REDACTED IN THE UNITED STATES DISTRICT …s3.amazonaws.com/hamptonroadscom/store/221.pdf · 1...

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REDACTED

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA

Norfolk Division UNITED STATES OF AMERICA v. ANTHONY GONZALEZ, a/k/a “Geezy,” (Counts 1, 2, 11, 13, 15-17, 21-30, 34, 39-71, 73-76, 79, 81, 82) CHARLES ALOYSIUS SANDERLIN, a/k/a “Rat,” a/k/a “Little Rat,” a/k/a “Dreads,” (Counts 1, 19, 33-37, 41-43, 46, 62, 64, 69, 71, 72, 74, 77, 78) RICHARD WILLIAM HOGGARD, a/k/a “Little Willie,” (Counts 1, 3-10, 12, 14-17, 66, 67) JOHN LEE MCCOY, III, a/k/a “J-Mac,” a/k/a “T-Mac,” (Counts 1, 18, 20, 51-56) RAYMOND DWIGHT MCCOY, a/k/a “Ray-Ray,” a/k/a “Lil Cuz,” (Counts 1, 32, 38, 77, 80) SHAWN JERMAINE BRANCH, a/k/a “Infinit,” a/k/a “Killer,” (Counts 1, 22, 31, 59, 73, 75, 76) RON QUARRIE WILLIAMS, a/k/a “Posse,” a/k/a “Josh,” a/k/a “Uncle Ron,” a/k/a “Solomon Jacobs,” (Counts 1, 60) Defendants.

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UNDER SEAL CRIMINAL NO. 2:09cr___ 21 U.S.C. § 846 Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances (Count 1) 21 U.S.C. § 848 Continuing Criminal Enterprise (Count 2) 21 U.S.C. § 841(a)(1) Possession with Intent to Distribute and Distribution of Controlled Substances (Counts 3, 6-11, 13-18, 21, 23-30, 32) 18 U.S.C. § 924(c)(1)(A) Using, Carrying, Possessing, Brandishing, and Discharging Firearms During and in Relation to and in Furtherance of Drug Trafficking Crimes (Counts 4, 12, 19, 20, 33, 35, 37-39) 18 U.S.C. § 1952(a)(3) Interstate Travel in Aid of Racketeering (Counts 5, 22, 31, 34, 36) 21 U.S.C. § 843(b) Using Communication Facilities to Cause, Commit, and Facilitate Felony Violations of the Controlled Substances Act (Counts 40-78) 21 U.S.C. § 856 Open and Maintain Drug-Involved Premises (Counts 79-82) 21 U.S.C. § 853 Criminal Forfeiture

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INDICTMENT

April 2009 Term - at Norfolk, Virginia

THE GRAND JURY CHARGES THAT:

COUNT ONE

From in or about 2003, and continuously thereafter up to and including the date of this

Indictment, in the Eastern District of Virginia and elsewhere, the following defendants:

ANTHONY GONZALEZ, a/k/a “Geezy” (hereinafter ANTHONY GONZALEZ)

CHARLES ALOYSIUS SANDERLIN, a/k/a “Rat,” a/k/a “Little Rat,” a/k/a “Dreads” (hereinafter CHARLES SANDERLIN)

RICHARD WILLIAM HOGGARD, a/k/a “Little Willie” (hereinafter RICHARD HOGGARD)

JOHN LEE MCCOY, III, a/k/a “J-Mac,” a/k/a “T-Mac” (hereinafter JOHN MCCOY)

RAYMOND DWIGHT MCCOY, a/k/a “Ray-Ray,” a/k/a “Lil Cuz” (hereinafter RAYMOND MCCOY)

SHAWN JERMAINE BRANCH, a/k/a “Infinit,” a/k/a Killer” (hereinafter SHAWN BRANCH)

RON QUARRIE WILLIAMS, a/k/a “Posse,” a/k/a Josh,” a/k/a “Uncle Ron,” a/k/a “Solomon Jacobs” (hereinafter RON WILLIAMS)

did unlawfully, knowingly and intentionally combine, conspire, confederate and agree together

and with other persons both known and unknown to commit the following offenses:

1. To unlawfully, knowingly and intentionally distribute and possess with intent to

distribute five (5) kilograms or more of a mixture and substance containing a detectable amount

of cocaine, a Schedule II narcotic controlled substance, in violation of Title 21, United States

Code, Sections 841(a)(1) and (b)(1)(A)(ii).


distribute one (1) kilogram or more of a mixture and substance containing a detectable amount of

heroin, a Schedule I narcotic controlled substance, in violation of Title 21, United States Code,

Sections 841(a)(1) and (b)(1)(A)(i).

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distribute fifty (50) grams or more of a mixture and substance containing cocaine base,

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

Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(iii).


distribute one-thousand (1000) kilograms or more of a mixture and substance containing a

detectable amount of marijuana, a Schedule I controlled substance, in violation of Title 21,

United States Code, Sections 841(a)(1) and (b)(1)(A)(vii).

5. To unlawfully, knowingly and intentionally use communication facilities to cause,

commit, and facilitate felony violations of the Controlled Substances Act, in violation of Title

21, United States Code, Section 843(b).

6. To unlawfully, knowingly and intentionally open, lease, rent, use and maintain

places for the purpose of manufacturing, distributing and using controlled substances and

manage and control places as owner, lessee, agent, employee, occupant and mortgagee and

unlawfully, knowingly and intentionally rent, lease profit from and make available for use the

places for the purpose of unlawfully manufacturing, storing, distributing and using controlled

substances, in violation of Title 21, United States Code, Section 856(a).

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WAYS, MANNER AND MEANS TO ACCOMPLISH THE CONSPIRACY

The primary purpose of the conspiracy was to make money in and through the

distribution of cocaine, cocaine base, heroin and marijuana (collectively referred to hereinafter as

“controlled substances”). The ways, manners and means by which that purpose was carried out

included, but were not limited to, the following:

1. It was a part of the conspiracy that the defendants and conspirators would and did

distribute and possess with the intent to distribute controlled substances in the Cities of Virginia

Beach, Norfolk, Chesapeake, Portsmouth and Hampton in the Eastern District of Virginia

(collectively referred to hereinafter as the “Tidewater area”) and in other areas of the Eastern

District of Virginia, Atlanta, Georgia; California; Miami, Florida; Phoenix, Arizona;

Albuquerque, New Mexico; Houston, Texas; Panama, Central America and elsewhere.

2. It was a further part of the conspiracy that the defendants and conspirators

procured controlled substances from sources of supply located in Texas, Florida, Georgia,

Arizona, California, and New York.

3. It was a further part of the conspiracy that the defendants and conspirators would

and did travel and cause others to travel in interstate and foreign commerce to facilitate the

distribution of controlled substances. The defendants and conspirators would and did travel, and

would and did facilitate travel by other defendants and conspirators to and from Georgia, Texas,

Arizona, California, Florida, New York, Virginia and Panama, Central America to facilitate the

procurement, purchase, transportation, delivery and distribution of shipments of controlled

substances and would and did transport and facilitate the transportation of the controlled

substances to the Tidewater area of the Eastern District of Virginia for distribution.

4. It was further a part of the conspiracy that the defendants and conspirators would

and did derive substantial gross receipts from the distribution of controlled substances, and

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would and did spend the money derived from the sale of controlled substances in various ways

which furthered and promoted the conspiracy.


and did launder proceeds from the distribution of controlled substances through various

companies and corporations set up and controlled by the defendants and conspirators. These

companies and corporations include but are not limited to: Soul Providers Management, Soul

Providers Entertainment, D & A Trucking, Soul Provider Trucking and Encore Management.


and did play different roles, take upon themselves different tasks and participate in the affairs of

the conspiracy through various criminal acts. The defendants and conspirators would and did

make themselves and their services available at different times throughout the conspiracy and

would participate in selected narcotics ventures and narcotics related financial transactions on an

“as needed” basis. The roles assumed and carried out by the defendants and coconspirators were

interchangeable at various times throughout the conspiracy. Some of the roles the defendants

and conspirators assumed and carried out included, among others: narcotics supplier,

leader/organizer, supervisor/manager, distributor/redistributor, broker, financier, transporter,

money launderer, money order and cashier’s check purchaser, depositor of drug proceeds, driver,

drug preparer and packager, runner, facilitator, bodyguard/escort, purchaser and provider of

handguns, enforcer, and courier for United States currency and controlled substances.


and did use residences, motel rooms and vehicles, to store, possess with intent to distribute and

distribute controlled substances and to store money and other proceeds derived from the

distribution of controlled substances.

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and did meet at various times and places, including, but not limited to: residences located at 1100

Ricks Court, Chesapeake, Virginia, 4728 Windemere Court, Apartment 102, Virginia Beach,

Virginia, and 333 Southgate Avenue, Virginia Beach, Virginia; and Encore Lounge nightclub

located at 1889 Virginia Beach Boulevard, Virginia Beach, Virginia, to package controlled

substances, using paraphernalia, to deliver packages of controlled substances, and to receive the

proceeds from the sales of controlled substances.


and did manufacture cocaine base, commonly known as “crack,” by cooking it in a variety of

ways.


and did use various methods to conceal the conspiracy and their unlawful drug activities to

insure the conspiracy’s continuing success. These methods include, but are not limited to the

following:

a. The defendants and conspirators would and did talk, and attempt to talk, in

code in an effort to avoid being associated with the conspiracy and to evade detection.

