Complaint AUSA Megan Cunniff Church (312) 886-1173 AUSA Michelle Nasser (312) 469-6201 UNITED STATES DISTRICT COURT NORTHERN DISTRICT of ILLINOIS EASTERN DIVISION
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AO 91 (Rev. 11/11) Criminal Complaint AUSA Megan Cunniff Church (312) 886-1173 AUSA Michelle Nasser (312) 469-6201 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CASE NUMBER: 14 CR 588 v. UNDER SEAL JASON MAREK, also known as “Murder” and “Murda”; THADIEUS GOODS, also known as “Big Weasy,” “Weasy,” and “Wang”; LAVANGELIST POWELL, also known as “Ju Ju” and “Juicy”; PRINCE JOHNSON, also known as “Primo”; PEARLISA STEVENSON, also known as “Wang Wang”; NATOSHA MCCOLLUM, also known as “Tasha”; and STEPHANIE LEWIS CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. COUNT ONE From on or about June 15, 2013 to on or about June 24, 2013, in the Northern District of Illinois, Eastern Division, and elsewhere, defendants JASON MAREK, also known as “Murder” and Murda”; THADIEUS GOODS, also known as “Big Weasy,” “Weasy,” and “Wang”; LAVANGELIST POWELL, also known as “Ju Ju” and “Juicy”; PRINCE JOHNSON, also known as “Primo”; PEARLISA STEVENSON, also known as “Wang Wang”; and NATOSHA McCOLLUM, also known as “Tasha” conspired with each other and with others known and unknown to knowingly and intentionally possess with intent to distribute and to distribute a controlled substance, namely, marijuana, in violation of 21 U.S.C. § 846. COUNT TWO On or about June 24, 2013, at Chicago, in the Northern District of Illinois, Eastern Division, defendant STEPHANIE LEWIS accessed a computer without authorization and exceeded authorized access to obtain information in furtherance of a criminal act in violation of the Constitution or laws of the United States, namely, violations of 18 U.S.C. § 1951 and 21 U.S.C. § 846, in violation of 18 U.S.C. § 1030(a)(2)(B). COUNT THREE From on or about June 22, 2013 to on or about June 24, 2013, at Chicago, in the Northern District of Illinois, Eastern Division, defendants LAVANGELIST POWELL, also known as “Ju Ju” and “Juicy”; PRINCE JOHNSON, also known as “Primo”; PEARLISA STEVENSON, also known as “Wang Wang”; NATOSHA McCOLLUM, also known as “Tasha”; and STEPHANIE LEWIS conspired with each other to access a computer without authorization and to exceed authorized access to obtain information in furtherance of a criminal act in violation of the Constitution or law of the United States, namely, violations of 18 U.S.C. § 1951 and 21 U.S.C. § 846, in violation of 18 U.S.C. § 1030(b). This criminal complaint is based upon these facts: X Continued on the attached sheet. BRYAN BUTLER Special Agent, Federal Bureau of Investigation (FBI) Sworn to before me and signed in my presence. Date: October 20, 2014 Judge’s signature City and state: Chicago, Illinois JEFFREY T. GILBERT, U.S. Magistrate Judge Printed name and Title UNITED STATES DISTRICT COURT ss NORTHERN DISTRICT OF ILLINOIS AFFIDAVIT I, BRYAN BUTLER, being duly sworn, state as follows: 1. I am a Special Agent with the Federal Bureau of Investigation, and have been so employed for four years. My current responsibilities include the investigation of public corruption offenses. 2. This affidavit is submitted in support of a criminal complaint alleging that: a. JASON MAREK, also known as “Murder” and “Murda” (MAREK); THADIEUS GOODS, aka “Big Weasy,” “Weasy,” and “Wang”; LAVANGELIST POWELL, aka “Ju Ju” and “Juicy”; PRINCE JOHNSON, aka “Primo”; PEARLISA STEVENSON, aka “Wang Wang”; and NATOSHA McCOLLUM, aka “Tasha” conspired with each other and with others known and unknown to knowingly and intentionally possess with intent to distribute and to distribute a controlled substance, namely, marijuana, in violation of 21 U.S.C. § 846; b. STEPHANIE LEWIS accessed a computer without authorization and exceeded authorized access to obtain information in furtherance of a criminal act in violation of the Constitution or laws of the United States, namely, violations of 18 U.S.C. § 1951 and 21 U.S.C. § 846, in violation of 18 U.S.C. § 1030(a)(2)(B); and c. POWELL, JOHNSON, McCOLLUM, and LEWIS conspired with each other to access a computer without authorization and to exceed authorized access to obtain information in furtherance of a criminal act in violation of the Constitution or law of the United States, namely, violations of 18 U.S.C. § 1951 and 21 U.S.C. § 846, in violation of 18 U.S.C. § 1030(b). 3. Because this affidavit is being submitted for the limited purpose of establishing probable cause in support of a criminal complaint charging (1) MAREK, GOODS, POWELL, JOHNSON, STEVENSON, and McCOLLUM with conspiracy to distribute a controlled substance, (2) LEWIS with unauthorized access and exceeding authorized access of a computer; and (3) POWELL, JOHNSON, McCOLLUM, and LEWIS with conspiracy to access without authorization and to exceed authorized access to a computer, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that the defendants committed the offenses alleged in the complaint. 