Post on 27-May-2020
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI FILiED EASTERN DIVISION
UNITED STATES OF AMERICA
Plaintiff
v
-ISRAEL ANGELES-MONTEZUMA
akIa Amigo (1)
ALAN CARDENAS akIa AI (2)
DAVID SCHAFFER (3) MICHAEL CHANDLER (4)
AMANDA YOUNG
akIa Amanda Jinkerson (5)
AMANDA MILBOURN (6)
BONNIE ORMAN (7) GUSTAVO ALVAREZ-ANGELES
akIa Guz (8)
-WILLIAM GILLMAN
akIa Mo (9)
JERRY HOPEWELL (10)
TERI FIEDLER (11)
TINA McROY (12)
RAQUEL GRAHAM (13)
MATTHEW KOENEKER (14)
TERRANCE BISE (15)
JUDY COLLINS (16)
DANIELLE WOLFF
akIa Sunshine (17)
SAMANTHA KING (18)
MICHAEL GARCIA (19)
DAVID GARCIA (20)
JENNIFER GARCIA (21)
DAMIEN GROvES (22)
VALERIE WILLIAMS (23)
MICHAEL KECK (24)
BRUCE NICHOLS (25)
SEP 2 8 2016 )
u S DistRICT COURT _) EASTERN DISTRICT QE MO
ST LOUIS)
) )
416-cr-00426 CDPJMB ) ) Ct I
) ) Ct I XV
) Ct I II ) Ct I
) Ct I
) ) Ct I ) Ct I
) Ct I
) ) Ct I
J ) Ct I
) Ct I ) Ct I
) Ct I IX XI
) Ct I IX X ) Ct I
) Ct I XIV
) Ct I
) ) Ct I VII
) Ct I VII
) Ct I
) Ct I
) Ct I
) Ct I
) Ct I XII
) Ct I XIII
1
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ROSCOE SINGER (26) ) Ct I III N V VI
DALE NORDIN (27) ) Ct I VIII
LARRY HAWKINS (28) ) Ct I XV
MARK FLOTRON (29) ) Ct I
HOLLY POLITTE (30) ) Ct I
NY TOMINACK (31) ) Ct I
JOHN BELL (32) ) Ct I II
ERIC BUHLINGER (33) ) Ct I DANIELLE DEWROCK (34) ) Ct I JOSEPH FRANCIS (35) ) Ct I
CATHERINE WOOLFORD ) Ct I akIa Cat (36) )
MARKHUSE ) Ct I akIa Marty (37) )
JULIE KOPPEN (38) and ) Ct I
JAMES RISNER (39) ) Ct I
) )
Defendants ) )
INDICTMENT
COUNT I
The Grand Jury charges that t I
A Beginning at an exact time unknown to the Grand Jury but including December
2014 and continuing thereafter to August 2016 in the Eastern District ofMissouri and
elsewhere the defendants I
ISRAEL ANGELES-MONTEZUMA alkla Amigo ALAN CARDENAS alkla AI DA VIO SCHAFFER MICIlAEL CHANDLER AMANDA YOUNG akla Amada
Jinkerson AMANDA MILBQURN BONNIE ORMAN GUSTAVO ALVAREZshyANGELES akIa Guz WILLIAM GILLMAN akIa Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER
TERRANCE BISE JUDY COLLINS DANIELLE WOLFF~ alkla Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA
2
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DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON
HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD akla Cat MARK
RUSE akla Marty and JULIE KOPPEN
did lmowingly and willfully cpnspire combine confederate and agree witheach other and other
persons Iaiown and unknown to this Grand Jury to commit offenses against the United States to
wit to distribute and possess with intent to distribute actual methamphetamine a Schedule II
controlled substance in violation ofTitle 21 United States Code Section 841(a)(1) and
B MANNER AND MEANS OF THE CONSPIRACY
The defendants accomplished and attempted to accomplish the objects of the conspiracy
in the following manner and through the following means
1 It is part of said drug trafficking conspiracy that members of the conspiracy
arranged for and did in fact distribute actual methamphetamine in the St Louis metropolitan area
and elsewhere in the Eastern District ofMissouri
2 It is part of said drug trafficking conspiracy that the distribution ofactual
methamphetamine generated significant proceedS
3 It is part of said drug trafficking conspiracy that ISRAEL ANGELESshy
MONTEZUMA aIkIa Amigo served as a source of supply for actual methamphetamine to the
conspiracy
4 It is part of said drug trafficking conspiracy that ALAN CARDENAS served as a
source of supply for actual methamphetamine to the conspiracy
5 It is part of said drug trafficking conspiracy that DAVID SCHAFFER served as a
distributor for the conspiracy
3
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6 It is part of said drug trafficking conspiracy that MICHAEL CHANDLER served
as a source ofsupply for the conspiracy
7 It is part of said drug trafficking conspiracy that after her brother DAVID
SCHAFFER went to prison AMANDA YOUNG took over his responsibilities as a distributor
for the conspiracy
8 It is part of said drug trafficking conspiracy that AMANDA MILBOURN served
as a distributor for the conspiracy
9 It is part of said drug trafficking conspiracy that GUSTAVO ALVAREZshy
ANGELES akIa Guz collected drug proceeds maintained a location at which controlled
substances were stored (commonly referred to as a stash house) and served as a distributor for
the conspiracy
1O It is part of said drug trafficking conspiracy that WILLIAM GILLMAN akIa
Mo acted as a courier and distributor for the conspiracy
11 It is part of said drug trafficking conspiracy that JERRY HOPEWELL acted as a
courier for the conspiracy
12 It is part of said drug trafficking conspiracy that TERI FIEDLER acted as a
courier for the conspiracy
13 It is part of said drug trafficking conspiracy that TINA McROY acted as a courier
and distributor for the conspiracy
14 It is part of said drug trafficking conspiracy that RAQUEL GRAHAM acted as a
courier and facilitator for the conspiracy
15 It is part of said drug trafficking conspiracy that MATTHEW KOENEKER
served as a distributor for the conspiracy
4
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middot
16 It is part of said drug trafficking conspiracy that TERRANCE BISE served as a
distributor and an enforcer for the conspiracy
17 It is part of said drug trafficking conspiracy that JUDy COLLINS served as a
courier for the conspiracy
18 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine served as a distributor for the conspiracy
