Case 3:23-cr-00056-VAB Document 80 Filed 08/02/23 Page 1 of 15

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

Grand Jury B-22-1

UNITED STATES OF AMERICA CRIMINAL NO. 3:23CR56 (VAB)

v. VIOLATIONS:

JAEDYN RIVERA, a.k.a. "Jae Honcho" 18 U.S.C. §§ 1962(d) and 1963(a)

TY.TON PRESTON, a.k.a. "TJ'' (Racketeering Conspiracy)
SAMUEL DOUGLAS, a.k.a. "Blamm"
QUA YMAR SUGGS 18 U.S.C. §§ 1959(a)(3), 1959(a)(5), and
KIVEON HYMAN, a.k.a. "Tiny" 1959(a)(6) (VCAR Assault with a
DONELL ALLICK, JR., a.k.a. "D-Nice" Dangerous Weapon, VCAR Attempted
DEVIN SUGGS, a.k.a. "JB" Assault with a Dangerous Weapon, and
NYZAIRE BARNES, a.k.a. "Melo" VCAR Attempted Murder)
ANTWAN HILL, a.k.a. "Bandz"
21 U.S.C. §§ 841(a)(l), 84l(b)(l)(B)(vi),
841(b)(l)(C), and 846 (Conspiracy to
Distribute and to Possess with Intent to
Distribute Fentanyl and Cocaine)

18 U.S.C. §§ 922(g)(l) and 924(a)(2)

(Unlawful Possession of a Firearm by a
Felon)

18 U.S.C. § 2 (Aiding and Abetting)

SUPERSEDING INDICTMENT

The Grand Jury charges:

COUNT ONE
(Racketeering Conspiracy)

The Enterprise

1. At all times relevant to this Superseding Indictment, the defendants JAEDYN

RIVERA, a.k.a. "Jae Honcho"; TY.TON PRESTON, a.k.a. "TJ"; SAMUEL DOUGLAS,

a.k.a. "Blamm"; QUA YMAR SUGGS; KIVEON HYMAN, a.k.a. "Tiny"; DONELL

ALLICK, JR., a.k.a. "D-Nice"; DEVIN SUGGS, a.k.a. "JB"; NYZAIRE BARNES, a.k.a.

"Melo"; ANTWAN HILL, a.k.a. "Bandz," and others known and unknown to the Grand

Jury, were members and associates of the New Haven street gang, the "Exit 8" gang, a
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criminal organization whose members and associates engaged in, among other activities,

narcotics distribution and acts of violence, including murders and assaults.

2. The Exit 8 gang began as a street gang based in the geographic area accessed

by exiting Interstate 91 at Exit 8 in New Haven, but it currently has members and associates

who either are incarcerated or living throughout the City of New Haven and surrounding

towns. There is a younger sect of the Exit 8 gang, which refers to itself specifically as the

"Honcho Gang." Exit 8 members and associates often communicate through various forms

of electronic communication, including Facebook messenger, Snapchat, Instagram, phone

calls, text messages, and music videos posted online. At times, members and associates use

gang symbols and code words to communicate in order to avoid revealing their criminal

activity.

3. Members and associates of the Exit 8 gang are expected to protect the name,

reputation, and status of the gang from rival gang members and other persons. To protect the

gang and enhance its reputation, members and associates are expected to use any means

necessary to force respect from those who have shown disrespect, including committing acts

of intimidation, threats of violence, and acts of violence.

4. At all times relevant to this Indictment, the Exit 8 gang, including its leaders,

members, and associates, constituted an enterprise as defined in Title 18, United States Code,

Section 1961 (4) (hereinafter "the Enterprise"), that is, a group of individuals associated in

fact that engaged in, and the activities of which affected, interstate and foreign commerce.

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.

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5. The Exit 8 gang has long-standing issues with other neighborhood gangs

within the City of New Haven, specifically gang members from within the "Hill" (the

southwestern-most neighborhood of New Haven) and the area of New Haven known as the

"G" (an area based around Farnam Courts, a former housing complex in the Fair Haven

section of New Haven), as well as with other neighborhood gangs. Violence between these

groups is retaliatory in nature, and members of Exit 8 are believed to be responsible for a

number of non-fatal and fatal shootings in the Hill section and other areas of New Haven.

