MAR Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 1 of 32 PageID# 28. IN THE UNITED STATES DISTRICT COURT FOR frhe

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1 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 1 of 32 PageID# 28 IN THE UNITED STATES DISTRICT COURT FOR frhe EASTERN DISTRICT OF VIRGINIA FILED IN OP. COURT. MAR Newport News Division CLERK. U.S. DISTRICT COURT NEWPORT NEWS. VA UNITED STATES OF AMERICA CRIMINAL NO. 4:14CR59 v. ERIC PRIDGEN a/k/a "Rabbif a/k/a "Rab" (Counts 1, 3-7, 9-11, 13-14, 16-17) HERBERT PRIDGEN a/k/a "Bok" (Counts 1-4,6-7,9, 12,15-17) DOUGLAS ASHBY a/k/a "Murder Mance" a/k/a "Mance" a/k/a "Murder" (Counts 1,3, 9, 12) MAURICE MCLAIN a/k/a "Mo" (Counts 1) ROBBIE BOWLES a/k/a "Rob" (Counts 1) ANTONIO JOHNSON (Counts 3-4, 8) 18U.S.C. 1962(d) Racketeering Conspiracy (Count 1) 18U.S.C. 1959(a)(1) and 2 Murder in Aid of Racketeering (Counts 6, 11, 16) 18U.S.C. 9240X0 and 2 Using, Carrying, and Discharging a Firearm During and in Relation to, and Possession and Discharging of a Firearm in Furtherance of, a Crime of Violence Resulting in Murder (Counts , 17) 18 U.S.C. 922(g)(1) Felon in Possession of Firearm and Ammunition (Counts 2, 5, 10, 14-15) 18U.S.C. 1951(a) Conspiracy to Interfere with Commerce by Robbery (Count 3) 18U.S.C. 1951(a) and 2 Interference with Commerce by Robbery (Counts 4, 9)

2 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 2 of 32 PageID# 29 SECOND SUPERSEDING INDICTMENT MARCH 2015 TERM - at Newport News, Virginia THE GRAND JURY CHARGES THAT: COUNT ONE (Racketeering Conspiracy) The Enterprise 1. The defendants ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN, a/k/a "Bok," DOUGLAS ASHBY, a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," MAURICE MCLAIN a/k/a "Mo," and ROBBIE BOWLES, a/k/a "Rob," and others known and unknown to the Grand Jury, were members and associates ofa neighborhood gang that was known alternatively as "Thug Relations," "TR," "the Duct," "Warwick Lawnz," and "from the Duct to the Lawnz" (hereafter, Thug Relations). Thug Relations had subsidiary groups called"grind Team Clique" or "GTC," and "Hollow Tip Clique" or "HTC." Thug Relations was a criminal organization whose members and associates engaged in acts of violence, including murder, threat ofmurder, attempted murder, malicious wounding, robbery, attempted robbery, witness intimidation, and narcotics distribution. Thug Relations operated principally in a geographic area that included the Aqueduct Apartments, St. Michael's Apartments, Warwick Lawns, Warwick Town Homes, Heritage Trace Apartments, Mariner's Landing Apartments, Sharon Drive, and the Savage Drive areas ofnewport News, Virginia. 2. Members ofthug Relations signified their membership in various ways. Members bore tattoos such as "Thug Relations," "TR," "the Duct," "Warwick Lawnz," and "Duct to the Lawnz," "Grind Team Clique," "GTC," "Hollow Tip Clique" and "HTC." Thug Relations members displayed distinctive hand signs. When entering a business or gathering of

3 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 3 of 32 PageID# 30 people, ThugRelations members and associates would yell slogans such as "TR," The Duct," "The Lawnz," and others. 3. Thug Relations clashed with other gangs including "The Dump Squad," "Courthouse Green," and "The Black P-Stones," which was also known as the "P-Stones," who claimed allegiance to the "Bloods" gang. Thug Relations members engaged in acts of intimidation and violence toward rival gangs. Some members of Thug Relations claimed to be aligned with the "Crips" gang. 4. Thug Relations, including its members and associates, constituted an "Enterprise" as defined by Title 18,United States Code, Section 1961 (4) (hereinafter "the Enterprise"), that is, a group of individuals associated in fact that was engaged in, and the activities of whichaffected, interstate and foreign commerce. The Enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose ofachieving the objectives ofthe Enterprise. 5. The above-described Enterprise, through its members and associates, engaged in racketeering activity as defined in Title 18, United States Code, Section 1961(1), namely, acts involving murder and robbery, in violation ofthe Code of Virginia, and in violation oftitle 18, United States Code Section 1951, and drug trafficking, in violation oftitle 21, United States Code, Sections 841 and 846. Purposes and Objectives ofthe Enterprise 6. The purposes ofthe Enterprise included the following: a. Enriching, preserving, expanding, and protecting the power, territory, and prestige of the Enterprise through the use of intimidation, violence, and threats of

4 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 4 of 32 PageID# 31 violence to include murder, attempted murder, malicious wounding, assault, robbery, and narcotics distribution. b. Promoting and enhancing the Enterprise and its members' and associates' activities. c. Sharing and disseminating information about the enterprise's plans and activities among members and associates of the enterprise. d. Keeping rival drug dealers and gang members in fear of the Enterprise and in fear ofits members and associates through threats of violence and acts ofviolence. e. Confronting and retaliating against rival gangs and rival drug dealers through the use of intimidation, violence, threats ofviolence, and assaults. f. Providing assistance to the Enterprise's members and associates who committed crimes, in order to hinder, obstruct, and prevent law enforcement authorities from identifying, apprehending, and successfully prosecuting the offenders, by witness intimidation, perjury, destruction and disposal ofevidence, and other means. g. Financially supporting members of the Enterprise through the trafficking of cocaine base, known as "crack" cocaine, cocaine, and marijuana, and through robberies and home invasions. Means and Methods ofthe Enterprise 7. The means and methods used by the defendants and their associates, included, but were not limited to, the following: a. Using intimidation, violence, and threats ofviolence to preserve and