19 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine introduced AMANDA YOUNG to BONNIE ORMAN who then served as
AMANDA YOUNGS alternate source of supply
20 It is part of said drug trafficking conspiracy that SAMANTHA KING served as a
facilitator for the conspiracy
21 It is part of said drug trafficking conspiracy that MICHAEL GARCIA served as a I
facilitator for the conspiracy
22 It is part of said drug trafficking conspiracy that DAVID GARCIA served as a
facilitator and distributor for the conspiracy
23 It is part ofsaid drug trafficking conspiracy that JENNIFER GARCIA served as a
courier for the conspiracy
24 It is part of said drug trafficking conspiracy that DAMIEN GROVES served as a
courier for the conspiracy
25 It is part of said drug trafficking conspiracy that VALERIE WILLIAMS served as
a facilitator and a courier for the conspiracy
26 It is part of said drug trafficking conspiracy that MICHAEL KECK served as a
distributor and facilitator and courier for the conspiracy
5
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
6
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
7
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
8
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
9
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
10
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
11
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
12
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
13
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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ROSCOE SINGER (26) ) Ct I III N V VI
DALE NORDIN (27) ) Ct I VIII
LARRY HAWKINS (28) ) Ct I XV
MARK FLOTRON (29) ) Ct I
HOLLY POLITTE (30) ) Ct I
NY TOMINACK (31) ) Ct I
JOHN BELL (32) ) Ct I II
ERIC BUHLINGER (33) ) Ct I DANIELLE DEWROCK (34) ) Ct I JOSEPH FRANCIS (35) ) Ct I
CATHERINE WOOLFORD ) Ct I akIa Cat (36) )
MARKHUSE ) Ct I akIa Marty (37) )
JULIE KOPPEN (38) and ) Ct I
JAMES RISNER (39) ) Ct I
) )
Defendants ) )
INDICTMENT
COUNT I
The Grand Jury charges that t I
A Beginning at an exact time unknown to the Grand Jury but including December
2014 and continuing thereafter to August 2016 in the Eastern District ofMissouri and
elsewhere the defendants I
ISRAEL ANGELES-MONTEZUMA alkla Amigo ALAN CARDENAS alkla AI DA VIO SCHAFFER MICIlAEL CHANDLER AMANDA YOUNG akla Amada
Jinkerson AMANDA MILBQURN BONNIE ORMAN GUSTAVO ALVAREZshyANGELES akIa Guz WILLIAM GILLMAN akIa Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER
TERRANCE BISE JUDY COLLINS DANIELLE WOLFF~ alkla Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA
2
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DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON
HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD akla Cat MARK
RUSE akla Marty and JULIE KOPPEN
did lmowingly and willfully cpnspire combine confederate and agree witheach other and other
persons Iaiown and unknown to this Grand Jury to commit offenses against the United States to
wit to distribute and possess with intent to distribute actual methamphetamine a Schedule II
controlled substance in violation ofTitle 21 United States Code Section 841(a)(1) and
B MANNER AND MEANS OF THE CONSPIRACY
The defendants accomplished and attempted to accomplish the objects of the conspiracy
in the following manner and through the following means
1 It is part of said drug trafficking conspiracy that members of the conspiracy
arranged for and did in fact distribute actual methamphetamine in the St Louis metropolitan area
and elsewhere in the Eastern District ofMissouri
2 It is part of said drug trafficking conspiracy that the distribution ofactual
methamphetamine generated significant proceedS
3 It is part of said drug trafficking conspiracy that ISRAEL ANGELESshy
MONTEZUMA aIkIa Amigo served as a source of supply for actual methamphetamine to the
conspiracy
4 It is part of said drug trafficking conspiracy that ALAN CARDENAS served as a
source of supply for actual methamphetamine to the conspiracy
5 It is part of said drug trafficking conspiracy that DAVID SCHAFFER served as a
distributor for the conspiracy
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6 It is part of said drug trafficking conspiracy that MICHAEL CHANDLER served
as a source ofsupply for the conspiracy
7 It is part of said drug trafficking conspiracy that after her brother DAVID
SCHAFFER went to prison AMANDA YOUNG took over his responsibilities as a distributor
for the conspiracy
8 It is part of said drug trafficking conspiracy that AMANDA MILBOURN served
as a distributor for the conspiracy
9 It is part of said drug trafficking conspiracy that GUSTAVO ALVAREZshy
ANGELES akIa Guz collected drug proceeds maintained a location at which controlled
substances were stored (commonly referred to as a stash house) and served as a distributor for
the conspiracy
1O It is part of said drug trafficking conspiracy that WILLIAM GILLMAN akIa
Mo acted as a courier and distributor for the conspiracy
11 It is part of said drug trafficking conspiracy that JERRY HOPEWELL acted as a
courier for the conspiracy
12 It is part of said drug trafficking conspiracy that TERI FIEDLER acted as a
courier for the conspiracy
13 It is part of said drug trafficking conspiracy that TINA McROY acted as a courier
and distributor for the conspiracy
14 It is part of said drug trafficking conspiracy that RAQUEL GRAHAM acted as a
courier and facilitator for the conspiracy
15 It is part of said drug trafficking conspiracy that MATTHEW KOENEKER