For instance, the defendants and conspirators rarely, if ever, uttered the words “cocaine,”

“marijuana,” “heroin,” ”crack,” “money,” “guns,” “firearms” or “cell phone” in

conversation with other defendants and coconspirators. Rather, the defendants used

coded language and referred to marijuana in terms including but not limited to: “smoke,”

“puff the magic dragon,” “buds” and “shake;” referred to cocaine as “white,” “white

sale,” and “birds;” referred to heroin as “brown” and “beige;” referred to controlled

substances generally as “folders,” and “work;” referred to money as “change;” referred to

firearms as “joints;” and referred to a cell phone as a “junk,” “joint,” “watch,” “horn,”

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and “file.” In addition, the defendants and conspirators typically referred to monetary

amounts or drug quantities only as single numbers (e.g., $5,600 was referred to simply as

“56”) or in other unconventional terms, such as a “pound” which meant a five kilogram

quantity of cocaine.

b. The defendants and conspirators would and did evade and attempt to

evade detection by engaging in counter-surveillance.

c. The defendants and conspirators would and did change distribution

locations to evade detection and would conduct transactions secretly to avoid detection.

d. The defendants and conspirators would and did use alias names and

nicknames to hide their true identity.

e. The defendants and conspirators would and did use false addresses to hide

their true residences. For instance, ANTHONY GONZALEZ routinely provided 333

Southgate Avenue Virginia Beach, Virginia as his address to commercial airlines

ticketing personnel and law enforcement officers during the conspiracy, when, in fact,

333 Southgate Avenue is the address of E.M. and GONZALEZ has resided exclusively at

other locations during the conspiracy. CHARLES SANDERLIN caused his Virginia

driver’s license, vehicle registrations and cell phone account to list 6075 Foresttown

Drive, Norfolk, Virginia as SANDERLIN’s address, when, in fact, SANDERLIN has

resided exclusively at other locations during the conspiracy.

f. The defendants and conspirators would and did hold themselves out as

music producers, rappers, entrepreneurs, club owners, clothing designers, and other

legitimate occupations in order to conceal the true source of their income and to conceal

the conspiracy and their unlawful drug activities to insure the conspiracy’s continuing

success

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and did use communication facilities in a variety of ways to further and promote the conspiracy,

including, but not limited to, the following:

a. The defendants and conspirators would and did obtain, change, and use

cellular telephones, some of which were subscribed to in nominee names, to contact other

members;

b. The defendants and conspirators would and did obtain cellular telephones

and then use the telephones to contact other members to engage in multiple acts involving

the criminal drug conspiracy;

c. The defendants and conspirators would and did preserve and protect

profits of the conspiracy through the use of cellular telephones and other telephones;

d. The defendants and conspirators would and did promote and enhance the

conspiracy and its members' and its associates' activities through the use of cellular

telephones and other telephones.

e. The defendants and conspirators would and did change/drop cellular

telephones frequently in order to evade monitoring and detection.


and did receive, obtain, and purchase numerous firearms which the defendants and conspirators

shared and transferred among themselves and which the defendants and conspirators used,

carried, possessed, brandished and discharged during and in relation to and in furtherance of the

conspiracy. It was further a part of the conspiracy that the defendants and conspirators would

and did use residences and open air locations adjacent to the residences to use, store, possess and

have firearms available for their use, to protect, to further, and to promote the conspiracy.

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OVERT ACTS

In furtherance of the conspiracy, and to accomplish the objects of the conspiracy, the

following overt acts, among others, were committed in the Eastern District of Virginia and

elsewhere:

1. On or about May 17, 2004, at Norfolk, Virginia, CHARLES SANDERLIN

purchased a Taurus Model 945 .45 caliber semi-automatic pistol bearing serial number NXB-

48061 for $647.89.

2. On or about May 26, 2004, RICHARD HOGGARD and a coconspirator traveled

from the Eastern District of Virginia to Bronx, New York to purchase two kilograms of cocaine

for further distribution.

3. On or about May 26, 2004, at Bronx, New York, RICHARD HOGGARD and a

coconspirator possessed a Glock Model 20 10mm semi-automatic pistol bearing serial number

UL084US, a Glock Model 23 .40 caliber semi-automatic pistol bearing serial number

DBU305US and $39, 917.

4. In or about August of 2004, at Virginia Beach, Virginia, RICHARD HOGGARD

distributed cocaine to a coconspirator for further distribution.

5. On or about June 17, 2004, at Norfolk, Virginia, CHARLES SANDERLIN

purchased a Hechler & Koch Model USP40V1 .40 caliber semi-automatic pistol bearing serial

number 22-35138.

6. In or about September of 2004, at Norfolk, Virginia, RICHARD HOGGARD

distributed two kilograms of cocaine to a coconspirator for $44,000 for further distribution.

7. In or about October of 2004, at Norfolk, Virginia, RICHARD HOGGARD

distributed one kilogram of cocaine to a coconspirator for $22,000 for further distribution.

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8. On or about November 5, 2004, at Albuquerque, New Mexico, RON WILLIAMS

possessed three kilograms of cocaine with intent to distribute.

9. On or about November 8, 2004, at Portsmouth, Virginia, RICHARD HOGGARD

distributed 4.5 ounces of cocaine (a ‘big eight’) to a coconspirator for $3,500 for further

distribution.

10. On or about November 11, 2004 at Portsmouth, Virginia, a coconspirator

possessed 57.7 grams of cocaine base with intent to distribute.

11. In or about November of 2004, at Norfolk, Virginia, RICHARD HOGGARD


12. In or about December of 2004, at Norfolk, Virginia, RICHARD HOGGARD


13. On January 13, 2005, at Norfolk, Virginia, CHARLES SANDERLIN obtained a

permit to carry a concealed handgun from the Circuit Court of Norfolk, Virginia.

14. In or about 2005, ANTHONY GONZALEZ distributed cocaine to a coconspirator

for further distribution.

15. In or about February of 2005, at Picasso’s nightclub at Virginia Beach, Virginia,

RICHARD HOGGARD met with a coconspirator for the purpose of obtaining a new cocaine

supplier.

16. In or about February of 2005, at 333 Southgate Avenue, Virginia Beach, Virginia,

RICHARD HOGGARD and ANTHONY GONZALEZ met with a coconspirator/cocaine

supplier nicknamed “J.B.” to discuss cocaine quantities and prices.

17. In or about March of 2005, at Virginia Beach, Virginia, ANTHONY GONZALEZ

purchased seven kilograms of cocaine from “J.B.” for further distribution.

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18. In or about April of 2005, at Norfolk, Virginia, RICHARD HOGGARD

discharged a firearm, namely a ‘MAC-11.’

19. On or about April 29, 2005, in the 3200 block of Green Lakes Drive in Virginia

Beach, Virginia, RICHARD HOGGARD possessed a Ruger Model P95DC 9mm semi-automatic

pistol bearing serial number 94-0027872, a Leinad Cobray Model PM-11 9mm semi-automatic

pistol ( a ‘MAC-11’) bearing serial number 314-58322, $6,147 in drug proceeds and seven grams

of marijuana.

20. In or about May of 2005, at 333 Southgate Avenue, Virginia Beach, Virginia,

ANTHONY GONZALEZ distributed three kilograms of cocaine to RICHARD HOGGARD and

one kilogram of cocaine to a coconspirator.

21. In or about May of 2005, at Norfolk, Virginia, RICHARD HOGGARD

brandished a 9mm handgun while distributing narcotics.

22. On or about May 7, 2005, ANTHONY GONZALEZ caused Sprint/Nextel to

change his cellular phone number.

23. On or about May 10, 2005, at Virginia Beach, Virginia, ANTHONY

GONZALEZ, using drug proceeds, obtained United States Post Office money orders in amounts

totaling $8,000 and delivered them to a coconspirator.

24. On or about May 10, 2005, at the Norfolk International Airport, Norfolk,

Virginia, three coconspirators possessed approximately $28,000, which included $8,000 in

United States Post Office money orders in the name of ANTHONY GONZALEZ.

25. On or about May 23, 2005, at Virginia Beach, Virginia, RAYMOND MCCOY

purchased a Taurus Model 24/7 .40 caliber semi-automatic pistol bearing serial number

SXD69533, a holster, .40 caliber ammunition and a range membership for $577.57.

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26. In or about June of 2005, at the Hampton Inn on Northampton Boulevard in

Virginia Beach, Virginia, ANTHONY GONZALEZ and RICHARD HOGGARD distributed

three kilograms of cocaine to a coconspirator for $69,000 for further distribution.

27. On or about June 8, 2005, at Virginia Beach, Virginia, RAYMOND MCCOY

obtained a permit to carry a concealed weapon from the Circuit Court of Virginia Beach,

Virginia.

28. On or about July 4, 2005, at the Waffle House restaurant located at 5656 Indian

River Road, Virginia Beach, Virginia, RAYMOND MCCOY brandished a .40 caliber firearm at

an individual.

29. On or about July 12, 2005, at Virginia Beach, Virginia, ANTHONY GONZALEZ

purchased a 2000 Ford Excursion with $11,100 in drug proceeds.

30. On or about July 24, 2005, at Virginia Beach, Virginia, RICHARD HOGGARD

discharged a firearm, namely an ‘AR-15.’

31. In or about July of 2005, in the parking lot of an Arby’s restaurant in Virginia

Beach, Virginia, ANTHONY GONZALEZ and RICHARD HOGGARD distributed three

kilograms of cocaine to a coconspirator for $69,000 for further distribution.

32. In or about August of 2005, at 1204 Edenham Court, Virginia Beach, Virginia,

ANTHONY GONZALEZ and RICHARD HOGGARD distributed five kilograms of cocaine to a

coconspirator for $115,000 for further distribution.

33. On or about December 8, 2005, at Virginia Beach, Virginia, JOHN MCCOY

purchased a Smith & Wesson Model 60 .357 caliber revolver bearing serial number CJL0671,

ammunition, and a range membership for $581.78.

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34. On or about December 12, 2005, at Virginia Beach, Virginia, JOHN MCCOY

made application to the Circuit Court of Virginia Beach, Virginia for a permit to carry a

concealed firearm.

35. In or about January of 2006, at Virginia Beach, Virginia, ANTHONY

GONZALEZ, while armed with a handgun, distributed two kilograms of powder cocaine and

one-half kilogram of crack cocaine to a coconspirator for $49,000 for further distribution.

