hell's lovers indictment 2

8/3/2019 Hell's Lovers Indictment 2

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADO

Criminal Case No.

UNITED STATES OF AMERICA,

Plaintiff,v.

1. GEORGE H. ASKEW,2. ROMELL E. BULLOCK,3. GREGORY A. COLLINS,

4. GEORGE A. GADDY,5. DELBERT J. GARDNER,6. RICHARD W. JOHNSON,7. SHEPS H. KHAMSAHU,8. ERIC LUGO,9. LAWRENCE T. MARTIN,10. JOHNIE A. MYERS,11. DARRELL R. PARKER,12. CALVIN R. RILEY,13. COREY L. RILEY,14. THOMAS A. SCHRAH, JR.,

15. JAMES R. SWITZER, and16. CLIFFORD M. WRIGHT,

Defendants.

______________________________________________________________________________

INDICTMENT

Maintaining Drug-Involved Premises

(21 U.S.C. 856(a)(1) and (2) and (b))

Possession with Intent to Distribute Cocaine

(21 U.S.C. 841(a)(1) and (b)(1)(A),(B), and (C))

Prohibited Person in Possession of Firearm

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(18 U.S.C. 922(g)(1) and 924(a)(2))

Possession of Firearm in Furtherance of Drug Trafficking Felony

(18 U.S.C. 924(c))

Possession with Intent to Distribute Marijuana

(21 U.S.C. 841(a)(1) and (b)(1)(D))

Conspiracy to Distribute Cocaine(21 U.S.C. 846 and 841(a)(1) and (b)(1)(A),(B), and (C))

Conspiracy to Maintain Drug-Involved Premises

(21 U.S.C. 846 and 856(a)(1) and (2) and (b))

Aiding and Abetting

(18 U.S.C. 2)______________________________________________________________________________

The Grand Jury Charges:

COUNT ONEPossession with Intent to Distribute More than 28 Grams of Crack Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(B)

On or about March 17, 2009, within the State and District of Colorado, the defendant,

GEORGE H. ASKEW,

knowingly distributed and possessed with intent to distribute more than 28 grams of a substance and

mixture containing a detectable amount of cocaine base (also known as crack cocaine), a Schedule

II controlled substance.

All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(B).

COUNT TWO


18 U.S.C. 922(g)(1), 924(a)(2) and 2


GEORGE H. ASKEW,

knowingly possessed a firearm which had been transported in interstate commerce, having been

convicted previously of a crime punishable by imprisonment for a term exceeding one year.

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All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2,

Possession of Weapon by Prohibited Person.

COUNT THREEUsing a Residence for the Purpose of Distributing Controlled Substance

21 U.S.C. 856(a)(1) and (2) and (b)


GEORGE H. ASKEW,

knowingly used a place, to wit: the residence known as 3701 E. 29th Avenue, Denver, Colorado,

for the purpose of distributing quantities of a mixture and substance containing a detectable amount

of cocaine base (also known as crack cocaine), a Schedule II controlled substance.

All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b),

Maintaining drug-involved premises.

COUNT FOUR

Possession of Firearm in Furtherance of Drug Trafficking Felony

18 U.S.C. 924(c)


GEORGE H. ASKEW,

knowingly possessed a firearm in furtherance of a felony drug trafficking crime for which he could

be prosecuted in a court of the United States, to wit: knowingly to use and maintain a drug involved

premises in violation of Title 21 U.S.C. 856 (a)(1) and (2) and (b)(1), and knowingly possessing

with intent to distribute a quantity of a substance and mixture containing a detectable amount of

cocaine base, a Schedule II controlled substance commonly known as crack cocaine, in violation

of Title 21 U.S.C. 841(a)(1) and (b).

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All in violation of Title 18, United States Code, Section 924(c)(1)(A)(I), Possessing a

firearm in furtherance of drug trafficking felony offense.

COUNT FIVEPossession with Intent to Distribute Crack Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)

On or about June 18, 2009, within the State and District of Colorado, the defendant,

DELBERT J. GARDNER,

knowingly possessed with intent to distribute a quantity of a substance and mixture containing a

detectable amount of cocaine base (also known as crack cocaine), a Schedule II controlled

substance.

All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).

COUNT SIX


21 U.S.C. 841(a)(1) and (b)(1)(C)


ERIC LUGO,


detectable amount of cocaine, a Schedule II controlled substance.


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COUNT SEVEN


21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2

On or about April 14, 2010, within the State and District of Colorado, the defendant,

ERIC LUGO,



All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(c) and Title

18, United States Code, Section 2.