5 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 5 of 32 PageID# 32 protectthe Enterprise's territory and criminal activities. b. Using intimidation, violence, and threats of violence to promote and enhance the Enterprise's prestige, reputation, and position in the community. c. Communicating with other members and associates in person and by telephone to plan, discuss, and coordinate criminal activities, and to receive support, encouragement, and assistance for such activities. d. Providing resources (such as transportation, firearms, and controlled substances) to facilitate the commission of crimes committed by other members and associates ofthe Enterprise. e. Promoting a climate of fear in the community through intimidation, violence, and threats of violence to further the criminal activities of Enterprise members, which included narcotics trafficking activities, murder, attempted murder, malicious wounding, and robbery. f. Using intimidation, violence, and threats of violence against known and suspected rival gang members, rival drug dealers,and various individuals. g. Protecting the Enterprise and its members from detection, apprehension, and prosecution by law enforcement officers by using threats of violence to dissuade potential witnesses from notifying or cooperating with authorities. h. Confronting and retaliating against rival gangs and rival drug dealers through the use ofintimidation, violence, threats ofviolence, and assaults. i. Robbing other drug dealers to obtain cash, firearms, and drugs for re-sale. j. Trafficking in cocaine base, commonly known as "crack cocaine," 5

6 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 6 of 32 PageID# 33 cocaine, and marijuana. k. Sharing among the Enterprise supplies of, and storage locations for, cocaine base, cocaine, marijuana, and firearms. 1. Protecting the territory of the Enterprise to allow the Enterprise's members to earn money through the sale ofcontrolled substances within its territory. m. Claiming and marking the territory of the Enterprise by the use of graffiti, slogans, tattoos, and the boasting aboutthe existence, exploits, and violentacts of the Enterprise in rap songs, rap videos, and on social media websites. The Racketeering Conspiracy 8. Beginning at some point in or about December 2003, the exact date being unknown to the Grand Jury, until on or about June 2012, in the Eastern District of Virginia and elsewhere, the defendants ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN a/k/a "Bok," DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder,"MAURICE MCLAIN a/k/a "Mo," and ROBBIE BOWLES, a/k/a "Rob," together with others known and unknown to the Grand Jury, being persons employed by and associated with Thug Relations as described in Paragraphs One through Seven ofthis Count, did knowingly and intentionally combine, conspire, confederate, and agree with each other, and with other persons known and unknown to the Grand Jury, to violate Title 18,United States Code, Section 1962(c), namely to conduct and participate, directly and indirectly, in the conduct of the affairs of that Enterprise, which was engaged in and the activities of which affected interstate commerce, through a pattern ofracketeering activity, as that term is defined by Title 18, United States Code, Section 1961(1) and (5), which consisted of multiple acts

7 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 7 of 32 PageID# 34 involving: a. Murder, Attempted Murder, and Conspiracy to Commit Murder, chargeable under Va. Code , , and , and the common law ofvirginia; b. Robbery, Attempted Robbery, and Conspiracy to Commit Robbery chargeable under Va. Code , , and , and the common law ofvirginia; and multiple acts indictable under: c. 18 U.S.C (Conspiracy to Interfere with and Interference with Commerce by Robbery). 9. It was further apart ofthe conspiracy that each defendant knowingly agreed that a conspirator would commit at least two acts of racketeering activity in the conduct ofthe enterprise's affairs. Overt Acts 10. Infurtherance ofthe conspiracy and to achieve the objects and purposes ofthe conspiracy, the defendants and others knownand unknown committed overt acts in the Eastern District ofvirginia and elsewhere, including, but not limited tothe following: a. In or about2004, HERBERT PRIDGEN, ASHBY and others, known and unknown, agreed and conspired to rob a cocaine supplier in North Carolina. b. In or about 2004, HERBERT PRIDGEN, ASHBY and others, known and unknown, used firearms to commit a robbery ofthe cocaine supplier innorth Carolina, the proceeds ofwhich included cocaine.

8 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 8 of 32 PageID# 35 c. In or about January 2005, HERBERT PRIDGEN and others, known and unknown, agreed and conspired with P.S. that P.S. would sell cocaine provided by HERBERT PRIDGEN. d. On or about January 2,2005, HERBERT PRIDGEN and others, known and unknown, agreed and conspired to kill P.S. because P.S. had not paid for the cocaine P.S. was supposed to sell. e. On or about January 2,2005, HERBERT PRIDGEN and others, known and unknown, used firearms to shoot and attempt to kill P.S., striking P.S. in the leg. f. Onorabout January 4,2005, BOWLES and others, known andunknown, agreed and conspired to use force to rob G.T., a marijuana dealer, ofmarijuana and United States currency. g. On or about January 4,2005, BOWLES and others, known and unknown, used firearms to commit a robbery of G.T., the proceeds of which included marijuana. h. On or about April 14, 2005, HERBERT PRIDGEN and others, known and unknown, agreed and conspired to use force to rob K.J. of cocaine, heroin, and cash. i. On or about April 14, 2005, HERBERT PRIDGEN and others, known and unknown, attempted to rob K.J. by force. j. On or about April 14,2005, HERBERT PRIDGEN and others, known and unknown, used firearms to shootat K.J. while K.J. fled from the attempted robbery, striking K.J. in the back. 8

