Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 1 of 38

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UNITED STATES DISTRICT COURT NO 'ViNSA.s
EASTERN DISTRICT OF ARKANSAS t V 0.,1 2022
CENTRAL DIVISION By: '4N/N(y H. Do

UNITED STATES OF AMERICA ) No. 4:22CRCO]X)-SM

)
V. ) 21 U.S.C. § 846
) 21 U.S.C. § 841(a)(l)
FREDDIE GLADNEY, JR.; ) 21 U.S.C. §§ 841(b)(l)(A),(B),(C),(D)
FREDDIE GLADNEY, III, a/k/a ) 21 U.S.C. § 843(b)
BANKROLL FREDDIE, a/k/a ) 18 U.S.C. § 922(a)(6)
DEEDEE; ) 18 U.S.C. § 922(g)(l)
JEREMY GREEN, a/k/a JG; ) 18 U.S .C. § 924(c)
DONALD TEAGUE, a/k/a BIG D; )
TIMOTHY PARKER, a/k/a BIG BABY; )
ERICAVETT; )
DEWAYNE BAKER, a/k/a WOLF; )
BRODERICK CHUNN, a/k/a MONEY, )
a/k/a RODERICK CHUNN; )
JAMAL DANIELS; )
CLIFFORD DAVIS; )
LC DAVIS; )
RICKEY FOREMAN, JR. , a/k/a SLIXC; )
DARIUS FURLOW, a/k/a LIL D; )
DEANDRE GA TES, a/k/a GAMBLE; )
JONATHON GREEN; )
EDWARD HOUSE, II; )
MARCUS HUGHES, a/k/a PERM; )
MARQUIS HUNT; )
HERSHEL JONES; )
ANGEL KING; )
KOBI KNIGHT; )
JENNIFER LENAIR; )
JOE MORGAN, III; )
AARON NICHOLS, a/k/a A-NICK; )
MARIO NICKSON; )
KAJARVIS O'NEAL, a/k/a FLUTE; )
SASHA QUAMINA; )
ANTONIO RATTLER, a/k/a SAM; )
DONNELL LAKEITH REED, )
a/k/a KEITH; )
BRANDON KINGSLEY ROBINSON; )
NICHOLAS ROGERS, a/k/a NICK; )
JAY SLAUGHTER; )
MATTHEW TAYLOR; )
KIMINISKI TEAGUE; and )
MICHAEL WILLIAMS, a/k/a MIKE )

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INDICTMENT

THE GRAND JURY CHARGES THAT:

COUNT 1

A. From in or about March 2021 continuing through in or about October 2022, in the

Eastern District of Arkansas and elsewhere, the defendants,

FREDDIE GLADNEY, JR.;

FREDDIE GLADNEY, III, a/k/a BANKROLL FREDDIE, DEE DEE;
JEREMY GREEN, a/k/a JG;
DONALD TEAGUE, a/k/a BIG D;
TIMOTHY PARKER, a/k/a BIG BABY;
ERICAVETT;
DEWAYNE BAKER, a/k/a WOLF;
BRODERICK CHUNN, a/k/a MONEY, a/k/a RODERICK CHUNN;
JAMAL DANIELS;
CLIFFORD DAVIS;
LC DAVIS;
RICKEY FOREMAN, JR., a/k/a SLIXC;
DARIUS FURLOW, a/k/a LIL D;
DEANDRE GATES, a/k/a GAMBLE;
JONATHON GREEN;
EDWARD HOUSE, II;
MARCUS HUGHES, a/k/a PERM;
MARQUIS HUNT;
HERSHEL JONES;
ANGEL KING;
KOBI KNIGHT;
JENNIFER LENAIR;
JOE MORGAN, III;
AARON NICHOLS, a/k/a A-NICK;
MARIO NICKSON;
KAJARVIS O'NEAL, a/k/a FLUTE;
SASHA QUAMINA;
ANTONIO RATTLER, a/k/a SAM;
DONNELL LAKEITH REED,
a/k/a KEITH;
BRANDON KINGSLEY ROBINSON;
NICHOLAS ROGERS, a/k/a NICK;
JAY SLAUGHTER;
MATTHEW TAYLOR
KIMINISKI TEAGUE; and
MICHAEL WILLIAMS, a/k/a MIKE;

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voluntarily and intentionally conspired with each other, and with others known and unknown to

the grand jury, to knowingly and intentionally distribute and possess with intent to distribute a

mixture and substance containing a detectable amount of cocaine, a Schedule II controlled

substance; a mixture and substance containing a detectable amount of cocaine base, commonly

known as crack cocaine, a Schedule II controlled substance; a mixture and substance containing a

detectable amount of methamphetamine, a Schedule II controlled substance; and marijuana, a

Schedule I controlled substance, in violation of Title 21, United States Code, Section 841(a)(l).

B. With respect to DONALD TEAGUE, TIMOTHY PARKER, ERIC AVETT, and

BRODERICK CHUNN, the amount of controlled substances involved in the conspiracy

attributable to the defendant as a result of the defendant's own conduct and the conduct of other

co-conspirators reasonably foreseeable to the defendant, is 5 kilograms or more of a mixture and

substance containing a detectable amount of cocaine, a Schedule II controlled substance, in

violation of Title 21, United States Code, Section 841(b)(l)(A).

C. With respect to FREDDIE GLADNEY, JR., FREDDIE GLADNEY, III, L C

DAVIS, and KOBI KNIGHT, the amount of controlled substances involved in the conspiracy

attributable to the defendant as a result of the defendant's own conduct and the conduct of other

co-conspirators reasonably foreseeable to the defendant, is 500 grams or more, but less than 5

kilograms, of a mixture and substance containing a detectable amount of cocaine, a Schedule II

controlled substance, in violation of Title 21, United States Code, Section 841(b)(l)(B).

