Case 4:18-cr-00053-KGB Document 3 Filed 02/06/18 Page 1 of 12 FILED

U.S. DISTRICT COURT

EASTERN DISTRICT ARKANSAS

FEB - 6 2018
UNITED STATES DISTRICT COURT JAMES W. McCORM
EASTERN DISTRICT OF ARKANSAS By: _ _ _ _..-+.,ir:~lf:":-::"::l't:'
UNITED STATES OF AMERICA )
) No. 4:18CR ~'B
OOOS?J
)
v. ) 21 U.S.C. § 841(a)(l), (b)(l) (B), (C), (D)
) 21U.S.C.§846
) 18 U.S.C. § 922(g)(l), 924(c)
CLIFTON LAMON THOMAS aka "Bliff' )
DEWQUAN MARQUIS JOHNS aka "Bread" )
MARVIN KENTRAL COLLINS aka "Tral Wayz" )
BILAL JOHNS MUHAMMAD aka "Feezio" )
MARCHELIO ATWON ROBINSON )
aka "Big Juice" )
KYLE KEITH ROBINSON aka "T.S." )
SHADEED OMAR DAWKINS )
DENNIS RAMON CAMP )
JAMES RUBEN LANGFORD )
DONALD LEE YOUNG )
BILAL SEAN MUHAMMAD aka "Lil Feezi" )
aka "Redd" )
DAMIEN MARKEE YOUNG aka "D-Mac" )
aka "Shooter" )
KEN CURTIS KEYS )

INDICTMENT

THE GRAND JURY CHARGES THAT:

COUNT!

Beginning in or about January, 2017, and continuing through on or about February 6,

2018, in the Eastern District of Arkansas and elsewhere,

CLIFTON LAMON THOMAS aka "Bliff'

DEWQUAN MARQUIS JOHNS aka "Bread"
MARVIN KENTRAL COLLINS aka "Tral Wayz"
BILAL JOHNS MUHAMMAD aka "Feezio"
MARCHELIO ATWON ROBINSON aka "Big Juice"
KYLE KEITH ROBINSON aka "T.S."
SHADEED OMAR DAWKINS

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DENNIS RAMON CAMP

JAMES RUBEN LANGFORD
DONALD LEE YOUNG
BILAL SEAN MUHAMMAD aka "Lil Feezi" aka "Redd"
DAMIEN MARKEE YOUNG aka "D-Mac"
aka "Shooter"
KEN CURTIS KEYS

knowingly and intentionally conspired with each other and other persons known and unknown to

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

Schedule I and II controlled substances, to wit: mixtures or substances containing a detectable

amount of heroin, cocaine hydrochloride, and oxycodone in violation of Title 21, United States

Code, Section 841(a)(l).

1. With respect to defendant CLIFTON LAMON THOMAS, the amount of heroin involved

in the conspiracy attributable him as a result of his own conduct, and the conduct of other

co-conspirators reasonably foreseeable to him, is less than 100 grams of a mixture or

substance containing a detectable amount of heroin, in violation of Title 21, United States

Code, section 841(b)(l)(C).

2. With respect to defendants CLIFTON LAMON THOMAS, DEWQUAN MARQUIS

JOHNS, BILAL JOHNS MUHAMMAD, KYLE KEITH ROBINSON, MARCHELIO

ATWON ROBINSON, and SHADEED OMAR DAWKINS, the amount of cocaine

hydrochloride involved in the conspiracy attributable to each of them as a result of his

own conduct, and the conduct of other co-conspirators reasonably foreseeable to him, is

at least 500 grams, but less than 5 kilograms of a mixture or substance containing a

detectable amount of cocaine hydrochloride, in violation of Title 21, United States Code,

section 841 (b )(1 )(B).

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3. With respect to defendants DENNIS RAMON CAMP, JAMES RUBEN LANGFORD,

DONALD LEE YOUNG, the amount of cocaine hydrochloride involved in the

conspiracy attributable to each of them as a result of his own conduct, and the conduct of

other co-conspirators reasonably foreseeable to him, is less than 500 grams of a mixture

or substance containing a detectable amount of cocaine hydrochloride, in violation of

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

4. With respect to defendants JAMES RUBEN LANGFORD, MARVIN KENTRAL

COLLINS, DAMIEN MARKEE YOUNG, KEN CURTIS KEYS, BILAL SEAN

MUHAMMAD, and DONALD LEE YOUNG, the amount of marijuana involved in the

conspiracy attributable to each of them as a result of his own conduct, and the conduct of

other co-conspirators reasonably foreseeable to him, is less than 50 kilograms of a

mixture or substance containing a detectable amount of marijuana, in violation of Title

21, United States Code, section 841 (b )(1 )(D).

5. With respect to defendants CLIFTON LAMON THOMAS and BILAL JOHNS

MUHAMMAD the amount of oxycodone involved in the conspiracy attributable to each

of them as a result of his own conduct is a violation of Title 21, United States Code,

section 841 (b )( 1)(C).

