criminal xumber:#.' IC-c(-oOe /1

CLERKS OFFICE U. ,S DIST. COURTAT CFIARLOU ESVILE, VA

FILED

JUN 1 1 2218JUL D LEY CLERK

BY;RK

IN THEUNITED STATES DISTRICT COURT

FOR THEW ESTERN DISTRICT OF VIRGINIA

DAN VILLE DM SION

UNITED STATES OF AM ERICA

#.' IC-c(-oOe /1criminal xumber:DASHAW N ROM EER AN THOW

a/k/a Gçshon Don'' or <tstllnna''

DEM ETRTUS ALLEN STATENa/k/a sE-l-ruck''

TREDARW SJAMEM QUAN KEENEa/k/a EEBubba'' or ççBubs''

MONTEZ LAMAR ALLENa/lc/a K<llloc M illa''

JAVONTAY JACQUIS HOLLANDa/k/a tTa/' or ç:Reckless''

TANA SIA LASHAE COLEM ANa/k/a EENasia''

JERM AY SM ITH, JR.a/k/a çtittle Td11''

JALEN CORM ARRIUS TERRYa/k/a <<l7ats''

In Violation of:

18 U.S.C. j 218 U.S.C. j 924(c)(1)(A)(iii)18 U.S.C. j 924()18 U.S.C. j 1959(a)(1), (3), (5)18 U.S.C. j 1962 (d)18 U.S.C. j 1963

INDICTM EN T

USAO 2018R00302Case 4:18-cr-00012-MFU *SEALED* Document 5 Filed 06/11/18 Page 1 of 17 Pageid#: 12

COUNT ONERacketeering Conspiracy

The Grand Jury charges:

Introduction

1.

in New York City.

The New York Bloods Nation'' (herein, GGBloods'') street gang was formed in 1993

The Bloods street gang is compdsed of individual lmits, or EEsets,'' each identified

or affiliated with a certain street, neighborhood, or geograpllic area.

3. The MFLLAS (G<MILLAs'') is a set of the Bloods street gang that has operated in

the W estem District of Virginia, prim adly Danville, Virglm' 'a, since at lbast sometim e in or about

2015.

a. In addition to their violent cdminal activity, the M ILLAS derive income

f'rom dnzg distdbution and sales of firearm s and stolen property.

b. The M ILLAS operate within a defned geographic territory within

Danville, Virginia. M ILLAS maintain control over their tenitory through

the use of violence.

c. M embers of the M ILLAS are m ainly irlitiated through EEbeat ins'' that

typically consist of a twentyrone second beating by multiple gang

m embers. A m ember can also be GGblessed in'' by doing a predeterm ined

crime or list of crimes, such as a m urder or a series of robbedes or by

virtue of having belonged to another Bloods set. Female m embers can

also be illitiated by having sexfzal intercolzrse with m ultiple gang m embers.

USWO 2018R00302Case 4:18-cr-00012-MFU *SEALED* Document 5 Filed 06/11/18 Page 2 of 17 Pageid#: 13

d. The M ILLAS comm orlly utilize a variety of unifying marks, manners, and

identifiers, including GGgang signs'' that are specific to the gang

organization. Am ong others, these insignia include the s-pointed star.

The m embers of the M ILLAS often identify themselves by using one hand

to form an çGM ,'' showing they are m embers of the M ILLA Bloods gang.

M embers of the M ILLAS also identify them selves with red colored

clothing or weadng a red bandana or çdtlagy'' as is typical with Bloods

gangs nationally.

The M ILLAS operate lmder a specifc hierarchy and leadership structure.

Generally, members are ranked based upon how long an individual has

been a m ember of the gang, the number and severity of cdm es an

individual has comm itted on behalf of the gang, and other contributions to

the gang and its entep tise. Different ççpositions'' within the gang have

different nam es, such as. Etone-star'' or Et ow'' which indicates the level that

person holds witllin the gang stnlcture. M embers can advance within the

leadership structure. The M ILLAS ftmction according to a set of rules

sometimes contained in GGbooks of lœowledge.'' Th8 books of knowledge

can descdbe such things as the leadership structure, oaths, regulations, and --

gang history.