COUNT EIGHT


18 U.S.C. 922(g)(1), 924(a)(2) and 2

On or about October 30, 2010, within the State and District of Colorado, the defendant,

DARRELL R. PARKER,

knowingly possessed a firearm and ammunition which had been transported in interstate

commerce, having been convicted previously of a crime punishable by imprisonment for a term

exceeding one year.



COUNT NINE

Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

On or about January 29, 2009, within the State and District of Colorado, the defendant,

CALVIN R. RILEY,

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detectable amount of cocaine, a Schedule II controlled substance and intentionally did aid, abet, and

cause the same.


COUNT TEN


18 U.S.C. 922(g)(1), 924(a)(2) and 2

On or about July 10, 2009, within the State and District of Colorado, the defendant,

CALVIN R. RILEY,

knowingly possessed a firearm and ammunition which had been transported in interstate commerce,

having been convicted previously of a crime punishable by imprisonment for a term exceeding one

year.



COUNT ELEVEN

Maintaining Drug-Involved Premises

21 U.S.C. 856(a)(1) and (2) and (b)

Between on or about April 7, 2010, and on or about July 30, 2011, within the State and

District of Colorado, the defendant,

COREY L. RILEY,

knowingly used a place, to wit: the residence known as 2331 Pontiac Street, Denver, Colorado, for

the purpose of distributing quantities of a substance containing a detectable amount of cocaine, a

Schedule II controlled substance, and marijuana, a Schedule I controlled substance.

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All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b),

Maintaining drug-involved premises.

COUNT TWELVEPossession with Intent to Distribute Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT THIRTEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)

On or about May 6, 2010, within the State and District of Colorado, the defendant,

COREY L. RILEY,


detectable amount of cocaine, a Schedule II controlled substance..

All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1).

COUNT FOURTEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,


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COUNT FIFTEENPossession with Intent to Distribute Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT SIXTEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT SEVENTEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,

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COUNT EIGHTEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT NINETEEN


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT TWENTY

Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,

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COUNT TWENTY-ONE


21 U.S.C. 841(a)(1) and (b)(1)(C)


COREY L. RILEY,




COUNT TWENTY-TWO


21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2


COREY L. RILEY,



All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(c) and Title

18 Section 2.

COUNT TWENTY-THREE


21 U.S.C. 841(a)(1) and (b)(1)(C)

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COREY L. RILEY,




COUNT TWENTY-FOUR

Possession with Intent to Distribute Marijuana

21 U.S.C. 841(a)(1) and (b)(1)(D)


COREY L. RILEY,


detectable amount of marijuana, a Schedule I controlled substance.

All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(D).

COUNT TWENTY-FIVE

Possessing Firearm in Furtherance of Drug Trafficking Felony Offense18 U.S.C. 924(c)


COREY L. RILEY,

knowingly possessed a firearm in furtherance of a federal felony drug trafficking crime, to wit:

knowingly to use and maintain a drug involved premises, the residence known as 2331 Pontiac

Street, Denver, Colorado, in violation of Title 21 U.S.C. 856 (a)(1) and (2) and (b)(1).

All in violation of Title 18, United States Code, Section 924(c)(1)(A)(I), Possessing a

firearm in furtherance of drug trafficking felony offense.

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COUNT TWENTY-SIX

Possession with Intent to Distribute More than 500 grams of Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(B)18 U.S.C. 2


COREY L. RILEY,

knowingly distributed and knowingly possessed with intent to distribute more than 500 grams of

a substance and mixture containing a detectable amount of cocaine, a Schedule II controlled

substance and intentionally did aid and abet the same.

All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(B) and Title

18, United States Code, Section 2.

COUNT TWENTY-SEVEN

Conspiracy to Distribute more than 5 Kilograms of Cocaine

21 U.S.C. 846 and 841(a)(1) and (b)(1)(A)18 U.S.C. 2

Between on or about January 1, 2005 and on or about June 12, 2007, within the State

and District of Colorado and elsewhere, the defendant,

COREY L. RILEY,

knowingly agreed with Z.A. and other persons to the Grand Jury known and unknown knowingly

to possess with intent to distribute and knowingly to distribute more than five kilograms of a

substance and mixture containing a detectable amount of cocaine, a Schedule II controlled

substance, and intentionally did aid, abet, and cause the same.

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All in violation of Title 21, United States Code, Sections 846 and 841(a)(1) and (b)(1)(A)

and Title 18, United States Code, Section 2, Conspiracy to distribute more than five kilograms of

cocaine.