D. With respect to DEWAYNE BAKER, JAMAL DANIELS, CLIFFORD DAVIS,

MARQUIS HUNT, HERSHEL JONES, ANGEL KING, JOE MORGAN, III, MARIO

NICKSON, ANTONIO RATTLER, and BRANDON KINGSLEY ROBINSON, the amount of

controlled substances involved in the conspiracy attributable to the defendant as a result of the

defendant's own co.1,1duct and the conduct of other co-conspirators reasonably foreseeable to the

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defendant, is less than 500 grams of a mixture and substance containing a detectable amount of

cocaine, a Schedule II controlled substance, in violation of Title 21, United States Code, Section

841 (b )(1 )(C).

E. With respect to FREDDIE GLADNEY, JR., TIMOTHY PARKER, ERJC AVETT,

BRODERJCK CHUNN, and L C DAVIS, the amount of controlled substances involved in the

conspiracy attributable to the defendant as a result of the defendant's own conduct and the conduct

of other co-conspirators reasonably foreseeable to the defendant, is 28 grams or more, but less than

280 grams, of a mixture and substance containing a detectable amount of cocaine base, commonly

known as crack cocaine, a Schedule II controlled substance, in violation of Title 21, United States

Code, Section 841(b)(l)(B).

F. With respect to JAMAL DANIELS and ANTONIO RATTLER, the amount of

controlled substances involved in the conspiracy attributable to the defendant as a result of the

defendant's own conduct and the conduct of other co-conspirators reasonably foreseeable to the

defendant, is less than 28 grams of a mixture and substance containing a detectable amount of

cocaine base, commonly known as crack cocaine, a Schedule II controlled substance, in violation

of Title 21, United States Code, Section 841(b)(l)(C).

G. With respect to BRODERJCK CHUNN and MARQUIS HUNT, the amount of

controlled substances involved in the conspiracy attributable to the defendant as a result of the

defendant's own conduct and the conduct of other co-conspirators reasonably foreseeable to the

defendant, is 500· grams or more of a mixture and substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, in violation of Title 21, United States Code,

Section 841(b)(l)(A).

H. With respect to DONALD TEAGUE and TIMOTHY PARKER, the amount of

controlled substances involved in the conspiracy attributable to the defendant as a result of the

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defendant's own conduct and the conduct of other co-conspirators reasonably foreseeable to the

defendant, is 50 grams or more, but less than 500 grams of a mixture and substance containing a

detectable amount of methamphetamine, a Schedule II controlled substance, in violation of Title

21, United States Code, Section 84l(b)(l)(B).

J. With respect to FREDDIE GLADNEY, JR., FREDDIE GLADNEY, III, and

JEREMY GREEN, the amount of controlled substances involved in the conspiracy attributable to

the defendant as a result of the defendant's own conduct and the conduct of other co-conspirators

reasonably foreseeable to the defendant, is 100 kilograms or more, but less than 1,000 kilograms,

of marijuana, a Schedule I controlled substance, in violation of Title 21, United States Code,

Section 84l(b)(l)(B).

K. With respect to DONALD TEAGUE, TIMOTHY PARKER, BRODERICK

CHUNN, JAMAL DANIELS, RICKEY FOREMAN, DARRIUS FURLOW, DEANDRE

GATES, JONATHON GREEN, EDWARD HOUSE, II, MARCUS HUGHES, MARQUIS

HUNT, JENNIFER LENAIR, AARON NICHOLS, MARIO NICKSON, KAJARVIS O'NEAL,

SASHA QUAMINA, ANTONIO RATTLER, DONNELL LAKEITH REED, BRANDON

KINGSLEY ROBINSON, NICHOLAS ROGERS, JAY SLAUGHTER, MATTHEW TAYLOR,

KIMINISKI TEAGUE, and MICHAEL WILLIAMS, the amount of controlled substances

involved in the conspiracy attributable to the defendant as a result of the defendant's own conduct

and the conduct of other co-conspirators reasonably foreseeable to the defendant, is less than 50

kilograms of marijuana, a Schedule I controlled substance, in violation of Title 21, United States

Code, Section 841 (b)(1 )(D).

All in violation of Title 21, United States Code, Section 846.

COUNT2

On or about May 25, 2021, in the Eastern District of Arkansas, the defendant,

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FREDDIE GLADNEY, III,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I .

controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and

841 (b )(1 )(D).

COUNT3

On or about May 25, 2021, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly and intentionally possessed one or more of the following firearms:

1. an Anderson Manufacturing Model AMI 5, multi-caliber rifle, bearing

serial number 16110644;

2. a Glock, Model 19, 9mm pistol, bearing serial number BTNP614;

3. a Glock, Model 43X, 9mm pistol, bearing serial number BTTF330;

4. a Taurus International, Model G2C, 9mm pistol, bearing serial number

TLW87873;

5. a Diamondback Firearms, Model DB15, 5.56 NATO caliber rifle, bearing

serial number DB2445497; and

6. a Norinco, Model SKS Type 56, 7.62x39 rifle, bearing serial number

18006266};

in furtherance of a drug trafficking crime prosecutable in a comi of the United States, that is: a

violation of Title 21, United States Code, Section 846, as set fo1ih in Count 1 of this Indictment,

and a violation of Title 21, United States Code, Section 841(a)(l), as set fo1ih in Count 2 of this

Indictment.

All in violation of Title 18, United States Code, Section 924( c)(1 )(A).

