Indictment (Document 3, No. 4:26-cr-00075-JKW-RJK, filed October 14, 2026)
Summary
Sealed indictment filed October 14, 2026 in the Eastern District of Virginia, Newport News Division, case No. 4:26-cr-00075. It charges Virginia State Senator Louise Lucas, her daughters Lisa Lucas Burke and Theresa Lucas-Lamb, her grandson Ryan Eichelberger, Prince Albert William Hudson III, Carlton Upton, Jr. and Tameka Johnson in eight counts. They include racketeering conspiracy through what it calls the Lucas Enterprise, marijuana distribution conspiracy, money laundering conspiracy, honest services fraud conspiracy, maintaining drug-involved premises and a firearm count. It describes The Cannabis Outlet in Portsmouth and Virginia's slow move toward legal retail marijuana sales. Count eight charges Upton with wire fraud: his April 10, 2020 Economic Injury Disaster Loan application for Virginia Freedom Life allegedly hid four prior felony convictions and brought a loan of $11,800.
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Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 1 of 45 PagelD# 79
FILED
IN OPEN COURT
APT
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
| 2006
CLERK, U.S. DISTRICT COURT
NEWPORT NEWS, VA
Newport News Division
UNITED STATES OF AMERICA
UNDER SEAL
; CRIMINAL NO. 4:26CR 75
18 U.S.C. § 1962(d)
Racketeering Conspiracy
(Count 1)
LILLIE LOUISE LUCAS
(Counts 1, 2, 3, 4, 5)
LISA LUCAS BURKE
(Counts 1, 2, 3,4, 5) 21 U.S.C. §§ 846 and 841
Conspiracy to Distribute and Possess with
Intent to Distribute Marijuana,
PRINCE ALBERT WILLIAM HUDSON,
(Count 2)
Il
(Counts 1, 2, 3) 18 U.S.C. § 1956(h)
Conspiracy to Launder Money
RYAN EICHELBERGER (Count 3)
(Counts 1, 2, 3, 5, 7)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
) 18 U.S.C. §§ 1349, 1343 and 1346
THERESA LUCAS-LAMB ) Conspiracy to Commit Honest Services Fraud
(Counts 1, 2, 3, 5) ) (Count 4)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
CARLTON UPTON, JR.
2 2
Maintaining a Drug Involved Premises
TAMEKA JOHNSON (Counts 5, 6)
(Count 2, 3, 6) 18 U.S.C. 924(c)(1)(A)
Possess Firearm in Furtherance of Drug
Trafficking
(Count 7)
18 U.S.C. §§ 1343 and 2
Wire Fraud
(Count 8)
18 U.S.C. §§ 924(d), 982(a)(1);
21 U.S.C. § 853; 28 U.S.C. § 2461
Forfeiture Allegation
INDICTMENT
October 2026 Term — at Newport News, Virginia
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At all times relevant to this indictment:
BACKGROUND
A. Federal Law
a. The Controlled Substances Act, Title 21, United States Code, Sections 801, et
seq. (hereinafter CSA) and its implementing regulations, set forth which drugs and other
substances are defined by law as “Controlled Substances.” Those Controlled Substances are then
assigned to one of five schedules — Schedule I, II, III, IV, or V, depending on their potential for
abuse, likelihood of physical or psychological dependency, accepted medical use, and accepted
safety for use under medical supervision.
b. The term “Schedule J” means the drug or other substance has no currently accepted
medical use and cannot be safely used even under medical supervision. No prescriptions may be
written for Schedule I substances.
c. The term “Schedule II” means the drug or other substance has a high potential for
abuse, the drug has a currently accepted medial use with severe restrictions, and abuse of the drug
may lead to severe psychological or physical abuse dependence. Certain Schedule II drugs can be
crushed and snorted, or dissolved and injected, to get an immediate high. This abuse can lead to
addiction, overdose, and sometimes death.
d. The term “Schedule III” means the drug or other substance has a high potential for
abuse, but less than the drugs or substances listed in Schedule II, the drug has a currently accepted
medical use with severe restrictions, and abuse of the drug may lead to severe psychological or
physical dependence.
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e. — The term “Schedule IV” means the drug or other substance has a low potential for
abuse relative to the drugs or substances in Schedule III, the drug has a currently accepted medical
use in treatment, and abuse of the drug may lead to limited (relative to the drugs or substances in
Schedule III) physical dependence or psychological dependence.
f. Under the CSA, marijuana classification is split. State licensed medical marijuana
and FDA approved products are classified as Schedule III. Recreational and unlicensed marijuana
is classified as Schedule I.
g. Cannabis sativa is a flowering plant that contains hundreds of compounds; the
cultivation of the plant contributes to different compound concentrations. Of these, A9-
tetrahydrocannabinol (THC) and cannabidiol (CBD) are of special relevance. THC is a
psychoactive compound whose effects are the result of action on the brain’s endogenous
cannabinoid receptors (CB1 and CB2). Some of the psychoactive effects of THC intoxication can
include (1) euphoric or “high” states of elevated mood and relaxation, (2) “perceptional
disturbances regarding time, color, or sound, among others, (3) cognitive impairment of short-term
memory and learning, (4) anxiety or paranoia, and (5) dissociative states such as depersonalization.
THC can also produce physiological effects including tachycardia, orthostatic hypotension, dry
mouth, red eyes, and increased appetite. Long-term use is associated with reduced intelligence
quotient (IQ) scores, schizophrenia or other psychoses, anxiety, increased risk of suicidal ideation,
planning, and attempts, and cyclic vomiting syndrome; THC is also known to have adverse
reproductive consequences in both males and females. THC is the active component of marijuana.
h. The Agriculture Improvement Act of 2018 or “Farm Bill” defined hemp as a
cannabis sativa plant containing 0.3% or less of THC by dry weight; hemp, as defined, is legal to
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cultivate and sell across state lines. Anything above the concentration of 0.3% THC by dry weight
is federally illegal. In December 2025, President Trump signed Executive Order 14730,
“Increasing Medical Marijuana and Cannabidiol Research,” which directed appropriate authorities
to take measures to reclassify marijuana from a Schedule I to a Schedule III drug. This change
does not affect the federal legality of marijuana but instead allows for greater scientific research .
into potential medicinal uses of the compound. In Virginia, under Va. Code § 4.1-1100 and Va.
Code § 18.2-248.1 marijuana is illegal to buy or sell, but adults 21 years of age or older may
possess up to one (1) ounce. This statute presumes that any amount above two ounces is not for
personal use.
i. CBD is not nearly as psychoactive as THC and, when taken in moderate doses
with THC, it ameliorates the psychoactive effects of THC via allosteric modulation, that is, it
changes the shape of the CB1 and CB2 receptors impacting the ability of THC to bind to them.
CBD is legal both federally and in the Commonwealth of Virginia. |
j. Delta-8-tetrahydrocannabinol occurs naturally only in very small quantities in the
cannabis sativa plant; however, through chemical transformation of CBD, A8s-
tetrahydrocannabinol can be synthesized in quantities efficient for the production of intoxicating
products. Delta-8-tetrahydrocannbinol is less psychoactive than traditional A9-
tetrahydrocannibnol but is still psychoactive.
B. Virginia Law
a. Virginia Code Section 4.1-1100 et seq., governs the sale and possession of
marijuana in the Commonwealth of Virginia.
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b. Pursuant to Virginia Code Section 4.1-1100(A), adults 21 or older can legally
possess up to 2 (two) ounces of marijuana in any public place or an equivalent amount of marijuana
product as determined by regulation promulgated by the Board of Directors of the Virginia
Cannabis Control Authority.
c. Pursuant to Virginia Code Section 4.1-1100(B), possession of over 2 (two) ounces
of marijuana is subject to varying criminal penalties depending on the amount. The penalties range
from misdemeanor offenses to a felony for possession of 1 (one) pound or more of marijuana.
d. Under Virginia Code Section 4.1-1600, Virginia has legalized a “Medical
Cannabis Program.” A practitioner as defined under Virginia law, in the course of his professional
practice may issue a written certification for the use of cannabis products (as defined by Virginia
law) for treatment or to alleviate the symptoms of any diagnosed condition or disease determined
by the practitioner to benefit from such use.
e. Pursuant to Virginia Code 18.2-248.1, it is unlawful for any person to sell give,
distribute or possess with intent to sell, give, or distribute marijuana. This same Virginia Code
section provides both misdemeanor and felony penalties in relation to the illegal sale of various
amounts of marijuana. Possession with intent to distribute or distribution of more than one ounce
but less than five pounds is a Class Five Felony. Possession with intent to distribute or distribution
of more than five pounds is a felony punishable by imprisonment of not less than five years nor
more than thirty years.
C. Virginia Marijuana Licensing
a. Effective July 2020, Virginia decriminalized simple marijuana possession, and the
first medical dispensary opened the following month. Recreational use laws that took effect July
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2021 allowed adults to possess one ounce (28g), cultivate four plants per household and share
marijuana where there was no commercial transaction. Retail sales, however, were limited to
medical patients. In 2021, the Virginia Cannabis Control Authority (CCA) was created in Virginia.
