Indictment — United States v. Jones (Dkt. 1, N.D. Miss.)

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An indictment filed April 24, 2019 as Doc #: 1 in Case 3:19-cr-00065-DMB-RP in the U.S. District Court for the Northern District of Mississippi against Donald Jones, Wilton Johnson, Jeremy Smith, Carl McMillian, James Vaughn, Justin Hannah and Joe Johnson. It alleges that the defendants were members and associates of the Simon City Royals, which it describes as a criminal organization engaged in narcotics distribution, firearms trafficking and acts of violence, and an enterprise under Title 18, United States Code, Section 1959(b)(2). The counts charge violent crimes in aid of racketeering under 18 U.S.C. § 1959(a)(3) and 18 U.S.C. §2, including assault resulting in serious bodily injury under Mississippi law.

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Case: 3:19-cr-00065-DMB-RP Doc #: 1 Filed: 04/24/19 1 of 10 PagelD "FILED

                                                                  APR 2 4 2019

                IN THE UNITED STATES DISTRICT COURT             DAVIPS RES. LER
              FOR THE NORTHERN DISTRICT OF MISSISSIPPI                     Deputy

 UNITED STATES OF AMERICA,

            Plaintiff,                         Criminal No. 3:14 CR US

 vs.
                                               18 U.S.C. §2
 DONALD JONES                                  18 U.S.C. § 1959(a)(3)
      a/k/a WORM,
 WILTON JOHNSON
      a/k/a BIG BOI,
 JEREMY SMITH
      a/k/a LIL ONE,
 CARL MCMILLIAN,
 JAMES VAUGHN
      a/k/a SIR FLUTE,
 JUSTIN HANNAH, and
 JOE JOHNSON,

            Defendants.

                              INDICTMENT

THE GRAND JURY CHARGES:

                        GENERAL ALLEGATIONS

      le   Atall times relevant to this Superseding Indictment, the defendants, DONALD

JONES, WILTON JOHNSON, JEREMY SMITH, CARL MCMILLIAN, JAMES

VAUGHN, JUSTIN HANNAH, JOE JOHNSON, and others known and unknown to the

Grand Jury, were members and associates of the Simon City Royals, a criminal organization

engaged in narcotics distribution, firearms trafficking, and acts of violence involving murder,

attempted murder, and assault. At all relevant times, the Simon City Royals operated in the

Northern District of Mississippi and elsewhere.

Case: 3:19-cr-00065-DMB-RP Doc #: 1 Filed: 04/24/19 2 of 10 PagelD #: 2

The Racketeering Enterprise

2. The Simon City Royals, including its leaders, members, and associates,
constituted an “enterprise,” as defined in Title 18, United States Code, Section 1959(b)(2)
(hereinafter “the enterprise”), that is, a group of individuals associated in fact that engaged
in, and the activities of which affected, interstate and foreign commerce. The enterprise
constituted an ongoing organization whose members and associates, including its prospective
members (“prospects”), functioned as a continuing unit for a common purpose of achieving
the objectives of the enterprise.

Structure and Operation of the Enterprise

3. The Simon City Royals was a violent criminal gang which began in the
Chicago, Illinois area in the late 1950’s. The Simon City Royals were members of the “Folk
Nation Alliance”, also known as the “Brothers of the Struggle” that consisted of other violent
criminal gangs to include the Gangster Disciples. Since that time, the Simon City Royals
spread throughout the United States, including the entire State of Mississippi, where they are
the third largest gang in the state.

4. Between 2010 and 2012 the primary “sect” of the Simon City Royals began
identifying as “Chapter XIII.” While the other sects of Simon City Royals still exist in
Mississippi, “Chapter XIII” was the strongest faction with the largest representation both
inside and outside of prison.

5. Like the Gangster Disciples, the Simon City Royals are composed of both male
and female members. Male members often referred to themselves as “Sir” or “Royal Knights”
while female members referred to themselves as “Royal Ladies.” While both sexes are

represented in membership, only male members of the gang were allowed to hold leadership

Case: 3:19-cr-O0065-DMB-RP Doc #: 1 Filed: 04/24/19 3 of 10 PagelD #: 3

roles. Upon joining the Simon City Royals, a member was given a 6-digit number that usually
begins with the number 13 and a “Sir Name.” These identifiers were used to track
membership, standing, and protect your real identity from law enforcement. In addition, each
member received a birth certificate.

