelvic area) while entering a vehicle in the parking lot of the Family Food
Mart on Starr Street in Bomb Squad territory. Victim R, an employee of a bottling
company, had exited the store with a co-worker after completing a repair job on a
cooler. The coworker heard Ezra JOHNSON, a.k.a. “Lil Wody,” say, “you’re lucky,
you’re going to get a pass today, you’re working.” Moments later, Keith
GREGORY, a.k.a. “Kilo,” approached the passenger side of the vehicle and shot at
Victim R approximately 6 times. Just prior to the shooting, Antoine Ross saw
defendant Torieuanno WHITE exit the store and tell JOHNSON “there’s a
motherfucker in there that’s an opp.” This shooting was documented in Peoria
Police Department investigation 17-9722.
This incident, including the presence of defendants WHITE, JOHNSON,
FLORA, and GREGORY, and the shooting itself, was captured on surveillance
cameras located at the Food Market and Nimmos Hardware. The video footage
will show that defendant Mytrez FLORA is seated at front door of the store and
clearly notes the entry of Victim R, a rival gang member. Later, Torieuanno A.
WHITE and Ezra JOHNSON enter the store at different times to determine the
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status of Victim R. When it appears that Victim R and his coworker are finishing
up their work and preparing to leave, Ezra JOHNSON rushes to exit the store and
hurriedly motions to Torieuanno WHITE with his hands as if he wants Torieuanno
WHITE to hurry. Shortly thereafter, Torieuanno WHITE is seen walking back
across Starr Street with defendant Keith GREGORY and toward the side of the
Family Food Mart. Keith GREGORY is then seen walking from the group, pulling
out a handgun from his waistband, and shooting Victim R at point blank range.
WHITE, JOHNSON, GREGORY, Ross and others immediately flee the area and,
within seconds, Mytrez FLORA enters the view of the surveillance camera on his
bike and, while talking on his phone, rides to the side of the building and looks to
the area where the shooting had just occurred.
CGM-1 will testify that Keith T. GREGORY was at CGM-1’s house prior to
the shooting and had a .22 cal black revolver. CGM-1’s relative told him that
Torieuanno A. WHITE, Keith T. GREGORY and a third person came to house out
of breath. Keith T. GREGORY’s mother picked him up in a blue PT Cruiser. CGM1 believed that they put the gun used in the shooting in his attic. CMG-1 owned a
.38 caliber chrome handgun at the time.
CGM-1 spoke to GREGORY in person a day or two after GREGORY shot
Victim R. According to GREGORY, Torieuanno WHITE had informed him that
one of the “opps” was inside of the store and that he was a “fo” (Zone 4 Gang
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member). WHITE asked GREGORY if he had his gun on him, and GREGORY said
that he did.

Torieuanno WHITE instructed GREGORY to shoot Victim

R. GREGORY stated that he was hesitant because of nearby cameras, and that he
expressed his concerns to WHITE. GREGORY told CGM-1 that he decided to go
through with the shooting of CGM-1.
CMG-2 will testify that Torieuanno WHITE called him and said he needed
to get into his apartment in the Harrison Homes. WHITE arrived and was
sweating with his shirt off. WHITE told CMG-2 that “[Victim R]” was working at
the store on Starr Street. WHITE gave Keith GREGORY an ugly, rusty .22 caliber
gun and told him to shoot “[Victim R]”. CMG-2 stated he knows the .22 revolver
belonged to WHITE. CMG-2 knew GREGORY put the gun in CGM-1’s house on
Arago where the police later found it.
CGM-3 will testify that he was driving down Starr Street shortly after the
shooting. When CGM-3 turned south onto Arago Street, CGM-3 saw Torieuanno
WHITE and an unidentified male flagging him down. WHITE asked for a ride to
the Harrison Homes and told CGM-3 that GREGORY had just shot an “opp” at
the store.
(22) Shooting: August 6, 2017 (Overt Act (gg)) (Counts 30 & 31)
On or about August 6, 2017, Eugene HAYWOOD, a.k.a. “Nunu,” attempted
to murder Victim S by shooting Victim S because he was selling marijuana and
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making money in Bomb Squad territory. This shooting was documented in Peoria
Police Department investigation 17-17547.
CGM-4 will testify that he witnessed the Victim S shooting. CGM-4
observed Victim S yelling at some younger guys for breaking into his apartment.
CGM-4 will state that the younger guys had gone into Victim S’s apartment where
they stole cannabis. After Victim S walked off, the younger guys came over and
told CGM-4, Jahlin WILSON, Eugene HAYWOOD, and Brian TYLER, who were
all standing in a group at the time. CGM-4 saw HAYWOOD walk off around the
side of the building they were standing next to.
CGM-4 heard HAYWOOD ask the younger guys if that was him (referring
to Victim S). HAYWOOD then walked off, following Victim S. CGM-4 stated that
HAYWOOD walked off and went around the corner when he heard several
gunshots. CGM-4 then saw HAYWOOD running through the field and he saw
Victim S was shot in the leg.
CGM-1 will testify that that Eugene HAYWOOD set up a home invasion of
a guy (Victim S) from the Taft Homes who was selling marijuana in the Harrison
Homes. HAYWOOD was upset because Victim S was from the Taft and not
sharing the drug profits with Harrison Homes people. HAYWOOD gave Qualin
Lewis a gun to do the home invasion. After the home invasions, Victim S came