36. On or about February 1, 2006, ANTHONY GONZALEZ caused Sprint/Nextel to


37. On or about February 19, 2006, in Houston, Texas, ANTHONY GONZALEZ met

with a coconspirator.

38. On or about March 10, 2006, at Norfolk, Virginia, CHARLES SANDERLIN

purchased a Taurus Model PT92 9mm semi-automatic pistol bearing serial number TXE80773

for $524.99.

39. On or about April 14, 2006, at Virginia Beach, Virginia, JOHN MCCOY

possessed approximately 480 pounds of marijuana with intent to distribute.

40. On or about June 1, 2006, ANTHONY GONZALEZ signed a contract to purchase

a 2007 Mercedes Benz S550 Sedan VIN #WDDNG71X87A051214 for $90,835 dollars.


purchased a Taurus Model 617 .357 caliber revolver bearing serial number ZA364784 for

$388.49.


purchased a Glock Model 19 9mm semi-automatic pistol bearing serial number MD847US for

$472.49.

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43. On or about July 18, 2006, ANTHONY GONZALEZ caused Sprint/Nextel to


44. On or about July 31, 2006, at Virginia Beach, Virginia, CHARLES SANDERLIN

purchased a Taurus Model 24/7 .40 caliber semi-automatic pistol bearing serial number

SXA42688 for $ 451.59.

45. In or about October of 2006, in the Eastern District of Virginia, ANTHONY

GONZALEZ and a coconspirator purchased six kilograms of cocaine for further distribution.

46. On or about October 15, 2006, at Virginia Beach, Virginia, JOHN MCCOY shot a

man in the face and neck in retaliation for a drug-related burglary committed at RAYMOND

MCCOY’s residence at 3715 Sylvan Lane, Virginia Beach, Virginia on December 13, 2004.

47. On or about January 29, 2007, ANTHONY GONZALEZ signed a contract to

purchase a 2007 Toyota Avalon Sedan VIN #4T1BK36B87U206422 for $34,646.

48. On or about February 8, 2007, ANTHONY GONZALEZ caused Sprint/Nextel to


49. On or about March 25, 2007, at Hampton, Virginia, a coconspirator purchased an

IMI Model Baby Eagle 9mm semi-automatic pistol bearing serial number 36313894 to be used,

carried and possessed in furtherance of the conspiracy.

50. On or about May 20, 2007, ANTHONY GONZALEZ caused a coconspirator,

D.G., to purchase ten money orders totaling $5,000 with drug proceeds.


D.G., to purchase three money orders totaling $1,500 with drug proceeds.


D.G., to purchase two money orders totaling $1,000 with drug proceeds.

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53. On or about May 25, 2007, a coconspirator, D.G., caused the deposit of ten

money orders totaling $5,000 into a bank account controlled by ANTHONY GONZALEZ.

54. On or about May 24, 2007, ANTHONY GONZALEZ and SHAWN BRANCH

traveled via Southwest Airlines from Norfolk, Virginia to Phoenix, Arizona to meet with a

coconspirator.

55. On or about May 24, 2007 at Phoenix, Arizona, ANTHONY GONZALEZ and

SHAWN BRANCH stayed at the Arizona Grand Resort.

56. On or about May 25, 2007, at Phoenix, Arizona, ANTHONY GONZALEZ and

SHAWN BRANCH met with coconspirators to discuss a drug debt of $120,000 owed by

GONZALEZ for six kilograms of cocaine previously supplied to GONZALEZ.

57. On or about May 26, 2007, ANTHONY GONZALEZ and SHAWN BRANCH

travelled via Southwest Airlines from Phoenix, Arizona to Fort Lauderdale, Florida.



59. In or about May of 2007, in the Eastern District of Virginia, ANTHONY

GONZALEZ possessed 625 pounds of marijuana with intent to distribute.

60. In or about May of 2007, at 1100 Ricks Court, Chesapeake, Virginia, ANTHONY

GONZALEZ paid a coconspirator approximately $540,000 for 625 pounds of marijuana.

61. In or about May of 2007, ANTHONY GONZALEZ caused approximately

$540,000 to be shipped via courier to a coconspirator in Phoenix, Arizona.

62. On or about June 5, 2007, a coconspirator, D.G., caused the deposit of seven

money orders totaling $3,500 into a bank account controlled by GONZALEZ.

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63. In or about August of 2007, in the Eastern District of Virginia, ANTHONY

GONZALEZ possessed 400 pounds of marijuana and ten kilograms of cocaine with intent to

distribute.

64. On or about September of 2007, at 1100 Ricks Court, Chesapeake, Virginia,

ANTHONY GONZALEZ paid a coconspirator $200,000 for ten kilograms of cocaine and

approximately $180,000 in partial payment for 400 pounds of marijuana.

65. In or about September of 2007, in the Eastern District of Virginia, ANTHONY

GONZALEZ possessed approximately 400 pounds of marijuana and fourteen kilograms of

cocaine with intent to distribute.

66. In or about September of 2007, at Virginia Beach, Virginia, ANTHONY

GONZALEZ possessed one kilogram of heroin with intent to distribute.

67. In or about October of 2007, ANTHONY GONZALEZ made a $300,000 partial

payment to a coconspirator for fourteen kilograms of cocaine and 400 pounds of marijuana.

68. In or about October of 2007, at 1100 Ricks Court, Chesapeake, Virginia,

ANTHONY GONZALEZ paid a coconspirator $65,000 for one kilogram of heroin.

69. In or about October of 2007, at Virginia Beach, Virginia, ANTHONY

GONZALEZ possessed one kilogram of heroin with intent to distribute.

70. In or about October of 2007, at 1100 Ricks Court, Chesapeake, Virginia,

ANTHONY GONZALEZ paid a coconspirator $55,000 for heroin.

71. In or about October of 2007, ANTHONY GONZALEZ caused approximately

$120,000 to be shipped via courier to a coconspirator in Phoenix, Arizona.

72. In or about October of 2007, in the Eastern District of Virginia, ANTHONY

GONZALEZ possessed 400 pounds of marijuana with intent to distribute.

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73. On or about October 10, 2007, ANTHONY GONZALEZ caused Sprint/Nextel to


74. On or about October 23, 2007, at Virginia Beach, Virginia, RAYMOND MCCOY

signed a lease agreement for 4728 Windemere Court, Apartment 102, Virginia Beach, Virginia.

75. On or about November 2, 2007, in Virginia Beach, Virginia, ANTHONY

GONZALEZ purchased Encore Lounge located at 1889 Virginia Beach Boulevard from a

coconspirator for 40 pounds of marijuana and approximately $80,000 in drug proceeds.

76. In or about November of 2007, in the Eastern District of Virginia, ANTHONY

GONZALEZ possessed 400 pounds of marijuana and ten kilograms of cocaine with intent to

distribute.

77. In or about December of 2007, a coconspirator traveled via commercial airlines

from Phoenix, Arizona to Norfolk, Virginia to collect a drug debt owed by ANTHONY

GONZALEZ.

78. In or about January of 2008, at Virginia Beach, Virginia, ANTHONY

GONZALEZ and coconspirators, anticipating the arrival of police, concealed two kilograms of

cocaine and firearms on the premises of Encore Lounge following a car accident outside the

club.

79. On or about January 15, 2008 a coconspirator traveled via Delta Airlines from

Phoenix, Arizona to Norfolk, Virginia to collect a drug debt owed by ANTHONY GONZALEZ.

80. On or about January 16, 2008, in Hampton, Virginia, JOHN MCCOY and a

coconspirator purchased a black 2004 Nissan 350Z VIN # JN1AZ34E94M154306 for $23,000 in

drug proceeds provided by ANTHONY GONZALEZ.

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81. On or about January 16, 2008, CHARLES SANDERLIN transferred title of a

2001 Chrysler 300M equipped with a hidden compartment at the Virginia Department of Motor

Vehicles from RAYMOND MCCOY to SANDERLIN.

82. On or about January 17, 2008, ANTHONY GONZALEZ caused a black 2004

Nissan 350Z VIN # JN1AZ34E94M154306 to be delivered to New York for the purpose of

installing hidden compartments in the vehicle for the transportation of narcotics and United

States currency.

83. On or about January 19, 2008, a coconspirator traveled via American Airlines

from Norfolk, Virginia to Phoenix, Arizona.

84. On or before January 22, 2008, at Virginia Beach, Virginia, ANTHONY

GONZALEZ caused SHAWN BRANCH to travel via a 2001 Chrysler 300M equipped with a

hidden compartment and titled in the name of CHARLES SANDERLIN to Phoenix, Arizona for

the purpose of delivering United States currency in order to purchase a multi-hundred pound

shipment of marijuana.

85. On or about January 22, 2008, SHAWN BRANCH obtained a room at the

Homewood Suites in Phoenix, Arizona.

86. On or about January 24, 2008, at Phoenix, Arizona, SHAWN BRANCH travelled

via Delta Airlines to Norfolk, Virginia.

87. On or about January 28, 2008, at Virginia Beach, Virginia, RAYMOND MCCOY

utilized 4728 Windemere Court, Apartment #102, for the purpose of storing, repackaging and

distributing controlled substances.

88. On or about January 28, 2008, in Virginia Beach, Virginia, RAYMOND MCCOY

possessed approximately 201 grams of marijuana with intent to distribute.

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89. On or about February 1, 2008, ANTHONY GONZALEZ caused a coconspirator,

D.G., to purchase five money orders totaling $2,500 with drug proceeds.


D.G., to purchase eight money orders totaling $4,000 with drug proceeds.



92. On or about February 12, 2008, a coconspirator, D.G., caused the deposit of

seventeen money orders totaling $8,500 into a bank account controlled by GONZALEZ.

93. On or about February 12, 2008, CHARLES SANDERLIN signed a contract to

purchase a maroon 2006 Nissan 350Z VIN # JN1AZ34D46M300637 for $21,008.62.

