Indictment — United States v. Chuny Ann Reed, No. 4:22CR090 AGF/SRW (Dkt. 19, E.D. Mo.)
Summary
A two-count federal indictment filed February 16, 2022 in the U.S. District Court for the Eastern District of Missouri in United States v. Chuny Ann Reed, 4:22CR090 AGF/SRW. Count I charges that on or about February 5, 2022, in the City of St. Louis, Reed knowingly distributed a mixture containing cocaine base and fentanyl, Schedule II controlled substances, and that serious bodily injury to M.T. resulted from its use. Count II charges distribution of cocaine base and fentanyl on the same date under Title 21, United States Code, Section 841. A forfeiture allegation seeks proceeds of the offenses and property used to commit them, or substitute property. The indictment is marked as a true bill and carries the names of U.S. Attorney Sayler A. Fleming and three Assistant U.S. Attorneys.
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Full text
FILED
UNITED STATES DISTRICT COURT FEB 16 2022
EASTERN DISTRICT OF MISSOURI U. S. DISTRICT COURT
EASTERN DIVISION EASTERN DISTRICT OF MO
ST.LOUIS
UNITED STATES OF AMERICA, )
)
Plaintiff,
/
)
)
v. )
) 4:22CR090 AGF/SRW
CHUNY ANN REED, )
)
Defendants. )
)
INDICTMENT
COUNTI
The Grand Jury charges that:
On or about February 5, 2022, in the City of St. Louis, Missouri, within the Eastern District
of Missouri,
CHUNY ANN REED,
the defendant herein, did knowingly and intentionally distribute a mixture or substance containing
a detectable .amount of cocaine base and fentany 1, Schedule II controlled substances,
In violation of Title 21, United States Code, Section 841(a)(1), and
That the serious bodily injury ofM.T., a person whose identity is known to the Grand Jury,
resulted from the use of such fentanyl and cocaine base so distributed by the defendant, thereby
making the offenst; punishable under Title 21, United States Code, Section 841(b)(1)(C).
COUNT II
The Grand Jury further charges that:
On or about February 5, 2022, in the City of St. Louis, Missouri, within the Eastern District
of Missouri,
CHUNY ANN REED,
the defendant herein, did knowingly and intentionally distribute a mixture or substance containing
a detectable amount of cocaine base and fentanyl, Schedule II controlled substances,
In violation of Title 21, United States Code, Section 841(a)(1).
FORFEITURE ALLEGATION
The Grand Jury further finds by probable cause that:
1. Pursuant to Title 21, United States Code, Sections 853(a), upon conviction of an
offense in violation of Title 21, United States Code, Section 841(a)(1), as set forth in Counts I
and II, the defendant shall forfeit to the United States of America any property, constituting, or
derived from, any proceeds obtained, directly or indirectly, as the result of such violation, and
any property used, or intended to be used, in any manner or part, to commit, or to facilitate the
commission of such violation.
2. Subject to forfeiture is a sum of money equal to the total value of any property,
constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of the
violations set forth in Counts I and II.
3. • If any of the property described above, as a result of any act or omission of the
defendants:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
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c. has b~en 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 of America will be entitled to the forfeiture of substitute property pursuant to
Title 21, United States Code, Section 853(p).
A TRUE BILL.
FOREPERSON
SAYLER A. FLEMING
United States Attorney
ERIN GRANGER, #53593MO
JAMES C. DEL WORTH, #29702MO
NATHAN CHAPMAN, #60978MO
Assistant United States Attorneys
111 South 10th Street, Room 20.333
St. Louis, MO 63102
(314) 539-2200
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