9 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 9 of 32 PageID# 36 k. On or about May 21,2005, HERBERT PRIDGEN, ASHBY, BOWLES, and others, known and unknown, agreed and conspired to murder M.W. because M.W. was from Courthouse, a rival gang. 1. On or about May 21, 2005, HERBERT PRIDGEN, ASHBY, BOWLES, and others, known and unknown, used firearms to shoot and attempt to kill M.W. as his vehicle traveled through Thug Relations territory, striking M.W. in the face and shoulder. m. Onor about February 12,2006, HERBERT PRIDGEN and others, known and unknown, agreed and conspired to use force to rob T.C. of marijuana and United States currency. n. Onor about February 12,2006, HERBERT PRIDGEN and others, known and unknown, used firearms to attempt a robbery oft.c, a marijuana dealer. During the robbery, T.C. was shot in the chest. o. On or about February 12, 2006, while attempting to rob T.C, HERBERT PRIDGEN discharged a firearm, shooting T.W. in the back. p. Onor about July 14,2006, HERBERT PRIDGEN, ASHBY, BOWLES, and others, known and unknown, agreed and conspired to use firearms to shoot and attempt to kill E.J., T.H., and L.W, because of an argument over a missing firearm. q. On or about July 14,2006, HERBERT PRIDGEN, ASHBY, BOWLES, and others, known and unknown, used firearms to shoot and attempt to kill E.J., T.H., and L.W. r. Onor about July3,2007, ASHBY, BOWLES, MCLAIN, andothers, known and

10 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 10 of 32 PageID# 37 unknown, threatened and intimidated Aaron Sumler, K.M., and J.J. because Aaron Sumler, K.M., and J.J. had been dealing cocaine base in Aqueduct Apartments. s. On orabout July 5,2007, ASHBY, BOWLES, and MCLAIN conspired and agreed to use firearms to shoot and kill Aaron Sumler and K.M. because Aaron Sumler and K.M. hadbeen dealing cocaine base in Aqueduct Apartments. t. On or about July 5,2007, ASHBY, BOWLES, and MCLAIN used firearms to shoot and kill Aaron Sumler because Aaron Sumler had been dealing cocaine base in Aqueduct Apartments. u. On or about July 5,2007, ASHBY, BOWLES, and MCLAIN used firearms to shoot atand attempt to kill K.M. because K.M. had been dealing cocaine base in Aqueduct Apartments. v. On or about January 10, 2008, ASHBY, MCLAIN, and others, known and unknown, agreedand conspired to rob R.L., a marijuana trafficker. w. On or about January 10, 2008, ASHBY, MCLAIN, and others, known and unknown, drove together to R.L.'s house with the purpose ofrobbing R.L, a marijuana trafficker. x. On or about January 10, 2008, ASHBY, MCLAIN, and others, known and unknown, attempted to enter R.L.'s house with the purpose ofrobbing R.L., a marijuana trafficker. y. On or about January 10, 2008, ASHBY and others, known and unknown, 10

11 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 11 of 32 PageID# 38 discharged firearms into R.L.'s house, knowing the house to be occupied by R.L. and B.L., striking B.L. in the chest. z. On or about April 17,2008, amember ofthug Relations known to the grand jury "pointed out" K.T. to HERBERT PRIDGEN as K.T. exited a nightclub. aa. On or about April 17,2008, HERBERT PRIDGEN used a firearm to shoot and attempt tokill K.T. because K.T. had disrespected HERBERT PRIDGEN in a nightclub. bb. On or about November 15,2009, HERBERT PRIDGEN asked members and associates of Thug Relations for a firearm. In response, a Thug Relations associate handed HERBERT PRIDGEN a Glock 9mm caliber semi-automatic pistol. cc. Onor about November 16,2009, HERBERT PRIDGEN and other Thug Relations members, known and unknown, attempted to dispose of a Glock 9mm caliber semi-automatic pistol to prevent location by law enforcement. dd. Onor about December 15, 2009, ERIC PRIDGEN, HERBERT PRIDGEN, and others, known and unknown, agreed and conspired to rob Lafayette Bailey, a marijuana and ecstasy dealer. ee. On or about December 15,2009, a member of Thug Relations known to the grand jurydrove HERBERT PRIDGEN, ERIC PRIDGEN and others to Lafayette Bailey's residence with the purposeof committing a robbery. ff. On or about December 15, 2009, HERBERT PRIDGEN, ERIC PRIDGEN, and others forcibly entered Lafayette Bailey's residence to commit a robbery of Lafayette Bailey. 11

12 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 12 of 32 PageID# 39 gg. On or about December 15,2009, HERBERT PRIDGEN, ERIC PRIDGEN, and others used firearms to forcibly take marijuana andunited States currency from theresidence of Lafayette Bailey. hh. On or about December 15, 2009, HERBERT PRIDGEN and ERIC PRIDGEN used firearms to shoot and kill Lafayette Bailey. ii. On or about January 6, 2010, ERIC PRIDGEN, HERBERT PRIDGEN, DOUGLAS ASHBY, and others, known andunknown, agreed and conspired to robj.t., a marijuana dealer. jj. On or aboutjanuary 6,2010, ERIC PRIDGEN, HERBERT PRIDGEN, and others, known and unknown, conducted surveillance ofthe residence of J.T. as preparation for a robbery. kk. Onor about January 8,2010, a member of Thug Relations drove ERIC PRIDGEN, HERBERT PRIDGEN, DOUGLAS ASHBY, and others, known and unknown, to the residence ofj.t. 11. On or about January 8,2010, ERIC PRIDGEN, HERBERTPRIDGEN, DOUGLAS ASHBY, and others, known and unknown, forcibly entered the residence of J.T. mm. On or about January 8,2010, ERIC PRIDGEN, HERBERT PRIDGEN, DOUGLAS ASHBY and others, known and unknown, used firearms to forcibly take marijuana, electronics, jewelry, and United States currency from the residence of J.T. nn. On or about January 8,2010, ERIC PRIDGEN used a firearm to shoot and kill 12