COUNT TWENTY-EIGHT


18 U.S.C. 922(g)(1), 924(a)(2) and 2

On or about February 13, 2009, within the State and District of Colorado, the defendant,

JAMES R. SWITZER,

knowingly possessed a firearm and ammunition which had been transported in interstate commerce,

having been convicted previously of a crime punishable by imprisonment for a term exceeding one

year.

All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2.

COUNT TWENTY-NINE


21 U.S.C. 841(a)(1) and (b)(1)(C)

On or about January 28, 2010, within the State and District of Colorado, the defendant,

CLIFFORD M. WRIGHT,



All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C) .

COUNT THIRTY


21 U.S.C. 841(a)(1) and (b)(1)(C)

On or about February 19, 2010, within the State and District of Colorado, the defendant,

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CLIFFORD M. WRIGHT,




COUNT THIRTY-ONE

Conspiracy to Use and Maintain Drug-Involved Premises

21 U.S.C. 846 and 856(a)(1) and (2) and (b)

Between on or about January 1, 2005, and on or about September 30, 2011, within the State

and District of Colorado, the defendants,

2. ROMELL E. BULLOCK,

3. GREGORY A. COLLINS,

4. GEORGE A. GADDY,

7. SHEPS H. KHAMSAHU,

9. LAWRENCE T. MARTIN,

10. JOHNIE A. MYERS,

12. CALVIN R. RILEY,

13. COREY L. RILEY, and

14. THOMAS A. SCHRAH, JR.,

knowingly agreed with one another and with others, to the Grand Jury known and unknown, to

maintain and to use a place, to wit: premises informally known as the Hells Lovers Motorcycle

Club clubhouse, for the purpose of using and distributing quantities of a substance containing a

detectable amount of cocaine, a Schedule II controlled substance, and quantities of a substance and

mixture containing a detectable amount of marijuana, a Schedule I controlled substance.

All in violation of Title 21, United States Code, Sections 846 and 856(a)(1) and (2) and (b),

and Pinkerton v. United States, 328 U.S. 640 (1946)(Pinkerton liability for the reasonably

foreseeable conduct of co-conspirators), Conspiracy to use and maintain drug-involved premises.

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COUNT THIRTY-TWO

Using and Maintaining Drug-Involved Premises

21 U.S.C. 856(a)(1) and (2) and (b)

Aiding and Abetting

18 U.S.C. 2

Between on or about January 1, 2005, and on or about December 30, 2011, within the State

and District of Colorado, the defendants,

1. GEORGE H. ASKEW,

2. ROMELL E. BULLOCK,

3. GREGORY A. COLLINS,

4. GEORGE A. GADDY,

5. DELBERT J. GARDNER,

6. RICHARD W. JOHNSON,

7. SHEPS H. KHAMSAHU,8. ERIC LUGO,

9. LAWRENCE T. MARTIN,

10. JOHNIE A. MYERS,

11. DARRELL R. PARKER,

12. CALVIN R. RILEY,

13. COREY L. RILEY,

14. THOMAS A. SCHRAH, JR.,

15. JAMES R. SWITZER, and

16. CLIFFORD M. WRIGHT,

knowingly maintained and used a place, to wit: premises informally known as the Hells Lovers

Motorcycle Club clubhouse, for the purpose of using and distributing quantities of a substance and

mixture containing a detectable amount of marijuana, a Schedule I controlled substance, and

quantities of a substance containing a detectable amount of cocaine, a Schedule II controlled

substance, and intentionally aided and abetted another to maintain and use said premises for the

purposes of using and distributing Schedule I and a Schedule II controlled substances.

All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b), and

Title 18, United States Code, Section 2, Maintaining drug-involved premises, and aiding and

abetting another to do so.

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FORFEITURE ALLEGATION

18 U.S.C. 3665

1. The allegations contained in Counts One through Thirty-Two of this Indictment are

hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to

the provisions of Title 18, United States Code, Section 3665 and Title 28, United States Code,

Section 2461(c).

2. Upon conviction of the violations alleged in Counts One through Thirty-Two of this

Indictment, each such defendant shall forfeit to the United States, pursuant to Title 18, United States

Code, Section 3665 any and all of the defendants right, title and interest in all property constituting

and derived from any proceeds obtained directly and indirectly as a result of such offense, and in

all property used, or intended to be used, in any manner or part, to commit, or to facilitate the

commission of such offense, to wit:

(A) Firearms;

(B) Approximately $16,500.00 in cash;

(C) Currency;

(D) Ammunition.