6. The Exit 8 gang had multiple criminal objectives, one of which was

enrichment of the members and associates of the organization through the distribution of

controlled substances, including fentanyl, heroin, cocaine base ("crack"), marijuana, and

Percocet pills. Exit 8 gang members and associates engaged in narcotics trafficking together.

They shared customers and referred each other to customers. Often, drug related activity was

coordinated and facilitated by text messaging and Facebook messenger.

7. Members and associates of the Exit 8 gang committed, conspired, attempted,

and threatened to commit acts of violence to protect the Enterprise and to protect fellow

members and associates of the Exit 8 gang as well as the reputation of deceased members.

These acts of violence included acts of murder and assault intended to protect the Exit 8

gang fi:om rival gangs and to otherwise promote the standing and reputation of the Enterprise

amongst rival gangs as well as amongst other Exit 8 gang members.

Purposes of the Exit 8 Gang

8. The purposes of the Enterprise included the following:

a. Enriching the members and associates of the Enterprise through, among other

things, the distribution and sale of controlled substances.

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b. Preserving and protecting the power, territory, reputation, and profits of the

Enterprise through the use of intimidation, violence, threats of violence, and acts of violence,

including acts involving murder and assault.

c. Promoting and enhancing the Enterprise and the activities and authority of its

members and associates.

d. Keeping victims and potential victims, witnesses, and rival gang members in

fear of the Enterprise and in fear of its members and associates through threats of violence

and acts of violence, including acts involving murder and assault.

e. Providing assistance to members and associates of the Enterprise who

committed crimes for and on behalf of the Enterprise.

f. Providing financial support and information to members and associates of the

Enterprise, including those incarcerated for committing acts of violence, distribution of

controlled substances, and other offenses.

g. Protecting the Enterprise and its members and associates from detection and

prosecution by law enforcement authorities through acts of intimidation and violence against

potential witnesses, including members and associates of the Enterprise, to crimes

committed by members of the Enterprise.

h. Hindering, obstructing, and preventing law enforcement officers from

identifying, apprehending, and successfully prosecuting and punishing members and

associates of the Exit 8 gang.

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Means and Methods of the Exit 8 Gang

9. Among the means and methods employed by the members and associates in

conducting and participating in the conduct of the affairs of the Enterprise were the

following:

a. Members and associates of the Enterprise committed, conspired, attempted,

and threatened to commit acts of violence, including acts involving murder, against rival

gang members and other individuals adverse to the Enterprise.

b. Members and associates of the Enterprise promoted and celebrated the

criminal conduct of the Enterprise, namely narcotics distribution, acts involving violence,

and the use and possession of firearms, on social media applications and websites such as

Facebook, Instagram, Snapchat, and YouTube.

c. Members and associates of the Enterprise obtained, possessed, shared, used,

and disposed of firearms.

d. Members and associates of the Enterprise distributed controlled substances.

e. Members and associates of the Enterprise stole vehicles, at times from outside

of the state, and used those stolen vehicles when committing acts of violence.

The Racketeering Conspiracy

10. From approximately 2018 to the present, in the District of Connecticut and

elsewhere, the defendants JAEDYN RIVERA, a.lea. "Jae Honcho"; TYJON PRESTON,

a.k.a. "TJ"; SAMUEL DOUGLAS, a.k.a. "Blamm"; QUA YMAR SUGGS; KIVEON

HYMAN, a.lea. "Tiny"; DONELL ALLICK, JR., a.k.a. "D-Nice"; DEVIN SUGGS, a.k.a.

"JB"; NYZAIRE BARNES, a.k.a. "Melo"; and ANTWAN HILL, a.k.a. "Bandz," together

with others known and unknown to the Grand Jury, being persons employed by and

associated with the Enterprise described in the preceding paragraphs, namely, the Exit 8

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gang, knowingly combined, conspired, confederated, and agreed with others known and

unknown to the Grand Jury to violate the racketeering law of the United States, namely, 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 Exit 8 gang, which was engaged in, and the

activities of which affected, interstate and foreign commerce, through a pattern of

racketeering activity consisting of:

a. Multiple acts involving murder chargeable under the following provisions of

state law: Connecticut General Statutes §§ 53a-54a (murder); 53a-48

(conspiracy); 53a-49 (attempt); and 53a-8 (aiding and abetting).

b. Multiple acts involving the distribution of controlled substances in violation

of the laws of the United States, namely, Title 21, United States Code,

Sections 841 and 846.

c. Multiple acts indictable under Title 18, United States Code, Section 2312

(relating to interstate transportation of stolen motor vehicles).

d. Multiple acts indictable under Title 18, United States Code, Section 2313

(relating to receipt and possession of stolen motor vehicles).