13 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 13 of 32 PageID# 40 Lloyd Robinson. oo. On or about March 16,2010, ERIC PRIDGEN and HERBERT PRIDGEN agreed and conspired to murder Dominique Wharton, because Wharton was publicly accusing ERIC PRIDGEN of cooperating with law enforcement. pp. On or about March 16,2010, ERIC PRIDGEN and HERBERT PRIDGEN used firearms to shoot and kill Dominique Wharton. qq. On or about July 21,2011, DOUGLAS ASHBY, MAURICE MCLAIN, and others, known and unknown, agreed and conspired to purchase two pounds of marijuana from A.T., paying A.T. $1,000 to obtain marijuana from A.T.'s supplier. rr. On or about July 21,2011, MAURICE MCLAIN used a firearm to shoot and attempt to kill A.T. because A.T. had provided MAURICE MCLAIN and DOUGLAS ASHBY with grass clippings instead ofmarijuana. ss. On or about August 4,2011, DOUGLAS ASHBY met with A.T. and received $300 from A.T. as a partial repayment of the money ASHBY and MCLAIN had given A.T. to purchase marijuana. tt. On or about June 7, 2012, ROBBIE BOWLES used a firearm to shoot and attempt to kill J.F., after an altercation over whether J.F. could sell controlled substances in Aqueduct Apartments. Notice of Special Sentencing Factors 11. On or about July 5, 2007, in the Eastern District ofvirginia, the defendants 13

14 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 14 of 32 PageID# 41 DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," MAURICE MCLAIN a/k/a "Mo," and ROBBIE BOWLES a/k/a "Rob," and aided and abetted by others known and unknown, did murder Aaron Sumler, in violation ofsection ofthe Code of Virginia, to wit, the defendants killed Sumler with malice and said killing was willful, deliberate, and premeditated. 12. On or about December 15,2009, in the Eastern District ofvirginia, the defendants, HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," aided and abetted by others known and unknown, did murder Lafayette Bailey, in violation ofsection ofthe Code of Virginia, to wit, the defendant killed Bailey with malice and said killing was willful, deliberate, and premeditated, and said killing was in the commission of, or attempt to commit, robbery. 13. On or about January 8, 2010, in the Eastern District ofvirginia, the defendants, HERBERT PRIDGEN, a/k/a "Bok," ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," and DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," aided and abetted by others known and unknown, did murder Lloyd Robinson, in violation ofsection ofthe Code ofvirginia, to wit, the defendantskilled Robinson with malice and said killing was willful, deliberate, and premeditated, and said killing was in the commission of, or attempt to commit, robbery. 14. On or about March 16,2010, in the Eastern District ofvirginia, the defendants, HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," aided and abetted by others known and unknown, did murder Dominque Wharton, in violation ofsection ofthe Code ofvirginia, to wit, the defendants killed Wharton with malice and said killing was willful, deliberate, and premeditated. 14

15 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 15 of 32 PageID# 42 (In violation oftitle 18, United States Code, Section 1962(d).) COUNT TWO (Felon in Possession of a Firearm) THE GRAND JURY CHARGES THAT: From on or about November 15,2009, to on or about November 16, 2009, in Newport News, Virginia, in the Eastern District ofvirginia, defendant HERBERT PRIDGEN, a/k/a "Bok," having been previously convicted ofa felony crime punishable by imprisonment for a term exceeding one year, did unlawfully and knowingly possess, in and affecting commerce, a Glock 9mm caliber semi-automatic pistol, PMC 9mm caliber ammunition, Winchester 9mm caliber ammunition, and Remington 9mm caliber ammunition, which had been shipped and transported in interstate and foreign commerce. (In violation of Title 18, United States Code, Section 922(g)(1)). COUNT THREE (Conspiracy to Interfere with Commerce by Robbery) THE GRAND JURY CHARGES THAT: 1. Drug trafficking is an inherently economic enterprise that affects interstate commerce. 2. Beginning on a date unknown to the Grand Jury, but not later than in or about December 2003, and continuing through at least in or about June 2010, in the Eastern District of Virginia, the defendants, ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN, a/k/a "Bok," DOUGLAS ASHBY, a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," and ANTONIO JOHNSON, and other coconspirators known and unknown, did knowingly and willfully combine, conspire, confederate, and agree with each other to unlawfully obstruct, delay, and affect, and attempt to obstruct, delay, and affect, commerce as that term is defined in Title 15

16 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 16 of 32 PageID# 43 18, United States Code, Section 1951(b)(3), and the movement of articles and commodities in such commerce, by robbery as that term is defined in Title 18, United States Code, Section 1951(b)(1), in that the defendants did unlawfully agree to take controlled substances and United States currency from the person of drug traffickers against their will by means of actual and threatened force, violence, and fear of injury, immediate and future, to each oftheir persons, and property in their custody and possession, that is, the defendants, aiding and abetting each other, used, carried, displayed, possessed, brandished, pointed, and discharged firearms at said drug traffickers, and demanded controlled substances and United States currency, in violation of Title 18, United States Code, Section 1951: Ways. Manner and Means ofthe Conspiracy It was part of the conspiracy that the defendants would and did: 1. identify a victim drug trafficker for robbery; 2. conduct surveillance ofthe drug trafficker's residence; 3. enter the drug trafficker's residence while using, carrying, and possessing firearms during and in relation to and in furtherance of the robbery crime; 4. place the drug trafficker and other occupants of the residence in fear of injury and violence by using and threatening to use the firearms and force to cause injury; and 5. steal controlled substances and United States currency in the victim drug trafficker's possession, and other items of value, such asjewelry and video gaming systems. Overt Acts In furtherance of the conspiracy and in order to effect the objects thereof, the defendants and their co-conspirators committed and caused to be committed the following overt acts, among others, in the Eastern District ofvirginia: 16

