Court filing
RICO Indictment — United States v. Haviland et al. (SFV Mama Gang)
Filed August 7, 2024 in U.S. v. Haviland; one of 2 filings from this case.
Record facts
| Court | U.S. District Court, C.D. Cal. (filed NVD 2:25-mj-00883-NJK as magistrate complaint transfer) |
|---|---|
| Filed | 2024-08-07 |
U.S. District Court, C.D. Cal. (filed NVD 2:25-mj-00883-NJK as magistrate complaint transfer) · No. 2:25-mj-00883-NJK · Doc. 1 · 2024-08-07 · Docket on CourtListener
Full text
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 1 of 255
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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
2:25-mj-00883-NJK
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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
C
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bearing the swastika, such as in the pictures below:
C
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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:
C
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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
C
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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.
C
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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.
C
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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).
C
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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. 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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 173 of 255
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28
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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26
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 175 of 255
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26
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 176 of 255
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23
24
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26
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 177 of 255
177
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21
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26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 178 of 255
178
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26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 179 of 255
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21
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23
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26
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 180 of 255
180
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13
14
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25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 181 of 255
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14
15
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23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 182 of 255
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14
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24
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26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 183 of 255
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13
14
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22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 184 of 255
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 185 of 255
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25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 186 of 255
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27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 187 of 255
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22
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 188 of 255
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23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 189 of 255
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21
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23
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25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 190 of 255
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 191 of 255
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26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 192 of 255
192
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26
27
28
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,
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 193 of 255
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28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 194 of 255
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22
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 195 of 255
195
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11
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 196 of 255
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21
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 197 of 255
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11
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21
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23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 198 of 255
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14
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20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 199 of 255
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10
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20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 200 of 255
200
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21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 201 of 255
201
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11
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20
21
22
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24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 202 of 255
202
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5
6
7
8
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10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 203 of 255
203
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3
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5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 204 of 255
204
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5
6
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8
9
10
11
12
13
14
15
16
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18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 205 of 255
205
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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 206 of 255
206
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6
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8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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.
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 207 of 255
207
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5
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8
9
10
11
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14
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20
21
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23
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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;
2.
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
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 254 of 255
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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
Case 2:25-mj-00883-NJK Document 1 Filed 12/22/25 Page 255 of 255File and source
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