The CCA was to be responsible for the regulation of medical cannabis, the adult use retail market,
and regulated hemp products pursuant to VA Code 4.10600 et seq. Specifically, the CCA would
oversee the approval of licenses to individuals and/or entities engaged in the sale of recreational
marijuana or cannabis (which terms are used interchangeably). The CCA has a Board of Directors
appointed by the Governor and confirmed by the General Assembly.
b. On January 22, 2021, Virginia SB 1406 “Marijuana; legalization of simple
possession, penalties,” sponsored by LILLIE LOUISE LUCAS (hereinafter LOUISE LUCAS) and
another senator was advanced by the state Senate Rehabilitation and Social Services Committee.
This bill and its House of Delegates counterpart passed on February 5, 2021, and, following the
amendment process, was signed by Governor Northam. The Senate version pressed for
legalization to begin in July 2021. However, the House version delayed legislation until January
2024 (that would have included retail sales). The amended law signed by the Governor reached a
compromise that legalized recreational use in July 2021, with scheduled retail sales to follow
beginning in January 2024. A re-enactment clause required the Virginia legislature to re-approve
the sales provision for it to take effect.! Following a change in leadership in the House of Delegates
in 2021, this re-enactment was not taken up by the legislature in 2022. Thus, commercial sales of
marijuana remained illegal.
| A “re-enactment clause” is a provision attached to a bill that requires the Virginia
General Assembly to vote again to pass the legislation in order for it to take effect.
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c. During the 2023 session of the General Assembly, all bills to begin recreational
sales failed to pass with the split Republican run House of Delegates and the Democratic run State
Senate. In 2024, following Democratics taking control of the state legislature in the 2023 elections,
legislation was again introduced to begin recreational sales. Though the House and Senate passed
a bill to allow recreational sales to commence on May 1, 2025, Governor Youngkin vetoed the bill
on March 28, 2024. This process was repeated in 2025 with another passed bill and another veto.
All of these efforts to create a retail market for marijuana involved the establishment of a licensing
scheme for marijuana sales. These licenses were anticipated to be very valuable given the expected
amount of revenue to be generated by marijuana sales. Though retail use was not authorized,
applications could be made for a marijuana business license.
d. In the 2026 legislative session, following the 2025 election of Governor
Spanberger, both houses passed companion bills to legalize retail marijuana sales, beginning in
2027, to be administered by the CCA. The Governor sent the bill back with several amendments
that would have delayed the launch of retail sales from January to July 2027, and increased
penalties for public consumption. When the legislature voted to reject these amendments on April
22, 2026, the Governor vetoed the original bill in May. A deal was subsequently announced in
June with provisions regulating recreational marijuana sales enacted in the annual budget
legislation, with sales planned to begin July 1, 2027. On that date, entities with licenses issued by
the CCA can commence commercial sales of marijuana in the Commonwealth of Virginia.
GENERAL ALLEGATIONS
A. LOUISE LUCAS was elected to the Virginia State Senate in 1991. As a state
senator, LOUISE LUCAS is currently the Chairman of the Senate Finance and Appropriations
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Committee which handles the state budget, tax policy and state expenditures. Since 2020, she has
been elected by the Virginia Senate as the President Pro Tempore. In this role she serves as the
presiding member of the state senate in the absence of the Lieutenant. Governor. LOUISE LUCAS
owns a number of business entities, including Lucas Lodge, LLC, Lucas Hospitality, LLC, and
The Cannabis Outlet, all located in Portsmouth, VA.
B. LOUISE LUCAS’ family members include LISA LUCAS BURKE, RYAN
EICHELBERGER and. THERESA LUCAS-LAMB. LISA LUCAS BURKE and THERESA
LUCAS-LAMB are the natural daughters of LOUISE LUCAS. RYAN EICHELBERGER is the
son of THERESA LUCAS-LAMB and the grandson of LOUISE LUCAS. LISA LUCAS BURKE
is an employee of Lucas Lodge and conducts business on behalf of Lucas Lodge and The Cannabis
Outlet. THERESA LUCAS-LAMB previously worked as the manager of The Cannabis Outlet
with her son RYAN EICHELBERGER working with her to run the day-to-day operations of the
store. THERESA LUCAS-LAMB was forced out of the business by her mother in the Fall of 2024
and was replaced as manager by RYAN EICHELBERGER.
C. PRINCE ALBERT WILLIAM HUDSON, III, is a businessman who owns a
number of businesses to include Agri-Carter, LLC, which advertises itself as a provider of hemp
and CBD based products. He also owns Regal Industries, LLC, which does business as Exotic
‘World, a CBD store in Danville, VA. |
D. CARLTON UPTON, JR. was a business partner of LOUISE LUCAS in Virginia
Freedom Life, which encompassed The Cannabis Outlet and another business, The CBD Shoppe,
beginning in 2019.
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E. On June 10, 2020, LOUISE LUCAS participated in certain protest activity in
Portsmouth, VA. The Portsmouth Police Chief charged LOUISE LUCAS with two felony charges
arising from the protests. After the filing of these charges, the Chief was placed on leave. In
November 2020, the Commonwealth Attorney for Portsmouth dismissed the charges against
LOUISE LUCAS. The Police Chief was fired the same day.
F. On or about November 23, 2009, LOUISE LUCAS registered Lucas Lodge, LLC,
with a business address of 1120 Lakeview Dr, Portsmouth, Va. Portsmouth, VA. This business
was portrayed as being a health care provider for adults with intellectual challenges.
G. On or about October 23, 2009, LOUISE LUCAS organized Lucas Hospitality,
LLC, with a business address of 1214 County St. Portsmouth, VA. The intended nature of this
business is unknown. The business name is affiliated with The Cannabis Outlet, which purports to
sell hemp related products.
H. On or about October 1, 2018, PRINCE ALBERT WILLIAM HUDSON, III,
registered Agri-Carter with a business address of 3213 Garland Ave., Richmond, VA 23222.
I. On or about February 28, 2019, CARLTON UPTON, JR., registered Virginia
Freedom Life with a business address of 345 Granby Street, Norfolk, VA. The intended nature of
this business is unknown but shares an address with The CBD Shoppe, which claims to sell hemp
related products.
J. On June 2, 2021, THERESA LUCAS-LAMB registered Backyard Entertainment,
LLC, with a business address of 1214 County St., Portsmouth, VA. The intended nature of this
business is unknown.
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K. Following his hiring in 2022, a senior law enforcement officer warned LOUISE
LUCAS that selling marijuana was illegal and was going to get her in trouble one day. At a
subsequent meeting between the senior law enforcement officer, another Virginia state legislator,
and LOUISE LUCAS to discuss the various issues related to law enforcement, the senior law
enforcement officer reiterated that LOUISE LUCAS needed to stop selling marijuana and asked
her why, given that she was a state senator and a wealthy woman, she would engage in criminal
behavior. LOUISE LUCAS did not answer this question. The legislator agreed that LOUISE
LUCAS should not associate herself with selling marijuana, while it was still illegal.
L. On March 23, 2023, HUDSON registered Regal Industries, LLC, with a business
address of 518 Arnett Blvd., Danville, VA. Regal Industries, LLC has a fictitious name or “doing
business as” Exotic World, with the State Corporation Commission.
M. On January 31, 2023, and July 26, 2024, LOUISE LUCAS was issued violation
notices from the Virginia Department of Agriculture and Consumer Services related to The
Cannabis Outlet and offering non-compliant cannabis products for sale. The latter notice imposed
a $66,500 fine for the violations which included THC levels above .3% in certain products.
N. On September 26, 2024, The Cannabis Outlet experienced a burglary.
EBICHELBERGER and LUCAS-BURKE provided the complaint to the Portsmouth Police
Department and provided video of the burglary. They claimed that $450 and approximately $3,000
worth of marijuana products were missing. On October 23, 2024, the suspected marijuana
products were recovered by the Portsmouth Police Department.
O. No state criminal prosecution has ever been initiated concerning the activity of
The Cannabis Outlet.
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COUNT ONE
(Racketeering Conspiracy)
THE GRAND JURY CHARGES THAT:
1. The General Allegations Section is realleged and incorporated as if fully set forth
herein.
The Enterprise
2. At all times relevant to this Indictment, in the Eastern District of Virginia and
elsewhere, the defendants, LOUISE LUCAS, LISA LUCAS BURKE, PRINCE ALBERT
WILLIAM HUDSON, III, RYAN EICHELBERGER, THERESA LUCAS-LAMB, CARLTON
UPTON, JR., and others known and unknown, were members and associates of the Lucas
Enterprise, a criminal organization, which was engaged in, among other things, conspiracy to
distribute and possess with intent to distribute marijuana, distribution of marijuana, possession
with intent to distribute marijuana, maintaining drug involved locations, possession of firearms in
furtherance of drug trafficking, conspiracy to launder money, money laundering, conspiracy to
commit honest services fraud, and bribery, and which operated principally in the Eastern Virginia,
Virginia.
3. The Lucas Enterprise, including its leaders, members and associates, constituted an
“enterprise,” as defined in Title 18, United States Code, Section 1961(4), that is, a group of
individuals associated in fact. The enterprise constituted an ongoing organization whose members
and associates functioned as a continuing unit for a common purpose of achieving the objectives
of the enterprise. This enterprise was engaged in, and its activities affected interstate and foreign
commerce.