17 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 17 of 32 PageID# As Overt Acts of this conspiracy, the Grand Jury adopts, re-alleges, and incorporates by reference herein the factual allegations set forth in Counts 4, 5, 7through 10, 12, 13 ofthis indictment. (All inviolation oftitle 18, United States Code, Section 1951(a)). COUNT FOUR (Interference with Commerce by Robbery) 1. Drug trafficking is an inherently economic enterprise that affects interstate commerce. 2. On or about December 15, 2009, in Newport News, Virginia, in the Eastern District of Virginia, defendants ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN, a/k/a "Bok," and ANTONIO JOHNSON, and other co-conspirators known to the Grand Jury did knowingly and unlawfully obstruct, delay, and affect, and attempt to obstruct, delay, and affect commerce as that term is defined in Title 18, United States Code, Section 1951(b)(3), and the movement ofarticles and commodities in such commerce, by knowingly and willfully attempting to commit robbery, as thatterm is defined in Title 18, United States Code, Section 1951(b)(1), in thatthedefendant didunlawfully attempt to take controlled substances and United States currency from the person of drug trafficker Lafayette Bailey, against his will by means of actual and threatened force, violence, and fear of injury, immediate and future, to his person, that is, defendants ERIC PRIDGEN, HERBERT PRIDGEN, and ANTONIO JOHNSON, and their co-conspirators used, carried, displayed, possessed, brandished, and pointed firearms at Lafayette Bailey, demanded his controlled substances and property, and ERIC PRIDGEN and HERBERT PRIDGEN discharged firearms, and did aid, abet, and assist each other in the commission of the offense. 17

18 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 18 of 32 PageID# 45 (In violation oftitle 18, United States Code, Sections 1951(a) and 2). COUNT FIVE (Felon in Possession offirearm) On or about December 15,2009, in Newport News, Virginia, in the Eastern District of Virginia, defendant ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," having been previously convicted ofa felony crime punishable by imprisonment for a term exceeding one year, did unlawfully and knowingly possess, in and affecting commerce, a Smith &Wesson 9 mm caliber semi-automatic pistol, and Winchester 9 mm caliber Luger ammunition, which had been shipped and transported in interstate and foreign commerce. (In violation of Title 18, United States Code, Section 922(g)(1)). COUNT SIX (Murder in Aid of Racketeering) THE GRAND JURY FURTHER CHARGES THAT: 1. Paragraphs 1,2, 3, 6, and 7 ofcount One of this Second Superseding Indictment are re-alleged and incorporated as if fully set out herein. 2. At all times relevant to this Second Superseding Indictment, Thug Relations constituted an"enterprise," as defined in Title 18, United States Code, Section 1959(b)(2), that is, a group ofindividuals associated in fact, which was engaged in, and the activities ofwhich affected, interstate and foreign commerce. The enterprise constituted an ongoing organization whose members functioned as a continuing unit for a common purpose of achieving the objectives ofthe enterprise. 3. At all times relevant to this Second Superseding Indictment, Thug Relations, the above-described enterprise, through its members and associates, engaged in racketeering activity, 18

19 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 19 of 32 PageID# 46 as defined in Title 18, United States Code, Sections 1959(b)(1) and 1961(1), which consistedof multiple acts involving: a. Murder, Attempted Murder, and Conspiracy to Commit Murder, chargeable under Va. Code , , and , and the common law ofvirginia; b. Robbery, Attempted Robbery, and Conspiracy to Commit Robbery chargeable under Va. Code , , and , and the common law ofvirginia; and multiple acts indictable under: c. 18 U.S.C 1951 (Conspiracy to Interfere with and Interference with Commerce by Robbery) d. 21 U.S.C 841 & 846 (Drug Trafficking). 4. On or about December 15,2009, in the Eastern District ofvirginia, the defendants, HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," aided and abetted by others known and unknown, for the purpose ofmaintaining and increasing position in Thug Relations, an enterprise engaged in racketeering activity, did murder Lafayette Bailey, in violation ofva. Code, (In violation oftitle 18, United States Code, Sections 1959(a)(1) and 2.) COUNT SEVEN (Use of a Firearm Resulting in Death) THE GRAND JURY CHARGES THAT: On or about December 15,2009, in NewportNews Virginia, in the Eastern District of Virginia, defendants HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a"rab," and other coconspirators known to the Grand Jury did unlawfully and knowingly use, carry, brandish, and discharge a firearm during and in relation to a crime ofviolence for which 19

20 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 20 of 32 PageID# 47 he may be prosecuted in a Court ofthe United States, that is Racketeering Conspiracy, in violation oftitle 18, United States Code, Section 1962(d), as set forth in Count One of this Second Superseding Indictment, Interference with Commerce by Robbery, in violation oftitle 18, United States Code, Section 1951, as set forth in Count Four, and Murder in Aid of Racketeering, in violation oftitle 18, United States Code, Section 1959(a)(1), as set forth in Count Six of this Second Superseding Indictment, which are incorporated herein, and in the course of said offenses, caused the death of Lafayette Bailey through the use of a firearm, and the killing constituted murder, as defined in Title 18 United States Code, Section 1111(a), in that the defendants, with malice aforethought, did unlawfully kill Lafayette Bailey by shooting him witha firearm anddid aid, abet, and assisteachotherin the commission of the offense. (In violation oftitle 18, United States Code, Sections 924(c)(1) and 0) and 2). COUNT EIGHT (Use ofa Firearm Resulting in Death) THE GRAND JURY CHARGES THAT: On or about December 15, 2009, in Newport News Virginia, in the Eastern Districtof Virginia, defendant ANTONIO JOHNSON and other co-conspirators known to the Grand Jury, did unlawfully and knowingly use, carry, brandish, and discharge a firearm during and in relation to a crime of violence for which he may beprosecuted ina Court of theunited States, thatis Interference with Commerce by Robbery, in violation of Title 18, United States Code, Section 1951, as set forth incount Four, which is incorporated herein, and inthe course ofsaid offense, caused the death of Lafayette Bailey through the use ofa firearm, and the killing constituted murder, as defined in Title 18 United States Code, Section 1111(a), in that the defendant, with 20