94. On or about February 25, 2008, ANTHONY GONZALEZ signed a contract to

purchase a 2006 Bentley Continental Flying Spur Sedan VIN #SCBBR53W46C036456 for

$127,500 dollars, which included a $16,668.09 down payment and $1,668.09 monthly payments.

95. In or between February and April of 2008, ANTHONY GONZALEZ caused a

maroon 2006 Nissan 350Z VIN # JN1AZ34D46M300637 to be delivered to New York for the

purpose of installing a hidden compartment in the vehicle for the transportation of narcotics and

United States currency.

96. On or about April 10, 2008, in the Eastern District of Virginia, a coconspirator

caused the deposit of $5,400 in drug proceeds.

97. On or about April 10, 2008, in the Eastern District of Virginia, a coconspirator

caused the deposit of $6,000 in drug proceeds.

98. In or about April of 2008, at Virginia Beach, Virginia, ANTHONY GONZALEZ

caused a black 2004 Nissan 350Z VIN # JN1AZ34E94M154306 to be delivered to a

coconspirator in Phoenix, Arizona.

20

99. On or about April 16, 2008, a coconspirator traveled via Delta Airlines from


100. On or about April 21, 2008, ANTHONY GONZALEZ caused Sprint/Nextel to


101. On or about April 23, 2008, a coconspirator traveled via Delta Airlines from


102. On or about May 16, 2008, at Norfolk, Virginia, CHARLES SANDERLIN

purchased a Kel-Tec Model P32 .32 caliber semi-automatic pistol bearing serial number CHY98,

a 10 round Kel-Tec grip extension and a IMI 9mm Baby Eagle 15 round magazine for $342.27 to

be used, carried and possessed in furtherance of the conspiracy.

103. On or about June 13, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN traveled via AirTran Airlines from Newport News, Virginia to Fort Lauderdale,

Florida to meet with a coconspirator.

104. On or about June 17, 2008, ANTHONY GONZALEZ obtained a cell phone

assigned telephone number (305) 608-1148 to be utilized in furtherance of the conspiracy.

105. On or about June 17, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN traveled via American Airlines from Miami, Florida to the country of Panama to

meet with a coconspirator.

106. On or about June 22, 2008 ANTHONY GONZALEZ and CHARLES

SANDERLIN traveled via American Airlines from the country of Panama to Miami, Florida.

107. On or about July 4, 2008, ANTHONY GONZALEZ utilized his cell phone to

advise RICHARD HOGGARD that, “I want that junk, man you know that money.”

21

108. On or about July 4, 2008, ANTHONY GONZALEZ and SHAWN BRANCH

utilized GONZALEZ’s cell phone to conduct a drug-related conversation, during which

conversation BRANCH asked GONZALEZ, “Sire, where should I report to Sire?”

109. On or about July 6, 2008, ANTHONY GONZALEZ and a coconspirator in

Miami, Florida utilized GONZALEZ’s cell phone to plan a delivery of narcotics into the Eastern

District of Virginia for further distribution.


direct a Spanish speaking coconspirator to contact a drug courier in Miami, Florida concerning a

delivery of narcotics into the Eastern District of Virginia for further distribution.


direct a Spanish speaking coconspirator to provide a drug courier from Miami, Florida with

directions to the Virginia Beach area.

112. On or about July 7, 2008, a coconspirator contacted ANTHONY GONZALEZ on

GONZALEZ’s cell phone to advise that the coconspirator had given the drug courier from

Miami, Florida directions to the Virginia Beach area.


direct RICHARD HOGGARD to deliver a sum of drug proceeds.


update CHARLES SANDERLIN on the status of a narcotics shipment.


discuss a wire transfer of drug proceeds with a coconspirator.

116. On or about July 8, 2008, CHARLES SANDERLIN informed ANTHONY

GONZALEZ over GONZALEZ’s cell phone that he (SANDERLIN) was in possession of “two

folders” of “white” (cocaine).

22

117. On or about July 8, 2008, CHARLES SANDERLIN discussed the status of a

shipment of narcotics with ANTHONY GONZALEZ over GONZALEZ’s cell phone.


direct a coconspirator in Miami, Florida to call on another “junk” (cell phone).


direct CHARLES SANDERLIN, “to be bakerman right now” (to cook cocaine into crack

cocaine for further distribution).


direct a coconspirator to determine when a shipment of narcotics would arrive.


discuss the “load” being delayed with a coconspirator in Miami, Florida.


contact CHARLES SANDERLIN to verify that SANDERLIN was converting cocaine into crack

cocaine for further distribution.

123. On or about July 9, 2008, CHARLES SANDERLIN traveled via AirTran Airlines

from Newport News, Virginia to Fort Lauderdale, Florida.


contact a coconspirator in Miami, Florida to facilitate communications between the coconspirator

and CHARLES SANDERLIN.


discuss contacting a coconspirator in Miami, Florida with CHARLES SANDERLIN.

126. On or about July 9, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN, utilizing GONZALEZ’s cell phone, discussed “change” (drug proceeds) being

transported to Florida.

23


direct a coconspirator in Miami, Florida to contact GONZALEZ over another cell phone.


Miami, Florida utilized GONZALEZ’s cell phone to discuss the cost of a shipment of narcotics.


discuss statements made by a coconspirator to law enforcement.


direct JOHN MCCOY to deliver money to a coconspirator, S.G.-1.


direct a coconspirator, S.G.-1, to take possession of a quantity of money.

132. On or about July 10, 2008, a coconspirator called ANTHONY GONZALEZ on

GONZALEZ’s cell phone and warned GONZALEZ that another coconspirator who was

incarcerated had been promised by law enforcement that he (the incarcerated coconspirator)

could walk out in “street clothes” if he (the incarcerated coconspirator) could get someone to

“trick you (referring to GONZALEZ) up.”

133. On or about July 11, 2008, at 5576 Aurora Drive, Virginia Beach, Virginia, a

coconspirator picked up JOHN MCCOY.


direct a coconspirator, S.G.-1, to contact JOHN MCCOY.

135. On or about July 11, 2008, ANTHONY GONZALEZ contacted a coconspirator,

D.G., to discuss the prospect of GONZALEZ facing federal drug charges, during which

conversation ANTHONY GONZALEZ referred to himself as the “Last of the Mohicans”

because he had not been imprisoned on federal drug charges and further stated, “they know that I

ain’t crazy enough to be actually be hand-to-hand stuff.”

24


D.G., to advise her that business was “productive” and not to trust another coconspirator.


D.G., to discuss the activities of agents of the Virginia Alcoholic Beverage Control concerning

Encore Lounge.

138. On or about July 11, 2008, ANTHONY GONZALEZ and JOHN MCCOY

utilized GONZALEZ’s cell phone to discuss the need to talk on another phone.

139. On or about July 13, 2008, CHARLES SANDERLIN traveled via AirTran

Airlines from Fort Lauderdale, Florida to Newport News, Virginia.


contact a coconspirator in Miami, Florida.


Miami, Florida utilized GONZALEZ’s cell phone to discuss the need to talk on another phone.

142. On or about July 15, 2008, ANTHONY GONZALEZ and JOHN MCCOY

utilized GONZALEZ’s cell phone to discuss the distribution of narcotics.


send a text message to JOHN MCCOY stating, “Need 57 each”.

144. On or about July 15, 2008, JOHN MCCOY sent ANTHONY GONZALEZ a text

message asking, “You think you can do 56?”


send a text message to JOHN MCCOY stating, “I will”.

146. On or about July 15, 2008, JOHN MCCOY sent ANTHONY GONZALEZ a text

message asking, “Gotcha. Just talked 2 auntie.”

25


send a text message to JOHN MCCOY, instructing MCCOY to contact a coconspirator, S.G.-1,

stating, “Yeah c if she @ Peake n call me”.


contact a coconspirator, S.G.-1, to give her instructions on the distribution of a quantity of

narcotics.


contact a coconspirator, S.G.-1, to direct her to take possession of a sum of drug proceeds.


contact a security guard at Encore Lounge concerning a statement recently provided to law

enforcement by the security guard during which conversation ANTHONY GONZALEZ asked,

“You told, Rat got in the car with me too, Right?”


direct a coconspirator, S.G.-1, to distribute a quantity of narcotics to JOHN MCCOY.

152. On or about July 17, 2008, a coconspirator, S.G.-1, contacted ANTHONY

GONZALEZ seeking guidance concerning the quantity of narcotics she should distribute to

JOHN MCCOY.


contact a coconspirator, S.G.-1, to ask, “you at the white sale?” (referring to cocaine).


Airlines from Newport News, Virginia to Fort Lauderdale, Florida.

155. On or about July 19, 2008, at Washington, D.C., ANTHONY GONZALEZ

possessed a firearm in the glove box of his 2007 Mercedes Benz S550.

26

156. On or about July 20, 2008, RICHARD HOGGARD contacted ANTHONY

GONZALEZ on GONZALEZ’s cell phone and asked GONZALEZ, “What you want me to do

with the change?”


Airlines from Fort Lauderdale, Florida to Newport News, Virginia.


contact a coconspirator, S.G.-1, during which conversation S.G.-1 stated, “Oh, OK...What are

doing…puff the magic dragon?” (referring to marijuana).


contact SHAWN BRANCH in order to obtain United States currency.


Miami, Florida, utilized GONZALEZ’s cell phone to discuss a shipment of narcotics and United

States currency.

161. On or about July 24, 2008, ANTHONY GONZALEZ utilized GONZALEZ’s cell

phone to discuss a seizure of cocaine by law enforcement in Albuquerque, New Mexico in 2004

during which conversation GONZALEZ stated to RON WILLIAMS, “I could be in that b*tch

(prison) with you”.

162. On or about July 27, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN utilized GONZALEZ’s cell phone to discuss travel to Miami in furtherance of the

conspiracy.


Airlines from Newport News, Virginia to Fort Lauderdale, Florida in furtherance of the

conspiracy.

