FILED UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

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Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 1 of 12 JWV/GRD: MAY 2013 GJ# 30 FILED 2013 Apr-29 AM 11:56 U.S. DISTRICT COURT N.D. OF ALABAMA UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION UNITED STATES OF AMERICA ) ) v. ) Case No.: ), ) ) Champ, ) WALTER JOHNSON, ) ) Walt T, ), ) ) Rosé, ) GRADY ISAM JENKINS, ) ) Shady Grady, ) DEANDRE R. MURRELL, ) ) Laray, ) ) Tojo, ) DEALDRE R. MURRELL, ) ) Twin, ) ABE JOHNSON, ) ) Cuz, ) VERNON LLWELLYN MCADORY, ) ) RJ, ) WILBERT CURTIS DALTON, JR., ) ) Bing, )

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 2 of 12 and ) MARION REYNOLDS, JR., ) ) Tuna ) I N D I C T M E N T COUNT ONE: [21 U.S.C. 846, 841(a)(1), (b)(1)(a) and (b)(1)(c)] The Grand Jury charges that: rd From in or about May, 2012, to on or about the 23 day of April, 2013, more exact dates being unknown to the Grand Jury, in Jefferson County, within the Northern District of Alabama, and elsewhere, the defendants,, Champ, WALTER JOHNSON, Walt T,, Rosé, GRADY ISAM JENKINS, Shady Grady, DEANDRE R. MURRELL, Laray, Tojo, DEALDRE R. MURRELL, Twin, ABE JOHNSON, Cuz, 2

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 3 of 12 VERNON LLWELLYN MCADORY, RJ, and MARION REYNOLDS, JR., Tuna, did knowingly, intentionally, and unlawfully conspire and agree with each other and with others both known and unknown to the Grand Jury to knowingly, intentionally, and unlawfully possess with the intent to distribute and to distribute one kilogram or more of a mixture and substance containing a detectible amount of heroin, and five kilograms or more of a mixture and substance containing a detectable amount of cocaine hydrochloride, each a controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(a), and an amount of codeine (Phernergan with promethazine-codeine) and hydrocodone (Tussionex), each a controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(c), all in violation of Title 21, United States Code, Section 846. COUNT TWO: [21 U.S.C. 841(a)(1) and (b)(1)(c)] The Grand Jury charges that: th On or about the 28 day of November, 2012, in Jefferson County, within the Northern District of Alabama, the defendants, 3

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 4 of 12 GRADY ISAM JENKINS, Shady Grady, and WILBERT CURTIS DALTON, JR., Bing, did knowingly, intentionally, and unlawfully distribute an amount of heroin, a controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(c). COUNT THREE: [21 U.S.C. 841(a)(1) and (b)(1)(a)] The Grand Jury charges that: th On or about the 25 day of January, 2013, in Jefferson County, within the Northern District of Alabama, the defendants,, Champ, and, Rosé, did knowingly, intentionally, and unlawfully possess with the intent to distribute one kilogram or more of a mixture and substance containing a detectible amount of heroin, a controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(a). 4

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 5 of 12 COUNT FOUR: [21 U.S.C. 841(a)(1) and (b)(1)(b)] The Grand Jury charges that: th On or about the 25 day of January, 2013, in Jefferson County, within the Northern District of Alabama, the defendants,, Champ, and, Rosé, did knowingly, intentionally, and unlawfully possess with the intent to distribute 500 grams or more of a mixture and substance containing a detectible amount of cocaine hydrochloride, a controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(b). COUNT FIVE: [21 U.S.C. 841(a)(1) and (b)(1)(c)] The Grand Jury charges that: th On or about the 9 day of April, 2013, in Jefferson County, within the Northern District of Alabama, the defendant, GRADY ISAM JENKINS, Shady Grady, did knowingly, intentionally, and unlawfully distribute an amount of heroin, a 5

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 6 of 12 controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(c). COUNTS SIX THROUGH FORTY-ONE: [21 U.S.C. 843(b)] The Grand Jury charges: 1. That on or about the date and time listed below, in Jefferson County, within the Northern District of Alabama, and elsewhere, the defendant(s), as more specifically identified herein, did knowingly, intentionally, and unlawfully use a communication facility, that being, a telephone, to facilitate the commission of a felony that is a drug trafficking crime, that is, the drug trafficking crime, alleged in Count One of this Indictment, in violation of Title 21, United States Code, Section 843(b). 2. The allegations set forth in paragraph 1, above, are hereby realleged and incorporated by reference for each of the following counts, as though fully set forth therein: COUNT DATE TIME DEFENDANT(S) 6 10/18/12 7:33 p.m. and WALTER JOHNSON 7 10/19/12 10:14 p.m. and WALTER JOHNSON 8 11/05/12 8:42 p.m. DEANDRE R. MURRELL and 6