M em bers of the M ILLAS are required to possess flrearm s. M embers of

the M ILLAS show them selves brandislling these weapons in publicly

available videos and photographs on social m edia, such as Facebook, in


order to promote the gang's violent and intimidating image. The

members of the MILLAS also use social media as a recmitmeni tool.

At a11 tim es relevant to tlais Indictm ent, the M ILLAS, in the W estern District of

Virginia and elsewhere, engaged in crim inal activity, including but not lim ited to: assault-,

robbery; attempted mlzrder; mmder; dnzg trafficking; and conspiracy to commit those crimes.I

The M ILLA m em bers comm itted crim inal acts, including acts of violence, to m aintain

m embership within the gang.

The Racketeedng Entep rise

At a11 tim es relevant to this Indictm ent, defendants DA SHAW N ROM EER

ANTHONY, DEMETRU S ALLEN STATEN, TREDAU S JANGY QUAN KEENE,

M ONTEZ LAG R ALLEN, JAVONTAY JACQUIS HOLLAND, TANASG LASHAE

COLEM AN , JERM AY SM ITH, JR., JAI,EN CO S TEM Y, and others known and

unknown, were members and associates of a crim inal organization, the M ILLAS, a set of the

5.

Bloods street gang, engaged h1, among other things, acts involving mttrder, robbely assault, and

the trafficldng of controlled substances, within the W estem District of Virginia and elsewhere.

The M ILLAS, including its leadersllip, m embership, and associates, constitm ed-an

ççenterprise,'' as defined by Title 18, United States Code, Section 196144), that is, a group of

individuals associated in fact. The enterprise constitm ed an ongoing qrganization whose

members functioned as a continuing unit for a common purpose of achieving the objectives. of

the enterprise. This enteprise was engaged in, and its activities affected, interstate and foreign

Com m efce.

4USAO 2018R00302Case 4:18-cr-00012-MFU *SEALED* Document 5 Filed 06/11/18 Page 4 of 17 Pageid#: 15

Pum oses of the Entem rise

The purposes of the enterprise included promoting and enhancing the enterprise

and its reputation through, am ong other things, com mitting acts of violence, including acts

itw olving m urder, assault, and robbery; enforcing discipline am ong the m embers; enriclzing its

m embers and associates through am ong other things, trafficldng in controlled substances and

committing acts of violence including robbery; prolonging the activities of the enterprise by

providing assistance to m em bers of the entep rise who comm itted crim es for and on behalf of the

enterprise, and by thwarting efforts of law enforcem ent to apprehend enterpdse m embers.

M anner and M eans of the Entep dse

8. Am ong the m anner and m eans by which the members and their associates

conducted and participated in the conduct of the affairs of the entep tise were the following:

a. M embers engaged in shootings and acts involving murder;

b. M embers of the enterprise and their associates robbed individuals

and businesses',

M embers of the enterprise and their associates traffcked in

flrearm s, wbich involved the straw purchase of the flrearm s in

C.

Virginia and selling them in other states;

M embers of the enterpdse and their associates obstmcted justice by

destroying and hiding evidence and freal'ms with the intent to

d.

impair their availability for use in an official proceeding;

M embers of the enterpdse and their associates distributed

controlled substances, and used the proceeds of those dnzg

e.


transactions to benelt gang members and to help finance their

enterprise.

9.

Role of the Defendants and Co-conspirators

The roles of the defendants and co-conspirators included, but were not limited to,

the following:

a. DASHAW N ROM EER ANTHON Y, a/k/a f<shon Don'' or G<stllnnay'' was

' (

a mepber of the MILLAS, and was a leader of the enteprise who directed and guided other

m embers of the enterpdse in canying out certain llnlawful and other activities in furtherance of

conducting the enteprise's affairs. His rank was a Etow'' (also called GçBig Homie'') which

placed him at the top of the racketeedng entep rise hierarchy in Danville at tim es relevant to tllis

indictment.

b. DEMETRIUS ALLEN STATEN, a/k/a tTnlck'' was EEblessed'' into the

MILLAS by ANTHONY and maiptained a leadership position in the racketeeling enterpdse.

