kamara, gilbrilla et al indictment
TRANSCRIPT
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA
-v. -
GILBRILLA KAMARA,a/k/a ~Gibril Kamara,"a/k/a ~Anthony Smith,"a/k/a ~GK,"
a/k/a "Gibry, "a/k/a "Gee Wee,"a/k/a ~River Stallon,"
ALI SESAY,a/k/a "Aliue Sesay,"a/k/a "Alie Sesay," and
GENNOR JALLOH,a/k/a ~Chernoh Nuhu Jalloh,"
Defendants.
SEALED INDICTMENT
10 Cr.
t OCRIM ~~.4 5'7j
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COUNT ONE
NARCOTICS IMPORTATION CONSPIRACY
The Grand Jury charges:
BACKGROUND
1. During the last decade, drug trafficking
organizations based in South America have increasingly used
countries along or near the West African coast as trans-shipment
hubs for importing massive quantities of cocaine to be later
distributed in Europe or elsewhere within Africa. Through a
combination of privately owned aircraft and maritime vessels,
these organizations, predominately based in Colombia and
Venezuela, have transported hundreds of tons of cocaine, worth
billions of dollars, to places such as Guinea Bissau, Guinea
Conakry, Sierra Leone, Togo, Mali, Ghana, Nigeria and Liberia.
In so doing, representatives of these drug trafficking
organizations have often sought to bribe high-level public
officials with large cash payments and narcotics in order to
ensure the safe passage, storage, and distribution of their
cocaine shipments.
THE DEFENDANTS
2. Since at least in or about 2007, GILBRILLA KAMARA,
a/k/a "Gibril Kamara," a/k/a "Anthony Smith," a/k/a "GK," a/k/a
"Gibry," a/k/a "Gee Wee," a/k/a "River Stallon," the defendant,
has actively recruited South American drug trafficking
organizations to establish operations in various West African
countries, including Liberia, Guinea Conakry, Guinea Bissau,
Sierra Leone, and Nigeria. At the same time, KAMARA has made
efforts to corrupt and influence Government officials within the
West African region in order to establish secure locations that
such drug trafficking organizations can use to receive, store and
trans-ship cocaine, free from law enforcement intervention.
KAMARA has also distributed cocaine that he received from these
drug trafficking organizations to locations within Africa and to
Europe.
3. Since at least in or about 2007, ALI SESAY, a/k/a
"Aliue Sesay," a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a
"Chernoh Nuhu Jalloh," the defendants, worked in West Africa,
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including in Sierra Leone, on behalf of KAMARA. SESAY and JALLOH
assisted KAMARA with KAMARA's drug distribution enterprise and
with his efforts to corrupt and influence Government officials
for the benefit of South American drug trafficking organizations,
as described in paragraph 2, above.
MEANS AND METHODS OF THE CONSPIRACY
4. From in or about 2009, up to and including in or
about May 2010, GILBRILLA KAMARA, a/k/a/ ~Gibril Kamara," a/k/a
~Anthony Smith," a/k/a ~GK," a/k/a ~Gibry," a/k/a ~Gee Wee,"
a/k/a ~River Stallon," ALI SESAY, a/k/a "Aliue Sesay," a/k/a
"Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the
defendants, made efforts to influence and corrupt Government
officials in Liberia, with the goal of persuading those
officials, in exchange for payment, to allow South American drug
trafficking organizations to transport cocaine to Liberia, store
it there, and ultimately distribute it to Europe and other
locations within Africa. By in or about October 2009, KAMARA had
already devoted significant resources to his efforts to corrupt
officials in Liberia and began attempting to contact high-level
government officials whom he knew to be the Director and Deputy
Director of the Republic of Liberia National Security Agency
("RLNSA"), both of whom, unbeknownst to KAMARA, were working
jointly with the United States Drug Enforcement Administration
("DEA") in an undercover capacity ("UC-l" and ~UC-2",
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respectively). (UC-l, the Director of the RLNSA, is also the son
of the President of Liberia.)
