Indictment — United States v. Claire Patricia Haviland et al. (SFV Enterprise) — United States v. Natasha Ann Opsal (E.D. Wash.)

Record facts

UNITED STATES DISTRICT COURT · No. 2:24-cr-00570-WLH · Doc. 1 · 2024-09-26 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
October 2023 Grand Jury 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
CLAIRE PATRICIA HAVILAND, 
   aka “Trish,” 
   aka “SFV Mama,” 
BRIAN GLENN EKELUND, 
   aka “Rascal,” 
JOHN MICHAEL REED, 
   aka “Johnny Boi SFV,” 
KENNETH CRISWELL, 
   aka “Spinner,” 
STEVEN MICHAEL SILVERBERG, 
   aka “Meat SFV,” 
DONALD EVERETT CUNNINGHAM, 
   aka “DJ,” 
   aka “Monster,” 
CORY DANIEL SIMS, 
   aka “Sicko SFV,” 
BRIANNE BREWER, 
   aka “Bri,” 
   aka “Brianne Brewer Gill,” 
ZACHARY S. WINTERS, 
   aka “Boogie SFV,” 
COLIN NICHOLAS SLACK, 
   aka “Shorty SFV,” 
ROBERT M. SLAYTON, 
   aka “Bezerker,” 
MICHAEL VITANZA, 
 aka “Suspect,” 
PAUL JOHN PICHIE, 
   aka “Sinister,” 
CR No.  
I N D I C T M E N T 
[18 U.S.C. § 1962(d): Racketeer 
Influenced and Corrupt 
Organizations Conspiracy; 21 
U.S.C. § 846: Conspiracy to 
Distribute and to Possess with 
Intent to Distribute Controlled 
Substances; 18 U.S.C. § 1349: 
Conspiracy To Commit Bank Fraud; 
18 U.S.C. § 1344: Bank Fraud; 18 
U.S.C. § 1028A: Aggravated 
Identity Theft; 21 U.S.C. 
§§ 841(a)(1), (b)(1)(A),
(b)(1)(B), (b)(1)(C), (b)(2):
Possession with Intent to
Distribute and Distribution of
Controlled Substances; 18 U.S.C.
§ 922(g)(1): Felon in Possession
of a Firearm and Ammunition; 18
U.S.C. § 924(c)(1)(A): Possess a
Firearm in Furtherance of a Drug
Trafficking Crime; 18 U.S.C.
§ 1029(a)(3): Possession of
Fifteen or More Unauthorized
Access Devices; 18 U.S.C. § 2(a):
Aiding and Abetting; 18 U.S.C.
§§ 924(d)(1), 981(a)(1)(C),
982(a)(2)(A), 1963(a)(3), 21
2:24-CR-00570-WLH
SEP 26 2024
rsm
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ERIC STEVE SCHULTZ, 
GUY MANNING WILLS, 
   aka “FedEx,” 
CHARISSA MARIE CHOTARD, 
 aka “Brat,” 
JULIE ANN ROMERO, 
CYNTHIA VAN VLYMEN, 
   aka “Siren,” 
PAUL ERIC ATKINSON, 
   aka “Pork Chop,” 
ERNEST HILL, 
   aka “Badger,” 
PAGET GARY EKELUND, 
SCOTT JOSHUA VENNUM, 
MICHAEL ANTHONY CHATTERTON, 
   aka “Reckless,” 
CODY JENE SMITH, 
   aka “Codie Smith Gigliello,” 
   aka “Shifty,” 
CHRISTOPHER CRAIG, 
GABRIELA IBARRA, 
   aka “Gabby,” 
ASHLEE NICOLE SWINK, 
KEVIN D. FRANCIS, 
RICHARD KEVIN RILEY, 
KENNETH DANIEL PAYER, 
   aka “Tower,” 
   aka “Sugg White,” 
KENNETH RICHARD MACDONALD, 
   aka “Misfit SFV,” 
   aka “Kenny Mac,” 
ADAM L. RODNEY, 
WILLIAM SCOTT POLLAY, 
CHRISTOPHER PATRICK POLLAY, 
DANIEL YACOUB, 
   aka “Danny Boy,” 
TARA JANE BECKWITH, 
JULIO ABNER GAITHER, 
   aka “Indio,” 
SIMON R. FREEMAN, 
   aka “Grumpy,” 
MICHAEL ANDREW MORENO, 
EARL EDDSON WATTS, 
ELMER ROLANDO VILLATORO, 
   aka “Wacky,” 
ALBERT ETHAN EKLUND, 
KEVIN DANIEL MULVIHILL, 
   aka “Mo,” 
CIARA JACOBS, 
   aka “Simba Jay,” 
CURTIS WATSTEIN, 
   aka “Stretch,” 
ROBERT ANTHONY BAKER, 
RYAN SCOTT HARBAND, 
NISHANT RAMACHANDRAN, 
U.S.C. §§ 853, 881(a)(6) and (11), 
& 28 U.S.C. § 2461(c): Forfeiture] 
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CHASE AUSTIN FLACK, 
TAYLOR C. BINGAMAN, 
   aka “Scummy,” 
   aka “Scumfuck,” 
JAMES ALLEN THAEMERT, 
   aka “JT,” 
   aka “Big Foot,” 
DAVID MITCHELL SHAPIRO, 
SEAN CRAIG GLUCKMAN, 
JEREMY RUSSEL SCHWARTZ, 
   aka “Ironman,” 
JUSTIN DANIEL DIETZEN, 
CHRISTOPHER MARK PREVEDELLO, 
   aka “Mouse,” 
   aka “Evil,” 
MASON EDWARD HEINTZ, 
CYNTHIA MARIE MUNOZ, 
   aka “Thumper,” 
HENISI UTSLER, 
   aka “Henisi Montoya,” 
REBEKA ANNA BENEDICT, 
   aka “Lazy Egg,” 
MEGAN MEJIA, 
WALTER HUBERT LEIMERT, 
   aka “Creepz,” 
AMANDA JOY RAVIN, 
TANYA NURRIA RESNICK, 
MARIA ANNA JAMES, 
   aka “Maria Daizy,” 
MATT THOMAS POWERS, 
   aka “Oso,” 
CODY SEAN CHAN, and 
JOI UNGAMRUNG, 
 
Defendants. 
 
  
 
 
The Grand Jury charges: 
COUNT ONE 
[18 U.S.C. § 1962(d)] 
A. 
THE ENTERPRISE 
1. 
At all relevant times, defendants CLAIRE PATRICIA HAVILAND, 
aka “Trish,” aka “SFV Mama” (“HAVILAND”), BRIAN GLENN EKELUND, aka 
“Rascal” (“B. EKELUND”), JOHN MICHAEL REED, aka “Johnny Boi SFV” 
(“REED”), ROBERT M. SLAYTON, aka “Bezerker” (“SLAYTON”), KENNETH 
CRISWELL, aka “Spinner” (“CRISWELL”), STEVEN MICHAEL SILVERBERG, aka 
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“Meat SFV” (“SILVERBERG”), DONALD EVERETT CUNNINGHAM, aka “DJ,” aka 
“Monster” (“CUNNINGHAM”), CORY DANIEL SIMS, aka “Sicko SFV” (“SIMS”), 
BRIANNE BREWER, aka “Bri,” “Brianne Brewer Gill,” (“BREWER”), ZACHARY 
S. WINTERS, aka “Boogie” (“WINTERS”), COLIN NICHOLAS SLACK, aka 
“Shorty SFV” (“SLACK”), and unindicted co-conspirator #3, unindicted 
co-conspirator #9, unindicted co-conspirator #12, unindicted  co-
conspirator #23, unindicted co-conspirator #31, unindicted co-
conspirator #39, unindicted co-conspirator #41, unindicted co-
conspirator #42, unindicted co-conspirator #43, unindicted co-
conspirator #44, unindicted co-conspirator #45, unindicted co-
conspirator #46, unindicted co-conspirator #48, and others known and 
unknown to the Grand Jury, were members and associates of the San 
Fernando Valley Peckerwoods (“SFV”), a criminal organization engaged 
in, among other things, conspiracy to traffic in narcotics, narcotics 
trafficking, wire fraud, financial institution fraud, and fraud and 
related activity in connection with identification documents and 
access devices.  The SFV criminal organization operated in the Central 
District of California and elsewhere. 
2. 
The SFV, including its leaders, members, and associates, 
constituted an enterprise as defined by Title 18, United States Code, 
Section 1961(4), that is, a group of individuals associated in fact 
that was engaged in, and the activities of which affected, interstate 
and foreign commerce (hereinafter referred to as the “SFV enterprise,” 
“SFV criminal enterprise,” “SFV,” or the “SFV Peckerwoods”).  The SFV 
enterprise constituted an ongoing organization whose members 
functioned as a continuing unit for a common purpose of achieving the 
objectives of the enterprise. 
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B. 
GENERAL DEFINITIONS 
1. 
The San Fernando Valley, known locally as “the Valley,” is 
an urbanized valley in Los Angeles County, California.  It is situated 
to the north of the Los Angeles Basin and contains a large portion of 
the city of Los Angeles, several unincorporated areas, and the 
incorporated cities of Burbank, Calabasas, Glendale, Hidden Hills, and 
San Fernando.  Neighborhoods within the San Fernando Valley include 
Canoga Park, Granada Hills, North Hollywood, Northridge, Pacoima, 
Reseda, Sherman Oaks, Studio City, Sun Valley, Toluca Lake, Valley 
Village, Van Nuys, and Woodland Hills.  Notable streets within the San 
Fernando Valley include Ventura Boulevard, Laurel Canyon Boulevard, 
Coldwater Canyon Boulevard, Mulholland Drive, and Riverside Drive. 
2. 
Signal is an encrypted messaging service for instant 
messaging, voice calls, and video calls.  The instant messaging 
function includes sending text, voice notes, images, videos, and other 
files.  Communication may be one-to-one between users or may involve 
group messaging. 
3. 
Telegram Messenger, commonly known as Telegram, is a cloud-
based, cross-platform, encrypted instant messaging service.  It allows 
users to exchange messages, share media and files, and hold private 
and group voice or video calls as well as public livestreams.  
Telegram also offers end-to-end encryption in voice and video calls, 
and in optional private chats, which Telegram calls Secret Chats. 
4. 
Facebook Messenger is an American proprietary instant 
messaging app and platform developed by Meta Platforms.  Messenger is 
used to send messages and exchange photos, videos, stickers, audio, 
and files, and to react to other users’ messages and interact with 
bots.  The service also supports voice and video calling. 
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5. 
Cash App is a mobile payment service available in the 
United States and the United Kingdom that allows users to transfer 
money to one another using a mobile phone app. 
6. 
Zelle is a United States–based digital payments network 
that enables individuals to electronically transfer money from their 
bank accounts to another registered user’s bank account using a mobile 
device or the website of a participating banking institution. 
7. 
The California Department of Corrections and Rehabilitation 
or (“CDCR”) manages the State of California’s prison system.  Each 
incarcerated inmate is assigned to a CDCR facility with a security 
level that corresponds to their calculated placement score range.  
Placement scores are determined by the incarcerated person’s age, 
crime committed and if violence was used, prior incarcerations, and 
gang involvement.  The highest placement range is a Level IV.  Level 
IV CDCR facilities have a secure perimeter with internal and external 
armed coverage and housing units or cell block housing with cells non-
adjacent to exterior walls. 
8. 
The Federal Bureau of Prisons or (“BOP”) manages federal 
prisons for individuals incarcerated in connection with violations of 
federal criminal law. 
9. 
Inmates in BOP and CDCR custodial facilities are not 
permitted to have cellular telephones.  A contraband cellular 
telephone is a cellular telephone that an inmate has unauthorized 
access to while in a BOP or CDCR custodial facility. 
10. 
A happy card is a greeting card that is saturated in a 
controlled substance, including methamphetamine, heroin, or fentanyl, 
and sent to an inmate who is incarcerated in a CDCR or BOP facility.  
The card will resemble a normal greeting card, however, inmates are 
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able to ingest the drugs in custody by chewing on small pieces of the 
card.  The recipient of the happy card may also generate money while 
in custody by selling portions of the card to other inmates. 
11. 
“Taxes” are a portion of profits generated by criminal 
activity, including drug distribution activity, that must be paid to a 
criminal organization in exchange for the ability to engage in crime 
in the “territory” overseen by that criminal organization. 
12. 
The SFV criminal enterprise is a white criminal street gang 
primarily located in the San Fernando Valley, and is alternatively 
known as the San Fernando Valley Peckerwoods, “SFV,” and/or “SFV 
Peckerwoods.”  Peckerwoods also have factions in cities and 
communities such as Chatsworth, Granada Hills, Canoga Park, Tujunga, 
North Hollywood, Burbank, Reseda, and Tarzana.   
13. 
The name “Peckerwoods” was originally a derogatory term for 
white people developed in the prison system that has since been 
adopted by white supremacist groups themselves.  Presently, a 
Peckerwood, or “Wood,” is what a white inmate is known as in prison.  
Peckerwoods take pride in being a “Wood,” and no longer consider the 
term to be derogatory. 
14. 
Peckerwoods use the symbol of a woodpecker to represent 
their Peckerwood status, as depicted below:  
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15. 
Unindicted co-conspirator #3 is one of the founding members 
of SFV.  He is presently housed in federal custody at FCI Florence. 
16. 
SFV members often refer to the SFV as the “Family” or the 
“Car” and refer to fellow SFV members as “Brothers.”  The leaders of 
the SFV criminal enterprise are referred to as the “Key Holders” or 
having “the keys to the car.”  These leaders have ultimate authority 
in all SFV matters.   
17. 
Female Peckerwoods are known as “Featherwoods.”  The most 
common symbol for Featherwoods is simply the word “Featherwood,” or an 
image of a feather.  Female Peckerwoods refer to themselves as  
“Featherwoods” in Internet messages and memes, such as the image 
depicted below: 
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18. 
The letters SFV are the most popular tattoo by SFV 
Peckerwoods, as well as the 818-area code.  The name variation 
Peckerwood Gangsters (“PWG”) is often attached or identified with in 
relation to SFV Peckerwoods.  In addition to “SFV” referring to the  
geographic location of the “San Fernando Valley,” SFV members also use 
the letters to refer to the acronym of “Searching for Victims.”  SFV 
members often demonstrate their membership in SFV through tattoos such 
as those depicted below: 
 
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19. 
The Peckerwoods support white nationalist ideas and use 
symbols like the swastika and “88,” the white supremacist numerical 
code for “Heil Hitler.”  SFV members often demonstrate their support 
for SFV’s ideology through tattoos, clothing, and other items 
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bearing the swastika, such as in the pictures below: 
 
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20. 
SFV members engage in a wide variety of criminal activity, 
including drug trafficking, crimes of violence, and fraud.  In 2016, 
the Los Angeles City Attorney’s Office filed nuisance abatement orders 
against SFV members and associates and identified properties in 
Granada Hills and Canoga Park as havens for SFV criminal activity.  
According to those filings, Los Angeles police officers recovered 
stolen vehicles and credit cards, heroin, and methamphetamine on 
multiple occasions at the Granada Hills home of defendant REED, an SFV 
member.  Photographs from inside one of the residences that was the 
subject of the filings showed swastikas and Confederate flags adorning 
the walls, as well as an SFV symbol, as depicted below: 
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21. 
In the past decade, Facebook has become one of the most 
common methods that SFV members use to communicate regarding their 
shared criminal activities.  Most defendants and unindicted co-
conspirators identified in this Indictment have one or more personal 
Facebook profiles and have used Facebook Messenger to engage in drug 
trafficking, fraud, and witness intimidation, and/or to plot details 
of future criminal activity with other co-conspirators. 
22. 
Additionally, SFV members and associates established a 
private Facebook group on January 6, 2013 (the “SFV Facebook Page”).  
The SFV Facebook Page has remained active since that time.  Members of 
this private Facebook group use the SFV Facebook Page to:  
a. 
Affirm with others their active SFV membership, 
including by sharing their SFV monikers and pictures of their SFV 
tattoos.  
b. 
Update each other regarding law enforcement 
activities, including by sharing photographs of suspected undercover 
law enforcement officers that may be investigating SFV members or 
engaged in enforcement activity in the San Fernando Valley. 
c. 
Identify for each other individuals who are 
potentially cooperating with law enforcement to discuss whether 
violent retaliation is appropriate.   
d. 
Provide updates to each other regarding the status of 
members and associates of SFV and other criminal organizations who 
maintain positions of authority in and around the San Fernando 
Valley. 
23. 
As a white supremacist gang, the SFV at times takes orders 
from the Aryan Brotherhood (“AB” or “the Brand”) – the dominant white 
supremacist gang in California.  The SFV also pays a proceed of their 
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drug trafficking to the AB.  Payments of such “taxes” to the AB 
confers protection from rival gang attacks and allows the SFV to 
continue drug dealing and other criminal activity within AB-controlled 
territory. 
24. 
The AB has an “alliance” with the Mexican Mafia.  The 
Mexican Mafia, also known as “La Eme,” is another prison-based 
criminal organization comprised mostly of senior members of southern 
California Hispanic street gangs who have come together to control and 
profit from the activities of Hispanic gangs operating in southern 
California.  Canoga Park Alabama Street (“Canoga Park”) is a 
predominately Hispanic street gang operating in the west San Fernando 
Valley in the City of Los Angeles.  It is a gang that answers to the 
Mexican Mafia. 
25. 
Because of the alliance that the AB has with the Mexican 
Mafia, some AB members have the authority to tell Mexican Mafia 
members and members of Hispanic street gangs, such as Canoga Park, 
that members of white criminal street gangs, including the SFV 
criminal enterprise, are not to be “taxed” by members and associates 
of the Mexican Mafia.  
C. 
PURPOSES OF THE ENTERPRISE 
1. 
The purposes of the SFV enterprise included, but were not 
limited to, the following: 
a. 
Enriching members and associates of the SFV through, 
among other things, the control of, and participation in, the 
trafficking of controlled substances, and the commission of financial 
frauds. 
b. 
Maintaining control over all SFV territory. 
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c. 
Preserving, protecting, and expanding the power of SFV 
through the use of intimidation, violence, and threats of violence. 
d. 
Violently retaliating against rival gang members or 
perceived outsiders who challenge the SFV’s authority or attempt to 
encroach on the SFV’s territory. 
D. 
MEANS AND METHODS OF THE ENTERPRISE 
1. 
The means and methods by which members and associates of 
the SFV conducted and participated in the conduct of the affairs of 
the SFV included the following: 
a. 
Members and associates of the SFV committed, attempted 
to commit, conspired to commit, and threatened to commit acts of 
violence to preserve, protect, and expand the SFV’s criminal 
operations. 
b. 
Members and associates of the SFV promoted a climate 
of fear through acts of violence and threats to commit acts of 
violence. 
c. 
Members and associates of the SFV engaged in the 
trafficking of controlled substances, committed robberies, and 
committed financial fraud and identity theft schemes to generate 
revenue for the enterprise. 
d. 
Members and associates of the SFV communicated using 
social media to share information about, among other things, 
trafficking in controlled substances, committing fraud, rules of the 
SFV, identifying SFV members in good standing, and targeting people 
who broke SFV rules.  Such social media use included both an SFV-
members-only Facebook group and private, direct messages between SFV 
members and associates.  
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e. 
Members and associates of the SFV illegally maintained 
firearms and ammunition. 
2. 
Beginning on a date unknown to the Grand Jury, and 
continuing to in or around September 2024, in Los Angeles, Ventura, 
and Riverside Counties, within the Central District of California, and 
elsewhere, defendants HAVILAND, B. EKELUND, REED, SLAYTON, CRISWELL, 
SILVERBERG, CUNNINGHAM, SIMS, BREWER, WINTERS, and SLACK, and others 
known and unknown to the Grand Jury, being persons employed by and 
associated with the SFV, an enterprise which engaged in, and the 
activities of which affected, interstate and foreign commerce, 
unlawfully and knowingly combined, conspired, confederated, and agreed 
together and with each other 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 defined in Title 18, 
United States Code, Sections 1961(1) and 1961(5), which pattern of 
racketeering consisted of the following: 
a. 
Multiple offenses involving the distribution of, 
possession with intent to distribute, and conspiracy to distribute 
and possess with intent to distribute controlled substances, in 
violation of Title 21, United States Code, Sections 841, and 846; 
b. 
Multiple acts indictable under Title 18, United Staes 
Code, Sections 1343 (related to wire fraud) and 1344 (relating to 
financial institution fraud); and 
c. 
Multiple acts indictable under Title 18, United States 
Code, Sections 1028 (relating to fraud and related activity in 
connection with identification documents) and 1029 (relating to fraud 
and related activity in connection with access devices). 
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It was a further part of the conspiracy that each defendant 
agreed that a conspirator would commit at least two acts of 
racketeering in the conduct of the affairs of the enterprise. 
E. 
MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE 
ACCOMPLISHED 
The object of the conspiracy was to be accomplished, in 
substance, as follows: 
1. 
Defendants CUNNINGHAM and WINTERS, and others known and 
unknown to the Grand Jury, would maintain firearms and other dangerous 
weapons to be used in connection with the SFV criminal enterprise and 
its operations, including in connection with drug distribution 
activities. 
2. 
Defendants HAVILAND, BREWER, B. EKELUND, and others known 
and unknown to the Grand Jury, would maintain and oversee drug stash 
locations, including drug stash locations overseen by unindicted co-
conspirator #1 while co-conspirator #1 was in CDCR custody, where 
large quantities of fentanyl, methamphetamine, heroin, and other drugs 
were stored prior to distribution to drug customers in and around the 
Central District of California. 
3. 
Defendants HAVILAND, BREWER, B. EKELUND, WINTERS, and 
others known and unknown to the Grand Jury, including unindicted co-
conspirator #40, unindicted co-conspirator #43, unindicted co-
conspirator #44, and unindicted co-conspirator #48, would obtain drugs 
to distribute from drug sources of supply, some of which would be 
distributed by SFV members. 
4. 
Defendants HAVILAND, BREWER, B. EKELUND, WINTERS, and 
others known and unknown to the Grand Jury, including unindicted co-
conspirator #40, unindicted co-conspirator #43, unindicted co-
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conspirator #44, and unindicted co-conspirator #48, would distribute 
drugs to drug customers. 
5. 
Defendants HAVILAND, B. EKELUND, and others known and 
unknown to the Grand Jury, would distribute drugs to customers outside 
of the state of California via the mail. 
6. 
Defendant BREWER, and others known and unknown to the Grand 
Jury, would transport drugs to locations outside of the Central 
District of California in order to distribute drugs to customers in 
those districts. 
7. 
Defendants HAVILAND, B. EKELUND, and others known and 
unknown to the Grand Jury, would facilitate their drug distribution 
activity through the use of Cash App and Zelle by receiving money from 
drug customers and sending money to drug sources of supply via these 
mobile payment services. 
8. 
Senior members of the SFV criminal enterprise, including 
defendants HAVILAND, B. EKELUND, BREWER, and SLAYTON, and others known 
and unknown to the Grand Jury, would communicate directly with AB 
members or high-ranking AB associates, including via contraband 
cellular telephones that AB members or high-ranking AB associates 
maintained in custodial facilities, to obtain their input with respect 
to the activities of the SFV criminal enterprise, and communicate 
their input and orders to others. 
9. 
Defendants SIMS, BREWER, and others known and unknown to 
the Grand Jury, would carry out fraud schemes in order to generate 
money for themselves and other members of the SFV criminal enterprise. 
10. 
Defendant HAVILAND, BREWER, and others known and unknown to 
the Grand Jury, would share information with members and associates of 
the SFV criminal enterprise and the AB regarding law enforcement 
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activity and individuals who might be cooperating with law 
enforcement. 
F. 
OVERT ACTS 
In furtherance of the conspiracy and to accomplish its object, 
on or about the following dates, defendants HAVILAND, BREWER, B. 
EKELUND, REED, SLAYTON, CRISWELL, SILVERBERG, CUNNINGHAM, SIMS, 
WINTERS, SLACK, and others known and unknown to the Grand Jury, 
committed various overt acts in Los Angeles, Ventura, and Riverside 
Counties, within the Central District of California, and elsewhere, 
including but not limited to the following: 
Overt Act No. 1: 
On December 14, 2016, defendant BREWER 
posted the following screenshot of a news article to the SFV Facebook 
Page along with the comment, “Ugh oh.” 
Overt Act No. 2: 
On December 14, 2016, in response to 
defendant BREWER’s post, unindicted co-conspirator #48 posted to the 
SFV Facebook Page:  
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Literally laughed out loud.  Catch me if u can motherfuckers I stay 
riding dirty, stay with a warrent, this is RISKY and im a proud 
fucking member of SFV PWG!  Cant stop me if you cant catch me.  Fuck 
em its only a gang if your not in it!  Its my family and I fucking 
laugh at this cuz we arent stopping shit and theyve got a hell of a 
loss coming if they think they can stop us... 
 
Overt Act No. 3: 
On March 28, 2017, defendant BREWER posted 
to the SFV Facebook Page:  
Ok so I know we are all SFV and always will be no matter where we go 
but let’s do a roll call I am curious to where everyone has ended 
up!!!  I am in Lancaster Ca these days but still rep SFV every chance 
I get. 
 
Overt Act No. 4: 
On March 28, 2017, in response to defendant 
BREWER’s post, defendant CRISWELL posted to the SFV Facebook Page: 
“Center of the universe sfv.” 
Overt Act No. 5: 
On June 4, 2017, defendant BREWER posted to 
the SFV Facebook Page: “So let’s see if we can get some participation 
where in the valley is everyone from!  If your town is not on here 
add it and input your poll. Love my SFV heads.” 
Overt Act No. 6: 
On June 4, 2017, in response to defendant 
BREWER’s post, unindicted co-conspirator #48 posted to the SFV 
Facebook Page: “I grew up in canoga park, but my affiliation is 
tujunga-sunland.  Thats who loves me the most.” 
Overt Act No. 7: 
On June 7, 2017, in response to defendant 
BREWER’s post, defendant SIMS posted to the SFV Facebook Page: “Born 
and raised tujunga ∎SFV PECKER WOOD∎∎TUJUNGA DGAF∎” 
Overt Act No. 8: 
On July 9, 2017, unindicted co-conspirator 
#30 posted to the SFV Facebook Page: “S.F.V. COWBOY CHECKIN IN !!! 
HOMEBOYS SOUND THE FUCK OFF !!!!!” 
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Overt Act No. 9: 
On July 9, 2017, in response to unindicted 
co-conspirator #30’s post, unindicted co-conspirator #48 posted to 
the SFV Facebook Page: “Woods crackin brother Risky SFV PWG.” 
Overt Act No. 10: 
On May 12, 2020, defendant SIMS, using coded 
language in a Facebook message exchange, told defendant Chase Austin 
Flack (“Flack”) that he was preparing to place an order with a drug 
source of supply. 
Overt Act No. 11: 
On May 25, 2020, defendant SIMS received 
from a drug customer, using coded language in a Facebook message 
exchange, an order for a quarter of a pound of methamphetamine. 
Overt Act No. 12: 
On June 16, 2020, in response to unindicted 
co-conspirator #30’s post, defendant BREWER posted to the SFV 
Facebook Page: “Big bad Bri right here my peeps. Hop yall have a 
bitchen ass day.” 
Overt Act No. 13: 
On June 16, 2020, defendant SIMS posted to 
the SFV Facebook Page: “Sending mines from the rock....East side 
valley life TUJUNGA..SFV..SICKO.. SFV..PECKERWOODS...” 
Overt Act No. 14: 
On June 16, 2020, unindicted co-conspirator 
#30 posted to the SFV Facebook Page:  
Brothers and sister the fact I have to say this at all is Bullshit !! 
[J.J.] is out BAD !!!! If any of you post anything in support of 
[Black Lives Matter] like [J.J.] did , I will personally cut your 
fuckin letters off you !!!!! S.F.V. 
COWBOY !!! 
 
 
Overt Act No. 15: 
On June 16, 2020, in response to unindicted 
co-conspirator #30’s post, unindicted co-conspirator #48 posted to 
the SFV Facebook Page:  
I wish all the blacks and all the cops would just kill ALL of each 
other. Our side of the dayroom only! If thats all that was left in 
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the world, that would be awesome. 
 
Overt Act No. 16: 
On June 17, 2020, unindicted co-conspirator 
#42, using coded language in a Facebook message exchange, told 
defendant SLAYTON that the price for a quarter of a pound of 
methamphetamine had increased to $900. 
Overt Act No. 17: 
On June 18, 2020, defendant SLAYTON, using 
coded language in a Facebook message exchange, ordered a quarter of a 
pound of methamphetamine from unindicted co-conspirator #42. 
Overt Act No. 18: 
On June 18, 2020, defendant SILVERBERG 
posted to the SFV Facebook Page: “S F V MEAT from cahenga to Topanga 
I stay Reppin, check in In!!!!!!!!” 
Overt Act No. 19: 
On June 24, 2020, defendant CUNNINGHAM, 
using coded language in a Facebook message exchange, told defendant 
Amanda Joy Ravin (“Ravin”) that he had high-quality heroin available 
to distribute and offered to provide defendant Ravin with a sample of 
the drugs. 
Overt Act No. 20: 
On June 29, 2020, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #48 that he had heroin to distribute to customers. 
Overt Act No. 21: 
On June 30, 2020, defendant SLAYTON, using 
coded language in a Facebook message exchange, told defendant Jeremy 
Russel Schwartz (“Schwartz”) that he had methamphetamine available to 
distribute. 
Overt Act No. 22: 
On July 13, 2020, defendant SLAYTON, using 
coded language in a Facebook message exchange, told defendant 
Schwartz that he had heroin available to distribute. 
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Overt Act No. 23: 
On July 21, 2020, defendant SLAYTON, using 
coded language in a Facebook message exchange, told defendant 
Schwartz that he had methamphetamine and heroin available to sell. 
Overt Act No. 24: 
On July 21, 2020, defendant SLAYTON, using 
coded language in a Facebook message exchange, told defendant 
Schwartz that he had methamphetamine and heroin available to sell. 
Overt Act No. 25: 
On August 5, 2020, defendant WINTERS 
maintained a firearm and displayed a photograph of the firearm on 
Facebook messenger, as depicted below. 
 
Overt Act No. 26: 
On August 12, 2020, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
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asked unindicted co-conspirator #12 to identify the current leader of 
the SFV Hate Gang.   
Overt Act No. 27: 
On September 16, 2020, defendant SILVERBERG, 
using coded language in a Facebook message exchange, informed 
unindicted co-conspirator #48 that he had obtained a new firearm and 
sent unindicted co-conspirator #48 a photograph of the firearm, 
depicted below. 
 
Overt Act No. 28: 
On September 22, 2020, defendant WINTERS, 
using coded language in a Facebook message exchange, told defendant 
Cody Jene Smith (“Smith”) that he had approximately one ounce of 
heroin available to distribute. 
Overt Act No. 29: 
On October 3, 2020, defendant WINTERS, using 
coded language in a Facebook message exchange, told a drug customer 
that he had access to high-quality methamphetamine to sell at a 
discounted rate that he obtained from “the brotherhood.”  
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Overt Act No. 30: 
On October 11, 2020, defendant SLACK, using 
coded language in a Facebook message exchange, told defendant Henisi 
Utsler (“Utsler”) that he had “SFV blasted on [his] chest.” 
Overt Act No. 31: 
On October 19, 2020, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #48 that he needed to obtain a quarter of a pound of 
methamphetamine to deliver to San Diego. 
Overt Act No. 32: 
On November 10, 2020, defendant WINTERS, 
using coded language in a Facebook message exchange, agreed to sell 
defendant Smith an ounce of drugs for $600. 
Overt Act No. 33: 
On November 14, 2020, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told a drug 
customer that he had high-quality heroin available to distribute. 
Overt Act No. 34: 
On December 11, 2020, unindicted co-
conspirator #48 posted the following photograph via Facebook with the 
caption: “Bang bang.” 
 
