Indictment — No. 2:24-cr-20514 (Dkt. 1, E.D. Mich.)

Summary

The indictment filed September 18, 2024 in United States v. Orlando Maddox, Issac Thomas, Andre Maddox, Ralph Thomas and Angela Lewis, Case 2:24-cr-20514, in the U.S. District Court for the Eastern District of Michigan. Count One charges Orlando Maddox, Issac Thomas, Andre Maddox and Ralph Thomas with conspiracy to distribute and possess with intent to distribute a controlled substance under 21 U.S.C. §§ 846 & 841(a)(1), from in or around February 2023 through in or around May 2024. The indictment also cites 18 U.S.C. § 924(c) and money laundering conspiracy under 18 U.S.C. § 1956(h).

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Case 2:24-cr-20514-NGE-DRG ECF No.1, PagelD.1 Filed 09/18/24 Page 1 of 13 2

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Case: 2:24~cr-20514

Assigned To : Edmunds, Nancy G.
Referral Judge: Grand, David R.
Assign. Date : 9/18/2024

Vv. Description: IND USA V ORLANDO MADDOX ET AL (SS)
D-1 ORLANDO MADDOX, Violations:
D-2 ISSAC THOMAS, 21 U.S.C. § 846
D-3 ANDRE MADDOX, 21 U.S.C. § 841(a)(1)
D-4 RALPH THOMAS, and 18 U.S.C. § 924(c)
D-5 ANGELA LEWIS, 18 U.S.C. § 1956(h)
Defendants.
/
Indictment

The Grand Jury charges that:

Count One
Conspiracy to Distribute and Possess with Intent to Distribute a

Controlled Substance
21 U.S.C. §§ 846 & 841(a)(1)

D-1 ORLANDO MADDOX
D-2 ISSAC THOMAS

D-3 ANDRE MADDOX
D-4 RALPH THOMAS

From in or around February 2023, through in or around May
2024, in the Eastern District of Michigan, and elsewhere, the
defendants, ORLANDO MADDOX, ISSAC THOMAS, ANDRE

MADDOX, and RALPH THOMAS, knowingly and intentionally

Case 2:24-cr-20514-NGE-DRG ECF No.1, PagelD.2 Filed 09/18/24 Page 2 of 13

combined, conspired, confederated, and agreed with each other and with
persons known and unknown to the Grand Jury, to distribute and
possess with intent to distribute a controlled substance, in violation of
Title 21, United States Code, Sections 846 and 841(a)(1).

With respect to the defendant, ORLANDO MADDOX, the
controlled substances involved in the conspiracy attributable to him as
a result of his own conduct, and the conduct of other conspirators
reasonably foreseeable to him, are 400 grams or more of a mixture and
substance containing a detectable amount of fentanyl (N-phenyl-N-[1-
(2-phenylethy] )-4-piperidinyl] propanamide), in violation of Title 21,
United States Code, Section 841(b)(1)(A)(vi), 500 grams or more of a
mixture or substance containing a detectable amount of cocaine, in
violation of Title 21, United States Code, Section 841(b)(1)(B)GDdD, and
100 grams or more of heroin, in violation of Title 21, United States
Code, Section 841(b)(1)(B)(i).

With respect to the defendant, ISSAC THOMAS, the controlled
substance involved in the conspiracy attributable to him as a result of
his own conduct, and the conduct of other conspirators reasonably

foreseeable to him, is 400 grams or more of a mixture and substance

2

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.3 Filed 09/18/24 Page 3 of 13

containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-
phenylethyl )-4-piperidinyl] propanamide), in violation of Title 21,
United States Code, Section 841(b)(1)(A)(vi).

With respect to the defendant, ANDRE MADDOX, the controlled
substance involved in the conspiracy attributable to him as a result of
his own conduct, and the conduct of other conspirators reasonably
foreseeable to him, is 400 grams or more of a mixture and substance
containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-
phenylethyl )-4-piperidinyl] propanamide), in violation of Title 21,
United States Code, Section 841(b)(1)(A)(vi), and 100 grams or more of
heroin, in violation of Title 21, United States Code, Section
841(b)(1)(B)(i).