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COUNT4

A. On or about May 25, 2021, the defendant,

FREDDIE GLADNEY, JR.,

had previously and knowingly been convicted of a crime punishable by a term of imprisonment

exceeding one year, that is: Possession of Controlled Substance with Intent, in Pulaski County,

Arkansas, Circuit Court in Case Number CR 2010-3273 .

B. On or about May 25, 2021, in the Eastern District of Arkansas, the

defendant,

FREDDIE GLADNEY, JR.,

knowingly possessed, in and affecting commerce, one or more of the following fireanns:

1. an HS Produkt, Model XD-9, 9mm pistol, bearing serial number

XD157802; and

2. a FN USA, Model 509, 9mm pistol, bearing serial number GKS160112.

All in violation of Title 18, United States Code, Section 922(g)(l ).

COUNTS

A. On or about May 25, 2021, the defendant,

BRANDON KINGSLEY ROBINSON,

had previously and knowingly been convicted of a crime punishable by a tenn of imprisonment

exceeding one year, that is: Theft of Property (<$2,500 >$500), in Faulkner County, Arkansas,

Circuit Court in Case Number CR 2009-1120.

B. On or about May 25, 2021, in the Eastern District of Arkansas, the

defendant,

BRANDON KINGSLEY ROBINSON,

knowingly possessed, in and affecting commerce, one or more of the following firearms:

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1. a Smith & Wesson, model M&P9, 9mm pistol, bearing serial number

HNJ8389;and

. 2. an HS Produkt, model XD-40, sub-compact Mod.2, .40 caliber pistol, bearing

serial number BA288304.

All in violation of Title 18, United States Code, Section 922(g)(l).

COUNT6

On or about May 26, 2021, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly counseled, commanded, induced, and procured Individual A, in connection with the

acquisition of one or more of the following firearms :

L an HS Produkt, model XDM Elite, 9mm pistol, bearing serial number

BA271562;

2. a Smith & Wesson, M&P 15, 5.56 caliber pistol, bearing serial number

TS78421; and

3. a Bear Creek Arsenal, Model BCA 15, 5.56 caliber pistol, bearing serial number

50960;

from a licensed dealer of firearms within the meaning of Chapter 44, Title 18, United States Code,

to knowingly make a false and fictitious written statement to the licensed dealer of firean11S on a

Depmiment of Justice, Bureau of Alcohol, Tobacco, Firearms, and Explosives Form 4473 , which

statement was intended and likely to deceive the licensed dealer of fireanns , as to a fact material

to the lawfulness of such sale and transfer of the said firearms to Individual A under Chapter 44

of Title 18, in that Individual A stated that he was the actual transferee/buyer of the firearms

indicated on Form 4473, when in fact as Individual A then knew, Individual A was not the actual

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transferee/buyer of the firearms, but rather was acquiring the firearms for the defendant at the

defendant's direction.

All in violation of Title 18, United States Code, Sections 922(a)(6) and 2.

COUNT?

On or about May 27, 2021, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly counseled, commanded, induced, and procured Individual A, in connection with the

acquisition of the following fireaim: a Glock, Model 19 Gen 5, 9xl 9 caliber pistol, bearing serial

number BTPN833, from a licensed dealer of firearms within the meaning of Chapter 44, Title 18,

United States Code, to knowingly make a false and fictitious written statement to the licensed

dealer of fireaims on a Department of Justice, Bureau of Alcohol, Tobacco, Firearms, and

Explosives Form 4473, which statement was intended and likely to deceive the licensed dealer of

firearms, as to a fact material to the lawfulness of such sale and transfer of the said fireann to

Individual A under Chapter 44 of Title 18, in that Individual A stated that he was the actual

transferee/buyer of the fireann indicated on Form 4473, when in fact as Individual A then knew,

Individual A was not the actual transferee/buyer of the firearm but rather was acquiring the firearm

for the defendant at the defendant's direction.

All in violation of Title 18, United States Code, Sections 922(a)(6) and 2.

COUNTS

On or about May 28, 2021, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly counseled, commanded, induced, and procured Individual A, in connection with the

acquisition of the following fireaim: a FN America, 509 Compact Tactical, 9mm pistol, bearing

serial number GKS0 159727, from a licensed dealer of firearms within the meaning of Chapter 44,

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Title 18, United States Code, to knowingly make a false and fictitious written statement to the

licensed dealer of firearms on a Department of Justice, Bureau of Alcohol, Tobacco, Firearms, and

Explosives Form 4473, which statement was intended and likely to deceive the licensed dealer of

firearms, as to a fact material to the lawfulness of such sale and transfer of the said firearm to

Individual A under Chapter 44 of Title 18, in that Individual A stated that he was the actual

transferee/buyer of the firearm indicated on Form 4473, when in fact as Individual A then knew,

Individual A was not the actual transferee/buyer of the firearm but rather was acquiring the firearm

for the defendant at the c;lefendant' s direction.

All in violation of Title 18, United States Code, Sections 922(a)(6) and 2.

COUNT9

On or about October 9, 2021, in the Eastern District of Arkansas, the defendant,

JEREMY GREEN,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I

controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and

841 (b )(1 )(D).

COUNT 10

On or about October 9, 2021, in the Eastern District of Arkansas, the defendants,

JEREMY GREEN, and

AARON NICHOLS,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I

controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and

841 (b)(1 )(D).

