UNITED STATES DISTRICT COURT FOR SOUTHERN DISTRICT OF WEST VIRGIN} BECKLEY GRAND JURY 2017 APRIL 3, 2018 SESSION ‘UNITED STATES OF AMERICA e cemuanas no, 3: (Per 00070 21 U.S.C, § 846 21 0.8.0. § 841 (a) (2) WILDIE VERDELL PETERSON Also known as “Chill” MANGET BROWN PETERSON ~ 2 also known as “Money” LAWRENCE ANTHONY SYKES, OR.-3 also known as “Boog” BRIC CURTIS BROWN ~ 4 algo known as “Eddie” NYANZANGUSA BALDWIN 5 | ‘algo known as “Botch” Jee JARRED MOORE ~ & also known as ‘J” i COREY BEACH ~ 7 i LUTHER COLEMAN PRTERSON “# } also known as “Mook” i ASHLEY BROOKE PARDUE -? } SILAS SOLOMAN PARDUE -/2 CHARLES EDWARD GRAVES, gR.~// also known as “Bo” RRRELL LEDRZ REDD ~/2 also known as “Rell” also known as “Troy” ; LONNIE FREEMAN BERRY, IT “18 DAVID JOHN MILLER ~/ i also known as “John” WALCOMB JEROME simmons “/S also known as “Mac” ‘The Grand Jury Charges:couNT ONE 1. From at least August of 2017 to in and around February of 2018, at or near Huntington, Cabell County, West Virginia, within the Southern District of West Virginia and elsewhere, defendants WILLIE VERDELL PBTERSON, also known as Chill,” MANGET BROWN PETERSON, also known as “Money,” LAWRENCE ANTHONY SYKES, JR., also known as “Boog,” ERIC CURTIS BROWN, also known as “Eddie,” NYANZANGUSA BALDWIN, also known as “Botch,” JARRED MOORE, also known as "J," COREY BEACH, LUTHER COLEMAN PETERSON, also known as "Mook," ASHLEY BROOKE PARDUE, SILAS SCLOMAN PARDUE, CHARLES EDWARD GRAVES, JR., also known as “Bo,” TERRELL LEDEZ REDD, also kmown as “Rell” and also known as “Troy,” LONNIE FREEMAN BERRY, II, DAVID JOHN MILLER, also known as “John,” and MALCOMB JEROME SIMMONS, also known as “Mac,” together with persons whose identities are both known and unknown to the Grand Jury, knowingly conspixed to commit offenses in violation of 21 U.8.C, § 841(a) (1), that is knowingly and intentionally to distribute a quantity of heroin, a Schedule I controlled substance, and a quantity of fentanyl, a Schedule II controlled substance. 2. As part of the conspiracy, it was agreed upon and reasonably foreseeable as to defendants WILLIE VERDELL PETERSON, also known as “Chill,” and MANGBT BROWN PHTERSON, also known as “Woney," that 100 grams or more of heroin, a Schedule I controlledsubstance, would be distributed, in violation of 21 U.S.C, Section 841 (a) (1). In violation of Title 21, United States Code, Section 846.FORFEITURE cn In accordance with 21 U.S.C. § 853(a) and Rules 7(c) (2) and 32.2{a) of the Federal Rules of Criminal Procedure, and premised upon the conviction of the defendants, MANGRT BROWN PETERSON, also known as “Money,” LAWRENCE ANTHONY SYKES, JR., also known as “Boog,” ERIC CURTIS BROWN, also known as “Eddie,” NYANZANGUSA BALDWIN, also known as “Botch,” JARRED MOORE, also known as “0,” CORRY BEACH, LUTHER COLEMAN PRTERSON, also known ad “Mook,” ASHLEY BROOKE PARDUR, SILAS SOLOMAN PARDUE, CHARLES EDWARD GRAVES, JR., also known as “Bo,” TERRELL LEDEZ REDD, also known as “Rell” and also known as “Troy,” LONNIE FREEMAN BERRY, IZ, DAVID JOHN MILLER, also known as “John,” and MALCOMB JEROME SIMMONS, also known as “Mac,” of a violation of Subchapter I of Title 21, forth in Count One, the United States Code 801 et seg., as 4 defendants shall forfeit to the United states any property constituting or derived from any proceeds obtained, directly or indirectly, as the result of such violation, and any property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of the said offense(s), including but not limited to the following: (a) An amount of United States currency in that such sum in aggregate constitutes the gross proceeds involved in or traceable to property involved in the offense set forth | |() (e) te) {£) in Count One of this Indictment, for which sum the United States will seek the entry of a judgment; Approximately $541.00, more or less, in United States currency seized by the DEA and the West Virginia state Police on or about August 4, 2017; Approximately $3,868.00, more or less, in United States currency seized by the DEA and the West Virginia state Police on or about August 4, 2017; Approximately $939.00, more or less, in United States currency seized by the DEA and the West Virginia state Police on or about February 2, 2018; Kimber Ultra Carry TT 45 Auto pistol, serial number KU296175, seized by the DBA and the West Virginia state Police on August 4, 2017; Standard 38 caliber revolver, serial number sTi9664, seized by the DEA and the West Virginia State Police on August 4, 2017. NOTICE OF INTENT TO FORFRIT SUBSTITUTE ASSETS If any of the property described above, as a result of any act or omission of the defendants: a. cannot be located upon the exercise of due diligence; b. hag been transferred or sold to, or deposited with, 4 third party; ¢. has been placed beyond the jurisdiction of thehas been commingled with other property which cannot be divided without difficulty; the United states of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section #53 (p). MICHAEL B. STUART United States Attorney ae has been substantially diminished in value; or | | | i | 1 | Ea i Agsistant United States Attorney i