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Purposes of the Enterprise
4, The purposes of the enterprise included the following:
i. Obtaining and illegally distributing large quantities of illegal marijuana;
ii. Procuring “generational wealth” for, and enrichment of, members and associates of
the enterprise;
iii. Using the proceeds from the distribution of illegal marijuana sales to obtain
additional quantities of marijuana to continue and expand the enterprise’s illegal marijuana
business;
iv. Directing, obtaining, and influencing the provision of marijuana licenses to entities
in which members and associates retained and expected to procure a financial interest.
v. Using the political influence of LOUISE LUCAS to enact legislation and
regulations to financially benefit the Lucas Enterprise and to obtain recreational marijuana licenses
for members and associates of the Lucas Enterprise.
Means and Methods of the Enterprise
5. The means and methods by which Lucas Enterprise members and associates of the
Lucas Enterprise conducted and participated in the conduct of the affairs of the enterprise included,
but were not limited to, the following:
a. Members and associates of the Lucas Enterprise obtained and illegally distributed
. large quantities of marijuana through, among other avenues, businesses, entities, and locations
owned and operated by members and associates of the Lucas Enterprise;
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b. Members and associates of the Lucas Enterprise used various business entities
owned, operated, and maintained by members and associates of the Lucas Enterprise to disguise
the proceeds of illegal marijuana distribution;
c. Members and associates of the Lucas Enterprise used the political influence of
LOUISE LUCAS to insulate the Lucas Enterprise from state law enforcement actions;
d. In 2026, CARLTON UPTON, JR. worked with LOUISE LUCAS to use her
political position to obtain a recreational marijuana license for CARLTON UPTON, JR., with the
understanding that the proceeds of marijuana sales under the license would be shared with
LOUISE LUCAS to support the Lucas Enterprise;
e. Members and associates of the Lucas Enterprise used the political influence of
LOUISE LUCAS to enact legislation and obtain licenses that would financially benefit the Lucas
Enterprise and to further the goal of wealth accumulation for the Lucas Enterprise; and
f. LOUISE LUCAS used her political position in the Virginia state senate to insulate
the Lucas Enterprise from criminal scrutiny, to further the goal of wealth accumulation for the
Lucas Enterprise and to seek legislation benefiting the Lucas Enterprise.
| Roles of the Defendants
6. The roles of the defendants in the enterprise included, but were not limited to, the
following:
a. The defendant, LOUISE LUCAS, was the leader of the enterprise. LOUISE
LUCAS approved and directed criminal activities and other activities in furtherance of the
enterprise’s affairs, arranged for the acquisition and distribution of marijuana, supervised the
laundering of marijuana proceeds, used her political influence to attempt to influence Virginia
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legislation for the benefit of herself and family and maintained a premise for the distribution of
marijuana.
b. | The defendant LISA LUCAS-BURKE is the daughter of LOUISE LUCAS and
planned and participated in criminal activities and other activities in furtherance of the enterprise’s
affairs and attended meetings.
| Cc. The defendant, PRINCE ALBERT WILLIAM HUDSON, III, obtained marijuana
for members of the Lucas Enterprise, which would then be sold with the proceeds benefiting the
Lucas Enterprise. HUDSON was a regular supplier of The Cannabis Outlet and derived a
significant majority of his business and revenue from the sales of marijuana by The Cannabis
Outlet.
d. The defendant RYAN EICHELBERGER, is the son of THERESA LUCAS-LAMB
and acquired marijuana for distribution, supervised the distribution of marijuana and managed The
Cannabis Outlet for the Lucas Enterprise.
e. The defendant, THERESA LUCAS-LAMB, is the daughter of LOUISE LUCAS
and acquired marijuana for distribution, supervised the distribution of marijuana and managed The
Cannabis Outlet for the Lucas Enterprise.
f. The defendant, CARLTON UPTON, JR., was an early business partner in Virginia
Freedom Life with LOUISE LUCAS. Virginia Freedom Life encompassed The Cannabis Outlet
and The CBD Shoppe. UPTON also managed The CBD Shoppe and worked with LOUISE
LUCAS to obtain a recreational marijuana license, the proceeds of which would benefit the Lucas _
Enterprise.
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The Racketeering Conspiracy
7. Beginning on a date unknown, but starting no later than 2019, and continuing to
the return of this Indictment, in the Eastern District of Virginia and elsewhere, the defendants,
LOUISE LUCAS,
LISA LUCAS BURKE,
PRINCE ALBERT WILLIAM HUDSON, III,
RYAN EICHELBERGER,
THERESA LUCAS-LAMB,
CARLTON UPTON, JR.,
and others known and unknown, each being a person employed by and associated with the Lucas
Enterprise, an enterprise, engaged in, and the activities of which affected, interstate and foreign
commerce, did knowingly combine, conspire, confederate, and agree with one another 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 Lucas Enterprise through a pattern of racketeering
activity, as defined in Title 18, United States Code, Section 1961(1) and (5), which pattern of
racketeering activity consisted of:
a. multiple acts involving bribery, chargeable under Va. Code Ann §§ 18.2-447, 18.2-18,
18.2-22 and 18.2-26;
b. multiple offenses involving trafficking of controlled substances, in violation of 21
U.S.C. §§ 841, 846, and 856;
c. multiple acts indictable under 18 U.S.C. § 1343, 1346 (relating to honest services wire
fraud); and
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d. multiple acts indictable under 18 U.S.C. § 1956 (relating to the laundering of monetary
instruments).
8. It was further a part of the conspiracy that each defendant knowingly agreed that a
conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of
the enterprise.
Overt Acts
9. In furtherance of the conspiracy and to achieve the object and purposes of the
conspiracy, the defendants and others known and unknown committed and caused to be committed
overt acts in the Eastern District of Virginia, including but not limited to the following:
1. On or about March 25, 2019, Unindicted Co-conspirator #1 (UCC #1) registered Hair for
Dayzzzz, LLC with a business address of 1391 Watson St, Portsmouth, VA. The exact
nature of this business is unknown.
2. In or about 2021 LOUISE LUCAS and LISA LUCAS-BURKE opened The Cannabis
Outlet in Portsmouth, VA.
3. From on or about June 21, 2021, to March 9, 2023, Virginia Freedom Life, LLC listed
“The CBD Shoppe” as a fictitious name or “doing business as” as listed with the Virginia
State Corporation Commission. ,
4. On or about or between June 21, 2021, and March 9, 2023, Virginia Freedom Life, LLC
listed The Cannabis Outlet as a fictitious name or “doing business as” with the Virginia
State Corporation Commission rules.
5. OnJanuary 24, 2022, LOUISE LUCAS posted on social media that “I’m a 78 year grandma
who legalized pot and now has her own cannibis (sic) store. And I’m the last thing standing
between The GOP and total control of Virginia. That’s worth an RT!”
6. On or about February 1, 2022, LOUISE LUCAS listed herself as President/CEO of
Virginia Freedom Life on the Virginia Conflict of Interest and Ethics Advisory General
Assembly Statement of Economic Interests form.
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7. In early 2022, Indicted Co-conspirator #1 (ICC #1) contributed fifteen thousand dollars
($15,000.00) to the 420ish Unity Festival, which despite its name, was described as a
regional music event, and which was partly organized by LOUISE LUCAS. The receipt
was made out to “Freedom is Dope” which ICC #1 used as a business name.
RECEIVED FA FROM
ACCOUNT | ; Oust
PAYMENT 1$b00 ~ EY FROM ee .
8. Onor about April 19, 2022, ICC #1 met with LOUISE LUCAS, another individual, LISA
LUCAS-BURKE and THERESA LUCAS-LAMB at LOUISE LUCAS’ office at 1214
County St. Portsmouth, VA.
9. On or about April 19, 2022, LOUISE LUCAS asked ICC #1 if they were a member of law
enforcement before purchasing between three and five pounds of marijuana from ICC #1,
10. On or about April 19, 2022, LISA LUCAS-BURKE, paid ICC #1 (Freedom is Dope)
$6,600.00 via check from Virginia Freedom Life, for the marijuana.
VA FREEDOM LIFE LLC ~ 4
1214 COUNTY STREET
FORTSMOUTH VA 23704 ise Opt, £9 C032
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11. The $6,600.00 check drawn on the Virginia Freedom Life, LLC account, was returned for
insufficient funds.
12. On or about June 8, 2022, LOUISE LUCAS, wrote a check for $6,600.00 to ICC #1
(Freedom is Dope from a Backyard Entertainment, LLC account.
PLY, 22
13. On or about or between June 2022 and July 2022, ICC #1 delivered between three and five
pounds of marijuana to The Cannabis Outlet and was paid between $3,500.00 and
$4,000.00 in cash by LOUISE LUCAS.
14. On or about August 17, 2022, Mama’s Chicken LLC, was organized as a Delaware
business entity by Unindicted Co-conspirator #2 (UCC #2).
15. In or about August 2022, UCC #2 transmitted in interstate commerce funds to the state of
Delaware to organize Mama’s Chicken, LLC.
16. On or about August 22, 2022, LOUISE LUCAS contracted to purchase Mama’s Chicken,
LLC. for $1,050,000.00.
17. In or about August 2022, LOUISE LUCAS paid UCC #2 $750,000.00 for a 100% stake in
_ Mama’s Chicken, LLC, which was the shell holding company for which UCC #2 and
LOUISE LUCAS expected to obtain a Virginia. recreational marijuana license. The
agreement stipulated that UCC #2 would refund $525,000 if he had not obtained a license
by Dec. 31, 2025. Beginning in or about October 2022, LOUISE LUCAS began pressing
UCC #2 to return to her the $750,000.00.