6. The Simon City Royals employed a highly structured organization that
bestowed upon its members certain titles indicative of the member’s role or function within
the gang. The Simon City Royals use custom terminology to describe things like meetings,
subgroups and members. While some terminology is used both inside and outside of prison,
other terms only used for one or the other. For example, for those not in prison, the State is
subdivided into the Northern Commission and the Southern Commission, with a
“Commissioner” overseeing each. These commissions are then subdivided into regions,
typically made up of 2-6 counties, with an “Ambassador” overseeing these regions. For those
members who are incarcerated, the division and leadership is typically subdivided at the
facility level with the head of a correctional facility for the SCRs being the “Ambassador.”

7. The Simon City Royals have a detailed and uniform organizational structure,
which is outlined - along with various rules, procedures, and code of conduct - in a written
“constitution” widely distributed to members throughout Mississippi and elsewhere.

8. The title “Crown Prince” was reserved for the leader of the Simon City Royals.
In addition to the rank of “Crown Prince”, the Simon City Royals have or used a corporate
board style group that collectively made decisions at the State level for the gang, referred to
as “Made Men.” The “Crown Prince” and “Made Men” were the governing body over
activities both inside and outside of the prison system, with the command structure divided

between incarcerated members (Prison) and non-incarcerated (“Free World”) below them.

Case: 3:19-cr-O0065-DMB-RP Doc #: 1 Filed: 04/24/19 4 of 10 PagelD #: 4

The Simon City Royals organization in the “Free World” was primarily overseen by the
“Governor” who is a “Made Man.” The “State Board” was made up of members of varying
ranks who oversee specific “Departments” that relate to the functioning of the gang:
“Administration Department”, “Department of Defense”, “Department of Education”,
“Department of Business and Revenue”, “Prospect Department” “Special Operations
Department” and “Events Department”. These “Departments” also appeared to exist in
lower subdivisions of the gang under the “Commissioners” and “Ambassadors” where
members and the gang leaders determine their need to exist. A number of factors determined
a member's rank including, the amount of time an individual has been in the gang and the
amount of "work," or criminal activity a person commits on behalf of the gang.

9. The “Department of Defense” acted as the “enforcement” branch of the gang.
Historically members of this “Department” have been responsible for carrying out acts of
violence against both members and others outside of the organization.

10. The Simon City Royals organization within the State of Mississippi
correctional facilities was primarily overseen by four members of the organization.
Correctional facilities are considered “plugged in” when there are enough members of the
“Folk Nation”, primarily Simon City Royals and Gangster Disciples, to form a hierarchy
within the facility. Once a facility was “plugged in” a “Facility Board” was formed that
consists (at a minimum) of Gangster Disciples: “21.3”, “1.21.3”, “IC”, “ISC” and Simon City
Royals: “Ambassador” and “Ambassador Apprentice.” While this board was supposed to
act autonomously for the facility, actions were often taken at the direction of ranking officers

of both the Simon City Royals and the Gangster Disciples. Members were required to submit

Case: 3:19-cr-00065-DMB-RP Doc #: 1 Filed: 04/24/19 5 of 10 PagelD #: 5

reports daily to the board over each facility that tracks money earned, disciplinary actions,
and any violence/security threats that occur.

11. In addition to the direct chain of command incarcerated Simon City Royals
were subdivided into additional “Teams” in order to further their criminal enterprises. These
“Teams” had their own rank structure that appears to lack consistency from one to another.
These “Teams” consisted of “Intel”, “Money”, “Tech”, and “SOD”. The “Money Team”
and its members were responsible for collecting debts and managing the money of the
organization and its members. The “Money Team” managed this money through a system
of electronic ledgers, daily and weekly reporting. The “Tech Team” and its members were
responsible for earning money through fraud, extortion, identity theft and other schemes. The
“Tech Team” was also involved in dealing with bitcoin and the “Deep Web.”