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back to the Harrison Homes to retaliate and shoot at the Harrison Homes people.
HAYWOOD saw Victim S and shot him, striking him in the leg.
(23) Shooting: December 20, 2017 (Overt Act (ll)) (Cts 32 & 33)
On or about December 20, 2017, Kentrevion WATKINS, a.k.a. “Tutu,” yelled
“fuck your dead homey Smoka” at individuals he believed to be rival gang
members (Victim T) in a station wagon driving through Bomb Squad territory.
When the station wagon did a U-turn, WATKINS and Jovan MCCREE, a.k.a.
“Vano,” shot at the vehicle with a firearm. This shooting was documented in
Peoria Police Department investigation 17-28261. ShotSpotter confirms that at
10:01 AM, multiple shots were fired at 2524 W. Seibold.
CGM-3 will testify that Jovan McCree called CGM-3 and seemed panicked.
McCree told CGM-3 that there was a shooting and that he needed CGM-3 to pick
him up on Stanley Street. After getting picked up, McCree told CGM-3 that he was
with Kentrevion Watkins when a car with Moe Block members drove past.
Watkins yelled “fuck your dead homey Smoka”. The vehicle did a U-turn and
started driving back towards McCree and Watkins. WATKINS pulled out a gun
and started shooting at the vehicle. McCree told CGM-3 that Watkins wasn’t a
good shot, and that he had his head turned while shooting. McCree told CGM-3
that McCree also fired. McCree said that Watkins put the gun up at a house on
Griswold.
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(24) Murder: Nasjay Murry and Anthony Polnitz (Overt Act (pp))
On or about April 8, 2018, defendant Kentrevion WATKINS, a.k.a. “Tutu,”
provided Jermontay Brock, a.k.a. “O.C.” with defendant Kenwan CROWE’s
handgun. 18 Brock then used the gun shoot and kill Anthony Polnitz and Nasjay
Murry. Jermontay Brock is a juvenile. Brock was arrested for first degree murder
on April 11, 2018, prior to the return of the original indictment in the instant case
on June 21, 2018. At trial, the government will establish that Brock is a Bomb Squad
gang member and co-conspirator.
The government has tendered social media images in discovery that depict
Jermontay Brock with defendants Kentrevion WATKINS, Raevaughn ROGERS,
Jahlin WILSON, Kenwan CROWE, and Andre NEAL-FORD. In the following
image, Brock (far left) and defendant NEAL-FORD (forefront) display the “Marco
Movement” gang hand sign and the text, “Real 23” with two devil icons appears
on NEAL-FORD’s hand:

A summary of cooperating gang member testimony regarding Overt Act (pp) is set forth above
in Section IV.B.4.
18

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In another image, Brock stands with defendant CROWE while CROWE
displays the “Family First” hand sign. In yet another image, Brock stands with
defendant CROWE while CROWE displays the “Family First” hand sign. In yet
another image, Brock poses with five other individuals, including defendants
ROGERS, WATKINS, and WILSON, all who are displaying the “Magnolia 2300”
hand sign. In the following image, sent from the Facebook account of Jermontay
Brock to Kentrevion WATKINS, a.k.a. “Tutu” on March 24, 2018 (two weeks prior
to the murder of Murry and Polnitz), Brock (far right) appears with defendants