COUNT 11

On or about October 9, 2021, in the Eastern District of Arkansas, the defendants,

 Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 11 of 38

JEREMY GREEN, and

AARON NICHOLS,

knowingly and intentionally possessed one or more of the following firearms:

1. a Bersa SA, Model Thunder 380, .380 ACP pistol, bearing serial number

178964;

2. a Stmm, Ruger & Company, Model SR40, .40 caliber S&W pistol,

bearing serial number 34215519;

3. an FN USA, Model FNS-40, .40 caliber pistol, bearing serial number

GKU0105517; and

4. a Palmetto State A1mory, Model PA-15, .223 caliber pistol, bearing serial

number PA186914;

in fmiherance of a drug trafficking crime prosecutable in a comi of the United States, that is: a

violation of Title 21, United States Code, Section 846, as set forth in Count 1 of this Indictment,

and a violation of Title 21, United States Code, Section 841(a)(l), as set forth in Count 10 of this

Indictment.

All in violation of Title 18, United States Code, Section 924(c)(l)(A).

COUNT 12

A. On or about October 9, 2021, the defendant,

AARON NICHOLS,

had previously and knowingly been convicted of a crime pm1ishable by a term of imprisonment

exceeding one year, that is: Possession of a Schedule VI Controlled Substance with Purpose to

Deliver, in the Pulaski County, Arkansas, Circuit Comi in Case Number 2015-3977.

B. On or about October 9, 2021, in the Eastern District of Arkansas, the

defendant,

AARON NICHOLS,

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knowingly possessed, in and affecting commerce, one or more of the following firearms :

1. a Bersa SA, Model Thunder 380, .380 ACP pistol, bearing serial number

178964;

2. a Sturm, Ruger & Company, Model SR40,.40 caliber S&W pistol, bearing

serial number 34215519;

3. an FHN USA, Model FNS-40, .40 caliber pistol, bearing serial number

GKU0105517; and

4. a Palmetto State Armory, Model PA-15, .223 caliber pistol, bearing serial

number PA186914.

All in violation of Title 18, United States Code, Section 922(g)(l ).

COUNT 13

On or about October 21 , 2021, in the Eastern District of Arkansas, the defendant,

DEANDRE GATES ,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I

controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(l) and

841(b)(l)(D).

COUNT 14

On or about October 21, 2021, in the Eastern District of Arkansas, the defendant,

DEANDRE GATES ,

knowingly and intentionally possessed a fireaim: that is, a Glock, Model 23 Gen 5, .40 caliber

pistol, bearing serial number BTSN029, in fmiherance of a drug trafficking crime prosecutable

in a comi of the United States, that is : a violation of Title 21, United States Code, Section 846, as

set forth in Count 1 of this Indictment, and a violation of Title 21, United States Code, Section

841 (a)(l ), as set forth in Cotmt 13 of this Indictment.

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All in violation of Title 18, United States Code, Section 924( c)(1 )(A).

COUNT 15

On or about April 14, 2022, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I

controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and

841 (b )(1 )(D).

COUNT 16

On or about April 14, 2022, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly and intentionally possessed one or more of the following firearms:

1. a Romarm/Cugir, model Micro Draco, 7.62x39mm, pistol, bearing serial

number ROA 22 PMD-28522;

2. a Polymer80, model PF940C, 9mm, privately-made firearm, bearing no serial

number; and

3. any pmi designed and intended solely and exclusively, and combination of

parts designed and intended, for use in converting a weapon into a

machine gun,

in furtherance of a drug trafficking crime prosecutable in a comi of the United States, that is: a

violation of Title 21, United States Code, Section 846, as set forth in Count 1 of this Indictment,

and a violation of Title 21, United States Code, Section 841(a)(l), as set forth in Count 15 of this

Indictment.

All in violation of Title 18, United States Code, Sections 924( c)(1 )(A) and

924( c)(1 )(B)(ii).

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COUNT17

On or about April 14, 2022, in the Eastern District of Arkansas, the defendant,

FREDDIE GLADNEY, III,

knowingly possessed one or more machineguns, that is: any part designed and intended solely

and exclusively, and combination of paiis designed and intended, for use in converting a weapon

into a machinegun.

All in violation of Title 18, United States Code, Sections 922(0) and 924(a)(2).

COUNT 18

On or about June 23, 2022, in the Eastern District of Arkansas, the defendant,

EDWARD HOUSE, II,

knowingly and intentionally possessed with intent to distribute marijuana, a Schedule I

controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(l) and

841 (b)(1 )(D).

COUNT 19

A On or about June 23, 2022, the defendant,

EDWARD HOUSE, II,

had previously and knowingly been convicted of one or more of the following crimes punishable

by a term of imprisonment exceeding one year:

1. Theft by Receiving, in Pulaski County, Arkansas, Circuit Corni in Case

Number 2016-1435;

2. Poss. of Meth/Cocaine w/ Purpose to Deliver, Possession of Controlled

Substance, Schedule IV or V w/ Purpose to Deliver, and Possession of

Controlled Substance, Schedule VI, w/ Purpose to Deliver in Pulaski

County, Arkansas, Circuit Court in Case Number 2016-3778; and

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3. Fleeing, in Pulaski County, Arkansas, Circuit Court in Case Number 201 7-

2685.

B. On or about June 23, 2022, in the Eastern District of Arkansas, the

defendant,

EDWARD HOUSE, II,

knowingly possessed, in and affecting commerce, one or more rounds of the following

ammunition:

1. .45 auto caliber, PMC ammunition; and

2. .380 auto caliber, PMC ammunition.

All in violation of Title 18, United States Code, Section 922(g)(l).

'
COUNT20

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

TIMOTHY PARKER,

knowingly and intentionally possessed with intent to distribute a mixture and substance

containing a detectable amount of cocaine, a Schedule II controlled substance; and marijuana, a

Schedule I controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l)

and 841 (b )(1 )(C)&(D).