With respect to the defendant, RALPH THOMAS, the controlled
substances involved in the conspiracy attributable to him as a result of
his own conduct, and the conduct of other conspirators reasonably
foreseeable to him, are 40 grams or more of a mixture and substance
containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-
phenylethy] )-4-piperidinyl] propanamide), in violation of Title 21,

United States Code, Section 841(b)(1)(B)(vi), 500 grams or more of a

3

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.4 Filed 09/18/24 Page 4 of 13

mixture or substance containing a detectable amount of cocaine, in
violation of Title 21, United States Code, Section 841(b)(1)(B)Gi)dD, and
100 grams or more of heroin, in violation of Title 21, United States
Code, Section 841(b)(1)(B)Q).

Count Two

Possession of Fentanyl] with Intent to Distribute
21 U.S.C. § 841(a)(1)

D-1 ORLANDO MADDOX
D-2 ISSAC THOMAS
D-3 ANDRE MADDOX

On or about May 10, 2024, in the Eastern District of Michigan, the
defendants, ORLANDO MADDOX, ISSAC THOMAS, and ANDRE
MADDOX, knowingly and intentionally possessed with intent to
distribute a controlled substance, in violation of Title 21, United States
Code, Section 841(a)(1).

It is further alleged that the controlled substance involved was
400 grams or more of a mixture and substance containing a detectable
amount of fentanyl (N-pheny]-N-[1-(2-phenylethy]l )-4-piperidiny]]

propanamide), in violation of Title 21, United States Code, Section

841(b)(1)(A)(vi).

Case 2:24-cr-20514-NGE-DRG ECF No.1, PagelD.5 Filed 09/18/24 Page 5 of 13

Count Three
Possession of a Firearm in Furtherance of a Drug-Trafficking
Crime

18 U.S.C. § 924(c)(1)(A)

D-1 ORLANDO MADDOX
On or about May 10, 2024, in the Eastern District of Michigan, the
defendant, ORLANDO MADDOX, knowingly possessed a firearm, that
is, a Smith and Wesson 5.7x28 handgun, SN: PJJ896; a Smith &
Wesson 1911 .45 caliber pistol, SN: UCW5975; and a Glock 19 9mm
caliber pistol, SN: ZDA457, in furtherance of a drug-trafficking crime
for which he may be prosecuted in a court of the United States, that is,
conspiracy to possess with intent to distribute a controlled substance, as
charged in Count One of this Indictment; all in violation of Title 18,
United States Code, Section 924(c)(1)(A).
Count Four
Possession of a Firearm in Furtherance of a Drug-Trafficking

Crime

18 U.S.C. § 924(c)(1)(A)

D-3 ANDRE MADDOX
On or about May 10, 2024, in the Eastern District of Michigan, the
defendant, ANDRE MADDOX, knowingly possessed a firearm, that is, a

Taurus 45/410 The Judge Ultra-Lite .45LC/.410SS Revolver, SN:

5

Case 2:24-cr-20514-NGE-DRG ECF No.1, PagelD.6 Filed 09/18/24 Page 6 of 13

C0756220, in furtherance of a drug-trafficking crime for which he may
be prosecuted in a court of the United States, that is, conspiracy to
possess with intent to distribute a controlled substance, as charged in
Count One of this Indictment; all in violation of Title 18, United States
Code, Section 924(c)(1)(A).

Count Five
Possession of a Firearm by a Convicted Felon
18 U.S.C. § 922(g)(1)

D-1 ORLANDO MADDOX

On or about May 10, 2024, in the Eastern District of Michigan, the
defendant, ORLANDO MADDOX, knowing that he had been convicted
of a crime punishable by imprisonment for a term exceeding one year,
knowingly possessed, in and affecting interstate and foreign commerce,
a firearm, that is, a Smith and Wesson 5.7x28 handgun, SN: PJJ896; a
Smith & Wesson 1911 .45 caliber pistol, SN: UCW5975; a Glock 19
9mm caliber pistol, SN: ZDA457; a BC Defense SQS .556 caliber AR-15
style rifle, SN: BC104137; and a Western Field XNH-565-C 12-gauge
shotgun, no visible serial number, in violation of Title 18, United States

Code, Section 922(g)(1).