5. From at least in or about the fall of 2009 through
in or about May 2010, GILBRILLA KAMARA, a/k/a/ "Gibril Kamara,"
a/k/a "Anthony Smith," a/k/a "GK," a/k/a "Gibry," a/k/a "Gee
Wee," a/k/a "River Stallon," ALI SESAY, a/k/a "Aliue Sesay,"
a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu
Jalloh," the defendants, exchanged a series of emails and
telephone calls and held numerous meetings with UC-l, UC-2, and a
third government official who was also working jointly with the
DEA in an undercover capacity ("UC-3") to negotiate prices and
make specific arrangements for the secure transportation of
cocaine from South America through Liberia, including, but not
limited to, a 4,000 kilogram shipment of cocaine from Colombia.
A confidential source working with the DEA (the "CS"), who was
introduced as UC-l's "partner" and confidante, was present for
many of these meetings. In the course of negotiating with UC-l,
UC-2, UC-3, and the CS, the defendants understood that the CS,
who was to be paid by the defendants in the form of cocaine,
would import a portion of his share of the cocaine to the United
States.
STATUTORY ALLEGATIONS
6. From at least in or about 2009, up to and
including in or about May 2010, GILBRILLA KAMARA, a/k/a/ "Gibril
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Kamara," a/k/a "Anthony Smith," a/k/a "GK," a/k/a "Gibry," a/k/a
"Gee Wee," a/k/a "River Stallon," ALI SESAY, a/k/a "Aliue Sesay,"
a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu
Jalloh," the defendants, each of whom will first enter the United
States in the Southern District of New York, and others known and
unknown, unlawfully,. intentionally and knowingly did combine,
conspire, confederate and agree together and with each other to
violate the narcotics laws of the united States.
7. It was a part and an object of the conspiracy that
GILBRILLA KAMARA, a/k/a/ "Gibril Kamara," a/k/a "Anthony Smith,"
a/k/a "GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River
Stallon," ALI SESAY, a/k/a "Aliue Sesay," a/k/a "Alie Sesay," and
GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the defendants, and
others known and unknown, would and did distribute a controlled
substance, to wit, five kilograms and more of mixtures and
substances containing a detectable amount of cocaine, knowing and
intending that such substances would be unlawfully imported into
the United States or into waters within a distance of 12 miles of
the coast of the United States, in violation of Sections 812,
959 (a), 960 (a) (3) and 960 (b) (1) (B) of Title 21, United States
Code.
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OVERT ACTS
8. In furtherance of the conspiracy and to effect the
illegal object thereof, the following overt acts, among others,
were committed:
a. On or about November 30, 2009, ALI SESAY,
a/k/a "Aliue Sesay," a/k/a "Alie Sesay," the defendant, met with
UC-3 in Monrovia, Liberia. During the meeting, SESAY told UC-3
that GILBRILLA KAMARA, a/k/al "Gibril Kamara," a/k/a "Anthony
Smith," a/k/a "GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River
Stallon," the defendant, wanted security and protection in
Liberia for KAMARA's Colombian drug trafficking associates, and
asked for UC-3's help in making contact with UC-3's boss, UC-I
(the Director of the RLNSA and the son of the President of
Liberia) .
b. On or about November 30, 2009, SESAY placed a
telephone call to KAMARA in the presence of UC-3. UC-3 also
spoke to KAMARA. KAMARA reiterated his intentions to establish
security for his Colombian drug trafficking associates, as SESAY
had previously described to UC-3, requested a meeting with UC-I,
and asked for UC-3's assistance in facilitating his safe travel
to Monrovia, Liberia for that meeting.
c. .On or about December 8, 2009, UC-3 met with
SESAY and GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the
defendant, at a hotel in Mamba Point, Liberia. During the
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meeting, SESAY and JALLOH indicated that KAMARA had informed them
that certain Colombian drug traffickers were currently in Morocco
and, after meeting with KAMARA, would travel to Liberia. SESAY
and JALLOH informed UC-3 that KAMARA had instructed them to
locate small rural airstrips where cocaine could be unloaded
without detection, and that KAMARA and his Colombian drug
trafficking associates wanted to transport several million
dollars worth of cocaine to Liberia on small private aircraft.