COUNT21

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

TIMOTHY PARKER,

knowingly and intentionally possessed one or more of the following firearms:

1. an Iver Johnson Aims & Cycle Works, Model Revolver 1st, .32 caliber

S&W revolver, bearing serial number 9323;

2. a Taurus International Manufacturing, Model The Judge, .45 caliber

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revolver, bearing serial number KU298501;

3. a Forehand & Wadsw01ih, Model Bulldog, .38 caliber revolver, bearing

serial number 4 71;

4. a Carl Walther Arms, Model UZI, .22 LR pistol, bearing serial number

W1023325;and

5. a Glock, M~del 43, 9mm pistol, bearing serial number ADTB169,

in furtherance of a drug trafficking crime prosecutable in a court of the United States, that is: a

violation of Title 21, United States Code, Section 846, as set f01ih in Count I of this Indictment,

and a violation of Title 21, United States Code, Section 841(a)(l), as set forth in Count 20 of this

Indictment.

All in violation of Title 18, United States Code, Section 924(c)(l)(A).

COUNT22

A. On or about July 9, 2022, the defendant,

TIMOTHY PARKER,

had previously and knowingly been convicted of a crime punishable by a te1m of imprisonment

exceeding one year, that is: Distribution of More Than 5 Grams of Cocaine Base, in the United

States District Comi for the Eastern District of Arkansas, in Case Number 4:03CR00128-01-

WRW.

B. On or about July 9, 2022, in the Eastern District of Arkansas, the

defendant,

TIMOTHY PARKER,

knowingly possessed, in and affecting commerce, one or more of the following fireaims:

1. an Iver Johnson Arms & Cycle Works, Model Revolver 1st, .32 caliber

S&W revolver, bearing serial number 9323;

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2. a Taurus International Manufacturing, Model The Judge, .45 caliber

revolver, bearing serial number KU298501;

3. a Forehand & Wadsworth, Model Bulldog, .38 caliber revolver, bearing

serial number 4 71;

4. a Carl Walther Arms, Model UZI, .22 LR pistol, bearing serial number

W1023325;and

5. a Glock, Model 43, 9mm pistol, bearing serial number ADTB169.

All in violation of Title 18, United States Code, Section 922(g)(l ).

COUNT23

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

BRODERICK CHUNN,

knowingly and intentionally possessed with intent to distribute a mixture and substance

containing a detectable amount of cocaine, a Schedule II controlled substance; a mixture and

substance containing a detectable amount of cocaine base, commonly known as crack cocaine;

and marijuana, a Schedule I controlled substance, in violation of Title 21, United States Code,

Sections 841(a)(l) and 841(b)(l)(C)&(D).

COUNT24

A. On or about July 9, 2022, the defendant,

BRODERICK CHUNN,

had previously and knowingly been convicted of one or more of the following crimes punishable

by a term of imprisonment exceeding one year:

1. Domestic Battering - yd Degree, and Tenoristic Threatening/1 st Degree, in

Pulaski County, Arkansas, Circuit Comi in Case Number 2005 002493; and

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2. Conspiracy to possess with intent to distribute cocaine and cocaine base, in

the United States District Court for the Eastern District of Arkansas in Case

Number 4:05CR00109-02 JLH.

B. On or about July 9, 2022, in the Eastern District of Arkansas, the

defendant,

BRODERICK CHUNN,

knowingly possessed, in and affecting commerce, one or more rounds of the following

ammunition:

1. Hornady 9mm Luger ammunition; and

2. PPU .40 S& W caliber ammunition.

All in violation of Title 18, United States Code, Section 922(g)(l ).

COUNT25

On or about July 9, 2022, in the Eastern District of Arkansas, the defendants,

BRODERICK CHUNN, and

MARQUIS HUNT,

knowingly and intentionally possessed with intent to distribute more than 500 grams of a mixture

and substance containing a detectable amount of methamphetamine, a Schedule II controlled

substance; less than 500 grams of a mixture and substance containing a detectable amount of

cocaine, a Schedule II controlled substance; and marijuana, a Schedule I controlled substance; in

violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(A),(C)&(D).

COUNT26

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

MARQUIS HUNT,

knowingly and intentionally possessed a firearm, that is: a Taurus, model PT92 AF, 9mm pistol,

bearing serial number TJ159827, in fmiherance of a drug trafficking crime prosecutable in a

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court of the United States, that is: a violation of Title 21, United States Code, Section 846, as set

forth in Count 1 of this Indictment, and a violation of Title 21, United States Code, Section

841(a)(l), as set forth in Count 25 of this Indictment.

All in violation of Title 18, United States Code, Section 924( c)(1 )(A).

COUNT27

A. On or about July 9, 2022, the defendant,

MARQUIS HUNT,

had previously and knowingly been convicted of one or more of the following crimes punishable

by a term of imprisonment exceeding one year:

1. Possession of Marijuana with Intent to Deliver, in Pulaski County,

Arkansas, Circuit Comi in Case Number CR 2002 001620;

2. Possession of Firearm by Certain Persons, in Pulaski County, Arkansas,

Circuit Court in Case Number CR 2003 001869;

3. Possession of methylenedioxymethamphetamine (MDMA), and Possession

of cocaine hydrochloride, in the United States District Comi, Eastern

District of Arkansas in Case Number 4:07CR00234 JLH;

4. Fleeing, in Pulaski County, Arkansas Circuit Court in Case Number CR

2007 003503;

5. Possession of Meth/Cocaine with Purpose to Deliver and Drug

Paraphernalia, in Pulaski Com1ty, Arkansas, Circuit Comi in Case Number

2016-2649;

6. Failure to Appear, in Pulaski County, Arkansas, Circuit Comi in Case

Number 2017-0587; and

7. Theft of Property and Possession ofFireaims by Ce1iain Persons, in Pulaski

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County, Arkansas, Circuit Comi in Case Number 2017-2124.