STATEN 'S position witllin the racketeering enterprise was as a s-star, one level below

co-defendant ANTHONY.

TREDARIUS JAMERIQUAN KEENE, a/k/a f<Bubba'' or <fBubs'' was a

m ember of the M ILLA S and was, at one tim e, ranked as a s-star.

M ONTEZ LAM AR ALLEN, a/k/a Er oc'' was a m ember of the M ILLAS.

JAVONTAY JACQUIS HOLLAND a/k/a KTay'' or tcecldess'' was a

m ember of the M ILLAS and, at one time, held various leadership ranks for the racketeedng

enterprise.

f. TANA SIA LASHAE COLEM AN , a/k/a GW asia'' was a m ember of the

M ILLAS and, at one tim e, m ay have held the rank of l-star.

6USAO 2018R00302Case 4:18-cr-00012-MFU *SEALED* Document 5 Filed 06/11/18 Page 6 of 17 Pageid#: 17

g. JERM AY SM ITH, JR., a/k/a ltittle Trill'' was a member of the

M ILLAS.

h. JALEN CORM ARRTUS TERRY, a/k/a GTats'' held a leadership position

as a s-star in the M ILLAS at one tim e.

The Racketeeling Conspiracv

10. From within or about sometim e in 2015, the exact date being unknown to the

Grand Jury, and continuing through the date of tllis Indictment, in the W estem District of

Virginia and elsewhere, the defendants, DASHAW N ROM EER ANTHOW , DEM ETRIUS

ALLEN STATEN, TREDAREJS JAMEY QUM KEENE,MONTEZ LAG R ALLEN,

JAVONTAY JACQUIS HOLLAND, TANASJA LASHAE COLEMAN, JERMAY SMITH, JR.,

and JALEN CORM ARRIUS TERRY, together with each other and other persons lœ own.and

llnknown, being persons employed by and as'sociated with the M ILLAS, an entep dse wllich was

engaged sin, and the activities of which affected interstate and foreign commerce, knowingly and

intentionally did' combine,conspire, confederate and agree with each other, and with persons

known and llnknown to the Grand Jtuy to violate Title 18, United States Code, Section 1962(c),

that is, to conduct and participate, directly and indirectly, in the conduct of the affairs of the

enterprise through a pattern of racketeering activity, as that term is detined by Title 18, United

States Code, Sections 1961(1) and 1961(5), consisiing of multiple acts iiwolving:

a. M urder, chargeable tm der Virgirlia Code, Section 18.2-32, 18.2-22,

18.2-26 and 18.2-18 and the comm on 1aw of Virginia;

Robbezy chargeable under Virginia Code, Section 18.2-58, 18.2-22,

18.2-26 and 18.2-18 and the comm on 1aw of Virginia;

b.


multiple acts indictable tmder:

18 U.S.C. j 1512 (Tampering with a witness, victim, or an informantl;

multiple offenses involving:

d. Trafficldng in controlled substances in violation of 21 U.S.C. jj 841 and

846.

It was further part of the conspiracy that each defendant ap eed that a conspirator

would com mit at least two . acts of racketeering activity in the conduct of the affairs of the

enterpdse.

Overt Acts

12. In furtherance of the conspiracy and to achieve the objective thereotl the

defendants, and others known apd llnknown to the Grand Jury, perform ed and caused to be

perform ed a nllmber of overt acts in the W estern District of Virginia and elsewhere. The overt

acts pedbnned by the conspirators included, but are not lim ited to:

a. On June 15, 2016, DASHA W N ROM EER ANTHOW , DEM ETRIUS

ALLEN STATEN, TREDARIUS JAMERIQUAN KEENE, TANASIALA SHAE COLEM AN, JALEN CORM ARRIUS TERRY, and othersV own and llnknown to the Grand Jury, did shoot and attempt to mtlrderArmonti Devine W oplack and Dwight M ontel Harris at the SouthwyckApartment complex in Danville, Virginia.

b. On or about August 20, 2016, DASHAW N ROM EER ANTHONY,

DEMETRIUS ALLEN STATEN, TREDARIUS JAMERIQUAN KEENE,MONTEZ LAMAR ALLEN, JAVONTAY JAQUIS HOLLAND,TANASIA LASHA E COLEM AN, JERM AY SM ITH, JR., and otherslcnown and llnknown to the Grand Jury, mtlrdered Chdstopher Lam ontM otley in the Southwyck Apartm ent complex in Danville, Virginia anddid shoot at and attempt to murder Justion W ilson.