3. If any of the property described above, as a result of any act or omission of the

defendants:

a) cannot be located upon the exercise of due diligence;

b) has been transferred or sold to, or deposited with, a third

party;

c) has been placed beyond the jurisdiction of the Court;

d) has been substantially diminished in value; or

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e) has been commingled with other property which

cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 28, United States Code, Section 2461(c), to

seek forfeiture of any other property of said defendants up to the value of the forfeitable

property.

A TRUE BILL:

_Ink signature on file in the Clerks Office__GRAND JURY FOREPERSON

JOHN F. WALSHUnited States Attorney

s/ Guy TillBy: GUY TILLAssistant United States AttorneyUnited States Attorneys OfficeDistrict of Colorado

1225 17

th

Street, Suite 700Denver, CO 80202Telephone: (303) 454-0100Fax: (303) [email protected]

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DEFENDANT: 1. GEORGE H. ASKEW

YEARS OF BIRTH: 1973, 1975

ADDRESS: Denver, Colorado

COMPLAINT FILED: YES X NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER:

HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO

OFFENSE:

Count One: Possession with Intent to Distribute More than 28 Grams of Crack Cocaine21 U.S.C. 841(a)(1) and (b)(1)(B)

Count Two: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2

Count Three: Using a Residence for the Purpose of Distributing Controlled Substance21 U.S.C. 856(a)(1) and (2) and (b)

Count Four: Possession of Firearm in Furtherance of Drug Trafficking Felony18 U.S.C. 924(c)

Count Thirty-Two: Using and Maintaining Drug-Involved Premises

21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2

LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)

PENALTY:

Count One: Defendant has a prior PCS state felony conviction. NLT 10 years, NMT lifeimprisonment; a fine of NMT $8,000,000.00, or both; NLT 8 years supervised release following

any period of imprisonment; and a $100.00 special assessment.

Count Two: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.

Count Three: NMT 20 years imprisonment; a fine of NMT $500,000.00, or both; NMT 5 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.

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Count Four: NLT 5 years imprisonment; a fine of NMT $250,000.00, or both; and a $100.00special assessment.

Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.

NOTICE OF FORFEITURE

AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms

AUTHORIZED BY: Guy TillAssistant U.S. Attorney

ESTIMATED TIME OF TRIAL:

five days or less X over five days other

THE GOVERNMENT

X will seek detention in this case will not seek detention in this case

The statutory presumption of detention is applicable to this defendant.

OCDETF CASE: X Yes No

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DEFENDANT: 2. ROMELL E. BULLOCK

YEAR OF BIRTH: 1975





OFFENSE:

Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises

21 U.S.C. 846 and 856(a)(1) and (2) and (b)

Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2


PENALTY:

Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 special

assessment.






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THE GOVERNMENT




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DEFENDANT: 3. GREGORY A. COLLINS

YEAR OF BIRTH: 1954, 1958





OFFENSE:

Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises

21 U.S.C. 846 and 856(a)(1) and (2) and (b)

Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)

Aiding and Abetting18 U.S.C. 2

LOCATION OF OFFENSE: Denver County, Colorado

(COUNTY/CITY/STATE)

PENALTY:


Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.





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THE GOVERNMENT




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DEFENDANT: 4. GEORGE A. GADDY

YEAR OF BIRTH: 1945





Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)




PENALTY:




AGENT: Special Agent Jason Cole

Alcohol Tobacco and Firearms




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THE GOVERNMENT




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DEFENDANT: 5. DELBERT J. GARDNER

YEAR OF BIRTH: 1980





OFFENSE:

Count Five: Possession with Intent to Distribute Crack Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)




PENALTY:

Count Five: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.









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THE GOVERNMENT




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DEFENDANT: 6. RICHARD W. JOHNSON

YEAR OF BIRTH: 1955





OFFENSE:




PENALTY:

Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3

years supervised release following any period of imprisonment; and a $100.00 specialassessment








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THE GOVERNMENT




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DEFENDANT: 7. SHEPS H. KHAMSAHU

YEAR OF BIRTH: 1972








PENALTY:









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THE GOVERNMENT


The statutory presumption of detention is not applicable to this defendant.


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DEFENDANT: 8. ERIC LUGO

YEAR OF BIRTH: 1976





OFFENSE:

Count Six: Possession with Intent to Distribute Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Seven: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2



PENALTY:

Count Six: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.

Count Seven: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.






