Criminal Information — United States v. Terrell Davis (N.D. Ga., Dkt. 1, January 6, 2021)

Summary

Criminal Information in United States v. Terrell Davis, No. 1:20-CR-509-MLB, in the U.S. District Court for the Northern District of Georgia, Document 1, filed January 6, 2021. Counts One through Four charge conspiracy and possession with intent to distribute at least 100 kilograms of a mixture containing a detectable amount of marijuana, citing Title 21, United States Code, Sections 841(a)(1) and 846. Count Five charges possession of a firearm under Section 922(g)(1), Count Six charges conspiracy to commit offenses under Title 18, United States Code, Section 1956, and Count Seven charges possession of a cellular telephone by an inmate, under Sections 1791(a)(2) and 1791(d)(1)(F). Forfeiture allegations follow; the signature block names Bobby L. Christine, Acting United States Attorney.

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“Criminal Information — United States v. Terrell Davis (N.D. Ga., Dkt. 1, January 6, 2021).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cr-00509-dkt-1-n-d-ga-d74c624262/, SHA-256 5c7771e5c6d66f865030e9641b0c291764bd6413585378938be74c8b22d7175e.

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Case 1:20-cr-00509-MLB Document 1 Filed 01/06/21 Page 1 of IN
FILED 12OPEN COURT
U.S.D.C. -Atlanta

JAN 0 6 2021
JAMES N. HATTEN, Clerk
Deputy Clerk

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNITED STATES OF AMERICA
V. Criminal Information
TERRELL DAVIS A/K/A No. 1:20-CR-509-MLB
"RALO"

THE UNITED STATES ATTORNEY CHARGES THAT:

Count One
Beginning on a date unknown to the United States Attorney, but at least by in
or about December 2017, and continuing until on or about December 22, 2017, in
the Northern District of Georgia and elsewhere, the defendant, TERRELL
DAVIS, also known as "Ralo," and others known and unknown to the United
States Attorney, did knowingly and willfully combine, conspire, confederate,
agree and have a tacit understanding with one another, to violate Title 21, United
States Code, Section 841(a)(1), that is, to possess with the intent to distribute a
controlled substance, said conspiracy involving at least 100 kilograms of a
mixture and substance containing a detectable amount of marijuana, a Schedule I
controlled substance, pursuant to Title 21, United States Code, Section
841(b)(1)(B)(vii), all in violation of Title 21, United States Code, Section 846.
Count Two
On or about December 22, 2017, in the Northern District of Georgia and
elsewhere, the defendant, TERRELL DAVIS, also known as "Ralo," and others
known and unknown to the United States Attorney, aided and abetted by one
Case 1:20-cr-00509-MLB Document 1 Filed 01/06/21 Page 2 of 12

another, did knowingly and intentionally possess with the intent to distribute a
controlled substance, that is, at least 100 kilograms of a mixture and substance
containing a detectable amount of marijuana, a Schedule I controlled substance,
pursuant to Title 21, United States Code, Section 841(b)(1)(B)(vii), all in violation
of Title 21, United States Code, Section 841(a)(1), and Title 18, United States
Code, Section 2.
Count Three
Beginning on a date unknown to the United States Attorney, but at least by in
or about April 2018, and continuing until on or about April 15, 2018, in the
Northern District of Georgia and elsewhere, the defendant, TERRELL DAVIS,
also known as "Ralo," and others known and unknown to the United States
Attorney, did knowingly and willfully combine, conspire, confederate, agree and
have a tacit understanding with one another, to violate Title 21, United States
Code, Section 841(a)(1), that is, to possess with the intent to distribute a
controlled substance, said conspiracy involving at least 100 kilograms of a
mixture and substance containing a detectable amount of marijuana, a Schedule I
controlled substance, pursuant to Title 21, United States Code, Section
841(b)(1)(B)(vii), all in violation of Title 21, United States Code, Section 846.
Count Four
On or about April 15, 2018, in the Northern District of Georgia and elsewhere,
the defendant, TERRELL DAVIS, also known as "Ralo," and others known and
unknown to the United States Attorney, aided and abetted by one another, did
knowingly and intentionally possess with the intent to distribute a controlled

