United States District Court Northern District of Illinois Eastern Division
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AO 91 (Rev. 11/11) Criminal Complaint AUSAs Christopher Grohman (312) 469-6132 Rajnath P. Laud (312) 469-6306 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA CASE NUMBER: v. UNDER SEAL JOHNNY HERNDON, also known as “Goo,” CHRISTOPHER HARRIS, JONATHAN GREEN, also known as “Whiteboy” and “Whitey,” FABIAN REDMOND, also known as “Mook,” JONATHAN O'LEARY, also known as “JB,” ANTWAION EDWARDS, also known as “Fee,” MARCUS LONGSTREET, also known as “Chico,” MANUEL MEEKS, also known as “Big Shorty,” CAUIRENCE HERNDON, also known as “C” and G,” DESHAWN RICHARDSON, also known as “Shawn,” “Little Lord,” and “D,” ANDREW JONES, also known as “Crowbar,” PATRICIA NEAL, EDUARDO ZAMUDIO, also known as “Lalo” ROBERT RUSSELL, also known as “Hurk,” ROBERT SMITH, also known as “Bo,” DARRYL JONES, also known as “Heavy,” MILDRED SMITH, HARRY SMITH, KESHAW EUELL, and DARVEN MARION CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief: Count One Beginning no later than in or about 2013, and continuing until the present, at Chicago, in the Northern District of Illinois, the following Individuals did conspire with each other, and with others known and unknown, to knowingly and intentionally possess with intent to distribute and to distribute controlled substances, namely, 280 grams or more of mixtures and substances containing cocaine base, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1), in violation of Title 21, United States Code, Section 846: JOHNNY HERNDON, also known as (“aka”) “Goo,” CHRISTOPHER HARRIS, JONATHAN GREEN, aka “Whiteboy” and “Whitey,” FABIAN REDMOND, aka “Mook,” JONATHAN O’LEARY, aka “JB,” ANTWAION EDWARDS, aka “Fee,” MARCUS LONGSTREET, aka “Chico,” MANUEL MEEKS, aka “Big Shorty,” CAUIRENCE HERNDON, aka “C” and “G,” DeSHAWN RICHARDSON, aka “Shawn,” “Lord,” and “D,” ANDREW JONES, aka “Crowbar,” and PATRICIA NEAL (NEAL). Count Two On or about June 7, 2014, CHRISTOPHER HARRIS, at Chicago, in the Northern District of Illinois, Eastern Division, previously having been convicted of a crime punishable by a term of imprisonment exceeding one year, did knowingly possess, in and affecting interstate commerce, a firearm, namely, a loaded silver Rossi, Amadeo & Co. .357 caliber revolver bearing serial number F063110, which firearm had traveled in interstate commerce prior to defendant=s possession of the firearm, in violation of Title 18, United States Code, Section 922(g)(1). 2 Count Three On or about April 16, 2014, JOHNNY HERNDON, at Chicago, in the Northern District of Illinois, knowingly and intentionally distributed a controlled substance, namely, 100 grams or more of a mixtures and substances containing heroin, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Four On or about May 7, 2014, EDUARDO ZAMUDIO, aka “Lalo,” at Chicago, in the Northern District of Illinois, knowingly and intentionally distributed a controlled substance, namely, 100 grams or more of a mixtures and substances containing heroin, a Schedule I Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Five On or about July 24, 2014, ROBERT RUSSELL, aka “Hurk,” at Chicago, in the Northern District of Illinois, knowingly and intentionally possessed with the intent to distribute a controlled substance, namely, a quantity of mixtures and substances containing cocaine, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Six On or about May 1, 2014, ROBERT SMITH, aka “Bo,” at Chicago, in the Northern District of Illinois, knowingly and intentionally distributed a controlled substance, namely, 28 grams or more of a mixtures and substances containing cocaine base, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Seven On or about May 1, 2014, DARRYL JONES, aka “Heavy,” at Chicago, in the Northern District of Illinois, knowingly and intentionally possessed with the intent to distribute a controlled substance, namely, 28 grams or more of a mixtures and substances containing cocaine 3 base, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Eight On or about May 1, 2014, MILDRED SMITH, at Chicago, in the Northern District of Illinois, knowingly and intentionally possessed with the intent to distribute controlled substances, namely, a quantity of mixtures and substances containing cocaine base and a quantity of mixtures and substances containing cocaine, Schedule II Controlled Substances, in violation of Title 21, United States Code, Section 841(a)(1). Count Nine On or about April 26, 2014, HARRY SMITH, at Chicago, in the Northern District of Illinois, knowingly and intentionally possessed with the intent to distribute a controlled substance, namely, a quantity of mixtures and substances containing cocaine base, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). Count Ten On or about April 28, 2014, KESHAW EUELL, at Chicago, in the Northern District of Illinois, knowingly and intentionally possessed with the intent to distribute a controlled substance, namely, a quantity of a mixtures and substances containing cocaine, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). 