UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

-x

UNITED STATES OF AMERICA SEALED INDICTMENT

-v. -
10 Cr.
GILBRILLA KAMARA,
a/k/a ~Gibril Kamara,"
a/k/a ~Anthony Smith,"
a/k/a ~GK,"
t OCRIM ~~.4 5'7 j

a/k/ a "Gibry, "

a/k/a "Gee Wee,"
a/k/a ~River Stallon,"
ALI SESAY,
a/k/a "Aliue Sesay,"
a/k/a "Alie Sesay," and
GENNOR JALLOH,
a/k/a ~Chernoh Nuhu Jalloh,"

Defendants.

- -x

COUNT ONE

NARCOTICS IMPORTATION CONSPIRACY

The Grand Jury charges:

BACKGROUND

1. During the last decade, drug trafficking

organizations based in South America have increasingly used

countries along or near the West African coast as trans-shipment

hubs for importing massive quantities of cocaine to be later

distributed in Europe or elsewhere within Africa. Through a

combination of privately owned aircraft and maritime vessels,

these organizations, predominately based in Colombia and

Venezuela, have transported hundreds of tons of cocaine, worth

billions of dollars, to places such as Guinea Bissau, Guinea

Conakry, Sierra Leone, Togo, Mali, Ghana, Nigeria and Liberia.

In so doing, representatives of these drug trafficking

organizations have often sought to bribe high-level public

officials with large cash payments and narcotics in order to

ensure the safe passage, storage, and distribution of their

cocaine shipments.

THE DEFENDANTS

2. Since at least in or about 2007, GILBRILLA KAMARA,

a/k/a "Gibril Kamara," a/k/a "Anthony Smith," a/k/a "GK," a/k/a

"Gibry," a/k/a "Gee Wee," a/k/a "River Stallon," the defendant,

has actively recruited South American drug trafficking

organizations to establish operations in various West African

countries, including Liberia, Guinea Conakry, Guinea Bissau,

Sierra Leone, and Nigeria. At the same time, KAMARA has made

efforts to corrupt and influence Government officials within the

West African region in order to establish secure locations that

such drug trafficking organizations can use to receive, store and

trans-ship cocaine, free from law enforcement intervention.

KAMARA has also distributed cocaine that he received from these

drug trafficking organizations to locations within Africa and to

Europe.

3. Since at least in or about 2007, ALI SESAY, a/k/a

"Aliue Sesay," a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a

"Chernoh Nuhu Jalloh," the defendants, worked in West Africa,

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including in Sierra Leone, on behalf of KAMARA. SESAY and JALLOH

assisted KAMARA with KAMARA's drug distribution enterprise and

with his efforts to corrupt and influence Government officials

for the benefit of South American drug trafficking organizations,

as described in paragraph 2, above.

MEANS AND METHODS OF THE CONSPIRACY

4. From in or about 2009, up to and including in or

about May 2010, GILBRILLA KAMARA, a/k/a/ ~Gibril Kamara," a/k/a

~Anthony Smith," a/k/a ~GK," a/k/a ~Gibry," a/k/a ~Gee Wee,"

a/k/a ~River Stallon," ALI SESAY, a/k/a "Aliue Sesay," a/k/a

"Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the

defendants, made efforts to influence and corrupt Government

officials in Liberia, with the goal of persuading those

officials, in exchange for payment, to allow South American drug

trafficking organizations to transport cocaine to Liberia, store

it there, and ultimately distribute it to Europe and other

locations within Africa. By in or about October 2009, KAMARA had

already devoted significant resources to his efforts to corrupt

officials in Liberia and began attempting to contact high-level

government officials whom he knew to be the Director and Deputy

Director of the Republic of Liberia National Security Agency

("RLNSA"), both of whom, unbeknownst to KAMARA, were working

jointly with the United States Drug Enforcement Administration

("DEA") in an undercover capacity ("UC-l" and ~UC-2",

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respectively). (UC-l, the Director of the RLNSA, is also the son

of the President of Liberia.)

