Superseding Indictment — United States v. Aaron Michael Thomas and Darren Doil Means

Summary

A Superseding Indictment, Document 38, filed in USDC ND/OK on 01/17/24, Case No. 23-CR-00333-GKF, United States of America v. Aaron Michael Thomas and Darren Doil Means, Northern District of Oklahoma. Counts One through Three charge introduction of a misbranded drug into interstate commerce under 21 U.S.C. §§ 331(a) and 333(a)(2), naming gabapentin (Count One, on or about January 10, 2023), xylazine (Count Two) and pregabalin (Count Three). Count Four is headed Drug Conspiracy, Count Five Possession of Pregabalin with Intent to Distribute, Count Six Maintaining a Drug-Involved Premises, and Count Seven Smuggling Goods into the United States under 18 U.S.C. § 545. A forfeiture allegation under 21 U.S.C. § 853 seeks a money judgment and seized currency.

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Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT

FILED
JAN 17 2028
Mark C, McCartt,

FOR THE NORTHERN DISTRICT OF OKLAHOMA U-S. DISTRICT Glo

UNITED STATES OF AMERICA,

Plaintiff,

AARON MICHAEL THOMAS,
DARREN DOIL MEANS,

Defendants.

THE GRAND JURY CHARGES:

Case No. 23-CR-00333-GKF

SUPERSEDING INDICTMENT
[COUNTS ONE through THREE:
21 U.S.C. §§ 331(a) and 333(a)(2) -
Introduction of a Misbranded Drug
into Interstate Commerce;
COUNT FOUR: 21 U.S.C. §§ 846,
841(a)(1), 841(b)(3), 856(a)(1), and
856(b) — Drug Conspiracy;
COUNT FIVE: 21 U.S.C.

§§ 841(a)(1) and 841(b)(3) -
Possession of Pregabalin with
Intent to Distribute;

COUNT SIX: 21 U.S.C.

§§ 856(a)(1) and 856(b) —
Maintaining a Drug-Involved
Premises;

COUNT SEVEN: 18 U.S.C.

§ 545 — Smuggling Goods into the
United States;

Forfeiture Allegation: 21 U.S.C. §
853 — Drug Forfeiture]

COUNT ONE
[21 U.S.C. §§ 331(a) and 333(a)(2)]

On or about January 10, 2023, in the Northern District of Oklahoma and

elsewhere, the defendants, AARON MICHAEL THOMAS and DARREN DOIL

MEANS, with intent to defraud and mislead, introduced, delivered for introduction,

and caused the introduction of, and delivery for introduction into interstate

commerce of a misbranded drug, gabapentin, which was misbranded pursuant to
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 2 of 10

Title 21, United States Code, Section 352(a), because its labeling was false and
misleading in any particular, pursuant to Title 21, United States Code, Section
352(f)(1), because its labeling failed to bear adequate directions for use, and pursuant
to Title 21, United States Code, Section 352(0), because it was manufactured,
prepared, propagated, compounded, and processed in an establishment not duly
registered under Title 21, United States Code, Section 360.

All in violation of Title 21, United States Code, Sections 331(a) and 333(a)(2).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 3 of 10

COUNT TWO
[21 U.S.C. §§ 331(a) and 333(a)(2)]

On or about March 2, 2023, in the Northern District of Oklahoma and
elsewhere, the defendants, AARON MICHAEL THOMAS and DARREN DOIL
MEANS, with intent to defraud and mislead, introduced, delivered for introduction,
and caused the introduction of, and delivery for introduction into interstate
commerce of a misbranded drug, xylazine, which was misbranded pursuant to Title
21, United States Code, Section 352(a), because its labeling was false and misleading
in any particular, pursuant to Title 21, United States Code, Section 352(f)(1), because
its labeling failed to bear adequate directions for use, and pursuant to Title 21,
United States Code, Section 352(0), because it was manufactured, prepared,
propagated, compounded, and processed in an establishment not duly registered
under Title 21, United States Code, Section 360.

All in violation of 21 U.S.C. §§ 331(a) and 333(a)(2).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 4 of 10

COUNT THREE
[21 U.S.C. §§ 331(a) and 333(a)(2)]

On or about August 15, 2023, in the Northern District of Oklahoma and
elsewhere, the defendants, AARON MICHAEL THOMAS and DARREN DOIL
MEANS, with intent to defraud and mislead, introduced, delivered for introduction,
and caused the introduction of, and delivery for introduction into interstate
commerce of a misbranded drug, pregabalin, which was misbranded pursuant to
Title 21, United States Code, Section 352(a), because its labeling was false and
misleading, pursuant to Title 21, United States Code, Section 352(f)(1), because its
labeling failed to bear adequate directions for use, and pursuant to Title 21, United
States Code, Section 352(0), because it was manufactured, prepared, propagated,
compounded, and processed in an establishment not duly registered under Title 21,
United States Code, Section 360.