11. It was a part of the conspiracy that each defendant agreed that a conspirator

would commit at least two acts of racketeering activity in the conduct of the affairs of the

Enterprise.

Overt Acts

12. In furtherance of the conspiracy and to achieve the objects thereof: the

following overt acts, among others, were committed in the District of Connecticut and

elsewhere:

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a. From at least 2018 until 2023, in the District of Connecticut, JAEDYN

RIVERA, a.lea. "Jae Honcho"; TYJON PRESTON, a.k.a. "T.T"; SAMUEL
DOUGLAS, a.k.a. "Blamm"; QUA YMAR SUGGS; KIVEON HYMAN,
a.k.a. "Tiny"; DONELL ALLICK, JR., a.k.a. "D-Nice"; DEVIN SUGGS,
a.k.a. "JB"; ANTWAN HILL, a.lea. "Bandz," and other individuals known
and unknown to the Grand Jury, conspired together to sell narcotics including
fentanyl, heroin, crack, marijuana, oxycodone, and Percocet pills.

b. On or about June 16, 2018, in the District of Connecticut, SAMUEL

DOUGLAS, a.k.a. "Blamm," aml KIVEON HYMAN, a.k.a. "Ti11y ," shot and
attempted to kill, and aided and abetted in the same, a member and associate
of a rival gang, and C.S., whose true name is known to the Grand Jury, was
shot.

c. On or about January 24, 2019, in the District of Connecticut, members and

associates of the Exit 8 gang shot and attempted to kill M.L., a member and
associate of a rival gang, whose true name is known to the Grand Jury.

d. On or about July 14, 2020, in the District of Connecticut, TY JON PRESTON,

a.lea. "T.T," and others known and unknown to the Grand Jury, shot and
attempted to kill, and aided and abetted in the same, S.S., a member and
associate of a rival gang, whose true name is known to the Grand Jury.

e. On or about September 26, 2020, in the District of Connecticut, ANTWAN

HILL, a.k.a. "Bandz," TYJON PRESTON, a.k.a. "T.T," and others known and
unknown to the Grand Jury, shot at and attempted to kill, and aided and
abetted in the same, K.R., a member and associate of a rival gang, whose true
name is known to the Grand Jury.

f. On or about April 27, 2021, in the District of Connecticut, TYJON

PRESTON, a.k.a. "TJ," DEVIN SUGGS, a.k.a. "JB," and others known and
unknown to the Grand Jury, shot and attempted to kill, and aided and abetted
in the same, R.S., whose true name is known to the Grand Jury.

g. On or about May 3, 2021, in the District of Connecticut, JAEDYN RIVERA,

a.k.a. "Jae Honcho," aided and abetted by others known and unknown to the
Grand Jury, shot and attempted to kill, and aided and abetted in the same,
J.M. and M.L., members and associates of a rival gang, whose true names are
known to the Grand Jury.

h. On or about May 10, 2021, in the District of Connecticut, JAEDYN

RIVERA, a.k.a. "Jae Honcho," and others known and unknown to the Grand
Jury, attempted to kill N.L., a member and associate of a rival gang, whose
true name is known to the Grand Jury.

1. On or about May 14, 2021, in the District of Connecticut, JAEDYN

RIVERA, a.k.a. "Jae Honcho," and DEVIN SUGGS, a.k.a. "JB," shot and
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attempted to kill, and aided and abetted in the same, C. W., a member and
associate of a rival gang, whose true name is known to the Grand Jury.

