Case 4:17-cr-00298-BSM Document 28 Filed 02/06/18 Page 1 of 5
FILED
U.S. DISTRICT COURT
EASTERN DISTRICT ARKANSAS
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS JAMES W. McCOR
By: _ _ _ _~~~~,.,.,.
UNITED STATES OF AMERICA )
) No. 4: 17CR00298 BSM
)
v. ) 21 U.S.C. § 841(a)(l), (b)(l) (B), (C), 846
) 18 U.S.C. § 922(g)(l)
)
ROBERT CARROLL TURPIN, III )
ZACHARY CHARLES JORDAN )
SERGIO ANDRES GONZALES )
ABRAHAM MARTIN RAMIREZ-GARCIA )
FELIPE DE JESUS HEREDIA-VELOZ )
ERIC DESHAWN FEARS )
ZACHARY ROBERT SMITH )
BROOKS HAYDEN JONES )
DONOVAN SHERARD WHITTINGTON )
BYRON DAVIS WARRINGTON )
ROGER STEVE ARRUE )
DUSTIN WAYNE McCARTY )
ANTONIO SANCHEZ FUENTES )
DEMETRIC ISSAC WILLIAMS )
LATOYAD. CARBAGE )
LISA ANN WELTON )
TRACIE LYNN BROWN and )
WILLIAM DAVID ALLEN )
SUPERSEDING INDICTMENT
THE GRAND JURY CHARGES THAT:
COUNT 1
Beginning in or about November 2015, and continuing through on or about February 6,
2018, in the Eastern District of Arkansas and elsewhere,
ROBERT CARROLL TURPIN, III
ZACHARY CHARLES JORDAN
SERGIO ANDRES GONZALES
ABRAHAM MARTIN RAMIREZ-GARCIA
FELIPE DE JESUS HEREDIA-VELOZ
ERIC DESHAWN FEARS
1
Case 4:17-cr-00298-BSM Document 28 Filed 02/06/18 Page 2 of 5
ZACHARY ROBERT SMITH
BROOKS HAYDEN JONES
DONOVAN SHERARD WHITTINGTON
BYRON DAVIS WARRINGTON
ROGER STEVE ARRUE
DUSTIN WAYNE McCARTY
ANTONIO SANCHEZ FUENTES
DEMETRIC ISSAC WILLIAMS
LATOYAD. CARBAGE
LISA ANN WELTON
TRACIE LYNN BROWN and
WILLIAM DAVID ALLEN
knowingly and intentionally conspired with each other and other persons known and unknown to
the grand jury to knowingly and intentionally possess with intent to distribute and to distribute
Schedule I, II and IV controlled substances, to wit: mixtures or substances containing a
detectable amount of marijuana, heroin, methamphetamine, cocaine, oxycodone, hydrocodone
and alprazolam, in violation of Title 21, United States Code, section 841(a)(l), (b)(l)(B) and (C).
1. With respect to defendants TURPIN, JORDAN, RAMIREZ-GARCIA, HEREDIA-
VELOZ, GONZALES, JONES, WARRINGTON, McCARTY, BROWN, and ALLEN,
the amount of methamphetamine involved in the conspiracy attributable to each of them
as a result of his own conduct, and the conduct of other co-conspirators reasonably
foreseeable to him, is at least 50 grams but less than 500 grams of a mixture or substance
containing a detectable amount of methamphetamine, in violation of Title 21, United
States Code, section 84l(b)(l)(B).
2. With respect to defendants TURPIN, JORDAN, and HEREDIA-VELOZ, the amount of
cocaine hydrochloride involved in the conspiracy attributable to each of them as a result
of his own conduct, and the conduct of other co-conspirators reasonably foreseeable to
him, is at least 500 grams, but less than 5 kilograms of a mixture or substance containing
2
I'
Case 4:17-cr-00298-BSM Document 28 Filed 02/06/18 Page 3 of 5
a detectable amount of cocaine hydrochloride, in violation of Title 21, United States
Code, section 84l(b)(l)(B).
All in violation of Title 21, United States Code, section 846.
COUNT2
On or about September 28, 2016, in the Eastern District of Arkansas, the defendant,
ZACHARY ROBERT SMITH
knowingly and intentionally possessed with intent to distribute and distributed a mixture or
substance containing heroin, a Schedule I controlled substance, in violation of Title 21, United
States Code, Section 841(a)(l) and (b)(l)(C).