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THE GOVERNMENT




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DEFENDANT: 9. LAWRENCE T. MARTIN

YEAR OF BIRTH: 1958








PENALTY:


Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment







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THE GOVERNMENT




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DEFENDANT: 10. JOHNIE A. MYERS

YEAR OF BIRTH: 1954








PENALTY:


Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment







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THE GOVERNMENT


The statutory presumption of detention is applicable to this defendant.OCDETF CASE: X Yes No

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DEFENDANT: 11. DARRELL R. PARKER

YEAR OF BIRTH: 1947, 1949





OFFENSE:

Count Eight: Prohibited Person in Possession of Firearm

18 U.S.C. 922(g)(1), 924(a)(2) and 2



PENALTY:

Count Eight: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.




AUTHORIZED BY: Guy Till



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Assistant U.S. Attorney



THE GOVERNMENT




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DEFENDANT: 12. CALVIN R. RILEY

YEAR OF BIRTH: 1961





OFFENSE:

Count Nine: Possession with Intent to Distribute Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Ten: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2





PENALTY:

Count Nine: Defendant has a prior PCS state felony conviction. NMT 30 years imprisonment; afine of NMT $2,000,000.00, or both; NLT 6 years supervised release following any period ofimprisonment; and a $100.00 special assessment.

Count Ten: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.




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years supervised release following any period of imprisonment; and a $100.00 special

assessment.






THE GOVERNMENT




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DEFENDANT: 13. COREY L. RILEY

YEAR OF BIRTH: 1969





OFFENSE:

Count Eleven: Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)

Count Twelve: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Thirteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Fourteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Fifteen: Possession with Intent to Distribute Cocaine

21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Sixteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Seventeen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Eighteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Nineteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Twenty: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Twenty-One: Possession with Intent to Distribute Cocaine



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21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Twenty-Two: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2

Count Twenty-Three: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Twenty-Four: Possession with Intent to Distribute Marijuana21 U.S.C. 841(a)(1) and (b)(1)(D)

Count Twenty-Five: Possessing Firearm in Furtherance of Drug Trafficking FelonyOffense18 U.S.C. 924(c)

Count Twenty-Six: Possession with Intent to Distribute More than 500 grams ofCocaine21 U.S.C. 841(a)(1) and (b)(1)(B)18 U.S.C. 2

Count Tenty-Seven: Conspiracy to Distribute more than 5 Kilograms of Cocaine21 U.S.C. 846 and 841(a)(1) and (b)(1)(A)




PENALTY:

Count Eleven: NMT 20 years imprisonment; a fine of NMT $500,000.00, or both; NMT 5 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.

Count Twelve: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

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Count Thirteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Fourteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Fifteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Sixteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Seventeen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Eighteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Nineteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 special

assessment.

Count Twenty: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Twenty-One: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 special

assessment.

Count Twenty-Two: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT

3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Twenty-Three: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.

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Count Twenty-Four: NMT 5 years imprisonment; a fine of NMT $250,000, or both; NLT 2years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Twenty-Five: NLT 5 years imprisonment, consecutive to any other sentence; a fine ofNMT $250,00.00, or both; NMT 3 years supervised release following any period ofimprisonment; and a $100.00 special assessment.

Count Twenty-Six: NLT 5 years, NMT 40 years imprisonment; a fine of NMT $5,000,000.00,or both; NLT 4 years supervised release following any period of imprisonment; and a $100.00special assessment.

Count Twenty-Seven: NLT 10 years, NMT life imprisonment; a fine of NMT $10,000,000.00,or both; NLT 5 years supervised release following any period of imprisonment; and a $100.00special assessment.








THE GOVERNMENT


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DEFENDANT: 14. THOMAS A. SCHRAH, JR.

YEAR OF BIRTH: 1948








PENALTY:









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THE GOVERNMENT




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DEFENDANT: 15. JAMES R. SWITZER

YEAR OF BIRTH: 1983





Count Twenty-Eight: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2




PENALTY:

Count Twenty-Eight: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT3 years supervised release following any period of imprisonment; and a $100.00 special

assessment.









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THE GOVERNMENT




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DEFENDANT: 16. CLIFFORD M. WRIGHT

YEAR OF BIRTH: 1972





OFFENSE:

Count Twenty-Nine: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)

Count Thirty: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)



PENALTY:

Count Twenty-Nine: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.

Count Thirty: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 years

supervised release following any period of imprisonment; and a $100.00 special assessment.


years supervised release following any period of imprisonment; and a $100.00 specialassessment.





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THE GOVERNMENT





hell's lovers indictment 2

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