On June 2, 2017, M ONTEZ LAIMAR ALLEN did possess with the intentto distribute madjuana, a Schedule I controlled substance. At the time ofpossession of the marijuana he also possessed a firenrm.


d. On or between 2016 through 2018, DASHAW N ROM EER ANTHOW ,DEMETRIUS M LEN STATEN, TREDARIUS JAMERIQUAN ICEENE,JAV ON TAY HOLLAND, TANASIA LASHA E COLEM AN, M ONTEZLAM AR ALLEN, JERM AY SM ITH, JR., JALEN CO STERRY and others lm own and llnknown to the Grand Jury, trafficked in

madjuana tltroughout the Danville, Virginia region.

On or between Decem ber 2015 through August 2016, DASHAW NROM EER ANTHON Y, JERM AY 'SM ITH, JR., TREDARIUSJAMERIQUAN KEENE, and others known and llnknown to the GrandJury, were involved in a number of assaults with a deadly weaponthroughout Danville, Virginia.

NW ICE OF SPECIM Z SENTENCING FACTORS

That 'on or about August 20, 2016, in the W estem Distdct of Virginia, defendants

DASHAW N ROM EER ANTHOW , DEM ETRIUS ALLEN STATEN, TREDARIU S

JAMERIQUAN KEENE, JAVONTAY JACQUIS HOLLAND, MONTEZ LAMAR ALLEN,

TANA SIA LASHAE COLEM AN , and JERM AY SM ITH, JR., did willfully, deliberately, and

with premeditation, kill Christopher Lam ont M otley, in violation of Title 18.2, Virginia Code,

Sections 32 and 18.

14. A1l in violation of Title 18, United States Code, Sections 1962(d) and 1963.

COUNT TW OViolent Crime in Aid of Racketeering, to-wit:Attempted M urder of Annonti Devine W om ack

The Grand Jury further charges that:

15. At a11 tim es relevant to this Indictm ent, the M FLLAS,including its leaders,

members, and associates, as more fully described in paragraph 1 through 10 of Cotmt One of tllis

Indictm ent, wllich are realleged and incop orated by reference as though set forth fully herein,


constituted an enterprise as defined in Title 18, United States Code, Section 1959(b)(2), that is, a

group of individuals associated in fact that was engaged in, and the activities of wllich affected,

interstate and foreign com m erce. The enterprise constituted an ongoing organization whose

members ftmctioned as a continuing tmit for a common purpose of achieving the objectives of

the enterprise.

16.

leaders, m embers and associates, engaged in racketeering activity as defined in Title 18, United

At a11 tim es relevant to tllis Indictm ent, the above-described enterprise, tllrough its

States Code, Sections 195909(1) and 196141), that is, multiple acts involving mtlrder and

robbery in violation of Virginia law; and trafticldng in controlled substances in violation of 21

U.S.C. jj 841 and 846.

17. On or about Jtme 15, 2016, in the W estem District of Virgirlia, for the purpose of

maintaining and increasing position in the M ILLAS, an enterprise engaged in racketeering

activity, DA SHAW N ROM EER ANTHON Y, DEM ETRIUS ALLEN STATEN, TREDARIUS

JAMERIQUAN IQEENE, JALEN CORMARRIUS TERRY, and TANASIA LASHAE

COLEM AN, did attempt to mtlrder Armonti Devine W om ack in violation of Virginia Code

Sections, 18.2-32, 18.2-26, and 18.2-18.