All in violation of 21 U.S.C. §§ 331(a) and 333(a)(2).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 5 of 10

COUNT FOUR
[21 U.S.C. §§ 846, 841(a)(1), 841(b)(3), 856(a)(1), and 856(b)]

Between on or about August 18, 2021, to on or about October 24, 2023, in the
Northern District of Oklahoma and elsewhere, the defendants, AARON MICHAEL
THOMAS and DARREN DOIL MEANS, knowingly, intentionally, and willfully
conspired, confederated, and agreed, together and with others known and unknown
to the Grand Jury, to:

(a) distribute and to possess with intent to distribute pregabalin, a Schedule V
controlled substance, in violation of Title 21, United States Code, Section
841(a)(1); and

(b) unlawfully and knowingly use and maintain a place located at 1847 West 57th
Place, Tulsa, Oklahoma, for the purpose of distributing pregabalin, a Schedule
V controlled substance, in violation of Title 21, United States Code, Sections
856(a)(1) and 856(b).

All in violation of Title 21, United States Code, Sections 846, 841(a)(1), 841(b)(3),

856(a)(1), and 856(b).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 6 of 10

COUNT FIVE
[21 U.S.C. §§ 841(a)(1) and 841(b)(3)]

On or about October 24, 2023, in the Northern District of Oklahoma and
elsewhere, the defendants, AARON MICHAEL THOMAS and DARREN DOIL
MEANS, knowingly and intentionally possessed with intent to distribute pregabalin,

a Schedule V controlled substance.

All in violation of Title 21, United States Code, Sections 841(a)(1) and

841(b)(3).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 7 of 10

COUNT SIX
[21 U.S.C. §§ 856(a)(1) and 856(b)]

From on or about August 18, 2021, to on or about October 24, 2023, in the
Northern District of Oklahoma, the defendants, AARON MICHAEL THOMAS
and DARREN DOIL MEANS, unlawfully and knowingly used and maintained a
place located at 1847 West 57th Place, Tulsa, Oklahoma, for the purpose of
distributing pregabalin, a Schedule V controlled substance.

All in violation of Title 21, United States Code, Sections 856(a)(1) and 856(b).
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 8 of 10

COUNT SEVEN
[18 U.S.C. § 545]

On or about August 18, 2021, the Northern District of Oklahoma, the
defendants, AARON MICHAEL THOMAS and DARREN DOIL MEANS,
fraudulently and knowingly imported and brought, and willfully caused to be
imported and brought, merchandise, namely, a parcel of pregabalin, into the United
States contrary to law, that is, with labeling that was false and misleading as to the
parcel’s contents, and labeling that did not bear adequate directions for use, contrary
to Title 21, United States Code Sections 331(a), 352(a), and 352(f)(1).

All in violation of Title 18, United States Code Section 545.
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 9 of 10

FORFEITURE ALLEGATION
[21 U.S.C. § 853]

The allegations contained in this Superseding Indictment are hereby realleged and
incorporated by reference for the purpose of alleging forfeitures pursuant to Title 21,
United States Code, Section 853, and Title 21, United States Code, Section
982(a)(7).

Upon conviction of the offenses alleged in this Superseding Indictment, as a part
of his sentences, the defendants, AARON MICHAEL THOMAS and DARREN
DOIL MEANS, shall forfeit to the United States any property constituting, or
derived from, or traceable to, the proceeds obtained, directly or indirectly, as a result
of such violations and any property, real or personal, that was used or intended to be
used to commit or to facilitate the violations of federal law. The property to be
forfeited includes, but is not limited to:

MONEY JUDGMENT

1. A money judgment in an amount representing proceeds obtained by AARON

MICHAEL THOMAS and DARREN DOIL MEANS as a result of the
offenses; and

CURRENCY

2. All United States currency seized from AARON MICHAEL THOMAS and
DARREN DOIL MEANS by law enforcement on October 24, 2023.
Case 4:23-cr-00333-GKF Document 38 Filed in USDC ND/OK on 01/17/24 Page 10 of 10

All pursuant to Title 21, United States Code, Section 853.

CLINTON J. JOHNSON A TRUE BILL
United States Attorney

A: i aa /s/ Grand Jury Foreperson
NATHAN E. MICHEL Grand Jury Foreperson
Assistant United States Attorney

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