B. On or about July 9, 2022, in the Eastern District of Arkansas, the

defendant,

MARQUIS HUNT,

knowingly possessed, in and affecting commerce, a firearm, that is: a Taurus, model PT92 AF,

9mm pistol, bearing serial number TJ159827.

All in violation of Title 18, United States Code, Section 922(g)(l ).

COUNT28

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

LC DAVIS,

knowingly and intentionally possessed with intent to distribute a mixtme and substance

containing a detectable amount of cocaine base, commonly known as crack cocaine, a Schedule

II controlled substance, in violation of Title 21 , United States Code, Sections 841(a)(l) and

841 (b )(1 )(C).

COUNT29

On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

LC DAVIS,

knowingly and intentionally possessed one or more of the following firearms:

1. a Winchester, Model 1400, 16 gauge shotgun, bearing serial number

135807; and

2. a Taurus, Model G2C 9mm pistol, bearing serial number TMD30346;

in fmiherance of a drug trafficking crime prosecutable in a comi of the United States, that is: a

violation of Title 21 , United States Code, Section 846, as set fo1ih in Count 1 of this Indictment,

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and a violation of Title 21 , United States Code, Section 841(a)(l), as set forth in Count 28 of this

Indictment.

All in violation of Title 18, United States Code, Section 924( c)(1 )(A).

COUNT30

A. On or about July 9, 2022, the defendant,

LC DAVIS,

had previously and knowingly been convicted of one or more of the following crimes punishable

by a term of imprisonment exceeding one year:

1. Operating a Continuing Criminal Enterprise, in Ouachita County, Arkansas,

Circuit Court in Case Number CR-92-188; and

2. Conspiracy to Manufacture and Possess with Intent to Distribute Cocaine

Base, in the United States District Court, Eastern District of Arkansas in

Case Number 4:00CR00239-001 SWW.

B. On or about July 9, 2022, in the Eastern District of Arkansas, the defendant,

L CDAVIS,

knowingly possessed, in and affecting commerce, one or more of the following firearms :

1. a Winchester, Model 1400, 16 gauge shotgun, bearing serial number

135807;and

2. a Taurus, Model G2C 9mm pistol, bearing serial number TMD30346.

All in violation of Title 18, United States Code, Section 922(g)(l).

COUNT31

On or about April 27, 2021, in Session 1190 (TP 1), in the Eastern District of Arkansas,

the defendant,

FREDDIE GLADNEY, JR.,

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knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth-in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT32

On or about April 27, 2021, in Session 1189 (TP2), in the Eastern District of Arkansas,

the defendant,

FREDDIE GLADNEY, III,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT33

On or about July 7, 2021, in Session 358 (TP3), in the Eastern District of Arkansas, the

defendant,

JEREMY GREEN,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

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COUNT34

On or about February 8, 2022, in Session 136 (TP8), in the Eastern District of Arkansas,

the defendant,

DONALD TEAGUE,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT35

On or about June 10, 2022, in Session 92 (TP 10), in the Eastern District of Arkansas, the

defendant,

TIMOTHY PARK.ER,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT36

On or about June 22, 2022, in Session 2805 (TPlO), in the Eastern District of Arkansas,

the defendant,

ERICAVETT,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

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controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT37

On or about May 15, 2021 , in Session 4531 (TPl), in the Eastern District of Arkansas,

the defendant,

DEWAYNE BAKER

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT38

On or about July 7, 2022, in Session 6389 (TPl0), in the Eastern District of Arkansas, the

defendant,

BRODERICK CHUNN,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT39

On or about May 15, 2021, in Session 4618 (TPl), in the Eastern District of Arkansas,

the defendant,

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JAMAL DANIELS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(6).

COUNT40

On or about April 22, 2021, in Session 469 (TPl), in the Eastern District of Arkansas, the

defendant,

CLIFFORD DAVIS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(6).

COUNT41

On or about June 28, 2022, in Session 4206 (TPl0), in the Eastern District of Arkansas,

the defendant,

LC DAVIS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(6).

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COUNT42

On or about May 18, 2021, in Session 360 (TP2), in the Eastern District of Arkansas, the

defendant,

RICKEY FOREMAN, JR.,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT43

On or about June 3, 2021, in Session 874 (TP2), in the Eastern District of Arkansas, the

defendant,

DARRIUS FURLOW,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT44

On or about July 29, 2021, in Session 1876 (TP3), in the Eastern District of Arkansas, the

defendant,

DEANDRE GATES,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

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controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT45

On or about July 15, 2021 , in Session 912 (TP3), in the Eastern District of Arkansas, the

defendant,

JONATHON GREEN,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21 , United States Code, Section 843(b).

COUNT46

On or about April 29, 2021 , in Session 95 (TPl), in the Eastern District of Arkansas, the

defendant,

MARCUS HUGHES,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21 , United States Code, Section 843(b).

