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Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 1 of 11 PageID# 2

FILED
IN OPFNCnilRT
IN THE UNITED STATES DISTRICT COURT FC
- K 1 It

EASTERN DISTRICT OF VIRGINIA


SEP 1 2 2017

CLERK. U.S. DISTRICl CUUHf


Newport News Division NEWPORT NEWS. VA

UNITED STATES OF AMERICA


CRIMINAL NO. 4:17CR
V.

KEVIN SAMUELS 21 U.S.C.§846


(Counts 1-3) Conspiracy to Possess with Intent to
Distribute Heroin
(Count 1)
SCOTT FLETCHER
(Counts I, 4, 5) 21 U.S.C. §841
Distribute Heroin
AARON WILLIAMS (Count 2-8)
(Counts 1,6-8)

21 U.S.C. §853
Forfeiture Allegation

INDICTMENT

SEPTEMBER 2017 Term - At Newport News, Virginia


Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 2 of 11 PageID# 3

COUNT ONE

THE GRAND JURY CHARGES THAT:

On or about or between October 2016 and September, 2017, in the Eastern District of

Virginia and elsewhere, the defendants, KEVIN SAMUELS, SCOTT FLETCHER, and AARON

WILLIAMS did unlawfully, knowingly and intentionally combine, conspire, confederate and

agree together with other persons known and unknown to the grand jury to commit the following

offenses against the United States:

1. Distribute 100 grams or more of a mixture or substance containing a detectable

amount of heroin, a Schedule I narcotic controlled substance, in violation of Title 21, United

States Code, Section 841 (a) (1) and (b) (1) (B).

4. Possess with intent to distribute100 grams or more of a mixture or substance

containing a detectable amount of heroin, a Schedule I narcotic controlled substance, in violation

of Title 21, United States Code, Section 841(a)(1) and (b)(1) (B).

(All in violation of Title 21, United States Code, Sections 846, 841(a)(1) and
841(b)(1)(C)).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 3 of 11 PageID# 4

COUNT TWO

THE GRAND JURY FURTHER CHARGES THAT:

On orabout March 9,2017, in^anTpton, Virginia, inthe Eastern District of Virginia and

elsewhere, the defendant, SCOTT FLETCHER did unlawfully, knowingly and distribute a

mixture or substance containing a detectable amount of heroin, a Schedule I narcotic controlled

substance.

(All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(B).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 4 of 11 PageID# 5

COi:rNT THREE

THE GRAND JURY FURTHER CHARGES THAT:

On or about March 24,2017, in Hampton, Virginia, in the Eastern District of Virginia

and elsewhere, the defendant, SCOTT FLETCHER did unlawfully, knowingly and distribute a

mixture or substance containing a detectable amount of heroin, a Schedule I narcotic controlled

substance.

(All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 5 of 11 PageID# 6

COUNT FOUR

THE GRAND JURY FURTHER CHARGES THAT:

On or about April 4, 2017, in Newport News, Virginia, in the Eastern District of Virginia

and elsewhere, the defendant, KEVIN SAMUELS did unlawfully, knowingly and distribute a

mixture or substance containing a detectable amount of heroin, a Schedule I narcotic controlled

substance.

(All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 6 of 11 PageID# 7

COUNT FIVE

THE GRAND JURY FURTHER CHARGES THAT:

On or about April 6,2017, in Newport News, Virginia, in the Eastern District of Virginia

and elsewhere, the defendant, KEVIN SAMUELS did unlawfully, knowingly and distribute a

mixture or substance containing a detectable amount of heroin, a Schedule I narcotic controlled

substance.

(All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 7 of 11 PageID# 8

COUNT SIX

THE GRAND JURY FURTHER CHARGES THAT:

On or about October 3,2016, in Hampton, Virginia, in the Eastern District of Virginia

and elsewhere, the defendant, AARON WILLIMAS did unlawfiilly, knowingly and distribute a

mixture or substance containing a detectable iamount of heroin, a Schedule I narcotic controlled

substance.