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18. Between in or about Fall 2022 to early 2023, ICC #2 sold The Cannabis Outlet multi-pound
quantities of marijuana totaling approximately 100 pounds, for $100,000-$150,000 which
LOUISE LUCAS, through THERESA LUCAS-LAMB, paid for with $52,000.00 in checks
and the remainder in cash.
19. On or about October 3, 2022, LOUISE LUCAS sent two text messages to ICC #2
concerning a meeting at the “store”.
From: +17573282966 Louse Lucas
To:
Good morning this is to confirm the time for our meeting at the store today. | am so
excited and looking forward to seeing you
_we (The Lucas Ladies)iove doing business with you
20. On or about October 3, 2022, ICC #2 provided LOUISE LUCAS two itemized invoices,
shown in the photograph, for marijuana provided to the Cannabis Outlet.
21. On or about October 13, 2022, THERESA LUCAS-LAMB sent text messages to ICC #2
concerning payment for marijuana supplies.
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would be ok with a payment of 10. I'll be here until
what misiye e can you g get here loday d hepa r od reed more
Also, you never did give me more additional Voo Doo but you still have it on the list
22. On or about October 29, 2022, ICC #2 sent a text message to THERESA LUCAS-LAMB
discussing marijuana distribution strategies.
23. On or about October 29, 2022, THERESA LUCAS-LAMB sent a text message to ICC
#2noting she needed more flower.
24. HUDSON placed a photograph of himself with UPTON and LOUISE LUCAS on his
Facebook page dated January 19, 2023. He also posted photographs of himself inside of
what appear to be large marijuana grows.
25. On or about February 1, 2023, LOUISE LUCAS listed herself as President/CEO of
Virginia Freedom Life on the Virginia Conflict of Interest and Ethics Advisory General
Assembly Statement of Economic Interests form.
26. On or about March 21, 2023, LOUISE LUCAS listed the name The Cannabis Outlet as a
fictitious name or “doing business as” under Lucas Hospitality, LLC.
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27. During the month of December 2023, The Cannabis Outlet made payments of more than
$21,000 to UCC #1.
28. During the month of January 2024, The Cannabis Outlet made payments of more than
$26,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
29. During the month of February 2024, The Cannabis Outlet made payments of more than
$29,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
30. During the month of March 2024, The Cannabis Outlet made payments of more than
$129,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
31. During the month of April 2024, The Cannabis Outlet made payments of more than
$132,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
32. During the month of May 2024, The Cannabis Outlet made payments of more than
$125,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
33. During the month of June 2024, The Cannabis Outlet made payments of more than
$123,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
34. During the month of July 2024, The Cannabis Outlet made payments of more than $79,000
to HUDSON, which were deposited into his Agri-Carter LLC bank account at Fulton Bank.
35. During the month of August 2024, The Cannabis Outlet made payments of more than
$91,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
36. During the month of September 2024, The Cannabis Outlet made payments of more than
$67,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
37. On or about October 4, 2024, a controlled purchase of marijuana was made by law
enforcement from The Cannabis Outlet.
38. On or about October 18, 2024, a controlled purchase of marijuana was made by law
enforcement from The Cannabis Outlet.
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39. During the month of October 2024, The Cannabis Outlet made payments of more than
$74,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
40. During the month of October 2024, The Cannabis Outlet made payments of more than
$18,600 to UCC #1. .
41. On or about November 8, 2024, a controlled purchase of marijuana was made by law
enforcement from The Cannabis Outlet.
42. During the month of November 2024, The Cannabis Outlet made payments of more than
$51,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
43. During the month of November 2024, The Cannabis Outlet made payments of more than
$58,000 to UCC #1.
44, During the month of December 2024, The Cannabis Outlet made payments of more than
$40,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
45. On or about January 3, 2025, UCC #1 registered High-In-Wellness as a business with an
address of 1112 Pickett Road, Norfolk, VA 23502. The purported nature of this business
is unknown.
46. During the month of January 2025, The. Cannabis Outlet made payments of more than
$36,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
47. During the month of January 2025, The Cannabis Outlet made payments of more than
$47.700 to UCC #1.
48. During the month of February 2025, The Cannabis Outlet made payments of more than
$55,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
49. During the month of February 2025, The Cannabis Outlet made payments of more than
$22,900 to UCC #1.
50. During the month of March 2025, The Cannabis Outlet made payments of more than
$38,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
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51. During the month of March 2025, The Cannabis Outlet made payments of more than
$53,800 to UCC #1.
52. During the month of April 2025, The Cannabis Outlet made payments of more than
$54,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
53. During the month of April 2025, The Cannabis Outlet made payments of more than
$45,100 to UCC #1.
54, On or about May 5, 2025, an undercover law enforcement agent (UC) purchased 10.2
grams of marijuana from The CBD Shoppe.
55. During the month of May 2025, The Cannabis Outlet made payments of more than $43,000
to HUDSON, which were deposited into his Agri-Carter LLC bank account at Fulton Bank.
56. During the month of May 2025, The Cannabis Outlet made payments of more than $47,200
to UCC #1.
57. During the month of June 2025, The Cannabis Outlet made payments of more than $77,000
to HUDSON, which were deposited into his Agri-Carter LLC bank account at Fulton Bank.
58. During the month of June 2025, The Cannabis Outlet made payments of more than $3,400
to UCC #1.
59. During the month of July 2025, The Cannabis Outlet made payments of more than $73,000
to HUDSON, which were deposited into his Agri-Carter LLC bank account at Fulton Bank.
60. During the month of July 2025, The Cannabis Outlet made payments of more than $62,600
to UCC #1.
61. On or about July 14, 2025, THERESA LUCAS-LAMB received a payment of $2,500.00
from the Agri-Carter business account controlled by HUDSON.
62. On or about August 1, 2025, THERESA LUCAS-LAMB received a payment of $2,500.00
from the Agri-Carter business account controlled by HUDSON.
63. On or about August 13, 2025, Norfolk Police seized seven pounds of marijuana that had
been shipped to High-In-Wellness at 1112 Pickett Road, Norfolk, VA 23502.
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64. On or about August 18, 2025, THERESA LUCAS-LAMB received a payment of
$2,500.00 from the Agri-Carter business account controlled by HUDSON.
65. During the month of August 2025, The Cannabis Outlet made payments of more than
$33,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
66. During the month of August 2025, The Cannabis Outlet made payments of more than
$34,800 to UCC #1.
67. During the month of September 2025, The Cannabis Outlet made payments of more than
$81,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
68. On or about September 9, 2025, THERESA LUCAS-LAMB received a payment of
$2,500.00 from the Agri-Carter business account controlled by HUDSON.
69. On or about September 19, 2025, THERESA LUCAS-LAMB received a payment of
$3,900.00 from the Agri-Carter business account controlled by HUDSON.
70. On or about October 6, 2025, THERESA LUCAS-LAMB received a payment of $2,500.00
from the Agri-Carter business account controlled by HUDSON.
71.On or about October 20, 2025, THERESA LUCAS-LAMB received a payment of
$2,500.00 from the Agri-Carter business account controlled by HUDSON.
72. On or about October 23, 2025, a controlled purchase of one half (4) ounce of marijuana
was made by law enforcement from Tthe Cannabis Outlet.
73. On or about October 31, 2025, a controlled purchase of one ounce of marijuana was made
by law enforcement from Tthe Cannabis Outlet. During the transaction, EICHELBERGER
informed the undercover officer that an additional load of “product” was due on November
3, 2025.
74. During the month of October 2025, The Cannabis Outlet made payments of more than
$27,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
75. On or about November 3, 2025, PRINCE ALBERT WILLIAMS HUDSON, Ill, delivered
multiple large boxes to Tthe Cannabis Outlet.
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76. On or about November 4, 2025, THERESA LUCAS-LAMB received a payment of
$2,500.00 from the Agri-Carter business account controlled by HUDSON.
77, On or about November 15, 2025, LOUISE LUCAS sent UCC #2 a text message concerning
her $750,000.00 August 2022 payment that she had tried to recover.
Sat, Nov 15 at 11:10AM
I | received a message from you
after the election wherein you stated
that you have the answer. And, you
know | will be carrying the legislation
as the Chief Co-patron. Yes, we can
make a lot of money but, before we
start down that road again; how about
we begin with you sending at least a
good faith payment of the money you
owe me with arrangements for the
balance. Then we can talk about future
business plans.
L. Louise Lucas ©
78. On or about November 24, 2025, THERESA LUCAS-LAMB received a payment of
$2,500.00 from the Agri-Carter business account controlled by HUDSON.
79. On or about November 26, 2025, PRINCE ALBERT WILLIAM HUDSON, III, delivered
two large boxes to The Cannabis Outlet.
80. During the month of November 2025, The Cannabis Outlet made payments of more than
$35,000 to HUDSON, which were deposited into his Agri-Carter LLC bank account at
Fulton Bank.
81. On or about December 9, 2025, law enforcement made a controlled purchase of one ounce
of marijuana from High-In-Wellness.