COUNT47

On or about February 12, 2022, in Session 741 (TP8), in the Eastern District of Arkansas,

the defendant,

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HERSHEL JONES,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT48

On or about May 17, 2021, in Session 4805 (TPl), in the Eastern District of Arkansas,

the defendant,

ANGEL KING,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT49

On or about June 20, 2022, in Session 2532 (TPl 0), in the Eastern District of Arkansas,

the defendant,

KOBI KNIGHT,

knowingly and intentionally used a c01mnunication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

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COUNT SO

On or about May 5, 2021, in Session 2448 (TPl), in the Eastern District of Arkansas, the

defendant,

JENNIFER LENAIR,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNTSl

On or about April 29, 2021, in Session 1594 (TPl), in the Eastern District of Arkansas,

the defendant,

JOE MORGAN, III,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set fo1ih in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT52

On or about July 17, 2021, in Session 993 (TP3), in the Eastern District of Arkansas, the

defendant,

AARON NICHOLS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

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controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT 53

On or about May 15, 2021, in Session 4470 (TPl), in the Eastern District of Arkansas,

the defendant,

MARIO NICKSON,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT54

On or about May 19, 2021, in Session 491 (TP2), in the Eastern District of Arkansas, the

defendant,

KAJARVIS O'NEAL,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT 55

On or about September 27, 2021, in Session 2389 (TP3), in the Eastern District of

Arkansas, the defendant,

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 Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 31 of 38

SASHA QUAMINA,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT56

On or about May 3, 2021, in Session 2148 (TPl), in the Eastern District of Arkansas, the

defendant,

ANTONIO RATTLER,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT57

On or about July 21, 2021, in Session 1271 (TP3), in the Eastern District of Arkansas, the

defendant,

NICHOLAS ROGERS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

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COUNT58

On or about May 19, 2021, in Session 496 (TP2), in the Eastern District of Arkansas, the

defendant,

JAY SLAUGHTER,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT 59

On or about June 1, 2021, in Session 1849 (TP2), in the Eastern District of Arkansas, the

defendant,

MATTHEW TAYLOR,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21, United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT60

On or about July 2, 2021, in Session 105 (TP3 ), in the Eastern District of Arkansas, the

defendant,

KIMINISKI TEAGUE,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

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controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

COUNT 61

On or about July 9, 2021 , in Session 529 (TP3), in the Eastern District of Arkansas, the

defendant,

MICHAEL WILLIAMS,

knowingly and intentionally used a communication facility, that is: a telephone, in committing,

causing and facilitating a conspiracy to distribute and to possess with intent to distribute a

controlled substance in violation of Title 21 , United States Code, Section 846, as set forth in Count

1 of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

FORFEITURE ALLEGATION 1

Upon conviction of Counts 1, 2, 9, 10, 13, 15, 18, 20, 23 , 25, 28, 31 , 32, 33, 34, 35, 36, 37,

38, 39, 40, 41 , 42, 43 , 44, 45, 46, 47, 48, 49, 50, 51 , 52, 53 , 54, 55, 56, 57, 58, 59, 60 or 61 of this

Indictment, the defendants, FREDDIE GLADNEY, JR., FREDDIE GLADNEY, III, JEREMY

GREEN, DONALD TEAGUE, TIMOTHY PARKER, ERIC AVETT, DEWAYNE BAKER,

BRODERICK CHUNN, JAMAL DANIELS, CLIFFORD DAVIS, L C DAVIS, RICKEY

FOREMAN, JR., DARIUS FURLOW, DEANDRE GATES, JONATHON GREEN, EDWARD

HOUSE, II, MARCUS HUGHES, MARQUIS HUNT, HERSHEL JONES, ANGEL KING, KOBI

KNIGHT, JENNIFER LENAIR, JOE MORGAN, III, AARON NICHOLS , MARIO NICKSON,

KAJARVIS O'NEAL, SASHA QUAMINA, ANTONIO RATTLER, DONNELL LAKEITH

REED, BRANDON KINGSLEY ROBINSON, NICHOLAS ROGERS, JAY SLAUGHTER,

MATTHEW TAYLOR, KIMINISKI TEAGUE, and MICHAEL WILLIAMS, shall forfeit to the

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United States, under Title 21, United States Code, Section 853(a)(l), all property constituting, or

derived from, any proceeds the person obtained, directly or indirectly, as a result of the offense,

including, but not limited to, the following specific property:

1. Jewelry seized from Freddie Gladney, III;

2. $71,160.00 seized from Jennifer Lenair and Freddie Gladney, Jr.;

3. $216,200.00 seized from Jeremy Green;

4. $1,001.00 seized from Jeremy Green;

5. $14,980.00 seized from Deandre Gates;

6. Jewelry seized from Deandre Gates;

7. $209,103.00 seized from Broderick Chunn;

8. 2013 Jeep, VIN: 1C4BJWDG1DL577754 seized from Broderick Chunn;

9. $1,085.00 seized from LC Davis; and

10. Jewelry seized from Dom1ell Lakeith Reed and Tynkia Reed.

FORFEITURE ALLEGATION 2

Upon conviction of Count 1, 2, 9, 10, 13, 15, 18, 20, 23, 25, 28, 31, 32, 33, 34, 35, 36, 37,

38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60 or 61 of this

Indictment, the defendants, FREDDIE GLADNEY, JR., FREDDIE GLADNEY, III, JEREMY

GREEN, DONALD TEAGUE, TIMOTHY PARKER, ERIC AYETT, DEWAYNE BAKER,

BRODERICK CHUNN, JAMAL DANIELS, CLIFFORD DAVIS, L C DAVIS, RICKEY

FOREMAN, JR., DARIUS FURLOW, DEANDRE GATES, JONATHON GREEN, EDWARD

HOUSE, II, MARCUS HUGHES, MARQUIS HUNT, HERSHEL JONES, ANGEL KING, KOBI

KNIGHT, JENNIFER LENAIR, JOE MORGAN, III, AARON NICHOLS, MARIO NICKSON,

KAJARVIS O'NEAL, SASHA QUAMINA, ANTONIO RATTLER, DONNELL LAKEITH

REED, BRANDON KINGSLEY ROBINSON, NICHOLAS ROGERS, JAY SLAUGHTER,

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 Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 35 of 38

