Sinisa Simic Indictment

Case 8:10-cr-00639-PJM Document 36 Filed 03/14/11 Page 1 of 25
~~AC/ADC/SR: USAO2010ROO841
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA *

*
v. * CRIMINAL NO. PJM-IO-0639
*
SINISA SIMIC, and * (Conspiracy to Distribute and I)ossess
MIRZA KUNJUNDZIC, * With Intent to Distribute Controlled
* Substanee, 21 U.S.c. ~ 846; Conspiracy
Defendants * to Interfere with Commerce by
* Extortion, 18 U.S.C. ~ 1951(a);
* Conspiracy to Possess Firearm in
* Furtherance of Drug Trafficking Crime
* and Crime of Violence, 18 U.S.c.
* ~ 924(0); Interference with Commerce
* by Extortion, 18 U.S.C. ~ 1951;
* Distribution of Controlled Substances,
* 21 U.S.C. ~ 841(a)(I); Possession of
* Firearm in Furtherance of Drug
* Trafficking Crime and Crime of
* Violence, 18 U.S.c. ~ 924(c); False
* Statement During Purchase of Firearm,
* 18 U.S.C. ~ 922(a)(6); Transfer of
* Firearm in Furtherance of Drug
* Trafficking Crime and Crime of
* Violence, 18 U.S.c. ~ 924(h); Aiding and
* Abetting, 18 U.S.C. ~ 2; Forfeiture,
* 21 U.S.C. ~ 853, 28 U.S.c. ~ 2461(c),
* 18 U.S.C. ~ 924(d»)
*
*******
SUPERSEDING INDICTMENT
COUNT ONE
(Drug Conspiracy)
The Grand Jury for the District of Maryland charges that:
At all times relevant to this Superseding Indictment:
I. Defendant SINISA SIMIC, a resident of Virginia, was an active duty officer with
the Prince George's County Police Department ("PGCPD").

2. Defendant MIRZA KUNJUNDZIC was a resident of Virginia.
3. Between in or about September 2009 and in or about January 20 I0, in the District of
Maryland and elsewhere, the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
did knowingly conspire with each other and others known and unknown to the Grand Jury to
distribute and possess with intent to distribute 500 grams or more of a mixture or substance
containing a detectable amount of cocaine, a Schedule II controlled substance.
21 U.S.C. 9 846
2
COUNT SEVEN
(Possession of a Firearm in Furtherance of a Crime of Violence)
The Orand Jury for the District of Maryland further charges:
I. Paragraphs I and 2 of Count One and Paragraphs 2 and 3 of Count Two are
COUNT TWO
(Hobbs Act Conspiracy)
The Orand Jury for the District of Maryland further charges that:
I. Paragraphs I and 2 of Count One are incorporated here.
2. Maryland and Virginia imposed state taxes on the salc of cigarettes. Maryland
imposed a $2.00 sales tax on each pack of cigarettes. Virginia imposed a $0.30 sales tax on each
pack of cigarettes. The United States Department of the Treasury imposed a federal excise tax of
$1.01 on the sale of each pack of cigarettes.
3. Each pack of cigarettes sold in Maryland and Virginia was required to contain state
tax stamps indicating that state taxes had been paid.
4. Between in or about September 2009 and in or about January 20 I0, in the District of
Maryland and elsewhere, the defendants,
SINISA SIMIC, and

MIRZA KUN,JUNDZIC,
did knowingly, willfully, and unlawfully conspire with each other, others, and public officials known
and unknown to the Orand Jury to obstruct, delay, and affect commerce, and the movement of
articles and commodities in commerce, by extortion in the form ofpublic officials obtaining, under
color of official right, the property of others with their consent and not due to the officials and their
offices, to wit, by agreeing that certain individuals would provide things of value, including money,
to public officials, including defendant SINISA SIMIC, in rcturn for ofticial acts involving the
enforcement of state and federal laws by POCPD, and the transport and distribution of untaxed
cigarettes in Maryland, Virginia and elsewhere.
18 U.S.C. S 1951(a)
3
COUNT THREE
(Firearm Conspiracy)
The Grand Jury for the District of Maryland further charges:
2. Between in or about September 2009 and in or about January 20 I0, in thc District
of Maryland and elsewhere, the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
did knowingly, willfully and unlawfully conspire with each other and other persons, known and
unknown to the Grand Jury, to knowingly, intentionally and unlawfully possess firearms,
including a Taurus 9mm semi-automatic handgun and a .50 caliber, Israeli Military Industries,
Model Desert Eagle, handgun, Serial Number 32203531, in furtherance of a drug trafficking
crime and a crime of violence for which they may be prosecuted in a court of the United States,
to wit, conspiracy to possess with intent to distribute controlled substances, in violation of
Title 21, United States Code, Section 846, and conspiracy to commit extortion under color of
official right, in violation of Title 18, United States Code, Section 1951(a), as set forth in Counts
One and Two of this Superseding Indictment and incorporated here.
18 U.S.C. 9 924(0)
4
COUNT FOUR
(Hobbs Act - Extortion Under Color of Offici:t1 Rigbt)
The Grand Jury for the District of Maryland further charges that:
incorporated here.
2. On or about September 9, 2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, and