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Overt Act No. 35: 
On December 15, 2020, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told defendant 
SLACK that he needed to deliver heroin to a drug customer. 
Overt Act No. 36: 
On January 10, 2021, defendant WINTERS, 
using coded language in a Facebook message exchange, agreed to supply 
half an ounce of high-quality heroin to another member of the SFV 
criminal enterprise. 
Overt Act No. 37: 
On January 14, 2021, in response to 
unindicted co-conspirator #48’s post, unindicted co-conspirator #51 
posted: “never the matter 4 weeks 4 month 40 years iits S.F.V.” 
Overt Act No. 38: 
On January 16, 2021, defendant SIMS, using 
coded language in a Facebook message exchange, agreed to supply 
methamphetamine to a drug customer. 
Overt Act No. 39: 
On January 17, 2021, defendant SILVERBERG, 
using coded language in a Facebook message exchange, ordered heroin 
from defendant SLACK. 
Overt Act No. 40: 
On January 19, 2021, defendant WINTERS, 
using coded language in a Facebook message exchange, agreed to supply 
heroin to defendant Smith. 
Overt Act No. 41: 
On January 30, 2021, defendant SLACK, using 
coded language in a Facebook message exchange, told defendant 
SILVERBERG that he was able to supply him with a quarter of a pound 
of drugs. 
Overt Act No. 42: 
On February 11, 2021, unindicted co-
conspirator #48 sent another SFV member the following Facebook 
message: “My closet door... signed by everyone...” together with the 
below photograph. 
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Overt Act No. 43: 
On February 20, 2021, defendant WINTERS, 
using coded language in a Facebook message exchange, agreed to supply 
drugs to defendant Walter Hubert Leimert (“Leimert”). 
Overt Act No. 44: 
On March 8, 2021, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
unindicted co-conspirator #49 that unindicted co-conspirator #41 
wanted to purchase a firearm from unindicted co-conspirator #49.  
Overt Act No. 45: 
On March 8, 2021, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
unindicted co-conspirator #49 that members of the SFV criminal 
enterprise “have a constant need ALWAYS for firearms and you become 
their supplier you could blow up.” 
Overt Act No. 46: 
On March 22, 2021, in Los Angeles, 
California, unindicted co-conspirator #43 possessed with intent to 
distribute approximately 397.3 grams of methamphetamine that was 100% 
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pure, 247 grams of a mixture or substance containing a detectable 
amount of heroin, and 12 grams of a mixture or substance containing a 
detectable amount fentanyl. 
Overt Act No. 47: 
On April 1, 2021, defendant SIMS, using 
coded language in a Facebook message exchange, sent defendant BREWER 
victim M.N.’s date of birth, social security number, and address so 
that defendant BREWER could activate a stolen credit card. 
Overt Act No. 48: 
On April 7, 2021, defendant WINTERS sent 
defendant Ashlee Nicole Swink (“Swink”) $500 via Cash App and 
indicated that the money was on behalf of unindicted co-conspirator 
#2. 
Overt Act No. 49: 
On April 25, 2021, defendant WINTERS, using 
coded language in a Facebook message exchange, told a drug customer 
that he had fentanyl available to distribute. 
Overt Act No. 50: 
On May 16, 2021, unindicted co-conspirator 
#45, using coded language in a Facebook message exchange, agreed to 
supply ounces of methamphetamine to defendant SILVERBERG. 
Overt Act No. 51: 
On June 20, 2021, defendant SLAYTON, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #43 that his new Cash App tag was: $SFVsFinestWhiteBoi88. 
Overt Act No. 52: 
On July 20, 2021, defendant CUNNINGHAM, 
using coded language in a Facebook message exchange, agreed to supply 
unindicted co-conspirator #50 with an ounce of methamphetamine at a 
discounted price so that unindicted co-conspirator #50 could make a 
profit selling the drugs to customers. 
Overt Act No. 53: 
On September 12, 2021, defendant WINTERS, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #1 that he was hiding from law enforcement. 
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Overt Act No. 54: 
On September 24, 2021, defendant CUNNINGHAM, 
using coded language in a Facebook message exchange, told defendant 
Ravin that he had heroin available to distribute. 
Overt Act No. 55: 
On September 25, 2021, defendant WINTERS, 
using coded language in a Facebook message exchange, told defendant 
Taylor C. Bingaman (“Bingaman”) that he was able to sell him an ounce 
of fentanyl for $1,300. 
Overt Act No. 56: 
On September 26, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told defendant Sean Craig Gluckman (“Gluckman”) that if defendant 
Gluckman “cr[ied] to the big homie” and told unindicted co-
conspirator #6 about defendant Utsler’s debt, he was “gonna kill 
[defendant Gluckman,]” not “beat [defendant Gluckman] up, not stab 
[defendant Gluckman], like actually fucking take [defendant 
Gluckman’s] life.” 
Overt Act No. 57: 
On October 2, 2021, defendant WINTERS, using 
coded language in a Facebook message exchange, told defendant 
Bingaman that he was able to distribute fentanyl for $900 an ounce. 
Overt Act No. 58: 
On October 22, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told another SFV member that members of the SFV criminal enterprise 
“answer to the aryan brotherhood in prison,” and that the AB “wrote 
the code.” 
Overt Act No. 59: 
On October 22, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told another SFV member that AB members “can be ruthless but you 
gotta appreciate that many of them are doing life behind us not 
having to fight for our shoes when we hit the county.” 
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Overt Act No. 60: 
On October 22, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told another SFV member that members of the SFV criminal enterprise 
are “friendly with south [siders] and we share neighborhoods with 
them but we don’t answer to them.” 
Overt Act No. 61: 
On October 28, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told unindicted co-conspirator #49 that a member of the SFV criminal 
enterprise wanted to purchase a firearm from unindicted co-
conspirator #49. 
 
Overt Act No. 62: 
On December 5, 2021, unindicted co-
conspirator #41, using Facebook Messenger, sent defendant Gluckman 
the photograph depicted below of a new firearm that he had obtained. 
 
Overt Act No. 63: 
On December 21, 2021, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
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told defendant SLACK that a drug customer wanted to purchase a 
quarter of an ounce of drugs from defendant SLACK. 
Overt Act No. 64: 
On January 21, 2022, unindicted co-
conspirator #48, using coded language in a Facebook message exchange, 
told another SFV member that he didn’t “have ANY big homie except 
[unindicted co-conspirator #3] and members of the brand.” 
Overt Act No. 65: 
On February 3, 2022, defendant SIMS, using 
coded language in a Facebook message exchange, ordered a quarter of a 
pound of methamphetamine from a drug source of supply. 
Overt Act No. 66: 
On February 17, 2022, defendant BREWER 
possessed methamphetamine to distribute, as well as credit card 
numbers and identification cards that belonged to other individuals. 
Overt Act No. 67: 
On February 22, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #48 that he had high-quality methamphetamine available 
to distribute at a price of $130 an ounce. 
Overt Act No. 68: 
On February 28, 2022, defendant BREWER, 
using coded language in a Facebook message exchange, agreed to supply 
heroin to unindicted co-conspirator #48. 
Overt Act No. 69: 
On March 1, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #48 that defendant Richard Kevin Riley (“Riley”) was 
his drug source of supply. 
Overt Act No. 70: 
On March 9, 2022, defendant WINTERS, using 
coded language in a Facebook message exchange, told defendant Leimert 
that he was able to obtain high-quality heroin from a drug source of 
supply. 
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Overt Act No. 71: 
On March 18, 2022, defendant WINTERS, using 
coded language in a Facebook message exchange, agreed to supply 
fentanyl to a drug customer. 
Overt Act No. 72: 
On March 20, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told defendant 
Kenneth Daniel Payer (“Payer”) that he presently had an ounce of 
heroin and needed heroin customers. 
Overt Act No. 73: 
On March 20, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told a drug 
customer that he had high-quality heroin available to distribute. 
Overt Act No. 74: 
On March 26, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told a drug 
customer that he had high-quality heroin and methamphetamine 
available to distribute. 
Overt Act No. 75: 
On March 31, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
defendant Payer that unindicted co-conspirator #3 was the one who had 
made unindicted co-conspirator #48 a “peckerwood gangster.” 
Overt Act No. 76: 
On April 4, 2022, in Los Angeles California, 
unindicted co-conspirator #48 possessed a Glock, Model 22, .40 
caliber pistol and numerous rounds of ammunition while in a vehicle 
with defendant Payer. 
Overt Act No. 77: 
On April 8, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told defendant 
Payer that he presently had fentanyl available to distribute. 
Overt Act No. 78: 
On April 15, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant Ravin 
that he had heroin available to distribute. 
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Overt Act No. 79: 
On April 20, 2022, defendant SIMS, using 
coded language in a Facebook message exchange, told a drug customer 
that he was able to supply methamphetamine. 
Overt Act No. 80: 
On April 22, 2022, defendant SLACK, using 
coded language in a Facebook message exchange, asked defendant BREWER 
to send him money via Cash App so that he could obtain additional 
drugs from a source of supply. 
Overt Act No. 81: 
On April 23, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told a drug customer 
that he had an ounce of heroin available to distribute. 
Overt Act No. 82: 
On April 26, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told defendant 
Smith that he had fentanyl available to distribute. 
Overt Act No. 83: 
On April 29, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant Tara 
Jane Beckwith (“Beckwith”) that he had high-quality fentanyl 
available to distribute to customers. 
Overt Act No. 84: 
On May 7, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant 
Beckwith that he had high-quality fentanyl available to distribute 
and that he would be able to obtain heroin to distribute from a drug 
source of supply. 
Overt Act No. 85: 
On May 11, 2022, defendant BREWER, using 
coded language in a Facebook message exchange, ordered two ounces of 
drugs from defendant SLACK. 
Overt Act No. 86: 
On May 11, 2022, defendant BREWER, using 
coded language in a Facebook message exchange, ordered two ounces of 
drugs from defendant CRISWELL. 
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Overt Act No. 87: 
On May 13, 2022, defendant SILVERBERG, using 
coded language in a Facebook message exchange, agreed to supply an 
ounce of methamphetamine to unindicted co-conspirator #48. 
Overt Act No. 88: 
On May 25, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, agreed to supply an 
ounce of fentanyl to a drug customer. 
Overt Act No. 89: 
On May 25, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, agreed to facilitate 
the supply of heroin to a drug customer that defendant Beckwith had 
identified for him. 
Overt Act No. 90: 
On May 28, 2022, defendant SILVERBERG, using 
coded language in a Facebook message exchange, told a drug customer 
that he had fentanyl available to distribute and warned the customer 
not to say “fetty” on Facebook Messenger. 
Overt Act No. 91: 
On May 29, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant Ravin 
that he had heroin available to distribute. 
Overt Act No. 92: 
On June 12, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant Ciara 
Jacobs (“Jacobs”) that he had M30 pills available to distribute. 
Overt Act No. 93: 
On June 12, 2022, defendant WINTERS posted 
to a Facebook group chat: “[Y]ou already know that I’m the big bad 
boogy man from the west end!  SFV rocker earned not bought along with 
my handle because I boogy down after the shot.” 
Overt Act No. 94: 
On June 13, 2022, an unindicted co-
conspirator and SFV member, using coded language in a Facebook 
message exchange, told defendant BREWER that he had methamphetamine 
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available to distribute and sent defendant BREWER a photograph of the 
drugs, shown below. 
 
Overt Act No. 95: 
On June 13, 2022, defendant BREWER, using 
coded language in a Facebook message exchange, ordered 
methamphetamine from the SFV member who had sent her the photograph 
of the drugs that were available. 
Overt Act No. 96: 
On June 16, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
unindicted co-conspirator #13 that he was unindicted co-conspirator 
#3’s “arm” with respect to the SFV criminal enterprise while 
unindicted co-conspirator #3 was in custody. 
Overt Act No. 97: 
On June 16, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
unindicted co-conspirator #13 that unindicted co-conspirator #31 
presently had the “keys” to the SFV criminal enterprise and was equal 
to unindicted co-conspirator #3 and told unindicted co-conspirator 
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#13 that unindicted co-conspirator #3 did not have authority over 
unindicted co-conspirator #31. 
Overt Act No. 98: 
On June 22, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, offered to sell 
nine grams of heroin to a drug customer for $250. 
Overt Act No. 99: 
On June 24, 2022, defendant CRISWELL, using 
coded language in a Facebook message exchange, told defendant 
Beckwith that he possessed fentanyl to distribute. 
Overt Act No. 100: 
On June 27, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, asked 
defendant CRISWELL to supply him with an ounce of methamphetamine as 
well as a quantity of heroin. 
Overt Act No. 101: 
On June 27, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, agreed to supply 
an ounce of methamphetamine as well as a quantity of heroin to 
unindicted co-conspirator #48. 
Overt Act No. 102: 
On July 1, 2022, defendant Smith, using 
coded language in a Facebook message exchange, agreed to supply a 
quarter of a pound of methamphetamine as well as an ounce of fentanyl 
to defendant SILVERBERG. 
Overt Act No. 103: 
On July 1, 2022, defendant SIMS, using coded 
language in a Facebook message exchange, told Facebook user J.P. that 
defendant SIMS “got cracked with a strap and a bunch of drugs then 
bailed the got cracked with another gun and fraud,” and explained 
that, when he was arrested with drugs, it was “not that much it was a 
light day a pound and like 4 or 5 [ounces] of [heroin] and a loaded 
compact 45.” 
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Overt Act No. 104: 
On July 5, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
unindicted co-conspirator #13 that unindicted co-conspirator #3 was 
his “big homie” as it related to the SFV criminal enterprise. 
Overt Act No. 105: 
On July 19, 2022, defendant SILVERBERG 
possessed approximately 70.35 grams of methamphetamine and 10.81 
grams of heroin to distribute to drug customers in Northridge, 
California. 
Overt Act No. 106: 
On July 20, 2022, defendant REED sent 
defendant BREWER the following Facebook message:  
“I was gonna see if you knew anybody who fucked with norcos and Zanex 
some body gave me some blue 30s and the z bars that owes me money now 
there just 2 more felonies in the glove box feel me ?” 
 
Overt Act No. 107: 
On July 23, 2022, defendant BREWER, using 
coded language in a Facebook message exchange, ordered an ounce of 
drugs from defendant REED. 
Overt Act No. 108: 
On July 23, 2023, defendant CUNNINGHAM, in 
his residence in Granada Hills, California, possessed with intent to 
distribute approximately 953.5 grams of fentanyl and 336 grams of 
methamphetamine, and possessed multiple firearms, numerous rounds of 
ammunition, body armor, and tools to press kilogram fentanyl bricks.    
Overt Act No. 109: 
On August 25, 2023, defendant BREWER, using 
coded language in a recorded telephone call, told defendant Guy 
Manning Wills (“Wills”) that unindicted co-conspirator #40’s 
residence was “raided” by law enforcement. 
Overt Act No. 110: 
On August 25, 2023, defendants BREWER and 
Wills, using coded language in a recorded telephone call, speculated 
regarding the identity of individuals who might be cooperating with 
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law enforcement against members of the SFV criminal enterprise and 
members and associates of the AB. 
Overt Act No. 111: 
On September 27, 2023, defendant B. EKELUND, 
using coded language in a recorded telephone call, told unindicted 
co-conspirator #11 that defendant Wills would deliver drug 
distribution proceeds to unindicted co-conspirator #11 on defendant 
B. EKELUND’s behalf. 
Overt Act No. 112: 
On September 28, 2023, defendant B. EKELUND, 
using coded language in a recorded telephone call, told unindicted 
co-conspirator #11 to give B. EKELUND’s telephone to unindicted co-
conspirator #35 while defendant B. EKELUND was in custody. 
Overt Act No. 113: 
On October 29, 2023, defendant SLAYTON sent 
defendant Kevin D. Francis (“Francis”) $550 via Cash App. 
Overt Act No. 114: 
On November 6, 2023, using coded language in 
a recorded telephone call, defendants HAVILAND and Julie Ann Romero 
(“Romero”) discussed thousands of dollars of drug distribution 
proceeds that were at defendant HAVILAND’s residence, and the portion 
of the drug distribution proceeds that belonged to unindicted co-
conspirator #1 versus the portion that belonged to an individual 
referred to as “L.” 
Overt Act No. 115: 
On November 7, 2023, defendant REED, using 
coded language in a recorded telephone call, told defendant Michael 
Anthony Chatterton (“Chatterton”) that he was traveling to defendant 
Chatterton’s location to deliver a quantity of drugs and instructed 
defendant Chatterton to send him money via Cash App. 
Overt Act No. 116: 
On November 19, 2022, defendant BREWER, 
using coded language in a Facebook message exchange, told defendant 
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SIMS that she was attempting to fraudulently obtain a social security 
number of an identity theft victim.     
Overt Act No. 117: 
On November 29, 2023, defendant BREWER, 
using coded language in a Facebook message exchange, agreed to obtain 
a social security number of an identity theft victim for defendant 
SIMS. 
Overt Act No. 118: 
On December 22, 2023, defendant REED, using 
coded language in a recorded telephone call, agreed to supply an 
ounce of drugs to a customer. 
Overt Act No. 119: 
On December 22, 2023, defendant REED, using 
coded language in a recorded telephone call, agreed to meet a drug 
customer in Tarzana, California to supply the customer with drugs. 
Overt Act No. 120: 
On December 28, 2023, defendant REED, using 
coded language in a recorded telephone call, agreed to distribute 
Xanax to a drug customer. 
Overt Act No. 121: 
On December 29, 2023, defendant REED, using 
coded language in a recorded telephone call, agreed to supply eight 
ounces of drugs to a drug customer. 
Overt Act No. 122: 
On January 2, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant David 
Mitchell Shapiro (“Shapiro”) that defendant SLAYTON had half a pound 
of methamphetamine available to distribute to defendant Shapiro. 
Overt Act No. 123: 
On January 2, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told a drug customer 
that the price of an ounce of methamphetamine was $100 and that 
defendant SLAYTON was attempting to obtain heroin to distribute to 
customers from his drug source of supply. 
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Overt Act No. 124: 
On January 3, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant 
Christopher Mark Prevedello (“Prevedello”) that he had fentanyl 
available to distribute and that he was able to sell a quarter of an 
ounce of fentanyl for $450. 
Overt Act No. 125: 
On January 3, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant Francis 
that a drug customer was interested in purchasing $3,000 worth of 
fentanyl. 
Overt Act No. 126: 
On January 3, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant Francis 
that he had $1,200 in cash and $500 in Cash App. 
Overt Act No. 127: 
On January 4, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, agreed to supply 
fentanyl to defendant James Allen Thaemert (“Thaemert”). 
Overt Act No. 128: 
On January 4, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, agreed to supply 
fentanyl to defendant Ernest Hill (“Hill”) to distribute to drug 
customers. 
Overt Act No. 129: 
On January 5, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant 
Prevedello that he had an ounce of drugs available to distribute. 
Overt Act No. 130: 
On January 5, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant William 
Scott Pollay (“W. Pollay”) that he would be obtaining additional 
drugs to distribute from a drug source of supply.     
Overt Act No. 131: 
On January 6, 2024, defendant REED, using 
coded language in a recorded telephone call, told a drug customer 
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that he had high-quality methamphetamine available to distribute and 
would determine the price of a pound of the methamphetamine. 
Overt Act No. 132: 
On January 8, 2024, defendant SLAYTON sent 
defendant Francis $500 via Cash App. 
Overt Act No. 133: 
On January 8, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant Hill that 
he had fentanyl available to distribute. 
Overt Act No. 134: 
On January 9, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, agreed to supply 
methamphetamine to defendant W. Pollay.     
Overt Act No. 135: 
 On January 10, 2024, unindicted co-
conspirator #8 and defendant HAVILAND, using coded language in a text 
message exchange, discussed the fact that unindicted co-conspirator 
#1 had his contraband cellular telephone seized by law enforcement. 
Overt Act No. 136: 
On January 12, 2024, defendant SLAYTON, 
using coded language in a recorded telephone call, told defendant 
Prevedello that he was going to obtain methamphetamine to distribute 
from a drug source of supply.   
Overt Act No. 137: 
On March 17, 2024, defendant REED possessed 
with intent to distribute methamphetamine in a vehicle in Tujunga, 
California. 
Overt Act No. 138: 
On March 18, 2024, defendant REED possessed 
with intent to distribute approximately 86.13 grams of 
methamphetamine in Tujunga, California. 
Overt Act No. 139: 
On March 20, 2024, defendant BREWER 
coordinated a three-way telephone call between herself, unindicted 
co-conspirator #1, and defendant Charissa Marie Chotard (“Chotard”). 
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Overt Act No. 140: 
On March 28, 2024, defendant SIMS possessed 
multiple social security numbers, driver’s license numbers, dates of 
birth, bank account numbers, and credit card numbers stolen from 
identity theft victims. 
 
 
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COUNT TWO 
[21 U.S.C. § 846] 
Parts A and B of Count One are re-alleged and incorporated by 
reference as if fully set forth herein. 
A. 
OBJECTS OF THE CONSPIRACY 
Beginning on a date unknown to the Grand Jury, and continuing to 
in or around September 2024, in Los Angeles, Ventura, and Riverside 
Counties, within the Central District of California, and elsewhere, 
defendants HAVILAND, B. EKELUND, REED, CRISWELL, SILVERBERG, 
CUNNINGHAM, SIMS, BREWER, WINTERS, SLACK, ROBERT M. SLAYTON, aka 
“Bezerker” (“SLAYTON”), MICHAEL VITANZA, aka “Suspect” (“VITANZA”), 
PAUL JOHN PICHIE, aka “Sinister” (“PICHIE”), ERIC STEVE SCHULTZ 
(“SCHULTZ”), GUY MANNING WILLS, aka “FedEx” (“WILLS”),  CHARISSA 
MARIE CHOTARD, aka “Brat” (“CHOTARD”), JULIE ANN ROMERO (“ROMERO”), 
CYNTHIA VAN VLYMEN, aka “Siren” (“VAN VLYMEN”), PAUL ERIC ATKINSON, 
aka “Pork Chop” (“ATKINSON”), ERNEST HILL (“HILL”), PAGET GARY 
EKELUND (“P. EKELUND”), SCOTT JOSHUA VENNUM (“VENNUM”),  MICHAEL 
ANTHONY CHATTERTON, aka “Reckless” (“CHATTERTON”), CODY JENE SMITH, 
aka “Codie Smith Gigliello,” aka “Shifty,” (“SMITH”),  CHRISTOPHER 
CRAIG, aka “Lefty” (“CRAIG”), GABRIELA IBARRA, aka “Gabby” 
(“IBARRA”), ASHLEE NICOLE SWINK (“SWINK”), KEVIN D. FRANCIS 
(“FRANCIS”), RICHARD KEVIN RILEY (“RILEY”), KENNETH DANIEL PAYER, aka 
“Tower,” aka “Sugg White” (“PAYER”), KENNETH RICHARD MACDONALD, aka 
“Misfit,” aka “Kenny Mac,” (“MACDONALD”), ADAM L. RODNEY (“RODNEY”), 
WILLIAM SCOTT POLLAY (“W. POLLAY”), CHRISTOPHER PATRICK POLLAY (“C. 
POLLAY”), DANIEL YACOUB, aka “Danny Boy” (“YACOUB”), TARA JANE 
BECKWITH (“BECKWITH”), JULIO ABNER GAITHER, aka “Indio” (“GAITHER”), 
SIMON R. FREEMAN, aka “Grumpy” (“FREEMAN”), MICHAEL ANDREW MORENO 
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(“MORENO”), EARL EDDSON WATTS (“WATTS”), ELMER ROLANDO VILLATORO, aka 
“Wacky” (“VILLATORO”), ALBERT ETHAN EKLUND (“EKLUND”), KEVIN 
MULVIHILL, aka “Mo” (“MULVIHILL”), CIARA JACOBS, aka “Simba Jay” 
(“JACOBS”), CURTIS WATSTEIN, aka “Stretch” (“WATSTEIN”), ROBERT 
ANTHONY BAKER (“BAKER”), RYAN SCOTT HARBAND (“HARBAND”), NISHANT 
RAMACHANDRAN (“RAMACHANDRAN”), CHASE AUSTIN FLACK (“FLACK”), TAYLOR 
C. BINGAMAN, aka “Scummy,” aka “Scumfuck” (“BINGAMAN”), JAMES ALLEN 
THAEMERT, aka “JT,” aka “Big Foot” (“THAEMERT”), DAVID MITCHELL 
SHAPIRO (“SHAPIRO”), SEAN CRAIG GLUCKMAN (“GLUCKMAN”), JEREMY RUSSEL 
SCHWARTZ, aka “Ironman” (“SCHWARTZ”), JUSTIN DANIEL DIETZEN 
(“DIETZEN”), CHRISTOPHER MARK PREVEDELLO, aka “Mouse,” aka “Evil” 
(“PREVEDELLO”),  MASON EDWARD HEINTZ (“HEINTZ”), CYNTHIA MARIE MUNOZ, 
aka “Thumper” (“MUNOZ”), HENISI UTSLER, aka “Henisi Montoya” 
(“UTSLER”), REBEKA ANNA BENEDICT, aka “Lazy Egg” (“BENEDICT”), MEGAN 
MEJIA (“MEJIA”), WALTER HUBERT LEIMERT, aka “Creepz” (“LEIMERT”), 
AMANDA JOY RAVIN (“RAVIN”), TANYA NURRIA RESNICK (“RESNICK”), MATT 
THOMAS POWERS, aka “Oso” (“POWERS”), CODY SEAN CHAN (“CHAN”), JOI 
UNGAMRUNG (“UNGAMRUNG”), and others known and unknown to the Grand 
Jury, conspired and agreed with each other to knowingly and 
intentionally (1) possess with intent to distribute, and 
(2) distribute: 
1. 
At least 50 grams of methamphetamine, a Schedule II 
controlled substance, in violation of Title 21, United States Code, 
Sections 841(a)(1) and (b)(1)(A)(viii); 
2. 
At least 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, Sections 
841(a)(1) and (b)(1)(A)(viii); 
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3. 
At least five grams of methamphetamine, a Schedule II 
controlled substance, in violation of Title 21, United States Code, 
Sections 841(a)(1) and (b)(1)(B)(viii); 
4. 
At least 50 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, Sections 
841(a)(1) and (b)(1)(B)(viii); 
5. 
A mixture and substance containing a detectable amount of 
methamphetamine, a Schedule II controlled substance, in violation of 
Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C); 
6. 
At least 400 grams of a mixture and substance containing a 
detectable amount of N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] 
propanamide (“fentanyl”), a Schedule II narcotic drug controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a)(1) and (b)(1)(A)(vi);  
7. 
At least 40 grams of a mixture and substance containing a 
detectable amount of fentanyl, a Schedule II narcotic drug controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a)(1) and (b)(1)(B)(vi);  
8. 
A mixture and substance containing a detectable amount of 
fentanyl, a Schedule II narcotic drug controlled substance, in 
violation of Title 21, United States Code, Sections 841(a)(1) and 
(b)(1)(C);  
9. 
At least a kilogram of a mixture and substance containing a 
detectable amount of heroin, a Schedule I narcotic drug controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a)(1) and (b)(1)(A)(i);  
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10. 
At least 100 grams of a mixture and substance containing a 
detectable amount of heroin, a Schedule I narcotic drug controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a)(1) and (b)(1)(B)(i); 
11. 
A mixture and substance containing a detectable amount of 
heroin, a Schedule I narcotic drug controlled substance, in violation 
of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C); 
12. 
At least 280 grams of a mixture and substance containing a 
detectable amount of cocaine base, a Schedule II narcotic drug 
controlled substance, in violation of Title 21, United States Code, 
Sections 841(a)(1) and (b)(1)(A)(iii); 
13. 
At least 28 grams of a mixture and substance containing a 
detectable amount of cocaine base, a Schedule II narcotic drug 
controlled substance, in violation of Title 21, United States Code, 
Sections 841(a)(1) and (b)(1)(B)(iii); 
14. 
A mixture and substance containing a detectable amount of 
cocaine base, a Schedule II narcotic drug controlled substance, in 
violation of Title 21, United States Code, Sections 841(a)(1) and 
(b)(1)(C); 
15. 
A mixture and substance containing a detectable amount of 
phencyclidine (“PCP”), a Schedule III controlled substance, in 
violation of Title 21, United States Code, Sections 841(a)(1) and 
(b)(1)(E)(i); and 
16. 
Gamma hydroxybutyric acid (“GHB”), a Schedule I controlled 
substance, in violation of Title 21, United States Code, Sections 
841(a)(1) and (b)(1)(C). 
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B. 
MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE 
ACCOMPLISHED 
The objects of the conspiracy were to be accomplished, in 
substance, as follows: 
1. 
Defendants HAVILAND, VITANZA, PICHIE, SCHULTZ, CHOTARD, 
ROMERO, HILL, and others known and unknown to the Grand Jury, would 
communicate directly with AB members or high-ranking AB associates, 
including via contraband cellular telephones that AB members or high-
ranking AB associates maintained in custodial facilities, to obtain 
their input and assistance with respect to drug trafficking 
activities. 
2. 
Defendant HAVILAND, and others known and unknown to the 
Grand Jury, would communicate directly with Mexican Mafia 
representatives, including “M.T.,” also known as “Trouble,” regarding 
drug trafficking in and around the San Fernando Valley. 
3. 
Defendants VITANZA and PICHIE, and others known and unknown 
to the Grand Jury, including unindicted co-conspirator #1, and 
unindicted co-conspirator #40, would negotiate the purchase of large 
quantities of drugs from cartel members to distribute to drug 
customers in and around the Central District of California. 
4. 
Defendant CUNNINGHAM, and others known and unknown to the 
Grand Jury, would manufacture and press kilogram bricks of fentanyl to 
distribute to drug customers in and around the Central District of 
California. 
5. 
Defendants HAVILAND, B. EKELUND, CUNNINGHAM, BREWER, WILLS, 
ATKINSON, P. EKELUND, VENNUM,  and others known and unknown to the 
Grand Jury, would maintain and oversee drug stash locations, including 
drug stash locations overseen by unindicted co-conspirator #1 while 
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co-conspirator #1 was in CDCR custody, where large quantities of 
fentanyl, methamphetamine, heroin, and other drugs were stored prior 
to distribution to drug customers in and around the Central District 
of California. 
6. 
Defendants HAVILAND, B. EKELUND, REED, CRISWELL, 
SILVERBERG, CUNNINGHAM, SIMS, BREWER, WINTERS, SLACK, SLAYTON, 
VITANZA, PICHIE, SCHULTZ, CHOTARD, VAN VLYMEN, ATKINSON, HILL, P. 
EKELUND, VENNUM, CHATTERTON, SMITH, CRAIG, IBARRA, SWINK, FRANCIS, 
RILEY, PAYER, MACDONALD, RODNEY, W. POLLAY, C. POLLAY, YACOUB, 
BECKWITH, GAITHER, FREEMAN, MORENO, WATTS, VILLATORO, EKLUND, 
MULVIHILL, JACOBS, WATSTEIN, BAKER, HARBAND, RAMACHANDRAN, FLACK, 
BINGAMAN, THAEMERT, SHAPIRO, GLUCKMAN, SCHWARTZ, DIETZEN, PREVEDELLO, 
HEINTZ, MUNOZ, UTSLER, BENEDICT, MEJIA, LEIMERT, RAVIN, POWERS, CHAN, 
UNGAMRUNG and others known and unknown to the Grand Jury, would obtain 
drugs to distribute from drug sources of supply. 
7. 
Defendants HAVILAND, B. EKELUND, REED, CRISWELL, 
SILVERBERG, CUNNINGHAM, SIMS, BREWER, WINTERS, SLACK, SLAYTON, 
VITANZA, PICHIE, SCHULTZ, VAN VLYMEN, HILL, P. EKELUND, VENNUM, 
CHATTERTON, SMITH, CRAIG, IBARRA, SWINK, FRANCIS, RILEY, PAYER, 
MACDONALD, RODNEY, W. POLLAY, C. POLLAY, YACOUB, BECKWITH, GAITHER, 
FREEMAN, MORENO, WATTS, VILLATORO, EKLUND, MULVIHILL, JACOBS, 
WATSTEIN, BAKER, HARBAND, RAMACHANDRAN, FLACK, BINGAMAN, THAEMERT, 
SHAPIRO, GLUCKMAN, SCHWARTZ, DIETZEN, PREVEDELLO, HEINTZ, MUNOZ, 
UTSLER, BENEDICT, MEJIA, LEIMERT, RAVIN, RESNICK, POWERS, CHAN, 
UNGAMRUNG, and others known and unknown to the Grand Jury, would 
distribute drugs to drug customers. 
8. 
Defendants SILVERBERG, BREWER, and others known and unknown 
to the Grand Jury, would transport drugs to locations outside of the 
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Central District of California in order to distribute drugs to 
customers in those districts. 
9. 
Defendants FRANCIS, PAYER, and others known and unknown to 
the Grand Jury, would distribute drugs to individuals in custodial 
facilities.   
10. 
Defendants HAVILAND, B. EKELUND, CHATTERTON, and others 
known and unknown to the Grand Jury, would distribute drugs to 
customers outside of the state of California via the mail. 
11. 
Defendant WILLS, and others known and unknown to the Grand 
Jury, would maintain, store, and disperse the drug distribution 
proceeds that were generated by co-conspirators. 
12. 
Defendants CUNNINGHAM, VITANZA, SCHULTZ, and others known 
and unknown to the Grand Jury, would maintain firearms and other 
dangerous weapons to be used in connection with drug distribution 
activities. 
13. 
Defendants HAVILAND, B. EKELUND, SLAYTON, VITANZA, SCHULTZ, 
HILL, P. EKELUND, VENNUM, CHATTERTON, FRANCIS, MACDONALD, W. POLLAY, 
BECKWITH, GAITHER, FREEMAN, MULVIHILL, WATSTEIN, BAKER, RAMACHANDRAN, 
THAEMERT, SHAPIRO, CHAN, UNGAMRUNG, and others known and unknown to 
the Grand Jury, would facilitate their drug distribution activity 
through the use of Cash App and Zelle by receiving money from drug 
customers and sending money to drug sources of supply via these mobile 
payment services. 
14. 
Defendants SIMS, BREWER, WINTERS, BINGAMAN, GLUCKMAN, 
SCHWARTZ, and others known and unknown to the Grand Jury, would carry 
out fraud schemes in order to generate money for themselves and to use 
in connection with drug distribution activities. 
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15. 
Defendant HAVILAND, B. EKELUND, BREWER, VITANZA, PICHIE, 
SCHULTZ, WILLS, CHOTARD, CHATTERTON, SWINK, DIETZEN, MUNOZ, and others 
known and unknown to the Grand Jury, would share information with co-
conspirators regarding law enforcement activity and individuals who 
might be cooperating with law enforcement.   
  