21 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 21 of 32 PageID# 48 malice aforethought, did unlawfully kill Lafayette Bailey by shooting him with a firearm and did aid, abet, and assist others in the commission of the offense. (In violation oftitle 18, United States Code, Sections 924(c)(1) and (j) and 2). COUNT NINE (Interference with Commerce by Robbery) 1. Drug trafficking is an inherently economic enterprise that affects interstate commerce. 2. On or about January 8, 2010, in Newport News, Virginia, in the Eastern District of Virginia, defendants ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN, a/k/a "Bok," and DOUGLAS ASHBY, a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," and other co-conspirators known to the Grand Jury did knowingly and unlawfully obstruct, delay, and affect, and attempt to obstruct, delay, and affect commerce as that term isdefined in Title 18, United States Code, Section 1951(b)(3), and the movement of articles and commodities in such commerce, by knowingly and willfully committing robbery, as that term is defined in Title 18, United States Code, Section 1951(b)(1), in that the defendant did unlawfully take and obtain controlled substances and United States currency from 'the person of drug traffickers Lloyd Robinson and "JT" against their will by means of actual and threatened force, violence, and fear of injury, immediate and future, to each of their persons, that is, defendants ERIC PRIDGEN, HERBERT PRIDGEN, DOUGLAS ASHBY and their co-conspirators used, carried, displayed, possessed, brandished, and pointed firearms at Lloyd Robinson and "JT," demanded their controlled substances and property, and ERIC PRIDGEN discharged a firearm, and did aid, abet, and assist each other in the commission ofthe offense. (In violation of Title 18, United States Code, Sections 1951(a) and 2). 21

22 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 22 of 32 PageID# 49 COUNT TEN (Felon in Possession of Firearm and Ammunition) On or about January 8, 2010, in NewportNews, Virginia, in the Eastern Districtof Virginia, defendant ERIC PRIDGEN, a/k/a"rabbit,"a/k/a"rab," having been previously convicted of a felony crime punishable by imprisonment for a term exceeding one year, did unlawfully and knowingly possess, in and affecting commerce, a Smith& Wesson 9 mm caliber semi-automatic pistol, and Winchester 9mm caliberluger ammunition, which had been shipped and transported in interstate and foreign commerce. (In violation of Title 18, United States Code, Section 922(g)(1)). COUNT ELEVEN (Murder in Aid of Racketeering) THE GRAND JURY FURTHER CHARGES THAT: 1. Paragraphs 1 through 3 of Count Six of this Second Superseding Indictment are re-alleged and incorporated as if fully set out herein. 2. On or about January 8,2010, in the Eastern District ofvirginia, the defendant, ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," aided and abetted by others known and unknown, for the purpose of maintaining and increasing positionin Thug Relations, an enterprise engaged in racketeering activity, did murder Lloyd Robinson, in violation of Va. Code, (In violation oftitle 18, United States Code, Sections 1959(a)(1) and 2.) COUNT TWELVE (Use of a Firearm Resulting in Death) THE GRAND JURY CHARGES THAT: On or about January 8,2010, in Newport News Virginia, in the Eastern District of Virginia, defendants DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a 22

23 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 23 of 32 PageID# 50 "Murder," and HERBERT PRIDGEN, a/k/a"bok,"and other coconspirators known to the Grand Jury did unlawfully and knowingly use, carry, brandish, and discharge a firearm during and in relation to a crime ofviolence for which he may be prosecuted in a Court ofthe United States, that is Racketeering Conspiracy, in violation of Title 18, United States Code, Section 1962(d), as set forth in Count One of this Second Superseding Indictment, and Interference with Commerce by Robbery, in violation of Title 18, United States Code, Section 1951, as setforth in Count Nine, which are incorporated herein, and in the course of saidoffenses, caused the death of Lloyd Robinson through the use of a firearm, and the killing constituted murder, as defined in Title 18 United States Code, Section 1111(a), in that the defendants, with malice aforethought, did unlawfully kill Lloyd Robinson by shooting him with a firearm anddid aid, abet, and assist each other and others in the commission ofthe offense. (In violation of Title 18,United States Code, Sections 924(c)(1) and (j) and 2). COUNT THIRTEEN (Use ofa Firearm Resulting in Death) THE GRAND JURY CHARGES THAT: On or about January 8, 2010, in Newport News Virginia, in the Eastern District of Virginia, defendant ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," and other coconspirators known to the Grand Jury did unlawfully and knowingly use, carry, brandish, and discharge a firearm during and in relation to a crime of violence for which he may be prosecuted in a Court of the United States, that is Racketeering Conspiracy, in violation of Title 18, United States Code, Section 1962(d), as set forth in CountOne of this Second Superseding Indictment, Interference with Commerce by Robbery, in violation of Title 18, United StatesCode, Section 1951, as set forth in Count Nine, and Murder in Aid of Racketeering, in violation of Title 18, 23