18. A1l in violation of Title 18, United States Code, Sections 2 and 1959(a)(5).

10USAO 2018R00302Case 4:18-cr-00012-MFU *SEALED* Document 5 Filed 06/11/18 Page 10 of 17 Pageid#:

21

COUNT THREEUse of Firearm During a Violent Crime in Aid of

Racketeedng, to-wit: Attempted M lzrder of the Armonti Devine W om ack


19. On or about June 15, 2016, DASHAW N ROM EER ANTHON Y, DEM ETRIUS

M LEN STATEN, TM DARIUS JAMERIQUAN KEENE, and JALEN CORMARRJUS

TERRY, and TANASIA LASHAE COLEG N, in the W estem District of Virginia, did

knowingly use, cany brandish, and discharge a firearm dudng and in relation to a crim e of

violence for wllich they may be prosecuted in a court of the Urlited States, that is, a violation of

Title 18, United States Code, Section 1959(a)(5), as set forth in Count Two of this Indictment.

20. A11 in violation of Title 18, Urlited States Code, Sections, 2 and 924(c)(1)(A)(iii).

COIJNT FOURViolent Crim e in Aid of Racketeedng, to-wit:

Assault with a Dangerous W eapon of Atnnonti Devine W om ack


21. Paragraphs 15 and 16 of Cotmt Two are realleged and incoporated by reference

h er e m'

22. On or about Jlm e 15, 2016, in the W estem Disttict of Virginia, for the purpose of

m aintaining and increasing position in the M ILLAS, an enterpdse engaged in racketeeling

activity, DA SHAW N ROM EER ANTHONY, DEM ETRIUS ALLEN STATEN, TREDARIUS

JAMERIQUAN KEENE, JM EN CORM ARRIUS TERRY, and TANASIA LASHAE

COLEM AN , did assault Arm onti Devine W om ack with a dangerous weapon in violation of

Virgirlia Code Section, 18.2-282 and 18.2-18.1

A11 in violation of Title 18, United States Code, Sections 2 and 1959(a)(3).


22

COUNT FIVEUse of Firearm Dllring a Violent Cdme in Aid of

Racketeedng, to-wit: A ssault with a Dangerous W eapon of Arm onti Devine W omack


24. on or about june15, 2016, DASHAWN ROMEER ANTHONY, DEMETRIUS

ALLEN STATEN, TREDARIUS JAMERIQUAN KEENE, JALEN CORM ARRIUS TERRY,

and TANASIA LA SHAE COLEM AN, in the W estern District of Virginia, did u owingly use,

carry, brandish, and discharge a firealnn dudng and in relation to a crim e of violence for wlzich

lhey may be prosecuted in a court of the Urlited States, that is, a violation of Title 18, United

States Code, Seption 1959, as set forth in Count Four of this Indictm ent.

A11 in violation of Title 18, United States Code, Sections 2 and 924(c)(1)(A)(iii).

COUNT SIXViolent Cdm e in Aid of Racketeering, to-wit:Attempted M urder of Dwight M ontel Harris


26. Paragraphs 15 and 16 of Count Two of this Indictment are realleged and

incop orated by reference as though set forth fully herein.

On or about Jtme 15, 2016, in the W estem District of Virginia, for the pup ose of

m aintairling and increasing position in the M ILLAS, an entep rise engaged in racketeedng.. /

'

activity, DASHAWN ROMEER ANTHONY, DEMETRIUS ALLEN STATEN, TREDMUUS

JAMERIQUAN KEENE, JALEN CORM ARRIUS TERRY, and TANASIA LASHAE

COLEM AN, did attempt to murder Dwight M ontel Han'is in violation of Virginia Code Sections,

18.2-32, 18.2-26, and 18.2-18.

28. A11 in violation of Title 18, United States Code, Sectioris 2 and 1959(a)(5).


23

CO UNT SEVENUse of Firearm Dlzring a Violent Crime in Aid of

Racketeedng, to-wit: Attempted M urder of the Dwight M ontel Hanis


29. On or about Jtme 15, 2016, DASHAW N ROM EER ANTH ON Y', DEM ETRTUS

ALLEN STATEN, TREDAZUS JAMERIQUAN JQEENE, JM EN CORMARRRJS TERRY,

and TANA SIA LASHAE COLEM AN , in the W estern District of Virginia, did knowingly use,

cany brandish, and discharge a firearm dllring and in relation to a crim e of violence for wllich

they m ay be prosecuted in a court of the United States, that is, a violation of Title 18, United

States Code, Section 1959, as set forth in Count Six of this Indictm ent.