 
C. 
OVERT ACTS 
In furtherance of the conspiracy and to accomplish its objects, 
on or about the following dates, defendants HAVILAND, B. EKELUND, 
REED, CRISWELL, SILVERBERG, CUNNINGHAM, SIMS, BREWER, WINTERS, SLACK, 
SLAYTON, VITANZA, PICHIE, SCHULTZ, WILLS, CHOTARD, ROMERO, VAN 
VLYMEN, ATKINSON, HILL, P. EKELUND, VENNUM, CHATTERTON, SMITH, CRAIG, 
IBARRA, SWINK, FRANCIS, RILEY, PAYER, MACDONALD, RODNEY, W. POLLAY, 
C. POLLAY, YACOUB, BECKWITH, GAITHER, FREEMAN, MORENO, WATTS, 
VILLATORO, EKLUND, MULVIHILL, JACOBS, WATSTEIN, BAKER, HARBAND, 
RAMACHANDRAN, FLACK, BINGAMAN, THAEMERT, SHAPIRO, GLUCKMAN, SCHWARTZ, 
DIETZEN, PREVEDELLO, HEINTZ, MUNOZ, UTSLER, BENEDICT, MEJIA, LEIMERT, 
RAVIN, RESNICK, POWERS, CHAN, UNGAMRUNG, and others known and unknown 
to the Grand Jury, committed various overt acts in Los Angeles, 
Ventura, and Riverside Counties, within the Central District of 
California, and elsewhere, including, but not limited to, Overt Acts 
numbered 10, 11, 16, 17, 19-24, 28-29, 31-33, 35-36, 38-41, 43, 46, 
47, 49-55, 63, 65-74, 77-92, 94-95, 98-140, as set forth in Part F of 
Count One, which are re-alleged and incorporated by reference as if 
fully set forth herein, as well as the following: 
Overt Act No. 104: 
On December 29, 2019, unindicted co-
conspirator #47 told an undercover law enforcement officer who she 
believed was a drug customer (the “UC”) that she “knew the right 
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people in the Valley,” and that she would be able to supply the UC 
with large quantities of drugs. 
Overt Act No. 105: 
On January 2, 2020, unindicted co-
conspirator #47 told the UC that she could supply him with pounds of 
methamphetamine at a price of $1650 a pound, and ounces of heroin at 
a price of $800 an ounce. 
Overt Act No. 106: 
On January 9, 2020, unindicted co-
conspirator #47 sold the UC an ounce of methamphetamine for $130. 
Overt Act No. 107: 
On March 27, 2020, defendant C. POLLAY, 
using coded language in a Facebook message exchange, asked defendant 
SIMS for the price of an ounce of methamphetamine for a drug 
customer. 
Overt Act No. 108: 
On March 27, 2020, defendant C. POLLAY, 
using coded language in a Facebook message exchange, asked defendant 
SIMS for the price of an ounce of methamphetamine for a drug 
customer. 
Overt Act No. 109: 
On April 24, 2020, defendant SCHWARTZ, using 
coded language in a Facebook message exchange, told defendant SLAYTON 
that he needed 10 to 20 pounds of methamphetamine. 
Overt Act No. 110: 
On April 25, 2020, defendant BENEDICT, using 
coded language in a Facebook message exchange, told defendant MUNOZ 
that she would be able to supply a pound of methamphetamine to 
defendant MUNOZ for $2,300. 
Overt Act No. 111: 
On April 25, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that a drug customer had $1,700 available to purchase 
methamphetamine. 
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Overt Act No. 112: 
On May 8, 2020, defendant FLACK, using coded 
language in a Facebook message exchange, asked unindicted co-
conspirator #23 to supply a pound of methamphetamine at a good price. 
Overt Act No. 113: 
On May 12, 2020, defendant FLACK, using 
coded language in a Facebook message exchange, told defendant SIMS 
that he wanted to purchase ten pounds of methamphetamine at a good 
price. 
Overt Act No. 114: 
On May 12, 2020, unindicted co-conspirator 
#23, using coded language in a Facebook message exchange, told 
defendant FLACK that he would be able to purchase a pound of 
methamphetamine for $2,000. 
Overt Act No. 115: 
On May 13, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that she needed a drug source of supply who could 
consistently sell her drugs to distribute. 
Overt Act No. 116: 
On May 13, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that she had traveled to Palmdale, California to obtain 
drugs to distribute. 
Overt Act No. 117: 
On May 13, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that she was thinking about asking defendant HAVILAND to 
teach her how to manufacture methamphetamine due to the current 
shortage in methamphetamine to distribute. 
Overt Act No. 118: 
On May 13, 2020, in Canoga Park, California, 
unindicted co-conspirator #42 possessed approximately 453.19 grams of 
methamphetamine and approximately 206.23 grams of heroin to 
distribute to drug customers. 
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Overt Act No. 119: 
On May 15, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, asked a drug source of 
supply for a pound of methamphetamine. 
Overt Act No. 120: 
On May 16, 2020, defendant FLACK, using 
coded language in a Facebook message exchange, asked to purchase an 
ounce of drugs from unindicted co-conspirator #23 for $600. 
Overt Act No. 121: 
On May 21, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, asked unindicted co-
conspirator #22 if defendant HAVILAND presently had drugs available 
to distribute. 
Overt Act No. 122: 
On June 16, 2020, defendant WINTERS, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that he had identified a drug source of supply who was able 
to supply high-quality heroin at a good price. 
Overt Act No. 123: 
On June 17, 2020, defendants ATKINSON, B. 
EKELUND, and IBARRA attempted to enter the United States from Mexico 
at the Calexico, California, West Port of Entry with approximately 
113.39 grams of methamphetamine and $5,000 concealed in their 
vehicle. 
Overt Act No. 124: 
On June 17, 2020, defendant ATKINSON 
possessed $10,000 in cash while attempting to enter the United States 
via Mexico. 
Overt Act No. 125: 
On June 17, 2020, defendant B. EKELUND 
possessed $12,300 in cash while attempting to enter the United States 
via Mexico. 
Overt Act No. 126: 
On June 17, 2020, defendant IBARRA concealed 
approximately 2.39 grams of Xanax and approximately 2.21 grams of 
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heroin in her body cavity while attempting to enter the United States 
via Mexico. 
Overt Act No. 127: 
On June 20, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #22 that she had methamphetamine available to distribute. 
Overt Act No. 128: 
On June 22, 2020, defendant MUNOZ, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #22 that she had methamphetamine available to distribute. 
Overt Act No. 129: 
On July 4, 2020, defendant C. POLLAY, using 
coded language in a Facebook message exchange, ordered an ounce of 
fentanyl from unindicted co-conspirator #47. 
Overt Act No. 130: 
On July 7, 2020, defendant SMITH, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #48 that he had heroin available to distribute. 
Overt Act No. 131: 
On August 4, 2020, defendant VILLATORO 
possessed approximately 211.82 grams of methamphetamine, depicted in 
the below photographs, to distribute to drug customers, as well as a 
firearm in a motel room in Van Nuys, California. 
 
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Overt Act No. 132: 
On August 11, 2020, defendant CRAIG, using 
coded language in a Facebook message exchange, sent to defendant 
GLUCKMAN the photograph depicted below of M30 pills that he had 
available to distribute: 
 
 
Overt Act No. 133: 
On August 22, 2020, defendant C. POLLAY, 
using coded language in a Facebook message exchange, ordered $450 of 
fentanyl as well as a quantity of methamphetamine from unindicted co-
conspirator #43. 
Overt Act No. 134: 
On August 26, 2020, defendant SMITH, in a 
Facebook message exchange, sent defendant WINTERS a photograph, 
depicted below, of a firearm that he possessed. 
 
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Overt Act No. 135: 
On August 26, 2020, defendant C. POLLAY, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #43 that he was in Hollywood obtaining GHB, fentanyl, 
and methamphetamine to distribute to drug customers. 
Overt Act No. 136: 
On August 29, 2020, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant WINTERS 
that he had a large quantity of heroin available to distribute. 
Overt Act No. 137: 
On August 29, 2020, defendant WINTERS, using 
coded language in a Facebook message exchange, told defendant SMITH 
that he also had heroin available to distribute. 
Overt Act No. 138: 
On September 2, 2020, defendant SHAPIRO 
possessed approximately 218.97 grams of methamphetamine to distribute 
to drug customers in a vehicle that he was driving in Canoga Park, 
California. 
Overt Act No. 139: 
On September 2, 2020, defendant CRAIG 
possessed approximately an ounce of methamphetamine to distribute to 
drug customers in a vehicle that he was driving in Newhall, 
California. 
Overt Act No. 140: 
On September 11, 2020, defendant RAVIN, 
using coded language in a Facebook message exchange, offered to 
supply methamphetamine to unindicted co-conspirator #44. 
Overt Act No. 141: 
On October 2, 2020, defendant VAN VLYMEN 
possessed approximately 11.06 grams of methamphetamine to distribute 
to drug customers, a digital scale, and drug packaging material in a 
vehicle that she was driving in Woodland Hills, California. 
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Overt Act No. 142: 
On October 5, 2020, unindicted co-
conspirator #50, using coded language in a Facebook message exchange, 
offered to sell an AR-15 “ghost gun” with an ammunition clip, 
depicted in the photographs below, to defendant CUNNINGHAM for 
$1,400. 
 
Overt Act No. 143: 
On October 6, 2020, defendant DIETZEN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #44 that he was obtaining additional drugs to distribute 
to customers from a drug source of supply. 
Overt Act No. 144: 
On October 7, 2020, unindicted co-
conspirator #43, using coded language in a Facebook message exchange, 
told defendant C. POLLAY that defendant C. POLLAY owed unindicted co-
conspirator #43 $1,840 in connection with defendant C. POLLAY’s drug 
distribution activities. 
Overt Act No. 145: 
On October 15, 2020, defendant IBARRA, using 
coded language in a Facebook message exchange, identified for 
unindicted co-conspirator #43 a drug source of supply who would sell 
three units of heroin at a price of $425 a unit to unindicted co-
conspirator #43. 
Overt Act No. 146: 
On October 25, 2020, unindicted co-
conspirator #42, using coded language in a Facebook message exchange, 
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told defendant WATSTEIN that the price of half an ounce of heroin was 
$325. 
Overt Act No. 147: 
On October 31, 2020, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant WINTERS 
that he had high quality cocaine available to distribute. 
Overt Act No. 148: 
On November 2, 2020, defendant IBARRA, using 
coded language in a Facebook message exchange, told a drug customer 
that she needed to obtain heroin to distribute from a drug source of 
supply. 
Overt Act No. 149: 
On November 11, 2020, defendant JACOBS, 
using coded language in a Facebook message exchange, told defendant 
WATSTEIN that she needed $450 to obtain more drugs from a drug source 
of supply. 
Overt Act No. 150: 
On November 11, 2020, defendant YACOUB 
possessed methamphetamine, heroin, and cocaine base to distribute to 
customers, a digital scale, and $520 in drug distribution proceeds in 
Littlerock, California. 
Overt Act No. 151: 
On November 28, 2020, defendant DIETZEN, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #44 to meet him at a drug stash house located on 9400 
Valjean Avenue in North Hills, California. 
Overt Act No. 152: 
On December 5, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $600 via Cash App. 
Overt Act No. 153: 
On December 6, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $600 via Cash App. 
Overt Act No. 154: 
On December 9, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $400 via Cash App. 
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Overt Act No. 155: 
On December 10, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $200 via Cash App. 
Overt Act No. 156: 
On December 14, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $600 via Cash App. 
Overt Act No. 157: 
On December 16, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $100 via Cash App. 
Overt Act No. 158: 
On December 17, 2020, defendant HILL and 
unindicted co-conspirator #21, using coded language in a Facebook 
message exchange, ordered fentanyl from defendant JACOBS. 
Overt Act No. 159: 
On December 18, 2020, defendant SHAPIRO sent 
unindicted co-conspirator #42 $100 via Cash App. 
Overt Act No. 160: 
On December 24, 2020, unindicted co-
conspirator #21, using coded language in a Facebook message exchange, 
ordered fentanyl from defendant JACOBS. 
Overt Act No. 161: 
On December 29, 2020, defendant WATSTEIN, 
using coded language in a Facebook message exchange, told defendant 
UTSLER that he needed a pound of methamphetamine to distribute to 
customers. 
Overt Act No. 162: 
On December 29, 2020, defendant UTSLER, 
using coded language in a Facebook message exchange, told a drug 
customer that she had methamphetamine available to distribute to 
customers.     
Overt Act No. 163: 
On December 31, 2020, defendant CRAIG, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #47 that he was purchasing pounds of drugs from a drug 
source of supply for $1,900. 
Overt Act No. 164: 
On December 31, 2020, unindicted co-
conspirator #47, using coded language in a Facebook message exchange, 
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told defendant CRAIG that she was able to sell pounds of high-quality 
drugs at a price of $1,850 a pound. 
Overt Act No. 165: 
On December 31, 2020, defendant CRAIG, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #47 that he wanted to obtain an ounce sample of drugs 
from her in order to see if he wanted to purchase pounds of drugs 
from her in the future. 
Overt Act No. 166: 
On January 1, 2021, defendant JACOBS, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #21 that she had fentanyl available to distribute to 
customers. 
Overt Act No. 167: 
On January 2, 2021, unindicted co-
conspirator #41, using coded language in a Facebook message exchange, 
told defendant IBARRA that he needed to obtain two ounces of 
methamphetamine from a drug source of supply. 
Overt Act No. 168: 
On January 2, 2021, defendant IBARRA, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #41 that she was able to obtain drugs to distribute from 
both defendant B. EKELUND as well as unindicted co-conspirator #42. 
Overt Act No. 169: 
On January 3, 2021, defendant WATSTEIN, 
using coded language in a Facebook message exchange, told defendant 
UTSLER that he needed an ounce of high-quality methamphetamine. 
Overt Act No. 170: 
On January 7, 2021, defendant WATSTEIN, 
using coded language in a Facebook message exchange, ordered heroin 
and an ounce of methamphetamine from unindicted co-conspirator #42. 
Overt Act No. 171: 
On January 15, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, told defendant 
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RAVIN that he would let her know when he obtained heroin from a drug 
source of supply. 
Overt Act No. 172: 
On January 15, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, identified a 
drug customer that wanted to obtain a half an ounce of 
methamphetamine from a drug source of supply. 
Overt Act No. 173: 
On January 22, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $1,100 via Cash App. 
Overt Act No. 174: 
On January 26, 2021, unindicted co-
conspirator #42, using coded language in a Facebook message exchange, 
told defendant BENEDICT that she owed unindicted co-conspirator #42 
$890 in connection with a drug transaction. 
Overt Act No. 175: 
On January 27, 2021, defendant C. POLLAY, 
using coded language in a Facebook message exchange, ordered an ounce 
of fentanyl from defendant WATSTEIN and stated that he was willing to 
pay $1,300 for the drugs. 
Overt Act No. 176: 
On January 27, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $220 via Cash App. 
Overt Act No. 177: 
On January 30, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, offered to 
supply methamphetamine to defendant SMITH in exchange for a copy of 
the Woodland Hills counterfeit postal mail key. 
Overt Act No. 178: 
On January 30, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, identified for 
defendant SCHWARTZ the counterfeit postal mail keys that defendant 
SMITH possessed. 
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Overt Act No. 179: 
On February 2, 2021, defendant BENEDICT, 
using coded language in a Facebook message exchange, ordered $175 of 
fentanyl from unindicted co-conspirator #42. 
Overt Act No. 180: 
On February 5, 2021, defendant WATSTEIN, 
using coded language in a Facebook message exchange, told defendant 
C. POLLAY that he had fentanyl available to distribute.   
Overt Act No. 181: 
On February 5, 2021, defendant C. POLLAY, 
using coded language in a Facebook message exchange, ordered an ounce 
of heroin from defendant WATSTEIN to distribute to drug customers. 
Overt Act No. 182: 
On February 6, 2021, defendant RAVIN, using 
coded language in a Facebook message exchange, identified a drug 
customer that needed to obtain heroin from unindicted co-conspirator 
#44. 
Overt Act No. 183: 
On February 7, 2021, defendant WATSTEIN, 
using coded language in a Facebook message exchange, ordered an ounce 
of methamphetamine from defendant UTSLER. 
Overt Act No. 184: 
On February 15, 2021, defendant C. POLLAY, 
using coded language in a Facebook message exchange, ordered half an 
ounce of fentanyl from defendant WATSTEIN. 
Overt Act No. 185: 
On February 15, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $220 via Cash App. 
Overt Act No. 186: 
On February 18, 2021, defendant GLUCKMAN, 
using coded language in a Facebook message exchange, asked defendant 
SLACK to supply him with an ounce of drugs in exchange for money that 
defendant GLUCKMAN was generating for defendant SLACK in connection 
with fraud. 
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Overt Act No. 187: 
On February 23, 2021, defendant BENEDICT, 
using coded language in a Facebook message exchange, ordered 
methamphetamine from unindicted co-conspirator #42. 
Overt Act No. 188: 
On February 24, 2021, defendant JACOBS, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #21 that she was obtaining an ounce of fentanyl to 
distribute to customers from a drug source of supply. 
Overt Act No. 189: 
On February 24, 2021, defendant WATSTEIN, 
using coded language in a Facebook message exchange, ordered two 
ounces of methamphetamine from unindicted co-conspirator #43. 
Overt Act No. 190: 
On February 24, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, told defendant 
SMITH that he had sold a rifle that belonged to defendant SMITH to a 
customer for $700 and that defendant SCHWARTZ would take $100 in 
connection with the firearm sale. 
Overt Act No. 191: 
On February 27, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $400 via Cash App. 
Overt Act No. 192: 
On March 5, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $610 via Cash App. 
Overt Act No. 193: 
On March 6, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $250 via Cash App. 
Overt Act No. 194: 
On March 7, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant 
SCHWARTZ that he had high-quality fentanyl available to distribute. 
Overt Act No. 195: 
On March 12, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $750 via Cash App. 
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Overt Act No. 196: 
On March 14, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told defendant SWINK 
that he presently had methamphetamine to distribute. 
Overt Act No. 197: 
On March 14, 2021, defendant SWINK, using 
coded language in a Facebook message exchange, offered to sell 
defendant GLUCKMAN counterfeit $100 bills. 
Overt Act No. 198: 
On March 17, 2021, defendant GLUCKMAN, in a 
Facebook message exchange, sent unindicted co-conspirator #43 the 
photograph depicted below of a firearm to which he had access.   
 
Overt Act No. 199: 
On March 19, 2021, defendant SWINK posted a 
copy of a law enforcement report involving her, K.R., and H.C. to the 
SFV Facebook Page, and stated the following: 
Just in case anyone comes across [K.R.] or [H.C.] just know that this 
shit happened.  Gave all kinds of statements to the cops and blamed 
all his shit on me.  Just got out after doing 16 months.  Not to 
mention he’s going around telling people his name is bam bam SFV.  
Yep real quality person.  Just thought I’d let you all know. 
 
Overt Act No. 200: 
In response to defendant SWINK’s Facebook 
post regarding K.R., defendant FRANCIS posted to the SFV Facebook 
Page: 
[K.R.] is a piece of shit.  I can’t wait for the real Bam gets out of 
prison and sells him to the nigs for using his name. 
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Overt Act No. 201: 
On March 19, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, ordered 
methamphetamine from unindicted co-conspirator #43. 
Overt Act No. 202: 
On March 20, 2021, defendant WINTERS, using 
coded language in a Facebook message exchange, stated that he would 
arm himself and meet with defendant LEIMERT at a location in Los 
Angeles, California. 
Overt Act No. 203: 
On March 21, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, told defendant C. 
POLLAY that he had high-quality fentanyl available to distribute. 
Overt Act No. 204: 
On March 22, 2021, in Los Angeles, 
California, unindicted co-conspirator #43 possessed approximately 
397.3 grams of methamphetamine that was 100% pure, 247 grams of 
heroin, and 12 grams of a mixture or substance containing a 
detectable amount fentanyl to distribute to drug customers. 
Overt Act No. 205: 
On March 22, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $400 via Cash App. 
Overt Act No. 206: 
On March 24, 2021, defendant BREWER sent 
defendant RAMACHANDRAN $2,000 via Cash App. 
Overt Act No. 207: 
On May 26, 2021, defendant BENEDICT, using 
coded language in a Facebook message exchange, agreed to supply 
heroin to defendant SCHWARTZ. 
Overt Act No. 208: 
On March 27, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $260 via Cash App. 
Overt Act No. 209: 
On March 28, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $800 via Cash App. 
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Overt Act No. 210: 
On March 29, 2021, unindicted co-conspirator 
#2 and unindicted co-conspirator #16, using coded language in a 
Facebook message exchange, directed defendant GLUCKMAN to obtain five 
pistols and two rifles. 
Overt Act No. 211: 
On March 30, 2021, defendant CRAIG agreed to 
sell a drug customer half an ounce of drugs for $300. 
Overt Act No. 212: 
On April 2, 2021, defendant CRAIG, using 
coded language in a Facebook message exchange, agreed to sell heroin 
to defendant RAVIN. 
Overt Act No. 213: 
On April 3, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, ordered six ounces of 
methamphetamine from unindicted co-conspirator #43. 
Overt Act No. 214: 
On April 5, 2021, defendant SWINK, using 
coded language in a Facebook message exchange, asked to purchase two 
ounces of drugs from defendant GLUCKMAN. 
Overt Act No. 215: 
On April 8, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #43 that a drug customer wanted to purchase nine ounces 
of methamphetamine. 
Overt Act No. 216: 
On April 11, 2021, unindicted co-conspirator 
#43 sent defendant WATSTEIN $100 via Cash App. 
Overt Act No. 217: 
On April 13, 2021, unindicted co-conspirator 
#42, using coded language in a Facebook message exchange, discussed 
with defendant BENEDICT drugs that she had stored on his behalf at 
her residence, and complained that he was missing a quarter of a 
pound of methamphetamine and 100 Xanax pills. 
Overt Act No. 218: 
On April 14, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, told unindicted co-
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conspirator #43 that he saw law enforcement in the area and, as a 
result, “lost fucking a backpack full of cash and dope and few guns” 
that defendant SMITH was holding for his drug source of supply. 
Overt Act No. 219: 
On April 17, 2021, defendant SMITH sent 
unindicted co-conspirator #43 $200 via Cash App. 
Overt Act No. 220: 
On April 18, 2021, defendant SMITH sent 
unindicted co-conspirator #43 $150 via Cash App. 
Overt Act No. 221: 
On April 19, 2021, defendant SMITH sent 
unindicted co-conspirator #43 $200 via Cash App. 
Overt Act No. 222: 
On April 19, 2021, defendant WINTERS sent 
defendant SWINK $1,000 via Cash App and indicated that the money was 
on behalf of unindicted co-conspirator #2. 
Overt Act No. 223: 
On April 19, 2021, unindicted co-conspirator 
#43 sent defendant WATSTEIN $200 via Cash App. 
Overt Act No. 224: 
On April 26, 2021, defendant LEIMERT, using 
coded language in a Facebook message exchange, ordered an ounce of 
heroin and an ounce of methamphetamine from unindicted co-conspirator 
#42. 
Overt Act No. 225: 
On April 28, 2021, defendant BENEDICT, using 
coded language in a Facebook message exchange, ordered an ounce of 
methamphetamine from unindicted co-conspirator #42. 
Overt Act No. 226: 
On April 29, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #42 that he would send unindicted co-conspirator #42 
$3,300 in connection with a drug transaction. 
Overt Act No. 227: 
On May 3, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $500 via Cash App. 
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Overt Act No. 228: 
On May 6, 2021, defendant WATSTEIN, using 
coded language in a Facebook message exchange, ordered five ounces of 
methamphetamine from unindicted co-conspirator #43. 
Overt Act No. 229: 
On May 9, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that he needed to obtain nine ounces of heroin to 
distribute to customers. 
Overt Act No. 230: 
On May 9, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that he had attempted to contact defendant BENEDICT 
to obtain the heroin to distribute and said that he planned to 
contact unindicted co-conspirator #42. 
Overt Act No. 231: 
On May 9, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that unindicted co-conspirator #41 had high-quality 
methamphetamine to distribute, and sent defendant IBARRA the below 
picture of the drugs: 
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Overt Act No. 232: 
On May 10, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant 
GLUCKMAN that defendant SMITH had high-quality heroin and 
methamphetamine available to distribute. 
Overt Act No. 233: 
On May 11, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $300 via Cash App. 
Overt Act No. 234: 
On May 12, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $500 via Cash App. 
Overt Act No. 235: 
On May 17, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that he was able to supply her and others with high-
quality methamphetamine to distribute to customers at a price of 
$1,350 a pound. 
Overt Act No. 236: 
On May 20, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $500 via Cash App. 
Overt Act No. 237: 
On May 26, 2021, defendant BENEDICT told 
defendant SCHWARTZ that she had heroin available to sell. 
Overt Act No. 238: 
On May 27, 2021, unindicted co-conspirator 
#23, using coded language in a Facebook message exchange, warned 
defendant FLACK that federal law enforcement agents had searched her 
residence and business. 
Overt Act No. 239: 
On May 27, 2021, defendant IBARRA, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #41 that defendant B. EKELUND was able to supply two 
ounces of heroin to a drug customer. 
Overt Act No. 240: 
On May 28, 2021, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant JACOBS 
that he had high-quality fentanyl available to distribute. 
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Overt Act No. 241: 
On June 2, 2021, defendant SHAPIRO, using 
coded language in a Facebook message exchange, ordered an ounce of 
heroin from defendant WATSTEIN and explained to defendant WATSTEIN 
that he could not get the drugs from unindicted co-conspirator #42 
because unindicted co-conspirator #42 was incarcerated. 
Overt Act No. 242: 
On June 10, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, agreed to supply an 
ounce of methamphetamine to defendant WINTERS. 
Overt Act No. 243: 
On June 11, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $300 via Cash App. 
Overt Act No. 244: 
On June 11, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $550 via Cash App. 
Overt Act No. 245: 
On June 16, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #41 that he had sent unindicted co-conspirator #41 $100 
for an ounce of drugs via Cash App. 
Overt Act No. 246: 
On June 19, 2021, defendant SWINK, using 
coded language in a Facebook message exchange, told defendant 
GLUCKMAN that she would distribute an ounce of heroin to customers 
and share the drug distribution proceeds with defendant GLUCKMAN. 
Overt Act No. 247: 
On June 22, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $120 via Cash App. 
Overt Act No. 248: 
On June 23, 2021, unindicted co-conspirator 
#42, using coded language in a Facebook message exchange, told 
defendant BENEDICT that he had just obtained additional drugs to 
distribute from a source of supply. 
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Overt Act No. 249: 
On June 23, 2021, defendant BENEDICT, using 
coded language in a Facebook message exchange, ordered heroin to 
distribute from a drug source of supply. 
Overt Act No. 250: 
On June 24, 2021, unindicted co-conspirator 
#42, using coded language in a Facebook message exchange, asked 
defendant BENEDICT to send money to him via Zelle that she owed in 
connection with her drug distribution activities and told her that 
the amount that she presently owed him was $1,250. 
Overt Act No. 251: 
On July 1, 2021, defendant BENEDICT, using 
coded language in a Facebook message exchange, ordered 
methamphetamine from unindicted co-conspirator #42. 
Overt Act No. 252: 
On July 3, 2021, defendant BENEDICT, using 
coded language in a Facebook message exchange, directed unindicted 
co-conspirator #42 to supply a quarter of a pound of methamphetamine 
to a drug customer. 
Overt Act No. 253: 
On July 4, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that he had sent her $1,050 via Cash App in 
connection with a prior drug transaction with defendant B. EKELUND. 
Overt Act No. 254: 
On July 4, 2021, unindicted co-conspirator 
#41 sent defendant IBARRA the following Facebook message: “Someone is 
oding[.] You have that shit to bring them back[?]” 
Overt Act No. 255: 
On July 4, 2021, in response to unindicted 
co-conspirator #41’s question, defendant IBARRA sent unindicted co-
conspirator #41 the following Facebook message: “Yes[.] At my pad[.]” 
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Overt Act No. 256: 
On July 16, 2021, unindicted co-conspirator 
#41, using coded language in a Facebook message exchange, told 
defendant IBARRA that he had generated $20,000 in drug distribution 
proceeds and had money to obtain methamphetamine from defendant B. 
EKELUND, and sent defendant IBARRA the below photograph: 
 
Overt Act No. 257: 
On July 17, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant WINTERS 
that he had high-quality heroin and methamphetamine available to 
distribute. 
Overt Act No. 258: 
On July 17, 2021, defendant LEIMERT sent 
unindicted co-conspirator #42 $1,000 via Cash App. 
Overt Act No. 259: 
On July 21, 2021, unindicted co-conspirator 
#50, using coded language in a Facebook message exchange, complained 
about the quality of an ounce of methamphetamine that defendant 
CUNNINGHAM had supplied and asked for him to supply a replacement 
quantity of methamphetamine. 
Overt Act No. 260: 
On July 23, 2021, defendant LEIMERT, using 
coded language in a Facebook message exchange, ordered an ounce of 
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heroin and an ounce of methamphetamine from unindicted co-conspirator 
#42. 
Overt Act No. 261: 
On July 23, 2021, defendant SCHWARTZ, using 
coded language in a Facebook message exchange, agreed to supply 
methamphetamine and heroin to a drug customer. 
Overt Act No. 262: 
On July 23, 2021, defendant LEIMERT, using 
coded language in a Facebook message exchange, ordered an ounce of 
heroin and an ounce of methamphetamine from unindicted co-conspirator 
#42. 
Overt Act No. 263: 
On July 24, 2021, defendant C. POLLAY, using 
coded language in a Facebook message exchange, sent defendant 
GLUCKMAN photographs of a credit card stolen from victim T.H. so that 
defendant GLUCKMAN could activate the stolen credit card and share 
money obtained from the card with defendant C. POLLAY. 
Overt Act No. 264: 
On July 26, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant 
SCHWARTZ that he had methamphetamine available to distribute to 
customers. 
Overt Act No. 265: 
On July 27, 2021, defendant UTSLER, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #52 that she had a pound of high-quality methamphetamine 
available to distribute to customers. 
Overt Act No. 266: 
On July 29, 2021, defendant SHAPRIO, using 
coded language in a Facebook message exchange, agreed to bring a 
scale to a meeting with unindicted co-conspirator #42 so that 
unindicted co-conspirator #42 could weigh out the drugs that he was 
going to supply to defendant SHAPIRO. 
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Overt Act No. 267: 
On July 29, 2021, defendant RAVIN, using 
coded language in a Facebook message exchange, told defendant 
CUNNINGHAM that she had a quarter of a pound of methamphetamine 
available to distribute but could not sell the methamphetamine for 
less than $450. 
Overt Act No. 268: 
On July 30, 2021, defendant SCHWARTZ, using 
coded language in a Facebook message exchange, agreed to supply 
methamphetamine to a drug customer. 
Overt Act No. 269: 
On July 30, 2021, defendant UTSLER, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #52 that defendant UTSLER had identified a drug customer 
who was willing to purchase half an ounce of methamphetamine for 
$140, 
Overt Act No. 270: 
On August 4, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $300 via Cash App. 
Overt Act No. 271: 
On August 7, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $250 via Cash App.  
Overt Act No. 272: 
On August 18, 2021, defendant SHAPIRO sent 
unindicted co-conspirator #42 $500 via Cash App. 
Overt Act No. 273: 
On August 31, 2021, defendant PAYER, using 
coded language in a Facebook message exchange, asked defendant 
VILLATORO if he had fentanyl available to distribute and told 
defendant VILLATORO that he was selling a quarter to a half an ounce 
of fentanyl to drug customers each day. 
Overt Act No. 274: 
On September 3, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, asked unindicted 
co-conspirator #40 if he had fentanyl available to distribute. 
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Overt Act No. 275: 
On September 7, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, asked to 
purchase a pound of drugs from unindicted co-conspirator #50 for 
$1,100. 
Overt Act No. 276: 
On September 7, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #40 that he had 2,000 M30 oxycodone pills valued at 
$12,000 available to distribute to customers. 
Overt Act No. 277: 
On September 7, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told defendant 
PAYER that he had 2,000 M30 oxycodone pills valued at $12,000 
available to distribute to customers. 
Overt Act No. 278: 
On September 7, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #50 that he had 2,000 M30 oxycodone pills valued at 
$12,000 available to distribute to customers. 
Overt Act No. 279: 
On September 7, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, offered to sell 
unindicted co-conspirator #45 a pound of methamphetamine for $1,300. 
Overt Act No. 280: 
On September 10, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $1,100 via Cash App.  
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Overt Act No. 281: 
On September 11, 2021, defendant JACOBS, 
using coded language in a Facebook message exchange, told defendant 
GLUCKMAN that she had high-quality methamphetamine available to 
distribute and sent defendant GLUCKMAN a photograph of the drugs she 
possessed, depicted below. 
 
Overt Act No. 282: 
On September 13, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #50 that he had high-quality methamphetamine available 
to distribute. 
Overt Act No. 283: 
On September 14, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told defendant 
PAYER that he had methamphetamine available to distribute. 
Overt Act No. 284: 
On September 15, 2021, defendant UTSLER, 
using coded language in a Facebook message exchange, told a drug 
customer that she had methamphetamine and Xanax available to 
distribute. 
Overt Act No. 285: 
On September 15, 2021, unindicted co-
conspirator #40, using coded language in a Facebook message exchange, 
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warned defendant VILLATORO that an individual cooperating with law 
enforcement was involved in their drug distribution activities. 
Overt Act No. 286: 
On September 15, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $400 via Cash App. 
Overt Act No. 287: 
On September 19, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #50 that he had two pounds of methamphetamine 
available to distribute. 
Overt Act No. 288: 
On September 19, 2021, unindicted co-
conspirator #50, using coded language in a Facebook message exchange, 
told defendant VILLATORO that she had GHB available to distribute, 
depicted in the below photograph. 
 
