Case 4:17-cr-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 1 of 14 IN THE UNITED STATES DISTRICT COURT POR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION UNITED STATES OF AMERICA crno: H:lTcr(0b vs, BARBARA LANDY, a/lda “E-5,” a/W/a “Fizzy” JOSHUA LEE RANDALL, a/W/a “Rude Boy,” FRANK WILLIAM TRUITT, a/k/a “Fatz,” ADRIAN JERELL LANE, a/k/a “Ace,” SYDNEY DEVIN MCDOUGALL, JERRICK LAROD THOMAS, a/k/a “Juice,” CHELSEY NICOLE INMAN, DEREK BELLAMY, a/k/a “Bloody D,” TIMOTHY SINGLETARY, ALEXIS KIRT, MATTHEW DeWITT, STACY CAMBAS, ANDREW PERRY, ) d ) ) ) d d d ) ) ) ) ) ) ) ) ) ) ) ) » ) ) ) ) » > d ) » d D1 USC. § 841@)(1) 21 USC. § 841 (01)(C) 21 U.S.C. § 841O\(1)D) 21 U.S.C. § 846 21 USC. § 8430) 18 USC. § 922(@\(1) 18 U.S.C. § 924(2)(2) 18 USC. § 924(e) 18 USC. § 924(6)(1)(A) 18 US.C. § 924@) 18 US.C. § 924) 18 USC. §2 21 USC. § 853, 21 USC. § 881 28 US.C. § 2461(0) SEALED INDICTMENT USCA 30Case 4:17-c'-00108-CRI SEALED" Document 3*SEALED* Filed 02/15/17 Page 2of14 ‘THE GRAND JURY CH IARGES: Backeround ute ‘At all times relevant to this indictment, numerous Defendants tamed in this indictment, BARBARA LANDY, a/k/a “£-5,” a/k/a “Fizzy,” JOSHUA LEE RANDALL, afkia “Rude Boy,” FRANK, WILLIAM TRUITT, a/k/a “Fatz,” ADRIAN JERELL LANE, a/k/a “Ace,” DEREK BELLAMY, a/k/a “Bloody D,” TIMOTHY SINGLETARY, and were members of the Billie East Side Bloods set (“Billies"} of the United Blood Nation CUBN"), a national criminal organization, or gang, that generates revenue by selling illegal narcotics and by engaging in other criminal activities. ‘The Billies operate primarily in the eastern portion of the District of South Carolina, including the Florence and Myrtle Beach areas. 2. Members of the Billies carry, use, possess, and sell firearms to ficilitate their drug trafficking enterprise. Firearms allow Billies members to not only protect illegal drugs they possess for the purpose of distribution and money Billies members make from the distribution, but they also allow Billios mezabers to protect geographic areas they inhabit from intrusion from rival gangs or other drug trafficking organizations (DTOs”) who seek to compete with the Billies for drug sales, 3 In addition to using firearms to injure or kill members of rival gangs or DTOs, members of the Billies also use firearms to generate more revenue they can use to purchase more illegal drugs for distribution, For exaraple, Billies members often sell firearms and use the proceeds from these sales to purchase more illegal drugs that members can distribute. Billies USCA 31Case 4:17-cF-00108-CRI *SEALED* Document 3 *SEALED* Filed 02/15/17 Page 3 of 14 smembers also commit robberies and use proceeds from these robberies to purchase more illegal drugs that members can distribute. COUNT (Drug Trafficking Conspiracy) “The Grand Jury re-alloges and incorporates by reference Paragraphs 1 through 3, as if fully set fosth herein. “That beginning at a time unknowm to the grand jury, but beginning at least in or around 2012, and continuing thereafter, up to and including the date of this Indictment, in the District of South Caroline and elsewhere, the Defendants, BARBARA LANDY, a/k/a “R-5," | alla “Bizzy” JOSHUA LEE RANDALL, alla “Rude Boy,” FRANK WILLIAM TRUITT, a//a “Patz,” ADRIAN JERELL LANE, a/k/a “Ace,” SYDNEY DEVIN MCDOUGALL, \ JERRICK LAROD THOMAS, a/k/a “Suice;” CHELSEY NICOLE INMAN, DEREK BELLAMY, a/k/a “Bloody D,” TIMOTHY SINGLETARY, ALEXIS KIRT, MATTHEW DeWITT, STACY CAMBAS, ANDREW PERRY and Imowingly and intentionally did combine, conspire, agree and have tacit understending with each other and with others, both known and unknown to the grend jury, to knowingly, intentionally and unlawfully possess