30. A11 in violation of Title 18, United States Code, Sections 2 and 924(c)(1)(A)(iii).

COUNT EIGH TViolent Clim e in Aid of Racketeeling, to-wit:

Assault with a Dangerous W eapon of Dwight M ontel Harris


Paragraphs 15 and 16 of Count Two of this Indictm ent are realleged and

incorporated by reference as though set forth fully herein.

On or about June 15, 2016, in the W estem Disttict of Virginia, for the pupose of

m aintaining and increasing position in the M ILLA S, an entep dse engaged in racketeering

activity, DASHAW N ROM EER ANTHOW , DEM ETRIUS M LEN STATEN , TREDARRJS

JAMERIQUAN IQEENE, JALEN CORMARRIUS TERRY, and TANASIA LASHAE

COLEM AN, did assault Dwight M ontel Hanis with a dangerous weapon in violation of Virginia

Code Section, 18.2-282 and 18.2-18.

33. A11 in violation of Title 18, United States Code, Sections 2 and 1959(a)(3).


24

COUNT M NEUse of Firearm During a Violent Cdme in Aid of

Racketeedng, to-wit: Assault with a Dangerous W eapon of Dwight M ontel Harris


34. On or about June 15, 2016, DASHAW N ROM EER ANTHON Y, DEM ETRTUS

ALLEN STATEN, TREDARTUS JAMERIQUAN KEENE, JALEN CORM ARRIUS TERRY,

and TANASIA LASHAE COFEMAN, in the Westem District of Virginia, did lcnowingly use,

cany brandish, and discharge a flreat'm duting and in relation to a cdme of violence for which

they m ay be prosecuted in a court of the Ulzited States, that is, a violation of Title 18, United

States Code, Section 1959, as set forth in Count Eight of this Indictment.

35. A11 in violation of Title 18, Uited States Code, Sections 2 and 924(c)(1)(A)(iii).

COUNT TENViolent Crim e in Aid of Racketeering, to-wit:

M urder of Chdstopher Lam ont M otley


36. Paragraphs 15 and 16 of Colmt Two of this lndictment are realleged and

incorporated by reference as though set forth fully hemin.

On or about August 20, 2016, in the W estern DisG ct of Virginia, for the pup ose

of m aintaining and increasing position in the M ILLAS, àn enterprise engaged in racketeering

acivity, DASHAW N ROM EER ANTHOW , DEM ETRIUS M LEN STATEN , TM DARIUS

JAMERJQUAN KEENE, JAVONTAY JACQUIS HOLLAND, MONTEZ LAM AR ALLEN,

TANASJA LASHAE COLEM AN , and JERM AY SM ITH, JR., did murder Chdstopher Lam ont

M otley, in violation of Virginia Code Section, 18.2-32 and 18.2-18.

38. A11 in violation of Title 18, United States Code, Sections 2 and 1959(a)(1).


25

COUNT ELEVENUse of Firearm Duri. ng a Violent Crim e in Aid of

Racketeeting, to-wit: M lzrder of Chdstopher Lam ont M otley


39. On or about August 20, 2016, DASHAW N ROM EER ANTHON Y,

DEMETRX S ALLEN STATEN, TREDAU S JAMEM QUAN KEENE, JAVONTAY

JACQUIS HOLLAND, MONTEZ LAMAR ALLEN, TANASG LASHAE COLEMAN, and

JERM AY SM ITH, JR., in the W estem District of Virgirlia, did knowingly use, cany brandish

and discharge a tirearm duting and in relation to a crime of violence for which they may be

prosecuted in a court of the United States, that is, a violation of Title 18, United States Code,

Section 1959, as set forth in Cotmt Ten of this Indictm ent, and in the course of a violation of

Title 18, United States Code, Section 924(c), caused the death of a person tluough the use of a

firearm, which ldlling is murder as desned in Title 18, United States Code, Section 1 1 1 1(a).