27


Miami, Florida utilized GONZALEZ’s cell phone to discuss a dispute and the need to utilize

another cell phone to avoid surveillance.


Airlines from Fort Lauderdale, Florida to Newport News, Virginia in furtherance of the

conspiracy.


contact a coconspirator to discuss various individuals who were incarcerated on federal drug

offenses and the prospect of these individuals cooperating with the government.

167. On August 2, 2008, ANTHONY GONZALEZ utilized his cell phone to notify a

coconspirator in Miami, Florida that CHARLES SANDERLIN would be traveling to Florida.

168. On August 3, 2008, ANTHONY GONZALEZ and CHARLES SANDERLIN

utilized GONZALEZ’s cell phone to attempt a coded conversation concerning drugs but then

decided to meet in person.

169. On or about August 5, 2008, at Newport News, Virginia, CHARLES

SANDERLIN possessed an IMI Model Baby Eagle 9mm semi-automatic pistol bearing serial

number 36313894 and a second chance bullet proof vest.

170. On or about August 5, 2008, CHARLES SANDERLIN traveled via AirTran

Airlines from Newport News, Virginia to Fort Lauderdale, Florida in furtherance of the

conspiracy.

171. On or about August 5, 2008, CHARLES SANDERLIN purchased a cashier’s

check for $6,500 with drug proceeds.

172. On or about August 5, 2008, CHARLES SANDERLIN contacted ANTHONY

GONZALEZ on GONZALEZ’s cell phone and stated, “paranoia”. ANTHONY GONZALEZ

28

then directed CHARLES SANDERLIN not to discuss “numbers” with a coconspirator in Miami,

Florida.

173. On or about August 5, 2008, ANTHONY GONZALEZ utilized his cell phone to

provide a coconspirator in Miami, Florida with CHARLES SANDERLIN’s cell phone number.


contact a coconspirator, a police officer, and asked the coconspirator to obtain information

concerning a federal grand jury investigation.


GONZALEZ on GONZALEZ’s cell phone during a meeting with a coconspirator in Miami,

Florida.


contact a coconspirator, a police officer, to discuss whether ANTHONY GONZALEZ was going

to be arrested on drug charges.

177. On or about August 10, 2008, ANTHONY GONZALEZ and a coconspirator in

Miami, Florida utilized GONZALEZ’s cell phone to discuss the status of a shipment of narcotics

during which conversation ANTHONY GONZALEZ instructed the coconspirator to utilize

another cell phone.

178. On or about August 10, 2008, ANTHONY GONZALEZ contacted a

coconspirator, S.G.-2, on his cell phone and instructed her to pick up a quantity of narcotics.


advise a coconspirator that S.G.-2 would be arriving shortly.


direct a coconspirator, S.G.-2, to a residence.

29

181. On or about August 10, 2008, a coconspirator, S.G.-2, contacted ANTHONY

GONZALEZ on his cell phone and stated, “he gave me the whole thing and said to bring it to

you” to which GONZALEZ replied, “Oh God.”


Miami, Florida utilized GONZALEZ’s cell phone to discuss the status of a narcotics transaction.

183. On or about August 15, 2008, RICHARD HOGGARD contacted ANTHONY

GONZALEZ on GONZALEZ’s cell phone and asked, “You got some chips…some bread…like

three cent?”

184. On or about August 16, 2008, a coconspirator, a police officer, contacted

ANTHONY GONZALEZ on GONZALEZ’s cell phone and informed GONZALEZ that he (the

officer) had been approached by officers from Internal Affairs concerning GONZALEZ’s drug

activities.

185. On or about August 16, 2008, a coconspirator in possession of three firearms

bailed out of a moving vehicle while it was being pursued by law enforcement.

186. On or about August 16, 2008, a coconspirator disposed of three firearms in an

attempt to prevent their seizure by law enforcement.

187. On or about August 17, 2008, a coconspirator attempted to recover three firearms

previously disposed of on August 16, 2008 by another coconspirator.

188. On or about August 17, 2008, ANTHONY GONZALEZ advised RICHARD

HOGGARD on GONZALEZ’s cell phone, “I got a new one” referring to a new cell phone

number.

189. On or about August 18, 2008, CHARLES SANDERLIN traveled from Fort

Lauderdale, Florida to Newport News, Virginia on AirTran Airlines in furtherance of the

conspiracy.

30

190. On or about August 23, 2008, RICHARD HOGGARD informed ANTHONY

GONZALEZ, “we lost…seven joints (guns) in…six days,” during a telephone conversion.

191. On or about August 23, 2008, during a telephone conversion, ANTHONY

GONZALEZ asked a coconspirator, a police officer, to determine whether RICHARD

HOGGARD was the target of a police investigation.

192. On or about August 23, 2008, ANTHONY GONZALEZ advised a coconspirator,

a police officer, “Everybody with me got guns.”


advise a coconspirator that he and CHARLES SANDERLIN would need “smoke” (referring to

marijuana).

194. On or about August 25, 2008, ANTHONY GONZALEZ, CHARLES

SANDERLIN, RICHARD HOGGARD and a coconspirator from Miami, Florida traveled to Las

Vegas, Nevada on Southwest Airlines.

195. On or about August 28, 2008, ANTHONY GONZALEZ, CHARLES

SANDERLIN and RICHARD HOGGARD traveled via Southwest Airlines from Las Vegas,

Nevada to Norfolk, Virginia.

196. In or about August of 2008, ANTHONY GONZALEZ received seven kilograms

of cocaine from a coconspirator in Houston, Texas for redistribution.


direct CHARLES SANDERLIN to the residence of a coconspirator, S.W., in the 3700 block of

Wind Ridge Road in the city of Virginia Beach, Virginia.

198. On or about August 29, 2008, ANTHONY GONZALEZ contacted a

coconspirator, S.W., to direct her to open the garage door at her residence for CHARLES

SANDERLIN.

31

199. On or about August 29, 2008, CHARLES SANDERLIN operated a 2006 Nissan

350Z equipped with a hidden compartment in furtherance of the conspiracy.

200. On August 29, 2008, at Virginia Beach, Virginia, CHARLES SANDERLIN

purchased Pyrex cookware in order to cook cocaine into crack.


GONZALEZ on GONZALEZ’s cell phone and indicated, “I’m leaving now” as he was departing

the residence of S.W. in Virginia Beach, Virginia.

202. On or about August 29, 2008, ANTHONY GONZALEZ, utilizing his cell phone,

contacted CHARLES SANDERLIN to ask SANDERLIN where he was and to inform

SANDERLIN, “I’m gonna move my car so you can pull inside.”

203. On or about August 29, 2008, at Chesapeake, Virginia, CHARLES SANDERLIN

possessed an IMI Model Baby Eagle 9mm semi-automatic pistol bearing serial number

36313894, a Kel-Tec Model P32 .32 caliber semi-automatic pistol bearing serial number

CHY98, a second chance bullet proof vest and United States currency.


Miami, Florida utilized GONZALEZ’s cell phone to arrange a meeting between the

coconspirator and CHARLES SANDERLIN.

205. On or about September 6, 2008, ANTHONY GONZALEZ, utilizing his cell

phone, contacted a coconspirator and stated, “I got another jack though” (referring to another cell

phone).

206. On or about September 6, 2008, CHARLES SANDERLIN utilized

SANDERLIN’s cell phone to direct a coconspirator to purchase additional cell phones.

32

207. On or about September 7, 2008, ANTHONY GONZALEZ utilized his cell phone

to instruct a coconspirator to keep a gunshot victim and the police off the property of Encore

Lounge.

208. On or about September 8, 2008, ANTHONY GONZALEZ contacted SHAWN

BRANCH and discussed having “smoke.”

209. On or about September 10, 2008, RICHARD HOGGARD contacted CHARLES

SANDERLIN on SANDERLIN’s cell phone and directed SANDERLIN to call on another

“watch” (phone).

210. On or about September 14, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN utilized GONZALEZ’s cell phone to contact a coconspirator in Miami, Florida to

inform the coconspirator that GONZALEZ was being followed by law enforcement.

211. On or about September 14, 2008, a coconspirator in Miami, Florida, using

ANTHONY GONZALEZ’s cell phone, thanked CHARLES SANDERLIN for the “change”

(money).

212. On or about September 16, 2008, SHAWN BRANCH contacted ANTHONY

GONZALEZ on GONZALEZ’s cell phone and stated to GONZALEZ, “I just bought some

smoke…where you want me to come.”

213. On or about September 16, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN traveled via AirTran Airlines from Newport News, Virginia to Fort Lauderdale,

Florida.

214. On or about September 17, 2008, ANTHONY GONZALEZ and SHAWN

BRANCH utilized GONZALEZ’s cell phone, during which conversation BRANCH stated that

he would not get “caught.”

33

215. On or about September 24, 2008, at 3715 Sylvan Lane, Virginia Beach, Virginia,

RAYMOND MCCOY possessed a Taurus Model 24/7 .40 caliber semi-automatic pistol bearing

serial number SXA42688, previously purchased by CHARLES SANDERLIN.

216. On or about September 25, 2008, a coconspirator contacted ANTHONY

GONZALEZ on GONZALEZ’s cell phone and stated to GONZALEZ, “I’m here with my boy

and he’s giving me something right now…it’s really nice…like half in buds…half in shake.”

217. On or about September 25, 2008, RAYMOND MCCOY and CHARLES

SANDERLIN utilized SANDERLIN’s cell phone to discuss the seizure of a firearm by police.

218. On or about September 26, 2008, CHARLES SANDERLIN and a coconspirator

utilized SANDERLIN’s cell phone to discuss the shooting of RAYMOND MCCOY.

219. On or about September 26, 2008, ANTHONY GONZALEZ and RAYMOND

MCCOY utilized GONZALEZ’s cell phone to discuss the shooting of RAYMOND MCCOY.

220. On or about September 29, 2008, ANTHONY GONZALEZ and a coconspirator

in Miami, Florida utilized GONZALEZ’s cell phone to discuss meeting together.