5. From at least in or about the fall of 2009 through

in or about May 2010, GILBRILLA KAMARA, a/k/a/ "Gibril Kamara,"

a/k/a "Anthony Smith," a/k/a "GK," a/k/a "Gibry," a/k/a "Gee

Wee," a/k/a "River Stallon," ALI SESAY, a/k/a "Aliue Sesay,"

a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu

Jalloh," the defendants, exchanged a series of emails and

telephone calls and held numerous meetings with UC-l, UC-2, and a

third government official who was also working jointly with the

DEA in an undercover capacity ("UC-3") to negotiate prices and

make specific arrangements for the secure transportation of

cocaine from South America through Liberia, including, but not

limited to, a 4,000 kilogram shipment of cocaine from Colombia.

A confidential source working with the DEA (the "CS"), who was

introduced as UC-l's "partner" and confidante, was present for

many of these meetings. In the course of negotiating with UC-l,

UC-2, UC-3, and the CS, the defendants understood that the CS,

who was to be paid by the defendants in the form of cocaine,

would import a portion of his share of the cocaine to the United

States.

STATUTORY ALLEGATIONS

6. From at least in or about 2009, up to and

including in or about May 2010, GILBRILLA KAMARA, a/k/a/ "Gibril

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Kamara," a/k/a "Anthony Smith," a/k/a "GK," a/k/a "Gibry," a/k/a

"Gee Wee," a/k/a "River Stallon," ALI SESAY, a/k/a "Aliue Sesay,"

a/k/a "Alie Sesay," and GENNOR JALLOH, a/k/a "Chernoh Nuhu

Jalloh," the defendants, each of whom will first enter the United

States in the Southern District of New York, and others known and

unknown, unlawfully,. intentionally and knowingly did combine,

conspire, confederate and agree together and with each other to

violate the narcotics laws of the united States.

7. It was a part and an object of the conspiracy that

GILBRILLA KAMARA, a/k/a/ "Gibril Kamara," a/k/a "Anthony Smith,"

a/k/a "GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River

Stallon," ALI SESAY, a/k/a "Aliue Sesay," a/k/a "Alie Sesay," and

GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the defendants, and

others known and unknown, would and did distribute a controlled

substance, to wit, five kilograms and more of mixtures and

substances containing a detectable amount of cocaine, knowing and

intending that such substances would be unlawfully imported into

the United States or into waters within a distance of 12 miles of

the coast of the United States, in violation of Sections 812,

959 (a), 960 (a) (3) and 960 (b) (1) (B) of Title 21, United States

Code.

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 OVERT ACTS

8. In furtherance of the conspiracy and to effect the

illegal object thereof, the following overt acts, among others,

were committed:

a. On or about November 30, 2009, ALI SESAY,

a/k/a "Aliue Sesay," a/k/a "Alie Sesay," the defendant, met with

UC-3 in Monrovia, Liberia. During the meeting, SESAY told UC-3

that GILBRILLA KAMARA, a/k/al "Gibril Kamara," a/k/a "Anthony

Smith," a/k/a "GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River

Stallon," the defendant, wanted security and protection in

Liberia for KAMARA's Colombian drug trafficking associates, and

asked for UC-3's help in making contact with UC-3's boss, UC-I

(the Director of the RLNSA and the son of the President of

Liberia) .

b. On or about November 30, 2009, SESAY placed a

telephone call to KAMARA in the presence of UC-3. UC-3 also

spoke to KAMARA. KAMARA reiterated his intentions to establish

security for his Colombian drug trafficking associates, as SESAY

had previously described to UC-3, requested a meeting with UC-I,

and asked for UC-3's assistance in facilitating his safe travel

to Monrovia, Liberia for that meeting.

c. .On or about December 8, 2009, UC-3 met with

SESAY and GENNOR JALLOH, a/k/a "Chernoh Nuhu Jalloh," the

defendant, at a hotel in Mamba Point, Liberia. During the

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meeting, SESAY and JALLOH indicated that KAMARA had informed them

that certain Colombian drug traffickers were currently in Morocco

and, after meeting with KAMARA, would travel to Liberia. SESAY

and JALLOH informed UC-3 that KAMARA had instructed them to

locate small rural airstrips where cocaine could be unloaded

without detection, and that KAMARA and his Colombian drug

trafficking associates wanted to transport several million

dollars worth of cocaine to Liberia on small private aircraft.