40. A1l in violation of Title 18, Urlited States Code, Sections 2 and 924().

COUNT TM V LVEViolent Crim e in Aid of Racketeering, to-wit:

Attempted M lzrder of Justion W ilson

The Grand Jury farther charges that:

41. Paracaphs 15 and 16 of Colmt Two of tllis Indictment are realleged and

incorporated by reference as though set forth fully herein.

42. On or about August 20, 2016, in the W estem District of Virginia, for the pup ose

of maintaining and increasing position in the M ILLAS, an enterpdse engaged in racketeedng

activity, DASHAW N ROM EER ANTHOW , DEM ETRIU S ALLEN STATEN, TREDAIUUS

JAMERIQUAN IQEENE, JAVONTAY JACQUIS HOLLAND, MONTEZ LAMAR ALLEN,


26

TANASIA LASHAE COLEM AN, and JERM AY SMITH, JR., did attempt to murder Justion

W ilson in violation of Virginia Code Sections, 18.2-32, 18.2-26, and 18.2-18.

A11 in violation of Title 18, Urkited States Code, Sections 2 and 1959(a)(5).

COUNT THIRTEENUse of Firearm Dlzting a Violent Crime in Aid of

Racketeeting, to-wit: Attempted M urder of the Justion W ilsont


44. On or about August 20, 2016, DASHAW N ROM EER AN THOW ,

DEMETRIUS ALLEN STATEN, TREDARIUS JAMERIQUAN KEENE, MONTEZ LAMAR

M LEN, JAVONTAY JACQUIS HOLLAND, TANASIA LASHAE COLEM AN, and JERM Y

SM ITH, JR., in the W estem Distdct of Virginia,did lœ owipgly use, cany brandish, and

of violence for which they m ay bedischarge a flrearm dllring and in relation to a crim e


Section 1959, as set forth in Colmt Twelve of this Indictm ent.

A11 in violation of Title 18, United States Code, Sections 2 and 924(c)(1)(A)(iii).

COUNT FOURTEENViolent Cdme in Aid of Râcketeedng, to-wit:

A ssault with a DangerousW eapon of Justion W ilson


46. Paragraphs 15 and 16 of Count Two of tllis Indictm ent are realleged and

incop orated by reference as though set forth ftzlly herein. On or about August 20, 2016, i.n the

W estem Dishict of Virglm' 'a for the purpose of m aintaining and increasing position in the

M 1I,LAs, an enterpdse engaged in racketeeting activity, DASHAW N ROM EER ANTHON Y,

DEMETU S ALLEN STATEN, TREDAM US JAMEY QUAN KEENE, JAVONTAY


JACQUIS HOLLAND, MONTEZ LAMAR ALLEN, TANASG LASHM COLEMAN, and

JERM AY SM ITH, JR., did. assault Justion W ilson with a dangerous weapon in violation of

Virginia Code Section, 18.2-282 and 18.2-18.

47. Al1 i.n violation of Title 18, United States Code, Sections 2 and 1959(a)(3).

COUNT FIFTEENUse of Firenrm Dudng a V'iolent Crime in Aid of

Racketeedng, to-wit: Assault of Justion W ilson with a Dangerous W eapon


48. On or about August 20, 2016, DASHAW N ROG ER ANTHONY,

DEMETRIUS M LEN STATEN, MONTEZ LAMAR ALLEN, TREDARIUS JAMERIQUAN

KEENE, JAVONTMW JACQUiS HOLLAND, TANASG LASHAE COLENLYN rd

JERM AY SMITH, .IR., in the W estem District of Virginia, did knowingly use, cany, brandish,

and discharge a firenrm during and in relation toa crime of violence for which they may be


l

Section 1959, as set forth in Count Fourteen of this Indictment.

49. All in violation of Title 18, United States Code, Sedions 2 and 924(c)(1)(A)(iii).

A TRUE BILL tllis 11 day of Jlme, 2018.

/s/ FOREPERSONFOM PERSON

> T.THONL:S L CULLENLZWTED STATES ATTORNEY


28

Date post:	03-Feb-2022
Category:	Documents
Upload:	others
View:	4 times
Download:	0 times

criminal xumber:#.' IC-c(-oOe /1

Documents