221. On or about September 29, 2008, at Virginia Beach, Virginia, a coconspirator

possessed cocaine, cocaine base and a semi-automatic pistol.

222. On or about September 30, 2008, CHARLES SANDERLIN utilized his cell

phone to make arrangements for a female to pick up $2500 from SANDERLIN to post the bond

of a coconspirator who was arrested on September 29, 2008 in possession of narcotics previously

provided by SANDERLIN.

223. On or about October 4, 2008, ANTHONY GONZALEZ and a coconspirator

utilized GONZALEZ’s cell phone to discuss the need to be careful talking drug business around

individuals who may be “wired up.”

34

224. On or about October 8, 2008, at Norfolk, Virginia, RICHARD HOGGARD

distributed six ounces of cocaine to a coconspirator.

(In violation of Title 21, United States Code, Section 846.)

COUNT TWO From in or about 2003 and continuously thereafter up to and including in or about the

date of this Indictment, in the Eastern District of Virginia and elsewhere, ANTHONY

GONZALEZ did unlawfully, knowingly and intentionally engage in a continuing criminal

enterprise, that is, he did knowingly and intentionally violate Title 21, United States Code,

Sections 841, 843, 846 and 856 including, but not limited to, those violations alleged in this

Indictment, which are re-alleged and incorporated by reference herein, and did commit other

violations of said statutes, which violations were part of a continuing series of violations of said

statutes undertaken by ANTHONY GONZALEZ in concert with at least five other persons with

respect to whom ANTHONY GONZALEZ occupied positions of organizer, a supervisory

position, and any other position of management, and from which continuing series of violations

ANTHONY GONZALEZ obtained substantial income and resources.

(All in violation of Title 21, United States Code, Section 848(a) and (c).)

35

COUNT THREE

On or about May 26, 2004, in the Eastern District of Virginia, RICHARD HOGGARD

did unlawfully, knowingly and intentionally attempt to possess with intent to distribute

approximately two (2) kilograms of cocaine, a Schedule II narcotic controlled substance.

(In violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B), 846 and Title 18, United States Code, Section 2.)

COUNT FOUR

On or about May 26, 2004, in the Eastern District of Virginia, RICHARD HOGGARD

did unlawfully, knowingly and intentionally use, carry and possess firearms, that is: a Glock

model 20 10mm semi-automatic pistol bearing serial number ULO84US and a Glock model 23

.40 caliber semi-automatic pistol bearing serial number DBU305U, during and in relation to and

in furtherance of a drug trafficking crime for which he may be prosecuted in a court of the

United States, that is, attempt to possess with the intent to distribute approximately two (2)

kilograms of cocaine, a Schedule II narcotic controlled substance, in violation of Title 21, United

States Code, Sections 841(a)(1) and (b)(1)(B) and 846, as set forth in Count Three of this

Indictment.

(All in violation of Title 18, United States Code, Sections 924(c)(1)(A) and 2.)

36

COUNT FIVE

On or about May 26, 2004, in the Eastern District of Virginia and elsewhere, RICHARD

HOGGARD did unlawfully, knowingly and intentionally travel in interstate commerce with the

intent to promote, manage, carry on, and facilitate the promotion, management, and carrying on,

of an unlawful activity, said unlawful activity being a business enterprise involving the

distribution of cocaine, a Schedule II narcotic controlled substance, in violation of the laws of the

United States, and thereafter the defendant RICHARD HOGGARD did perform and attempt to

perform acts intended to promote, manage, and facilitate the carrying on of the said unlawful

activity, namely on or about May 26, 2004, RICHARD HOGGARD and a coconspirator

travelled from Virginia Beach, Virginia to Bronx, New York in possession of approximately

$39,917 in cash and two loaded semi-automatic firearms for the purpose of acquiring two (2)

kilograms of cocaine, which RICHARD HOGGARD and the coconspirator intended to bring

back to the Eastern District of Virginia for redistribution.

(All in violation of Title 18, United States Code, Sections 1952(a)(3) and 2).

COUNT SIX

In or about September 2004, at Norfolk, in the Eastern District of Virginia, RICHARD

HOGGARD did unlawfully, knowingly and intentionally distribute approximately two (2)

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

narcotic controlled substance.

(In violation of Title 21, United States Code, Sections 841(a)(1), (b)(1)(B) and Title 18, United States Code, Section 2.)

37

COUNT SEVEN

In or about October 2004, at Norfolk, in the Eastern District of Virginia, RICHARD

HOGGARD did unlawfully, knowingly and intentionally distribute approximately one (1)

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



COUNT EIGHT

On or about November 8, 2004, at Portsmouth, in the Eastern District of Virginia,

RICHARD HOGGARD did unlawfully, knowingly and intentionally distribute approximately

128 grams (4.5 ounces) of a mixture and substance containing a detectable amount of cocaine, a

Schedule II narcotic controlled substance.

(In violation of Title 21, United States Code, Sections 841(a)(1), (b)(1)(C) and Title 18, United States Code, Section 2.)

COUNT NINE

On or about November 8, 2004, at Portsmouth, in the Eastern District of Virginia,

RICHARD HOGGARD did unlawfully, knowingly and intentionally distribute approximately 64

grams (2.25 ounces) of a mixture and substance containing cocaine base, commonly known as

crack cocaine, a Schedule II narcotic controlled substance.

(In violation of Title 21, United States Code, Sections 841(a)(1), (b)(1)(A)(iii) and Title 18, United States Code, Section 2.)

38

COUNT TEN

In or about December 2004, at Norfolk, in the Eastern District of Virginia, RICHARD

HOGGARD did unlawfully, knowingly and intentionally distribute approximately one (1)

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



COUNT ELEVEN

In or about February 2005, at Virginia Beach, in the Eastern District of Virginia,

ANTHONY GONZALEZ did unlawfully, knowingly and intentionally possess with intent to

distribute approximately seven (7) kilograms of a mixture and substance containing a detectable

amount of cocaine, a Schedule II narcotic controlled substance.

(In violation of Title 21, United States Code, Sections 841(a)(1), (b)(1)(A) and Title 18, United States Code, Section 2.)

39

COUNT TWELVE

On or about April 29, 2005, at Virginia Beach, in the Eastern District of Virginia,

RICHARD HOGGARD did unlawfully, knowingly and intentionally use, carry and possess

firearms, that is: a Ruger model P95DC 9mm semi-automatic pistol bearing serial number 94-

0027872 and a Leinad Cobray model PM-11 9mm semi-automatic pistol bearing serial number

314-58322, during and in relation to and in furtherance of a drug trafficking crime for which he

may be prosecuted in a court of the United States, that is, conspiracy to distribute and possess

with the intent to distribute controlled substances, in violation of Title 21, United States Code,

Sections 846 and 841(a)(1), as set forth in Count One of this Indictment.


COUNT THIRTEEN

In or about May 2005, at Virginia Beach, in the Eastern District of Virginia, ANTHONY

GONZALEZ did unlawfully, knowingly and intentionally distribute approximately four (4)

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



40

COUNT FOURTEEN

In or about May 2005, at Virginia Beach, in the Eastern District of Virginia, RICHARD

HOGGARD did unlawfully, knowingly and intentionally possess with intent to distribute

approximately three (3) kilograms of a mixture and substance containing a detectable amount of

cocaine, a Schedule II narcotic controlled substance.


COUNT FIFTEEN

In or about June 2005, at Norfolk, in the Eastern District of Virginia, ANTHONY

GONZALEZ and RICHARD HOGGARD did unlawfully, knowingly and intentionally distribute




COUNT SIXTEEN

In or about July 2005, at Virginia Beach, in the Eastern District of Virginia, ANTHONY

GONZALEZ and RICHARD HOGGARD did unlawfully, knowingly and intentionally distribute




41

COUNT SEVENTEEN

In or about August 2005, at Virginia Beach, in the Eastern District of Virginia,

ANTHONY GONZALEZ and RICHARD HOGGARD did unlawfully, knowingly and

intentionally distribute approximately five (5) kilograms of a mixture and substance containing a

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


COUNT EIGHTEEN On or about April 14, 2006, at Virginia Beach, in the Eastern District of Virginia, JOHN

MCCOY did unlawfully, knowingly and intentionally possess with intent to distribute

approximately 218.18 kilograms (480 pounds) of a mixture and substance containing a

detectable amount of marijuana, a Schedule I controlled substance.

(In violation Title 21, United States Code, Section 841(a)(1), (b)(1)(B)(vii) and Title 18, United States Code, Section 2.)

42

COUNT NINETEEN

On or about July 31, 2006, at Virginia Beach, in the Eastern District of Virginia,

CHARLES SANDERLIN did unlawfully, knowingly and intentionally use, carry and possess a

firearm, that is: a Taurus model 24/7 .40 caliber semi-automatic pistol bearing serial number

SXA42688, during and in relation to and in furtherance of a drug trafficking crime for which he





COUNT TWENTY

On or about October 15, 2006, at Virginia Beach, in the Eastern District of Virginia,

JOHN MCCOY did unlawfully, knowingly and intentionally discharge a firearm, that is: a 9mm

semi-automatic pistol, during and in relation to and in furtherance of a drug trafficking crime for

which he may be prosecuted in a court of the United States, that is, conspiracy to distribute and

possess with the intent to distribute controlled substances, in violation of Title 21, United States

Code, Sections 846 and 841(a)(1), as set forth in Count One of this Indictment.

(All in violation of Title 18, United States Code, Sections 924(c)(1)(A)(iii) and 2.)