d.During the same meeting on or about December

8, 2009, JALLOH and SESAY diVUlged to UC-3 that KAMARA and his

associates had contacts and a partial ownership in a large

commercial airline that operates in the region, and that they

intended to use passenger flights departing from Monrovia to

transport the cocaine out of Liberia.

e. During the same meeting on or about December

8, 2009, JALLOH and SESAY further stated that KAMARA

and representatives of the Colombian drug traffickers would

travel to Liberia in the near future to meet with UC-l and pay

one million dollars in cash to secure protection for an initial

shipment of cocaine. JALLOH and SESAY further stated that an

additional one million dollar payment would be paid to UC-l by

KAMARA and the Colombian drug traffickers for every subsequent

flight that was able to safely deliver cocaine in Liberia.

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 f. On or about March 9, 2010, KAMARA was brought

to the RLNSA headquarters building in Monrovia, Liberia by UC-3

in order to meet with UC-l and UC-2. The CS participated in the

meeting and was introduced to KAMARA as UC-l's "partner" and

confidante. At the meeting, the use of Liberia as a secure

location for receiving and trans-shipping thousand-kilogram

quantities of cocaine was discussed. The CS advised KAMARA that

if cocaine was to be used as payment in exchange for security,

the CS would want to send the cocaine to Accra, Ghana

immediately, and then place the cocaine on a flight to New York.

During the meeting, UC-l told KAMARA that all future negotiations

for security payments and coordination of the future drug

shipments would need to be handled by the CS.

g. On or about March 10, 2010, KAMARA attended a

subsequent meeting with the CS during which KAMARA discussed

specific details of his plan to bring cocaine shipments into and

through Liberia, including the type of plane that would be used,

the airport that the plane would fly into, the dangers of flying

cocaine from Bolivia and Venezuela into West Africa, and the type

of payments required for allowing the plane to fly into Liberia.

h. During the same meeting on or about March 10,

2010, KAMARA agreed that the CS would receive part of the payment

in the form of cocaine, which the CS indicated would be

transported to Ghana, and then to the united States for

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distribution. KAMARA also stated that the first flight into

Liberia would be carrying 4,000 kilograms of cocaine. At the end

of the meeting, KAMARA made additional inquiries as to whether

UC-1 and the CS could control Sierra Leone as well, and stated

that if one can control Liberia and Sierra Leone, "the sky's the

limit."

i. On or about March 31, 2010, KAMARA sent the

CS two scanned passports, via electronic mail, of individuals

KAMARA later described as decision-makers in a specific Colombian

drug trafficking organization, so that the CS could secure a visa

for these individual to travel to Liberia in order to pay UC-1

and the CS for the safe passage through Liberia of the

organization's cocaine.

j. On or about May 19, 2010, JALLOH met with UC-

3 and the CS in Monrovia, Liberia, and JALLOH reaffirmed his

understanding of the agreement, as the CS and KAMARA had

discussed, to fly cocaine into Liberia, and that a portion of

that cocaine (which represented the payment to the CS) would then

be sent to the United States and to Europe. During that same

meeting, JALLOH stated that the initial down payment for safe

passage of the cocaine through Liberia had been redirected to

Dakar, Senegal by the Colombian drug trafficking organization,

but that JALLOH and KAMARA were selling cocaine in Europe and

Sierra Leone to generate more cash revenue to pay UC-1 the

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previously promised down payment to secure the safe passage of

the cocaine.

k. On or about May 19, 2010, SESAY spoke on the

telephone with JALLOH in the presence of UC-3 and the CS, about

their plan to facilitate cocaine shipments from Liberia to Ghana

and the United States.