with intent to distribute and distribute heroin and marijuana, both Schedule I controlled substances, and cocaine and fentanyl, both Schedule Tl controlled substances, and; USCA4 32Case 4:17-c1-00108-CRI *SEALED" Document 3*SEALED* Filed 02/15/17 Page 4 of 14 With respoot to the Defendants listed below, the amourt involved inthe conspiracy attributable 10 each Defendant as a result of his or her own conduct, and the conduct of other conspirators reasonably foreseeable to the Defendant, is: DEFENDANT ‘CONTROLLED PENALTY SUBSTANCE BARBARA LANDY, aquantity ofheroin | §§ 841(6)(1)(O) and and a quantity of HOO) marijuana | JOSHUA LEE RANDALL "a quantity of heroin, a | §§ 841(b)(1)(C) and quantity ofmarijuana, | (6\(1)(D) and a quastity of fentanyl ‘a quantity of heroin, a | §§ 841(6)(1)(C) and quantity of marijuana, | (b\(1)(D) and a quantity of cocaine FRANK WILLIAM TRUITT ]aquantity ofheroin | § 841(6)(1)(C) "ADRIAN JERELL LANE aquantity ofheroin | §§ 841@)N(C) and and a quantity of (yD) marijuana SYDNEY DEVIN MCDOUGALL | a ‘quantity of heroin §§ 841(6)(1)(C) and | and a quantity of Uy) marijuana ‘aquantity ofheroin | §§ 841(b)(1)(C) and and a quantity of XD) marijuana | JERRICK LAROD THOMAS | a quantity ofheroin, a | §§ 841@)(1KC) and quantity of marijuana, | (b)(1)(D) a quantity of cocaine, and a quantity of fentanyl ‘aquantity ofheroin | § 841(6\1)(C) ‘CHELSEY NICOLE INMAN ‘aquantity ofheroin | § 841(E)\(I)(C) and a quantity of fentanyl DEREK BELLAMY ‘quantity ofheroin | § 841(6)(1)(C) USCA4 33Case 4:17-cr-00108-CRI*SEALED* Document 3*SEALED* Filed 02/16/17 Page 5 of 14 TIMOTHY SINGLETARY a quantity ofheroin | § 84106)(1(C) ALEXIS KIRT aqumtty ofheroin | SFUOHOO ‘a quantity ofcocaine | §§ 841(b)(I)(O) and anda quantity of (YI) marijuana aquantity ofheroin | § 841(E XTC) MATTHEW DeWITT a quantity ofheroin | § 841XINKO) STACY CAMBAS SsA1ODC) ‘@ quantity of heroin S841) | ANDREW PERRY ‘aquantity ofheroin | § 841(b)(1XO) ‘a quantity ofheroin | § 841(6)(1)(C) Allin violation of Title 21, United States Code, Sections 841(a)(L) and 846. COUNT 2 (Conspiracy to Use, Carry, and Possess Firearms in Furtherance of a Drug Trafficking Crime) ‘THE GRAND JURY FURTHER CHARGES: ‘The Grand Jury re-alleges and incorporates by reference Paragraphs | through 3, as fully set forth herein. ‘That beginning at a time unknown to the grand jury, but beginning at Jeast in or around 2012, and continuing thereafter, up to and including the date of this Indictment, in the District of South Carolina and elsewhere, the Defendants, BARBARA LANDY, a/k/a “E-5,” Mie “Picy,”" JOSHUA LEE RANDALL, a/kia “Rude Boy,” 5 USCA4 34Case 4:17-c1-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 6 of 14 JRANK WILLIAM TRUITT, a/k/a “Ratz,” CHELSEY NICOLE INMAN, TIMOTHY SINGLETARY, did knowingly and unlawfully combine, conspire, confederate and agree together and have tacit understanding with each other, to keowingly use and carry a firearm during and in relation to, and to possess firearms in furtherance of drug trafficking crimes which are prosecutable in a court of the United States, to wit: conspiracy to possess with the intent o distribute, possession with the intent fo distribute, and distribution of heroin and marijuana, both Schedule I controlled substances, and cocaine and fentanyl, both Schedule IL controlled substances, in violation of Title 21, United States Code, Sections 841(a)(1) and 846; Inviolation of Title 18, United States Code, Section 924(0). COUNT 3 ‘THE GRAND JURY. FURTHER CHARGES: ‘That on or ebout December 4, 2016, in the District of South Carolina, the Defendant, knowingly, intentionally and unl fully did possess with intent to distribute a quantity of cocaine, a