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

COUNT2

On or about January 19, 201 7, in the Eastern District of Arkansas, the defendant,

SHADEED OMAR DAWKINS

knowingly and intentionally possessed with intent to distribute and distributed less than 500

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grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(C).

COUNT3

On or about January 20, 2017, in the Eastern District of Arkansas, the defendant,

CLIFTON LAMON THOMAS aka "Bliff'

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing heroin, a Schedule I controlled substance, in violation of Title 21, United

States Code, Section 841(a)(l) and (b)(l)(C).

COUNT4

On or about February 2, 2017, in the Eastern District of Arkansas, the defendant,

CLIFTON LAMON THOMAS aka "Bliff'

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing heroin, a Schedule I controlled substance, in violation of Title 21, United

States Code, Section 841(a)(l) and (b)(l)(C).

COUNTS

On or about March 9, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz" and

DAMIEN MARKEE YOUNG aka "D-Mac" aka "Shooter"

aiding and abetting one another, knowingly and intentionally possessed with intent to distribute

and distributed a mixture or substance containing marijuana, a Schedule I controlled substance,

in violation of Title 21, United States Code, Section 841(a)(l) and (b)(l)(D), and Title 18,

United States Code, Section 2.

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COUNT6

On or about March 23, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz" and

DAMIEN MARKEE YOUNG aka "D-Mac" aka "Shooter"

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing marijuana, a Schedule I controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(D).

COUNT7

On or about March 23, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz"

in furtherance of a drug trafficking crime for which he can be prosecuted in a court of the United

States, to wit, possession with intent to distribute marijuana and distribution of marijuana as

charged in Count 6 of this Indictment, knowingly possessed a firearm in violation of Title 18,

United States Code, Section 924(c)(l)(A)(i).

COUNTS

On or about April 5, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz"

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing marijuana, a Schedule I controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(D).

COUNT9

On or about April 26, 201 7, in the Eastern District of Arkansas, the defendant,

CLIFTON LAMON THOMAS aka "Bliff'

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knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing heroin, a Schedule I controlled substance, in violation of Title 21, United

States Code, Section 841(a)(l) and (b)(l)(C).

COUNT 10

On or about May 11, 201 7, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz"

and DAMIEN MARKEE YOUNG aka "D-Mac" aka "Shooter"

aiding and abetting one another, knowingly and intentionally possessed with intent to distribute

and distributed a mixture or substance containing marijuana, a Schedule I controlled substance,

in violation of Title 21, United States Code, Section 841(a)(l) and (b)(l)(D), and Title 18,

United States Code, Section 2.

COUNT 11

On or about May 11, 201 7, in the Eastern District of Arkansas, the defendant,
•
KEN CURTIS KEYS

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

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

Section 841(a)(l) and (b)(l)(D).

COUNT 12

On or about May 11, 2017, in the Eastern District of Arkansas, the defendant,

KEN CURTIS KEYS

in furtherance of a drug trafficking crime for which he can be prosecuted in a court of the United

States, to wit, conspiracy to possess with intent to distribute marijuana and possession with intent

to distribute marijuana as charged in Counts 1and6 ofthis Indictment, knowingly possessed a

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firearm, to wit, one Sig Sauer 9mm handgun, serial number U890110, in violation of Title 18,

United States Code, Section 924(c)(l)(A)(i).

COUNT 13

A. Prior to May 11, 2017, the defendant, KEN CURTIS KEYS, had been convicted

of the following offense: Possession with Purpose to Deliver a Controlled Substance, C Felony,

in Pulaski County Circuit Court case number 60 CR-16-702, on August 30, 2016; and

B. The crime set forth in paragraph A above was punishable by a term of

imprisonment exceeding one year.

C. On or about May 11, 2017, in the Eastern District of Arkansas,

KEN CURTIS KEYS

did knowingly possess the following firearm in and affecting commerce, to wit: one Sig Sauer

9mm handgun, serial number U890110, in violation of Title 18, United States Code, Section

922(g)(l).

COUNT 14

On or about June 27, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz"

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing marijuana, a Schedule I controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(D).

COUNT 15

On or about July 13, 2017, in the Eastern District of Arkansas, the defendant,

MARCHELIO ATWON ROBINSON aka "Big Juice"

KYLE KEITH ROBINSON aka "T.S." and

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SHADEED OMAR DAWKINS

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(C).

COUNT 16

On or about August 11, 2017, in the Eastern District of Arkansas, the defendant,

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(C).

COUNT 17

On or about August 14, 2017, in the Eastern District of Arkansas, the defendant,

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(C).

COUNT 18

On or about August 30, 2017, in the Eastern District of Arkansas, the defendant,

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l) and (b)(l)(C).