82. On or about December 9, 2025, law enforcement made a controlled purchase of one ounce
of marijuana from The CBD Shoppe.
83. On or about December 12, 2025, Herbal Outlet, LLC was organized with a business address
of 1214 County St. Portsmouth, VA.
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84. On or about January 13, 2026, EICHELBERGER sent a text message to Tameka Johnson,
stating “Morning Tameka! Can you pull up Friday with some flower & I’ll have a list of
stuff for you to try & get for next time.”
85. On or about February 14, 2026, EICHELBERGER sent a text message to Johnson, “Also
can you get the COAs for the flower and other products?”, to which Johnson responded
“Okay.”
86. On or about February 19, 2026, EICHELBERGER sent a text message to Johnson, “How
much for just the Tyson and Extract?” To which Johnson responded “Tyson-1100.”
87. On or about February 19, 2026, Johnson sent a text message to EICHELBERGER, “I’m
giving U some good prices now.” “How much flower do you need?”
88. On or about April 11, 2026, EICHELBERGER sent a text message to Johnson, “What up
Tameka. You got a few P’s you can pullup in the morning?”
| 89. On or about April 11, 2026, Johnson sent a text message to EICHELBERGER, “How
many”, to which EICHELBERGER responded, “4 or 5”.
90. On or about January 30, 2026, UCC #2 met with LOUISE LUCAS, per her request, at her
legislative office at the Capitol complex in Richmond, VA where UCC #2 provided
LOUISE LUCAS with a “partial repayment” of the money LOUISE LUCAS paid for an
interest in Mama’s Chicken, LLC. The $100,000 was provided to UCC #2 by the FBI.
91. During the meeting with UCC #2 on January 30, 2026, LUCAS telephoned the president
of the Virginia Cannabis Association and Vice Chair of the Virginia Beach Cannabis Task
Force and informed him that she and UCC #2 were “back in the same tent again.”
92. On or about January 30, 2026, LOUISE LUCAS called UCC #2 and asked for “samples”
of marijuana flowers she could try out during their scheduled meeting on January 31, 2026.
93. On or about January 31, 2026, LOUISE LUCAS and UCC #2 met at her legislative office
at 1214 County Street, Portsmouth, VA. During the meeting LOUISE LUCAS called LISA
LUCAS-BURKE and EICHELBERGER for a group conversation during which they
discussed their sources of supply for marijuana. When asked by UCC #2 whether The
Cannabis Outlet was receiving hemp, LUCAS-BURKE and EICHELBERGER both
responded “[i]t’s not hemp, it’s THC.”
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94. On or about January 31, 2026, following the conclusion of the group conversation,
LOUISE LUCAS and UCC #2 continued discussing marijuana and marijuana licensing as
a way for LOUISE LUCAS to “get generational wealth and this is my last chance.”
95. On or about January 31, 2026, LOUISE LUCAS and UCC #1 met at The Cannabis Outlet.
96. On or about February 3, 2026, UCC #1 arrived at The Cannabis Outlet and took a large
bag from his vehicle and took it inside the business.
97. On or about February 5, 2026, law enforcement made a controlled purchase of 69.5 grams
of marijuana from The CBD Shoppe.
98. On or about February 5, 2026, law enforcement made a controlled purchase of 116 grams
of marijuana from High-In-Wellness.
99. On or about February 9, 2026, LOUISE LUCAS called UCC #2 and discussed the language
surrounding the recreational marijuana legislation pending in the Virginia General
Assembly and the possibility of UCC #2 receiving a license and sharing the proceeds with
her because “this is our last chance at generational wealth . . .. I’ve got too old to not be
greedy.”
100. On or about February 11, 2026, law enforcement observed UCC #2 dispose of a white trash
bag in a dumpster. The trash bag was retrieved by law enforcement and found to contain
19 packaging bags with the odor of marijuana.
101.On or about March 7, 2026, LOUISE LUCAS called EICHELBERGER and discussed
Tameka Johnson as a “middleman” for marijuana sources of supply.
102.On or about March 9, 2026, LOUISE LUCAS telephoned another Virginia legislator and
informed them that she needed to get the marijuana license because “I got to get the license
and I got to get the money rolling in because I want -- I want to make generation, create some
generational wealth. .. . I need to be covered under his (UPTON’s) um, hemp license.”
UPTON and the license were discussed in prior conversations between LOUISE LUCAS
- and the Virginia legislator.
103. On or about March 11, 2026, LOUISE LUCAS was involved in a telephone conference with
a Virginia legislator and LISA LUCAS-BURKE. The call concerned the 420ish Unity
Festival and LOUISE LUCAS stated “The whole police department protected us.” The
Virginia legislator responded that the cannabis legislation would make sure “everything is _
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on the up and up” to which LOUSIE LUCAS responded “ [a]nd make it legal because I did,
when I did it, it was obviously illegal.”
104. On or about March 11, 2026, LOUISE LUCAS was involved in a telephone conference with
two Virginia legislators and LISA LUCAS-BURKE concerning recreational marijuana
licenses. During the call LOUISE LUCAS stated, “we trying to disqualify somebody [UCC
#2] until he pays me back my money.”
105.On or about March 17, 2026, UCC #2 arrived at The Cannabis Outlet and entered the
business with a duffle bag.
106.On or about March 27, 2026, LISA LUCAS-BURKE informed LOUISE LUCAS that
HUDSON was coming with the “stuff”.
107. On or about March 27, 2026, HUDSON visited The Cannabis Outlet and delivered six large
boxes. HUDSON then left with a large red duffle bag.
108. On or about March 31, 2026, UPTON met with LOUISE LUCAS at her office located at
1214 County Street, Portsmouth, VA. Prior to the meeting, UPTON telephoned LOUISE
LUCAS and during the conversation stated, “I only got five licenses, but you know what I
mean, you first, so I need to talk to you like before I make any decisions that affect you.”
109. On or about April 23, 2026, LOUISE LUCAS telephoned a member of the CCA who asked
if there was anything they could do for her. LOUISE LUCAS responded that she needed “to
invest in something that -- that can help me generate some uh, generational wealth for my
family.” When the board member suggested cannabis licenses, LOUISE LUCAS responded
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that “got a couple of bad apples who are going to be applying for a license who do not get
them.”
110. On or about April 28, 2026, LOUISE LUCAS telephoned EICHELBERGER and asked
where he thought he would be getting “the flower”. EICHELBERGER responded, “(UCC
#2) and -- and Prince and Tameka.”
111. On or about May 6, 2026, a federal search warrant was executed at The Cannabis Outlet
where marijuana was recovered.
112. Onorabout May 6, 2026, a federal search warrant was executed at The CBD Shoppe where
marijuana was recovered.
113. On or about May 6, 2026, a federal search warrant was executed at Exotic World in
Danville, VA, a business owned by HUDSON, where marijuana was recovered.
114. On or about July 10, 2026, law enforcement made a controlled purchase of two separate
strains titled “Sativa” and “Indica” from the Cannabis Outlet. Both tested positive for
marijuana.
(In violation of Title 18, United States Code, Section 1962(d)).
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COUNT TWO
(Conspiracy to Distribute and Possess with Intent to Distribute Marijuana)
THE GRAND JURY FURTHER CHARGES THAT:
1, The factual allegations in paragraphs 1 through 9 of Count One of this Indictment
are realleged and incorporated as if fully set out herein.
2. On or about or between 2020 and 2026, in the Eastern District of Virginia and
elsewhere, the defendants, LOUISE LUCAS, LISA LUCAS BURKE, PRINCE ALBERT
WILLIAM HUDSON, III, RYAN EICHELBERGER, THERESA LUCAS-LAMB, CARLTON
UPTON, JR., TAMEKA JOHNSON and others known and unknown, did unlawfully, knowingly
and intentionally combine, conspire, confederate and agree together with other persons known and
unknown to the grand jury to commit the following offenses against the United States:
3. Distribute 100 kilograms or more of a mixture or substance containing a detectable
amount of marijuana, a Schedule I controlled substance, in violation of Title 21, United States
Code, Section 841(a)(1) and (b)(1)(B).
4, Possess with intent to distribute 100 kilograms or more of a mixture or substance
containing a detectable amount of marijuana, a Schedule I controlled substance, in violation of
Title 21, United States Code, Section 841(a)(1) and (b)(1)(B).
(All in violation of Title 21, United States Code, Sections 846, 841(a)(1) and
841(b)(1)(B)).
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COUNT THREE
(Conspiracy to Launder Money)
THE GRAND JURY FURTHER CHARGES THAT:
1. The factual allegations in paragraphs 1 through 9 of Count One of-this Indictment
are realleged and incorporated as if fully set out herein.