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Jahlin WILSON, Kenrevion WATKINS, Raevaughn ROGERS, and others. The text,
“23 DaYoungans” appears on the image:

On April 13, 2018, (two days after Brock was arrested), defendants Jahlin
WILSON and Raevaughn ROGERS each re-posted, on their separate accounts, a
similar photo depicting the same group of Bomb Squad members, accompanied
by the text, “Murder 1—First Degree—We had a run in da streets—We gone come
from under dis shit—omm –G.” (emphasis added). Further, on the same day of

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the murders, but later in the day, Jermontay Brock sent the following private
message to Ravaughn ROGERS:

At trial, CGM-5 will testify that he was present at the party with other Bomb
Squad members, including but not limited to, Jermontay Brock, defendant
Raevaughn ROGERS, and defendant Kentrevion WATKINS.
CGM-5 saw Anthony Polnitz, a member of the rival gang, Moe Block, enter
the party. CGM-5 saw Jermontay Brock standing on a couch, observing people in
attendance. Brock got down from the couch and started shooting. CGM-5 got on
the floor because he wasn’t sure how many people were shooting. When he got up
after the shooting, CGM-5 saw two bodies on the floor. CGM-5 tried running out
of the house but was confronted by a male with a firearm who said, “you just shot
my homie.” CGM-5 ran back into the house and upstairs with defendant
Raevaughn ROGERS. CGM-5 then jumped out of the window to flee the house.
CGM-5 will testify that Brock used defendant Kenwan CROWE’s firearm to
commit the murders. CGM-5 had seen the gun on prior occasions and knew it to
be owned by Crowe. CGM-5 had observed defendant Raevaughn ROGERS and
defendant Kentrevion WATKINS carrying CROWE’s firearm. CGM-5 was not
sure which one had given it to Brock prior to the shooting.
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CGM-5 will also testify that a day or two after the murders, CGM-5
accompanied defendants Mytrez FLORA and Ezra JOHNSON when they picked
up Jermontay Brock from his house on Millman Street. CGM-5, FLORA,
JOHNSON, and Brock then traveled together to defendant Kenwan CROWE’s
house near the Peoria Airport where they met with Kentrevion WATKINS,
Kenwan CROWE, Sherman WILLIAMS, and other Bomb Squad gang members.
CGM-5 will testify that Brock discussed the two murders with CGM-5 and
defendants FLORA, JOHNSON, WILLIAMS, WATKINS and CROWE. CGM-5
will state that all Bomb Squad members present told Brock not to discuss what
happened with anyone. Brock told the listed defendants that someone named
“[redacted]” from the Harrison Homes had witnessed the murder. CGM-5 will
testify that Anthony Polnitz was a rival gang member and that Polnitz and another
individual shot defendant Kenwan CROWE at the Harrison Homes a year prior.
CGM-5 will testify that the murder of Polnitz was a retaliation shooting.
As previously indicated, the government will introduce Facebook
messenger conversations between ROGERS, WATKINS, and others from night of
the homicides. The evidence will show that approximately 18 minutes prior to the
shooting, defendant ROGERS sent a Facebook message to Kentrevion WATKINS
telling him to “[s]lide in” (come into the party). WATKINS responded by asking,
“why…I ain’t got no bread” (no money to pay the cover charge). ROGERS then
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told WATKINS, “[a]in’t nun of us pay or get searched.” WATKINS then asked if
the party was really good, asking “[i]t’s bussin[?]” and ROGERS responded,
“Yea.” ROGERS sent WATKINS a thumbs up emoji.
Facebook records also reflect that twenty minutes after the homicides,
defendant Kenwan CROWE’s girlfriend sent a Facebook Messenger message to
defendant ROGERS, asking him, “[w]here tf is Kenwan [Crowe]…tell him to call
me now.” ROGERS responded by stating, “[f]inna come”, indicating that he/they
were heading to a location. CROWE’s girlfriend responded, “[g]o there now who
all with y’all” (who is with you). ROGERS responded by indicating that he was
with defendant CROWE, stating, “Me & him.”
V.

