SEALED 4 S/ T
Case 3:21-mj-02060-JLB Document 1 Filed 05/21/21 PageID.68 Page 1 of 53 1 2 3 SEALED 4 s/ T. Ferris 5 6 7 ORDERED UNSEALED on 07/19/2021 s/ TrishaF 8 9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 UNITED STATES OF AMERICA, Case No.: 21-MJ-2060 13 Plaintiff, COMPLAINT FOR VIOLATION OF: 14 v. Title 21 U.S.C.§ 841(a)(1) 15 Distribution of a Controlled Substance 16 Lindsay Renee HENNING, (Felony); Title 21 U.S.C. §§ 841(a)(1) 17 Garrett Carl TUGGLE, and 846 Conspiracy to Distribute LSD (Felony); Title 18, U.S.C., Sec. 1349 – 18 Defendants. Conspiracy; Title 18, U.S.C., Sec. 19 981(a)(1)(C), and Title 28, U.S.C., Sec 2461(c) – Criminal Forfeiture 20 21 22 23 The undersigned complainant being duly sworn states: 24 COUNT ONE 25 On or about June 15, 2020, within the Southern District of California, defendant, 26 Lindsay Renee HENNING, did knowingly and intentionally distribute approximately 7 27 grams (0.015 pounds) of a mixture and substance containing a detectable amount of 28 Case 3:21-mj-02060-JLB Document 1 Filed 05/21/21 PageID.69 Page 2 of 53 1 methylenedioxymethamphetamine (MDMA), a Schedule II Controlled Substance in 2 violation of Title 21, United States Code, Section 841(a)(1). 3 COUNT TWO 4 Beginning at a date unknown and continuing up to and including September 8, 2020, 5 within the Southern District of California, defendant, Lindsay Renee HENNING, did 6 knowingly and intentionally conspire together with JT and with other persons known and 7 unknown to distribute approximately 1 gram and more, of a mixture and substance 8 containing a detectable amount of lysergic acid diethylamide (LSD), a Schedule I 9 Controlled Substance; in violation of Title 21, United States Code, Sections 841(a)(1) and 10 846 and, Title 18, United States Code, Section 2.
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