Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 1 of 12 SEALED WESTERN DISTRICT OF TEXAS MIDLAND-ODESSA DIVISION JUL 23.2014 D7T CLERK. u.s. WESTERN 01ST OF EXAS 6Y DEPUTY UNITED STATES OF AMERICA, Plaintiff, LUIS JOSE TARANGO TERRAZAS, JOE ANTHONY KAY, MERIN JAMES MCCULLEY, MiCHAEL ALEXANDER LOZANO, ZACHERY QUENTIN BAILEY, WILLIAM RAY WARREN, CAMERON EDWARD GEE, Defendants. CRIMINAL NO. MO-14-CR- (L SUPERSEDING INDICTMENT [Vio: 21 U.S.C. 846 - Conspiracy; 21 U.S.C. 841(a)(1)- Possession With Intent to Distribute a Controlled Substance; 18 USC 924(c) - Possession of a Firearm in Furtherance of a Drug Trafficking Crime; 21 U.S.C. 860 Distribution of a Controlled Substance Within 1000 feet Of a School; 18 U.S.C. 2 Aid and Abet] THE GRAND JURY CHARGES: COUNT ONE [21 U.S.C. 8461 That from on or about June 2010 through on or about June 12, 2014, in the Western District of Texas, the Northern District of Texas, and elsewhere, the Defendants, LUIS JOSE TARANGO TERRAZAS, JOE ANTHONY KAY, MERIN JAMES MCCULLEY, MICHAEL ALEXANDER LOZANO, ZACHERY QUENTIN BAILEY, WILLIAM RAY WARREN, AND CAMERON EDWARD GEE, did combine, conspire, confederate and agree together, with each other, and with others known and unknown to the Grand Jury to possess with intent to distribute and distribute controlled substances, which offense involved one kilogram or more of a mixture and substance containing a detectable
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 2 of 12 amount of heroin; five kilograms or more of a mixture and substance containg a detectable amount of cocaine; and five hundred (500) grams or more of a mixture and substance containing a detectable amount of methamphetamine, in violation of Title 21, United States Code, Sections 841(a)(1). QUANTITY OF CONTROLLED SUBSTANCES INVOLVED IN THE CONSPIRACY The quantity of controlled substances involved in the conspiracy and attributable to each Defendant as a result of each Defendant's own conduct and as a result of the conduct of other conspirators reasonably foreseeable to each Defendant is one kilogram or more of a mixture and substance containing a detectable amount of heroin; five kilograms or more of a mixture and substance containg a detectable amount of cocaine; and five hundred (500) grams or more of a mixture and substance containing a detectable amount of methamphetamine; in violation of 21 U.S.C. 841(b)(1)(A). All contrary to Title 21, United States Code, Section 846. COUNT TWO [18 U.S.C. 924(c)] That on or about April 24, 2014, in the Northern District of Texas, the Defendant, MICHAEL ALEXANDER LOZANO, did knowingly possess firearms, to wit: a Ruger Mark II Target,.22 caliber semi-automatic pistol, serial number 21724460, a Ruger SR22,.22 caliber semi-automatic pistol, serial number 362-70131, a Ruger 10/22,.22 caliber semi-automatic rifle, serial number 82553112, a Mossberg Maverick model 88,.12 gauge shotgun, serial number MV54661N, in furtherance of the drug trafficking crime charged in Count One of this Indictment, re-alleged herein, in violation of Title 18, United States Code, Sections 924(c)(l).