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COUNT 19

On or about September 1, 2017, in the Eastern District of Arkansas, the defendant,

DAMIEN MARKEE YOUNG aka "D-Mac" aka "Shooter"

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing marijuana, a Schedule I controlled substance, in violation of Title 21,

United States Code, Section 84l(a)(l) and (b)(l)(D).

COUNT20

On or about September 13, 2017, in the Eastern District of Arkansas, the defendant,

DEWQUAN MARQUIS JOHNS aka "Bread" and

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 84l(a)(l) and (b)(l)(C).

COUNT21

On or about September 26, 201 7, in the Eastern District of Arkansas, the defendant,

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 84l(a)(l) and (b)(l)(C).

COUNT22

On or about October 12, 2017, in the Eastern District of Arkansas, the defendant,

BILAL JOHNS MUHAMMAD aka "Feezio"

knowingly and intentionally possessed with intent to distribute and distributed less than 500

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grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 84l(a)(l) and (b)(l)(C).

COUNT23

On or about October 12, 2017, in the Eastern District of Arkansas, the defendant,

MARCHELIO ATWON ROBINSON aka "Big Juice"

KYLE KEITH ROBINSON aka "T.S." and
SHADEED OMAR DAWKINS

knowingly and intentionally possessed with intent to distribute and distributed less than 500

grams of cocaine hydrochloride, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 84l(a)(l) and (b)(l)(C).

COUNT24

On or about October 26, 201 7, in the Eastern District of Arkansas, the defendant,

SHADEED OMAR DAWKINS

in furtherance of a drug trafficking crime for which he can be prosecuted in a court of the United

States, to wit, conspiracy to possess with intent to distribute cocaine as charged in Count 1 of this

Indictment, knowingly possessed one or more firearms including, but not limited to, the following:

one black Ruger 10-22 rifle with pistol grip serial number 355-07699; one Glock 27 pistol serial

number B4W572US; one black Springfield Armory X-D .45 caliber semi auto pistol serial

number MG525404, in violation of Title 18, United States Code, Section 924(c)(l)(A)(i).

COUNT25

On or about December 9, 201 7, in the Eastern District of Arkansas, the defendant,

BILAL SEAN MUHAMMAD aka "Lil Feezi" aka "Redd"

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

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

Section 841(a)(l) and (b)(l)(D).

COUNT26

On or about December 9, 201 7, in the Eastern District of Arkansas, the defendant,

BILAL SEAN MUHAMMAD aka "Lil Feezi" aka "Redd"

in furtherance of a drug trafficking crime for which he can be prosecuted in a court of the United

States, to wit, possession with intent to distribution cocaine as charged in Count 25 of this

Indictment, knowingly possessed one or more firearms including, but not limited to, the following:

one black Smith and Wesson 9mm handgun, serial number HBE5534, in violation of Title 18,

United States Code, Section 924(c)(l)(A)(i).

COUNT27

On or about December 14, 2017, in the Eastern District of Arkansas, the defendant,

MARVIN KENTRAL COLLINS aka "Tral Wayz"

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

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

Section 841(a)(l) and (b)(l)(D).

COUNT28

On or about January 18, 2018, in the Eastern District of Arkansas, the defendant,

DONALD LEE YOUNG

knowingly and intentionally possessed with intent to distribute and distributed a mixture or

substance containing cocaine hydrochloride, a Schedule II controlled substance, in violation of

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

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FORFEITURE ALLEGATION 1

Upon conviction of one or more of the offenses alleged in Counts 12 & 13 of this

Indictment, KEN CURITS KEYS shall forfeit to the United States, under 18 U.S.C. § 924(d), 21

U.S.C. § 853, and 28 U.S.C. § 2461(c), all firearms and ammunition involved in the commission of

the offense, including, but not limited to, the following: one Sig Sauer 9mm handgun, serial number

U890110, and all ammunition seized on May 11, 2017.

FORFEITURE ALLEGATION 2

Upon conviction of one or more of the offenses alleged in Counts 1 and 24 of this

Indictment, SHADEED OMAR DAWKINS shall forfeit to the United States, under 18 U.S.C. §

924(d), :41 U.S.C. § 853, and 28 U.S.C. § 2461(c), all 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: one black Ruger 10-22 rifle with pistol grip serial number 355-07699; one

Glock 27 pistol serial number B4W572US; one black Springfield Armory X-D .45 caliber semi

auto pistol serial number MG525404 and all ammunition seized on October 26, 2017.

FORFEITURE ALLEGATION 3

Upon conviction of the offense alleged in Count 26, of this Indictment, BILAL SEAN

MUHAMMAD aka "Lil Feezi" aka "Redd" shall forfeit to the United States, under 18 U.S.C. §

924(d), 21 U.S.C. § 853, and 28 U.S.C. § 2461(c), all 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: one black Smith and Wesson 9mm handgun, serial number HBE5534 and all

ammunition seized on December 9, 2017.

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