u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426...

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI FILiED. EASTERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. - ISRAEL ANGELES-MONTEZUMA, a/kIa "Amigo" (1), . ALAN CARDENAS, a/kIa "AI" (2), DAVID SCHAFFER (3), MICHAEL CHANDLER (4), AMANDA YOUNG, a/kIa "Amanda Jinkerson" (5), AMANDA MILBOURN (6), BONNIE ORMAN (7), GUSTAVO ALVAREZ-ANGELES, a/kIa "Guz" (8), -WILLIAM GILLMAN, a/kIa ''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, a/kIa "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 ) ) ) 4:16-cr-00426 CDP/JMB ) ) 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 Case: 4:16-cr-00426-CDP-JMB Doc. #: 2 Filed: 09/28/16 Page: 1 of 21 PageID #: 81

Transcript of u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426...

Page 1: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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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

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)

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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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Page 2: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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

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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

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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

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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Page 3: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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

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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

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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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Page 4: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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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

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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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Page 5: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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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

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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

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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

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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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Page 6: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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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

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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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Page 7: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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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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Page 8: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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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Page 9: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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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Page 10: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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Page 11: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

~

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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Page 12: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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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Page 13: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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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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Page 15: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 16 of 21 PageID 96

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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 17 of 21 PageID 97

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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 18 of 21 PageID 98

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

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

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Page 17: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 17 of 21 PageID 97

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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 18 of 21 PageID 98

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

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

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Page 18: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

Case 416-cr-00426-CDP-JMB Doc 2 Filed 092816 Page 18 of 21 PageID 98

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

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

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Page 19: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

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

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Page 20: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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

Page 21: u. DistRICT COURT Plaintiff, ST. LOUIS 4:16-cr-00426 CDP/JMBbloximages.newyork1.vip.townnews.com/stltoday.com/... · 2016-10-04 · is part ofsaid drug trafficking conspiracy that

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