Overt Act No. 289: 
On September 20, 2021, defendant YACOUB 
possessed a firearm as well as drugs to distribute to customers. 
Overt Act No. 290: 
On September 20, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, offered to sell 
unindicted co-conspirator #40 two pounds of drugs for $1,800. 
Overt Act No. 291: 
On September 26, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $1,450 via Cash App. 
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Overt Act No. 292: 
On September 29, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, agreed to supply 
heroin to a drug customer. 
Overt Act No. 293: 
On October 1, 2021, defendant UTSLER, using 
coded language in a Facebook message exchange, directed to sell a 
quarter of an ounce of methamphetamine to a drug customer for no less 
than $60 and no more than $80. 
Overt Act No. 294: 
On October 3, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $400 via Cash App. 
Overt Act No. 295: 
On October 5, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $600 via Cash App. 
Overt Act No. 296: 
On October 5, 2021, defendant RAVIN, using 
coded language in a Facebook message exchange, asked if defendant 
SCHWARTZ wanted to trade any heroin that he possessed with a quantity 
of methamphetamine that she possessed. 
Overt Act No. 297: 
On October 7, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $200 via Cash App. 
Overt Act No. 298: 
On October 9, 2021, defendant UTSLER, using 
coded language in a Facebook message exchange, told a drug customer 
that she was with defendant CRISWELL and that she had nearly an ounce 
of methamphetamine available to distribute. 
Overt Act No. 299: 
On October 10, 2021, defendant LEIMERT, 
using coded language in a Facebook message exchange, told defendant 
BINGAMAN that he was able to supply heroin. 
Overt Act No. 300: 
On October 12, 2021, defendant MULVIHILL 
sent unindicted co-conspirator #47 $700 via Cash App. 
Overt Act No. 301: 
On October 13, 2021, unindicted co-
conspirator #41 sent defendant SCHULTZ $970 via Cash App. 
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Overt Act No. 302: 
On October 15, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #40 that he had fifteen pounds of high-quality drugs 
to distribute. 
Overt Act No. 303: 
On October 16, 2021, defendant VILLATORO, 
using coded language in a Facebook message exchange, told defendant 
PAYER that he had PCP available to distribute to customers. 
Overt Act No. 304: 
On October 22, 2021, defendant SHAPIRO sent 
defendant B. EKELUND $950 via Cash App. 
Overt Act No. 305: 
On October 30, 2021, defendant LEIMERT, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #42 that he had money and needed to obtain additional 
drugs to distribute to customers. 
Overt Act No. 306: 
On November 6, 2021, defendant SCHULTZ sent 
defendant RAMACHANDRAN $1,000 via Cash App. 
Overt Act No. 307: 
On November 10, 2021, defendant UTSLER, 
using coded language in a Facebook message exchange, asked a drug 
source of supply for the price of half a pound of methamphetamine. 
Overt Act No. 308: 
On November 11, 2021, defendant BINGAMAN, 
using coded language in a Facebook message exchange, told a drug 
customer that he had high-quality heroin available to distribute. 
Overt Act No. 309: 
On November 12, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, ordered half a 
pound of methamphetamine from unindicted co-conspirator #23. 
Overt Act No. 310: 
On November 13, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, complained that 
the half of pound of methamphetamine that she and unindicted co-
conspirator #46 had supplied the previous day was “way short.” 
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Overt Act No. 311: 
On November 13, 2021, unindicted co-
conspirator #23, using coded language in a Facebook message exchange, 
explained to defendant SCHWARTZ that the scale that unindicted co-
conspirator #46 had used to weigh out the half pound of 
methamphetamine needed to be recalibrated and that unindicted co-
conspirator #46 had made an error when he had weighed out the drugs. 
Overt Act No. 312: 
On November 14, 2021, defendant MULVIHILL 
sent unindicted co-conspirator #47 $1,600 via Cash App. 
Overt Act No. 313: 
On November 21, 2021, defendant WATTS, using 
coded language in a Facebook message exchange, asked defendant PAYER 
to direct any heroin customers to defendant WATTS, and defendant 
WATTS offered to direct any fentanyl customers to defendant PAYER. 
Overt Act No. 314: 
On November 22, 2021, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant WATTS 
that he had heroin customers in Northeast Los Angeles that he would 
send to defendant WATTS. 
Overt Act No. 315: 
On November 22, 2021, defendant WATTS, using 
coded language in a Facebook message exchange, told defendant PAYER 
that he sold heroin at a price of $325 a half an ounce and $650 for 
an ounce. 
Overt Act No. 316: 
On November 22, 2021, defendant SCHULTZ sent 
defendant RAMACHANDRAN $1,000 via Cash App. 
Overt Act No. 317: 
On November 25, 2021, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant WATTS 
that he planned to meet with his drug source of supply. 
Overt Act No. 318: 
On November 26, 2021, defendant B. EKELUND 
sent defendant RAMACHANDRAN $500 via Cash App. 
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Overt Act No. 319: 
On December 5, 2021, defendant SLAYTON and 
unindicted co-conspirator #48, using coded language in a Facebook 
message exchange, agreed that defendant GLUCKMAN was an “idiot” for 
“play[ing] games with [B]rand members.” 
Overt Act No. 320: 
On December 7, 2021, defendant BINGAMAN, 
using coded language in a Facebook message exchange, ordered fentanyl 
from defendant SMITH. 
Overt Act No. 321: 
On December 23, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, sent defendant 
GLUCKMAN photographs of high-end stolen merchandise that he had 
available to sell and told defendant GLUCKMAN that he had obtained 
the items from a “smash-and-grab” at a shopping center in Canoga 
Park, California. 
Overt Act No. 322: 
On December 23, 2021, defendant SMITH, using 
coded language in a Facebook message exchange, asked defendant 
GLUCKMAN to provide him with a stolen credit card number so that he 
could obtain a rental car. 
Overt Act No. 323: 
On December 25, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #23 that he had a 9mm firearm, depicted below, 
available to sell to her or unindicted co-conspirator #46. 
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Overt Act No. 324: 
On December 26, 2021, defendant BECKWITH, 
using coded language in a Facebook message exchange, told defendant 
PAYER that she was in Hemet, California selling fentanyl to drug 
customers. 
Overt Act No. 325: 
On December 26, 2021, defendant B. EKELUND 
sent defendant RAMACHANDRAN $500 via Cash App. 
Overt Act No. 326: 
On December 27, 2021, defendant BINGAMAN, 
using coded language in a Facebook message exchange, told defendant 
BECKWITH that he was able to obtain ounces of fentanyl for $700 to 
$800 an ounce. 
Overt Act No. 327: 
On December 27, 2021, defendant BECKWITH, 
using coded language in a Facebook message exchange, told defendant 
BINGAMAN that drug customers in Hemet, California were paying $120 a 
gram for fentanyl and that she and defendant BINGAMAN could sell one 
to two ounces of fentanyl a day if they worked together. 
Overt Act No. 328: 
On December 31, 2021, defendant MULVIHILL 
sent unindicted co-conspirator #47 $900 via Cash App. 
Overt Act No. 329: 
On December 31, 2021, defendant SCHWARTZ, 
using coded language in a Facebook message exchange, told unindicted 
co-conspirator #23 that he had given unindicted co-conspirator #23’s 
name to a drug customer as the drug customer needed a new source of 
supply. 
Overt Act No. 330: 
On January 1, 2022, defendant MULVIHILL sent 
unindicted co-conspirator #47 $100 via Cash App. 
Overt Act No. 331: 
On January 1, 2022, unindicted co-
conspirator #47 sent defendant MULVIHILL $250 via Cash App. 
Overt Act No. 332: 
On January 2, 2022, defendant MULVIHILL sent 
unindicted co-conspirator #47 $150 via Cash App. 
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Overt Act No. 333: 
On January 3, 2022, defendant MULVIHILL sent 
unindicted co-conspirator #47 $500 via Cash App. 
Overt Act No. 334: 
On January 4, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #48 that he had methamphetamine and fentanyl available to 
distribute to customers. 
Overt Act No. 335: 
On January 6, 2022, defendant BINGAMAN, 
using coded language in a Facebook message exchange, told defendant 
BREWER that he had access to oxycodone to distribute to drug 
customers. 
Overt Act No. 336: 
On January 6, 2022, unindicted co-
conspirator #41 sent defendant SCHULTZ $1,200 via Cash App. 
Overt Act No. 337: 
On January 7, 2022, defendant CRAIG, using 
coded language in a Facebook message exchange, agreed to supply 
heroin to defendant SILVERBERG. 
Overt Act No. 338: 
On January 7, 2022, defendant WATSTEIN, 
using coded language in a Facebook message exchange, told defendant 
CRAIG that he had heroin available to distribute. 
Overt Act No. 339: 
On January 9, 2022, defendant UTSLER, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #49 that he could use her Bank of America bank account to 
cash counterfeit checks that he printed. 
Overt Act No. 340: 
On January 10, 2022, defendant LEIMERT 
possessed approximately 109.24 grams of methamphetamine and 18.46 
grams of heroin to distribute to drug customers in a vehicle that he 
was driving in Palmdale, California. 
Overt Act No. 341: 
On January 11, 2022, defendant SMITH, using 
coded language in a Facebook message exchange, asked defendant 
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GLUCKMAN to help him generate money using stolen business bank 
account numbers. 
Overt Act No. 342: 
On January 18, 2022, unindicted co-
conspirator #41 sent defendant SCHULTZ $500 via Cash App. 
Overt Act No. 343: 
On January 24, 2022, defendant BECKWITH, 
using coded language in a Facebook message exchange, sent a drug 
customer a picture of purple fentanyl that she had available to 
distribute, depicted below: 
 
Overt Act No. 344: 
On January 31, 2022, defendant UTSLER 
possessed a knife, a loaded firearm, and methamphetamine while 
driving a vehicle in Northridge, California. 
Overt Act No. 345: 
On February 1, 2022, defendant SILVERBERG, 
using coded language in a Facebook message exchange, told defendant 
CRAIG that he had methamphetamine available to distribute. 
Overt Act No. 346: 
On February 3, 2022, defendant EKLUND 
possessed approximately 137.8 grams of methamphetamine and 25.1 grams 
of heroin, as well as $1,169 in cash and a fraudulent California 
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identification card in a vehicle that he was driving in Beverly 
Hills, California. 
Overt Act No. 347: 
On February 6, 2022, defendant GLUCKMAN, 
using coded language in a Facebook message exchange, asked defendant 
JACOBS the current price of an ounce of fentanyl. 
Overt Act No. 348: 
On February 8, 2022, unindicted co-
conspirator #41 sent defendant SCHULTZ $800 via Cash App. 
Overt Act No. 349: 
On February 26, 2022, unindicted co-
conspirator #41 sent defendant SCHULTZ $300 via Cash App. 
Overt Act No. 350: 
On February 28, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #48 that he had access to fentanyl and methamphetamine to 
distribute to drug customers. 
Overt Act No. 351: 
On March 4, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, ordered 
methamphetamine to distribute to customers from defendant VILLATORO. 
Overt Act No. 352: 
On March 7, 2022, defendant WINTERS, using 
coded language in a Facebook message exchange, asked defendant 
LEIMERT to supply him with heroin after defendant LEIMERT obtained a 
quantity of heroin from a source of supply. 
Overt Act No. 353: 
On March 9, 2022, defendant WATTS, using 
coded language in a Facebook message exchange, told defendant PAYER 
that he had high-quality methamphetamine available to distribute to 
customers. 
Overt Act No. 354: 
On March 14, 2022, unindicted co-conspirator 
#41 sent defendant SCHULTZ $1,500 via Cash App. 
Overt Act No. 355: 
On March 21, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant WATTS 
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that defendant SILVERBERG had high quality methamphetamine available 
to distribute to drug customers. 
Overt Act No. 356: 
On March 21, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant WATTS 
that defendant CUNNINGHAM regularly possessed kilograms of fentanyl 
to distribute to customers. 
Overt Act No. 357: 
On March 22, 2022, defendant VILLATORO, 
using coded language in a Facebook message exchange, told defendant 
RAVIN that he had taken seven ounces of methamphetamine and seven 
grams of heroin from a drug dealer to satisfy a drug debt and offered 
to give defendant RAVIN the seven grams of heroin. 
Overt Act No. 358: 
On March 22, 2022, defendant VILLATORO, 
using coded language in a Facebook message exchange, told defendant 
PAYER that he had heroin and methamphetamine available to distribute. 
Overt Act No. 359: 
On March 22, 2022, defendant WATTS, using 
coded language in a Facebook message exchange, asked defendant PAYER 
to “front” him a quantity of fentanyl to distribute to drug 
customers. 
Overt Act No. 360: 
On March 23, 2022, defendant YACOUB 
possessed approximately 20.72 grams of fentanyl, 12.1 grams of 
heroin, and 45.4 grams of methamphetamine to distribute to customers, 
as well as two digital scales, 54 rounds of 9mm ammunition, and 
$1,019 in cash, in his residence and vehicle in Littlerock, 
California. 
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Overt Act No. 361: 
On March 30, 2022, defendant GLUCKMAN 
possessed with intent to distribute approximately 243 grams of 
methamphetamine in a vehicle in Henderson, Nevada, depicted in the 
photograph below. 
 
Overt Act No. 362: 
On March 31, 2022, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #41 that law enforcement officers in Henderson, Nevada 
had obtained a search warrant for defendant GLUCKMAN’s hotel room and 
vehicle, and that he needed to obtain a hotel room immediately to 
avoid law enforcement. 
 
Overt Act No. 363: 
On April 1, 2022, defendant WATSTEIN, using 
coded language in a Facebook message exchange, told defendant RAVIN 
that he was able to supply her with an ounce of methamphetamine. 
Overt Act No. 364: 
On April 1, 2022, defendant WATSTEIN, using 
coded language in a Facebook message exchange, warned defendant RAVIN 
that unindicted co-conspirator #45 was facing a lengthy prison 
sentence for engaging in drug distribution activities via Facebook 
Messenger. 
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Overt Act No. 365: 
On April 15, 2022, defendant WATSTEIN, using 
coded language in a Facebook message exchange, agreed to supply 
defendant RAVIN with heroin. 
Overt Act No. 366: 
On April 19, 2022, defendant SHAPIRO 
possessed with intent to distribute methamphetamine in Hidden Hills, 
California. 
Overt Act No. 367: 
On April 19, 2022, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant 
GLUCKMAN that he would be able to obtain four ounces of fentanyl for 
$1,600 from a source of supply. 
Overt Act No. 368: 
On May 11, 2022, defendant EKLUND possessed 
approximately 190.7 grams of fentanyl and 111.7 grams of 
methamphetamine to distribute to drug customers in his residence in 
Panorama City, California. 
Overt Act No. 369: 
On May 14, 2022, defendant RODNEY, using 
coded language in a text message exchange, arranged to obtain a pound 
of fentanyl from a drug source of supply. 
Overt Act No. 370: 
On May 18, 2022, defendant RODNEY, using 
coded language in a text message exchange, agreed to supply four 
ounces of drugs to a drug customer. 
Overt Act No. 371: 
On May 24, 2022, defendant RODNEY possessed 
approximately 1,165.23 grams fentanyl and 83.02 grams of 
methamphetamine to distribute to drug customers in his residence in 
Los Angeles, California. 
Overt Act No. 372: 
On May 30, 2022, unindicted co-conspirator 
#48, using coded language in a Facebook message exchange, told 
defendant BREWER that defendant PAYER was planning to rob a 
“craigslist drug dealer.” 
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Overt Act No. 373: 
On June 6, 2022, defendant BAKER sent 
defendant MULVIHILL $300 via Cash App. 
Overt Act No. 374: 
On June 7, 2022, defendant BINGAMAN asked 
defendant BECKWITH to supply him with fentanyl. 
Overt Act No. 375: 
On June 9, 2022, defendant WATSTEIN agreed 
to supply defendant RAVIN with heroin. 
Overt Act No. 376: 
On June 13, 2022, defendant SMITH, using 
coded language in a Facebook message exchange, agreed to supply 
methamphetamine to unindicted co-conspirator #48. 
Overt Act No. 377: 
On June 21, 2022, defendant BAKER sent 
defendant MULVIHILL $300 via Cash App. 
Overt Act No. 378: 
On June 26, 2022, defendant BAKER sent 
defendant MULVIHILL $1,100 via Cash App. 
Overt Act No. 379: 
On June 28, 2022, defendant BAKER sent 
defendant MULVIHILL $350 via Cash App. 
Overt Act No. 380: 
On July 1, 2022, defendant BINGAMAN, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he was obtaining a quarter of an ounce of fentanyl from 
a drug source of supply for defendant BINGAMAN and defendant BECKWITH 
to sell to drug customers. 
Overt Act No. 381: 
On July 1, 2022, defendant BAKER sent 
defendant MULVIHILL $1,200 via Cash App. 
Overt Act No. 382: 
On July 1, 2022, defendant SMITH, using 
coded language in a Facebook message exchange, agreed to supply a 
quarter of a pound of methamphetamine as well as an ounce of fentanyl 
to defendant SILVERBERG. 
Overt Act No. 383: 
On July 2, 2022, defendant SMITH, using 
coded language in a Facebook message exchange, told defendant 
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BINGAMAN that he had access to high-quality fentanyl and 
methamphetamine. 
Overt Act No. 384: 
On July 3, 2022, defendant BAKER sent 
defendant MULVIHILL $1,330 via Cash App. 
Overt Act No. 385: 
On July 9, 2022, defendant BAKER sent 
defendant MULVIHILL $500 via Cash App. 
Overt Act No. 386: 
On July 16, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that unindicted co-conspirator #48’s residence had been 
“raided” by law enforcement. 
Overt Act No. 387: 
On July 16, 2022, defendant BAKER sent 
defendant MULVIHILL $900 via Cash App. 
Overt Act No. 388: 
On July 23, 2022, defendant BAKER sent 
defendant MULVIHILL $350 via Cash App. 
Overt Act No. 389: 
On July 24, 2022, defendant BAKER sent 
defendant MULVIHILL $200 via Cash App. 
Overt Act No. 390: 
On July 25, 2022, defendant BAKER sent 
defendant MULVIHILL $1,000 via Cash App. 
Overt Act No. 391: 
On August 1, 2022, defendant BAKER sent 
defendant MULVIHILL $300 via Cash App. 
Overt Act No. 392: 
On August 2, 2022, defendant BAKER sent 
defendant MULVIHILL $380 via Cash App. 
Overt Act No. 393: 
On August 8, 2022, defendant BAKER sent 
defendant MULVIHILL $490 via Cash App. 
Overt Act No. 394: 
On August 10, 2022, defendant RAMACHANDRAN 
possessed methamphetamine to distribute to customers and a loaded 
firearm while driving a stolen motorcycle in Los Angeles, California. 
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Overt Act No. 395: 
On August 18, 2022, defendant BENEDICT, 
using coded language in a Facebook message exchange, agreed to supply 
drugs to a customer. 
Overt Act No. 396: 
On August 23, 2022, defendant MUNOZ, using 
coded language in a Facebook message exchange, agreed to supply 
heroin to defendant IBARRA. 
Overt Act No. 397: 
On August 26, 2022, defendant BAKER sent 
defendant MULVIHILL $250 via Cash App. 
Overt Act No. 398: 
On August 27, 2022, defendant BAKER sent 
defendant MULVIHILL $800 via Cash App. 
Overt Act No. 399: 
On August 29, 2022, a drug customer, using 
coded language in a Facebook message exchange, ordered half an ounce 
of drugs from defendant BENEDICT. 
Overt Act No. 400: 
On August 30, 2022, defendant BAKER sent 
defendant MULVIHILL $100 via Cash App. 
Overt Act No. 401: 
On September 1, 2022, defendant IBARRA, 
using coded language in a Facebook message exchange, asked defendant 
MUNOZ to supply heroin and Xanax.   
Overt Act No. 402: 
On September 2, 2022, defendant LEIMERT, 
using coded language in a Facebook message exchange, told defendant 
WINTERS that he had obtain heroin from a drug source of supply. 
Overt Act No. 403: 
On September 4, 2022, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he had two ounces of methamphetamine available to 
distribute. 
Overt Act No. 404: 
On September 18, 2022, defendant BAKER sent 
defendant MULVIHILL $500 via Cash App. 
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Overt Act No. 405: 
On September 24, 2022, defendant BAKER sent 
defendant MULVIHILL $550 via Cash App. 
Overt Act No. 406: 
On October 11, 2022, defendant BAKER sent 
defendant MULVIHILL $470 via Cash App. 
Overt Act No. 407: 
On October 14, 2022, defendant BAKER sent 
defendant MULVIHILL $200 via Cash App. 
Overt Act No. 408: 
On October 24, 2022, defendant BAKER sent 
defendant MULVIHILL $250 via Cash App. 
Overt Act No. 409: 
On October 28, 2022, defendant BAKER sent 
defendant MULVIHILL $1,000 via Cash App. 
Overt Act No. 410: 
On November 14, 2022, defendant MULVIHILL 
possessed with intent to distribute approximately 51 grams of 
methamphetamine, 19 grams of PCP, and 1,511 grams of fentanyl in a 
vehicle that he was driving in Los Angeles, California. 
Overt Act No. 411: 
On November 16, 2022, defendant BAKER sent 
defendant MULVIHILL $700 via Cash App. 
Overt Act No. 412: 
On November 30, 2022, unindicted co-
conspirator #51, using coded language in a Facebook message exchange, 
told defendant WATSTEIN that defendant FRANCIS had been arrested. 
Overt Act No. 413: 
On December 2, 2022, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CHATTERTON that he had a drug source of supply for hydrocodone. 
Overt Act No. 414: 
On December 3, 2022, defendant MACDONALD, 
using coded language in a Facebook message exchange, instructed 
defendant CHAN to send him $200 so that defendant MACDONALD could 
obtain additional heroin to distribute. 
Overt Act No. 415: 
On December 5, 2022, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
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CHAN that he needed to obtain additional drugs to distribute because 
his customers were having drug withdrawal symptoms. 
Overt Act No. 416: 
On December 17, 2022, defendant BAKER sent 
defendant MULVIHILL $600 via Cash App. 
Overt Act No. 417: 
On December 20, 2022, defendant BECKWITH, 
using coded language in a Facebook message exchange, told defendant 
BINGAMAN that she possessed high-quality crack cocaine as well as 
ounces of fentanyl to distribute to drug customers. 
Overt Act No. 418: 
On December 20, 2022, defendant BAKER sent 
defendant MULVIHILL $230 via Cash App. 
Overt Act No. 419: 
On January 3, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, agreed to supply 
fentanyl to a drug customer. 
Overt Act No. 420: 
On January 3, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, told a drug 
customer that the price of an ounce of high-quality methamphetamine 
was $150. 
Overt Act No. 421: 
On January 6, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, told a drug 
customer that she had fentanyl available to distribute. 
Overt Act No. 422: 
On January 7, 2023, defendant BAKER sent 
defendant MULVIHILL $365 via Cash App. 
Overt Act No. 423: 
On January 8, 2023, defendant BAKER sent 
defendant MULVIHILL $450 via Cash App. 
Overt Act No. 424: 
On January 9, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, agreed to split 
the price of an ounce of drugs that she and a drug customer were 
going to obtain from a drug source of supply. 
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Overt Act No. 425: 
On January 10, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, agreed to supply 
heroin to defendant SCHWARTZ. 
Overt Act No. 426: 
On January 10, 2023, defendant IBARRA, using 
coded language in a Facebook message exchange, told defendant 
BENEDICT that she had heard that unindicted co-conspirator #34 “was 
in big trouble With the brand.” 
Overt Act No. 427: 
On January 16, 2023, defendant BENEDICT, 
using coded language in a Facebook message exchange, told defendant 
SCHWARTZ that she had heroin available to distribute. 
Overt Act No. 428: 
On January 18, 2023, defendant GLUCKMAN 
possessed stolen personal identifying information belonging to more 
than 50 victims in a vehicle he was driving in Los Angeles, 
California. 
Overt Act No. 429: 
On January 23, 2023, defendant BAKER sent 
defendant MULVIHILL $500 via Cash App. 
Overt Act No. 430: 
On January 26, 2023, defendant BAKER sent 
defendant MULVIHILL $800 via Cash App. 
Overt Act No. 431: 
On January 31, 2023, defendant BAKER sent 
defendant MULVIHILL $1,083 via Cash App. 
Overt Act No. 432: 
On January 31, 2023, defendant LEIMERT, 
using coded language in a Facebook message exchange, ordered a 
quarter of an ounce of methamphetamine from defendant WATSTEIN.  
Overt Act No. 433: 
On February 9, 2023, defendant BAKER sent 
defendant MULVIHILL $200 via Cash App. 
Overt Act No. 434: 
On February 9, 2023, defendant MULVIHILL 
possessed with intent to distribute approximately 5.3 grams of 
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cocaine base, 743.6 grams of fentanyl, and 1,999 grams of 
methamphetamine in a hotel room in Los Angeles, California. 
Overt Act No. 435: 
On February 10, 2023, defendant BECKWITH, 
using coded language in a Facebook message exchange, told defendant 
YACOUB that she was selling high-quality fentanyl. 
Overt Act No. 436: 
On February 15, 2023, defendant BECKWITH, 
using coded language in a Facebook message exchange, sent defendant 
PAYER a photograph of purple fentanyl that she and defendant 
MACDONALD would have access to. 
Overt Act No. 437: 
On February 15, 2023, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he needed an ounce of fentanyl. 
Overt Act No. 438: 
On February 21, 2023, defendant MULVIHILL 
possessed with intent to distribute approximately 18.5 grams of 
heroin, 304 grams of fentanyl, and 172 grams of methamphetamine in a 
vehicle in Los Angeles, California. 
Overt Act No. 439: 
On February 27, 2023, defendant RILEY sold 
approximately 195.6 grams of methamphetamine and 25.82 grams of 
heroin to a Confidential Informant (“CI”). 
Overt Act No. 440: 
On March 3, 2023, defendant HILL sent 
defendant VENNUM $230 via Cash App. 
Overt Act No. 441: 
On March 27, 2023, defendant RILEY sold 
approximately 214.1 grams of methamphetamine and 26.01 grams of 
heroin to a CI. 
Overt Act No. 442: 
On April 4, 2023, defendant BAKER sent 
defendant MULVIHILL $700 via Cash App. 
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Overt Act No. 443: 
On April 13, 2023, defendant RILEY possessed 
with intent to distribute approximately one pound of methamphetamine 
in a vehicle that he was driving. 
Overt Act No. 444: 
On April 13, 2023, defendant RILEY possessed 
with intent to distribute methamphetamine, heroin, and fentanyl, as 
well as firearms, ammunition, body armor, pay/owe sheets, and a 
digital scale, in his residence in Van Nuys, California. 
Overt Act No. 445: 
On April 15, 2023, defendant BAKER sent 
defendant MULVIHILL $700 via Cash App. 
Overt Act No. 446: 
On April 29, 2023, defendant LEIMERT, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #23 that he was going to meet with a drug source of 
supply to obtain an additional quantity of drugs. 
Overt Act No. 447: 
On May 8, 2023, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he had large quantities of heroin and fentanyl 
available to distribute to customers. 
Overt Act No. 448: 
On May 9, 2023, defendant IBARRA, using 
coded language in a Facebook message exchange, agreed to supply a 
quarter of an ounce of heroin to unindicted co-conspirator #23. 
Overt Act No. 449: 
On May 15, 2023, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant IBARRA 
that he had heroin available to distribute. 
Overt Act No. 450: 
On May 15, 2023, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he had high-quality fentanyl available to distribute 
customers, and that the fentanyl “is gonna drop people [because] it’s 
fucking fire.” 
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Overt Act No. 451: 
On May 16, 2023, unindicted co-conspirator 
#23, using coded language in a Facebook message exchange, told 
defendant IBARRA that she was obtaining heroin from a drug source of 
supply. 
Overt Act No. 452: 
On May 17, 2023, defendant IBARRA, using 
coded language in a Facebook message exchange, agreed to supply 
unindicted co-conspirator #23 with methamphetamine. 
Overt Act No. 453: 
On May 17, 2023, unindicted co-conspirator 
#33 sent defendant VENNUM $1,000 via Cash App and stated that the 
money was from unindicted co-conspirator #1. 
Overt Act No. 454: 
On May 27, 2023, defendant CHAN, using coded 
language in a Facebook message exchange, told defendant MACDONALD 
that he had identified a drug customer who was interested in 
purchasing $2,500 of fentanyl. 
Overt Act No. 455: 
On June 8, 2023, unindicted co-conspirator 
#23, using coded language in a Facebook message exchange, asked 
defendant IBARRA to supply her with methamphetamine. 
Overt Act No. 456: 
On June 10, 2023, defendant BECKWITH, using 
coded language in a Facebook message exchange, told defendant PAYER 
that she was waiting for her drug source of supply to deliver cocaine 
that she was planning to use to make crack cocaine. 
Overt Act No. 457: 
On June 16, 2023, defendant BAKER sent 
defendant MULVIHILL $200 via Cash App. 
Overt Act No. 458: 
On June 19, 2023, defendant VENNUM sent 
defendant P. EKELUND $500 via Cash App and indicated that the money 
was “from L.” 
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Overt Act No. 459: 
On June 25, 2023, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant IBARRA 
that he had heroin available to distribute. 
Overt Act No. 460: 
On June 28, 2023, defendant VITANZA sent 
defendant POWERS $450 via Cash App. 
Overt Act No. 461: 
On June 30, 2023, defendant CHAN agreed to 
supply defendant BECKWITH with fentanyl. 
Overt Act No. 462: 
On July 6, 2023, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant JACOBS 
that he had high-quality fentanyl available to distribute to 
customers. 
Overt Act No. 463: 
On July 6, 2023, defendant MACDONALD, using 
coded language in a Facebook message exchange, complained to 
defendant CHAN that the price of methamphetamine was likely going to 
rise to $3,000 a pound. 
Overt Act No. 464: 
On July 8, 2023, unindicted co-conspirator 
#2, using coded language in a recorded telephone call, used a 
contraband cellular telephone to instruct defendant WILLS to contact 
him as needed. 
Overt Act No. 465: 
On July 8, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, warned defendant WILLS 
to exercise caution when speaking to unindicted co-conspirator #2 via 
telephone as defendant PICHIE suspected that their telephones were 
being intercepted by law enforcement. 
Overt Act No. 466: 
On July 9, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant PICHIE 
that a Mexican Mafia member had been murdered, and that individuals 
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associated with that Mexican Mafia member would likely soon be 
murdered as well. 
Overt Act No. 467: 
On July 9, 2023, defendant P. EKELUND sent 
defendant VENNUM $500 via Cash App. 
Overt Act No. 468: 
On July 9, 2023, defendants BREWER and 
WILLS, using coded language in a recorded telephone call, discussed 
the fact that a Mexican Mafia member had been murdered, and 
speculated about the identity of the individual who would be adopting 
that Mexican Mafia member’s responsibilities now that he was dead. 
Overt Act No. 469: 
On July 9, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, told defendant WILLS 
that individuals associated with M.T. had previously robbed one of 
defendant HAVILAND’s marijuana grow houses, and that “white boys,” 
with “pistols and shit” retaliated by engaging in an armed 
confrontation with the individuals. 
Overt Act No. 470: 
On July 12, 2023, defendant BECKWITH, using 
coded language in a Facebook message exchange, told defendant YACOUB 
that a drug customer needed to obtain fentanyl. 
Overt Act No. 471: 
On July 13, 2023, defendant VENNUM sent 
defendant P. EKELUND $300 via Cash App. 
Overt Act No. 472: 
On July 20, 2023, defendant RILEY possessed 
with intent to distribute approximately 38 grams of fentanyl, 53.9 
grams of methamphetamine, 185.3 grams of heroin, and 114.14 grams of 
Alprazolam, as well as loaded firearm, a digital scale, and more than 
$17,000 in cash, in a vehicle that he was driving in Van Nuys, 
California. 
Overt Act No. 473: 
On July 21, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant PICHIE 
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that he had collected $1,500 from [S.H.], and agreed to meet with 
defendant PICHIE “in person” the next day to determine if the money 
was designated for defendant PICHIE or another individual. 
Overt Act No. 474: 
On July 30, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, told defendant WILLS 
that an inmate at Pelican Bay State Prison would contact defendant 
WILLS to “relay a message” regarding “riots at Pelican Bay” that 
involved “the whites and the southerners” stabbing each other, so 
that defendant PICHIE could learn the details regarding who started 
the conflict and share the information with other AB members who were 
in custody, including those with access to a contraband cellular 
telephone. 
Overt Act No. 475: 
On August 1, 2023, defendant W. POLLAY sent 
defendant MEJIA $1,000 via Cash App. 
Overt Act No. 476: 
On August 1, 2023, defendant BAKER sent 
defendant MULVIHILL $399 via Cash App. 
Overt Act No. 477: 
On August 2, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, sent defendant 
Chan a photograph of a sample of drugs that he was able to obtain 
from a source of supply, depicted below. 
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Overt Act No. 478: 
On August 3, 2023, defendant CHAN, using 
coded language in a Facebook message exchange, told defendant 
UNGAMRUNG that he had mailed her a package that contained 
methamphetamine and at least five grams fentanyl to an address in 
North Carolina and sent her a photograph of the package. 
Overt Act No. 479: 
On August 6, 2023, defendant BAKER sent 
defendant MULVIHILL $1,278 via Cash App. 
Overt Act No. 480: 
On August 6, 2023, defendant FREEMAN, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that he was sending defendant MACDONALD $200 in connection 
with their drug distribution activities. 
Overt Act No. 481: 
On August 7, 2023, defendant BAKER sent 
defendant MULVIHILL $194 via Cash App. 
Overt Act No. 482: 
On August 8, 2023, defendant W. POLLAY sent 
defendant MEJIA $1,200 via Cash App. 
Overt Act No. 483: 
On August 9, 2023, defendant BAKER sent 
defendant MULVIHILL $580 via Cash App. 
Overt Act No. 484: 
On August 12, 2023, defendant BAKER sent 
defendant MULVIHILL $125 via Cash App. 
Overt Act No. 485: 
On August 12, 2023, defendant IBARRA, using 
coded language in a recorded telephone call, agreed to supply an 
ounce of methamphetamine to defendant WILLS. 
Overt Act No. 486: 
On August 15, 2023, defendant BAKER sent 
defendant MULVIHILL $873 via Cash App. 
Overt Act No. 487: 
On August 15, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, obtained an update from 
an inmate at Pelican Bay State Prison about the current relationship 
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between inmates aligned with the AB and inmates aligned with the 
Mexican Mafia at the custodial facility. 
Overt Act No. 488: 
On August 16, 2023, defendant FREEMAN sent 
defendant CHATTERTON $200 via Cash App. 
Overt Act No. 489: 
On August 16, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, contacted defendant 
VITANZA and identified himself as a fellow AB member with the moniker 
“Sinister.” 
Overt Act No. 490: 
On August 16, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, reassured unindicted co-
conspirator #4 that, despite the fact that defendant PICHIE had to 
wear an ankle monitor, he was able to assist the AB, including by 
sharing information with AB members in custody who had access to 
contraband cellular telephones. 
Overt Act No. 491: 
On August 16, 2023, unindicted co-
conspirator #4, using coded language in a recorded telephone call, 
identified for defendant PICHIE the individuals that unindicted co-
conspirator #5 wanted murdered. 
Overt Act No. 492: 
On August 16, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, complained to defendant 
VITANZA that unindicted co-conspirator #4 was the only AB member who 
contacted defendant PICHIE directly via a contraband cellular 
telephone without using Signal or Telegram to communicate over the 
telephone. 
Overt Act No. 493: 
On August 16, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, told defendant VITANZA 
that he was introduced to defendant WILLS when he was in prison with 
unindicted co-conspirator #24 and that defendant WILLS had been 
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managing money for defendant PICHIE and doing other work on his 
behalf for a long time. 
Overt Act No. 494: 
On August 16, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant PICHIE 
that defendant CHOTARD was “helpful,” “trustworthy,” and “good with a 
gun and a pencil.” 
Overt Act No. 495: 
On August 17, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CHAN that he was selling fentanyl for $300 a half an ounce and $170 
for a quarter of an ounce, and included the below photograph: 
 