Schedule I] controlled substance, and a quantity of marijuana, a Schedule I controlled substance; In violation of Title 21, United States Code, Sections 841(a)(1), 841(b)(1(C), and 8416)(0). USCA4 35,Case 4:17-c1-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 7 of 14 COUNTS ‘THE GRAND JURY FURTHER CHARGES: ‘That on or about December 16, 2016, in the District of South Carolina, the Defendants, JOSHUA LEE RANDALL a/kla “Rude Boy,” end CHELSEY NICOLE. INMAN, knowingly, intentionally and unlawfully did possess with intent to distribute a quantity ofheroin, a Schedule I controlled substance, and fentany}, a Schedule II controlled substance, and did aid and abet each other in the commission of the aforesaid offense; In violation of Title 21, United States Code, Sections 841(a)(1) and 841(0)(1)(), and Title 18, United States Code, Section 2 COUNTS ‘THE GRAND JURY FURTHER CHARGES: ‘That on or about December 16, 2016, in the District of South Carolina, the Defendants, JOSHUA LEE RANDALL a/k/a “Rude Boy,” and CHELSEY NICOLE INMAN, knowingly did possess a firearm in furtherance of a drug trafficking crime which is prosecutable in a court of the United States, and did aid and abet each other in the commission of the aforesaid offense; In violation of Title 18, United States Code, Sections 924(¢)(1)(A) and 2. USCA4 36Case 4:17-cr-00108-CRI*SEALED* Document 3*SEALED* Filed 02/16/17 Page 8 of 14 COUNT § ‘THE GRAND JURY FURTHER CHARGES: ‘That on or about December 16, 2016, im the District of South Carolina, the Defendant, JOSHUA LEE RANDALL a/k/a “Rude Boy,” heving been convicted of a crime punishable by imprisonment fora term exceeding one year, knowingly did possess in and affecting commerce, @ firearm and ammunition, thet is a Taurus 380 caliber pistol, 380 caliber ammunition, and 7.62 caliber ammunition, all of which had been shipped and transported in interstate commerce; In violation of Title 18, United Stetes Code, Sections 922(g)(1), 924(8)(2) and 924(). COUNT? ‘THE GRAND JURY FURTHER CHARGES: That on or sbout January 24, 2017, in the District of South Carolina, the Defendant, saving been convicted of a crime punishable by imprisonment for e term exceeding one year, knowingly did possess in and affecting ‘commerce, firearms and ammunition, that is a Teurus 9 millimeter pistol, a Smith & Wesson 9 millimeter pistol, a Browning 9 millimeter pistol, a Rohn .22 caliber revolver, an Jiminez, Arms 380 caliber pistol, a Titan.25 caliber pistol Jiminez 9 millimeter pistol, 380 caliber ammunition, (32 caliber ammunition, and 9 millimeter ammunition, all of which had been shipped and transported in interstate commerce; In violation of Title 18, United States Code, Sections 922(g)(1), 924(@)(2) and 924(2). USCA4 37Case 4:17-c'-00108-CRI*SEALED* Document 3*SEALED* Filed 02/15/17 Page 9 of 14 The Grand Jury re-alleges and incorporates by reference Paragraphs 1 COUNTS 8-33 “THE GRAND JURY FURTHER CHARGES: through 3, as if fully set forth herein. ‘That on or about the dates set forth below, in the District of South Carolina, the Defendants knowingly and intentionally did use a communication facility, to wit: 8 telephone, to facilitate the commission of a felony under the Controlled Substances Act, to wit: conspiracy to possess with intent +o distribute and possession with intent to distribute and distribution of heroin and marijuana, both Schedule I controlled substances, and cocaine and fentanyl, both Schedule IT controlled substances, and did aid and abet each other in the commission of the aforesaid offense, in violation of Title 21, United States Code, Sections 841(a)(1) and 846; COUNT DATE DEFENDANT je 3 December 9, 2016 | i 9 December 9,2016 | JOSHUA LEE