served as a distributor for the conspiracy
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middot
16 It is part of said drug trafficking conspiracy that TERRANCE BISE served as a
distributor and an enforcer for the conspiracy
17 It is part of said drug trafficking conspiracy that JUDy COLLINS served as a
courier for the conspiracy
18 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine served as a distributor for the conspiracy
19 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine introduced AMANDA YOUNG to BONNIE ORMAN who then served as
AMANDA YOUNGS alternate source of supply
20 It is part of said drug trafficking conspiracy that SAMANTHA KING served as a
facilitator for the conspiracy
21 It is part of said drug trafficking conspiracy that MICHAEL GARCIA served as a I
facilitator for the conspiracy
22 It is part of said drug trafficking conspiracy that DAVID GARCIA served as a
facilitator and distributor for the conspiracy
23 It is part ofsaid drug trafficking conspiracy that JENNIFER GARCIA served as a
courier for the conspiracy
24 It is part of said drug trafficking conspiracy that DAMIEN GROVES served as a
courier for the conspiracy
25 It is part of said drug trafficking conspiracy that VALERIE WILLIAMS served as
a facilitator and a courier for the conspiracy
26 It is part of said drug trafficking conspiracy that MICHAEL KECK served as a
distributor and facilitator and courier for the conspiracy
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON
HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD akla Cat MARK
RUSE akla Marty and JULIE KOPPEN
did lmowingly and willfully cpnspire combine confederate and agree witheach other and other
persons Iaiown and unknown to this Grand Jury to commit offenses against the United States to
wit to distribute and possess with intent to distribute actual methamphetamine a Schedule II
controlled substance in violation ofTitle 21 United States Code Section 841(a)(1) and
B MANNER AND MEANS OF THE CONSPIRACY
The defendants accomplished and attempted to accomplish the objects of the conspiracy
in the following manner and through the following means
1 It is part of said drug trafficking conspiracy that members of the conspiracy
arranged for and did in fact distribute actual methamphetamine in the St Louis metropolitan area
and elsewhere in the Eastern District ofMissouri
2 It is part of said drug trafficking conspiracy that the distribution ofactual
methamphetamine generated significant proceedS
3 It is part of said drug trafficking conspiracy that ISRAEL ANGELESshy
MONTEZUMA aIkIa Amigo served as a source of supply for actual methamphetamine to the
conspiracy
4 It is part of said drug trafficking conspiracy that ALAN CARDENAS served as a
source of supply for actual methamphetamine to the conspiracy
5 It is part of said drug trafficking conspiracy that DAVID SCHAFFER served as a
distributor for the conspiracy
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6 It is part of said drug trafficking conspiracy that MICHAEL CHANDLER served
as a source ofsupply for the conspiracy
7 It is part of said drug trafficking conspiracy that after her brother DAVID
SCHAFFER went to prison AMANDA YOUNG took over his responsibilities as a distributor
for the conspiracy
8 It is part of said drug trafficking conspiracy that AMANDA MILBOURN served
as a distributor for the conspiracy
9 It is part of said drug trafficking conspiracy that GUSTAVO ALVAREZshy
ANGELES akIa Guz collected drug proceeds maintained a location at which controlled
substances were stored (commonly referred to as a stash house) and served as a distributor for
the conspiracy
1O It is part of said drug trafficking conspiracy that WILLIAM GILLMAN akIa
Mo acted as a courier and distributor for the conspiracy
11 It is part of said drug trafficking conspiracy that JERRY HOPEWELL acted as a
courier for the conspiracy
12 It is part of said drug trafficking conspiracy that TERI FIEDLER acted as a
courier for the conspiracy
13 It is part of said drug trafficking conspiracy that TINA McROY acted as a courier
and distributor for the conspiracy
14 It is part of said drug trafficking conspiracy that RAQUEL GRAHAM acted as a
courier and facilitator for the conspiracy
15 It is part of said drug trafficking conspiracy that MATTHEW KOENEKER
served as a distributor for the conspiracy
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middot
16 It is part of said drug trafficking conspiracy that TERRANCE BISE served as a
distributor and an enforcer for the conspiracy
17 It is part of said drug trafficking conspiracy that JUDy COLLINS served as a
courier for the conspiracy
18 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine served as a distributor for the conspiracy
19 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine introduced AMANDA YOUNG to BONNIE ORMAN who then served as
AMANDA YOUNGS alternate source of supply
20 It is part of said drug trafficking conspiracy that SAMANTHA KING served as a
facilitator for the conspiracy
21 It is part of said drug trafficking conspiracy that MICHAEL GARCIA served as a I
facilitator for the conspiracy
22 It is part of said drug trafficking conspiracy that DAVID GARCIA served as a
facilitator and distributor for the conspiracy
23 It is part ofsaid drug trafficking conspiracy that JENNIFER GARCIA served as a
courier for the conspiracy
24 It is part of said drug trafficking conspiracy that DAMIEN GROVES served as a
courier for the conspiracy
