Case 2:13-cr-20085-KHV-JPO Document 10 Filed 07/31/13 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (KANSAS CITY DOCKET) UNITED STATES OF AMERICA, Plaintiff, vs. VERTRICK JORDAN, Defendant. ) ) ) ) ) ) ) ) )

No. 13-20085-01-KHV-JPO

INDICTMENT
The Grand Jury charges that: COUNT 1 Background At all times material and relevant to this Indictment: 1. Defendant VERTRICK JORDAN was a resident of Smith County, Texas. 2. PETE DAVIS was a resident of Jackson County, Missouri. 3. MELVIN. R. ROBINSON was a resident of Wyandotte County, Kansas. Conspiracy and Its Objects 4. Between on or about March 1, 2013, up to and including March 23, 2013, said dates

being approximate and inclusive, in the District of Kansas and elsewhere, the defendant VERTRICK JORDAN ("JORDAN") did knowingly conspire and agree with PETE DAVIS, Jr., MELVIN L. ROBINSON and with persons known and unknown to the Grand Jury, to commit the following offenses against the United States, to wit: a. knowingly sponsoring and exhibiting an animal in an animal fighting venture, in which

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an animal was moved in interstate commerce, in violation of Title 7, United States Code, Section 2156(a)(1); and b. knowingly buying, transporting, delivering, and receiving for the purposes of

transportation in interstate commerce, any dog for the purpose of having the dog participate in an animal fighting venture, in violation of Title 7, United States Code, Section 2156(b). Manner and Means By Which the Conspiracy Was Carried Out 5. The members of the conspiracy used various manners and means to effect the object and purpose of the conspiracy, including but not limited to the following: a. It was a part of the conspiracy that the defendant and co-conspirators would knowingly and illegally acquire, breed, and train pit bull dogs for the purpose of entering them in animal fighting ventures. b. It was further part of the conspiracy that defendant and co-conspirators would organize and operate unlicensed kennels for pit bull dogs. c. It was further part of the conspiracy that the defendant and co-conspirators would communicate via telephone, cellular telephone, electronic mail and other forms of interstate communication, with various individuals and unindicted co-conspirators located within and outside the District of Kansas (including Texas), in order to promote, sponsor, and conduct animal fighting ventures. d. It was further part of the conspiracy that the defendant and co-conspirators, would collect forfeit fees for those participating in the animal fighting ventures. e. It was further part of the conspiracy that the defendant and co-conspirators, would promote, sponsor, and conduct illegal gambling and bookmaking activities in conjunction with said

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animal fighting ventures. f. It was further part of the conspiracy that defendant and co-conspirators would deny pit bull dogs that participated in animal fighting ventures adequate and humane medical treatment of wounds and injuries suffered as a result of the dog fights. g. It was further part of the conspiracy that defendant and co-conspirators would routinely and inhumanely abandon and destroy certain pit bull dogs that became severely injured, wounded, or disabled as a result of participating in animal fighting ventures. Overt Acts 6. In furtherance of and to effect the objectives of the conspiracy, and to accomplish its purposes and objectives, the defendant or other conspirators committed and caused to be committed the following overt acts, among others, in the District of Kansas and elsewhere: March 17, 2013, Dog fight 7. From in or about March 2013, until on or about March 23, 2013, DAVIS maintained a farm in Harrison County, Missouri (hereinafter the Missouri Farm) for the purpose of housing and training pit bull dogs. 8. The pit bull dogs housed at the Missouri Farm were trained and maintained by DAVIS, ROBINSON, and others, as fighting dogs. 9. On March 17, 2013, DAVIS, ROBINSON, and others traveled to the Missouri Farm. 10. On March 17, 2013, DAVIS, ROBINSON, and others held three dog fights involving six dogs and then took one dog from the Missouri Farm to Kansas City, Kansas. 11. On March 17, 2013, DAVIS told a Confidential Source they would be attending the big "dog show" in Dallas the coming weekend.

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12. On March 22, 2013 at approximately 3:19 a.m., DAVIS arrived at a residence in Kansas City, Kansas in a white Chevrolet Suburban bearing Texas plates. 13. On March 22, 2013, at approximately 3:30 a.m., several individuals got into the white Suburban, a beige Tahoe, and a Nissan Altima and left Kansas City, Kansas, and traveled through the state of Oklahoma. 14. On March 22, 2013, all three vehicles crossed the border from Oklahoma into Texas at 10:25 a.m. and arrived at Tyler, Texas at approximately 1:50 p.m. March 23, 2013, Scheduled Animal Fighting Venture 15. On March 23, 2013 at 6:23 p.m., DAVIS, ROBINSON, and other unnamed

co-conspirators left the motel they were staying at in Tyler, Texas, with ROBINSON's pit bull dog that he had brought from Kansas to enter in the animal fighting venture and drove to JORDAN's residence in Tyler, Texas. 16. On March 23, 2013, other co-conspirators brought pit bull dogs to JORDAN's

residence to enter them in the animal fighting venture. 17. On March 23, 2013, the animal fighting venture was to be a "two dog card" and a

"grand championship" match where each dog was required to have won four previous fights to qualify for the grand championship match. 18. On March 23, 2013, JORDAN permitted a dogfighting pit to be constructed on his property. 19. On March 23, 2013, two trophies were observed next to the dogfighting pit. 20. On March 23, 2013, JORDAN maintained approximately 10 pit bull dogs on his property for the purpose of breeding them in order to sell them to individuals to enter into animal

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fighting ventures. 21. This was all in violation of Title 18, United States Code, Section 371. FORFEITURE NOTICE 22. The allegations contained in Count 1 of this Indictment are hereby realleged and

incorporated by reference for the purpose of alleging forfeiture pursuant to Title 7, United States Code, Section 2156 (f) and Title 28, United States Code, Section 2461 (c). 23. Upon conviction of the offense in violation of Title 7, United States Code, Section

2156, the defendant, VERTRICK JORDAN, shall forfeit to the United States any and all animals that were involved in the violation, including but not limited to the 18 dogs seized on or about March 23, 2013, in Texas by the Federal Bureau of Investigation. 24. Further, the defendants shall be responsible for all costs incurred by the United

States, and any assisting third-party, for the care of all dogs or other animals seized during this investigation and prosecution. This is all pursuant to Title 7 United States Code, Sections 2156 (f) and Title 28, United States Code, Section 2461 (c). A TRUE BILL.

Dated: July 31, 2013

/s/ Foreperson FOREPERSON

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/s/ Tristram W. Hunt, Ks. S. Ct. No.18196, for BARRY R. GRISSOM United States Attorney District of Kansas 500 State Avenue, Suite 360 Kansas City, Kansas Tel. 913-551-6730 Fax 913-551-6541 Ks. S. Ct. No. 10866 Barry.Grissom@usdoj.gov

(It is requested that trial of the above captioned case be held in Kansas City, Kansas.)

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PENALTIES Count 1: NMT 5 years imprisonment; NMT $250,000 fine; NMT 3 years supervised release; $100 special assessment fee; and Forfeiture allegation.