24 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 24 of 32 PageID# 51 United States Code, Section 1959(a)(1), as set forth in Count Eleven ofthis Second Superseding Indictment, whichare incorporated herein, and in the course of said offenses, causedthe death of Lloyd Robinson through the use of a firearm, and the killing constituted murder, as defined in Title 18 United States Code, Section 1111(a), in that the defendant, with malice aforethought, did unlawfully kill Lloyd Robinson by shooting him with a firearm and did aid, abet, and assist others in the commission ofthe offense. (In violation of Title 18, United States Code, Sections 924(c)(1) and (j) and 2). COUNT FOURTEEN (Felon in Possession offirearm) THE GRAND JURY CHARGES THAT: On or about March 16, 2010, in Newport News, Virginia, in the Eastern District of Virginia, defendant ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," having been previously convictedof a felony crime punishable by imprisonment for a term exceeding one year, did unlawfully and knowingly possess, in and affecting commerce, a Smith & Wesson9 mm caliber semi-automatic pistol, and PMC 9 mm caliberammunition, which had been shipped and transported in interstate and foreign commerce. (In violation oftitle 18, United States Code, Section 922(g)(1)). COUNT FIFTEEN (Felon in Possession ofammunition) THE GRAND JURY CHARGES THAT: On or about March 16,2010, in Newport News, Virginia, in the Eastern District of Virginia, defendant HERBERT PRIDGEN, a/k/a "Bok," having beenpreviously convicted of a felony crimepunishable by imprisonment for a term exceedingone year, did unlawfully and 24

25 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 25 of 32 PageID# 52 knowingly possess, in and affecting commerce, Remington 9 mm caliber ammunition, which had been shipped and transported in interstate and foreign commerce. (In violation of Title 18, United States Code, Section 922(g)(1)). COUNT SIXTEEN (Murder in Aid of Racketeering) THE GRAND JURY FURTHER CHARGES THAT: 1. Paragraphs 1 through 3 ofcount Six ofthis Second Superseding Indictment are re-alleged and incorporated as iffully set out herein. 2. On or about March 16, 2010, in the Eastern District ofvirginia, the defendants, HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," aided and abetted by others known and unknown, for the purpose ofmaintaining and increasing position in Thug Relations, an enterprise engaged in racketeering activity, did murder Dominque Wharton, in violation ofva. Code, (In violation oftitle 18, United States Code, Sections 1959(a)(1) and 2.) COUNT SEVENTEEN (Use ofa Firearm Resulting in Death) THE GRAND JURY CHARGES THAT: On or about March 16, 2010, in Newport News Virginia, in the Eastern District of Virginia, the defendants HERBERT PRIDGEN, a/k/a "Bok," and ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," did unlawfully and knowingly use, carry, brandish, and discharge a firearm during and in relation to a crime ofviolence for which he may be prosecuted in a Court ofthe United States, that is Racketeering Conspiracy, in violation oftitle 18, United States Code, Section 1962(d), as set forth in Count One ofthis Second Superseding Indictment, and 25

26 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 26 of 32 PageID# 53 Murder in Aid ofracketeering, in violation oftitle 18, United States Code, Section 1959(a)(1), as set forth in Count Sixteen ofthis Second Superseding Indictment, which is incorporated herein, and in the course ofsaid offense, caused the death ofdominque Wharton through the use ofa firearm, and the killing constituted murder, as defined in Title 18 United States Code, Section 1111(a), in that the defendants, with malice aforethought, did unlawfully kill Dominque Wharton by shooting him with a firearm and did aid, abet, and assist each other in the commission ofthe offense. (In violation oftitle 18, United States Code, Sections 924(c)(1) and (j) and 2). FORFEITURE THE GRAND JURY FURTHER ALLEGES THAT: 1. The defendants, ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab," HERBERT PRIDGEN a/k/a "Bok," DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder," MAURICE MCLAIN a/k/a "Mo," and ROBBIE BOWLES, a/k/a "Rob," as part ofthe sentencing pursuant to Fed. R. Crim.P. 32.2: (A) ifconvicted ofany count ofthis Superseding Indictment, shall forfeit to the United States any and all firearms and ammunition involved in, used in, or intended to be used in such violation, pursuant to Title 18, United States Code, Section 924(d); and (B) if convicted ofany 18 U.S.C offense shall forfeit to the United States any and all property, real and personal, that constitutes or is derived from proceeds traceable to such violations, pursuant to Title 18, United States Code, Section 981(a)(1)(C). 2. The property referenced above includes, but is not limited to Glock 9mm caliber semi-automaticpistol and Smith & Wesson 9 mm caliber semi-automatic pistol. 3. If any ofthe above-described forfeitable property, as a result ofany act or omission 26

27 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 27 of 32 PageID# 54 of thedefendants (a)cannot be located upon theexercise of duediligence; (b)has been transferred or sold to,or deposited with, a third party; (c)has been placed beyond thejurisdiction of thecourt; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot bedivided without difficulty, it is the intention of the United States, pursuant totitle 21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c), to seek forfeiture of any otherproperty of the defendants up to the value of the forfeitable property described above. (Pursuant to Title 18, United States Code, Sections 924(d) and 981(a)(1)(C); and Title 28, United States Code, Section 2461(c)) NOTICE OF SPECIAL FINDINGS 1. The allegations of Counts Six, Seven, Eight, Eleven, Twelve, Thirteen, Sixteen, and Seventeen ofthis Second Superseding Indictment are re-alleged and incorporated as iffully set out herein. 2. As to Counts Six, Seven, Eleven, Thirteen, Sixteen, and Seventeen, the defendant, ERIC PRIDGEN, a/k/a "Rabbit," a/k/a "Rab": a. was over 18years of age at the time of the offenses(title 18, United StatesCode, Section 3591(a)); b. intentionally killed the victim (Title 18, United States Code, Section 3591(a)(2)(A)); c. intentionally inflicted serious bodily injury that resulted inthe death ofthe victim (Title 18, United States Code, Section 3591(a)(2)(B)); d. intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would be used in conjunction with a person, other 27