Overt Act No. 496: 
On August 17, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CHAN that he had methamphetamine and fentanyl available to distribute 
and instructed defendant Chan to meet him at the drug stash house 
located at 9400 Valjean Avenue in North Hills, California. 
Overt Act No. 497: 
On August 19, 2023, defendant VENNUM, using 
coded language in a recorded telephone call, told defendant WILLS 
that he was at the residence located on Tyrone Avenue in Van Nuys, 
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California and that unindicted co-conspirator #1 had instructed him 
to contact defendant WILLS. 
Overt Act No. 498: 
On August 20, 2023, defendant W. POLLAY sent 
defendant MEJIA $1,610 via Cash App. 
Overt Act No. 499: 
On August 21, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
FREEMAN that a drug source of supply would sell half an ounce of 
fentanyl for $600. 
Overt Act No. 500: 
On August 22, 2023, defendant BAKER sent 
defendant MULVIHILL $300 via Cash App. 
Overt Act No. 501: 
On August 23, 2023, defendant WILLS, using 
coded language in a recorded telephone call, and unindicted co-
conspirator #38 discussed the fact that defendant RILEY had recently 
been arrested with guns and a large quantity of drugs. 
Overt Act No. 502: 
On August 24, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, agreed to obtain 
$250 worth of drugs from a source of supply for defendant FREEMAN and 
would collect the money from defendant FREEMAN that evening or the 
following morning. 
Overt Act No. 503: 
On August 25, 2023, defendant MACDOANLD, 
using coded language in a Facebook message exchange, told defendant 
MORENO that he presently had $1,700 and needed an additional $300 to 
obtain a quarter pound of drugs. 
Overt Act No. 504: 
On August 25, 2023, defendant MACDOANLD, 
using coded language in a Facebook message exchange, told defendant 
MORENO that he was working with three other individuals in addition 
to defendant Moreno to distribute drugs. 
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Overt Act No. 505: 
On August 25, 2023, defendant MACDONALD sent 
defendant Moreno a payment request for $300, depicted in the image 
below, in connection with an upcoming drug transaction. 
 
Overt Act No. 506: 
On August 25, 2023, defendants PICHIE and 
VITANZA, using coded language in a recorded telephone call, discussed 
defendant VITANZA’s fentanyl distribution activities. 
Overt Act No. 507: 
On August 25, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, told defendant VENNUM 
that unindicted co-conspirator #1 wanted defendant PICHIE to speak 
with defendant VENNUM and that he would contact defendant VENNUM 
using Signal. 
Overt Act No. 508: 
On August 25, 2023, defendant VENNUM, using 
coded language in a recorded telephone call, told defendant PICHIE 
that he was going to retrieve “30” from his storage unit to deliver 
to defendants PICHIE and VITANZA to store in a “low-key spot.” 
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Overt Act No. 509: 
On August 25, 2023, defendant PICHIE, using 
coded language in a recorded telephone call, told defendant WILLS 
that he needed help with “something important,” and instructed 
defendant WILLS to meet him and defendant VITANZA at defendant 
WILLS’s storage unit. 
Overt Act No. 510: 
On August 25, 2023, defendant WILLS, using 
coded language in a recorded telephone call, agreed to keep the item 
that defendants PICHIE and VITANZA obtained from defendant VENNUM in 
his residence and transfer it to his storage unit the next day. 
Overt Act No. 511: 
On August 26, 2023, defendant BAKER sent 
defendant MULVIHILL $100 via Cash App. 
Overt Act No. 512: 
On August 28, 2023, defendant YACOUB, using 
coded language in a Facebook message exchange, told defendant 
BECKWITH that he had obtained two ounces of fentanyl to distribute to 
drug customers. 
Overt Act No. 513: 
On September 1, 2023, defendant W. POLLAY 
sent defendant MEJIA $300 via Cash App. 
Overt Act No. 514: 
On September 3, 2023, defendant VITANZA sent 
defendant POWERS $400 via Cash App. 
Overt Act No. 515: 
On September 3, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
FREEMAN that he was able to obtain drugs to distribute from a source 
of supply at a discounted price. 
Overt Act No. 516: 
On September 3, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, agreed to sell 
defendant FREEMAN 5.5 grams of drugs for at a discounted price. 
Overt Act No. 517: 
On September 5, 2023, defendant BAKER sent 
defendant MULVIHILL $395 via Cash App. 
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Overt Act No. 518: 
On September 7, 2023, defendant BAKER sent 
defendant MULVIHILL $200 via Cash App. 
Overt Act No. 519: 
On September 8, 2023, defendant PICHIE, 
using coded language in a recorded telephone call, reminded defendant 
WILLS to only communicate regarding criminal activity via Signal and 
warned defendant WILLS that unindicted co-conspirator #2 had gotten 
“snapped up in a RICO” and that his contraband cellular telephone had 
recently been seized by law enforcement. 
Overt Act No. 520: 
On September 9, 2023, defendant BAKER sent 
defendant MULVIHILL $100 via Cash App. 
Overt Act No. 521: 
On September 9, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, displayed a 
photograph of drugs that he had available to distribute and told 
defendant CHAN that he was located at the drug stash house located at 
9400 Valjean Avenue in North Hills, California. 
Overt Act No. 522: 
On September 9, 2023, defendant PICHIE, 
using coded language in a recorded telephone call, instructed 
defendant WILLS to download Signal in order to obtain an update 
regarding unindicted co-conspirator #2’s RICO case and the status of 
his seized contraband cellular telephone. 
Overt Act No. 523: 
On September 9, 2023, defendant RAMACHANDRAN 
possessed 276.82 grams of methamphetamine and 93.89 grams of fentanyl 
as well as a firearm in a vehicle that he was driving in Los Angeles, 
California. 
Overt Act No. 524: 
On September 10, 2023, defendant W. POLLAY 
sent defendant MEJIA $299 via Cash App. 
Overt Act No. 525: 
On September 10, 2023, defendant SLAYTON 
sent defendant GAITHER $400 via Cash App. 
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Overt Act No. 526: 
On September 13, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
FREEMAN that the price for three grams of fentanyl was $100. 
Overt Act No. 527: 
On September 13, 2023, defendant CHAN 
traveled to the drug stash house located at 9400 Valjean Avenue in 
North Hills, California to purchase drugs to distribute. 
Overt Act No. 528: 
On September 13, 2023, defendant VENNUM sent 
unindicted co-conspirator #21 $230 via Cash App and indicated that 
the money was from unindicted co-conspirator #1. 
Overt Act No. 529: 
On September 13, 2023, defendant VITANZA 
sent defendant POWERS $283 via Cash App. 
Overt Act No. 530: 
On September 15, 2023, defendant W. POLLAY 
sent defendant MEJIA $300 via Cash App. 
Overt Act No. 531: 
On September 16, 2023, defendant MORENO, 
using coded language in a Facebook message exchange, ordered a 
quarter of an ounce of drugs from defendant MACDONALD. 
Overt Act No. 532: 
On September 21, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, agreed to supply 
defendant MACDONALD with drugs to distribute to customers, and 
defendant MACDONALD agreed to deliver a portion of his drug 
distribution proceeds to defendant VITANZA. 
Overt Act No. 533: 
On September 22, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he would have $500 in drug distribution proceeds for 
defendant VITANZA later that day and told defendant VITANZA that he 
presently needed an additional ounce and a half of drugs to 
distribute to customers. 
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Overt Act No. 539: 
On September 27, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, directed defendant 
CHOTARD to contact unindicted co-conspirator #1 on his contraband 
cellular telephone and tell unindicted co-conspirator #1 that 
defendant VITANZA wanted to obtain an additional quantity of fentanyl 
to sell to customers, that he presently had money to pay for the 
drugs in advance, and that he had many drug customers ready to 
purchase drugs. 
Overt Act No. 540: 
On September 27, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that he was going to obtain fentanyl to distribute from a 
drug source of supply. 
Overt Act No. 541: 
On September 27, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, instructed 
defendant CHOTARD to contact unindicted co-conspirator #1 on his 
contraband cellular telephone and tell unindicted co-conspirator #1 
that defendant VITANZA needed to obtain another quantity of high-
quality fentanyl to distribute. 
Overt Act No. 542: 
On September 27, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
CHOTARD that he had recently been obtaining drugs to distribute at a 
good price from unindicted co-conspirator #1 and complained that he 
always lost money when unindicted co-conspirator #2 was involved in 
supplying him with drugs. 
Overt Act No. 543: 
On September 27, 2023, defendant CHOTARD, 
using coded language in a recorded telephone call, told defendant 
VITANZA that she was presently communicating with unindicted co-
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conspirator #1 on his contraband cellular telephone and that 
unindicted co-conspirator #1 wanted defendant VITANZA to call him. 
Overt Act No. 544: 
On September 28, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that he was going to pick up a load of drugs to distribute, 
and that half of the load was designated for defendant PICHIE to 
distribute to customers. 
Overt Act No. 545: 
On September 28, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that defendant PICHIE did not want to assist him in picking 
up the load of drugs, and complained that the last time he and 
defendant PICHIE obtained a load of drugs, defendant VITANZA “fuckin’ 
weighed it out” on his own while defendant PICHIE just stood there 
watching “with a bandana all over his face.” 
Overt Act No. 546: 
On September 28, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that defendant PICHIE had tried to convince defendant 
VITANZA that neither of them personally had to pick up the load of 
drugs because both he and defendant VITANZA had earned the status of 
being made AB members. 
Overt Act No. 547: 
On September 28, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he would pick up the load of drugs for defendants 
VITANZA and PICHIE. 
Overt Act No. 548: 
On September 28, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, warned defendant 
THAEMERT that the load of drugs he was going to pick up was very 
large, that he should not touch the drugs, and that the smell of the 
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drugs would be very powerful and that defendant THAEMERT would leave 
“a vapor trail when [he] drive[s]” away with the quantity of drugs 
designated for defendants VITANZA and PICHIE. 
Overt Act No. 549: 
On September 28, 2023, defendant B. EKELUND, 
using coded language in a recorded telephone call, told unindicted 
co-conspirator #11 to give his telephone to unindicted co-conspirator 
#35 while defendant B. EKELUND was in custody. 
Overt Act No. 550: 
On September 28, 2023, defendant WILLS, 
using coded language in a recorded telephone call, agreed to send 
$300 - $500 of defendant B. EKELUND’s drug distribution proceeds to 
defendant B. EKELUND’s custodial facility. 
Overt Act No. 551: 
On September 30, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendants 
CHATTERTON and POWERS that he still owed a drug source of supply 
$7,000 in connection with his drug distribution activities. 
Overt Act No. 552: 
On September 30, 2023, defendant CHATTERTON, 
using coded language in a recorded telephone call, offered to use his 
“name” to get a “fresh credit limit” with a drug source of supply to 
obtain additional drugs to distribute. 
Overt Act No. 553: 
On October 2, 2023, unindicted co-
conspirator #32, using coded language in a recorded telephone call, 
told defendant WILLS that fentanyl that unindicted co-conspirator #32 
had recently smoked was supplied by unindicted co-conspirator #1 and 
that unindicted co-conspirator #1 maintained a drug stash house on 
Tyrone Avenue in Van Nuys, California. 
Overt Act No. 554: 
On October 3, 2023, defendants B. EKELUND 
and WILLS and unindicted co-conspirator #36, using coded language in 
a recorded telephone call, discussed their concern that unindicted 
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co-conspirator #35 had overdosed on drugs after unindicted co-
conspirator #35 took custody of defendant B. EKELUND’s supply of 
drugs. 
Overt Act No. 555: 
On October 3, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant IBARRA 
that he was concerned that unindicted co-conspirator #35 had possibly 
died of a fentanyl overdose and told defendant IBARRA that unindicted 
co-conspirator #35 was responsible for storing defendant B. EKELUND’s 
stash of drugs. 
Overt Act No. 556: 
On October 3, 2023, defendant B. EKELUND, 
using coded language in a recorded telephone call, provided 
defendants PICHIE and WILLS with unindicted co-conspirator #35’s true 
name, and defendant PICHIE told defendant B. EKELUND that he and 
defendant WILLS would “check the hospitals and the morgue” for 
unindicted co-conspirator #35’s body. 
Overt Act No. 557: 
On October 4, 2023, unindicted co-
conspirator #11, using coded language in a recorded telephone call, 
told defendant WILLS that unindicted co-conspirator #35 was dead and 
that she had located both “a coroner report and a Hollywood News 
report” verifying his death. 
Overt Act No. 558: 
On October 4, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #10 that unindicted co-conspirator #35 possessed “all of 
[defendant B. EKELUND’s] dope,” his keys, as well as other belongings 
in unindicted co-conspirator #35’s residence when unindicted co-
conspirator #35 died of a fentanyl overdose. 
Overt Act No. 559: 
On October 4, 2023, defendant VITANZA sent 
defendant POWERS $450 via Cash App. 
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Overt Act No. 560: 
On October 6, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant THAEMERT 
that he would be able to sell him an ounce of fentanyl for $400. 
Overt Act No. 561: 
On October 6, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he was able to sell 3.5 grams of fentanyl to a drug 
customer for $225. 
Overt Act No. 562: 
On October 6, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant POWERS 
that he needed to meet with defendant P. EKELUND to obtain drugs to 
distribute. 
Overt Act No. 563: 
On October 6, 2023, defendant POWERS, using 
coded language in a recorded telephone call, told defendant VITANZA 
that his Cash App card was not working but that he had cash available 
for defendant VITANZA to obtain additional drugs from defendant P. 
EKELUND.   
Overt Act No. 564: 
On October 6, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, directed defendant 
THAEMERT to obtain $450 in cash from defendant POWERS to use to 
obtain a quantity of fentanyl from defendant P. EKELUND. 
Overt Act No. 565: 
On October 6, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, directed defendant 
POWERS to give defendant THAEMERT the cash for the drugs that 
defendant VITANZA was going to obtain from defendant P. EKELUND. 
Overt Act No. 566: 
On October 6, 2023, defendant VITANZA, using 
coded language in a recorded telephone call, said that he expected to 
obtain ten ounces of drugs from defendant P. EKELUND and that he 
would give one of the ounces to defendant THAEMERT. 
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Overt Act No. 567: 
On October 6, 2023, unindicted co-
conspirator #1, in a text message, provided defendant RAMACHANDRAN 
with the new telephone number to his contraband cellular telephone. 
Overt Act No. 568: 
On October 8, 2023, defendant FREEMAN, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that he would send defendant MACDONALD $250 to obtain more 
drugs from a drug source of supply. 
Overt Act No. 569: 
On October 8, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he presently had $260 in drug distribution proceeds for 
defendant VITANZA. 
Overt Act No. 570: 
On October 9, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant IBARRA 
that he would determine who was distributing heroin now that 
defendant B. EKELUND was in custody. 
Overt Act No. 571: 
On October 11, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, agreed to supply 
heroin to defendant POWERS. 
Overt Act No. 572: 
On October 11, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, agreed to supply 
an ounce of drugs to defendant ROMERO for $120. 
Overt Act No. 573: 
On October 11, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that defendant MACDONALD owed him $2,000 in drug 
distribution proceeds. 
Overt Act No. 574: 
On October 12, 2023, defendant GAITHER sent 
defendant SLAYTON $100 via Cash App. 
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Overt Act No. 575: 
On October 13, 2023, defendant GAITHER sent 
defendant SLAYTON $450 via Cash App. 
Overt Act No. 576: 
On October 14, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that defendant MACDONALD wanted to rob a drug source of 
supply. 
Overt Act No. 577: 
On October 14, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
CHOTARD that unindicted co-conspirator #1 had arranged for defendant 
SCHULTZ to deliver drugs to defendant VITANZA. 
Overt Act No. 578: 
On October 14, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, agreed to meet 
with defendant SCHULTZ to obtain drugs to distribute. 
Overt Act No. 579: 
On October 22, 2023, defendant GAITHER sent 
defendant SLAYTON $200 via Cash App. 
Overt Act No. 580: 
On October 22, 2023, defendant BAKER sent 
defendant MULVIHILL $175 via Cash App. 
Overt Act No. 581: 
On October 24, 2023, defendant P. EKELUND 
possessed with intent to distribute approximately 982.2 grams of 
fentanyl and 135.3 grams of methamphetamine, as well as multiple 
firearms and several rounds of ammunition, in Van Nuys, California. 
Overt Act No. 582: 
On October 24, 2023, defendant VENNUM 
possessed firearms and multiple rounds of ammunition in Van Nuys, 
California. 
Overt Act No. 583: 
On October 25, 2023, defendant SHAPIRO sent 
defendant SLAYTON $100 via Cash App. 
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Overt Act No. 584: 
On October 28, 2023, defendant PAYER, using 
coded language in a Facebook message exchange, asked defendant 
MACDONALD to supply fentanyl to sell to drug customers. 
Overt Act No. 585: 
On October 29, 2023, defendant SLAYTON sent 
defendant FRANCIS $550 via Cash App. 
Overt Act No. 586: 
On November 1, 2023, defendant VITANZA sent 
unindicted co-conspirator #40 $400 via Cash App. 
Overt Act No. 587: 
On November 3, 2023, defendant CHAN, using 
coded language in a recorded telephone call, ordered an ounce of 
drugs from defendant MACDONALD. 
Overt Act No. 588: 
On November 3, 2023, defendant MACDONALD, 
using coded language in a text message exchange, asked defendant 
FREEMAN to send him cash so that defendant MACDONALD could obtain an 
additional quantity of drugs from a source of supply. 
Overt Act No. 589: 
On November 5, 2023, defendant CHAN, using 
coded language in a recorded telephone call, told defendant MACDONALD 
that they could obtain two ounces of methamphetamine and two ounces 
of high-quality fentanyl for $1,200 from a drug source of supply. 
Overt Act No. 590: 
On November 5, 2023, defendant SLAYTON, 
using coded language in a recorded telephone call, agreed to provide 
fentanyl to defendant THAEMERT once defendant SLAYTON obtained an 
additional quantity of fentanyl from a drug source of supply. 
Overt Act No. 591: 
On November 6, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
PAYER that he was planning to rob a drug source of supply. 
Overt Act No. 592: 
On November 6, 2023, defendant UNGAMRUNG, 
using coded language in a recorded telephone call, told defendant 
MACDONALD that she wanted to assist defendant MACDONALD to obtain 
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methamphetamine and fentanyl from a source of supply by contributing 
money to the upcoming drug transaction. 
Overt Act No. 593: 
On November 6, 2023, defendant UNGAMRUNG, 
using coded language in a recorded telephone call, told defendant 
MACDONALD that she had sent him money so that he could obtain half an 
ounce of methamphetamine as well as a quantity of fentanyl from a 
drug source of supply. 
Overt Act No. 594: 
On November 6, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
FREEMAN that defendant THAEMERT owed defendant VITANZA $1,100 in drug 
distribution proceeds. 
Overt Act No. 595: 
On November 6, 2023, defendant MACDONALD, in 
a text message exchange, provided defendant UNGAMRUNG with defendant 
BECKWITH’s Cash App account information. 
Overt Act No. 596: 
On November 6, 2023, defendant PAYER, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that he could obtain counterfeit money to be used in drug 
transactions. 
Overt Act No. 597: 
On November 6, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, complained to 
defendant UNGAMRUNG that defendant CHAN’s telephone was off despite 
defendant MACDONALD’s present efforts to negotiate a favorable deal 
for methamphetamine and high-quality fentanyl from a source of 
supply. 
Overt Act No. 598: 
On November 6, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
HEINTZ that he had sent defendant HEINTZ a text message regarding a 
quantity of methamphetamine. 
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Overt Act No. 599: 
On November 6, 2023, defendant ROMERO, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #1 that she had met with a third party at defendant 
HAVILAND’s residence and given him thousands of dollars in drug 
distribution proceeds on behalf of “L.” 
Overt Act No. 600: 
On November 6, 2023, defendant Romero sent 
unindicted co-conspirator #1 the following text message: 
Ya know I didn't think bout it and I really 
should’ve but I didn't just say too much on the phone today 
and if so I am sorry and I’ll be more mindful next time 
 
Overt Act No. 601: 
On November 7, 2023, unindicted co-
conspirator #27 sent defendant FRANCIS $500 via Cash App. 
Overt Act No. 602: 
On November 7, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that defendant MACDONALD’s drug source of supply oversaw a 
large drug distribution operation in Ventura County, obtained pounds 
of methamphetamine at a time, and generated approximately $100,000 a 
week in drug distribution proceeds. 
Overt Act No. 603: 
On November 7, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, offered to sell 
defendant MACDONALD two ounces of methamphetamine for $240. 
Overt Act No. 604: 
On November 8, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant IBARRA 
that unindicted co-conspirator #19 was the individual that AB members 
sent from Northern California to Southern California to facilitate 
criminal conduct on behalf of the AB. 
Overt Act No. 605: 
On November 8, 2023, defendant WILLS, using 
coded language in a recorded telephone call, told defendant IBARRA 
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that he was trying to “butter [unindicted co-conspirator #11] up and 
shit so I can fuckin’ find out where she’s at, fuckin’, and get her.” 
Overt Act No. 606: 
On November 9, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
POWERS that he had met with a drug source of supply who “slings 
fuckin’ dope,” and that he had “picked up a, a few ounces from her.” 
Overt Act No. 607: 
On November 11, 2023, defendant HEINTZ, 
using coded language in a text message exchange, ordered fentanyl 
from defendant THAEMERT. 
Overt Act No. 608: 
On November 11, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, ordered two ounces 
of heroin from a drug source of supply and told the drug supplier 
that he needed to return an ounce of fentanyl because the drugs were 
not good quality. 
Overt Act No. 609: 
On November 11, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, directed 
defendant PAYER to obtain a large amount of counterfeit money to be 
used in connection with drug transactions. 
Overt Act No. 610: 
On November 12, 2023, defendant GAITHER sent 
defendant SLAYTON $300 via Cash App. 
Overt Act No. 611: 
On November 12, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
HEINTZ that he had delivered $180 of fentanyl to defendant HEINTZ. 
Overt Act No. 612: 
On November 12, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
HEINTZ that he would “come to wherever [he was] with the scale right 
now” so that he could ensure that all of the fentanyl that he had 
previously delivered to defendant HEINTZ was there.  
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Overt Act No. 613: 
On November 13, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, ordered a quarter 
of an ounce of methamphetamine from defendant VAN VLYMEN. 
Overt Act No. 614: 
On November 14, 2023, defendant GAITHER sent 
defendant SLAYTON $300 via Cash App. 
Overt Act No. 615: 
On November 14, 2023, defendant CHAN, using 
coded language in a recorded telephone call, complained to defendant 
MACDONALD about the quality of drugs that defendant MACDONALD had 
obtained from a drug source of supply. 
Overt Act No. 616: 
On November 15, 2023, defendant SLAYTON sent 
defendant FRANCIS $200 via Cash App. 
Overt Act No. 617: 
On November 15, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
CHAN that defendant MACDONALD was going to rob a drug source of 
supply and steal his heroin and would give defendant CHAN two ounces 
of heroin after the robbery. 
Overt Act No. 618: 
On November 16, 2023, defendant RESNICK, 
using coded language in a recorded telephone call, told defendant 
CHATTERTON that she would obtain methamphetamine that defendant 
CHATTERTON had stored in his vehicle and would supply an ounce of 
methamphetamine to a drug customer. 
Overt Act No. 619: 
On November 16, 2023, defendant RESNICK, 
using coded language in a recorded telephone call, told defendant 
CHATTERTON that she spilled a portion of methamphetamine when she was 
weighing the drugs for a customer. 
Overt Act No. 620: 
On November 16, 2023, defendant HAVILAND, 
using coded language in a text message exchange, instructed defendant 
CHOTARD to tell defendant VITANZA that unindicted co-conspirator #8, 
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an AB commissioner, was being released from custody and that 
defendant VITANZA “need[ed] [to do] what’s expected.” 
Overt Act No. 621: 
On November 17, 2023, defendant CHAN, using 
coded language in a recorded telephone call, told defendant MACDONALD 
that defendant UNGAMRUNG would send defendant MACDONALD money for an 
additional quantity of drugs to distribute to customers. 
Overt Act No. 622: 
On November 17, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, ordered a quarter 
of an ounce of drugs from defendant SLAYTON. 
Overt Act No. 623: 
On November 18, 2023, defendant DIETZEN, 
using coded language in a text message exchange, ordered a half of a 
unit of drugs from defendant THAEMERT. 
Overt Act No. 624: 
On November 18, 2023, in a recorded 
telephone call using coded language, defendant CHOTARD discussed with 
defendant VITANZA the location of a quantity of fentanyl that they 
possessed. 
Overt Act No. 625: 
On November 18, 2023, defendant SLAYTON, 
using coded language in a text message exchange, agreed to supply a 
half of a pound of drugs to defendant THAEMERT for $500. 
Overt Act No. 626: 
On November 19, 2023, defendant CHAN, using 
coded language in a recorded telephone call, told defendant MACDONALD 
that defendant UNGAMRUNG would send money for a quantity of 
methamphetamine. 
Overt Act No. 627: 
On November 19, 2023, defendants MACDONALD 
and BECKWITH, using coded language in a recorded telephone call, told 
defendant CHAN that they were going to obtain methamphetamine from a 
drug source of supply. 
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Overt Act No. 628: 
On November 20, 2023, defendant CHAN, using 
coded language in a recorded telephone call, told defendant MACDONALD 
that defendant UNGAMRUNG wanted to obtain half an ounce of fentanyl 
and have an ounce of methamphetamine from a drug source of supply and 
would send money for the drugs. 
Overt Act No. 629: 
On November 20, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, reminded 
defendant UNGAMRUNG to send money via Cash App for half an ounce of 
fentanyl. 
Overt Act No. 630: 
On November 20, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
UNGAMRUNG that he regularly shipped drugs in the mail to “Chicago 
Idaho and Oklahoma.” 
Overt Act No. 631: 
On November 20, 2023, defendant CHATTERTON, 
using coded language in a text message exchange, told a drug customer 
that defendant RESNICK would look for the receipt for the package 
that contained methamphetamine that defendant CHATTERTON had shipped 
in the mail. 
Overt Act No. 632: 
On November 21, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, asked defendant 
VITANZA if he presently had methamphetamine to distribute. 
Overt Act No. 633: 
On November 21, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that she was obtaining additional methamphetamine to 
distribute from a drug source of supply. 
Overt Act No. 634: 
On November 21, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, ordered a quarter 
of an ounce of methamphetamine from defendant VAN VLYMEN. 
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Overt Act No. 635: 
On November 23, 2023, defendant DIETZEN, 
using coded language in a text message exchange, ordered a half of a 
unit of drugs from defendant THAEMERT. 
Overt Act No. 636: 
On November 25, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant VAN 
VLYMEN that he was going to supply her with high-quality drugs that 
her customers would like. 
Overt Act No. 637: 
On November 25, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that she would give defendant CHOTARD $400 in drug 
distribution proceeds. 
Overt Act No. 638: 
On November 25, 2023, defendant POWERS, 
using coded language in a recorded telephone call, told defendant 
FREEMAN that he would supply him with heroin. 
Overt Act No. 639: 
On November 25, 2023, defendant DIETZEN, 
using coded language in a recorded telephone call, told defendant 
CHOTARD that law enforcement officers had recently seized a quantity 
of fentanyl from his residence and that the officers were sending the 
drugs to the laboratory for testing. 
Overt Act No. 640: 
On November 26, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, told defendant 
MACDONALD that defendant VITANZA wanted to speak with defendant 
MACDONALD regarding drug distribution proceeds that defendant 
MACDONALD owed to defendant VITANZA. 
Overt Act No. 641: 
On November 26, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he had drug distribution proceeds to deliver to 
defendant VITANZA on behalf of defendant MACDONALD. 
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Overt Act No. 642: 
On November 26, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that defendant MACDONALD was able to obtain drugs to 
distribute from a source of supply at a discounted rate. 
Overt Act No. 643: 
On November 26, 2023, defendant THAEMERT 
sent defendant SLAYTON $400 via Cash App. 
Overt Act No. 644: 
On November 26, 2023, defendant POWERS, 
using coded language in a recorded telephone call, told defendant 
VITANZA that he would supply heroin to defendant FREEMAN. 
Overt Act No. 645: 
On November 26, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
FREEMAN that defendant POWERS would supply defendant FREEMAN with 
heroin once defendant POWERS obtained the drugs from a source of 
supply. 
Overt Act No. 646: 
On November 26, 2023, defendant FREEMAN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that defendant POWERS offered to supply defendant FREEMAN 
with heroin in the future. 
Overt Act No. 647: 
On November 27, 2023, defendant HEINTZ, 
using coded language in a recorded telephone call, ordered $300 of 
fentanyl from defendant THAEMERT.  
Overt Act No. 648: 
On November 27, 2023, defendant HEINTZ, 
using coded language in a recorded telephone call, told defendant 
THAEMERT that he had already obtained fentanyl from a drug source of 
supply but needed to obtain methamphetamine from defendant THAEMERT. 
Overt Act No. 649: 
On November 27, 2023, defendant CHOTARD, 
using coded language in a recorded telephone call, told defendant 
VITANZA that she possessed methamphetamine that she had obtained from 
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defendant HAVILAND and would be able to deliver the methamphetamine 
to defendant VITANZA. 
Overt Act No. 650: 
On November 28, 2023, defendant CRISWELL, 
using coded language in a Facebook message exchange, told defendant 
MACDONALD that unindicted co-conspirator #1 calls defendant CRISWELL 
to collect drug distribution proceeds. 
Overt Act No. 651: 
On November 28, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CRISWELL that he presently had drugs available to distribute and 
stated that he thought that defendant SCHULTZ did as well. 
Overt Act No. 652: 
On November 29, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
DIETZEN that he had morphine pills available to sell to a customer 
that defendant DIETZEN had identified. 
Overt Act No. 653: 
On November 29, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, complained to 
defendant VITANZA that a “Canoga Park” gang member “came by trying to 
talk politics,” and told defendant VAN VLYMEN that “anybody who’s not 
working with the Brand is going to get taxed” in connection with 
their drug distribution activities. 
Overt Act No. 654: 
On November 29, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, authorized 
defendant VAN VLYMEN to tell others that she was “working for the 
Brand.” 
Overt Act No. 655: 
On November 29, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, told defendant 
VITANZA that she told a “Canoga Park” gang member that “no, white 
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people, period, are gonna get taxed” by a Hispanic gang in the San 
Fernando Valley. 
Overt Act No. 656: 
On November 30, 2023, defendant VAN VLYMEN 
sent the following text message to defendant VITANZA complaining 
about the quality of drugs that he was supplying: 
There’s still complaints. The people closest to me try to buy it 
elsewhere before coming to me cuz it doesn’t seem to get them 
there.... You should be getting the best of the best but this has 
been consistently the worst available. Not talking shit, talking 
truth. Can you exchange?? I would like to[.] 
 