25 It is part of said drug trafficking conspiracy that VALERIE WILLIAMS served as
a facilitator and a courier for the conspiracy
26 It is part of said drug trafficking conspiracy that MICHAEL KECK served as a
distributor and facilitator and courier for the conspiracy
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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6 It is part of said drug trafficking conspiracy that MICHAEL CHANDLER served
as a source ofsupply for the conspiracy
7 It is part of said drug trafficking conspiracy that after her brother DAVID
SCHAFFER went to prison AMANDA YOUNG took over his responsibilities as a distributor
for the conspiracy
8 It is part of said drug trafficking conspiracy that AMANDA MILBOURN served
as a distributor for the conspiracy
9 It is part of said drug trafficking conspiracy that GUSTAVO ALVAREZshy
ANGELES akIa Guz collected drug proceeds maintained a location at which controlled
substances were stored (commonly referred to as a stash house) and served as a distributor for
the conspiracy
1O It is part of said drug trafficking conspiracy that WILLIAM GILLMAN akIa
Mo acted as a courier and distributor for the conspiracy
11 It is part of said drug trafficking conspiracy that JERRY HOPEWELL acted as a
courier for the conspiracy
12 It is part of said drug trafficking conspiracy that TERI FIEDLER acted as a
courier for the conspiracy
13 It is part of said drug trafficking conspiracy that TINA McROY acted as a courier
and distributor for the conspiracy
14 It is part of said drug trafficking conspiracy that RAQUEL GRAHAM acted as a
courier and facilitator for the conspiracy
15 It is part of said drug trafficking conspiracy that MATTHEW KOENEKER
served as a distributor for the conspiracy
4
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middot
16 It is part of said drug trafficking conspiracy that TERRANCE BISE served as a
distributor and an enforcer for the conspiracy
17 It is part of said drug trafficking conspiracy that JUDy COLLINS served as a
courier for the conspiracy
18 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine served as a distributor for the conspiracy
19 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine introduced AMANDA YOUNG to BONNIE ORMAN who then served as
AMANDA YOUNGS alternate source of supply
20 It is part of said drug trafficking conspiracy that SAMANTHA KING served as a
facilitator for the conspiracy
21 It is part of said drug trafficking conspiracy that MICHAEL GARCIA served as a I
facilitator for the conspiracy
22 It is part of said drug trafficking conspiracy that DAVID GARCIA served as a
facilitator and distributor for the conspiracy
23 It is part ofsaid drug trafficking conspiracy that JENNIFER GARCIA served as a
courier for the conspiracy
24 It is part of said drug trafficking conspiracy that DAMIEN GROVES served as a
courier for the conspiracy
25 It is part of said drug trafficking conspiracy that VALERIE WILLIAMS served as
a facilitator and a courier for the conspiracy
26 It is part of said drug trafficking conspiracy that MICHAEL KECK served as a
distributor and facilitator and courier for the conspiracy
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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middot
16 It is part of said drug trafficking conspiracy that TERRANCE BISE served as a
distributor and an enforcer for the conspiracy
17 It is part of said drug trafficking conspiracy that JUDy COLLINS served as a
courier for the conspiracy
18 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine served as a distributor for the conspiracy
19 It is part of said drug trafficking conspiracy that DANIELLE WOLFF aka
Sunshine introduced AMANDA YOUNG to BONNIE ORMAN who then served as
AMANDA YOUNGS alternate source of supply
20 It is part of said drug trafficking conspiracy that SAMANTHA KING served as a
facilitator for the conspiracy
21 It is part of said drug trafficking conspiracy that MICHAEL GARCIA served as a I
facilitator for the conspiracy
22 It is part of said drug trafficking conspiracy that DAVID GARCIA served as a
facilitator and distributor for the conspiracy
23 It is part ofsaid drug trafficking conspiracy that JENNIFER GARCIA served as a
courier for the conspiracy
24 It is part of said drug trafficking conspiracy that DAMIEN GROVES served as a
courier for the conspiracy
25 It is part of said drug trafficking conspiracy that VALERIE WILLIAMS served as
a facilitator and a courier for the conspiracy
26 It is part of said drug trafficking conspiracy that MICHAEL KECK served as a
distributor and facilitator and courier for the conspiracy
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
6
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
8
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
9
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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27 It is part of said drug trafficking conspiracy that BRUCE NICHOLS served as a
distributor and facilitator and courier for the conspiracy
28 It is part ofsaid drug trafficking conspiracy that ROSCOE SINGER served as a
distributor for the conspiracy
28 It is part of said drug trafficking conspiracy that DALE NORDIN served as a
distributor for the conspiracy
29 It is part ofsaid drug trafficking conspiracy that LARRY HAWKINS served as a
courier for the conspiracy~
30 It is part of said drug trafficking conspiracy that MARK FLOTRON served as a
distributor for the conspiracy
31 It is part of said drug trafficking conspiracy that HOLLY POLITTE served as a