MATTHEW TAYLOR, KIMINISKI TEAGUE, and MICHAEL WILLIAMS,, shall forfeit to the

United States, under Title 21, United States Code, Section 853(a)(2), all of the person's property

used or intended to be used, in any manner or part, to commit, or to facilitate the commission of

the offense, including, but not limited to, the following specific prope1iy:

1. $71,160.00 seized from Jennifer Lenair and Freddie Gladney, Jr.;

2. $216,200.00 seized from Jeremy Green;

3. $1,001.00 seized from Jeremy Green;

4. $14,980.00 seized from Deandre Gates;

5. $209,103.00 seized from Broderick Chunn;

6. 2013 Jeep, VIN: 1C4BJWDG1DL577754 seized from Broderick Chunn;

and

7. $1,085.00 seized from LC Davis.

FORFEITURE ALLEGATION 3

Upon conviction of one or more of the offenses charged in Count 1, 2, 3, 4, 5, 6, 7, 8, 9,

10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35,

36,37,38, 39,40,41,42,43,44,45,46,47,48,49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, or

61 of this Indictment, the defendants, FREDDIE GLADNEY, JR., FREDDIE GLADNEY, III,

JEREMY GREEN, DONALD TEAGUE, TIMOTHY PARKER, ERIC AYETT, DEWAYNE

BAKER, BRODERICK CHUNN, JAMAL DANIELS, CLIFFORD DAVIS, L C DAVIS,

RICKEY FOREMAN, JR., DARIUS FURLOW, DEANDRE GATES, JONATHON GREEN,

EDWARD HOUSE, II, MARCUS HUGHES, MARQUIS HUNT, HERSHEL JONES, ANGEL

KING, KOBI KNIGHT, JENNIFER LEN AIR, JOE MORGAN, III, AARON NICHOLS, MARIO

NICKSON, KAJARVIS O'NEAL, SASHA QUAMINA, ANTONIO RATTLER, DONNELL

LAKEITH REED, BRANDON KINGSLEY ROBINSON, NICHOLAS ROGERS, JAY

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SLAUGHTER, MATTHEW TAYLOR, KIMINISKI TEAGUE, and MICHAEL WILLIAMS,,

shall forfeit to the United States, under Title 18, United States Code, Section 924(d), Title 21,

United States Code, Section 853, and Title 28, United States Code, Section 2461(c), all fireaims

and ammunition involved in the commission of the offense, including, but not limited to, the

following specific property:

1. an Anderson Manufacturing Model AM15, multi-caliber rifle, bearing

serial number 16110644;

2. a Glock, Model 19, 9mm pistol, bearing serial number BTNP614;

3. a Glock, Model 43X, 9mm pistol, beai·ing serial number BTTF330;

4. a Taurus International, Model G2C, 9mm pistol, bearing serial number

TLW87873;

5. a Diamondback Fireanns, Model DB15, 5.56 NATO caliber rifle, bearing

serial number DB2445497;

6. a Norinco, Model SKS Type 56, 7.62x39 rifle, beai·ing serial number

18006266];

7. a Bersa SA, Model Thunder 380, .380 ACP pistol, bearing serial number

178964;

8. a Sturm, Ruger & Company, Model SR40, .40 caliber S&W pistol,

bearing serial number 34215519;

9. an FN USA, Model FNS-40, .40 caliber pistol, bearing serial number

GKU0105517;

10. a Palmetto State Armory, Model PA-15, .223 caliber pistol, bearing serial

number PA186914;

11 . a Glock, Model 23 Gen 5, .40 caliber pistol, bearing serial number

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Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 37 of 38

BTSN029;

12. a Romarm/Cugir, model Micro Draco, 7.62x39mm, pistol, bearing serial

number ROA 22 PMD-28522;

13. a Polymer80, model PF940C, 9mm, privately-made firearm, bearing no

serial number;

14. a machinegun, that is, a Glock conversion device;

15. an Iver Johnson Aims & Cycle Works, Model Revolver 1st, .32 caliber

S&W revolver, bearing serial number 9323;

16. a Taurus International Manufacturing, Model The Judge, .45 caliber

revolver, bearing serial number KU298501;

17. a Forehand & Wadswo1ih, Model Bulldog, .38 caliber revolver, bearing

serial number 471;

18. a Carl Walther Alms, Model UZI, .22 LR pistol, bearing serial number

W1023325;

19. a Glock, Model 43, 9mm pistol, bearing serial number ADTB 169;

20. a Taurus, model PT92 AF, 9mm pistol, bearing serial number TJ159827;

21. a Winchester, Model 1400, 16 gauge shotgun, bearing serial number

135807;

22. a Taurus, Model G2C, 9mm pistol, bearing serial number TMD30346;

23. an HS Produkt, Model XD-9, 9mm pistol, bearing serial number

XD157802;

24. a FN USA, Model 509, 9mm pistol, bearing serial number GKS 160112;

25. a Smith & Wesson, model M&P9, 9mm pistol, bearing serial number

HNJ8389;

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Case 4:22-cr-00300-JM Document 3 Filed 11/01/22 Page 38 of 38

26. an HS Produkt, model XD-40, sub-compact Mod.2, .40 caliber pistol,

bearing serial number BA288304;

27. Multiple rounds of .45 auto caliber, PMC ammunition;

28. One round of .380 auto caliber, PMC ammunition;

29. Multiple rounds ofHomady 9mm Luger ammunition;

30. Multiple rounds of PPU .40 S&W caliber ammunition; and

31. a Taurus, Model G2C 9mm pistol, bearing serial number TMR32350.

38