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substance, that is, at least 100 kilograms of a mixture and substance containing a
detectable amount of marijuana, a Schedule I controlled substance, pursuant to
Title 21, United States Code, Section 841(b)(1)(B)(vii), all in violation of Title 21,
United States Code, Section 841(a)(1), and Title 18, United States Code, Section 2.
Count Five
On or about Apri118, 2018, in the Northern District of Georgia, the defendant,
TERRELL DAVIS, also known as "Ralo," knowing that he had been previously
convicted of at least one of the following offenses:
1. Theft by Receiving Stolen Property, in the Superior Court of Fulton
County, Georgia, in or about 2010;
2. Possession of a Firearm by a Convicted Felon, in the Superior Court of
Fulton County, Georgia, in or about 2013, and
3. Theft by Receiving Stolen Property, in the Superior Court of Fulton
County, Georgia, in or about 2016,
each of which was a crime punishable by imprisonment for a term exceeding one
year, did knowingly possess a firearm, that is, a Walther PK380 .380 caliber pistol
and ammunition, said possession being in and affecting interstate and foreign
commerce, all in violation of Title 18, United States Code, Section 922(g)(1).
Count Six
Beginning on a date unknown to the United States Attorney, but at least as of
on or about September 22, 2015, and continuing through at least on or about May
4, 2018, in the Northern District of Georgia and elsewhere, the defendant,
TERRELL DAVIS, also known as "Ralo," and others known and unknown to the

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Case 1:20-cr-00509-MLB Document 1 Filed 01/06/21 Page 4 of 12

United States Attorney, did knowingly and willfully combine, conspire,
confederate, agree and have a tacit understanding with one another, to commit
certain offenses under Title 18, United States Code, Section 1956, that is, to
knowingly conduct and attempt to conduct financial transactions in and affecting
interstate and foreign commerce, which transactions involved the proceeds of
specified unlawful activity, that is, the felonious manufacture, importation,
receiving, concealment, buying, selling and otherwise dealing in a controlled
substance, that is, marijuana, a Scheduled I controlled substance, punishable
under a law of the United States, that is, Title 21, United States Code, Section
841(a)(1), knowing that the property involved in the financial transactions
represented the proceeds of some form of unlawful activity, and knowing the
transactions were designed in whole and in part to conceal and disguise the
nature, location, source, ownership, and control of proceeds of said unlawful
activity, in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i); all in
violation of Title 18, United States Code, Section 1956(h).
Count Seven
On or about April 17, 2019, in the Northern District of Georgia, the defendant,
TERRELL DAVIS, also known as "Ralo," an inmate of the Robert A. Deyton
Detention Facility, a facility in which persons are held in custody by direction of
and pursuant to a contract and agreement with the Attorney General, knowingly
possessed and obtained a prohibited and forbidden object, that is, a cellular
telephone and another device used by a user of commercial mobile service in

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connection with such service, in violation of Title 18 United States Code, Sections
1791(a)(2) and 1791(d)(1)(F).
Forfeiture
Upon conviction of one or more of the offenses alleged in Counts One
through Four of this Criminal Information, the defendant, TERRELL DAVIS, also
known as "Ralo," shall forfeit to the United States pursuant to Title 21, United
States Code, Section 853, all property constituting, or derived from, proceeds
obtained, directly or indirectly, as a result of the said violations and all property
used or intended to be used, in any manner or part, to commit, or to facilitate the
commission of said violations, including, but not limited to, the following:
a. MONEY JUDGMENT: A sum of money in United States currency equal
to the amount of proceeds the defendant obtained as a result of the
offenses for which the defendant is convicted.
b. REAL PROPERTY:
1. 1177 Lucile Avenue, all Units 1 through 20, Atlanta, Georgia
30310;
2. 1908 Kimberly Road, Atlanta, Georgia 30331;
3. 1918 W. Kimberly Road, Atlanta, Georgia 30331; and
4. 229 Maple Street, Atlanta, Georgia 30314.
c. VEHICLES:
1. 2010 Ford Econoline E-350 Van, bearing VIN
1FBSS3BL3ADA12654;