4 Count Eleven On or about July 22, 2014, DARVEN MARION, at Chicago, in the Northern District of Illinois, knowingly and intentionally distributed a controlled substance, namely, a quantity of a mixtures and substances containing cocaine, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1). This criminal complaint is based upon these facts: X Continued on the attached sheet. GRAHAM R. GRAFTON Special Agent, Bureau of Alcohol, Tobacco, Firearms & Explosives (ATF) Sworn to before me and signed in my presence. Date: August 6, 2014 Judge’s signature 5 City and state: Chicago, Illinois Michael T. Mason, U.S. Magistrate Judge Printed name and Title 6 NORTHERN DISTRICT ) ) OF ILLINOIS ) AFFIDAVIT I, Graham R. Grafton, Special Agent of the Bureau of Alcohol Tobacco, Firearms, and Explosives (“ATF”), having been duly sworn under oath, state as follows: I. PRELIMINARY MATTERS 1. I am a Special Agent with the ATF. I have been so employed since December 2012. As part of my regular duties as a Special Agent, I investigate criminal violations of the federal firearms laws, including Title 18, United States Code, Sections 922 and 924, as well as federal narcotics laws, including Title 21, United States Code, Sections 841(a)(1) and 846. I have received training regarding, among other things, violations of federal firearms and narcotics laws at the Federal Law Enforcement Training Center and the Federal Bureau of Investigation’s Academy. 2. I have been a law enforcement officer for approximately 10 years, having previously been employed as a Special Agent with the Federal Bureau of Investigation from 2004 to 2006 and the Naval Criminal Investigative Service (“NCIS”) from 2006 to 2012. For the majority of my time in law enforcement, I have been assigned to various local, regional and federal task forces, including participation in multiple Organized Crime Drug Enforcement Task Force (“OCDETF”) operations, focused on the investigation of violent crimes and narcotics trafficking. I have been involved in various forms of electronic surveillance and the debriefing of defendants, informants, and witnesses, as well as others who have knowledge of the distribution, transportation, storage, and importation of controlled substances. 1 3. Based on my training and experience, I am familiar with the ways in which narcotics traffickers operate, including, but not limited to their: (a) methods of distributing narcotics; (b) use of telephone communication devices; and (c) use of code words to conduct their drug-related transactions. Further, I am aware that cellular telephones are an important method of communication utilized by drug dealers generally, and the participants in this criminal enterprise in particular. 4. This affidavit is made in support of a multi-count criminal complaint charging that – a. Beginning no later than in or about 2013, and continuing until the present, at Chicago, in the Northern District of Illinois, the following Individuals did conspire with each other, and with others known and unknown, to knowingly and intentionally possess with intent to distribute and to distribute controlled substances, namely, 280 grams or more of mixtures and substances containing cocaine base, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1), in violation of Title 21, United States Code, Section 846: JOHNNY HERNDON, also known as (“aka”) “Goo” (HERNDON); CHRISTOPHER HARRIS, (HARRIS); JONATHAN GREEN, aka “Whiteboy” and “Whitey” (GREEN); FABIAN REDMOND, aka “Mook” (REDMOND); JONATHAN O’LEARY, aka “JB” (O’LEARY); ANTWAION EDWARDS, aka “Fee” (EDWARDS); MARCUS LONGSTREET, aka “Chico” (LONGSTREET); MANUEL MEEKS, aka “Big Shorty” (MEEKS); CAUIRENCE HERNDON, aka “C” and “G” (CAUIRENCE); DeSHAWN RICHARDSON, aka “Shawn,” “Little Lord” and “D” (RICHARDSON); ANDREW JONES, aka “Crowbar” (JONES); and PATRICIA NEAL (NEAL). 2 b. On or about June 7, 2014, CHRISTOPHER HARRIS, at Chicago, in the Northern District of Illinois, Eastern