distributor for the conspiracy
32 It is part of said drug trafficking conspiracy that IVY TOMINACK served as a
facilitator and distributor for the conspiracy
33 It is part ofsaid drug trafficking conspiracy that JOHN BELL acted as a
distributor for the conspiracy
34 It is part ofsaid drug trafficking conspiracy that ERIC BUHLINGER acted as a
distributor for the conspiracy
35 It is part ofsaid drug trafficking conspiracy that DANIELLE DEWROCK acted ~
as acourierdistributor for the conspiracy
36 It is part of said drug trafficking conspiracy that JOSEPH FRANCIS acted as a
facilitator for the conspiracy
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
9
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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37 It is part of said drug trafficking conspiracy that CATHERINE WOOLFORD
aIkIa Cat served as a facilitator and courier for the conspiracy
38 It is part ofsaid drug trafficking consprracy that MARK HUSE aIkIa Marty
acted as a courier and distributor for the conspiracy
39 It is part ofsaid drug trafficking conspiracy that JULIE KOPPEN acted as a
facilitator for the conspiracy
40 It is part of said drug trafficking conspiracy that JAMES RlSNER acted as a
facilitator for the conspiracy
41 It is part of said drug trafficking conspiracy that on September 6 2014 JAMES
RlSNER
42 It is part of said drug trafficking conspiracy that on December 11 20 14 DAVID
SCHAFFER possessed actual methamphetamine with the intent to distribute it
43 It is part of said drug trafficking conspiracy that ROSCOE SINGER distributed
andor aided and abetted the distribution ofactual methamp11etamine on May 13 2015 May 15
2015 and July 292015
44 It is part of said drug trafficking conspiracy that on May 17 2015 ROSCOE
SINGER possessed actual methamphetamine with the intent to dis~bute it
45 It is part of said drug trafficking conspiracy that on Augutgtt 25 2015 MICHAEL
CHANDLER distributed actualmethamphetamine to WILLIAM GILLMAN aIkIa Mo and
CATHERINE WOOLFORD aIkIa Cat at the residence ofJOSEPH FRANCIS in Kansas City
Missouri for transport to the Eastern District ofMissouri
46 It is part of said drug trafficking conspiracy that on August 252015 AMANDAmiddot
YOUNG retrieved actual methamphetamine from the WILLIAM GILLMAN and provided the
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
8
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
9
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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same to MARK HUSE aJka Marty with the intent that MARK HUSE aJka Marty would
transport the actual methamphetamine to another location on behalf ofAMANDA YOUNG
47 It is part of said drug trafficking conspiracy that on or about August 272015
MICHAEL CHANDLER distributed actual methamphetamine to WILLIAM GILLMAN and
JERRY HOPEWELL at the residence ofJOSEPH FRANCIS in Kansas City Missouri for
transport to the Eastern District ofMissouri
48 It is part of said drug trafficking conspiracy that on August 272015 WILLIAM
GILLMAN and JERRY HOPEWELL possessed actual methamphetamine and intended to
distribute it
49 It is part ofsaid drug trafficking conspiracy that on September 132015
DANIELLE DEWROCK and her boyfriend possessed actual methamphetamine DANIELLE J
DEWROCK also possessed a firearm When approached by police DANIELLE DEWROCK
discarded the firearm in the bushes and her boyfriend fled from police discarding the actual
methamphetamine as he fled DANIELLE DEWROCK subsequently contacted AMANDA
YOUNG to report these events DANIELLE DEWROCK returned to the scene and retrieved the
firearm she had discarded in the bushes
50 It is part of said drug trafficking conspiracy that on September 14 2015
MICHAEL GARCIA and SAMANTHA KING accepted delivery of actual methamphetamine
contained in a United Parcel Service package and that they intended to distribute the actual
methamphetamine
51 It is part of said drug trafficking conspiracy that on September 242015 TERI
FIEDLER and TINA McROY possessed actual methamphetamine and intended to distribute it
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
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52 It is part of said drug traffic~g conspiracy that on September 242015
AMANDA YOUNG and JULIE KOPPEN assisted TERl FIEDLER and TINA McROY in
transporting actual methamphetamine from Kansas City Missouri to the Eastern District of
Missouri by traveling in tandem (in a separate vehicle) in an effort to maintain the security of the
shipment ofmethamphetamine and to potentially assist in the event of law enforcement
intervention
53 It is part ofsaid drug trafficking conspiracy that on November 15 2015 in
Summit County Utah JUDY COLLINS transported $9000000 in proceeds from the sale of
controlled substances in a vehicle rented by V ALERlE WlLLIAMS
54 It is part of said drug trafficking conspiracy that on November 152015 JUDY
COLLINS contacted BONNIE ORMAN and provided her (COLLINS ) personal~ identifying
information so BONNIE ORMAN could assist in securing COLLINS release fromjaiL
55 It is part of said drug trafficking conspiracy that on November 152015 BONNIE
ORMAN contacted AMANDA MILBOURN and advised AMANDA MILBOURN Judys in
jaiL BONNIE ORMAN then instructed AMANDA MILBOURN to take some information
down and help me call some bondsmen out there
56 It is part of said drug trafficking conspiracy that on November 192015 two
Hispanic males driving a red 2007 Dodge Nitro passenger vehicle registered to V ALERlE