J. On or about May 17, 2021, in the District of Connecticut, members and

associates of the Exit 8 gang shot at and attempted to kill rival gang members.

k. On or about May 19, 2021, in the District of Connecticut, ANTWAN HILL,

a.k.a. "Bandz," TY.JON PRESTON, a.k.a. "TJ," and others known and
unknown to the Grand Jury, conspired to kill rival gang members and T.B., a
member and assodale of a rival gang, whose lrue name is known lo lhe Grauel
Jury, was killed.

1. On or about May 19, 2021, in the District of Connecticut, QUAYMAR

SUGGS, and others known and unknown to the Grand Jury, shot and killed,
and aided and abetted in the same, T.B., a member and associate of a rival
gang, whose true name is known to the Grand Jury.

m. On or about May 20, 2021, in the District of Connecticut, JAEDYN

RIVERA, a.k.a. "Jae Honcho," TYJON PRESTON, a.lea. "TJ," and others
known and unknown to the Grand Jury, shot and attempted to kill, and aided
and abetted in the same, rival gang members.

n. On or about May 20, 2021, in the District of Connecticut, JAEDYN

RIVERA, a.k.a. "Jae Honcho," DEVIN SUGGS, a.k.a. "JB," and others
known and unknown to the Grand Jury, shot and attempted to kill, and aided
and abetted in the same, K.K. and L.D., whose true names are known to the
Grand Jury.

o. On or about June 30, 2021, in the District of Connecticut, TY.JON

PRESTON, a.k.a. "TJ," shot at and attempted to kill D.L., whose true name
is known to the Grand Jury.

p. On or about July 5, 2021, in the District of Connecticut, ANTWAN HILL,

a.k.a. "Bandz," TY.JON PRESTON, a.k.a. "TJ," and others known and
unknown to the Grand Jury, shot and killed, and aided and abetted in the
same, C.J., whose true name is known to the Grand Jury.

q. On or about August 29, 2021, in the District of Connecticut, members and

associates of the Exit 8 gang shot and attempted to kill a member and
associate of a rival gang, and N.C. and Z.N., whose true names are known to
the Grand Jury, were shot.

r. On or about March 16, 2022, in the District of Connecticut, DEVIN SUGGS,

a.k.a. "JB," and others known and unknown to the Grand Jury, shot at and
attempted to kill rival gang members.

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s. On or about April 12, 2022, in the District of Connecticut, ANTWAN HILL,

a.k.a. "Bandz," NYZAIRE BARNES, a.k.a. "Melo," and others known and
unknown to the Grand Jury, shot at and attempted to kill, and aided and
abetted in the same, rival gang members.

t. On or about September 16, 2022, in the District of Connecticut, DONELL

ALLICK, JR., a.k.a. "D-Nice," and others known and unknown to the Grand
Jury, shot and killed, and aided and abetted in the same, K.C., whose true
name is known to the Grand Jury.

u. On or about January 20, 2023, DEVIN SUGGS, a.k.a. "JB," and others
known and unknown to the Grand Jury, stole a black BMW from Scarsdale,
New York, and drove it back into Connecticut.

v. On or about January 20, 2023, DEVIN SUGGS, a.k.a. "JB," and NYZAIRE
BARNES, a.k.a. "Melo," shot and attempted to kill, and aided and abetted in
the same, T.H., whose true name is known to the Grand Jury.

Special Sentencing Factors

13. On or about May 19, 2021, in the District of Connecticut, QUAYMAR

SUGGS and others known and unknown to the Grand Jury, did commit murder and aid and

abet in the commission of murder, that is, with the intent to cause the death of another person,

SUGGS did in fact cause the death of T.B., whose true name is known to the Grand Jury, in

violation of Connecticut General Statutes §§ 53a-54a and 53a-8.

14. On or about July 5, 2021, in the District of Connecticut, TYJON PRESTON,

a.k.a. "TJ," and others known and unknown to the Grand Jury, did commit murder and aid

and abet in the commission of murder, that is, with the intent to cause the death of another

person, PRESTON did in fact cause the death of CJ., whose true name is known to the

Grand Jury, in violation of Connecticut General Statutes§§ 53a-54a and 53a-8.