2. Beginning in or about 2020 through 2026, in the Eastern District of Virginia and
elsewhere, LOUISE LUCAS, LISA LUCAS BURKE, PRINCE ALBERT WILLIAM HUDSON,
III, RYAN EICHELBERGER, THERESA LUCAS-LAMB, CARLTON UPTON, JR., TAMEKA
JOHNSON the defendants herein, along with others known and unknown to the Grand Jury did
knowingly, willfully, and unlawfully combine, conspire, confederate and agree with each other
and other persons, both known and unknown, to commit offenses against the United States in
violation of Title 18, United States Code, Section 1956, to wit:
a. Laundering of monetary instruments, that is, to knowingly conduct and
attempt to conduct financial transactions affecting interstate and foreign
commerce, which transactions involved the proceeds of specified unlawful
activity, that is, conspiracy to distribute and possess with intent to distribute
marijuana, in violation of 21 U.S.C. § 846, as described in Count Two of this
Indictment, knowing that the transactions were designed in whole and in part
to conceal and disguise the nature, location, source, ownership, and control of
the proceeds of specified unlawful activity, and that while conducting and
attempting to conduct such financial transactions, knew that the property
involved in the financial: transactions represented the proceeds of some form
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of unlawful activity, in violation of Title 18, United States Code, Section
1956(a)(1)(B)G@); and
b. To knowingly conduct and attempt to conduct a financial transaction affecting
interstate and foreign commerce, which involved the proceeds of a specified
unlawful activity, that is conspiracy to distribute and possess with intent to
distribute marijuana, in violation of 21 U.S.C. § 846, as described in Count
Two of this Indictment, with the intent to promote the carrying on of specified
unlawful activity, that is conspiracy to distribute and possess with intent to
distribute marijuana, in violation of 21 U.S.C. § 846, and that while
conducting and attempting to conduct such financial transaction knew that the
property involved in the financial transaction represented the proceeds of
some form of unlawful activity in violation of Title 18, United States Code,
Section 1956(a)(1)(A)(i).
(In violation of Title 18, United States Code, Section 1956(h)).
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COUNT FOUR
(Conspiracy to Commit Honest Services Fraud)
THE GRAND JURY FURTHER CHARGES THAT:
1. The factual allegations in paragraphs 1 through 9 of Count One of this Indictment
are realleged and incorporated as if fully set out herein .
2. From in or about 2022 through in or about 2026, in the Eastern District of Virginia
and elsewhere, defendants LOUISE LUCAS, LISA LUCAS BURKE and CARLTON UPTON,
JR., knowingly and intentionally conspired with each other and with other persons known and
unknown to devise and intend to devise a scheme and artifice to defraud and deprive the citizens
of the Commonwealth of Virginia of their intangible right to the honest services of LOUISE
LUCAS, through bribery, and for the purpose of executing such scheme, did knowingly transmit,
or caused to be transmitted, any writing, signal, or sound by means of a wire communication in
interstate or foreign commerce, in violation of Title 18, United States Code, Section 1343 and
1346.
Purpose
3. The conspiracy and scheme and artifice had multiple purposes. One purpose of the
conspiracy and the scheme and artifice was for defendant LOUISE LUCAS to use her official
position as a state senator of the Commonwealth of Virginia to enrich herself by soliciting and/or
accepting payments, gifts, and other things of value from others (including conspirators). Another
purpose of the conspiracy and scheme and artifice was for LOUISE LUCAS to perform official
actions, including certain specific official actions and other official actions on an as-needed basis
to benefit UCC #2, UPTON and others.
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Manner and Means
4. The manner and means by which the conspirators would and did carry out the
conspiracy included, but were not limited to, the following:
a. LOUISE LUCAS was elected to serve as a state senator by the citizens of Virginia.
She was a vocal proponent of legislation authorizing and establishing a retail market for marijuana.
b. In order to benefit herself and The Lucas Enterprise, LOUISE LUCAS sought
opportunities to invest in and benefit from anticipated recreational marijuana licensing.
c. LOUISE LUCAS provided money to UCC #2 and obtained an ownership interest
in an entity created by UCC#2 in order to financially benefit from anticipated marijuana licensing
and sales in exchange for using her political influence to take official actions to steer a marijuana
license to UCC#2 and/or entities UCC#2 controlled and/or fronted.
d. LOUISE LUCAS did not report the interest obtained in this entity on her required
Statement of Economic Interests forms.
e. LOUISE LUCAS demanded and accepted a partial re-payment of her invested
funds ($100,000) from UCC#2 in exchange for continuing to work to direct a license to UCC#2.
5. LOUISE LUCAS engaged in official acts related to marijuana legislation on behalf
of UCC#2, UPTON and others on an as-needed basis.
6. In furtherance of this scheme, UCC#2, LOUISE LUCAS and other conspirators
engaged in and/or agreed to engage in wire transmissions in interstate commerce.
(In violation of Title 18, United States Code, Sections 1349, 1343 and 1346).
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COUNT FIVE
(Maintaining a Drug Involved Premises)
THE GRAND JURY FURTHER CHARGES THAT:
On or about or between 2020 and 2026, in the Eastern District of Virginia, defendants
LOUISE LUCAS, LISA LUCAS BURKE, RYAN EICHELBERGER, and THERESA LUCAS-
LAMB, did unlawfully and knowingly manage, and control real property and improvements
located at 1215 High Street, Portsmouth, VA 23704, as an owner and occupant, and did knowingly
and intentionally make available for use said place for the purpose of unlawfully manufacturing,
storing, distributing, and using a controlled substance.
(In violation of Title 21, United States Code, Section 856(a)(2)).
35
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 36 of 45 PagelD# 114
COUNT SIX
(Maintaining a Drug Involved Premises)
THE GRAND JURY FURTHER CHARGES THAT:
On or about or between 2020 and 2026, in the Eastern District of Virginia, defendants
CARLTON UPTON, JR. and TAMEKA JOHNSON, did unlawfully and knowingly manage, and
control real property and improvements located at 345 Granby Street, Suite A, Norfolk, VA 23510,
as an owner and occupant, and did knowingly and intentionally make available for use said place
for the purpose of unlawfully manufacturing, storing, distributing, and using a controlled
substance.
(All in violation of Title 21, United States Code, Section 856(a)(2)).
36
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 37 of 45 PagelD# 115
COUNT SEVEN
(Possess a Firearm in Furtherance of a Drug Trafficking Crime)
THE GRAND JURY FURTHER CHARGES THAT:
On or about May 6, 2026, in the Eastern District of Virginia, the defendant, RYAN
EICHELBERGER, aided and abetted by others known and unknown, did knowingly possess a
firearm in furtherance of, a drug trafficking crime for which they may be prosecuted in a court of
the United States, specifically, Conspiracy to Possess with Intent to Distribute and Distribute
Marijuana, the offense set forth in Count Two of this Indictment, the descriptions of which are
hereby incorporated by reference as though fully set forth herein.
(In violation of Title 18, United States Code, Sections 924(c)(1)(A)(iii) and 2).
37
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 38 of 45 PagelD# 116
COUNT EIGHT
(Wire Fraud)
THE GRAND TURY FURTHER CHARGES THAT:
1. The United States Small Business Administration (SBA) is an executive-branch
agency of the United States government that provides support to entrepreneurs and small
businesses. The mission of the SBA is to maintain and strengthen the nation’s economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.
2. As part of this effort, the SBA enables and provides for loans through banks, credit
unions and other lenders. These loans have government-backed guarantees. In addition to
traditional SBA funding programs, The CARES Act, which was signed into law in March 2020,
established several new temporary programs and provided for the expansion of others to address
the COVID-19 outbreak.
3. Another related response to the COVID-19 outbreak was an expansion of an
existing disaster-related program - the Economic Injury Disaster Loan (EIDL) - to provide for loan
assistance (including $10,000 advances) for small businesses and other eligible entities for loans
_ up to $2 million. The EIDL proceeds can be used to pay fixed debts, payroll, accounts payable
and other bills that could have been paid had the disaster not occurred; however, such loan
proceeds are not intended to replace lost sales or profits or for expansion of a business.
4. Unlike certain other types of SBA-guaranteed loans, EIDL funds are issued directly
from the United States Treasury and applicants apply through the SBA via an online portal and
application. The EIDL application process, which also uses certain outside contractors for system
support, collects information concerning the business and the business owner, including:
38
Case 4:26-cr-00075-JKW-RJK Document3_ Filed 10/14/26 Page 39 of 45 PagelD# 117
information as to the gross revenues for the business prior to January 31, 2020; the cost of goods
sold; and information as to any criminal history of the business owner. Applicants electronically
certify that the information provided is accurate and are warned that any false statement or
misrepresentation to the SBA or any misapplication of loan proceeds may result in sanctions,
including criminal penalties.
First Virginia Freedom Life EIDL Application
5. On or about April 10, 2020, CARLTON UPTON, JR., the defendant herein,
| electronically applied for an EIDL using the company name of Virginia Freedom Life. UPTON
claimed that Virginia Freedom Life was located at 6721 Hampton Parkway, Suffolk, Virginia.
6. On or about April 10, 2020, UPTON responded no to the question “have you ever
been convicted, plead (sic) guilty, plead (sic) nolo contendere, been placed on pretrial diversion,
or been placed on any form of parole or probation . . .”. This statement was false given UPTON’s
four prior felony convictions. |
7. UPTON listed gross revenue for Virginia Freedom Life of $58,463 and $35,000
costs of goods. UPTON was funded a loan in the amount of $11,800.
Second Virginia Freedom Life EIDL Application
8. On or about July 13, 2020, UPTON, the defendant herein, electronically applied
for an EIDL using the company name of Virginia Freedom Life.
9. UPTON listed gross revenue for Virginia Freedom Life of $450,000 and $300,000
costs of goods with rental income of $12,000. UPTON was declined for a loan.