WlLLIAMS were the subject ofa traffic stop in Dickinson County Kansas From a concealed
compartment in the Dodge Nitro investigators seized actual methamphetamine belonging to
ISRAEL ANGELES-MONTEZUMA aJkJa Amigo
57 It is part of said drug trafficking conspiracy that on December 9 2015 DALE
NORDIN possessed actual methamphetamine and intended to distribute it
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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58 It is part of said drug trafficking conspiracy that on December 142015
RAQUEL GRAHAM and MATTHEW KOENEKER possessed actual methamphetamine and
intended to distribute it
59 It is part of said drug trafficking conspiracy that on December 14~ 2015
RAQUEL GRAHAM possessed a firearm
60 It is part of said drug trafficking conspiracy that on December 142015
MATTHEW KOENEKER possessed a flIearm
61 It is part of said drug trafficking conspiracy that on or about December 14 2015
NY TOMiNACK and TERRANCE BISE agreed to accept delivery ofactual methamphetamine
sent via Federal Express
62 It is part of said drug trafficking conspiracy that on March 232016 MICHAEL
KECK possessed actual methamphetamine and intended to distribute it
63 It is part of said drug trafficking conspiracy that on April 8 2016 BRUCE
NICHOLS transported $11000000 in proceeds from the sale ofcontrolled substances from the
Eastern District ofMissouri to an unlmown final destination by way ofNevada
64 It is part of said drug trafficking conspiracy that on April 10 2016 BRUCE
NICHOLS and others known to the Grand Jury possessed actual methamphetamine with intent to
distribute it
65 It is part of said drug trafficking conspiracy that on April 27 2016 JENNIFER
GARCIA and DAMIEN GROVES were the subject ofa traffic stop in Placer County California
Investigators subsequently recovered actual methamphetamine concealed inside the door panels
of the vehicle JENNIFER GARCIA and DAMIEN GROVES were transporting the
10
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
11
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
13
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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~
methamphetamine to the Eastern District ofMissouri on behalf of DAVID GARCIA and
ISRAEL ANGELES-MONTEZUMA akIa Amigo
66 It is part of said drug trafficking conspiracy that on May 24 2016 TERRANCE
BISE agreed on behalfofISRAEL ANGELES-MONTEZUMA akIa Amigo to take delivery
ofa Federal Express box containing actual methamphetamine
67 It is part ofsaid drug trafficking conspiracy that on Jlll1e 212016 JUDY
COLLINS possessed actual methamphetamine and intended to distribute it The actual
methamphetamine was discovered in a traffic stop during which JUDY COLLINS pulled her
vehicle over directly in front ofBONNIE ORMANS residence
68 It is part of said drug trafficking conspiracy that on August 11 20 16 LARRY
HAWKlNS transported actual methamphetamine to the Eastern District ofMissouri on behalfof
ALAN CARDENAS akIa AI
69 It is part of said drug trafficking conspiracy that on August 112016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo provided $2996000 in proceeds from the sale of
controlled substances to a courier for transport to a location outside the Eastern District of
Missouri
70 It is part of said drug trafficking conspiracy that on August 26 2016 ALAN
CARDENAS akIa AI arranged to meet with a courier to collect $18500000 in drug
proceeds ALAN CARDENAS akIa AI fled on foot upon learning that the courier had been
intercepted by law enforcement
71 It is part of said dnrg trafficking conspiracy that on August 29 2016 ISRAEL
ANGELES-MONTEZUMA akIa Amigo recruited a courier to travel to Kansas City
Missouri to retrieve a quantity ofactual methamphetamine and transport the same into the
11
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
12
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
13
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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Eastern District ofMissouri for distribution The courier was intercepted in Callaway County
within the Western District ofMissouri
72 It is part of said drug trafficking conspiracy that members of the conspiracy
repeatedly used a telephone to cause ~d facilitate the distribution and possession with intent to
distribute actual methamphetamine
73 It is part of said drug trafficking conspiracy that the members of the conspiracy
employed multiple couriers to transport actual methamphetamine into the Eastern District of
Missouri
74 It is part of said drug trafficking conspiracy that the members of the conspiracy
4employed multiple couriers to transport the proceeds from the sale ofactual methamphetamine
out ofthe Eastern District ofMissouri
75 It is part of said drug trafficking conspiracy that the members of the conspiracy
maintained one or more premises within the Eastern District ofMissouri fm the purpose of
storing actual methamphetamine
All in violation ofTitle 21 United States Code Section 846
As to all defendants the amount of actual methamphetamine attributable to each as a
result ofhislher own conduct and the conduct of other conspirators knowll or reasonably
foreseeable to himlher is niore than 50 grams making the offense punishable under Title 21
United States Code Section 841 (b)(I)(A)(viii)
COUNT II
The Grand Jury further charges that
On or about December 11 2014 in Jefferson County within the Eastern District of