15. On or about September 16, 2022, in the District of Com1ecticut, DONELL

ALLICK, JR., a.k.a. "D-Nice," and others known and unknown to the Grand Jury, did

commit murder and aid and abet in the commission of murder, that is, with the intent to

cause the death of another person, ALLI CK, JR. did in fact cause the death of K.C., whose

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true name is known to the Grand Jury, in violation of Connecticut General Statutes §§ 53a-

54a and 53a-8.

All in violation of Title 18, United States Code, Sections 1962(d) and 1963(a).

COUNT TWO
(VCAR Attempted Assault with a Dangerous Weapon and VCAR Attempted Murder)

16. Paragraphs 1 through 9 are incorporated by reference.

17. At all times relevant to this Superseding Indictment, the Exit 8 gang,

including its leadership, its members, and its associates, constituted an enterprise as defined

in Title 18, United States Code, Section l 959(b )(2), that is, a group of individuals associated

in fact, which was engaged in, and the activities of which affected, interstate and foreign

commerce. 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.

18. At all times relevant to this Superseding Indictment, the above-described

enterprise, through its leadership, its members, and its associates, engaged in racketeering

activity as defined in Title 18, United States Code, Sections l 959(b )(1) and 1961(1), namely,

acts involving murder in violation of the laws of the State of Connecticut; offenses involving

the felonious distribution of controlled substances, in violation of Title 21, United States

Code, Sections 841 and 846; and multiple acts indictable under Title 18, United States Code,

Sections 2312 and 2313 involving the interstate transportation and possession of stolen

motor vehicles.

19. On or about May 20, 2021, in the District of Connecticut, the defendants

JAEDYN RIVERA, a.k.a. "Jae Honcho," and TYJON PRESTON, a.k.a. "TJ," together with

others known and unknown to the Grand Jury, and aiding and abetting each other, for the
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purpose of maintaining and increasing position in the Exit 8 gang, an enterprise engaged in

racketeering activity, intentionally and knowingly attempted to assault with a dangerous

weapon members of a rival gang, in violation of Connecticut General Statutes§§ 53a-59(a),

53a-49, and 53a-8, and attempted to murder members of a rival gang, in violation of

Connecticut General Statutes §§ 53a-54a, 53a-49, and 53a-8.

All in violation of Title 18, United States Code, Sections 1959(a)(5) and 1959(a)(6),

and Section 2.

COUNT THREE
(VCAR Assault with a Dangerous Weapon and VCAR Attempted Murder)

20. Paragraphs 1 through 9 and 17 through 18 are incorporated by reference.

21. On or about May 20, 2021, in the District of Connecticut, the defendant

JAEDYN RIVERA, a.k.a. "Jae Honcho," together with others known and unknown to the

Grand Jury, and aiding and abetting each other, for the purpose of maintaining and increasing

position in the Exit 8 gang, an enterprise engaged in racketeering activity, intentionally and

knowingly assaulted with a dangerous weapon K.K. and L.D., whose true names are known

to the Grand Jury, in violation of Connecticut General Statutes§§ 53a-59(a) and 53a-8, and

attempted to murder K.K. and L.D., whose true names are known to the Grand Jury, in

violation of Connecticut General Statutes §§ 53a-54a, 53a-49, and 53a-8.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and 1959(a)(5),

and Section 2.

COUNTFOUR
(VCAR Assault with a Dangerous Weapon and VCAR Attempted Murder)

22. Paragraphs 1 through 9 and 17 through 18 are incorporated by reference.

23. On or about June 30, 2021, in the District of Connecticut, the defendant

TYJON PRESTON, a.k.a. "TJ," together with others known and unknown to the Grand Jury,
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and aiding and abetting each other, for the purpose of maintaining and increasing position

in the Exit 8 gang, an enterprise engaged in racketeering activity, intentionally and

knowingly assaulted with a dangerous weapon D.L., whose true name is known to the Grand

Jury, in violation of Connecticut General Statutes §§ 53a-59(a) and 53a-8, and attempted to

murder D.L., whose true name is known to the Grand Jury, in violation of Connecticut

General Statutes §§ 53a-54a, 53a-49, and 53a-8.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and 1959(a)(5),

and Section 2.