12. Inside and outside the prison system, the Simon City Royals hold regular
meetings to coordinate their efforts, and to discuss gang business. During these meetings,
members discussed gang rivalries, criminal activity, and collected dues money from members.
The enterprise made its money primarily through the sale and distribution of controlled
substances, including methamphetamine, cocaine, marijuana, and various prescription pills,
the illegal sale of firearms, and the commission of robberies. The Simon City Royals provided
these narcotics to members that are incarcerated who distributed the narcotics inside the penal
facility. Enterprise members also utilized various social networking internet sites, including
Facebook, to sell and distribute controlled substances and firearms. The money goes to a
Treasurer or another higher-ranking member who have the discretion to spend the collected

money how the gang chooses. At times, the Treasurer or other ranking member uses the pot

Case: 3:19-cr-O0065-DMB-RP Doc #: 1 Filed: 04/24/19 6 of 10 PagelD #: 6

of money to purchase additional drugs, firearms, or put the money on the "books" of
incarcerated members.

13. The Simon City Royals indicated their affiliation with the gang by displaying
hand gestures (gang signs), obtaining tattoos, and wearing leather vests (“cuts”). Members
also proclaimed their affiliation by posting photographs, videos, and messages on various
social networking internet sites, including Facebook. The Simon City Royals have their own
language that members use to communicate with each other. For example, a “bag and tag”
order is an order to physically harm someone.

14. The Simon City Royals have an ongoing rivalry with the Vice Lords and other
People Nation gangs. The Simon City Royals are encouraged by their leadership to exact
violence against rival gang members.

15. |The Simon City Royals are involved in numerous crimes including, but not
limited to multiple acts involving murder and attempted , assaults, robberies, identity fraud,
mail and wire fraud, and the unlawful possession and trafficking of firearms and narcotics.
The Simon City Royals use violence as a means of retribution for acts done by rival gang
members, to intimidate witnesses, and a way for individual gang members to maintain or
advance their position within the gang. Members who disobey orders or rules or who are
deemed to have acted contrary to the best interest of the gang are punished. The punishment,
referred to as a "violation," consists of a beating and possible removal of the member from the
gang.

Purposes of the Enterprise

16. The purposes of the enterprise included, but were not limited to, the following:

Case: 3:19-cr-00065-DMB-RP Doc #: 1 Filed: 04/24/19 7 of 10 PagelD #: 7

a. Enriching the leaders, members, and associates of the enterprise through
among other things, the illegal trafficking of controlled substances and firearms.

b. Preserving and protecting the power, territory, operations, and proceeds
of the enterprise through the use of threats, intimidation, violence, and destruction, including,
but not limited to, acts of murder, attempted murder, assault with a dangerous weapon,
obstruction of justice, and other acts of violence.

c. Promoting and enhancing the enterprise and its members’ and
associates’ activities,

d. Keeping victims in fear of the enterprise and in fear of its leaders,
members, and associates through threats of violence and actual violence. The leaders,
members, and associates of the enterprise undertook all steps necessary to prevent the
detection of their criminal activities and sought to prevent and resolve the imposition of any
criminal liabilities upon their leaders, members, and associates, by the use of murder,
violence, and intimidation directed against witnesses, victims, and others.

e. Providing support to gang members who were charged with or
incarcerated for gang-related activities.

f. Preserving and protecting the financial proceeds of the enterprise by
money laundering funds through prepaid bank, debit and credit cards.

Means and Methods of the Enterprise
17. | The means and methods by which the members and associates conducted and
participated in the affairs of the Simon City Royals criminal enterprise included the following:

a. The members and associates of the enterprise attended regular meetings

where criminal activity was discussed, financial proceeds from criminal activity were

Case: 3:19-cr-00065-DMB-RP Doc #: 1 Filed: 04/24/19 8 of 10 PagelD #: 8

collected including, but not limited to, collection of drug proceeds from subordinate gang
members for senior Simon City Royals gang leaders, and disciplinary beatings of fellow
Simon City Royals gang members were administered.