Missouri the defendants
12
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
13
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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DAVID SCHAFFER and JOHN BELL i
did knowingly and intentionally possess with the intent to distribute actual methamphetamine a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a) (1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue cifhis
own conduct and the conduct of co-conspirators reasonably foreseeable to him is in excess of 50
grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTll
The Grand Jury further charges that
On or about May 132015 within the Eastern District of Missouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841 (a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT IV
The Grand Jury further charges that
On or about May 152015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
i did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 2~
United States Code Section 841(a)(l) and punishable under Title 21 United States Code
Section 841(b)(I)(C)
13
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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COUNT V
The Grand Jury further charges that
On or about May 172015 within the Eastern District 6fMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally possess with the intent to distribute actual rnethamp~etamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841(b)(1)(C)
COUNT VI
The Grand Jury further charges that
On or about July 292015 within the Eastern District ofMissouri the defendant
ROSCOE SINGER
did knowingly and intentionally distribute actual methamphetamine in violation ofTitle 21
United States Code Section 841(a)(1) and punishable under Title 21 United States Code
Section 841 (b)(1 )(C)
COUNT VII
The Grand Jury further charges that
On or about September 14 2015 in St Louis City within the Eastern District of
Missouri the defendants
1flCHAEL GARCIA and SAMANTHA KING
did knowingly and intentionally possess with the intent to distribute actual rnethamphetartllne a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841 (a)(I)
and Title 18 United States Code Section 2 and
14
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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the amount ofactual methamphetamine attributable to each defendant by virtue ofhlslher
own conduct and the conduct of coconspirators reasonably foreseeable to himlher is in exqess of
50 grams making the offense punishable under Title 21 United States Code Section
841 (b)(1)(A)(viii)
COUNTVIll
The Grand Jury further charges that
On or about December 92015 within the Eastern District ofMissouri the defendant
DALE NORDIN
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841 (a)(1) and punishable under Title 21
United States Code Section 841 (b)(1)(C)
COUNT IX
The Grand Jury further charges that
On or about December 14 2015 within the Eastern District ofMissouri the defendants
RAQUEL GRAHAM and MATTHEW KOENEKER
did knowingly and intentionally possess with the intent to distribute actual methamphetanime a
Schedule II controlled substance in violation ofTitle 21 United States Code Section 841(a)(1)
and Title 18 United States Code Section 2 and
the amount ofactual methamphetamine attributable to each defendant by virtue ofhislher
I own conduct and the conduct of co-conspirators reasonably forvseeab1e to himlher is in exqess of
I 50 grams making the offense punishable under Title 21 United States Code Section
I
841(b)(1 )(A)(viii) (
15
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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C-OUNTX
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
MATTHEW KOENEKER
did knowingly and intentionally use carry and possess a fireann to wit a Hi-Point model CF380 380
caliber semi-automatic pistol serial number P8072138 in furtherance of a drug trafficking crime to-wit
possession with the intent to distribute actual methamphetamine as charged in Count IX
In violation of Title 18 United States Code Section 924 (c)(I)(A) and punishable under Title 18
United States Code Section 924(c)(1)(A)(i)
COUNT XI
The Grand Jury further charges that
On or about December 142015 within the Eastern District ofMissouri the defendant
RAQUEL GRAHAM
did knowingly and intentionally use carry and possess a fireann to wit a Smith and Wesson 9 rom
handgun serial number DSD7185 in furtherance of a drug trafficking crime to-wit possession with the
intent to distribute actual methamphetamine as charged in Count IX
In violation ofTitle 18 United States Code Section 924 (c)(1)(A) and punishable under Title 18
United States Code Section 924( c) (1)(A)(i)
COUNT XII
The Grand Jury further charges that
On or about March23 2016 in St Louis City within the Eastern District ofMis so uti the
defendant
MICHAEL KECK
16
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(l) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendanfby virtue ofhis own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(1)(A)(viii)
COUNTxm
The Grand Jury further charges that
On or about April 1 0 2016 in st Louis City within the Eastern District ofMissouri the
defendant
BRUCE NICHOLS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofhis own conduct is in excess of 50 grams- making the offense punis~able
under Title21 United States Code Section 841 (b)(1)(A)(viii)
COUNT XIV
The Grand Jury further charges that
On or about June 21 2016 in St Louis City within the Eastern District ofMissouri the