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.7 Filed 09/18/24 Page 7 of 13

Count Six
Possession of a Firearm by a Convicted Felon
18 U.S.C. § 922(g)(1)

D-3 ANDRE MADDOX

On or about May 10, 2024, in the Eastern District of Michigan, the
defendant, ANDRE MADDOX, knowing that he had been convicted of a
crime punishable by imprisonment for a term exceeding one year,
knowingly possessed, in and affecting interstate and foreign commerce,
a firearm, that is, a Taurus 45/410 The Judge Ultra-Lite .45LC/.410SS
Revolver, SN: C0756220, in violation of Title 18, United States Code,

Section 922(g)(1).

Count Seven
Conspiracy to Launder Monetary Instruments
18 U.S.C. § 1956(h) & 1956(a)(1)(B)(i)

D-1 ORLANDO MADDOX
D-5 ANGELA LEWIS

From in or around March 2028, through February 2024, in the
Eastern District of Michigan, and elsewhere, the defendants,
ORLANDO MADDOX and ANGELA LEWIS, did knowingly,

conduct and attempt to conduct financial transactions affecting

interstate commerce and foreign commerce, which transactions involved

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.8 Filed 09/18/24 Page 8 of 13

the proceeds of specified unlawful activity, that is, conspiracy to
distribute controlled substances, knowing that the transactions were
designed in whole or in part to conceal and disguise the nature,
location, source, ownership, and control of the proceeds of specified
unlawful activity, and knowing, while conducting and attempting to
conduct such financial transactions, that the property involved in the
financial transactions represented the proceeds of some form of
unlawful activity, in violation of Title 18, United States Code, Section
1956(a)(1)(B)G).

Forfeiture Allegations

21 U.S.C. § 853; 18 U.S.C. § 924(d)
with 28 U.S.C. § 2461; and 18 U.S.C. § 982(a)(1)

The allegations contained in Counts One through Seven of this
Indictment are hereby realleged and incorporated by reference for the
purpose of alleging forfeiture pursuant to Title 21, United States Code,
Section 853(a), Title 18, United States Code, Section 924(d) together
with Title 28, United States Code, Section 2461, and Title 18, United
States Code, Sections 982(a)(1).

Upon conviction of a controlled substance violation of Title 21,

United States Code, Sections 841 and/or 846, as alleged in Counts One

8

Case 2:24-cr-20514-NGE-DRG ECF No.1, PagelD.9 Filed 09/18/24 Page 9 of 13

and Two of this Indictment, the defendant(s) shall forfeit to the United

States, pursuant to 21 United States Code, Section 853(a): (1) any

property, real or personal, constituting or derived from any proceeds

obtained, directly or indirectly, as a result of such violations; and (2)

any property, real or personal, used, or intended to be used, in any

manner or part, to commit, or to facilitate the commission of such

violation. The property to be forfeited includes, but is not limited to, the

following:

22612 Cherry Hill St., Dearborn, Michigan 48124, Wayne County:

One (1) AR style rifle (BC Defense SQS .556 caliber rifle, SN:
BCI04137)

One (1) Smith & Wesson 1911 .45 caliber pistol, SN:
UCW5975

One (1) Glock 19 9mm caliber, SN: ZDA457

One (1) Shotgun (Western Field XNH-565-C 12-gauge
shotgun, no visible serial number)

Three (3) Luxury watches (Franck Muller Conquistador
Watch, 8005KSC; Rolex watch, no visible serial number;
Audemars Piguet watch, SN: £96854

$2,304.00 USC seized from O. Maddox

22036 Kessler St., Detroit, Michigan 48219, Wayne County:

One (1) Pistol (Taurus 45/410 The Judge Ultra-Lite
.A45LC/.410SS Revolver, SN: C0756220)

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.10 Filed 09/18/24 Page 10 of 13

7700 Dacosta St., Detroit, Michigan 48239, Wayne County:

e $9,000 US currency
e One (1) Ruger American Pistol, SN: 861-58929
One (1) Beretta 92A1 9mm pistol, SN: K80463Z

Upon conviction of the firearm offenses charged in Counts Three,
Four, Five, or Six of this Indictment, in violation of Title 18, United
States Code, Section 924(c) or Section 922, defendants shall forfeit to
the United States any firearm and ammunition involved in said offense,
pursuant to Title 18, United States Code, Section 924(d)(1) together
with Title 28, United States Code, Section 2461, including but not
limited to:

22612 Cherry Hill St., Dearborn, Michigan 48124, Wayne County:

e One (1) AR style rifle (BC Defense SQS .556 caliber rile, SN:
BCI04137)

e One (1) Smith & Wesson 1911 .45 caliber pistol, SN:
UCW5975

e One (1) Glock 19 9mm caliber, SN: ZDA457

e One (1) Shotgun (Western Field XNH-565-C 12-gauge
shotgun, no visible serial number)

22036 Kessler St., Detroit, Michigan 48219, Wayne County:

e One (1) Pistol (Taurus 45/410 The Judge Ultra-Lite
A5LC/.410SS Revolver, SN: C0756220)

7700 Dacosta St., Detroit, Michigan 48239, Wayne County:

e One (1) Ruger American Pistol, SN: 861-58929
e One (1) Beretta 92A1 9mm pistol, SN: K80463Z

10

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.11 Filed 09/18/24 Page 11 of 13

Upon conviction of the money laundering offense charged in Count
Seven, in violation of Title 18, United States Code, Section 1956(h) and
1956(a)(1)(B)G), the defendants, ORLANDO MADDOX and ANGELA
LEWIS, shall forfeit to the United States any property, real or personal,
involved in such offense, and any property traceable to such property,
pursuant to Title 18, United States Code, Section 982(a)(1).

Forfeiture Money Judgment: Such property also includes, but is

not limited to, a forfeiture money judgment against the defendants in
an amount to be determined, representing the total value of all property
subject to forfeiture, as described herein.

Substitute Assets: If any of the property described above, as a

result of any act or omission of the defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third
party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be

divided without difficulty,

1]

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.12 Filed 09/18/24 Page 12 of 13

the United States of America shall be entitled to forfeiture of substitute
property under Title 21, United States Code, Section 853(p).
This is a True Bill.

/s/ Grand Jury Foreperson
Grand Jury Foreperson

DAWN N. ISON
United States Attorney

/s/ Benjamin Coats

Benjamin Coats
Chief, Drug Task Force Unit

/s/ Jason Dorval Norwood
Jason Dorval Norwood
Assistant United States Attorney

Dated: September 18, 2024

12

Case 2:24-cr-20514-NGE-DRG ECF No. 1, PagelD.13 Filed 09/18/24 Page 13 of 13

Case: 2:24-cr-20514

- Assigned To : Edmunds, Nancy G. 7
Criminal Case Cov _ Referral Judge: Grand, David R.

Assign. Date : 9/18/2024
Description: IND USA V ORLANDO MADDOX ET AL (SS)
NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to comprete nu aveuraery ni an reupew:

United States District Court
Eastern District of Michigan

PSs Riot Ona eee ; Companion Case Number:
This may be a companion case based upon LCrR 57.10 (b)(4)!: Judge Assigned: A
LlYes No AUSA’sInitias: LAY |
Y
Case Title: USA v. Orlando Maddox et al /

County where offense occurred : Wayne

Check One: [X]Felony L]Misdemeanor L]Petty
v [ndictment/ Information --- no prior complaint.
Indictment/ Information --- based upon prior complaint [Case number: ]
Indictment/ Information --- based upon LCrR 57.10 (d) [Complete Superseding section below].
Superseding-Gaseilnformation

Superseding to Case No: Judge:

[_]Corrects errors; no additional charges or defendants.
[_]!nvolves, for plea purposes, different charges or adds counts.
[_]Embraces same subject matter but adds the additional defendants or charges below:

Defendant name Charges Prior Complaint (if applicable)

Please take notice that the below listed Assistant United Stages Attorney is the attorney of record for
the above captioned case. a

September 18, 2024
Date

Jason Norwood
Assistant United States Attorney

211 W: Fort Street, Suite 2001

Detroit, MI 48226-3277

Phone: 313-226-99587

Fax: 313-226-9100

E-Mail address: Jason.Norwood@usdoj.gov
Attorney Bar #: OHO096306

1 Companion cases are matters in which it appears that (1) substantially similar evidence will be offered at trial, or (2) the same
or related parties are present, and the cases arise out of the same transaction or occurrence. Cases may be companion cases
even though one of them may have already been terminated.

G/1¢

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