 
Overt Act No. 657: 
On December 1, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
FREEMAN that a drug source of supply would be willing to sell 
defendant FREEMAN 12.5 grams of heroin for $275. 
Overt Act No. 658: 
On December 1, 2023, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
DIETZEN that the price of half a unit of drugs was $650 and the price 
of a full unit of drugs was $1,250. 
Overt Act No. 659: 
On December 1, 2023, defendant MACDONALD, 
using coded language in a recorded telephone call, told defendant 
FREEMAN that he was able to negotiate a good price for drugs for 
defendant FREEMAN because defendant MACDONALD “buy[s] everything” 
from the source of supply. 
Overt Act No. 660: 
On December 2, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, sent a 
photograph of drugs that he had available to distribute to a drug 
customer. 
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Overt Act No. 661: 
On December 2, 2023, defendant HEINTZ, using 
coded language in a recorded telephone call, ordered an ounce of 
drugs from defendant THAEMERT. 
Overt Act No. 662: 
On December 3, 2023, defendant CHAN, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that defendant UNGAMRUNG wanted to purchase an ounce of 
drugs from defendant MACDONALD if he was able to obtain the same 
quality of drugs from a previous transaction. 
Overt Act No. 663: 
On December 3, 2023, defendant CHAN, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that defendant CHAN was waiting with a drug customer that 
had $150 and asked if defendant BECKWITH was delivering the drugs for 
the customer soon. 
Overt Act No. 664: 
On December 5, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CRISWELL that he had methamphetamine available to distribute. 
Overt Act No. 665: 
On December 8, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, instructed 
defendant UNGAMRUNG to tell defendant CHAN to contact defendant 
MACDONALD regarding an upcoming drug transaction. 
Overt Act No. 666: 
On December 10, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, asked defendant 
UNGAMRUNG if she and defendant CHAN were going to contribute money so 
that defendants MACDONALD, CHAN, and UNGAMRUNG could purchase high-
quality drugs from a source of supply. 
Overt Act No. 667: 
On December 19, 2023, defendant SLAYTON, 
using coded language in a recorded telephone call, told an inmate at 
Pelican Bay State Prison that defendant PICHIE was attempting to 
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contact him because defendant PICHIE had heard that he was “slanging 
big pounds” of drugs. 
Overt Act No. 668: 
On December 20, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
UNGAMRUNG that he had methamphetamine for defendants CHAN and 
UNGAMRUNG. 
Overt Act No. 669: 
On December 19, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, contacted a drug 
source of supply to request a quarter of a pound of drugs for a 
customer. 
Overt Act No. 670: 
On December 20, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, scolded an 
individual for telling a third-party that defendant VAN VLYMEN’s 
house was “Brand protected” without proper authorization. 
Overt Act No. 671: 
On December 21, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
CHAN that defendant MACDONALD was obtaining a quarter of a pound of 
drugs from a drug source of supply and told defendant CHAN that he 
planned to give defendant CHAN half an ounce of methamphetamine. 
Overt Act No. 672: 
On December 21, 2023, unindicted co-
conspirator #1, in a text message exchange, sent defendant SCHULTZ a 
link to install Signal on defendant SCHULTZ’s new cellular telephone. 
Overt Act No. 673: 
On December 22, 2023, unindicted co-
conspirator #1, using coded language in a recorded telephone call, 
instructed defendant SCHULTZ to call him back on Signal or Telegram. 
Overt Act No. 674: 
On December 23, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, told defendant 
ROMERO that defendant VITANZA had engaged in an attempted murder 
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while incarcerated at the High Desert Prison located in Susanville, 
California. 
Overt Act No. 675: 
On December 23, 2023, defendant VITANZA, 
using coded language in a recorded telephone call, bragged to 
defendant ROMERO that he was the “youngest made member of the Aryan 
Brotherhood,” and described to defendant ROMERO his leadership style 
as an AB member. 
Overt Act No. 676: 
On December 23, 2023, defendant CRISWELL, 
using coded language in a Facebook message exchange, identified a 
customer that wanted to purchase drugs from defendant MACDONALD. 
Overt Act No. 677: 
On December 24, 2023, defendant SCHULTZ, 
using coded language in a text message, requested that unindicted co-
conspirator #1 use unindicted co-conspirator #1’s contraband cellular 
telephone to contact him. 
 
Overt Act No. 678: 
On December 26, 2023, defendant VAN VLYMEN, 
using coded language in a recorded telephone call, agreed to supply 
drugs to a customer. 
Overt Act No. 679: 
On December 27, 2023, defendant EKLUND sent 
defendant SLAYTON $175 via Cash App. 
Overt Act No. 680: 
On December 27, 2023, defendant SCHULTZ, 
using coded language in a recorded telephone call, agreed to supply 
fentanyl to defendant P. EKELUND. 
Overt Act No. 681: 
On December 27, 2023, defendant P. EKELUND 
possessed with intent to distribute 82 pills that contained fentanyl 
that he had obtained from defendant SCHULTZ. 
Overt Act No. 682: 
On December 27, 2023, defendant SCHULTZ, 
using coded language in a recorded telephone call, told defendant 
VENNUM that law enforcement officers confronted him and defendant P. 
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EKELUND during a drug transaction earlier that evening, and that law 
enforcement officers followed defendant P. EKELUND as he attempted to 
flee. 
Overt Act No. 683: 
On December 29, 2023, defendant GAITHER, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that defendant GAITHER would send him money via Cash App so 
that defendant SLAYTON could obtain additional drugs to distribute 
from a drug source of supply.  
Overt Act No. 684: 
On December 30, 2023, defendant GAITHER sent 
defendant SLAYTON $200 via Cash App. 
Overt Act No. 685: 
On December 30, 2023, defendants REED, using 
coded language in a recorded telephone call, and MUNOZ agreed to 
commit bank fraud with checks that defendant REED had stolen the 
night before. 
Overt Act No. 686: 
On December 30, 2023, defendant MUNOZ, using 
coded language in a recorded telephone call, told defendant REED that 
defendant SCHULTZ’s residence had been “raided” recently. 
Overt Act No. 687: 
On December 31, 2023, defendant PREVEDELLO, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that he had just stolen a brand-new Predator 2000 generator, 
and was willing to trade the stolen generator for methamphetamine or 
fentanyl. 
Overt Act No. 688: 
On December 31, 2023, defendant PREVEDELLO, 
using coded language in a recorded telephone call, asked defendant 
SLAYTON to supply him with methamphetamine to sell to customers at a 
profit. 
Overt Act No. 689: 
On December 31, 2023, defendant CHAN, using 
coded language in a Facebook message exchange, told defendant 
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MACDONALD that he was at defendant UNGAMRUNG’s parents’ house and was 
waiting for defendant UNGAMRUNG’s to deliver money so that they could 
purchase an additional quantity of drugs to distribute to customers. 
Overt Act No. 690: 
On December 31, 2023, defendant MACDONALD, 
using coded language in a Facebook message exchange, asked defendant 
CHAN to tell defendant UNGAMRUNG to send defendant MACDONALD money 
via Cash App so that they could obtain drugs to distribute from 
defendant VITANZA. 
Overt Act No. 691: 
On December 31, 2023, defendant HAVILAND 
sent her Cash App tag to a drug customer in Alabama so that the drug 
customer could pay defendant HAVILAND to ship methamphetamine in the 
mail to Alabama. 
Overt Act No. 692: 
On January 1, 2024, defendant HARBAND 
possessed approximately 217.85 grams methamphetamine and 82.89 grams 
of fentanyl, depicted below, to distribute to drug customers in a 
hotel room in Chatsworth, California.  
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Overt Act No. 693: 
On January 2, 2024, defendant GAITHER sent 
defendant SLAYTON $400 via Cash App. 
Overt Act No. 694: 
On January 2, 2024, defendant HAVILAND, 
using coded language in a text message exchange, told a drug customer 
that she was planning to ship methamphetamine via the mail to the 
customer in Alabama that day. 
Overt Act No. 695: 
On January 3, 2024, defendant PREVEDELLO, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that he needed to purchase an ounce of fentanyl and would 
contact defendant SLAYTON the next day. 
Overt Act No. 696: 
On January 3, 2024, defendant W. POLLAY, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that he would send defendant SLAYTON more money so that he 
could obtain additional drugs to distribute from a drug source of 
supply. 
Overt Act No. 697: 
On January 3, 2024, defendant MEJIA, using 
coded language in a recorded telephone call, told defendant SLAYTON 
that she had nearly $3,000 to purchase a quantity of fentanyl. 
Overt Act No. 698: 
On January 3, 2024, defendant MEJIA sent 
defendant SLAYTON $110 via Cash App. 
Overt Act No. 699: 
On January 3, 2024, defendant PICHIE, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #10 that he would be able to supply an ounce of drugs to 
a customer. 
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Overt Act No. 700: 
On January 3, 2024, defendant HAVILAND 
obtained approximately 26.1 grams of methamphetamine to ship in the 
mail to a drug customer in Alabama, depicted in the photo below. 
 
Overt Act No. 701: 
On January 4, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant HILL that 
the price of an ounce of fentanyl was between $450 and $500. 
Overt Act No. 702: 
On January 4, 2024, defendant HILL, using 
coded language in a recorded telephone call, told defendant SLAYTON 
that he wanted to obtain an ounce of fentanyl from defendant SLAYTON 
to sample, and, if defendant HILL was pleased with the quality of the 
fentanyl, he would be placing an order for additional ounces. 
Overt Act No. 703: 
On January 4, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, agreed to supply 
fentanyl to defendant THAEMERT. 
Overt Act No. 704: 
On January 4, 2024, defendant ROMERO, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #1 that “Trouble” had not yet been murdered. 
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Overt Act No. 705: 
On January 4, 2024, unindicted co-
conspirator #10, using coded language in a recorded telephone call, 
told defendant WILLS that he had obtained methamphetamine and would 
supply him with a portion of the drugs. 
Overt Act No. 706: 
On January 4, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant HILL that 
unindicted co-conspirator #1 had stated that no one was authorized to 
“tax” defendant HILL’s drug distribution activities. 
Overt Act No. 707: 
On January 5, 2024, defendant THAEMERT, 
using coded language in a recorded telephone call, that he would send 
defendant SLAYTON money in connection with drug distribution 
activity.   
Overt Act No. 708: 
On January 5, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant W. POLLAY 
that he would be obtaining additional drugs to distribute from a drug 
source of supply. 
Overt Act No. 709: 
On January 5, 2024, defendant THAEMERT, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that he would send defendant SLAYTON $400-$500 in drug 
distribution proceeds via Cash App. 
Overt Act No. 710: 
On January 5, 2024, defendant THAEMERT sent 
defendant SLAYTON $100 via Cash App. 
Overt Act No. 711: 
On January 5, 2024, defendant EKLUND sent 
defendant SLAYTON $500 via Cash App. 
Overt Act No. 712: 
On January 5, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant MEJIA 
that he was attempting to obtain both methamphetamine and fentanyl 
from a drug source of supply. 
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Overt Act No. 713: 
On January 5, 2024, defendant HAVILAND, 
using coded language in a text message exchange, told a drug customer 
in Alabama that the customer should receive the methamphetamine that 
defendant HAVILAND had shipped to the customer in the mail by 
“Monday.” 
Overt Act No. 714: 
On January 6, 2024, defendant THAEMERT sent 
defendant SLAYTON $250 via Cash App. 
Overt Act No. 715: 
On January 6, 2024, defendant SLAYTON sent 
defendant FRANCIS $520 via Cash App. 
Overt Act No. 716: 
On January 8, 2024, defendant EKLUND sent 
defendant SLAYTON $750 via Cash App.  
Overt Act No. 717: 
On January 8, 2024, defendant FRANCIS 
possessed with intent to distribute approximately 86.23 grams of 
fentanyl and 31.18 grams of methamphetamine, as well as drug 
distribution materials, in a hotel room in Agoura Hills, California. 
Overt Act No. 718: 
On January 8, 2024, defendant HILL, using 
coded language in a text message exchange, “a whole bunch” of 
methamphetamine from defendant SLAYTON. 
Overt Act No. 719: 
On January 8, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant HILL that 
he had fentanyl available to distribute but needed to obtain 
methamphetamine to distribute from a drug source of supply. 
Overt Act No. 720: 
On January 8, 2024, defendant HILL, using 
coded language in a recorded telephone call, requested that defendant 
SLAYTON deliver fentanyl to defendant HILL. 
Overt Act No. 721: 
On January 9, 2024, defendant HAVILAND, 
using coded language in a recorded telephone call, told a drug 
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customer that she had arranged for methamphetamine to be sent to the 
customer via the mail.   
Overt Act No. 722: 
On January 9, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, agreed to supply 
methamphetamine to defendant W. POLLAY. 
Overt Act No. 723: 
On January 9, 2024, defendant MEJIA, using 
coded language in a recorded telephone call, told defendant SLAYTON 
that she had enough money to purchase a “whole brick” of drugs from 
defendant SLAYTON. 
Overt Act No. 724: 
On January 9, 2024, defendant SLAYTON, using 
coded language in a recorded telephone call, told defendant MEJIA 
that defendant FRANCIS had been arrested the night before in 
connection with drug distribution activity. 
Overt Act No. 725: 
On January 10, 2024, defendant DIETZEN, 
using coded language in a recorded telephone call, ordered a quarter 
of a pound of drugs from defendant THAEMERT. 
Overt Act No. 726: 
On January 10, 2024, using coded language in 
a recorded telephone call, defendant THAEMERT told defendant DIETZEN 
that defendant THAEMERT would obtain the drugs from defendant 
SLAYTON. 
Overt Act No. 727: 
On January 10, 2024, defendant THAEMERT, 
using coded language in a recorded telephone call, asked defendant 
SLAYTON to supply a quarter of a pound of methamphetamine. 
Overt Act No. 728: 
On January 10, 2024, defendant THAEMERT sent 
defendant SLAYTON $100 via Cash App. 
Overt Act No. 729: 
On January 10, 2024, defendant HAVILAND, 
using coded language in a text message exchange, agreed to ship an 
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additional quantity of methamphetamine via the mail to a drug 
customer in Alabama. 
Overt Act No. 730: 
On January 10, 2024, defendant HAVILAND 
obtained approximately 19.1 grams of methamphetamine that she 
intended to ship to a drug customer in Alabama, depicted in the below 
photograph.   
 
Overt Act No. 731: 
On January 11, 2024, defendant SHAPIRO sent 
defendant SLAYTON $275 via Cash App. 
Overt Act No. 732: 
On January 11, 2024, defendant THAEMERT sent 
defendant SLAYTON $250 via Cash App. 
Overt Act No. 733: 
On January 11, 2024, defendant HAVILAND, 
using coded language in a recorded telephone call, told a drug 
customer in Alabama that she had just shipped a quantity of 
methamphetamine to the customer via the mail. 
Overt Act No. 734: 
On January 11, 2024, defendant SLAYTON, 
using coded language in a text message exchange, told defendant HILL 
that he was obtaining additional drugs to distribute from a drug 
source of supply. 
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Overt Act No. 735: 
On January 12, 2024, unindicted co-
conspirator #1, using coded language in a recorded telephone call, 
contacted defendant HAVILAND on his new contraband cellular telephone 
and attempted to communicate with her via Signal. 
Overt Act No. 736: 
On January 13, 2024, defendant SLAYTON, 
using coded language in a recorded telephone call, instructed 
defendant HILL to charge a drug customer $100 for a gram of drugs 
that the drug customer had requested. 
Overt Act No. 737: 
On January 13, 2024, defendant W. POLLAY, 
using coded language in a recorded telephone call, asked defendant 
SLAYTON to supply him with ounces of drugs. 
Overt Act No. 738: 
On January 13, 2024, defendant UNGAMRUNG, 
using coded language in a Facebook message exchange, ordered $180 of 
drugs from defendant MACDONALD. 
Overt Act No. 739: 
On January 13, 2024, defendant SLAYTON, 
using coded language in a recorded telephone call, told defendant 
GAITHER that a drug source of supply would be delivering an 
additional quantity of drugs to defendant SLAYTON later that day. 
Overt Act No. 740: 
On January 13, 2024, defendant GAITHER, 
using coded language in a recorded telephone call, reminded defendant 
SLAYTON to employ counter-surveillance tactics when driving his 
vehicle in connection with drug distribution activities. 
Overt Act No. 741: 
On January 13, 2024, defendant GAITHER, 
using coded language in a recorded telephone call, told defendant 
SLAYTON that he would meet with him after defendant SLAYTON obtained 
drugs to distribute from his source of supply. 
Overt Act No. 742: 
On January 15, 2024, defendant THAEMERT sent 
defendant SLAYTON $300 via Cash App. 
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Overt Act No. 743: 
On January 15, 2024, defendant UNGAMRUNG, 
using coded language in a Facebook message exchange, ordered an 
additional quantity of drugs from defendant MACDONALD. 
Overt Act No. 744: 
On January 18, 2024, defendant GAITHER sent 
defendant SLAYTON $200 via Cash App. 
Overt Act No. 745: 
On January 18, 2024, defendant CHAN, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that defendant UNGAMRUNG wanted to obtain additional 
fentanyl from defendant MACDONALD. 
Overt Act No. 746: 
On January 19, 2024, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
FREEMAN that he had identified a new drug source of supply that was 
able to supply drugs to sell at a “cheaper” price. 
Overt Act No. 747: 
On January 22, 2024, defendant BAKER, using 
coded language in a recorded telephone call, agreed to sell a pound 
of methamphetamine to a drug customer for $1,100. 
Overt Act No. 748: 
On January 22, 2024, defendant MACDONALD 
sent defendant MORENO the following Facebook message: “I just got 
burned by one of my runners he took off with a half ounce o stuff and 
never came back remember [defendant CHAN].” 
Overt Act No. 749: 
On January 23, 2024, defendant BAKER, using 
coded language in a recorded telephone call, told a drug customer 
that he had half a pound of methamphetamine available to sell to the 
drug customer. 
Overt Act No. 750: 
On January 23, 2024, defendant BAKER sold 
approximately 220.1 grams of methamphetamine to a drug customer for 
$600. 
Overt Act No. 751: 
On January 30, 2024, defendant BAKER, using 
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coded language in a recorded telephone call, agreed to sell a pound 
of methamphetamine to a drug customer for $1,100. 
Overt Act No. 752: 
On January 31, 2024, defendant BAKER sold 
approximately 443.8 grams of methamphetamine to a drug customer for 
$1,100. 
Overt Act No. 753: 
On January 31, 2024, defendant BAKER told a 
drug customer that he would sell methamphetamine for $900 a pound if 
the drug customer bought three pounds of methamphetamine at a time, 
and $850 a pound if the drug customer bought five pounds of 
methamphetamine at a time. 
 
Overt Act No. 754: 
On February 12, 2024, defendant SLAYTON sent 
defendant GAITHER $250 via Cash App. 
Overt Act No. 755: 
On February 13, 2024, defendant SLAYTON sent 
defendant GAITHER $200 via Cash App. 
Overt Act No. 756: 
On February 14, 2024, defendant SLAYTON sent 
defendant GAITHER $250 via Cash App. 
Overt Act No. 757: 
On February 16, 2024, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendants 
CHAN and UNGAMRUNG that he almost got caught by law enforcement with 
four ounces of fentanyl that he had hidden in a “laundry detergent 
box.” 
Overt Act No. 758: 
On February 17, 2024, defendant SLAYTON sent 
defendant GAITHER $250 via Cash App. 
Overt Act No. 759: 
On February 18, 2024, defendant SLAYTON sent 
defendant GAITHER $150 via Cash App. 
Overt Act No. 760: 
On February 20, 2024, defendant DIETZEN sent 
defendant BAKER $180 via Cash App. 
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Overt Act No. 761: 
On February 22, 2024, defendant CHOTARD sent 
defendant CHATTERTON the following text message: 
FYI- you might not want to let [defendant RESNIK] go too many places 
with [M.T.] Trouble.... she ain’t nothin but a has been, now lame who 
has to make a monthly quota to simply stay alive. . . .  Her own ppl 
make her pay an exact amount to stay breathing.  But let the wrong, I 
mean RIGHT person catch her slipping and ain’t nobody gonna do a 
muthafuckin thing to help her.  She will NEVER be cool with me or the 
[Aryan Brotherhood] again.  She’s burnt with us. 
 
Overt Act No. 762: 
On February 22, 2024, defendant HILL, using 
coded language in a recorded telephone call, discussed with a drug 
customer the “shard” of methamphetamine that was in the 
methamphetamine that defendant HILL had supplied to the customer the 
previous day. 
Overt Act No. 763: 
On February 23, 2024, defendant HILL, using 
coded language in a recorded telephone call, told a drug customer 
that he was able to supply half an ounce of fentanyl for $550. 
Overt Act No. 764: 
On February 23, 2024, defendant SHAPIRO, 
using coded language in a recorded telephone call, told a drug 
customer that he had highly potent morphine pills available to sell 
to drug customers. 
Overt Act No. 765: 
On February 25, 2024, defendant SHAPIRO, 
using coded language in a recorded telephone call, told a drug 
customer that he had heroin available to distribute. 
Overt Act No. 766: 
On February 26, 2024, defendant SHAPIRO, 
using coded language in a recorded telephone call, agreed to supply 
four ounces of methamphetamine to a drug customer. 
Overt Act No. 767: 
On February 27, 2024, defendant SHAPIRO, 
using coded language in a recorded telephone call, agreed to supply 
methamphetamine to a drug customer. 
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Overt Act No. 768: 
On February 27, 2024, defendant HILL, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #20 that he had high-quality drugs available to 
distribute. 
Overt Act No. 769: 
On February 27, 2024, defendant HILL, using 
coded language in a recorded telephone call, told a drug customer 
that unindicted co-conspirator #20 would deliver drugs to the 
customer and collect money for the drugs on behalf of defendant HILL. 
Overt Act No. 770: 
On March 1, 2024, defendant HILL, using 
coded language in a recorded telephone call, told a drug customer 
that he had obtained high-quality drugs to distribute. 
Overt Act No. 771: 
On March 2, 2024, defendant MACDONALD, using 
coded language in a Facebook message exchange, told defendants CHAN 
and UNGAMRUNG that he was obtaining high-quality drugs from a source 
of supply. 
Overt Act No. 772: 
On March 3, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, told a drug customer 
that he would contact a different drug source of supply to obtain 
better quality drugs to distribute. 
Overt Act No. 773: 
On March 3, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, instructed a drug source 
of supply to sell a quarter of an ounce of drugs to a customer. 
Overt Act No. 774: 
On March 3, 2024, defendant SLAYTON sent 
defendant GAITHER $1,200 via Cash App. 
Overt Act No. 775: 
On March 4, 2024, defendant SLAYTON sent 
defendant GAITHER $250 via Cash App. 
Overt Act No. 776: 
On March 4, 2024, unindicted co-conspirator 
#26, using coded language in a recorded telephone call, told 
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defendant HAVILAND that the Mexican Mafia and the AB still maintained 
a strong alliance, particularly in the federal penitentiary system. 
Overt Act No. 777: 
On March 4, 2024, unindicted co-conspirator 
#26, using coded language in a recorded telephone call, told 
defendant HAVILAND that unindicted co-conspirator #1 was not going to 
become a made AB member because other AB members, including 
unindicted co-conspirator #2, would lose access to and authority over 
the money that unindicted co-conspirator #1 was generating for the AB 
through criminal activities including drug distribution. 
Overt Act No. 778: 
On March 4, 2024, unindicted co-conspirator 
#26, using coded language in a recorded telephone call, told 
defendant HAVILAND that unindicted co-conspirator #1 needed to rely 
on unindicted co-conspirator #8 to keep him in good standing with the 
AB and to put unindicted co-conspirator #1 up for AB membership. 
Overt Act No. 779: 
On March 4, 2024, unindicted co-conspirator 
#26, using coded language in a recorded telephone call, told 
defendant HAVILAND that he had identified an individual who could 
press counterfeit Xanax pills. 
Overt Act No. 780: 
On March 6, 2024, defendant HILL, using 
coded language in a recorded telephone call, agreed to supply half an 
ounce of fentanyl to a drug customer. 
Overt Act No. 781: 
On March 8, 2024, unindicted co-conspirator 
#40 possessed approximately 5.7 kilograms of fentanyl to distribute 
to drug customers in a vehicle that he was driving in Englewood 
Cliffs, New Jersey. 
Overt Act No. 782: 
On March 8, 2024, defendant RAMACHANDRAN 
possessed with intent to distribute methamphetamine, heroin, and 
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fentanyl in a vehicle that he was driving in Redondo Beach, 
California. 
Overt Act No. 783: 
On March 10, 2024, defendant ATKINSON 
possessed 20.61 grams of methamphetamine and 99.76 grams of fentanyl 
to distribute to drug customers, as well as multiple rounds of 
ammunition, and $2,800 in cash in Van Nuys, California. 
Overt Act No. 784: 
On March 11, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, ordered two ounces of 
drugs from a drug source of supply. 
Overt Act No. 785: 
On March 11, 2024, defendant HAVILAND, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #37 that she and others were attempting to determine any 
individuals who had cooperated with federal law enforcement in 
unindicted co-conspirator #48’s federal prosecution. 
Overt Act No. 786: 
On March 12, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, told a drug source of 
supply that a customer wanted to purchase a pound of methamphetamine. 
Overt Act No. 787: 
On March 12, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, offered to sell a pound 
of methamphetamine to a drug customer for $1,400. 
Overt Act No. 788: 
On March 12, 2024, defendant HILL, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #21 that he had spoken with unindicted co-conspirator #1 
and told him that unindicted co-conspirator #21 was not AB “secretary 
material” so that unindicted co-conspirator #1 would stop calling 
unindicted co-conspirator #21 as much via his contraband cellular 
telephone. 
Overt Act No. 789: 
On March 13, 2024, defendant SHAPIRO, using 
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coded language in a recorded telephone call, agreed to supply 
methamphetamine to a drug customer. 
Overt Act No. 790: 
On March 13, 2024, defendant HILL, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #25 that unindicted co-conspirator #40, who was one of 
unindicted co-conspirator #1’s “top guys,” had recently been arrested 
in connection with drug distribution activity. 
Overt Act No. 791: 
On March 13, 2024, defendant HILL, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #25 that unindicted co-conspirator #1 had “huge, huge 
problems” because unindicted co-conspirator #40 had been delivering 
drugs for unindicted co-conspirator #1 when he “disappeared” days 
ago. 
Overt Act No. 792: 
On March 13, 2024, unindicted co-conspirator 
#29, using coded language in a recorded telephone call, warned 
defendant HAVILAND that the “alphabet guys,” referring to federal law 
enforcement agents, “got our friend.” 
Overt Act No. 793: 
On March 13, 2024, defendant HAVILAND, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #26 that unindicted co-conspirator #29 had warned her 
that the “dude in Georgia” had been arrested, and defendant HAVILAND 
and unindicted co-conspirator #26 discussed their concerns regarding 
the text messages that were on his telephone. 
Overt Act No. 794: 
On March 13, 2024, unindicted co-conspirator 
#26, using coded language in a recorded telephone call, instructed 
defendant HAVILAND to let unindicted co-conspirator #1 know that the 
individual in Georgia had been arrested, and warned defendant 
HAVILAND not to conduct any internet searches regarding the arrest. 
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Overt Act No. 795: 
On March 13, 2024, defendant HAVILAND sent a 
text message to defendant ROMERO that stated: “Can u come here real 
quick please[.]  It's important.” 
Overt Act No. 796: 
On March 13, 2024, defendant HAVILAND 
instructed defendant ROMERO to transport approximately 4,059.2 grams 
of fentanyl from defendant HAVILAND’s residence to an alternate 
location where law enforcement would not locate the drugs. 
Overt Act No. 797: 
On March 13, 2024, defendant ROMERO, using 
coded language in a recorded telephone call, told defendant VITANZA 
that an individual “in Georgia got busted,” and, as a result, she and 
defendant HAVILAND needed to store drugs from cartel member “L” at 
defendant VITANZA’s residence. 
Overt Act No. 798: 
On March 13, 2024, defendant ROMERO, using 
coded language in a recorded telephone call, told defendant HAVILAND 
that she was taking the drugs from “L” to defendant VITANZA’s 
residence. 
Overt Act No. 799: 
On March 13, 2024, defendant VITANZA, using 
coded language in a recorded telephone call, gave defendant ROMERO 
the code to a safe that was in his room, and warned defendant ROMERO 
to be careful when putting the drugs in it as there were already 
“real” guns in the safe. 
Overt Act No. 800: 
On March 13, 2024, defendant ROMERO placed 
approximately 4,059.2 grams of fentanyl in the safe in defendant 
VITANZA’s residence, and warned defendants CHOTARD and VITANZA not to 
get their fingerprints on the drugs that she was putting in the safe. 
Overt Act No. 801: 
On March 13, 2024, defendant ROMERO, using 
coded language in a recorded telephone call, told defendant HAVILAND 
that she had put the drugs from “L” in defendant VITANZA’s safe. 
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Overt Act No. 802: 
On March 13, 2024, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant 
CHATTERTON that law enforcement officers were at his residence, and 
asked defendant CHATTERTON to drive by the residence and report to 
defendant VITANZA what he saw. 
Overt Act No. 803: 
On March 13, 2024, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant HAVILAND 
that he needed to speak with her in person because law enforcement 
officers had executed a search warrant at his residence. 
Overt Act No. 804: 
On March 13, 2024, defendant VITANZA, using 
coded language in a recorded telephone call, told defendant HAVILAND 
that he was sending “Reckless” to his residence “to see if the cops 
are still there.” 
Overt Act No. 805: 
On March 13, 2024, defendant VITANZA 
possessed a black Ruger LCP Max, .380 caliber firearm, bearing serial 
number 380963495, and a tan Polymer 80 pistol with an attached laser, 
and possessed with intent to distribute approximately 49 grams of 
methamphetamine, in his residence in Los Angeles, California. 
Overt Act No. 806: 
On March 14, 2024, defendant CHOTARD, using 
coded language in a recorded telephone call, told an inmate at the 
California Institution for Women that law enforcement had searched 
her and defendant VITANZA’s residence and seized a large quantity of 
fentanyl and discussed changing the number to her telephone. 
Overt Act No. 807: 
On March 14, 2024, defendant HILL, using 
coded language in a recorded telephone call, told unindicted co-
conspirator #25 that unindicted co-conspirator #1 was “shitting his 
pants” due to recent law enforcement activity and was going to change 
the telephone number of his contraband cellular telephone. 
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Overt Act No. 808: 
On March 15, 2024, defendant SHAPIRO, using 
coded language in a recorded telephone call, agreed to supply 
fentanyl to a drug customer. 
Overt Act No. 809: 
On March 15, 2024, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
MORENO that he had identified a drug customer who wanted to purchase 
four ounces of drugs, and sent defendant MORENO a screenshot of 
communications related to the upcoming drug transaction. 
Overt Act No. 810: 
On March 15, 2024, defendant WILLS, using 
coded language in a recorded telephone call, warned defendant B. 
EKELUND that defendant ROMERO and unindicted co-conspirator #40 had 
both recently been arrested by law enforcement. 
Overt Act No. 811: 
On March 18, 2024, defendant MACDONALD, 
using coded language in a Facebook message exchange, told defendant 
MORENO that he had fentanyl available for defendant MORENO and 
instructed defendant MORENO to obtain fentanyl from him so that he 
would get a better price for fentanyl to distribute. 
Overt Act No. 812: 
On March 18, 2024, defendant MORENO sent 
defendant MACDONALD a photograph of drugs that he had available to 
distribute to customers, depicted below. 
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Overt Act No. 813: 
On March 23, 2024, defendant IBARRA, using 
coded language in a Facebook message exchange, requested to obtain 
heroin from defendant MUNOZ.  
Overt Act No. 814: 
On April 7, 2024, defendant MORENO, using 
coded language in a Facebook message exchange, told defendant 
MACDONALD that defendant MORENO had approximately 4 grams of “crack 
chips” available to distribute to customers, including a photograph, 
depicted below. 
 