COUNT FIVE
(Conspiracy to Distribute and to Possess with Intent to Distribute Fentanyl and Cocaine)

24. From in or about April 2022 through in or about October 2022, the exact

dates being unknown to the Grand Jury, in the District of Connecticut and elsewhere, the

defendant, SAMUEL DOUGLAS, a.k.a. "Blamm," and others known and unknown to the

Grand Jury, did knowingly conspire together and with one another to distribute and to

possess with intent to distribute 40 grams or more of a mixture and substance containing a

detectable amount of N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide

("fentanyl"), a Schedule II controlled substance, and a mixture and substance containing a

detectable amount of cocaine, its salts, optical or geometric isomers, or salts of isomers, a

Schedule II controlled substance, in violation of Title 21, United States Code, Sections

84l(a)(l), 841(b)(l)(B)(vi), and 841(b)(l)(C).

All in violation of Title 21, United States Code, Section 846.

COUNT SIX
(Unlawful Possession of a Firearm by a Felon)

25. On or about May 21, 2021, in the District of Connecticut, the defendant

JAEDYN RIVERA, a.k.a. "Jae Honcho," having been, and knowing that he had been,
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previously convicted in the Superior Court of the State of Connecticut of a crime punishable

by imprisonment for a term exceeding one year, specifically:

a. Criminal Possession of a Firearm, Ammunition, or an Electronic Defense

Weapon, in violation of Connecticut General Statutes§ 53a-217, on or about
June 11, 2019; and

b. Assault in the Second Degree, in violation of Connecticut General Statutes

§ 53a-60(a)(2), on or about June 11, 2019,

did knowingly possess a firearm in and affecting commerce, that is, a loaded Ruger LCP

.380 handgun with serial number 372-35841, which had been shipped and transported in

interstate and foreign commerce.

In violation of Title 18, United States Code, Sections 922(g)(l) and 924(a)(2).

FORFEITURE ALLEGATION
(Controlled Substances Offense)

26. Upon conviction of the controlled substances offense alleged in Count Five

of this Superseding Indictment, the defendant SAMUEL DOUGLAS, a.k.a. "Blamm," shall

forfeit to the United States, pursuant to Title 21, United States Code, Section 853, all right,

title, and interest in any property constituting, or derived from, proceeds obtained, directly

or indirectly, as a result of the violations of Title 21, United States Code, Sections 841 and

846, and any property used, or intended to be used, in any manner or part, to commit, or to

facilitate the commission of, the violations and a sum of money equal to the total amount of

proceeds obtained as a result of the offenses.

27. If any of the above-described forfeitable property, as a result of any act or

omission of the defendant, cannot be located upon the exercise of due diligence, has been

transferred, sold to, or deposited with a third party, has been placed beyond the jurisdiction

of the court, has been substantially diminished in value, or has been commingled with other

property which cannot be divided without difficulty, it is the intent of the United States,
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pursuant to Title 21, United States Code, Section 853(p ), to seek forfeiture of any other

property of the defendant up to the value of the forfeitable property described above.

All in accordance with Title 21, United States Code, Sections 853 and 881, and Rule

32.2(a) of the Federal Rules of Criminal Procedure.

FORFEITURE ALLEGATION
(Firearm Offense)

28. Upon conviction of the firearm offense alleged in Count Six of this

Superseding Indictment, the defendant JAEDYN RIVERA, a.k.a. "Jae Honcho," shall forfeit

to the United States, pursuant to Title 18, United States Code, Section 924( d) and Title 28,

United States Code, Section 2461 (c), all firearms and ammunition involved in the

commission of the offense, including but not limited to one Ruger LCP .380 handgun with

serial number 372-35841, and ammunition contained within that firearm, that was seized on

or about May 21, 2021.

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All in accordance with Title 18, United States Code, Section 924(d); Title 21, United

States Code, Section 853; Title 28, United States Code, Section 2461 (c); and Rule 32.2(a)

of the Federal Rules of Criminal Procedure.

A TRUE BILL
/s/

FOREPERSON

UNITED STATES OF AMERICA

VANESSA ROBERTS A ERY

UNITED STATES ATTORNEY

(l\~-L~
TARA E. LEVENS
ASSISTANT UNITED STATES ATTORNEY

RAHULKALE
ASSISTANT UNITED STATES ATIORNEY

JO I YN COURTNEY KAOUTZANIS
A SI ANT UNITED STATES ATTORNEY

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