43

COUNT TWENTY-ONE

In or about May 2007, at Chesapeake, in the Eastern District of Virginia, ANTHONY

GONZALEZ did unlawfully, knowingly and intentionally possess with intent to distribute




COUNT TWENTY-TWO

On or about May 24, 2007, in the Eastern District of Virginia and elsewhere, SHAWN

BRANCH and ANTHONY GONZALEZ did unlawfully, knowingly and intentionally travel in

interstate commerce with the intent to promote, manage, carry on, and facilitate the promotion,

management, and carrying on, of an unlawful activity, said unlawful activity being a business

enterprise involving the distribution of cocaine and cocaine base, Schedule II narcotic controlled

substances; marijuana, a Schedule I controlled substance; and heroin, a Schedule I narcotic

controlled substance; in violation of the laws of the United States, and thereafter the SHAWN

BRANCH and ANTHONY GONZALEZ did perform and attempt to perform acts intended to

promote, manage, and facilitate the carrying on of the said unlawful activity, namely on or about

May 24, 2007, SHAWN BRANCH and ANTHONY GONZALEZ travelled from Norfolk,

Virginia to Phoenix, Arizona to meet with a drug supplier concerning a drug debt of

approximately $120,000 for six kilograms of cocaine previously supplied to ANTHONY

GONZALEZ.


44

COUNT TWENTY-THREE

In or about August 2007, at Chesapeake, in the Eastern District of Virginia, ANTHONY





COUNT TWENTY-FOUR

In or about August 2007, at Chesapeake, in the Eastern District of Virginia, ANTHONY


approximately ten (10) kilograms of a mixture and substance containing a detectable amount of



COUNT TWENTY-FIVE

In or about September 2007, at Chesapeake, in the Eastern District of Virginia,


distribute approximately fourteen (14) kilograms of a mixture and substance containing a

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


45

COUNT TWENTY-SIX

In or about September 2007, at Chesapeake, in the Eastern District of Virginia,


distribute approximately 181.81 kilograms (400 pounds) of a mixture and substance containing a



COUNT TWENTY-SEVEN

In or about September 2007, at Virginia Beach, in the Eastern District of Virginia,


distribute approximately one (1) kilogram of a mixture and substance containing a detectable

amount of heroin, a Schedule I narcotic controlled substance.

(In violation Title 21, United States Code, Section 841(a)(1), (b)(1)(A) and Title 18, United States Code, Section 2.)

COUNT TWENTY-EIGHT

In or about October 2007, at Virginia Beach, in the Eastern District of Virginia,


distribute approximately one (1) kilogram of a mixture and substance containing a detectable

amount of heroin, a Schedule I narcotic controlled substance.


46

COUNT TWENTY-NINE

In or about November 2007, in the Eastern District of Virginia, ANTHONY


approximately ten (10) kilograms of a mixture and substance containing a detectable amount of



COUNT THIRTY

In or about November 2007, in the Eastern District of Virginia, ANTHONY





47

COUNT THIRTY-ONE

On or about January 22, 2008, in the Eastern District of Virginia and elsewhere, SHAWN

BRANCH did unlawfully, knowingly and intentionally travel in interstate commerce with the

intent to promote, manage, carry on, and facilitate the promotion, management, and carrying on,

of an unlawful activity, said unlawful activity being a business enterprise involving the

distribution of cocaine and cocaine base, Schedule II narcotic controlled substances; marijuana, a

Schedule I controlled substance; and heroin, a Schedule I narcotic controlled substance; in

violation of the laws of the United States, and thereafter SHAWN BRANCH did perform and

attempt to perform acts intended to promote, manage, and facilitate the carrying on of the said

unlawful activity, namely on or about January 22, 2008, SHAWN BRANCH drove from the

Eastern District of Virginia to Arizona transporting approximately $500,000 in drug proceeds to

a coconspirator.


COUNT THIRTY-TWO On or about January 28, 2008, at Virginia Beach, in the Eastern District of Virginia,

RAYMOND MCCOY did unlawfully, knowingly and intentionally possess with intent to

distribute approximately 200 grams of a mixture and substance containing a detectable amount

of marijuana, a Schedule I controlled substance.

(In violation Title 21, United States Code, Section 841(a)(1), (b)(1)(D) and Title 18, United States Code, Section 2.)

48

COUNT THIRTY-THREE

On or about May 16, 2008, at Norfolk, in the Eastern District of Virginia, CHARLES

SANDERLIN did unlawfully, knowingly and intentionally use, carry and possess a firearm, that

is: a Kel-Tec model P32 .32 caliber semi-automatic pistol bearing serial number CHY98, during

and in relation to and in furtherance of a drug trafficking crime for which he may be prosecuted

in a court of the United States, that is, conspiracy to distribute and possess with the intent to

distribute controlled substances, in violation of Title 21, United States Code, Sections 846 and

841(a)(1), as set forth in Count One of this Indictment.


49

COUNT THIRTY-FOUR

On or about June 13, 2008, in the Eastern District of Virginia and elsewhere, ANTHONY

GONZALEZ and CHARLES SANDERLIN did unlawfully, knowingly and intentionally travel

in interstate and foreign commerce with the intent to promote, manage, carry on, and facilitate

the promotion, management, and carrying on, of an unlawful activity, said unlawful activity

being a business enterprise involving the distribution of cocaine and cocaine base, Schedule II

narcotic controlled substances; marijuana, a Schedule I controlled substance; and heroin, a

Schedule I narcotic controlled substance; in violation of the laws of the United States, and

thereafter ANTHONY GONZALEZ and CHARLES SANDERLIN did perform and attempt to

perform acts intended to promote, manage, and facilitate the carrying on of the said unlawful

activity, namely on or about June 13, 2008, ANTHONY GONZALEZ and CHARLES

SANDERLIN travelled from Newport News, Virginia to Fort Lauderdale, Florida to travel from

Florida to the country of Panama on June 17, 2008 in order to meet with a Panamanian drug

supplier.


50

COUNT THIRTY-FIVE

On or about August 5, 2008, at Newport News, in the Eastern District of Virginia,

CHARLES SANDERLIN did unlawfully, knowingly and intentionally use, carry and possess a

firearm, that is: a IMI model Baby Eagle 9mm semi-automatic pistol bearing serial number

36313894, during and in relation to and in furtherance of a drug trafficking crime for which he





COUNT THIRTY-SIX

On or about August 5, 2008, in the Eastern District of Virginia and elsewhere,

CHARLES SANDERLIN did unlawfully, knowingly and intentionally travel in interstate

commerce with the intent to promote, manage, carry on, and facilitate the promotion,

management, and carrying on, of an unlawful activity, said unlawful activity being a business

enterprise involving the distribution of cocaine and cocaine base, Schedule II narcotic controlled

substances; marijuana, a Schedule I controlled substance; and heroin, a Schedule I narcotic

controlled substance; in violation of the laws of the United States, and thereafter CHARLES

SANDERLIN did perform and attempt to perform acts intended to promote, manage, and

facilitate the carrying on of the said unlawful activity, namely on or about August 5, 2008,

CHARLES SANDERLIN travelled from Newport News, Virginia to Fort Lauderdale, Florida to

deliver a sum of drug proceeds to a coconspirator.


51

COUNT THIRTY-SEVEN

On or about August 29, 2008, at Chesapeake, in the Eastern District of Virginia,

CHARLES SANDERLIN did unlawfully, knowingly and intentionally use, carry and possess

firearms, that is: a IMI model Baby Eagle 9mm semi-automatic pistol bearing serial number

36313894 and a Kel-Tec model P32 .32 caliber semi-automatic pistol bearing serial number

CHY98, during and in relation to and in furtherance of a drug trafficking crime for which he may

be prosecuted in a court of the United States, that is, conspiracy to distribute and possess with the

intent to distribute controlled substances, in violation of Title 21, United States Code, Sections

846 and 841(a)(1), as set forth in Count One of this Indictment.


COUNT THIRTY-EIGHT

From on or about May 25, 2005, and continuously thereafter up to and including on or

about September 24, 2008, at Virginia Beach, in the Eastern District of Virginia, RAYMOND

MCCOY did unlawfully, knowingly and intentionally use, carry and possess firearms during and

in relation to and in furtherance of a drug trafficking crime for which he may be prosecuted in a

court of the United States, that is, conspiracy to distribute and possess with the intent to




52

COUNT THIRTY-NINE

From in or about 2005, and continuously thereafter up to and including in or about

October 2008, at Virginia Beach, in the Eastern District of Virginia, ANTHONY GONZALEZ

did unlawfully, knowingly and intentionally use, carry and possess firearms during and in

relation to and in furtherance of a drug trafficking crime for which he may be prosecuted in a

court of the United States, that is, conspiracy to distribute and possess with the intent to




53

COUNT FORTY THROUGH SEVENTY-EIGHT On or about the dates and times set forth below, in the Eastern District of Virginia and

elsewhere, ANTHONY GONZALEZ, CHARLES SANDERLIN, RICHARD HOGGARD,

JOHN MCCOY, RAYMOND MCCOY, SHAWN BRANCH, and RON WILLIAMS, charged in

the counts set forth below, did unlawfully, knowingly and intentionally use a communication

facility in causing, committing and facilitating the commission of any act constituting any felony

violation of Title 21 of the United States Code, including but not limited to, possessing

controlled substances with intent to distribute and distributing controlled substances, in violation

of Title 21 of the United States Code § 841, and conspiracy to distribute controlled substances

and to possess controlled substances with intent to distribute, in violation of Title 21 of the

United States Code § 846, as charged in this Indictment.