COCONSPIRATOR STATEMENTS

The foregoing establishes that the charged individuals and others were
members of the conspiracy and/or aided and abetted the conspiracy charged in
the Third Superseding Indictment. At trial, the government will seek to introduce
the substance of the conversations involving these individuals and other coconspirators, as well as other statements made by these individuals, which relate
to the defendants’ joint criminal activity.
The government seeks admission of these conversations, in part, under Fed.
R. Evid. 801(d)(2)(E), as statements of coconspirators made during and in
furtherance of a conspiracy. The statements made by other individuals who are
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not coconspirators are admissible to provide context for the statements made by
the conspirators. Moreover, the law is clear that a tape-recorded excerpt may be
played in its entirety, including the statements of non-conspirators, because their
statements are not offered for their truth but merely to place the coconspirator
statements in context and make them intelligible for the jury. United States v. Zizzo,
120 F.3d 1338, 1348 (7th Cir. 1997); United States v. Davis, 890 F.2d 1373, 1380 (7th
Cir. 1989).
The statements that the government proposes to offer as coconspirator
statements are too voluminous to be listed in their entirety in this proffer, but the
nature of the statements are described by category below and they are otherwise
summarized within the discovery already tendered to defense counsel. These
illustrative categories, however, are not intended to be all encompassing, but rather
they explain the premise for the admission of representative statements that fall
into such categories. These statements—which will establish the information flow
between coconspirators intended to help each perform his role—will be
introduced mostly through the testimony of cooperating defendants.
The coconspirator statements offered at trial will concern the subjects listed
below.
1. Statements regarding other members of the conspiracy, including the
following:
a. Identifying other members of the conspiracy and their roles;
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b. Identifying the structure and origin of the conspiracy;
c. Reviewing a coconspirator’s exploits;
d. Recruiting potential coconspirators;
e. The roles of participants in the conspiracy’s illegal activities;
f. Assurances that a coconspirator can be trusted to perform his
role; and
g. To report coconspirators’ status and in turn receive assurances
of assistance from coconspirators.
2. Statements to conduct or help conduct the conspiracy’s activities,
including the following:
a. The purpose behind prior criminal acts carried out by the
conspiracy;
b. To plan criminal acts by the conspiracy;
c. To instill and maintain the trust and cohesiveness of the
conspiracy;
d. To advise of the progress and accomplishments of the
conspiracy;
e. To inform or reassure the listener regarding the conspiracy’s
activities;
f. To control damage to an ongoing conspiracy; and
g. To inform and update others about the current status of the
conspiracy or a conspiracy’s progress (including failures), and
to reassure or calm the listener regarding the progress or
stability of the conspiracy.
3. Statements concerning the means used to conceal the conspiracy’s
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illegal activities.
4. Statements to others outside the conspiracy to reassure those
individuals, to seek their cooperation, and to encourage them to not
reveal incriminating information.
As is evident from the categories’ description, all such statements made by
coconspirators furthered the conspiracy. Thus, under the case law summarized
above, all such statements are properly admitted at trial as coconspirator
statements under Fed. R. Evid. 801(d)(2)(E).
VI.

CONCLUSION

The above is an outline of the evidence that the government will introduce
to establish that the charged conspiracy existed. Based upon this proffer, the
government respectfully requests that this Court find that categories of
coconspirator statements listed above, as well as coconspirator statements like
them, are admissible pending the introduction of evidence to support this proffer.

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Respectfully submitted,
UNITED STATES OF AMERICA
JOHN C. MILHISER
UNITED STATES ATTORNEY
s/ RONALD L. HANNA
RONALD L. HANNA
Assistant United States Attorney
One Technology Plaza, 4th Floor
211 Fulton Street
Peoria, Illinois 61602
Telephone: 309/671-7050
s/ Adam W. Ghrist
ADAM W. GHRIST
Assistant United States Attorney
s/ Douglas F. McMeyer
DOUGLAS F. MCMEYER
Assistant United States Attorney

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CERTIFICATE OF SERVICE
I certify that on October 3, 2019, I filed a copy of the foregoing using the
CM/ECF system, which will cause notice of the foregoing to be sent to all parties
of record.
s/Ronald L. Hanna
Ronald L. Hanna

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