Overt Act No. 815: 
On April 13, 2024, defendant SLAYTON sent 
defendant GAITHER $120 via Cash App. 
Overt Act No. 816: 
On April 16, 2024, defendant WILLS, using 
coded language in a recorded telephone call, warned defendant B. 
EKELUND that defendant BREWER had recently been arrested, and that 
law enforcement had questioned her about him, defendant HAVILAND, and 
unindicted co-conspirator #1. 
Overt Act No. 817: 
On April 20, 2024, defendant PAYER, using 
coded language in a recorded telephone call, told defendant FRANCIS 
that he was making money while in custody selling drugs that he 
obtained via a “happy card.” 
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Overt Act No. 818: 
On April 22, 2024, defendant FRANCIS, using 
coded language in a recorded telephone call, agreed to send defendant 
PAYER heroin to sell to drug customers in a CDCR facility. 
Overt Act No. 819: 
On April 22, 2024, defendant SLAYTON sent 
defendant GAITHER $375 via Cash App. 
Overt Act No. 820: 
On April 26, 2024, unindicted co-conspirator 
#15, using coded language in a recorded telephone call, told 
defendant PAYER that she and defendant FRANCIS would send drugs to 
defendant PAYER in a CDCR facility. 
Overt Act No. 821: 
On April 27, 2024, defendant FRANCIS, using 
coded language in a recorded telephone call, told defendant PAYER 
that defendant FRANCIS was pressing “bricks” of fentanyl. 
Overt Act No. 822: 
On April 29, 2024, defendant SLAYTON sent 
defendant GAITHER $200 via Cash App. 
Overt Act No. 823: 
On May 6, 2024, defendant SLAYTON sent 
defendant GAITHER $200 via Cash App. 
Overt Act No. 824: 
On May 10, 2024, defendant SLAYTON sent 
defendant GAITHER $350 via Cash App. 
Overt Act No. 825: 
On May 21, 2024, defendant FRANCIS, using 
coded language in a recorded telephone call, told defendant PAYER 
that unindicted co-conspirator #2 had previously instructed defendant 
FRANCIS to construct a drone that would be able to carry up to 20 
pounds of drugs. 
Overt Act No. 826: 
On May 28, 2024, defendant W. POLLAY sent 
defendant SLAYTON $1,800 via Cash App. 
Overt Act No. 827: 
On June 4, 2024, defendant W. POLLAY sent 
defendant SLAYTON $850 via Cash App. 
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Overt Act No. 828: 
On June 20, 2024, defendant EKLUND possessed 
fentanyl to distribute to customers, as well as a pay/owe book, a 
scale, and $640 cash in a vehicle that he was driving in Los Angeles, 
California. 
Overt Act No. 829: 
On June 20, 2024, defendant EKLUND possessed 
fentanyl to distribute to customers, as well as Nazi paraphernalia 
and a short-barreled rifle, depicted below, in his residence in Los 
Angeles, California.  
 
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Overt Act No. 830: 
On June 22, 2024, unindicted co-conspirator 
#28 sent defendant FRANCIS $2,950 via Cash App. 
Overt Act No. 831: 
On July 27, 2024, defendant W. POLLAY sent 
defendant SLAYTON $450 via Cash App. 
Overt Act No. 832: 
On July 28, 2024, defendant VITANZA sent 
defendant POWERS $150 via Cash App. 
 
 
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COUNT THREE 
[18 U.S.C. § 1349] 
A. 
OBJECT OF THE CONSPIRACY 
Beginning on a date unknown and continuing until at least in or 
around July 2023, in Los Angeles and Ventura Counties, within the 
Central District of California, and elsewhere, defendants SEAN CRAIG 
GLUCKMAN (“GLUCKMAN”), COLIN NICHOLAS SLACK (“SLACK”), HENISI UTSLER 
(“UTSLER”), AMANDA JOY RAVIN (“RAVIN”), MARIA ANNA JAMES, aka “Maria 
Daizy” (“JAMES”), knowingly conspired with each other and with others 
known and unknown to the Grand Jury to commit Bank Fraud, in 
violation of Title 18, United States Code, Sections 1344(1), (2). 
B. 
THE PAYCHECK PROTECTION PROGRAM 
1. 
In or about March 2020, Congress passed and the President 
signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES 
Act”).   
2. 
One form of assistance provided by the CARES Act was the 
authorization of United States taxpayer funds in forgivable loans to 
small businesses for job retention and certain other expenses, through 
a program referred to as the Paycheck Protection Program (“PPP”).  PPP 
was implemented by the SBA with support from the Department of the 
Treasury.  The program provided small businesses with funds to pay up 
to eight weeks of payroll costs including benefits.  Funds could also 
be used to pay interest on mortgages, rent, and utilities.  Self-
employed individuals were able to apply for and obtain PPP loans.  
Applicants who were self-employed individuals must have been working 
as a self-employed individual on February 15, 2020. 
3. 
The Small Business Administration (“SBA”) delegated 
authority to third-party lenders including Benworth Capital, 
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Fountainhead SBF LLC, Harvest Small Business LLC, and Prestamos CDFI, 
LLC, to underwrite and approve PPP loans.  If a PPP loan application 
was approved, the participating lender would fund the PPP loan using 
its own monies, which were guaranteed by the SBA. 
4. 
In such a PPP loan application, the applicant was required 
to affirm, among other things that:   
a. 
The applicant was not presently incarcerated or, for 
any felony, subject to an indictment, criminal information, 
arraignment, or other means by which formal criminal charges are 
brought in any jurisdiction.  
b. 
The applicant had not, within the past five years, 
been convicted, pleaded guilty, pleaded nolo contendere, or commenced 
any form of parole or probation (including probation before judgment) 
for any felony involving fraud, bribery, embezzlement, or a false 
statement in a loan application or an application for federal 
financial assistance a qualifying business.  
c. 
The applicant was in operation on February 15, 2020, 
had not permanently closed, and was either an eligible self-employed 
individual, an independent contractor, or a sole proprietorship with 
no employees.   
5. 
The authorized representative of the applicant was also 
required to certify that “the information provided in this application 
and the information provided in all supporting documents and forms is 
true and accurate in material respects,” and “I understand that if the 
funds are knowingly used for unauthorized purposes, the federal 
government may hold me legally liable, such as for charges of fraud.” 
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C. 
MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE 
ACCOMPLISHED 
The object of the conspiracy was to be accomplished, in 
substance, as follows: 
1. 
Defendants GLUCKMAN and JAMES, as well as others known and 
unknown to the Grand Jury, would falsify information regarding their 
and their co-conspirators’ employment, income, and other personal 
identifying information (“PII”) to be used in connection with 
fraudulent PPP loan applications. 
2. 
Defendant JAMES would generate false telephone numbers to 
be used in connection with fraudulent PPP loan applications.     
3. 
Defendant GLUCKMAN would provide guidance to others, 
including defendants SLACK, UTSLER, JAMES, unindicted co-conspirator 
#2, unindicted co-conspirator #16, and unindicted co-conspirator #18 
regarding how to complete their fraudulent PPP loan applications. 
4. 
Defendants GLUCKMAN, SLACK, UTSLER, RAVIN, JAMES, 
unindicted co-conspirator #2, unindicted co-conspirator #16, and 
unindicted co-conspirator #18 would submit fraudulent PPP loan 
applications. 
5. 
Defendants GLUCKMAN and JAMES would sign fraudulent PPP 
loan applications on behalf of individuals incarcerated in CDCR 
facilities and would submit those fraudulent PPP loan applications on 
behalf of incarcerated co-conspirators.     
6. 
Defendants GLUCKMAN and JAMES would collect a portion of 
the proceeds from fraudulently obtained PPP loans from co-conspirators 
as payment for their assistance.   
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D. 
OVERT ACTS  
Overt Act No. 1: 
On March 25, 2021, unindicted co-conspirator 
#16, using coded language in a Facebook message exchange, sent a 
picture of himself and unindicted co-conspirator #2 in CDCR custody 
to defendant GLUCKMAN to demonstrate that defendant GLUCKMAN was 
communicating via Facebook with unindicted co-conspirator #16 and 
unindicted co-conspirator #2, who was serving a life-with-parole 
sentence for a 2003 second-degree murder conviction. 
Overt Act No. 2: 
On March 31, 2021, unindicted co-conspirator 
#43 submitted a Borrower Application Form for Schedule C Filers Using 
Gross Income that falsely stated that he was a self-employed 
“artist/writer” with a gross income of $249,820. 
Overt Act No. 3: 
On April 5, 2021, defendant GLUCKMAN 
submitted a Borrower Application Form for Schedule C Filers Using 
Gross Income that falsely stated that he was a self-employed 
“artist/writer” with a gross income of $249,820. 
Overt Act No. 4: 
On April 6, 2021, unindicted co-conspirator 
#43 obtained a PPP loan in the amount of $20,833. 
Overt Act No. 5: 
On April 12, 2021, defendant GLUCKMAN 
obtained a PPP loan in the amount of $20,833. 
Overt Act No. 6: 
On April 22, 2021, defendant GLUCKMAN and 
defendant JAMES, using coded language in a Facebook message exchange, 
agreed to work together to submit multiple fraudulent PPP loan 
applications and split any loan money that they received. 
Overt Act No. 7: 
On April 22, 2021, defendant JAMES, using 
coded language in a Facebook message exchange, told defendant GLUCKMAN 
that she would generate false telephone numbers to use in connection 
with fraudulent PPP loan applications. 
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Overt Act No. 8: 
On April 22, 2021, defendant UTSLER 
submitted a Borrower Application Form for Schedule C Filers Using 
Gross Income that falsely stated that she was a self-employed “screen 
writer” with a gross income of $180,498.02. 
Overt Act No. 9: 
On April 22, 2021, defendant SLACK submitted 
a Borrower Application Form for Schedule C Filers Using Gross Income 
that falsely stated that he was a self-employed “screen writer” with a 
gross income of $180,498.02, and used identical income and expense 
information that defendant UTSLER used on her fraudulent application. 
Overt Act No. 10: 
On April 23, 2021, defendant GLUCKMAN, in a 
Facebook message exchange, bragged to Facebook user J.L. that he was 
“making $ off [of unemployment benefits] . . . ppp loans.” 
Overt Act No. 11: 
On April 23, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #17 that he was waiting to see if a PPP loan “funded” 
before he submitted additional fraudulent PPP loan applications. 
Overt Act No. 12: 
On April 24, 2021, defendant UTSLER, using 
coded language in a Facebook message exchange, reminded defendant 
SLACK to sign documents in connection with a fraudulent PPP loan 
application. 
Overt Act No. 13: 
On April 24, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, sent a photograph of 
unindicted co-conspirator #16’s driver’s license as well as unindicted 
co-conspirator #2’s social security number to defendant JAMES to use 
in connection with fraudulent PPP loan applications on behalf of 
unindicted co-conspirator #16 and unindicted co-conspirator #2 while 
they were in CDCR custody. 
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Overt Act No. 14: 
On April 24, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, sent unindicted co-
conspirator #18’s PII to defendant JAMES to use in connection with 
fraudulent PPP loan applications on behalf of unindicted co-
conspirator #18. 
Overt Act No. 15: 
On April 24, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, communicated with 
unindicted co-conspirator #2 over a contraband cellular telephone that 
unindicted co-conspirator #2 possessed in CDCR custody and let 
unindicted co-conspirator #2 know that unindicted co-conspirator #16’s 
fraudulent PPP loan application had been successfully submitted. 
Overt Act No. 16: 
On April 24, 2021, unindicted co-conspirator 
#2, using coded language in a Facebook message exchange, told 
defendant GLUCKMAN that he was “panicking” because he received a 
prompt to upload a photo identification in connection with his 
fraudulent PPP loan application and reminded defendant GLUCKMAN that 
he had “stabbed ppl with less stress.” 
Overt Act No. 17: 
On April 25, 2021, unindicted co-conspirator 
#2, using coded language in a Facebook message exchange, told 
defendant GLUCKMAN that his fraudulent PPP loan had been approved. 
Overt Act No. 18: 
On April 26, 2021, defendant SLACK received 
a PPP loan in the amount of $20,833 from a third-party lender. 
Overt Act No. 19: 
On April 26, 2021, defendant JAMES signed 
and submitted a Borrower Application Form for Schedule C Filers Using 
Gross Income on unindicted co-conspirator #16’s behalf that falsely 
stated that unindicted co-conspirator #16 was a self-employed 
individual running a halfway house in Simi Valley, California and 
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generating a gross income of $122,756, when, in fact, unindicted co-
conspirator #16 was incarcerated in a CDCR facility. 
Overt Act No. 20: 
On April 26, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, reminded defendant 
JAMES that they had fraudulent PPP loan applications to complete. 
Overt Act No. 21: 
On April 27, 2021, defendant JAMES, using 
coded language in a Facebook message exchange, told defendant GLUCKMAN 
that she had signed a fraudulent PPP loan application for unindicted 
co-conspirator #16, and sent defendant GLUCKMAN photographs of the 
completed fraudulent application. 
Overt Act No. 22: 
On April 27, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #17 that he could submit fraudulent PPP loan applications 
using a driver’s license, social security number, and bank account 
number, and told unindicted co-conspirator #17 that defendant GLUCKMAN 
could generate all those pieces of information on unindicted co-
conspirator #17’s behalf if needed. 
Overt Act No. 23: 
On April 27, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told unindicted co-
conspirator #17 that his “model” for generating fraudulent PPP loan 
applications was $41,666 and that “U get 2npayments of [$20,000].” 
Overt Act No. 24: 
On April 29, 2021, defendant UTSLER received 
a PPP loan in the amount of $20,833 from a third-party lender.  
Overt Act No. 25: 
On April 30, 2021, unindicted co-conspirator 
#16 obtained a PPP loan in the amount of $20,833 from a third-party 
lender. 
Overt Act No. 26: 
On May 3, 2021, unindicted co-conspirator 
#18 submitted a Borrower Application Form for Schedule C Filers Using 
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Gross Income that falsely stated that he was a self-employed “food 
service” worker with a gross income of $204,899. 
Overt Act No. 27: 
On May 4, 2021, defendant GLUCKMAN, using 
coded language in a Facebook message exchange, told defendant JAMES 
that “[t]here people in prison [that needed help with fraudulent PPP 
loan applications] and they have [access to]. A [contraband] cell 
ph[o]ne for 9!Mor min.” 
Overt Act No. 28: 
On May 4, 2021, unindicted co-conspirator #2 
sent defendant GLUCKMAN the following Facebook message:  
Hey its waylon I got the [contraband cellular] phone all night hit me 
back asap let’s get some stuff done please okay. 
 
 
Overt Act No. 29: 
On May 4, 2021, defendant GLUCKMAN received 
the following Facebook message from defendant Smith: “hey bro can u 
send me a lil cheat sheet on how to do the ppp loan plz bro.” 
Overt Act No. 30: 
On May 5, 2021, defendant GLUCKMAN sent 
defendant JAMES the following photograph via Facebook Messenger: 
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Overt Act No. 31: 
On May 16, 2021, defendant JAMES sent 
defendant GLUCKMAN the following photograph via Facebook Messenger: 
 
Overt Act No. 32: 
On May 16, 2021, defendant UTSLER sent 
defendant GLUCKMAN the following Facebook message:  
Tell me why that stupid womply is saying for my second draw that I 
have requested to cancel my application??? 
 
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Overt Act No. 33: 
On May 16, 2021, defendant RAVIN submitted a 
Borrower Application Form for Schedule C Filers Using Gross Income 
that falsely stated that she was a self-employed and working in 
“catering” with a gross income of $184,254. 
Overt Act No. 34: 
On May 17, 2021, defendant JAMES obtained a 
PPP loan in the amount of $20,832 from a third-party lender. 
Overt Act No. 35: 
On May 20, 2021, defendant RAVIN obtained a 
PPP loan in the amount of $20,833 from a third-party lender. 
Overt Act No. 36: 
On May 25, 2021, defendant SLACK sent 
defendant GLUCKMAN the following photographs via Facebook Messenger: 
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Overt Act No. 37: 
On May 31, 2021, unindicted co-conspirator 
#18 obtained a PPP loan in the amount of $20,833 from a third-party 
lender. 
Overt Act No. 38: 
On June 15, 2021, defendant GLUCKMAN sent 
defendant SLACK the following photograph via Facebook Messenger: 
 
Overt Act No. 39: 
On June 15, 2021, defendant GLUCKMAN sent 
defendant SLACK the following Facebook message: “Your shits been in 
there bank approved since April.” 
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Overt Act No. 40: 
On September 18, 2021, defendant UTSLER 
applied to request that the SBA forgive the $20,833 PPP loan that she 
fraudulently obtained and falsely certified that she complied with all 
requirements in the Paycheck Protection Program Rules. 
Overt Act No. 41: 
On November 23, 2021, defendant UTSLER 
obtained an SBA forgiveness payment for the $20,833 PPP loan that she 
fraudulently obtained. 
Overt Act No. 42: 
On March 23, 2022, defendant RAVIN applied 
to request that the SBA forgive the $20,833 PPP loan that she 
fraudulently obtained and falsely certified that she complied with all 
requirements in the Paycheck Protection Program Rules. 
Overt Act No. 43: 
On March 30, 2022, defendant RAVIN obtained 
an SBA forgiveness payment for the $20,833 PPP loan that defendant 
UTSLER fraudulently obtained.   
Overt Act No. 44: 
Between December 2022 and July 2023, 
defendant SLACK received and ignored multiple notices from a third-
party lender to re-pay his $20,833 PPP loan.  
 
 
 
 
 
 
 
 
 
 
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COUNTS FOUR THROUGH TEN 
[18 U.S.C. § 1344(2), 2(a)] 
Beginning on a date unknown to the Grand Jury, and continuing 
until in or around January 2021, in Los Angeles County, within the 
Central District of California, and elsewhere, defendant SEAN CRAIG 
GLUCKMAN (“GLUCKMAN”), together with others known and unknown to the 
Grand Jury, knowingly and with intent to defraud, devised, 
participated in, and executed a scheme to obtain moneys, funds, 
credits, assets, and other property owned by and in the custody and 
control of federally-insured financial institutions by means of 
material false and fraudulent pretenses, representations, and 
promises. 
A. 
CALIFORNIA EMPLOYMENT DEVELOPMENT DEPARTMENT UNEMPLOYMENT 
INSURANCE 
1. 
The California Employment Development Department (“EDD”) 
administered the unemployment insurance (“UI”) benefits program for 
the State of California. 
2. 
On March 13, 2020, the President of the United States 
declared COVID-19 an emergency under the Robert T. Stafford Disaster 
Relief and Emergency Assistance Act.  As a result, Congress passed the 
Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), 
which President Donald J. Trump signed into law on March 27, 2020.  
The CARES Act provided over $2 trillion in economic relief protections 
to the American people from the public health and economic impacts of 
COVID-19. 
3. 
Prior to the enactment of the CARES Act, to be eligible for 
UI benefits administered by EDD, a person had to have been employed 
and worked in California and received at least a certain amount of 
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wages from an employer in the 18 months preceding his/her UI benefits 
claim.  Because of this requirement, self-employed workers, 
independent contractors, and employees with insufficient earnings were 
not eligible to receive regular UI benefits.   
4. 
The CARES Act established a new program — Pandemic 
Unemployment Assistance (“PUA”) — to provide UI benefits during the 
COVID-19 pandemic to people who did not qualify for regular UI 
benefits, including business owners, self-employed workers, 
independent contractors, and those with a limited work history, who 
were out of business or had significantly reduced their services as a 
direct result of the pandemic.  UI benefits provided under the PUA 
program were sometimes referred to as PUA benefits. 
5. 
Under the PUA provisions of the CARES Act, a person who was 
a business owner, self-employed worker, independent contractor, or gig 
worker could qualify for PUA benefits administered by EDD if he/she 
previously performed such work in California and was unemployed, 
partially unemployed, unable to work, or unavailable to work due to a 
COVID-19-related reason. 
6. 
Persons applying for PUA benefits did not need to submit 
any supporting documents to EDD with their applications.  Claimants 
reported their total income for the 2019 calendar year on the 
application.  The stated income was used to calculate the benefits to 
be paid, which were at least $167 per week. 
7. 
A PUA benefits claimant was required to answer various 
questions on his/her application to establish his/her eligibility for 
the benefits.  The claimant was required to provide his/her name, 
Social Security Number, and mailing address.  The claimant was also 
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required to identify a qualifying occupational status and COVID-19 
related reason for being out of work.  
8. 
After it approved an application for UI benefits, including 
an application submitted pursuant to the PUA program, the EDD would 
create a debit account (“EDD debit account”) with Bank of America.  An 
Electronic Bill Payment (“EBP”) debit card linked to the EDD debit 
account would then be mailed via the United States Postal Service from 
Bank of America to the claimant at the address the claimant provided 
as his/her mailing address on his/her UI benefits application. 
9. 
The EDD would deposit UI benefits, including pandemic 
benefits, to the EDD debit account. The debit card could then be used 
to withdraw the benefits from the EDD debit account in cash, using 
automated teller machines (“ATMs”), including ATMs that Bank of 
America operated, and to pay for purchases. 
10. 
Bank of America was a financial institution that was 
insured by the Federal Deposit Insurance Corporation. 
11. 
Defendant GLUCKMAN was a resident of Los Angeles County, 
California.  
B. 
THE FRAUDULENT SCHEME 
12. 
The fraudulent scheme operated and was carried out, in 
substance, in the following manner:  
a. 
Defendant GLUCKMAN or another individual would submit 
a fraudulent UI application to EDD using a victim’s name and personal 
identifying information (“PII”).  The PII sometimes accurately 
reflected that of the victim and was sometimes incorrect.  
b. 
Defendant GLUCKMAN would obtain a Bank of America 
debit card with access to EDD UI funds.  
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13. 
Defendant GLUCKMAN would use the Bank of America debit card 
to withdraw UI funds from an automated teller machine (“ATM”) without 
the victim’s permission.  In doing so, defendant GLUCKMAN falsely 
represented to Bank of America that he had the victim’s authority to 
use the ATM card and concealed from Bank of America that he was not 
authorized to use the ATM card. 
C. 
EXECUTION OF THE SCHEME 
14. 
On or about the following dates, in Los Angeles and 
Riverside Counties, within the Central District of California, and 
elsewhere, defendant GLUCKMAN, together with others known and unknown 
to the Grand Jury, aiding and abetting each other, committed and 
willfully caused others to commit the following acts, each of which 
constituted an execution of the fraudulent scheme: 
COUNT 
DATE 
ACT 
 
FOUR 
8/20/2020 
Use of an EDD debit card ending in 
2603 issued in the name of W.S., at 
Bank of America to make a 
withdrawal of $1,000, in Tarzana, 
California. 
 
FIVE 
9/06/2020 
Use of an EDD debit card ending in 
6488 issued in the name of D.L., at 
Bank of America to make a 
withdrawal of $1,000, in Los 
Angeles, California. 
 
SIX 
9/6/2020 
Use of an EDD debit card ending in 
9505 issued in the name of C.J., at 
Bank of America to make a 
withdrawal of $1,000, in Los 
Angeles, California. 
 
SEVEN 
9/6/2020 
Use of an EDD debit card ending in 
0458 issued in the name of W.D., at 
Bank of America to make a 
withdrawal of $1,000, in Los 
Angeles, California. 
 
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COUNT 
DATE 
ACT 
 
EIGHT 
9/6/2020 
Use of an EDD debit card ending in 
8864 issued in the name of Dav.L., 
at Bank of America to make a 
withdrawal of $1,000, in Los 
Angeles, California. 
 
NINE  
9/6/2020 
Use of an EDD debit card ending in 
7312 issued in the name of S.B., at 
Bank of America to make a 
withdrawal of $1,000, in Los 
Angeles, California. 
 
TEN 
1/21/2021 
Use of an EDD debit card ending in 
2557 issued in the name of P.H., at 
Bank of America to make a 
withdrawal of $1,000, in 
Northridge, California. 
 
 
 
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COUNTS ELEVEN THROUGH TWELVE 
[18 U.S.C. § 1028A(a)(1)] 
Paragraphs 1 through 13 of Counts Four through Ten of this 
Indictment are re-alleged and incorporated by reference as if fully 
set forth herein.  
On or about the dates set forth below, in Los Angeles County, 
within the Central District of California, and elsewhere, defendant 
GLUCKMAN, as set forth below, knowingly transferred, possessed, and 
used, and willfully caused to be transferred, possessed, and used, 
without lawful authority, means of identification that defendant knew 
belonged to other persons, namely, the names and Bank of America EDD 
debit account numbers of the individuals identified by initial below, 
during and in relation to the felony violations charged in the counts 
of this Indictment identified below: 
COUNT 
DATE 
OTHER 
PERSON(S) 
FELONY VIOLATION 
ELEVEN 
8/20/2020 
 
W.S. 
18 U.S.C. § 1344(a) as 
charged in Count Four ___ 
 
TWELVE 
9/06/2020 
D.L. 
18 U.S.C. § 1344(a) as 
charged in Count Five ___ 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTEEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about September 11, 2021, in Los Angeles County, within 
the Central District of California, defendant CIARA JACOBS, also 
known as “Simba Jay,” knowingly and intentionally possessed with 
intent to distribute methamphetamine, a Schedule II controlled 
substance, a photo of which is below. 
 
 
 
 
 
 
 
 
 
 
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COUNT FOURTEEN  
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about January 10, 2022, in Los Angeles County, within the 
Central District of California, defendant WALTER HUBERT LEIMERT, also 
known as “Creepz,” knowingly and intentionally possessed with intent 
to distribute at least 50 grams, that is, approximately 109.24 grams, 
of a mixture and substance containing a detectable amount of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTEEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about January 10, 2022, in Los Angeles County, within the 
Central District of California, defendant WALTER HUBERT LEIMERT, also 
known as “Creepz,” knowingly and intentionally possessed with intent 
to distribute heroin, a Schedule I narcotic drug controlled 
substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SIXTEEN  
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about February 3, 2022, in Los Angeles County, within the 
Central District of California, defendant ALBERT ETHAN EKLUND 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 137.8 grams, of a mixture and 
substance containing a detectable amount of methamphetamine, a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTEEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about February 3, 2022, in Los Angeles County, within the 
Central District of California, defendant ALBERT ETHAN EKLUND 
knowingly and intentionally possessed with intent to distribute 
heroin, a Schedule I narcotic drug controlled substance. 
 
 
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COUNT EIGHTEEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about March 23, 2022, in Los Angeles County, within the 
Central District of California, defendant DANIEL YACOUB, also known 
as “Danny Boy,” knowingly and intentionally possessed with intent to 
distribute heroin, a Schedule I narcotic drug controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT NINETEEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about March 23, 2022, in Los Angeles County, within the 
Central District of California, defendant DANIEL YACOUB, also known 
as “Danny Boy,” knowingly and intentionally possessed with intent to 
distribute methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about March 23, 2022, in Los Angeles County, within the 
Central District of California, defendant DANIEL YACOUB, also known 
as “Danny Boy,” knowingly and intentionally possessed with intent to 
distribute N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide 
(“fentanyl”), a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-ONE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about May 24, 2022, in Los Angeles County, within the 
Central District of California, defendant ADAM L. RODNEY knowingly 
and intentionally possessed with intent to distribute at least 50 
grams, that is, approximately 83.02 grams, of methamphetamine, a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-TWO 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi)] 
On or about May 24, 2022, in Los Angeles County, within the 
Central District of California, defendant ADAM L. RODNEY knowingly 
and intentionally possessed with intent to distribute at least 400 
grams, that is, approximately 1,165.23 grams, of a mixture and 
substance containing a detectable amount of N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-THREE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about February 9, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute at least 50 grams, that is, approximately 1,999 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-FOUR 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi)] 
On or about February 9, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute at least 400 grams, that is, approximately 743.6 grams, of 
a mixture and substance containing a detectable amount of N-phenyl-N-
[1-(2-phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-FIVE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about February 9, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute cocaine base, a Schedule II narcotic drug controlled 
substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-SIX 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about February 21, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute at least 50 grams, that is, approximately 172 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-SEVEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(vi)] 
On or about February 21, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute at least 40 grams, that is, approximately 304 grams, of a 
mixture and substance containing a detectable amount of N-phenyl-N-
[1-(2-phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-EIGHT 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about February 21, 2023, in Los Angeles County, within the 
Central District of California, defendant KEVIN MULVIHILL, also known 
as “Mo,” knowingly and intentionally possessed with intent to 
distribute heroin, a Schedule I narcotic drug controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT TWENTY-NINE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about February 27, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 195.6 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about February 27, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute  
heroin, a Schedule I narcotic drug controlled substance. 
 
 
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COUNT THIRTY-ONE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about March 27, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 214.1 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-TWO 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about March 27, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute 
heroin, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-THREE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(i)] 
On or about April 13, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least one kilogram, that is, approximately 1,006.5 grams, of a 
mixture and substance containing a detectable amount of heroin, a 
Schedule I narcotic drug controlled substance,  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-FOUR 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about April 13, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 3,726 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
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COUNT THIRTY-FIVE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi)] 
On or about April 13, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 400 grams, that is, approximately 3,480.16 grams, of a mixture 
and substance containing a detectable amount of N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-SIX 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about June 23, 2023, in Los Angeles County, within the 
Central District of California, defendant DONALD EVERETT CUNNINGHAM, 
also known as (“aka”) “DJ,” aka “Monster,” knowingly and 
intentionally possessed with intent to distribute at least 50 grams, 
that is, approximately 336 grams, of methamphetamine, a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-SEVEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi)] 
On or about June 23, 2023, in Los Angeles County, within the 
Central District of California, defendant DONALD EVERETT CUNNINGHAM, 
also known as (“aka”) “DJ,” aka “Monster,” knowingly and 
intentionally possessed with intent to distribute at least 400 grams, 
that is, approximately 953.5 grams, of a mixture and substance 
containing a detectable amount of N-phenyl-N-[1-(2-phenylethyl)-4-
piperidinyl] propanamide (“fentanyl”), a Schedule II controlled 
substance. 
 
 
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COUNT THIRTY-EIGHT 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 53.90 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT THIRTY-NINE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(i)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute at 
least 100 grams, that is, approximately 185.3 grams, of a mixture and 
substance containing a detectable amount of heroin, a Schedule I 
narcotic drug controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally distributed N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-ONE 
[21 U.S.C. §§ 841(a)(1), (b)(2)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly and intentionally possessed with intent to distribute 
alprazolam, a Schedule IV controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-TWO 
[21 U.S.C. §§ 841(a)(1), (b)(1)(C)] 
On or about August 17, 2023, in Los Angeles County, within the 
Central District of California, defendant KENNETH RICHARD MACDONALD, 
also known as (“aka”) “Misfit,” aka “Kenny Mac,” knowingly and 
intentionally possessed with intent to distribute N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance, pictured below. 
 
 
 
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COUNT FORTY-THREE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii); 18 U.S.C. § 2(a)] 
On or about September 26, 2023, in Los Angeles County, within 
the Central District of California, defendant BRIAN GLENN EKELUND, 
also known as (“aka”) “Rascal,” GUY MANNING WILLS, aka “FedEx,” 
unindicted co-conspirator #35, and unindicted co-conspirator #36, 
aiding and abetting each other, knowingly and intentionally possessed 
with intent to distribute at least 50 grams, that is, approximately 
3,122.8 grams, of methamphetamine, a Schedule II controlled 
substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-FOUR 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(i); 18 U.S.C. § 2(a)] 
On or about September 26, 2023, in Los Angeles County, within 
the Central District of California, defendant BRIAN GLENN EKELUND, 
also known as (“aka”) “Rascal,” GUY MANNING WILLS, aka “FedEx,” 
unindicted co-conspirator #35, and unindicted co-conspirator #36, 
aiding and abetting each other, knowingly and intentionally possessed 
with intent to distribute at least 100 grams, that is, approximately 
619.7 grams, of a mixture and substance containing a detectable 
amount of heroin, a Schedule I narcotic drug controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-FIVE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(ii); 18 U.S.C. § 2(a)] 
On or about September 26, 2023, in Los Angeles County, within 
the Central District of California, defendant BRIAN GLENN EKELUND, 
also known as (“aka”) “Rascal,” GUY MANNING WILLS, aka “FedEx,” 
unindicted co-conspirator #35, and unindicted co-conspirator #36, 
aiding and abetting each other, knowingly and intentionally possessed 
with intent to distribute at least 500 grams, that is, approximately 
552.6 grams, of a mixture and substance containing a detectable 
amount of cocaine, a Schedule II controlled substance. 
 
 
 
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COUNT FORTY-SIX 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about October 24, 2023, in Los Angeles County, within the 
Central District of California, defendant PAGET GARY EKELUND 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 135.3 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-SEVEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi)] 
On or about October 24, 2023, in Los Angeles County, within the 
Central District of California, defendant PAGET GARY EKELUND 
knowingly and intentionally possessed with intent to distribute at 
least 400 grams, that is, approximately 982.2 grams, of a mixture and 
substance containing a detectable amount of N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FORTY-EIGHT 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about November 15, 2023, in Los Angeles County, within the 
Central District of California, defendant MICHAEL ANTHONY CHATTERTON, 
also known as “Reckless,” knowingly and intentionally possessed with 
intent to distribute at least five grams, that is, approximately 
27.96 grams, of methamphetamine, a Schedule II controlled substance, 
depicted in the photo below. 
 
 
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COUNT FORTY-NINE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about November 28, 2023, in Los Angeles County, within the 
Central District of California, defendant MICHAEL ANTHONY CHATTERTON, 
also known as “Reckless,” knowingly and intentionally possessed with 
intent to distribute at least five grams, that is, approximately 
10.26 grams, of methamphetamine, a Schedule II controlled substance. 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about January 1, 2024, in Los Angeles County, within the 
Central District of California, defendant RYAN SCOTT HARBAND 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 217.85 grams, of a mixture and 
substance containing a detectable amount of methamphetamine, a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-ONE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(vi)] 
On or about January 1, 2024, in Los Angeles County, within the 
Central District of California, defendant RYAN SCOTT HARBAND 
knowingly and intentionally possessed with intent to distribute at 
least 40 grams, that is, approximately 82.89 grams, of a mixture and 
substance containing a detectable amount of N-phenyl-N-[1-(2-
phenylethyl)-4-piperidinyl] propanamide (“fentanyl”), a Schedule II 
controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-TWO 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about January 3, 2024, in Los Angeles County, within the 
Central District of California, defendant CLAIRE PATRICIA HAVILAND, 
also known as (“aka”) “Trish,” aka “SFV Mama,” knowingly and 
intentionally possessed with intent to distribute at least five 
grams, that is, approximately 26.1 grams, of methamphetamine, a 
Schedule II controlled substance, depicted in the photo below. 
 