4. This affidavit is based on my personal knowledge, information provided to me by other law enforcement officials, interviews of witnesses, review of consensually-recorded conversations and telephone calls placed by inmates within Cook County Jail, review of public records databases, and my training and experience as a law enforcement agent. 5. This investigation included the use of consensually-recorded telephone calls, audio recorded, and audio and video recorded meetings. The summaries of 2 recorded conversations in this affidavit do not include reference to all of the topics discussed during the conversations. Further, quoted material from the recorded conversations set out in this affidavit is taken from draft summaries, not final transcripts. 6. In many of the paragraphs describing consensually-recorded conversations, either over the phone or in person, interpretations of the discussion are included in brackets. These interpretations include meanings attributed to code words, coded language, or vague references used by speakers. My understanding and interpretation of the conversations is based upon the contents of the conversations, the context of prior and subsequent conversations, the events that transpired in this investigation, my knowledge derived from this investigation, my experience and training as a law enforcement agent and the experience and training of other law enforcement participating in this and other investigations, including narcotics investigations, and my conversations with witnesses involved in this case. The times listed for these recordings are approximate. In most cases, voice identifications are based on names used during the conversations, voice recognition that has been accomplished to date by law enforcement officers and by the Securus voice-biometric system, historical information developed during this investigation, and/or telephone subscriber information. Finally, the summaries below do not include all recordings, or all statements or topics covered during the course of the conversations. 3 I. OVERVIEW OF THE DEFENDANTS 7. According to training records obtained from Cook County Department of Corrections, MAREK has been employed as a Corrections Officer by the Department of Corrections since May 2011. On July 26, 2011, the Illinois Law Enforcement Training and Standards Board authorized MAREK to carry out “sworn duties as a peace officer in the State of Illinois.” According to recorded calls and the events that transpired during this investigation, STEVENSON and GOODS referred to MAREK by the nicknames “Murder” and “Murda.” 8. According to Department of Corrections personnel, Correctional Officers receive their assignments on a ninety-day periodic basis. Although an officer may be assigned to a location for a ninety-day period, the officer can receive daily ad-hoc reassignments. In June 2013, MAREK’s ninety-day periodic assignment was CCJ, Division 9, Tier 2H. During that period, MAREK worked an evening shift from 3:00 p.m. to 11:00 p.m. 9. According to Cook County Sheriff’s Office Inmate Classification Records, GOODS was an inmate at CCJ from approximately July 6, 2007 to February 11, 2014, on pending charges of murder. From June 30, 2012 to July 2, 2013, GOODS was housed in Division 9 on Tier 2H. According to Illinois State Police criminal history records, on or about February 10, 2014, GOODS was convicted of murder, in violation of 720 ILCS 5/9-1(A)(2), and received a sentence of sixty-five years’ imprisonment. According to a Chicago Police Department Identification Section criminal history report and recorded jail calls, GOODS uses 4 the aliases “Big Weasy,” “Weasy,” and “Wa.” According to statements made by GOODS during recorded jail calls, GOODS is married to STEVENSON, who uses the nickname “Wang-Wang.” 10. According to Cook County Sheriff’s Office Inmate Classification Records, POWELL has been an inmate at CCJ since approximately January 13, 2013, on pending charges of solicitation / murder; and from January 14, 2013 to September 13, 2013, POWELL was housed in Division 9, Tier 2H of CCJ. According to recorded telephone calls, POWELL uses the aliases “Ju-Ju” and “Juicy.” According to statements made by POWELL during recorded jail calls, including a call described in paragraph 29 below, POWELL is in a romantic relationship with McCOLLUM. 11. According to Cook County Sheriff’s Office Inmate Classification Records, JOHNSON has been an inmate at CCJ since approximately August 7, 2007, on pending charges of Intent to Commit First Degree Murder; and from March 8, 2013 to February 14, 2014, JOHNSON was housed in Division 9 on Tier 2H. According to recorded jail calls, JOHNSON uses the alias “Primo.” According to statements made by JOHNSON during recorded jail calls, JOHNSON is in a romantic relationship with LEWIS. 12. According to the City of Chicago employee directory, LEWIS is a “Supervisor Police Operations” in the Police Dispatch workgroup of the City of Chicago Office of Emergency Management and Communications.