d.During the same meeting on or about December
8, 2009, JALLOH and SESAY diVUlged to UC-3 that KAMARA and his
associates had contacts and a partial ownership in a large
commercial airline that operates in the region, and that they
intended to use passenger flights departing from Monrovia to
transport the cocaine out of Liberia.
e. During the same meeting on or about December
8, 2009, JALLOH and SESAY further stated that KAMARA
and representatives of the Colombian drug traffickers would
travel to Liberia in the near future to meet with UC-l and pay
one million dollars in cash to secure protection for an initial
shipment of cocaine. JALLOH and SESAY further stated that an
additional one million dollar payment would be paid to UC-l by
KAMARA and the Colombian drug traffickers for every subsequent
flight that was able to safely deliver cocaine in Liberia.
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f. On or about March 9, 2010, KAMARA was brought
to the RLNSA headquarters building in Monrovia, Liberia by UC-3
in order to meet with UC-l and UC-2. The CS participated in the
meeting and was introduced to KAMARA as UC-l's "partner" and
confidante. At the meeting, the use of Liberia as a secure
location for receiving and trans-shipping thousand-kilogram
quantities of cocaine was discussed. The CS advised KAMARA that
if cocaine was to be used as payment in exchange for security,
the CS would want to send the cocaine to Accra, Ghana
immediately, and then place the cocaine on a flight to New York.
During the meeting, UC-l told KAMARA that all future negotiations
for security payments and coordination of the future drug
shipments would need to be handled by the CS.
g. On or about March 10, 2010, KAMARA attended a
subsequent meeting with the CS during which KAMARA discussed
specific details of his plan to bring cocaine shipments into and
through Liberia, including the type of plane that would be used,
the airport that the plane would fly into, the dangers of flying
cocaine from Bolivia and Venezuela into West Africa, and the type
of payments required for allowing the plane to fly into Liberia.
h. During the same meeting on or about March 10,
2010, KAMARA agreed that the CS would receive part of the payment
in the form of cocaine, which the CS indicated would be
transported to Ghana, and then to the united States for
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distribution. KAMARA also stated that the first flight into
Liberia would be carrying 4,000 kilograms of cocaine. At the end
of the meeting, KAMARA made additional inquiries as to whether
UC-1 and the CS could control Sierra Leone as well, and stated
that if one can control Liberia and Sierra Leone, "the sky's the
limit."
i. On or about March 31, 2010, KAMARA sent the
CS two scanned passports, via electronic mail, of individuals
KAMARA later described as decision-makers in a specific Colombian
drug trafficking organization, so that the CS could secure a visa
for these individual to travel to Liberia in order to pay UC-1
and the CS for the safe passage through Liberia of the
organization's cocaine.
j. On or about May 19, 2010, JALLOH met with UC
3 and the CS in Monrovia, Liberia, and JALLOH reaffirmed his
understanding of the agreement, as the CS and KAMARA had
discussed, to fly cocaine into Liberia, and that a portion of
that cocaine (which represented the payment to the CS) would then
be sent to the United States and to Europe. During that same
meeting, JALLOH stated that the initial down payment for safe
passage of the cocaine through Liberia had been redirected to
Dakar, Senegal by the Colombian drug trafficking organization,
but that JALLOH and KAMARA were selling cocaine in Europe and
Sierra Leone to generate more cash revenue to pay UC-1 the
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previously promised down payment to secure the safe passage of
the cocaine.
k. On or about May 19, 2010, SESAY spoke on the
telephone with JALLOH in the presence of UC-3 and the CS, about
their plan to facilitate cocaine shipments from Liberia to Ghana
and the United States.