1. On or about May 19, 2010, JALLOH told the CS

during a telephone call that KAMARA wished to assure everyone in

Liberia that KAMARA, JALLOH, and SESAY were fully supportive of

the plan to use Liberia as a tran-shipment point for the

distribution of cocaine to the united States, Europe, and other

parts of Africa.

m. On or about May 20, 2010, KAMARA told the CS

during a telephone call that KAMARA would arrive in Liberia no

later than May 25. The CS informed KAMARA that he needed

KAMARA's help in distributing a large quantity of cocaine that

the CS had received in Liberia; KAMARA stated that he could

assist the CS and asked the CS to wait until KAMARA arrived in

Liberia on May 25. KAMARA informed the CS that KAMARA himself

also expected to receive a cocaine shipment.

n. On or about May 22, 2010, JALLOH provided UC-

3 a photocopy of his passport from Sierra Leone that had the name

~Chernoh Nuhu Jalloh," in order to further KAMARA, JALLOH, and

SESAY's efforts to distribute cocaine in Liberia.

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 o. On or about May 23, 2010, KAMARA called the

CS and informed the CS that KAMARA would be arriving in Liberia

on May 24, 2010. During that call, KAMARA requested that the CS

arrange for his hotel room and a driver.

p. On or about May 24, 2010, KAMARA met with the

CS at a hotel in Monrovia, Liberia. The CS explained that he

would be receiving 500 kilograms of cocaine within a few days, of

which the CS would send, by commercial flight from Accra, Ghana,

200 to 250 kilograms of cocaine to the united States. The CS and

KAMARA discussed the CS's obligation to send at least 200

kilograms of cocaine to the united States and KAMARA said he

could transport the cocaine to Accra, Ghana for the CS. KAMARA

also agreed to distribute the remaining 300 kilograms of cocaine

for the CS in Europe.

q. Also on or about May 24, 2010, and following

the meeting described in paragraph (p), above, JALLOH and SESAY

joined the meeting with KAMARA and the CS. KAMARA confirmed that

he was in charge of SESAY and JALLOH, and explained to them that

the CS would receive the cocaine in Liberia within a few days,

and that KAMARA, SESAY, and JALLOH would transport some of the

cocaine to Ghana and then sell the remaining cocaine. The CS

explained that the CS would need 200 kilograms of cocaine

transported each month to the airport in Accra, Ghana, and that

the timing of the transportation must be coordinated with the

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departure of the commercial flight leaving for New York. KAMARA,

SESAY and JALLOH confirmed that they understood that the cocaine

must be delivered to the airport in Ghana on the same day that

the flight departs.

(Title 21, United States Code, Section 963.)

FORFEITURE ALLEGATION

9. As a result of committing the controlled substance

offense alleged in Count One of this Indictment, GILBRILLA

KAMARA, a/k/a/ "Gibril Kamara," a/k/a "Anthony Smith," a/k/a

"GK," a/k/a "Gibry," a/k/a "Gee Wee," a/k/a "River Stallon," ALI

SESAY, a/k/a "Aliue Sesay," a/k/a "Alie Sesay," and GENNOR

JALLOH, a/k/a "Chernoh Nuhu Jalloh," the defendants, shall

forfeit to the United States, pursuant to 21 U.S.C. § 970, any

and all property constituting and derived from any proceeds that

the defendants obtained directly and indirectly as a result of

the said violation and any and all property used and intended to

be used in any manner or part to commit and to facilitate the

commission of the violation alleged in Count One of this

Indictment, including but not limited to, a sum of money

representing the amount of proceeds obtained as a result of the

offense described in Count One of this Indictment.

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 substitute Assets Provision

10. If any of the property described above as being

subject to forfeiture, 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;

c. has been 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;

it is the intention of the United States, pursuant to Title 21,

united States Code, Section 970, to seek forfeiture of any other

property of the defendants up to the value of the forfeitable

property.

(Title 21, United States Code, Sections 963 and 970.)

PREET BHARARA
United States Attorney

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 Form No. USA-33s-274 (Ed. 9-25-58)

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

- v -

GILBRILLA KAMARA,
ALI SESAY,
GENNOR JALLOH,

Defendants.

SEALED INDICTMENT

10 Cr.

(Title 21, United States Code,

Sections 963 and 970.)

PREET BHARARA
United States Attorney.

A TRUE BILL

J 7 Foreperson.