Count Date Time Defendant Charged with using the Communication Facility

Communication Facility Used

Call Session

40 7/6/2008 15:57 ANTHONY GONZALEZ 757-644-9441 0 41 7/7/2008 15:48 ANTHONY GONZALEZ

CHARLES SANDERLIN 757-644-9441 586

42 7/8/2008 13:16 ANTHONY GONZALEZ CHARLES SANDERLIN

757-644-9441 723


757-644-9441 744

44 7/8/2008 15:42 ANTHONY GONZALEZ 757-644-9441 745 45 7/8/2008 15:48 ANTHONY GONZALEZ 305-608-1148 90 46 7/8/2008 17:36 ANTHONY GONZALEZ


47 7/10/2008 18:46 ANTHONY GONZALEZ 305-608-1148 313 48 7/10/2008 21:27 ANTHONY GONZALEZ 757-644-9441 1202 49 7/10/2008 1:06 ANTHONY GONZALEZ 757-644-9441 1267 50 7/11/2008 8:24 ANTHONY GONZALEZ 757-644-9441 1275 51 7/15/2008 16:08 ANTHONY GONZALEZ

JOHN MCCOY 305-608-1148 581

52 7/15/2008 16:11 ANTHONY GONZALEZ JOHN MCCOY

305-608-1148 583


305-608-1148 585

54


305-608-1148 586


305-608-1148 587


305-608-1148 589

57 7/15/2008 17:19 ANTHONY GONZALEZ 305-608-1148 600 58 7/15/2008 18:47 ANTHONY GONZALEZ 305-608-1148 624 59 7/21/2008 15:26 SHAWN BRANCH

ANTHONY GONZALEZ 757-644-9441 3938

60 7/24/2008 18:53 ANTHONY GONZALEZ RON WILLIAMS

757-644-9441 6810





65 8/10/2008 22:42 ANTHONY GONZALEZ 757-644-9441 10985 66 8/15/2008 21:29 RICHARD HOGGARD


67 8/23/2008 10:50 ANTHONY GONZALEZ RICHARD HOGGARD

757-644-9441 15190





72 9/6/2008 17:25 CHARLES SANDERLIN 757-893-0553 2748 73 9/8/2008 22:24 SHAWN BRANCH



757-644-9441 20052

75 9/16/2008 13:34 SHAWN BRANCH ANTHONY GONZALEZ

757-644-9441 20154

76 9/25/2008 14:17 SHAWN BRANCH ANTHONY GONZALEZ

757-644-9441 21080

77 9/25/2008 18:12 RAYMOND MCCOY CHARLES SANDERLIN

757-893-0553 4497

78 9/30/2008 10:18 CHARLES SANDERLIN 757-893-0553 4810 (All in violation of Title 21, United States Code, Section 843(b) and Title 18, United States Code, Section 2).

55

COUNT SEVENTY-NINE

From in or about 2003 and continuously thereafter up to and including on or about the

date of this Indictment at Virginia Beach, in the Eastern District of Virginia, ANTHONY

GONZALEZ did unlawfully, knowingly and intentionally open, lease, rent, use and maintain a

place, that is, a residence located at 333 Southgate Avenue, for the purpose of manufacturing and

distributing controlled substances.

(All in violation of Title 21, United States Code, Section 856(a)(1) and Title 18, United States Code, Section 2.)

COUNT EIGHTY From on or about October 23, 2007 and continuously thereafter up to and including on or

about January 31, 2008 at Virginia Beach, in the Eastern District of Virginia, RAYMOND

MCCOY did unlawfully, knowingly and intentionally open, lease, rent, use and maintain a place,

that is, a residence located at 4728 Windemere Court, Apartment 102, for the purpose of

manufacturing and distributing controlled substances.


56

COUNT EIGHTY-ONE From on or about November 21, 2005 and continuously thereafter up to and including on

or about the date of this Indictment, at Chesapeake, in the Eastern District of Virginia,

ANTHONY GONZALEZ did unlawfully, knowingly and intentionally open, lease, rent, use and

maintain a place, that is, 1100 Ricks Court, for the purpose of manufacturing and distributing

controlled substances.


COUNT EIGHTY-TWO From in or about October 2007 and continuously thereafter up to and including in or

about March 2009, at Virginia Beach, in the Eastern District of Virginia, ANTHONY

GONZALEZ did unlawfully, knowingly and intentionally open, lease, rent, use and maintain a

place, that is, a business known as Encore Lounge located at 1889 Virginia Beach Boulevard, for

the purpose of manufacturing, distributing and using controlled substances and did manage and

control such place as owner, lessee, agent, employee, occupant and mortgagee and did

unlawfully, knowingly and intentionally rent, lease, profit from and make available for use such

place for the purpose of unlawfully manufacturing, storing, distributing and using controlled

substances.

(All in violation of Title 21, United States Code, Section 856(a)(1) and (a)(2) and Title 18, United States Code, Section 2.)

57

FORFEITURE ALLEGATION

Pursuant to Federal Rule of Criminal Procedure 32.2, the allegations contained in Counts

One, Two, Three, Six through Eleven, Thirteen through Eighteen, Twenty-One, Twenty-Three

through Thirty, Thirty-Two, Forty through Seventy-Eight, and Seventy-Nine through Eighty-

Two of this indictment are hereby realleged and incorporated by reference for the purpose of

alleging forfeitures pursuant to Title 21, Untied States Code, Section 853(a).

Upon conviction any of the offenses listed in Counts One, Two, Three, Six through

Eleven, Thirteen through Eighteen, Twenty-One, Twenty-Three through Thirty, Thirty-Two,

Forty through Seventy-Eight, and Seventy-Nine through Eighty-Two above, the Defendants,

ANTHONY GONZALEZ, CHARLES SANDERLIN, RICHARD HOGGARD, JOHN MCCOY,

RAYMOND MCCOY, SHAWN BRANCH, and RON WILLIAMS, shall forfeit to the United

States of America, any property, real or personal used, or intended to be used, in any manner or

part, to commit, or to facilitate the commission of a violation of 21 U.S.C. § 846 or any property

traceable to such property and any property, real or personal, constituting, or derived from, any

proceeds obtained, directly or indirectly, as a result of a violation of 21 U.S.C. § 846. Property

subject to forfeiture consists of, but is not limited to, the following:

1. The sum of not less than $ 9,926,000, which represents any property real or personal that constitutes, or is derived from or is traceable to the proceeds obtained directly or indirectly from the commission of the offenses described above

2. Real property and improvements located at 1100 Ricks Court, Chesapeake, Virginia, owned by Anthony Gonzalez.

3. Real property and improvements located at 5690 Morton Road, Alpharetta, Georgia, owned by Anthony Gonzalez.

4. A 2007 Mercedes-Benz S550 4 door VIN# WDDNG71X87A051214, owned by Anthony Gonzalez.

5. A 2006 Bentley Continental Flying Spur Sedan VIN# SCBBR53W46C036456, owned by Anthony Gonzalez.

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6. A 2007 Toyota Avalon 4 door VIN# 4T1BK36B87U206422, owned by Anthony Gonzalez.

7. A 2006 Nissan 350Z VIN# JN1AZ34D46M300637, owned by Charles Sanderlin.

8. A 2001 Chrysler 300M VIN# 2C3HE66G11H561188, owned by Charles Sanderlin.

9. A 2004 Chrysler Crossfire VIN# 1C3AN69L04X022412, owned by Charles Sanderlin, but titled in the nominee of Kiesha Braithewaite.

10. A 2004 GMC Yukon VIN# 1GKEK63U44J258186, owned by Shawn Branch.

11. A 2006 Infiniti M45 VIN# JNKBY01EX6M201044, owned by Richard Hoggard, but titled in the nominee of Karen Frost and Shana Gregory.

12. All bank accounts, safety deposit boxes and accounts receivable of Anthony Gonzalez to include, but not limited to the following accounts:

13. Wachovia Account# 1079235211720 owned by Anthony Gonzalez and titled in the name of Anthony Gonzalez and Davon Gonzalez;

14. Wachovia Account# 1053039226940 owned by Anthony Gonzalez;

15. Wachovia Account# 1010182544884 owned by Anthony Gonzalez and titled in the name of Davon Gonzalez;

16. Wachovia Account# 3000087952699 owned by Anthony Gonzalez and titled in the name of Davon Gonzalez.

17. Signature Bank Account# 1500341986 owned by Anthony Gonzalez and titled in the name of Soul Providers Management.

18. Signature Bank Account# 1500342494 owned by Anthony Gonzalez.

19. Signature Bank Account# 1500772499 owned by Anthony Gonzalez and titled in the name of Soul Provider Entertainment.

20. Signature Bank CD Account# 1500014690 owned by Anthony Gonzalez.

21. SunTrust Bank Account# 1000064012031 owned by Anthony Gonzalez and titled in the name of Encore Management.

22. Bank of America Account# 435009660854 owned by Anthony Gonzalez.

23. Bank of America Account# 435008091068 owned by Anthony Gonzalez.

24. Bank of America Account# 435008093053 owned by Anthony Gonzalez and titled in the name of Anthony Gonzalez and Ashlee Bunn.

25. Bank of America Account# 435001480252 owned by Anthony Gonzalez and titled in the name of Anthony Gonzalez and Ashlee Bunn.

26. Bank of America Account# 0041-3262-7072 owned by Raymond McCoy.

27. Bank of America Account# 0043-5257-4390 owned by Raymond McCoy.

28. Navy Federal Credit Union Account# 3007875-416 owned by Charles Sanderlin.

29. Navy Federal Credit Union Account# 7005784-900 owned by Charles Sanderlin.

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Pursuant to Title 21, United States Code, Section 853(p), the defendant shall forfeit

substitute property, up to the value of the property subject to forfeiture as described above, if, as

a result of any act or omission of the defendant, any such property subject to forfeiture cannot be

located upon the exercise of due diligence; has been transferred, sold to or deposited with a third

party; has been placed beyond the jurisdiction of the Court; has been substantially diminished in

value; or has been commingled with other property which cannot be divided without difficulty.

(All in accordance with Title 21, United States Code, Section 853).

60

United States v. Anthony Gonzalez, et al. Criminal No. 2:09cr A TRUE BILL: ____________________________________ FOREPERSON DANA J. BOENTE ACTING UNITED STATES ATTORNEY By: Darryl J. Mitchell Assistant United States Attorney Virginia Bar No. 37411 Attorney for the United States United States Attorney’s Office 101 West Main Street, Suite 8000 Norfolk, Virginia 23510 Office Number - 757-441-6331 Facsimile Number - 757-441-6689 E-Mail Address - [email protected]

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