COUNT3
On or about June 16, 2017, in the Eastern District of Arkansas, the defendant,
ROBERT CARROLL TURPIN, III
knowingly and intentionally possessed with intent to distribute and distributed at least 5 grams,
but less than 50 grams of methamphetamine (actual), a Schedule II controlled substance, in
violation of Title 21, United States Code, Section 841(a)(l) and (b)(l)(B).
COUNT4
On or about August 12, 2017, in the Eastern District of Arkansas, the defendant,
DEMETRICK ISSAC WILLIAMS
in furtherance of a drug trafficking crime for which he can be prosecuted in a court of the United
States, to wit, conspiracy to possess with intent to distribute and distribute controlled substances
as charged in Count 1 of this Superseding Indictment, knowingly possessed a firearm in violation
of Title 18, United States Code, Section 924(c)(l)(A)(i).
3
Case 4:17-cr-00298-BSM Document 28 Filed 02/06/18 Page 4 of 5
COUNTS
On or about September 13, 201 7, in the Eastern District of Arkansas, the defendant,
ROBERT CARROLL TURPIN, III
knowingly and intentionally possessed with intent to distribute a mixture or substance containing
methamphetamine and a mixture or substance containing cocaine hydrochloride, Schedule II
controlled substances, in violation of Title 21, United States Code, Section 841(a)(l) and
(b)(l)(C).
COUNT6
A. Prior to September 13, 2017, the defendant, ROBERT CARROLL TURPIN, III,
had been convicted of one or more of the following offenses: Possession of a Counterfeit
Substance; 203rd District Court Dallas, TX, case number F-0416088, June 8, 2005; Fraudulent
Use of a Credit Card, Arkansas County District Court, case number 2006-182, June 6, 2007; and
B. The crimes set forth in paragraph A above were punishable by a term of
imprisonment exceeding one year.
C. On or about September 13, 2017, in the Eastern District of Arkansas,
ROBERT CARROLL TURPIN, III
did knowingly possess one or more of the following in and affecting commerce, to wit: one
Ruger AR556 assault rifle, SN#850-94242; one Braztech L.C. 410 Shotgun, SN#SP561566; one
Norinco semi-automatic rifle, SN#l 725913; one Glock 43 semi-automatic pistol, SN#ZSM486;
and assorted ammunition located at 11718 Ashwood Drive, Little Rock, Arkansas, in violation of
Title 18, United States Code, Section 922(g)(l).
4
Case 4:17-cr-00298-BSM Document 28 Filed 02/06/18 Page 5 of 5
FORFEITURE ALLEGATION 1
Upon conviction of the offenses alleged in Count 1 and 5 of this Superseding Indictment,
ROBERT CARROLL TURPIN, III shall forfeit to the United States, under 18 U.S.C. § 924(d), 21
U.S.C. § 853, and 28 U.S.C. § 2461(c), all property used, or intended to be used, in any manner or
part, to commit, or to facilitate the commission of the offense, including, but not limited to, the
following: one Ruger AR556 assault rifle, SN#850-94242; one Braztech L.C. 410 Shotgun,
SN#SP561566; one Norinco semi-automatic rifle, SN#l 725913; one Glock 43 semi-automatic
pistol, SN#ZSM486; and all ammunition and any other firearms and firearm components located
at 11718 Ashwood Drive, Little Rock, Arkansas on September 13, 2017.
FORFEITURE ALLEGATION 2
Upon conviction of the offense alleged in Count 6 of this Superseding Indictment,
ROBERT CARROLL TURPIN, III shall forfeit to the United States, under 18 U.S.C. § 924(d), 21
U.S.C. § 853, and 28 U.S.C. §2461(c), all firearms and ammunition involved in the commission of
the offense, including, but not limited to, the following: one Ruger AR556 assault rifle, SN#850-
94242; one Braztech L.C. 410 Shotgun, SN#SP561566; one Norinco semi-automatic rifle,
SN#l 725913; one Glock 43 semi-automatic pistol, SN#ZSM486; and all ammunition and any
other firearms and firearm components located at 11718 Ashwood Drive, Little Rock, Arkansas
on September 13, 2017.
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