(All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 8 of 11 PageID# 9

COUNT SEVEN

THE GRAND JURY FURTHER CHARGES THAT;

On or about October^ 2016, inNewport News, Virginia, in the Eastern District of

Virginia and elsewhere, the defendant, AARON WILLIMAS did unlawfully, knowingly and

distribute a mixture or substance containing a detectable amount of heroin, a Schedule I narcotic

controlled.

(All in violation ofTitle 21, United States Code, Section 841(a)(1) and (b)(1)(C).
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 9 of 11 PageID# 10

COUNT EIGHT

THE GRAND JURY FURTHER CHARGES THAT:

On or about October 11,2016, in Newport News, Virginia, in the Eastern District of

Virginia and elsewhere, the defendant, AARON WILLIMAS did unlawfully, knowingly and

distribute a mixture or substance containing a detectable amount of heroin, a Schedule I narcotic

controlled substance within 1000 feet of the real property comprising an elementary school, to

wit: Sedgefield Elementary School.

(All in violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(C) and 860.)
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 10 of 11 PageID# 11

FORFEITURE ALLEGATION

THE GRAND JURY FURTHER CHARGES THAT:

A. The defendants, KEVIN SAMUELS, SCOTT FLETCHER, and

AARON WILLIAMS if convicted of the violation alleged in Counts One through Eight of the

indictment, shall forfeit to the United States:

1. Any and all property constituting, or derived from, any proceeds the

defendant obtained, directly or indirectly, as the result of such violation; and

2. Any of the defendant's property used, or intended to be used, in any

manner or part, to commit, or to facilitate the commission of such violation.

3. If any property that is subject to forfeiture above, (a) cannot be

located upon the exercise of due diligence, (b) has been transferred to, sold to, or deposited with

a third person, (c) has been place beyond the jurisdiction of the Court, (d) has been substantially

diminished in value, or (e) has been commingled with other property that cannot be subdivided

without difficulty; it is the intent of the United States to seek forfeiture of any other property of

the defendant, as subject to forfeiture under Title 21, United States Code, Section 853(p).

(In violation of Title 21, United States Code, Section 853.)

10
Case 4:17-cr-00089-RAJ-DEM Document 2 Filed 09/12/17 Page 11 of 11 PageID# 12

REDACTED COPY

UNTIED STATES V. KEVIN SAMUELS, ET. AL., 4:17CR

A TRUE BILL:
REDACTED COPY

FOREPERS ON

DANA J. BOENTE
UNITED STATES ATTORN£Y>

By:
Eric M. Hurt '
Assistant United States Attorney
Virginia State Bar No. 35765
Fountain Plaza Tluree, Suite 300
721 Lakefront Commons
Newport News, Virginia 23606
(757)591-4000

n
Case 4:17-cr-00089-RAJ-DEM Document 2-1 Filed 09/12/17 Page 1 of 3 PageID# 13

REDACTED
JS 45 (11/2002)

Criminal Case Cover Sheet U.S. District Court


Place of Offense: Under SeahYes 2^ No_ Judge Assigned:
City Superseding Indictment Criminal Number:
tt.
County/Parish Newport News Same Defendant New Defendant YES

Magistrate Judge Case Number Arraignment Date:


Scarch Warrant Case Number

R 20/R 40 from District of

Defendant Information:

Juvenile—Yes No X FBI#

Alias
Defendant Name: KEVIN SAMUELS Name(s)
Address:

Employment:
Def
Birth date06-81 SS# 2342 Sex M Race BIk Nationality US Place of Birth

Height Weight HairBLACK EyesBR Scars/Tattoos

InterpreterrX No Yes List language and/or dialect:


Location Status:

Arrest Date

Already in Federal Custody as of m

Already in State Custody On Pretrial Release Not in Custody


X Arrest Warrant Requested x Fugitive Summons Requested
ArrestWarrantPending Sought Bond

Defense Counsel information:

Name: Court Appointed


Address; Retained

Telephone: Public Defender

Oftice of Federal Public Defender should not be appointed due to conflict of


interest

CJA attorney should not be appointed due to conflict of


interest

U.S. Attorney Information:

AUSA Eric M. Hurt Telephone No; 591-4000 Bar #35765

Complainant Agency. Address & Phone Number or Person & Title:

HSI TFA Josh Calhoon

U.S.C. Citations:

Code/Section Description of Offense Charged Countfs) Capital/Felonv/Misd/Pettv

Setl 21 use 846 Conspiracy to dist heroin j felony


Set 2 21 use 841 Distribute heroin 2,3 felony
Set 3 felony
Set 4
Case 4:17-cr-00089-RAJ-DEM Document 2-1 Filed 09/12/17 Page 2 of 3 PageID# 14

REDACTED
JS 45(11/2002)

Criminal Case Cover Slieet U.S. District Court


Place of OfTense: Under SeahYes X No Judge Assigned:
City Superseding Indictment Criminal Number:_
County/Parish Newport News Same Defendant New Defendant YES

Magistrate Judge Case Number Arraignment Date:


Search Warrant Case Number

R 20/R 40 from District of

Defendant hiformatlon;

Juvenile "Yes No X FBI#


Alias
Defendant Name: SCOTT FLETCHER Name(s)
Address:

Employment:
Def
Birth date04-66 SS# 7512 Sex M Race BIk Nationality US Place of Birth

Height Weight HairBLACK. EyesBR Scars/Tattoos

lnterpreter:X No Yes List language and/or dialect:


Location Status:

Arrest Date

Already in Federal Custodyas of m

Already in State Custody On Pretrial Release _Not in Custody


X Arrest Warrant Requested x Fugitive Summons Requested
Arrest Warrant Pending X Detention Sought Bond

Defense Counsel Information:

Name: Court Appointed


Address: _Retained
Telephone: _Publ!C Defender
Office of Federal Public Defender should not be appointed due to confliet of
interest

CJA attorney should not be appointed due to conflict of


interest

U.S. Attorney Information:

AUSA Eric M. Hurt Telephone No: 591-4000 Bar#35765

Coninlainant Agencv. Address & Phone Number or Person & Title:


HSITFA Josh Calhoon

U.S.C. Citations:

Code/Section Description of Offense Charged Count(s) Canltal/Felonv/iVlisd/Pcttv

Setl 21 use 846 Conspiracy to dist heroin I feiony


Set 2 21 use 841 Distribute heroin 4,5 felony
Set 3 felony
Set 4

•u
Case 4:17-cr-00089-RAJ-DEM Document 2-1 Filed 09/12/17 Page 3 of 3 PageID# 15

REDACTED
JS 45 (11/2002}

Criminal Case Cover Sheet U.S. District Court


Place of Offense: Under SeahYes X No_ Judge Assigned:
City Superseding Indicimcnt Criminal Number

County/Parish Newport News Same Defendant New Defendant YES

Magistrate Judge Case Number Arraignment Date:


Searcii Warrant Case Number

R 20/R 40 from District of

Defendant Information;

Juvenile -Yes No X FBI #

Alias
Defendant Name: AARON WILLIAMS Name(s)
Address:

tLniployment:
Def
Birth date04-90 SS# 3539 Sex M Race B!k Nationality US Place of Birth

Height Weight HairBLACK EyesBR Scars/Tattoos

Intcrpreter:X No Yes List language and/or dialect:


Location Status:

Arrest Date

Already in Federal Custodyas of m

Already in State Custody On Pretrial Release Not in Custody


X Arrest Warrant Requested x Fugitive Summons Requested
Arrest WarrantPending X Detention Sought Bond

Defense Counsel Information:

Name: _Court Appointed


Address: Retained

Telephone: Public Defender

Office of Federal Public Defender should not be appointed due to conflict of


interest

CJA attorney should not be appointed due to conflict of


interest

U.S. Attorney Information:

AUSA l-ricM, Hurt Telephone No: 591-4000 Bar#35765

Coniplaiiiant Agency. Address & Phone Number or Person & Title:


HSITFA Josh Calhoon

U.S.C. Citations:

Code/Scction Description of Offense Charged CounKs^ Capital/Felonv/Misd/Pettv

Set 1 21 use 846 Conspiracy to dist heroin j felony


Set 2 21 use 841 Distribute heroin 6, 7, 8 felony
Set 3 felony
Set 4