b. To enforce discipline and the rules of the enterprise, members and
associates of the enterprise engaged in a system of “violations,” in which the defendants and
others committed murder, attempted murder, conspired to murder, physically assaulted, and
threatened those members and associates of the enterprise who violated rules, questioned
authority, or posed a threat to the leaders, members, or purposes of the enterprise.

c. To generate income, Simon City Royals gang members engaged in
illegal activities under the protection of the enterprise, including narcotics trafficking and
other illegal activities.

d. For protection, attacks, and armed combat, Simon City Royals gang
members acquired, carried and used firearms and metal objects, like prison shanks.

e. Members and associates of the enterprise employed and used gang-
related terminology, symbols, phrases, and gestures to demonstrate affiliation with the gang.

f. To perpetuate the enterprise and to maintain and extend their power,
members and associates of the enterprise committed and conspired to commit acts including
murder, attempted murder, intimidation, and assault against individuals who posed a threat
to the enterprise or jeopardized its operations, including rival gang members, Simon City
Royals gang members, and witnesses to illegal activities of the enterprise.

g. Members and associates of the enterprise hid, misrepresented,

concealed, and caused to be hidden, misrepresented, and concealed, the objectives of acts

Case: 3:19-cr-O0065-DMB-RP Doc #: 1 Filed: 04/24/19 9 of 10 PagelD #: 9

done in furtherance of the “enterprise,” and used coded language and other means of
communication to avoid detection and apprehension by law enforcement authorities.

h. To keep secret the activities of the enterprise, participants
communicated using codes and hidden messages, and used a _ network of
members/prospects/associates outside of prison to relay messages to incarcerated members
and associates. Members also used encrypted peer-to-peer messaging applications on mobile
devices that can be remotely deleted.

18. |The above-described enterprise, through its members, prospects and associates,
engaged in racketeering activity as defined in Sections 1959(b) (1) and 1961 (1), of Title 18,
United States Code, that is, multiple acts involving aggravated assault, in violation of
Mississippi Code Annotated, Section 97-3-7, murder and attempted murder in violation of
Mississippi Code Annotated, Section 97-3-19, and multiple acts involving narcotics
trafficking, in violation of Sections 841(a)(1) (distribution and possession with the intent to
distribute a controlled substance) and 846 (conspiracy to distribute and possession with the

intent to distribute a controlled substance) of Title 21, United States Code.

COUNT ONE
The Grand Jury further charges:
19. The allegations contained in paragraphs one through eighteen are realleged and
incorporated as if fully set forth herein.
20. On or around May 15, 2018, in the Northern District of Mississippi and
elsewhere, for the purposes of maintaining and increasing position in the Simon City Royals,
an enterprise engaged in racketeering activity, the defendants, WILTON JOHNSON,

DONALD JONES, and others known and unknown to the Grand Jury, aiding and abetting

Case: 3:19-cr-O0065-DMB-RP Doc #: 1 Filed: 04/24/19 10 of 10 PagelD #: 10

each other, did knowingly assault C.B. with a dangerous weapon, which resulted in serious
bodily injury, in violation of Mississippi Code Annotated, Section 97-3-7, and all in violation
of 18 U.S.C. §§ 1959(a)(3) and 2.

COUNT TWO

The Grand Jury further charges:

21. The allegations contained in paragraphs one through eighteen are realleged and
incorporated as if fully set forth herein.

22. On or around May 15, 2018, in the Northern District of Mississippi and
elsewhere, for the purposes of maintaining and increasing position in the Simon City Royals,
an enterprise engaged in racketeering activity, the defendants, JEREMY SMITH, CARL
MCMILLIAN, JAMES VAUGHN, JUSTIN HANNAH, JOE JOHNSON, and others
known and unknown to the Grand Jury, aiding and abetting each other, did knowingly assault
D.R. with a dangerous weapon, which resulted in serious bodily injury, in violation of

Mississippi Code Annotated, Section 97-3-7, and all in violation of 18 U.S.C. §§ 1959(a)(3)

and 2.

A TRUE BILL
q anu /s/ Signature Redacted
WILLIAM C. LAMAR FOREPERSON

UNITED STATES ATTORNEY

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