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 3 of 12 COUNT THREE [21 U.S.C. 841(a)(1) & 860] That on or about October 23, 2013, in the Western District of Texas, the Defendant, CAMERON GEE, unlawfully, knowingly and intentionally distributed a controlled substance within 1,000 feet of the real property comprising Fannin Elementary School in Midland, Texas, which offense involved a quantity of a mixture and substance containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 860. COUNT FOUR [21 U.S.C. 841(a)(1)] That on or about November 10, 2013, in the Western District of Texas, the Defendant, CAMERON GEE, unlawfully, knowingly and intentionally distributed a controlled substance within 1,000 feet of the real property comprising Fannin Elementary School in Midland, Texas, which offense involved a quantity of a mixture and substance containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(1) and 860. COUNT FIVE [21 U.S.C. 841(a)(1) & 860] That on or about November 15, 2013, in the Western District of Texas, the Defendant, CAMERON GEE, unlawfully, knowingly and intentionally possessed with intent to distribute a controlled substance within 1,000 feet of the real property comprising Fannin Elementary School in Midland, Texas,
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 4 of 12 which offense involved a quantity of a mixture and substance containing a detectable amount of heroin, in violation of Title 21, United States Code, Sections 841(a)(l) and 860. COUNT SIX [18 U.S.C. 924(c)] That on or about November 15, 2013, in the Western District of Texas, the Defendant, CAMERON GEE, did knowingly possess a firearm, to wit: a Ruger 44 magnum revolver, serial number 80-32489, in furtherance of the drug trafficking crime charged in Count Five of this Indictment, re-alleged herein, in violation of Title 18, United States Code, Sections 924(c)(1). COUNT SEVEN [21 U.S.C. 841(a)(1)J That on or about December 2, 2013, in the Western District of Texas, the Defendant, WILLIAM RAY WARREN, unlawfully, knowingly and intentionally distributed pills containing hydrocodone, a Scheduled III controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 841 (b)(1)(e)(i). COUNT EIGHT [21 U.S.C. 841(a)(1)1 That on or about December 3, 2013, in the Western District of Texas, the Defendant, WILLIAM RAY WARREN, unlawfully, knowingly and intentionally distributed pills containing hydrocodone, a Scheduled III controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 841 (b)( 1 )(E)(i).
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 5 of 12 COUNT NINE [21 U.S.C. 841(a)(1)1 That on or about December 5, 2013, in the Western District of Texas, the Defendants, WILLIAM RAY WARREN AND ZACHERY QUENTIN BAILEY, aided and abetted each other, unlawfully, knowingly and intentionally possessed with intent to distribute and distributed a controlled substance, which offense involved a quantity of a mixture and substance containing a detectable amount of methamphetamine, in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C). A TRUE BILL. Original Signed by the foreerson of the G4and Jury FOREP'ERSON OF THE GRAND JURY ROBERT PITMAN UNITED STATES ATTORNEY AUEY Assistant United States Attorney
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 6 of 12 PERSONAL DATA SHEET (REDACTED) WESTERN DISTRICT OF TEXAS COUNTY: MIDLAND DIVISION: JUDGE: JUNELL DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-l4-CR-162 DEFENDANT:LUIS JOSE TARANGO TERRAZAS ASSISTANT U.S. ATTORNEY: AUSTIN M. BERRY ADDRES S: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX Jennifer J. Wirsching 245 East Olive Avenue 4th Floor Burbank, CA 91502 818-563-2355 818-450-0466 (fax) wirschinglawoutlook.com DOB: XXXXXXXXXX DATE OF ST: June 13, 2014 BENCH WAT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(1)(a) - possession with intent to distribute. OFFENSE IS: FELONY a mandatory $100 special assessment. WDT-Cr-3
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 7 of 12 PERSONAL DATA SHEET (REDACTED) WESTERN DISTRICT OF TEXAS COUNTY: MIDLAND DIVISION: JUDGE: JUNELL DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-14-CR-162 ASSISTANT U.S. ATTORNEY: AUSTIN M. BERRY DEFENDANT:JOE ANTHONY KAY DOB: XXXXXXXXXX ADDRES S: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX NO ATTORNEY YET DATE OF ARREST: BENCH WARRANT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(l)(a) - possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine. OFFENSE IS: FELONY a mandatory $100 special assessment. WDT-Cr-3