39
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 40 of 45 PagelD# 118
, THE SCHEME AND ARTIFICE
10. From on or about at least April 2020, to in or about at least September 2020, in the
Eastern District of Virginia and elsewhere, CARLTON UPTON, JR.., the defendant herein, devised
and intended to devise a scheme and artifice to defraud, and to obtain money by means of
materially false and fraudulent pretenses, representations, promises and omissions.
11. It was a part of the scheme and artifice that the defendant sought to fraudulently
obtain disaster-related benefits in the form of SBA-sponsored Economic Injury Disaster (EIDL)
loans.
12. It was further a part of the scheme and artifice that the defendant submitted
applications for loans under the EIDL program that contained false statements, misrepresentations
and omissions related to the defendant’s income, claimed business entities and his prior criminal
record.
13. It was further a part of the scheme and attifice that the defendant falsely attested on
the aforementioned loan applications that the information presented was true and accurate.
14. It was further a part of the scheme and artifice that the defendant received and
obtained approximately $11,800 in EIDL proceeds.
15. It was further a part of the scheme and artifice that the defendant caused the
transmission of information and funds by wire between the Eastern District of Virginia and
locations outside of the Commonwealth of Virginia.
WIRING IN FURTHERANCE OF THE SCHEME
On or about April 10, 2020, CARLTON UPTON, JR., the defendant herein, having devised
and intended to devise a scheme and artifice to defraud and for obtaining money and property by
40
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 41 of 45 PagelD# 119
means of materially false, fraudulent and fictitious pretenses, representations and promises, as
described in Paragraphs 5-9 above and incorporated herein by reference, and, for the purpose of
executing the aforesaid scheme and artifice to defraud and for obtaining money and property by
means of materially false and fraudulent pretenses, representations and promises, in the Eastern
District of Virginia and elsewhere, did knowingly and willfully transmit and cause to be
transmitted by means of wire communication in interstate commerce, the following certain signs,
signals, and sounds: to wit, an Economic Injury Disaster Loan (EIDL) application to the SBA for
Virginia Freedom Life resulting in funding that contained false statements and misrepresentations
and omissions related to his business entity, employment, income and background.
to/from/through a location within the Eastern District of Virginia to/from/through a location
outside of the Commonwealth of Virginia.
(In violation of Title 18, United States Code, Sections 1343 and 2).
41
Case 4:26-cr-00075-JKW-RJK Document3 _ Filed 10/14/26 Page 42 of 45 PagelD# 120
FORFEITURE
THE GRAND JURY FURTHER FINDS PROBABLE CAUSE THAT:
1. The defendants, if convicted of the violation alleged in Count 1 of this indictment, shall
forfeit to the United States, as part of the sentencing pursuant to Federal Rule of Criminal
Procedure 32.2:
a. Any interest the defendant acquired or maintained in violation of Title 18, United
States Code, Section 1962;
b. Any interest in, security of, claim against, or property or contractual right of any
kind affording a source of influence over, any enterprise which the defendant has
established, operated, controlled, conducted, or participated in the conduct of, in
violation of Title 18, United States Code, Section 1962; and
c. Any property constituting, or derived from, any proceeds obtained, directly or
indirectly, from racketeering activity or unlawful debt collection in violation of
Title 18, United States Code, Section 1962.
2. The defendants, if convicted of the violation alleged in Count 3 of this indictment, shall
forfeit to the United States, as part of the sentencing pursuant to Federal Rule of Criminal
Procedure 32.2, any property, real or personal, involved in the violation, or any property
traceable to that property.
3. The defendants, if convicted of any of the violations alleged in Counts 2, 5, 6, and 7 of
this indictment, shall forfeit to the United States, as part of the sentencing pursuant to
Federal Rule of Criminal Procedure 32.2:
42
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 43 of 45 PagelD# 121
a. Any property constituting, or derived from, any proceeds obtained, directly or
indirectly, as the result of the violation; and
b. Any property used, or intended to be used, in any manner or part, to commit, or to
facilitate the commission of, the violation.
4. The defendants, if convicted of any of the violations alleged in this indictment, shall
forfeit to the United States, as part of the sentencing pursuant to Federal Rule of Criminal
Procedure 32.2, any firearm or ammunition involved in or used in the violation.
5. The defendants, if convicted of the violation alleged in Count 4 of this indictment, shall
forfeit to the United States, as part of the sentencing pursuant to Federal Rule of Criminal
Procedure 32.2, any property, real or personal, which constitutes or is derived from
proceeds traceable to the violation.
6. Ifany property that is subject to forfeiture above is not available, it is the intention of the
United States to seek an order forfeiting substitute assets pursuant to Title 21, United
States Code, Section 853(p) and Federal Rule of Criminal Procedure 32.2(e).
7. The assets subject to forfeiture include, but are not limited to:
A. Real property and improvements located at 1214 County Street,
Portsmouth, Virginia 23704;
B. Real property and improvements located at 1215 High Street,
Portsmouth, Virginia 23704;
C. Real property and improvements located at 530 Amett Boulevard,
Danville, Virginia 24540;
D. Real property and improvements located at 516-518 & 520 Arnett
Boulevard, Danville, Virginia 24540;
E. Real property and improvements located at 801 Freedom Avenue,
Portsmouth, Virginia 23701;
43
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 44 of 45 PagelD# 122
F. Funds on deposit in Southern Bank account # 2062104012.
(In accordance with Title 21, United States Code, Section 853; Title 18, United States
Code, Sections 924(d)(1), 981(a)(1)(C), 982(a)(1), and 1963(a); and Title 28, United States .
Code, Section 2461(c)).
44
Case 4:26-cr-00075-JKW-RJK Document3 Filed 10/14/26 Page 45 of 45 PagelD#. 123
Pursuant to the E-Government Act,
the original of this page has been filed
under seal in the Clerk’s Office.
UNITED STATES v. LILLIE LOUISE LUCAS, et. al. Criminal No. 4:26-CR- ai ri
A TRUE BILL:
REDACTED COS
FOREPERSON
TODD W. BLANCHE
ATTORNEY GENERAL
THEOPHANI K. STAMOS
FIRST ASSISTANT UNITED STATES ATTORNEY
By: ALLELE: Se QO
Eric M. Hurt
Brian J. Samuels
Assistant United States Attorneys
Attorneys for the United States
United States Attorney’s Office
Eastern District of Virginia
One City Center, Suite 200
11815 Fountain Way
Newport News, Virginia 23606
Phone: (757) 591-4000
Fax: (757) 591-0866
Case 4:26-cr-00075-JKW-RJK Document 3-1
REDAC
JS 45 (11/2002)
Criminal Case Cover Sheet
Filed 10/14
TED
/26 Page 1 of 1 PagelD# 131
U.S. District Court
Place of Offense:
Under Seal: Yes X No O
Judge Assigned:
City: EDVA
Previous Charging Document:
Criminal Number:
County/Parish: NN
Same Defendant:
New Defendant: Yes
Magistrate Judge Case Number:
Search Warrant Case Number:
R 20/R 40 from District of
Arraignment Date:
Defendant Information:
Juvenile: Yes No
FBI#
Defendant Name: Lillie Louise Lucas
| Alias Name(s):
‘Address: Portsmouth, VA
Birth Date: 1-1944 ssw: 4521
|Sex: F Race: Blk
| Nationality: US
Place of Birth: US
Height: | Weight:
Eyes:
Scars/Tattoos:
Interpreter: Yes] No
List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date:
|
C] Already in Federal Custody as of:
in:
O Already in State Custody
[] On Pretrial Release
O Not in Custody
&] Arrest Warrant Requested
OC) Fugitive
C1 Summons Requested
OO Arrest Warrant Pending
C) Detention Sought
O Bond
Defense Counsel Information:
Name: Anthony Capozzolo
O Court Appointed
Address: 10 Grand Central
155 East 44th Street, 25th Floor
New York, New York 10017
O Public Defender
Telephone: 212-897-1970
O Office of Federal Public Defender should not be appointed due to conflict of interest
Email:Anthony.Capozzolo@LBKM | 01 CJA attorney/s should not be appointed due to conflict of
LAW.com interest
OC No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
| |
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy 1 felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4 18 USC 1343, 1346, 1349 Conspiracy Honest Services Fraud {| 4 felony
Set 5 21 USC 856 Maintain Drug Premise B) felony
:26-cr- - - er iled 10/14/26
Case 4:26-cr-00075-JKW-RJK Document cTEB
Page 1 of 1 PagelD# 132
JS 45 (11/2002) . .