28 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 28 of 32 PageID# 55 than one of the participants in the offenses, and the victim diedas a direct result of the act (Title 18, United States Code, Section 3591(a)(2)(C)); e. intentionally and specifically engaged inan act of violence, knowing that the act created a grave risk of death to a person, other than one ofthe participants inthe offenses, such that participation in the act constituted a reckless disregard for human life and the victim died as a direct result ofthe act (Title 18, United States Code, Section 3591(a)(2)(D)); f. committed the offense as consideration for the receipt, or in the expectation ofthe receipt, of anything of pecuniary value (Title 18, United States Code, Section 3592(c)(8); g. committed theoffenses after substantial planning andpremeditation to cause the death of a person (Title 18, United States Code, Section 3592(c)(9)); and h. had previously been convicted oftwo or more State or Federal offenses punishable by a term of imprisonment of more thanone year, committed on different occasions, involving thedistribution of a controlled substance (Title 18, United States Code, Section 3592(c)(10)). 3. As to Counts Six, Seven, Twelve, Sixteen, and Seventeen, the defendant, HERBERT PRIDGEN, a/k/a "Bok": a. was over 18 years of age at the timeof the offenses (Title 18, United States Code, Section 3591(a)); b. intentionally killed the victim (Title 18, United States Code, Section 3591(a)(2)(A)); c. intentionally inflicted serious bodily injury that resulted in the death ofthe victim (Title 18, United States Code, Section 3591(a)(2)(B)); 28

29 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 29 of 32 PageID# 56 d. intentionally participated in an act, contemplating that the life ofa person would be taken and intending that lethal force would be used in conjunction with aperson, other than oneof the participants' in the offenses, and the victim died as a direct result of the act(title 18, United States Code, Section 3591(a)(2)(C)); e. intentionally and specifically engaged in an act ofviolence, knowing that the act created a grave risk of death to a person, other than one ofthe participants inthe offenses, such that participation in the act constituted a reckless disregard for human life and the victim died as a direct result of the act (Title 18, United States Code, Section 3591(a)(2)(D)); f. committed the offense as consideration for the receipt, or inthe expectation ofthe receipt, of anything of pecuniary value (Title 18, United States Code, Section 3592(c)(8); and g. committed the offenses aftersubstantial planning andpremeditation to cause the death of a person (Title 18, United States Code, Section 3592(c)(9)). 4. As to Count Twelve, the defendant DOUGLAS ASHBY a/k/a "Murder Mance," a/k/a "Mance," a/k/a "Murder": a. was over 18 years of age at the time of the offense(title 18,United StatesCode, Section 3591(a)); b. intentionally participated in an act, contemplating that the life of a person would be taken and intending that lethal force would beused in conjunction with a person, other than one ofthe participants in the offenses, and the victim died as a direct result ofthe act (Title 18, United States Code, Section 3591(a)(2)(C)); 29

30 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 30 of 32 PageID# 57 c. intentionally and specifically engaged in an act ofviolence, knowing that the act created a grave risk ofdeath to a person, other than one ofthe participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim died as a direct result ofthe act (Title 18, United States Code, Section 3591(a)(2)(D)); and d. committed the offense as consideration for the receipt, orin the expectation ofthe receipt, of anything of pecuniary value (Title 18, United States Code, Section 3592(c)(8); 5. As to Count Eight, the defendant, ANTONIO JOHNSON: a. was over 18 years of age at thetime of the offenses (Title 18, United States Code, Section 3591(a)); b. intentionally participated inan act, contemplating that the life ofa person would be taken and intending that lethal force would be used inconjunction with a person, other than one ofthe participants in the offenses, and the victim died as a direct result ofthe act (Title 18, United States Code, Section3591(a)(2)(C)); c. intentionally and specifically engaged inan act ofviolence, knowing that the act created a grave risk of death to a person, other than one of the participants in the offenses, such that participation in the act constituted a reckless disregard for human life and the victim died as a direct result of the act (Title 18, United States Code, Section 3591(a)(2)(D)); d. committed the offense as consideration for the receipt, or in the expectation of the receipt, of anything of pecuniary value (Title 18, United States Code, Section 3592(c)(8); and 30

31 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 31 of 32 PageID# 58 e. had previously been convicted oftwo or more State or Federal offenses punishable by a term ofimprisonment ofmore than one year, committed on different occasions, involving the distribution ofa controlled substance (Title 18, United States Code, Section 3592(c)(10)). (Pursuant to Title 18, United States Code, Sections 3591 and 3592.) 31

32 Case 4:14-cr RAJ-TEM Document 15 Filed 03/09/15 Page 32 of 32 PageID# 59 REDACTED COPY UNITED STATES v. ERjC PRIDGEN. HERBERT PRIDGEN. DOUGLAS ASHBY. MAURICE MCLAIN. ROBBIE BOWLES. ft AN funk) JOHNSON Criminal No. 4:14cr59 A TRUE BILL: REDACTED COPY FOREPERSON DANA J. BOENTE UNITED STATES ATTORNEY By:., I a***\w\ Lisa R. McKccI Assistant United States Attorney Fountain Plaza Three 721 Lakefront Commons, Suite 300 Newport News, VA / U By:., Jonathan~A. Ophardt Special Assistant United States Attorney Fountain Plaza Three 721 Lakefront Commons, Suite 300 Newport News, VA / By: niz <L Howard J. /.loinickt Managing Assistant United States Attorney Fountain Plaza Three 721 Lakefront Commons. Suite 300 Newport News, VA /