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2. 2015 Lamborghini Aventador Coupe,
bearing VIN ZHWUR1ZDXFLA03556; and
3. 2010 Mercedes Benz E350, bearing VIN WDDHF5GB5AA070763.
d. FIREARMS AND AMMUNITION:
1. HS Products XDS 9mm pistol, bearing serial no. S3756180; and
2. Walther PK380 .380 caliber pistol, bearing serial no. WB08776.
e. CASH AND BANK FUNDS:
1. $146,361.21 seized from SunTrust Bank account
XXXXXXXXX7387 held in the name of Famerica, LLC; and
2. $1,806.03 seized from SunTrust Bank account XXXXXXXXX4003
held in the name of Famerica, LLC.
f. PERSONAL PROPERTY:
1. One (1) black iPhone with SIM card, bearing serial number
353050090844984;
2. One (1) black iPhone with SIM card, bearing serial number
353024096171007;
3. One (1) Samsung Galaxy S8 with SIM card, bearing serial number
357721082189085;
4. One (1) ZTE model Z833 mobile phone with SIM card, bearing
serial number 325176231892;
5. One (1) silver iPhone SE model A1662 with SIM card, bearing
serial number 356598081208442;

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6. One (1) G Drive USP-C 4th external hard drive with power cable
and USB cable, bearing serial number WCC7K3UAX54;
7. One (1) 18kt white gold Rolex "President" watch with 15.00
carats of diamonds;
8. One (1) 14kt white gold "Famerica" pendant with 25.00 carats of
diamonds and chain;
9. One (1) 14kt white gold "dog bone Ralo" charm with
approximately 7.00 carats of diamonds;
10.One (1) 14kt white gold Avianne charm with approximately 5
carats total weight of diamonds;
11.One (1) 14kt white gold "BMG" charm with approximately 3.00
carats of diamonds;
12.One (1) 14kt white gold tennis necklace with 120 diamonds and a
total weight of approximately 25.00 carats;
13.One (1) 14kt white gold tennis necklace with 96 diamonds and a
total weight of approximately 24.00 carats;
14.One (1) 14kt white gold ring with 34 diamonds and a total weight
of approximately 7.00 carats;
15.One (1) 14kt white gold cluster earring with 18 diamonds and a
total weight of approximately 1.20 carats;
16.One (1) 14kt white gold "Allah" pendant with 150 diamond and a
total weight of approximately 4.00 carats;
Case 1:20-cr-00509-MLB Document 1 Filed 01/06/21 Page 8 of 12

17.One (1) 14kt white gold grill with 269 diamonds and a total
weight of 5.00 carats;
18.One (1) 14kt white gold grill with diamonds and a total weight of
8.00 carats; and
19.One (1) 14kt white gold three-row diamond bracelet with a total
weight of 12 carats.
Upon conviction of the offense alleged in Count Five of this Criminal
Information, the defendant, TERRELL DAVIS, also known as "Ralo," shall forfeit
to the United States pursuant to Title 18, United States Code, Section 924(c) and
Title 28, United States Code, Section 2461(c), any firearms and ammunition
involved in the offense, including but not limited to: one (1) Walther PK380 .380
caliber pistol, bearing serial number WB08776.
Upon conviction of the offense alleged in Count Six of this Criminal
Information, the defendant, TERRELL DAVIS, also known as "Ralo," shall forfeit
to the United States pursuant to Title 18, United States Code, Section 982(a)(1),
any property, real or personal, involved in the offense and any property
traceable to such property, including but not limited to the following:
a. MONEY JUDGMENT: A sum of money in United States currency
equal to the value of the property involved in the offense for which
the defendant is convicted.
b. REAL PROPERTY:
1. 1177 Lucile Avenue, all Units 1 through 20, Atlanta, Georgia
30310;