1. On or about May 19, 2010, JALLOH told the CS
during a telephone call that KAMARA wished to assure everyone in
Liberia that KAMARA, JALLOH, and SESAY were fully supportive of
the plan to use Liberia as a tran-shipment point for the
distribution of cocaine to the united States, Europe, and other
parts of Africa.
m. On or about May 20, 2010, KAMARA told the CS
during a telephone call that KAMARA would arrive in Liberia no
later than May 25. The CS informed KAMARA that he needed
KAMARA's help in distributing a large quantity of cocaine that
the CS had received in Liberia; KAMARA stated that he could
assist the CS and asked the CS to wait until KAMARA arrived in
Liberia on May 25. KAMARA informed the CS that KAMARA himself
also expected to receive a cocaine shipment.
n. On or about May 22, 2010, JALLOH provided UC
3 a photocopy of his passport from Sierra Leone that had the name
~Chernoh Nuhu Jalloh," in order to further KAMARA, JALLOH, and
SESAY's efforts to distribute cocaine in Liberia.
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o. On or about May 23, 2010, KAMARA called the
CS and informed the CS that KAMARA would be arriving in Liberia
on May 24, 2010. During that call, KAMARA requested that the CS
arrange for his hotel room and a driver.
p. On or about May 24, 2010, KAMARA met with the
CS at a hotel in Monrovia, Liberia. The CS explained that he
would be receiving 500 kilograms of cocaine within a few days, of
which the CS would send, by commercial flight from Accra, Ghana,
200 to 250 kilograms of cocaine to the united States. The CS and
KAMARA discussed the CS's obligation to send at least 200
kilograms of cocaine to the united States and KAMARA said he
could transport the cocaine to Accra, Ghana for the CS. KAMARA
also agreed to distribute the remaining 300 kilograms of cocaine
for the CS in Europe.
q. Also on or about May 24, 2010, and following
the meeting described in paragraph (p), above, JALLOH and SESAY
joined the meeting with KAMARA and the CS. KAMARA confirmed that
he was in charge of SESAY and JALLOH, and explained to them that
the CS would receive the cocaine in Liberia within a few days,
and that KAMARA, SESAY, and JALLOH would transport some of the
cocaine to Ghana and then sell the remaining cocaine. The CS
explained that the CS would need 200 kilograms of cocaine
transported each month to the airport in Accra, Ghana, and that
the timing of the transportation must be coordinated with the
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departure of the commercial flight leaving for New York. KAMARA,
SESAY and JALLOH confirmed that they understood that the cocaine
must be delivered to the airport in Ghana on the same day that
the flight departs.
(Title 21, United States Code, Section 963.)
FORFEITURE ALLEGATION
9. As a result of committing the controlled substance
offense alleged in Count One of this Indictment, GILBRILLA
KAMARA, a/k/a/ "Gibril Kamara," a/k/a "Anthony Smith," a/k/a
"GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River Stallon," ALI
SESAY, a/k/a "Aliue Sesay," a/k/a "Alie Sesay," and GENNOR
JALLOH, a/k/a "Chernoh Nuhu Jalloh," the defendants, shall
forfeit to the United States, pursuant to 21 U.S.C. § 970, any
and all property constituting and derived from any proceeds that
the defendants obtained directly and indirectly as a result of
the said violation and any and all property used and intended to
be used in any manner or part to commit and to facilitate the
commission of the violation alleged in Count One of this
Indictment, including but not limited to, a sum of money
representing the amount of proceeds obtained as a result of the
offense described in Count One of this Indictment.
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substitute Assets Provision
10. If any of the property described above as being
subject to forfeiture, 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
e. has been commingled with other
property which cannot be divided
without difficulty;
it is the intention of the United States, pursuant to Title 21,
united States Code, Section 970, to seek forfeiture of any other
property of the defendants up to the value of the forfeitable
property.
(Title 21, United States Code, Sections 963 and 970.)
PREET BHARARAUnited States Attorney
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Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- v -
GILBRILLA KAMARA,ALI SESAY,
GENNOR JALLOH,
Defendants.
SEALED INDICTMENT
10 Cr.
(Title 21, United States Code,Sections 963 and 970.)
PREET BHARARAUnited States Attorney.
A TRUE BILL
J 7 Foreperson.