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 7 of 12 9 11/05/12 10:03 p.m. and GRADY ISAM JENKINS 10 11/06/12 2:56 p.m. and DEANDRE R. MURRELL 11 11/06/12 5:59 p.m. and DEANDRE R. MURRELL 12 11/07/12 3:03 p.m. and 13 11/08/12 3:29 p.m. 14 11/08/12 7:43 p.m. 15 11/09/12 9:18 p.m. WALTER JOHNSON and 16 11/09/12 10:21 p.m. DEALDRE R. MURRELL and 17 11/10/12 4:04 p.m. and DEALDRE R. MURRELL 18 11/10/12 6:15 p.m. DEALDRE R. MURRELL and 19 11/10/12 9:17 p.m. 20 11/27/12 7:30 p.m. and GRADY ISAM JENKINS 21 11/27/12 8:27 p.m. and MARION REYNOLDS, JR. 22 11/27/12 8:50 p.m. and 7

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 8 of 12 23 11/27/12 10:36 a.m. and GRADY ISAM JENKINS 24 11/28/12 1:34 p.m. and GRADY ISAM JENKINS 25 11/28/12 10:15 p.m. and 26 11/28/12 10:55 p.m. and 27 11/29/12 6:36 p.m. and VERNON LLWELLYN MCADORY 28 12/03/12 5:36 p.m. ABE JOHNSON and 29 12/03/12 7:02 p.m. WALTER JOHNSON and 30 12/19/12 10:36 p.m. and ABE JOHNSON 31 12/19/12 10:47 p.m. and 32 12/20/12 5:40 p.m. MARION REYNOLDS, JR. and 33 12/20/12 7:04 p.m. and 34 1/23/13 6:15 p.m. 35 1/23/13 9:27 p.m. WALTER JOHNSON and 8

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 9 of 12 36 1/23/13 9:31 p.m. 37 1/24/13 4:07 p.m. and 38 1/24/13 8:20 p.m. and 39 1/25/13 5:49 p.m. and DEANDRE R. MURRELL 40 1/25/13 8:09 p.m. and 41 1/25/13 9:00 p.m. and NOTICE OF FORFEITURE: [21 U.S.C. 853(a)(1) and (a)(2)] The Grand Jury further notifies the defendants that: 1. The allegations of Counts One through Forty-One of this Indictment are realleged and incorporated by reference as though set forth fully herein for the purpose of alleging forfeiture to the United States pursuant to the provisions of Title 21, United States Code, Sections 853(a)(1) and (a)(2). 2. Pursuant to Rule 32.2(a), Fed. R. Crim. P., the defendants are hereby notified that, upon conviction of one or more of the offenses alleged in Counts One through Forty-One of this Indictment, defendants,, 9

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 10 of 12 Champ, WALTER JOHNSON, Walt T,, Rosé, GRADY ISAM JENKINS, Shady Grady, DEANDRE R. MURRELL, Laray, Tojo, DEALDRE R. MURRELL, Twin, ABE JOHNSON, Cuz, VERNON LLWELLYN MCADORY, RJ, WILBERT CURTIS DALTON, JR., Bing, and MARION REYNOLDS, JR., Tuna, shall forfeit to the United States pursuant to 21 U.S.C. 853(a), any property constituting, or derived from, proceeds obtained, directly or indirectly, as a result of the said violations and any property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of the said violations, including 10

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 11 of 12 but not limited to the following: JUDGMENT FOR PROCEEDS A sum of money equal to at least $5,000,000 in United States currency, representing the amount of proceeds obtained as a result of the offenses charged in Counts One through Forty of this Indictment, for which the defendants are jointly and severally liable. 3. If any of the above-described forfeitable property, as a result of any act or omission of the defendant(s): a. cannot be located upon the exercise of due diligence; b. has been transferred, or sold to, or deposited with, a third party; c. has been placed beyond the jurisdiction of the court; d. has been substantially diminished in value; or e. has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to 21 U.S.C. 853(p), to seek forfeiture of any other property of said defendant(s) up to the value of the 11

Case 2:13-cr-00140-SLB-JEO Document 1 Filed 04/25/13 Page 12 of 12 forfeitable property described above. All in accordance with Title 21, United States Code, Sections 853(a)(1) and (a)(2). A TRUE BILL /s/ FOREMAN OF THE GRAND JURY JOYCE WHITE VANCE United States Attorney /s/ GREGORY R. DIMLER Assistant United States Attorney 12