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2. 1908 Kimberly Road, Atlanta, Georgia 30331;
3. 1918 W. Kimberly Road, Atlanta, Georgia 30331; and
4. 229 Maple Street, Atlanta, Georgia 30314.
c. VEHICLES:
1. 2010 Ford Econoline E-350 Van, bearing VIN
1FBSS3BL3ADA12654;
2. 2015 Lamborghini Aventador Coupe,
bearing VIN ZHWUR1ZDXFLA03556; and
3. 2010 Mercedes Benz E350, bearing VIN WDDHF5GB5AA070763.
d. CASH AND BANK FUNDS:
1. $146,361.21 seized from SunTrust Bank account
XXXXXXXXX7387 held in the name of Famerica, LLC; and
2. $1,806.03 seized from SunTrust Bank account XXXXXXXXX4003
held in the name of Famerica, LLC.
e. PERSONAL PROPERTY:
1. One (1) black iPhone with SIM card, bearing serial number
353050090844984;
2. One (1) black iPhone with SIM card, bearing serial number
353024096171007;
3. One (1) Samsung Galaxy S8 with SIM card, bearing serial number
357721082189085;
4. One (1) ZTE model Z833 mobile phone with SIM card, bearing
serial number 325176231892;

9
Case 1:20-cr-00509-MLB Document 1 Filed 01/06/21 Page 10 of 12

5. One (1) silver iPhone SE model A1662 with SIM card, bearing
serial number 356598081208442;
6. One (1) G Drive USP-C 4tb external hard drive with power cable
and USB cable, bearing serial number WCC7K3UAX54;
7. One (1) 18kt white gold Rolex "President" watch with 15.00
carats of diamonds;
8. One (1) 14kt white gold "Famerica" pendant with 25.00 carats of
diamonds and chain;
9. One (1) 14kt white gold "dog bone Ralo" charm with
approximately 7.00 carats of diamonds;
10.One (1) 14kt white gold Aviarme charm with approximately 5
carats total weight of diamonds;
11.One (1) 14kt white gold "BMG" charm with approximately 3.00
carats of diamonds;
12.One (1) 14kt white gold tennis necklace with 120 diamonds and a
total weight of approximately 25.00 carats;
13.One (1) 14kt white gold tennis necklace with 96 diamonds and a
total weight of approximately 24.00 carats;
14.One (1) 14kt white gold ring with 34 diamonds and a total weight
of approximately 7.00 carats;
15.One (1) 14kt white gold cluster earring with 18 diamonds and a
total weight of approximately 1.20 carats;

10
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16.One (1) 14kt white gold "Allah" pendant with 150 diamond and a
total weight of approximately 4.00 carats;
17.One (1) 14kt white gold grill with 269 diamonds and a total
weight of 5.00 carats;
18.One (1) 14kt white gold grill with diamonds and a total weight of
8.00 carats; and
19.One (1) 14kt white gold three-row diamond bracelet with a total
weight of 12 carats.
If, as a result of any act or omission of the defendant, any property subject to
forfeiture:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided
without difficulty;
the United States intends, pursuant to Title 21, United States Code, Section
853(p), as incorporated by Title 18, United States Code, Section 982(b) and Title

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28, United States Code, Section 2461(c), to seek forfeiture of any other property of
said defendant up to the value of the forfeitable property.

BOBBY L. CHRISTINE
Acting United States Attorney

K. B ANAN
&i-ant United States Attorney
Geo 'a Bar No. 623388

t/(471-
SEKRET T. SNEED
Assistant United States Attorney
Georgia Bar No. 252939

600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

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