 
 
 
 
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COUNT FIFTY-THREE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about January 8, 2024, in Los Angeles County, within the 
Central District of California, defendant KEVIN D. FRANCIS knowingly 
and intentionally possessed with intent to distribute at least five 
grams, that is, approximately 31.18 grams, of methamphetamine, a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-FOUR 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(vi)] 
On or about January 8, 2024, in Los Angeles County, within the 
Central District of California, defendant KEVIN D. FRANCIS knowingly 
and intentionally possessed with intent to distribute at least 40 
grams, that is, approximately 86.23 grams, of a mixture and substance 
containing a detectable amount of N-phenyl-N-[1-(2-phenylethyl)-4-
piperidinyl] propanamide (“fentanyl”), a Schedule II controlled 
substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-FIVE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about January 10, 2024, in Los Angeles County, within the 
Central District of California, defendant CLAIRE PATRICIA HAVILAND, 
also known as (“aka”) “Trish,” aka “SFV Mama,” knowingly and 
intentionally possessed with intent to distribute at least five 
grams, that is, approximately 19.1 grams, of methamphetamine, a 
Schedule II controlled substance, depicted in the photo below. 
 
 
 
 
 
 
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COUNT FIFTY-SIX 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about January 31, 2024, in Los Angeles County, within the 
Central District of California, defendant ROBERT ANTHONY BAKER 
knowingly and intentionally possessed with intent to distribute at 
least 50 grams, that is, approximately 443.8 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-SEVEN 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about March 10, 2024, in Los Angeles County, within the 
Central District of California, defendant PAUL ERIC ATKINSON, also 
known as (“aka”) “Pork Chop,” aka “Chops,” knowingly and 
intentionally possessed with intent to distribute at least five 
grams, that is, approximately 20.61 grams, of methamphetamine, a 
Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-EIGHT 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(vi)] 
On or about March 10, 2024, in Los Angeles County, within the 
Central District of California, defendant PAUL ERIC ATKINSON, also 
known as (“aka”) “Pork Chop,” aka “Chops,” knowingly and 
intentionally possessed with intent to distribute at least 40 grams, 
that is, approximately 99.76 grams, of a mixture and substance 
containing a detectable amount of N-phenyl-N-[1-(2-phenylethyl)-4-
piperidinyl] propanamide (“fentanyl”), a Schedule II controlled 
substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT FIFTY-NINE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(viii)] 
On or about March 18, 2024, in Los Angeles County, within the 
Central District of California, defendant JOHN MICHAEL REED, also 
known as “Johnny Boi,” knowingly and intentionally possessed with 
intent to distribute at least 50 grams, that is, approximately 86.13 
grams, of a mixture or substance containing a detectable amount of 
methamphetamine, a Schedule II controlled substance, depicted in the 
photo below. 
 
 
 
 
 
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COUNT SIXTY 
[21 U.S.C. §§ 841(a)(1), (b)(1)(A)(vi); 18 U.S.C. § 2(a)] 
On or about March 13, 2024, in Los Angeles County, within the 
Central District of California, defendants MICHAEL VITANZA, also 
known as (“aka”) “Suspect,” CLAIRE PATRICIA HAVILAND, aka “Trish,” 
aka “SFV Mama,” CHARISSA MARIE CHOTARD, aka “Brat,” and JULIE ANN 
ROMERO, and others known and unknown to the Grand Jury, each aiding 
and abetting the other, knowingly and intentionally possessed with 
intent to distribute at least 400 grams, that is, approximately 
4,059.2 grams, of a mixture and substance containing a detectable 
amount of N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide 
(“fentanyl”), a Schedule II controlled substance. 
 
 
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COUNT SIXTY-ONE 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about March 13, 2024, in Los Angeles County, within the 
Central District of California, defendant MICHAEL VITANZA, also known 
as “Suspect,” knowingly and intentionally possessed with intent to 
distribute at least five grams, that is, approximately 49.0 grams, of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SIXTY-TWO 
[21 U.S.C. §§ 841(a)(1), (b)(1)(B)(viii)] 
On or about March 18, 2024, in Los Angeles County, within the 
Central District of California, defendant JOHN MICHAEL REED, also 
known as “Johnny Boi,” knowingly and intentionally possessed with 
intent to distribute at least 50 grams, that is, approximately 86.13 
grams, of a mixture and substance containing a detectable amount of 
methamphetamine, a Schedule II controlled substance. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SIXTY-THREE 
[18 U.S.C. § 922(g)(1)] 
On or about June 23, 2023, in Los Angeles County, within the 
Central District of California, defendant DONALD EVERETT CUNNINGHAM, 
also known as (“aka”) “DJ,” aka “Monster,” (“CUNNINGHAM”) knowingly 
possessed the following firearms, in and affecting interstate and 
foreign commerce: 
1. 
a Sterling Arms .25 caliber pistol, bearing serial number 
058339; 
2. 
an HS Produkt, Hellcat, 9mm pistol, bearing serial number 
BB540124; 
3. 
a Kel-Tec, PF-9, 9mm pistol, bearing serial number RVK24; 
4. 
a Kimber, Stainless Pro Carry II, .45 caliber pistol, 
bearing serial number KR292302; 
5. 
a Sturm, Ruger & Co., GP100, .357 revolver, bearing serial 
number 1742248; 
6. 
a Beretta, 950, .22 caliber pistol, bearing serial number 
87529CC; 
7. 
an A.A. Arms, AP9, 9mm pistol, bearing an obliterated 
serial number; 
8. 
a High Standard, Model 30, .22 caliber rifle, bearing no 
serial number; and 
9. 
a Mauser, P08, 9mm pistol, bearing no serial number. 
Defendant CUNNINGHAM possessed such firearms knowing that he had 
previously been convicted of at least one of the following felony 
crimes, each punishable by imprisonment for a term exceeding one 
year: 
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1. 
Possession of a Controlled Substance for Sale, in violation 
of California Health and Safety Code Section 11378, in the Superior 
Court for the State of California, County of Los Angeles, case number 
LA060537, on or about December 12, 2008; 
2. 
Possession of a Dangerous Weapon, in violation of 
California Penal Code Section 29800(a)(1), in the Superior Court for 
the State of California, County of Los Angeles, case number LA060537, 
on or about December 12, 2008; 
3. 
Possession of Methamphetamine, in violation of California 
Health and Safety Code Section 11377(a), in the Superior Court for the 
State of California, County of Los Angeles, case number LA066458, on 
or about May 20, 2011; 
4. 
Possession of Methamphetamine, in violation of California 
Health and Safety Code Section 11377(a), in the Superior Court for the 
State of California, County of Los Angeles, case number PA074960, on 
or about May 6, 2013; 
5. 
Possession of a Controlled Substance, in violation of 
California Health and Safety Code Section 11350(a), in the Superior 
Court for the State of California, County of Los Angeles, case number 
LA073726, on or about June 4, 2013; 
6. 
Possession of Methamphetamine, in violation of California 
Health and Safety Code Section 11377(a), in the Superior Court for the 
State of California, County of Los Angeles, case number LA073659, on 
or about June 4, 2013; and 
7. 
Felon in Possession of a Firearm, in violation of 
California Penal Code Section 29800(a)(1), in the Superior Court for 
the State of California, County of Los Angeles, case number BA444115, 
on or about March 24, 2016. 
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COUNT SIXTY-FOUR 
[18 U.S.C. § 922(g)(1)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
(“RILEY”) knowingly possessed the following firearm, in and affecting 
interstate and foreign commerce: a Taurus, Model PT-38S, .380 caliber 
semi-automatic pistol, bearing serial number LBM31379. 
Defendant RILEY possessed such firearms knowing that he had 
previously been convicted of at least one of the following felony 
crimes, each punishable by imprisonment for a term exceeding one 
year:   
1. 
Possession of a Firearm by a Felon, in violation of 
California Penal Code Section 12021(A)(1), in the Superior Court for 
the State of California, County of Los Angeles, case number LA067081, 
on or about March 21, 2011; 
2. 
Transportation or Sale of Methamphetamine, in violation of 
California Health and Safety Code Section 11379(A)), in the Superior 
Court for the State of California, County of Los Angeles, case number 
LA067081, on or about March 21, 2011; 
3. 
Possession of Methamphetamine for Sale, in violation of 
California Health and Safety Code Section 11378, in the Superior Court 
for the State of California, County of Los Angeles, case number 
LA067071, on or about March 21, 2011. 
 
 
 
 
 
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COUNT SIXTY-FIVE 
[18 U.S.C. § 922(g)(1)] 
On or about October 24, 2023, in Los Angeles County, within the 
Central District of California, defendant SCOTT JOSHUA VENNUM 
(“VENNUM”) knowingly possessed the following firearms, in and 
affecting interstate and foreign commerce: 
1. 
a Glock model 22, 40 caliber, semi-automatic pistol, 
bearing serial number AAFF852; and 
2. 
a Smith & Wesson model MP 15, 5.56 caliber, semi-automatic 
rifle, bearing serial number TH32357. 
Defendant VENNUM possessed such firearms knowing that he had 
previously been convicted of at least one of the following felony 
crimes, each punishable by imprisonment for a term exceeding one 
year:   
1. 
Possession of Methamphetamine for Sale, in violation of 
California Health and Safety Code Section 11378, in the Superior Court 
for the State of California, County of Orange, case number 03CF2251, 
on or about April 2, 2004; 
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Possession of Methamphetamine for Sale, in violation of 
California Health and Safety Code Section 11377, in the Superior Court 
for the State of California, County of Orange, case number 06HF1776, 
on or about November 27, 2006; 
3. 
Accessory after the Fact, in violation of California Penal 
Code Section 2, in the Superior Court for the State of California, 
County of Orange, case number 06NF4421, on or about April 16, 2007; 
4. 
False Impersonation, in violation of California Penal Code 
Section 529(3), in the Superior Court for the State of California, 
County of Orange, case number 09WF1762, on or about May 17, 2010; 
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5. 
Unauthorized Use of Another Person’s Personal Identifying 
Information, in violation of California Penal Code 530.5(a) in 
violation of California Penal Code 484e(a) in the Superior Court for 
the State of California, County of Orange, case number 09HF1173, on or 
about May 17, 2010;  
6. 
Petty Theft, in violation of California Penal Code 484e(a) 
in the Superior Court for the State of California, County of Orange, 
case number 09HF1173, on or about May 17, 2010. 
 
 
 
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COUNT SIXTY-SIX 
[18 U.S.C. § 922(g)(1)] 
On or about October 24, 2023, in Los Angeles County, within the 
Central District of California, defendant PAGET GARY EKELUND (“P. 
EKELUND”) knowingly possessed the following firearms, in and 
affecting interstate and foreign commerce: 
1. 
a Smith & Wesson model M&P 9C, 9mm caliber, semi-automatic 
pistol, bearing serial number HUJ4144; 
2. 
a Remington Arms model 700, 7-08 caliber, bolt action 
rifle, bearing serial number G6821774; 
3. 
a Remington Arms model 742, 30-06 caliber, bolt action 
rifle, bearing serial number 37032; 
4. 
a Weatherby model Vanguard, 30-06 caliber, bolt action 
rifle, bearing serial number VB226525; and 
5. 
a Sig Sauer model P220, 45 caliber, semi-automatic pistol, 
bearing serial number 37A005830. 
Defendant P. EKELUND possessed such firearms knowing that he had 
previously been convicted of at least one of the following felony 
crimes, each punishable by imprisonment for a term exceeding one 
year:   
1. 
Receiving Stolen Property, in violation of California Penal 
Code Section 496(a), in the Superior Court for the State of 
California, County of Los Angeles, case number PA029769, on or about 
July 24, 1998; and 
2. 
Vehicle Theft, in violation of California Vehicle Code 
Section 10851(a), in the Superior Court for the State of California, 
County of Los Angeles, case number LA094157, on or about August 19, 
2022. 
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COUNT SIXTY-SEVEN 
[18 U.S.C. § 922(g)(1)] 
On or about March 13, 2024, in Los Angeles County, within the 
Central District of California, defendant MICHAEL VITANZA, also known 
as “Suspect,” knowingly possessed the following firearm, in and 
affecting interstate and foreign commerce: a black Ruger LCP Max, 
.380 caliber firearm, bearing serial number 380963495, knowing that 
he had previously been convicted of the following felony crime 
punishable by a term of imprisonment exceeding one year: Criminal 
Threats, in violation of California Penal Code Section 422, in the 
Superior Court for the State of California, County of Los Angeles, 
case number PA858256, on or about June 25, 2008. 
 
 
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COUNT SIXTY-EIGHT 
[18 U.S.C. § 924(c)(1)(A)(i)] 
On or about April 13, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly possessed firearms, namely: (1) a SIG Sauer P226 pistol, 
bearing serial number U833548; (2) a Sten MKII rifle, bearing serial 
number 49873; (3) a Palmetto State Armory M4 rifle, bearing serial 
number LW184316; (4) a Beretta ARX 100 semi-automatic rifle, bearing 
serial number SX03106; (5) two Polymer80 firearms, bearing no serial 
numbers; (6) a Beretta Tomcat pistol, bearing serial number 
DAA096925; and (7) a Hi-Point Haskell JHP45 pistol, bearing serial 
number X4120545, in furtherance of a drug trafficking crime, namely, 
conspiracy to possess with intent to distribute and to distribute 
controlled substances, in violation of Title 21, United States Code, 
Section 846, as charged in Count Two of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SIXTY-NINE 
[18 U.S.C. § 924(c)(1)(A)(i)] 
On or about June 23, 2023, in Los Angeles County, within the 
Central District of California, defendant DONALD EVERETT CUNNINGHAM, 
also known as (“aka”) “DJ,” aka “Monster,” knowingly possessed 
firearms, namely: (1) a Sterling Arms .25 caliber pistol, bearing 
serial number 058339; (2) an HS Produkt, Hellcat, 9mm pistol, bearing 
serial number BB540124; (3) a Kel-Tec, PF-9, 9mm pistol, bearing 
serial number RVK24; (4) a Kimber, Stainless Pro Carry II, .45 
caliber pistol, bearing serial number KR292302; (5) a Sturm, Ruger & 
Co., GP100, .357 revolver, bearing serial number 1742248; (6) a 
Beretta, 950, .22 caliber pistol, bearing serial number 87529CC; 
(7) an A.A. Arms, AP9, 9mm pistol, bearing an obliterated serial 
number; (8) a High Standard, Model 30, .22 caliber rifle, bearing no 
serial number; and (9) a Mauser, P08, 9mm pistol, bearing no serial 
number, in furtherance of a drug trafficking crime, namely, 
conspiracy to possess with intent to distribute and to distribute 
controlled substances, in violation of Title 21, United States Code, 
Section 846, as charged in Count Two of this Indictment. 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY 
[18 U.S.C. § 924(c)(1)(A)(i)] 
On or about July 20, 2023, in Los Angeles County, within the 
Central District of California, defendant RICHARD KEVIN RILEY 
knowingly possessed a firearm, namely a Taurus, Model PT-38S, .380 
caliber semi-automatic pistol, bearing serial number LBM31379 in 
furtherance of a drug trafficking crime, namely, conspiracy to 
possess with intent to distribute and to distribute controlled 
substances, in violation of Title 21, United States Code, Section 
846, as charged in Count Two of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY-ONE 
[18 U.S.C. § 924(c)(1)(A)(i)] 
On or about October 24, 2023, in Los Angeles County, within the 
Central District of California, defendant PAGET GARY EKELUND 
knowingly possessed firearms, namely (1) a Smith & Wesson model M&P 
9C, 9mm caliber, semi-automatic pistol, bearing serial number 
HUJ4144; (2) a Remington Arms model 700, 7-08 caliber, bolt action 
rifle, bearing serial number G6821774; (3) a Remington Arms model 
742, 30-06 caliber, bolt action rifle, bearing serial number 37032; 
(4) a Weatherby model Vanguard, 30-06 caliber, bolt action rifle, 
bearing serial number VB226525; and (5) a Sig Sauer model P220, 45 
caliber, semi-automatic pistol, bearing serial number 37A005830   
in furtherance of a drug trafficking crime, namely, conspiracy to 
possess with intent to distribute and to distribute controlled 
substances, in violation of Title 21, United States Code, Section 
846, as charged in Count Two of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY-TWO 
[18 U.S.C. § 924(c)(1)(A)(i)] 
On or about March 13, 2024, in Los Angeles County, within the 
Central District of California, defendant MICHAEL VITANZA, also known 
as “Suspect,” knowingly possessed firearms, namely (1) a black Ruger 
LCP Max, .380 caliber firearm, bearing serial number 380963495; and 
(2) a tan Polymer 80 pistol with attached laser with no serial 
number, in furtherance of a drug trafficking crime, namely, 
conspiracy to possess with intent to distribute and to distribute 
controlled substances, in violation of Title 21, United States Code, 
Section 846, as charged in Count Two of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY-THREE 
[18 U.S.C. § 1029(a)(3)] 
On or about February 17, 2022, in Los Angeles County, within the 
Central District of California, defendant BRIANNE BREWER, also known 
as “Bri,” (“BREWER”) knowingly and with intent to defraud, possessed 
at least fifteen unauthorized access devices (as defined in Title 18, 
United States Code, Sections 1029(e)(1) and (3)), namely, 
approximately one social security number, fourteen credit account 
numbers, and five dates of birth all belonging to persons other than 
defendant BREWER, with said possession affecting interstate and 
foreign commerce. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY-FOUR 
[18 U.S.C. § 1028A(a)(1)] 
On or about February 17, 2022, in Los Angeles County, within the 
Central District of California, defendant BRIANNE BREWER, also known 
as “Bri,” (“BREWER”) knowingly possessed, without lawful authority, a 
means of identification that defendant BREWER knew belonged to 
another person, namely, the name, date of birth, and driver’s license 
number of victim N.B., during and in relation to the offense of 
Possession of Fifteen or More Unauthorized Access Devices, a felony 
violation of Title 18, United States Code, Section 1029(a)(3), as 
charged in Count Seventy-Three of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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COUNT SEVENTY-FIVE 
[18 U.S.C. § 1029(a)(3)] 
On or about March 28, 2024, in Los Angeles County, within the 
Central District of California, defendant CORY DANIEL SIMS, also 
known as  “Sicko,” (“SIMS”) knowingly and with intent to defraud, 
possessed at least fifteen unauthorized access devices (as defined in 
Title 18, United States Code, Sections 1029(e)(1) and (3)), namely, 
approximately four social security numbers, five credit account 
numbers, seven bank account numbers, and five dates of birth all 
belonging to persons other than defendant SIMS, with said possession 
affecting interstate and foreign commerce. 
 
 
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COUNT SEVENTY-SIX 
[18 U.S.C. § 1028A(a)(1)] 
On or about March 28, 2024, in Los Angeles County, within the 
Central District of California, defendant CORY DANIEL SIMS, also 
known as “Sicko,” knowingly possessed, without lawful authority, a 
means of identification that defendant SIMS knew belonged to another 
person, namely, the name, date of birth, and social security number 
of victim M.N., during and in relation to the offense of Possession 
of Fifteen or More Unauthorized Access Devices, a felony violation of 
Title 18, United States Code, Section 1029(a)(3), as charged in Count 
Seventy-Five of this Indictment. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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FORFEITURE ALLEGATION ONE 
[18 U.S.C. § 1963, 18 U.S.C. § 981(a)(1)(C), and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Federal Rule of Criminal Procedure 32.2, notice 
is hereby given to the defendants charged in Count One of the 
Indictment that the United States of America will seek forfeiture as 
part of any sentence, pursuant to Title 18, United States Code, 
Section 1963, Title 18, United States Code, Section 981(a)(1)(C), and 
Title 28, United States Code, Section 2461(c), in the event of any 
such defendant’s conviction under Count One of the Indictment.   
2. 
Any defendant so convicted shall forfeit to the United 
States of America the following: 
 
 
(a) Any interest the convicted defendant has acquired or 
maintained in violation of section 1962; 
 
 
(b) Any interest in, security of, claim against, or 
property or contractual right of any kind affording a source or 
influence over, any enterprise which the convicted defendant has 
established, operated, controlled, conducted, or participated in the 
conduct of, in violation of section 1962; 
 
 
(c) Any property constituting, or derived from, any 
proceeds which the person obtained, directly or indirectly, from 
racketeering activity in violation of section 1962; and 
 
 
(d) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a), (b), and (c). 
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), and 
Title 18, United States Code, Section 1963(m), any defendant so 
convicted shall forfeit substitute property, up to the total value of 
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the property described in the preceding paragraph if, as the result 
of any act or omission of said defendant, the property described in 
the preceding paragraph or any portion thereof (a) cannot be located 
upon the exercise of due diligence; (b) has been transferred, 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 that cannot be 
divided without difficulty. 
 
 
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FORFEITURE ALLEGATION TWO 
[21 U.S.C. § 853, 18 U.S.C. § 924(d)(1), 21 U.S.C. § 881(a)(6) and 
(a)(11), and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal 
Procedure, notice is hereby given to the defendants charged in Count 
Two of the Indictment that the United States of America will seek 
forfeiture as part of any sentence, pursuant to Title 21, United 
States Code, Section 853, Title 21, United States Code, Section 
881(a)(6) and (a)(11), Title 18, United States Code, Section 
924(d)(1), and Title 28, United States Code, Section 2461(c), in the 
event of any such defendant’s conviction under Count Two of the 
Indictment.   
2. 
Any defendant so convicted shall forfeit to the United 
States of America the following: 
 
 
(a)  All right, title, and interest in any and all 
property, real or personal, constituting or derived from, any 
proceeds which the defendant obtained, directly or indirectly, from 
any offense set forth in Count Two of the Indictment; 
 
 
(b)  All right, title, and interest in any and all 
property, real or personal, used, or intended to be used, in any 
manner or part, to commit, or to facilitate the commission of any 
offense set forth in Count Two of the Indictment;  
 
 
(c)  All right, title, and interest in any firearm or 
ammunition involved in or used in any such offense; and  
(d)  To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a), (b), and (c). 
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3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), any 
defendant so convicted shall forfeit substitute property, up to the 
total value of the property described in the preceding paragraph if, 
as the result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
 
 
 
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FORFEITURE ALLEGATION THREE 
[18 U.S.C. § 982(a)(2)(A), 18 U.S.C. § 981(a)(1)(C), and 28 U.S.C. 
§ 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to the defendants charged in any of 
Counts Three through Twelve of the Indictment that the United States 
of America will seek forfeiture as part of any sentence, pursuant to 
Title 18, United States Code, Section 982(a)(2)(A), Title 18, United 
States Code, Section 981(a)(1)(C), and Title 28, United States Code, 
Section 2461(c), in the event of any such defendant’s conviction under 
any of Counts Three through Twelve of the Indictment. 
2. 
Any defendant so convicted shall forfeit to the United 
States of America the following:  
 
 
(a) All right, title, and interest in any and all 
property, real or personal, constituting, or derived from, any 
proceeds traceable to any offense set forth in any of Counts Three 
through Twelve of the Indictment; and  
 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c) and 
Title 18, United States Code, Section 982(b), any defendant so 
convicted shall forfeit substitute property, up to the total value of 
the property described in the preceding paragraph if, as the result 
of any act or omission of said defendant, the property described in 
the preceding paragraph or any portion thereof (a) cannot be located 
upon the exercise of due diligence; (b) has been transferred, sold to 
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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 that cannot be 
divided without difficulty.  
 
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FORFEITURE ALLEGATION FOUR 
[21 U.S.C. § 853, 18 U.S.C. § 924(d)(1), 21 U.S.C. § 881(a)(6) and 
(a)(11), and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2(a) of the Federal Rules of Criminal 
Procedure, notice is hereby given to the defendants charged in any of 
Counts Thirteen through Sixty-Two of the Indictment that the United 
States of America will seek forfeiture as part of any sentence, 
pursuant to Title 21, United States Code, Section 853, Title 18, 
United States Code, Section 924(d)(1), Title 21, United States Code, 
Section 881(a)(6) and (a)(11), and Title 28, United States Code, 
Section 2461(c), in the event of any such defendant’s conviction 
under any of Counts Thirteen through Sixty-Two of the Indictment.   
2. 
Any defendant so convicted shall forfeit to the United 
States of America the following: 
 
 
(a)  All right, title, and interest in any and all 
property, real or personal, constituting or derived from, any 
proceeds which the defendant obtained, directly or indirectly, from 
any offense set forth in any of Counts Thirteen through Sixty-Two of 
the Indictment for which defendant is convicted; 
 
 
(b)  All right, title, and interest in any and all 
property, real or personal, used, or intended to be used, in any 
manner or part, to commit, or to facilitate the commission of any 
offense set forth in any of Counts Thirteen through Sixty-Two of the 
Indictment for which defendant is convicted;  
 
 
(c)  All right, title, and interest in any firearm or 
ammunition involved in or used in any such offense; and 
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(d)  To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a), (b), and (c). 
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), any 
defendant so convicted shall forfeit substitute property, up to the 
total value of the property described in the preceding paragraph if, 
as the result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
 
 
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FORFEITURE ALLEGATION FIVE 
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant CUNNINGHAM that the 
United States of America will seek forfeiture as part of any 
sentence, pursuant to Title 18, United States Code, Section 
924(d)(1), and Title 28, United States Code, Section 2461(c), in the 
event of such defendant’s conviction under any of Counts Sixty-Three 
or Sixty-Nine of the Indictment. 
2. 
Defendant CUNNINGHAM shall forfeit to the United States of 
America the following:  
 
 
(a) All right, title, and interest in any firearm or 
ammunition involved in or used in the offense set forth in any of 
Counts Sixty-Three or Sixty-Nine of the Indictment; and 
 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), 
defendant CUNNINGHAM shall forfeit substitute property, up to the 
value of the property described in the preceding paragraph if, as the 
result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
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FORFEITURE ALLEGATION SIX 
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant RILEY that the United 
States of America will seek forfeiture as part of any sentence, 
pursuant to Title 18, United States Code, Section 924(d)(1), and 
Title 28, United States Code, Section 2461(c), in the event of such 
defendant’s conviction under any of Counts Sixty-Four, Sixty-Eight, 
or Seventy of the Indictment. 
2. 
Defendant RILEY shall forfeit to the United States of 
America the following:  
 
(a) All right, title, and interest in any firearm or 
ammunition involved in or used in the offense set forth in any of 
Counts Sixty-Four, Sixty-Eight, or Seventy of the Indictment; and 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), 
defendant RILEY shall forfeit substitute property, up to the value of 
the property described in the preceding paragraph if, as the result of 
any act or omission of said defendant, the property described in the 
preceding paragraph or any portion thereof (a) cannot be located upon 
the exercise of due diligence; (b) has been transferred, 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 that cannot be 
divided without difficulty. 
 
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FORFEITURE ALLEGATION SEVEN 
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)] 
 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant VENNUM that the United 
States of America will seek forfeiture as part of any sentence, 
pursuant to Title 18, United States Code, Section 924(d)(1), and 
Title 28, United States Code, Section 2461(c), in the event of such 
defendant’s conviction under Count Sixty-Five of the Indictment. 
 
2. 
Defendant VENNUM shall forfeit to the United States of 
America the following:  
 
 
(a) All right, title, and interest in any firearm or 
ammunition involved in or used in the offense set forth in Count 
Sixty-Five of the Indictment; and 
 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
 
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), 
defendant VENNUM shall forfeit substitute property, up to the value 
of the property described in the preceding paragraph if, as the 
result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
 
 
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FORFEITURE ALLEGATION EIGHT 
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant P. EKELUND that the 
United States of America will seek forfeiture as part of any 
sentence, pursuant to Title 18, United States Code, Section 
924(d)(1), and Title 28, United States Code, Section 2461(c), in the 
event of such defendant’s conviction under any of Counts Sixty-Six or 
Seventy-One of the Indictment. 
2. 
Defendant P. EKELUND shall forfeit to the United States of 
America the following:  
 
 
(a) All right, title, and interest in any firearm or 
ammunition involved in or used in the offense set forth in any of 
Counts Sixty-Six or Seventy-One of the Indictment; and 
 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), 
defendant P. EKELUND shall forfeit substitute property, up to the 
value of the property described in the preceding paragraph if, as the 
result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
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FORFEITURE ALLEGATION NINE 
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant VITANZA that the 
United States of America will seek forfeiture as part of any 
sentence, pursuant to Title 18, United States Code, Section 
924(d)(1), and Title 28, United States Code, Section 2461(c), in the 
event of such defendant’s conviction under any of Counts Sixty-Seven 
or Seventy-Two of the Indictment. 
2. 
Defendant VITANZA shall forfeit to the United States of 
America the following:  
 
 
(a) All right, title, and interest in any firearm or 
ammunition involved in or used in the offense set forth in any of 
Counts Sixty-Seven or Seventy-Two of the Indictment; and 
 
 
(b) To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraph (a).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c), 
defendant VITANZA shall forfeit substitute property, up to the value 
of the property described in the preceding paragraph if, as the 
result of any act or omission of said defendant, the property 
described in the preceding paragraph or any portion thereof (a) 
cannot be located upon the exercise of due diligence; (b) has been 
transferred, 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 that cannot be divided without difficulty. 
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FORFEITURE ALLEGATION TEN 
[18 U.S.C. § 982(a)(2)(A), 18 U.S.C. § 981(a)(1)(C), 18 U.S.C. 
§ 1029, and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant BREWER that the United 
States of America will seek forfeiture as part of any sentence, 
pursuant to Title 18, United States Code, Section 982(a)(2)(A), Title 
18, United States Code, Section 981(a)(1)(C), Title 18, United States 
Code, Section 1029(c)(1)(C), and Title 28, United States Code, 
Section 2461(c), in the event of such defendant’s conviction under 
any of Counts Seventy-Three or Seventy-Four of the Indictment. 
2. 
Defendant BREWER shall forfeit to the United States of 
America the following:  
(a) 
All right, title, and interest in any and all 
property, real or personal, constituting, or derived from, any 
proceeds traceable to any offense set forth in any of Counts Seventy-
Three or Seventy-Four of the Indictment; 
(b) 
All personal property used or intended to be used to 
commit the offense set forth in any of Counts Seventy-Three or 
Seventy-Four of the Indictment; and 
(c) 
To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a), and (b).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c) and 
Title 18, United States Code, Section 982(b), and Title 18, United 
States Code, Section 1029(c)(2), defendant BREWER shall forfeit 
substitute property, up to the value of the property described in the 
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preceding paragraph if, as the result of any act or omission of said 
defendant, the property described in the preceding paragraph or any 
portion thereof (a) cannot be located upon the exercise of due 
diligence; (b) has been transferred, 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 that cannot be divided without 
difficulty. 
 
 
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FORFEITURE ALLEGATION ELEVEN 
[18 U.S.C. § 982(a)(2)(A), 18 U.S.C. § 981(a)(1)(C), 18 U.S.C. 
§ 1029, and 28 U.S.C. § 2461(c)] 
1. 
Pursuant to Rule 32.2 of the Federal Rules of Criminal 
Procedure, notice is hereby given to defendant SIMS that the United 
States of America will seek forfeiture as part of any sentence, 
pursuant to Title 18, United States Code, Section 982(a)(2)(A), Title 
18, United States Code, Section 981(a)(1)(C), Title 18, United States 
Code, Section 1029(c)(1()C), and Title 28, United States Code, 
Section 2461(c), in the event of such defendant’s conviction under 
any of Counts Seventy-Five or Seventy-Six of the Indictment. 
2. 
Defendant SIMS shall forfeit to the United States of 
America the following:  
(a) 
All right, title, and interest in any and all 
property, real or personal, constituting, or derived from, any 
proceeds traceable to any offense set forth in any of Counts Seventy-
Five or Seventy-Six of the Indictment;  
(b) 
All personal property used or intended to be used to 
commit the offense set forth in any of Counts Seventy-Five or 
Seventy-Six of the Indictment; and 
(c) 
To the extent such property is not available for 
forfeiture, a sum of money equal to the total value of the property 
described in subparagraphs (a), and (b).  
3. 
Pursuant to Title 21, United States Code, Section 853(p), 
as incorporated by Title 28, United States Code, Section 2461(c) and 
Title 18, United States Code, Section 982(b), and Title 18, United 
States Code, Section 1029(c)(2), defendant BREWER shall forfeit 
substitute property, up to the value of the property described in the 
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preceding paragraph if, as the result of any act or omission of said 
defendant, the property described in the preceding paragraph or any 
portion thereof (a) cannot be located upon the exercise of due 
diligence; (b) has been transferred, 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 that cannot be divided without 
difficulty. 
 
 
 
A TRUE BILL 
 
 
 
 
/s/ 
 
Foreperson 
 
 
E. MARTIN ESTRADA 
United States Attorney 
 
 
 
 
CAMERON L. SCHROEDER 
Assistant United States Attorney 
Chief, National Security Division 
 
DAVID T. RYAN 
Assistant United States Attorney 
Chief, Terrorism and Export   
Crimes Section 
 
REEMA M. EL-AMAMY 
Assistant United States Attorney 
Terrorism and Export Crimes 
Section 
 
JEREMIAH LEVINE 
Assistant United States Attorney 
Violent and Organized Crime 
Section 
 
 
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