Criminal Case Cover Sheet U.S. District Court
|Place of Offense: Under Seal: Yes & No Judge Assigned:
City: EDVA Previous Charging Document: Criminal Number:
County/Parish: NN
Same Defendant:
New Defendant: Yes
Magistrate Judge Case Number:
Search Warrant Case Number:
R 20/R 40 from District of
Arraignment Date:
Defendant Information:
FBI#
‘Defendant Name: Lisa Lucas-Burke
| Alias Name(s):
Address: Portsmouth, VA
Birth Date: 8-1963 SSH: 3506
ISex: F
Race: Blk
| Nationality: US
Place of Birth: US
Eyes:
Interpreter: Yes No
List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date:
|
C) Already in Federal Custody as of:
in:
CL) Already in State Custody
CJ On Pretrial Release
C) Not in Custody
XX] Arrest Warrant Requested
O Fugitive
C) Summons Requested
C] Arrest Warrant Pending
CL) Detention Sought
( Bond
Defense Counsel Information:
Name: Ci Court Appointed
Address
0 Public Defender
Telephone: O Office of Federal Public Defender should not be appointed due to conflict of interest
OCIA attorney/s should not be appointed due to conflict of
Email: interest
C) No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy 1 felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4 18 USC 1343, 1346, 1349 Conspiracy Honest Services Fraud | 4 felony
Set 5 21 USC 856 Maintain Drug Premise 5 felony
Case 4:26-cr-00075-JKW-RJK Document ey CTR 10/14/26
Page 1 of 1 PagelD# 133
JS 45 (11/2002)
Criminal Case Cover Sheet U.S. District Court
Place of Offense: Under Seal: Yes X] No O Judge Assigned:
City: EDVA Previous Charging Document: Criminal Number:
County/Parish: NN Same Defendant: New Defendant: Yes
Magistrate Judge Case Number: Arraignment Date:
Search Warrant Case Number:
R 20/R 40 from District of
Defendant Information:
Juvenile: Yes No FBI#
[Defendant Name: Prince Albert William Hudson, III | Alias Name(s):
Address:
Birth Date: 03-1983 Issu: 7113 |Sex: M Race: Blk | Nationality: US Place of Birth: US
Interpreter: Yes] No & |List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date:
C1 Already in Federal Custody as of: in:
C) Already in State Custody
C1 On Pretrial Release
(1) Not in Custody
Arrest Warrant Requested
O Fugitive
CL) Summons Requested
C) Arrest Warrant Pending
CL) Detention Sought
OO Bond
Defense Counsel Information:
Name: QO Court Appointed
Address
0) Public Defender
Telephone: O Office of Federal Public Defender should not be appointed due to conflict of interest
0) CIA attorney/s should not be appointed due to conflict of
Email: interest
0 No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy 1 felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4
Set 5
ober. “ay. {3-4 Filed 10/14/26
Case 4:26-cr-00075-JKW-RJK Document 3-4. File
JS 45 (11/2002)
Criminal Case Cover Sheet
Page 1 of 1 PagelD# 134
U.S. District Court
Place of Offense:
Under Seal: Yes XK) No
Judge Assigned:
City: EDVA
Previous Charging Document:
Criminal Number:
County/Parish: NN
Same Defendant:
New Defendant: Yes
Magistrate Judge Case Number:
Arraignment Date:
Search Warrant Case Number:
R 20/R 40 from District of
Defendant Information:
Juvenile: Yes No FBI#
Defendant Name: Ryan Eichelberger
| Alias Name(s):
‘Address: Portsmouth, VA
Birth Date: 07-1987 ssi: 6834 ISex: M Race: Bik | Nationality: US Place of Birth: US
Interpreter: Yes] No
List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date:
|
O) Already in Federal Custody as of:
in:
C] Already in State Custody
C] On Pretrial Release
{] Not in Custody
& Arrest Warrant Requested
1 Fugitive
(1) Summons Requested
CL] Arrest Warrant Pending
L] Detention Sought
OO Bond
Defense Counsel Information:
Name: CO Court Appointed
Address
O Public Defender
Telephone: 0 Office of Federal Public Defender should not be appointed due to conflict of interest
OCIA attorney/s should not be appointed due to conflict of
Email: interest
0 No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy | felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4 21 USC 856 Maintain Drug Involved Location 5 felony
Possess Firearm in Furtherance of
Set 5 18 USC 924(c) Drug Trafficking 8 felony
Case 4:26-cr-00075-JKW-RJK Docume ao. cris" 10/14/26
JS 45 (11/2002)
Criminal Case Cover Sheet
Page 1 of 1 PagelD# 136
U.S. District Court
Place of Offense: Under Seal: Yes X) No U1 Judge Assigned:
City: EDVA Previous Charging Document: Criminal Number:
County/Parish: NN
Same Defendant:
New Defendant: Yes
Magistrate Judge Case Number:
Search Warrant Case Number:
Arraignment Date:
R 20/R 40 from District of
Defendant Information:
Juvenile: Yes NoW& FBI#
Defendant Name: Theresa Lucas-Lamb
| Alias Name(s):
‘Address: Chesapeake.
Birth Date: 10-1965 _ |SS#: 8811
|Sex: F Race: BIk
\Nationality: US
Place of Birth: US
Height: | Weight:
Eyes:
|Scars/Tattoos:
Interpreter: YesL] No &
List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date:
|
C) Already in Federal Custody as of:
in:
OO Already in State Custody
C) On Pretrial Release
CL) Not in Custody
[XI Arrest Warrant Requested
C1 Fugitive
(1 Summons Requested
CO Arrest Warrant Pending
C1) Detention Sought
[ Bond
Defense Counsel Information:
Name: (1) Court Appointed
Address
O Public Defender
Telephone: QO Office of Federal Public Defender should not be appointed due to conflict of interest
0) CJA attorney/s should not be appointed due to conflict of
Email: interest
01 No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
| |
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy 1 felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4 21 USC 856 Maintain Drug Involved Premise 5 felony
Case 4:26-cr-00075-JKW-RJK Document 3 hope 10/14/26 Page 1 of 1 PagelD# 135
JS 45 (11/2002)
Criminal Case Cover Sheet U.S. District Court
Place of Offense: Under Seal: Yes X No O Judge Assigned:
City: EDVA Previous Charging Document: Criminal Number:
County/Parish: NN Same Defendant: New Defendant: No
Arraignment Date:
Magistrate Judge Case Number:
a To be set after indictment is
Search Warrant Case Number:
unsealed
R 20/R 40 from District of
Defendant Information:
Juvenile: Yes No FBI#
Defendant Name: Carlton Upton, Jr | Alias Name(s):
Address: Chesapeake, VA
Birth Date: 06-1972 iSS#: 0497 ISex: M Race: Blk |Nationality: US Place of Birth: US
Height: |Weight: Hair: Eyes: \Scars/Tattoos:
Interpreter: Yes] No List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date: |
CJ Already in Federal Custody as of: in:
C Already in State Custody XX] On Pretrial Release Not in Custody
OC Arrest Warrant Requested C1 Fugitive C) Summons Requested
C Arrest Warrant Pending (1) Detention Sought . O) Bond
Defense Counsel Information:
Name: Andrew Grinrod 0 Court Appointed
Address: 500 East Main St,
Suite 500, Norfolk, VA 23510 & Public Defender
Telephone: 757-457-0860 (CO Office of Federal Public Defender should not be appointed due to conflict of interest
Oo CIA attorney/s ; should not be appointed due to conflict of
Email: interest
C No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set 1 18 USC 1962 Racketeering Conspiracy 1 felony
Set 2 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 3 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 4 18 USC 1343, 1346, 1349 Conspiracy Honest Services Fraud | 4 felony
Set 5 21 USC 856 Maintain Drug Premise 6 felony
Set 6 18 USC 1343 Wire Fraud 8 felony
Set 7
Case 4:26-cr-00075-JKW-RJK DOCUM BRA CTEDE 10/14/26 Page 1 of 1 PagelD# 137
JS 45 (11/2002)
Criminal Case Cover Sheet U.S. District Court
Place of Offense: Under Seal: Yes No (1) Judge Assigned:
City: EDVA Previous Charging: Document: Criminal Number:
County/Parish: NN Same Defendant: New Defendant:
Magistrate Judge Case Number: Arraignment Date:
Search Warrant Case Number:
R 20/R 40 from District of
Defendant Information:
Juvenile: Yes] No FBI#
Defendant Name: Tameka Johnson | Alias Name(s):
Address:
Birth Date: 1982 Iss#: 3414 |Sex: F Race: Bik | Nationality: US Place of Birth: US
Height: [Weight: Hair: Eyes: |Scars/Tattoos:
Interpreter: Yes] No Xl |List Language and/or dialect:
Location Status: (Check one item in each column below)
Arrest Date: |
C Already in Federal Custody as of: in:
OC Already in State Custody C1) On Pretrial Release C1) Not in Custody
Arrest Warrant Requested C) Fugitive C1) Summons Requested
OO Arrest Warrant Pending C) Detention Sought CL) Bond
Defense Counsel Information:
| Name: C) Court Appointed
Address
O Public Defender
Telephone: C1 Office of Federal Public Defender should not be appointed due to conflict of interest
C1 CIA attorney/s should not be appointed due to conflict of
Email: interest
C1 No Conflicts Andrew Bossie
U.S. Attorney Information:
(S)AUSA: Eric M, Hurt/Brian J. Samuels Telephone No. 757-591-4000 Bar #: 35765
Complainant Agency, Address & Phone Number or Person & Title:
| | 7]
U.S.C. Citations:
Code/Section Description of Offense Charged Count(s) | Capital/Felony/Misd/Petty
Set I 21 USC 846 Conspiracy to Dist. Marijuana 2 felony
Set 2 18 USC 1956 Conspiracy to Launder Money 3 felony
Set 3 21 USC 856 Maintain Drug Involved Location 6 felony
Set 4
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