UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAHolding a Criminal TermGrand Jury Sworn in on May 15, 2009UNITED STATES OF AMERICA, : CRIMINAL NO. :v. : GRAND JURY ORIGINAL :CURTIS M. HOUSTON, : VIOLATIONS: 21 U.S.C. § 846also known as C, : (Conspiracy to Distribute and Possess Withalso known as Long Dog, : Intent to Distribute 5 Kilograms or More of: Cocaine and 50 Grams or More of CocaineTYRONE W. GLOSTER, : Base)also known as Freaky, : 21 U.S.C. § 853 : (Criminal Forfeiture)SAQUON K. BETHEA, :also known as Quon, :also known as Q, ::ELLIOTT F. DAVIS, :also known as L, ::WILLIAM R. A. SMITH, : also known as Anwan, :also known as Ant, :also known as Anwur, ::JIMMY L. HAIRSTON, ::WYATT E. ROBINSON, ::RICKY CHADWICK, : :Defendants. ::I N D I C T M E N TThe Grand Jury charges that:

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COUNT ONEFrom on or about October 1, 2008, to on or about August 1, 2010, within the District ofColumbia and elsewhere, CURTIS M. HOUSTON, also known as C, also known as Long Dog,TYRONE W. GLOSTER, also known as Freaky, SAQUON K. BETHEA, also known as Quon,also known as Q, ELLIOTT DAVIS, also known as L, WILLIAM R. A. SMITH, also known asAnwan, also known as Ant, also known as Anwur, JIMMY L. HAIRSTON, WYATT E.ROBINSON, RICKY CHADWICK and MARK D. SMITH, a co-conspirator not indicted herein,did knowingly and willfully combine, conspire, confederate and agree together and with otherpersons both known and unknown to the Grand Jury, to unlawfully, knowingly and intentionallydistribute and possess with intent to distribute a mixture and substance containing a detectableamount of cocaine, a Schedule II narcotic drug controlled substance, and the amount of said mixtureand substance was 5 kilograms or more, in violation of Title 21, United States Code, Sections841(a)(1) and 841(b)(1)(A)(I), and a mixture and substance containing a detectable amount ofcocaine base, also known as crack, a Schedule II narcotic drug controlled substance, and the amountof said mixture and substance was 50 grams or more, in violation of Title 21, United States Code,Sections 841(a)(1), 841(b)(1)(A)(ii), and 841(b)(1)(A)(iii). (Conspiracy to Distribute and Possess with Intent to Distribute 5 Kilograms or Moreof Cocaine and 50 Grams or More of Cocaine Base, in violation of Title 21, United StatesCode, Section 846) FORFEITURE ALLEGATION1. The allegations contained in Count One of this Indictment, Conspiracy to Distributeand Possess with Intent to Distribute 5 Kilograms or More of Cocaine and 50 Grams or More ofCocaine Base, in violation of Title 21, United States Code, Section 846, are hereby realleged and

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incorporated by reference for the purpose of alleging forfeiture pursuant to Title 21, United StatesCode, Section 853.2. Pursuant to Title 21, United States Code, Section 853, upon conviction of an offensein violation of Title 21, United States Code, Section 846, the defendants shall forfeit to the UnitedStates of America any property constituting, or derived from, any proceeds obtained, directly orindirectly, as the result of such offense and any property used, or intended to be used, in any manneror part, to commit, or to facilitate the commission of, the offense. The property to be forfeited includes, but is not limited to, the following:(a) Money Judgment:(i) a sum of money that is equal to the amount of money constituting,or derived from, proceeds obtained, directly or indirectly, as a resultof the offense alleged in Count One. (b) U.S. Currency(i) $5,617 in U.S. Currency, which represents a sum of money constituting, orderived from, proceeds obtained, directly or indirectly, as a result of the offensealleged in Count One.3. If any of the property described above, as a result of any act or omissionof the defendants:a. cannot be located upon the exercise of due diligence; b. has been transferred or sold to, or deposited with, a third party;c. has been placed beyond the jurisdiction of the court;d. has been substantially diminished in value; or

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e. has been commingled with other property which cannot be divided withoutdifficulty;the United States of America shall be entitled to forfeiture of substitute property pursuant to Title21, United States Code, Section 853(p).(Criminal Forfeiture, in violation of Title 21, United States Code, Section 853)A TRUE BILL:FOREPERSON.

Attorney of the United States inand for the District of Columbia.

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