defendant
JUDy COLLINS
17
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bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 21 of 21 PageID 101
bull
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and
the amount ofactual methamphetamine involved in the offense and attributable to the
defendant by virtue ofher own conduct is in excess of 50 grams making the offense punishable
under Title 21 United States Code Section 841 (b)(l)(A)(viii)
COUNT XV
The Grand Jury further charg~s that
On or about August 112016 in Jefferson County within the Eastern District ofMissouri
the defendant
ALAN CARDENAS aka AI and LARRY HAWKINS
did knowingly and intentionally possess with the intent to distribute actual methamphetamine
in violation ofTitle 21 United States Code Section 841(a)(1) and Title 18 United States Code
Section 2 and
the amount of actual methamphetamine involved in the offense and attributable to each
defendant by virtue ofhis own conduct and the conduct ofco-conspirators reasonably
foreseeable to him is in excess of 50 grams making the offense punishable under Title 21
United States Code Section 841(b )(1)(A)(viii)
18
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FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
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YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 20 of 21 PageID 100
853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 21 of 21 PageID 101
FORFEITURE ALLEGATION
1 The allegations of Count I of this Indictment are re-alleged and by this
reference fully incorporated herein for the purpose ofalleging forfeitures to the United States of
America pursuant to the provisions ofTitle 21 United States Code Section 853
2 The property real and personal ofdefendants ISRAEL ANGELESshyMONTEZUMA alka Amigo ALAN CARDENAS aka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA YOUNG alka Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alka Guz WILLIAM GILLMAN alka Mo JERRY HOPEWELL TERI FIEDLER TINA McROY RAQUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIELLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVIDGARCIA JENNIFER GARCIA DAMIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NI~HOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BUHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alka Cat MARK HUSE aIkIa Marty and JULIE KOPPEN
(a) constituting or derived from any proceeds the defendants obtained
directly or indirectly as a result of the violation oflaw set out in Count I ofthis Indictment and i
(b) used or intended to be used in any manner or part to commit or to
facilitate the commission ofsuch violations is property subject to forfeiture pursuant to Title 21
United States Code SeCtion 853(a)
3 Specifically subject to foJfeiture is appro~ately $23000000 in United Sta~es
I currency in that such sum in the aggregate is property constituting or derived from any pr~ceeds
the defendants obtained directly or indirectly as a result of the offense alleged in Count I i
I
4 Properties subject to forfeiture as set out at paragraph 2 and 3 above include but
are not liniited to
(a) The interest of ISRAEL ANGELES-MONTEZUMA aIkIa Amigo ALAN CARDENAS alka AI DAVID SCHAFFER MICHAEL CHANDLER AMANDA
19
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 19 of 21 PageID 99
YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
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853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 21 of 21 PageID 101
YOUNGalkla Amanda Jinkerson AMANDA MILBOURN BONNIE ORMAN GUSTAVO ALVAREZ-ANGELES alkla Guz WILLIAM GILLMAN alkla Mo[ JERRY HOPEWELL TERI FIEDLER TINA McROY R4-QUEL GRAHAM MATTHEW KOENEKER TERRANCE BISE JUDY COLLINS DANIElLE WOLFF alka Sunshine SAMANTHA KING MICHAEL GARCIA DAVID GARCIA JENNIFER GARCIA DAlVIIEN GROVES VALERIE WILLIAMS MICHAEL KECK BRUCE NICHOLS ROSCOE SINGER DALE NORDIN LARRY HAWKINS MARK FLOTRON HOLLY POLITTE IVY TOMINACK JOHN BELL ERIC BOHLINGER DANIELLE DEWROCK JOSEPH FRANCIS CATHERINE WOOLFORD alkla Cat MARK RUSE alkla Marty and JULIE KOPPEN in
(i) Approximately $9000000 in United States currency seized from a vehicle rented by
VALERIE WILLIAMS and driven by JUDy COLLINS in Summit County Utah on
November 152015
(ii) Approximately $1199900 in United States currency seized MICHAEL KECK on
March 212016
(iii) Approximately $11000000 in United States currency seized from a vehicle driven
by BRUCE NICHOLS in Nevada on April 8 2016
(iv) Approximately $2996000 in United States currency seized from a vehicle driven by
BRUCE NICHOLS in St Louis City on August 112016
5 If any bfthe property desGribed in paragraphs 23 and 4 above as a result of any act or omission of the defendants
(a) cannot be located upon the exercise ofdue 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 intent of the United States pursuant to Title 21 United States Code Section
20
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 20 of 21 PageID 100
853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 21 of 21 PageID 101
853(P) to seek forfeiture of any other property of the defendants up to the value of the property
described in paragraphs 2 3 and 4 above or elsewhere as being subject to forfeiture
A TRUE BILL
FOREPERSON
RICHARD G CALLAHAN United States Attorney
SIRENA MILLER WISSLER 55374MO
Assistant United States Attorney
111 S 10th Street Room 20333
St Louis MO 63102
(314) 539-2200
21
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