RANDALL SYDNEY DEVIN MCDOUGALL 10 December 9, 2016 TIMOTHY SINGLETARY i | December 9, 2016 ANDREW PERRY 2 December 9, 2016 | JOSHUA LEE RANDALL MATTHEW DeWITT USCA4 38Case 4:17-01-00108-CRI*SEALED" Document 3 *SEALED* Filed 02/15/17 Page 10 of 14 ie B [December 10,2016 Seana I 4 December 10,2016 | STACY CAMBAS et | ie 5 December 11,2016 [BARBARA LANDY | JOSHUA LEE RANDALL | 16 December 12, 2016 FRANK WILLIAM TRUITT Hee 7 December 13,2016 | CHELSEY NICOLE INMAN, STACY CAMBAS 18 December 13, 2016 ies 19 December 15,2016 | BARBARA LANDY JOSHUA LEE RANDALL — 20 December 16, 2016 | a ‘December 19,2016 | JOSHUA LEE RANDALL 2 ‘December 19,2016 | JOSHUA LEE RANDALL | 1 B December 22, 2016 TIMOTHY SINGLETARY 24 December 22, 2016 Bee USCA4 39Case 4:47-c1-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 11 of 14 3 December 26,2016 | JOSHUA LEE RANDALL JERRICK LAROD THOMAS 26 December 26, 2016 | JOSHUA LEE RANDALL B ‘December 29, 2016 | TIMOTHY SINGLETARY ia 2 December 51,2016 | BARBARA LANDY DEREK BELLAMY | 30 ‘[Jannary 2, 2077 BARBARA LANDY DEREK BELLAMY 31 Tanuary 3, 2017 BARBARA LANDY | 32 | January 6, 2017 JOSHUA LEE RANDALL ADRIAN JERELL LANE 3 Tanuary 7, 2017 BARBARA LANDY DEREK BELLAMY ah January 8, 2017 BARBARA LANDY 35 Tanaary 17,2017 ALEXIS KIRT USCA4 40Case 4:17-cr-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 12 of 14 [Allin violation of Title 21, United States Code, Section 843(b), and Title 18, United States Code, Section 2. 12 USCA 41Case 4:17-cr-00108-CRI *SEALED* Document 3*SEALED* Filed 02/15/17 Page 13 of 14 FORFEITURE REARM/DRUG OFFENSE: ‘Upon conviction for felony violations of Title 18 and 21, United States Code as charged in this Indictment, the Defendants, BARBARA LANDY, a/k/a “E-5,” a/k/a “Fizzy,” JOSHUA LEE RANDALL, a/k/a “Rude Boy,” FRANK WILLIAM TRUITT, a/k/a “Fatz,” ADRIAN JERELL LANE, wh/a “Ace,” SYDNEY DEVIN MCDOUGALL » JERRICK LAROD THOMAS, a/k/a “Juice;” CHELSEY NICOLE INMAN, DEREK BELLAMY, a/k/a “Bloody D,” ‘TIMOTHY SINGLETARY, ALEXIS KIRT, MATTHEW DeWITT, STACY CAMBAS, ANDREW PERRY and shall forfeit to the United States all of the Defendants’ right, title and interest in ‘and to any property, real and personal, (@ constituting, or derived from any proceeds the Defendant obtained, directly or indirectly, as the result of such violation(s) of Title 21, United States Code, and all property traceable to such property; (©) used or intended to be used, in any manner or part, to commit or to facilitate the commission of such violations of Title 21, United States Code; (©) any firearms and ammunition (as defined in 18 U.S.C. § 921)— (1) used or intended to be used to facilitate the transportation, sale, receipt, possession or concealment of controlled substances or any proceeds traceable to such property; (2) involved in or used in any knowing violations of 18 U.S.C. §§922 and 924, or violation of any other eriminal law of the United States, or imended to be used B USCA 42Case 4:17-cr-00108-CRI*SEALED* Document 3 *SEALED* Filed 02/15/17 Page 14 of 14 SUBSTITUTION OF ASSETS: Ifany forfeited property being subject to forfeiture, es a result of any act or omission of the Defendants: @ &) ©). @ © ‘cannot be located upon the exercise of due diligence; has been transferred or Sold to, or deposited with, a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or hes been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) to seek forfeiture of any other property of Defendants up to an amount equivalent to the value of the forfeitable property; Pursuant to Title 18, United States Code, 924(d), Title 21, United Stetes Code, Sections 853 and 881, and Title 28, United States Code, Section 2461(c). eee Bill FOREPERSON 7 4 USCA4 43