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 8 of 12 PERSONAL DATA SHEET (REDACTED) COUNTY: MIDLAND DIVISION: DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-14-CR-162 DEFENDANT: MERIN JAMES MCCULLEY JUDGE: JUNELL ASSISTANT U.S. ATTORNEY: AUST[N M. BERRY ADDRES S: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX DOB: XXXXXXXXXX DATE OF ARREST: PROSECUTION BY: Indictment BENCH WARRANT: XXX OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(1)(a) - possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine. OFFENSE IS: FELONY a mandatory $100 special assessment. WDT-Cr-3
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 9 of 12 PERSONAL DATA SHEET (REDACTED) COUNTY: MIDLAND DIVISION: JUDGE: JUNELL DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-14-CR-162 ASSISTANT U.S. ATTORNEY: AUSTIN M. BERRY DEFENDANT: MICHAEL ALEXANDER LOZANO DUB: XXXXXXXXXX ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX NO ATTORNEY YET DATE OF ARREST: BENCH WARRANT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(1)(a) - possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine; Ct. 2-18 USC 924(c) - Possession of firearm in furtherance of a drug trafficking crime. OFFENSE IS: FELONY a mandatory $100 special assessment; Ct. 2 - A 5 year minimum mandatory term of imprisonment, not to exceed life imprisonment (to run consecutive to Ct. 1); a term of supervised release not to exceed 5 years; a fine not to exceed $250,000; and a $100 mandatory special assessment. WDT-Cr-3
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 10 of 12 PERSONAL DATA SHEET WESTERN DISTRICT OF TEXAS COUNTY: MIDLAND DIVISION: DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-14-CR-162 DEFENDANT: ZACHERY QUENTIN BAILEY ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX JUDGE: JUNELL ASSISTANT U.S. ATTORNEY: AUSTIN M. BERRY NO ATTORNEY YET DUB: XXXXXXXXXX DATE OF ARREST: BENCH WARRANT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(1)(a) possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine; Ct. 9-21 USC 841(a)(1) - Possession with intent to distribute a quantity of methamphetamine. OFFENSE IS: FELONY a mandatory $100 special assessment; Ct. 9 - A term of imprisonment not to exceed 20 years; a 3 year minimum mandatory term of supervised release; a fine not to exceed $1 million; and a mandatory $100 special assessment. WDT-Cr-3
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 11 of 12 PERSONAL DATA SHEET COUNTY: MIDLAND DIVISION: JUDGE: JUNELL DATE:July 23, 2014 MAG CT #: N/A FBI #: CASE NO: MO-14-CR-162 DEFENDANT: WILLIAM RAY WARREN ASSISTANT U.S. ATTORNEY: AUSTiN M. BERRY ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX NO ATTORNEY YET DOB: XXXXXXXXXX DATE OF ARREST: BENCH WARRANT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. 1-21 USC 846 - Conspiracy; 21 USC 841(a)(l) & (b)(l)(a) - possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine; Ct. 7-21 USC 841(a)(1) - Distribution of a quantity of hydrocodone; Ct. 8-21 USC 841(a)(1) Distribution of a quantity of hydrocodone; Ct. 9-21 USC 841(a)(1) - Aiding and abetting possession with intent to distribute a quantity of methamphetamine. OFFENSE IS: FELONY a mandatory $100 special assessment; Ct. 7-8 (each) - A term of imprisonment not to exceed 10 years; a 2 year minimum mandatory term of supervised release; a fine not to exceed $500,000; and a mandatory $100 special assessment; Ct. 9 A term of imprisonment not to exceed 20 years; a 3 year mandatory minimum term of supervised release; a fine not to exceed $1 million; and a mandatory $100 special assessment.
Case 7:14-cr-00162-RAJ Document 24 Filed 07/23/14 Page 12 of 12 PERSONAL DATA SHEET COUNTY: MIDLAND DIVISION: JUDGE: JUNELL DATE:July 23, 2014 MAGCT#:N/A FBI#: CASE NO: MO-14-CR-162 DEFENDANT:CAMERON EDWARD GEE ASSISTANT U.S. ATTORNEY: AUSTIN M. BERRY ADDRESS: XXXXXXXXXXXXXXXXXXXXXXXXXXXXX NO ATTORNEY YET DOB: XXXXXXXXXX DATE OF ARREST: BENCH WARRANT: XXX PROSECUTION BY: Indictment OFFENSE (Code and Description): Ct. I - 21 USC 846 - Conspiracy; 21 USC 841(a)(1) & (b)(1)(a) - possession with intent to distribute (1) One Kilogram of heroin; (2) Five kilograms of cocaine; and (3) Five hundred (500) grams methamphetamine; Ct. 3- Ct. 5-21 USC 841(a)(1), 860 - Possession with intent to distribute a quantity of heroin within 1,000 feet of a school; Ct. 6-18 USC 924(c) - Possession of firearm in furtherance of a drug trafficking crime. OFFENSE IS: FELONY a mandatory $100 special assessment; Ct. 3 Ct. 5 A minimum term of imprisonment of 1 year, not to exceed 40 years; a 6 year minimum mandatory term of supervised release; a fine not to exceed $2 million; and a mandatory $100 special assessment; Ct. 6 A 5 year minimum mandatory term of imprisonment, not to exceed life imprisonment (to run consecutive to Ct. 5); a term of supervised release not to exceed 5 years; a fine not to exceed $250,000; and a $100 mandatory special assessment. WDT-Cr-3