MIRZA KUN,JUNDZIC,
did knowingly obstruct, delay, and affect commerce, and the movement of articles and commodities
in commerce, by extortion in the fonn of public officials obtaining, under color of official right, the
property of others with their consent and not due to the officials and their offices, to wit, by agreeing
that certain individuals known and unknown to the Grand Jury would provide things of value,
including money, to public officials, including defendant SINISA SIMIC, in return for using their
official authority and influence to ensure the safe transport and distribution of untaxed cigarettes in
Maryland, Virginia, and elsewhere, and official acts involving the enforcement of state and federal
laws by the PGCPD.
18 U.S.C. ~ 1951
18 U.S.C. ~ 2
5
COUNT FIVE
(I'ossession of a Firearm in Furtherance of a Crime of Violence)
incorporated here.
2. On or about September 9, 2009, in the District of Maryland and elsewhere, the
defendants,
SINISA SIMIC, and

MIRZA KUN.JUNDZIC,
did knowingly possess a firearm, to wit, a Taurus 9mm semi-automatic handgun, in furtherance of
a crime of violence for which they may be prosecuted in a court of the United States, to wit, extortion
under color of official right, in violation of Title 18, United States Code, Section 1951, as set forth
in Count Four of this Superseding Indictment and incorporated here.
18 U.S.C. S 924(c)
18 U.S.C. S2
6
COUNT SIX
(Hobbs Act - Extortion Under Color of Official Right)
I. Paragraphs 1 and 2 of Count One and Paragraphs 2 and 3 of Count Two are
incorporated here.
2. On or about September 14,2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
in commerce, by extortion in the form of public officials obtaining, under color of official right, the
that certain individuals known and unknown to the Orand Jury would provide things of value,
laws by the PO CPO.
18 U.S.C. S1951
18 U.S.C. S2
7
COUNT SEVEN
1. Paragraphs 1 and 2 of Count One and Paragraphs 2 and 3 of Count Two are
incorporated here.
2. On or about September 14, 2009, in the District of Maryland and elsewhere, the
defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
under color of official right, in violation of Title 18, United States Code, Section 1951 , as set forth
in Count Six of this Superseding Indictment and incorporated here.
18 U.S.C. S 924(c)
18 U.S.C. S2
I~__
I
COUNT EIGHT
(Distribution of Cocaine)
1. Paragraphs I and 2 of Count One are incorporated here.
2. On or about October 7, 2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMICt and

MIRZA KUNJUNDZIC,
did knowingly and intentionally distribute a quantity of a mixture or substance containing a
detectable amount of cocaine, a Schedule II controlled substance.
21 U.S.c. 9841(a)(I)
18 U.S.C. 9 2
9
COUNT NINE
The Grand Jury for the District of Maryland further chargcs that:
1. Paragraphs I and 2 of Count One and Paragraphs 2 and 3 of Count Two are
incorporated hcrc.
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
including money, to public officials, including defendant SINISA SIMI C, in return for using their
official authority and influence to ensure the safe transport and distribution of untaxcd cigarcttes in
laws by the PGCI'D.
18 U.S.C. S195\
18 U.S.C. S2
10
COUNT TEN
(Possession of a Firearm in Furtherance of a Drug
Trafficking Crime and a Crime of Violence)
incorporated here.
2. On or about October 7, 2009, in the District of Maryland and elsewhere, the

defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
a drug trafficking crime and a crime of violence for which they may be prosecuted in a court of the
United States, to wit, distribution of cocaine, in violation of Title 21, United States Code, Section
841 (a)(I), and extortion under color of official right, in violation of Title 18, United States Code,
Section 1951, as set forth in Counts Eight and Nine of this Superseding Indictment and incorporated
here.
18 U.S.C. Ii 924(c)
18 U.S.C. Ii 2
II
COUNT ELEVEN
1. Paragraphs I and 2 of Count One arc incorporated here.
2. On or about October 22,2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
21 U.S.C. S 841(a)(I)
18 U.S.C. S2
12
COUNT TWELVE
incorporated here.
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
laws by the POCPD.
18 U.S.C. ~ 1951
18 U.S.C. ~ 2
13
COUNT THIRTEEN
incorporated here.
defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
841 (a)( I), and extortion under color of official right, in violation of Title 18, United States Code,
Section 1951, as set forth in Counts Eleven and Twelve of this Superseding Indictment and
incorporated here.
18 U.S.C. ~ 924(c)
18 U.S.C. ~ 2
14
COUNT FOURTEEN
I. Paragraphs 1 and 2 of Count One and Paragraphs 2 and 3 of Count Two are
incorporated here.
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
official authority and influence to ensure the safe transport and distribution of untax cd cigarettes in
laws by the POCPD.
18 U.S.C. S 1951
18 U.S.C. S2
15
COUNT FIFTEEN
incorporated here.
defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
under color of ofticial right, in violation of Title 18, United States Code, Section 1951, as set forth
in Count Fourteen of this Superseding Indictment and incorporated here.
18 U.S.C. S 924(c)
18 U.S.C. S2
16
COUNT SIXTEEN
I. Paragraphs I and 2 of Count One are incorporated herc.
2. On or about November 12,2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, anll

MIRZA KUNJUNDZIC,
21 U.S.C. S 841(a)(I)
18 U.S.C. S2
17
COUNT SEVENTEEN
(Hobbs Act - Extortion Undcr Color of Official Right)
1. Paragraphs I and 2 of Count One and Paragraphs 2 and 3 of Count Two arc
incorporated here.
2. On or about November 12,2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
did knowingly obstruct, delay, and affect commerce, and the movemcnt of articles and commodities
laws by the POCPD.
18 U.S.C. ~ 1951
18 U.S.C. ~ 2
18
COUNT EIGHTEEN
Trafficking Crime and II Crime of Violence)
incorporated here.
2. On or about Novcmber 12, 2009, in the District of Maryland and elsewhere, the
defendants,
SINISA SIMIC, and

MIRZA KUNJUNJ)ZIC,
841 (a)(I), and extortion under color of official right, in violation of Title 18, United States Code,
Section 1951, as set forth in Counts Sixteen and Seventeen of this Superseding Indictment and
incorporated here.
18 U.S.C. ~ 924(c)
18 U.S.C. ~ 2
19
COUNT NINETEEN
1. Paragraphs I and 2 of Count One and Paragraphs 2 and 3 of Count Two are
incorporated here.
2. On or about December 3, 2009, in the District of Maryland and elsewhere,
the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
did knowingly obstruct, delay, and affect commerce, and the movemcnt of articlcs and commodities
in commerce, by cxtortion in the form of public officials obtaining, under color of official right, the
Maryland, Virginia, and elsewhere, and official acts involving the enforcement of state and fedcral
laws by the PGCPD.
18 U.S.C. S 1951
18 U.S.C. S2
20
COUNT TWENTY
incorporated here.
2. On or about December 3, 2009, in the District of Maryland and elsewhere, the
defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
under color of official right, in violation of Title 18, United States Code, Section 1951, as set forth
in Nineteen of this Superseding Indictment and incorporated here.
18 U.S.C. 9924(c)
18 U.S.c. 92
21
COUNT TWENTY-ONE
(False Statement During Purchase of a Firearm)
2. In or about December 2009, in the District of Maryland, the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
in connection with the acquisition of a firearm, namely a .50 caliber, Israeli Military Industries,
Model Desert Eagle, handgun, Serial Number 32203531, from Engage Armament, a licensed dealer
of firearms, did knowingly made a false and fictitious oral and written statement to Engage
Armament, which statement was intended and likely to deceive Engage Armament, as to a fact
material to the lawfulness of such acquisition of the said firearm by Defendant SINISA SIMIC, in
that Defendant SINISA SIMIC represented that the purchase of the firearm was for his lise, when
in fact he knew that he was purchasing said firearm at the direction of and for usc by Defendant
MIRZA KUNJUNDZIC.
18 U.S.C. S 922(a)(6)
18 U.S.C. S2
22
COUNT TWENTY-TWO
(Transfer of a Firellrm in Furtherance of a Drug
2. In or about December 2009, in the District of Maryland and elsewhere, the
defendants,
SINISA SIMIC, and

MIRZA KUN,JUNDZIC,
did knowingly transfer a fircarm, that is, a .50 caliber, Israeli Military Industries, Model Desert
Eagle, handgun, Serial Number 32203531, knowing that the firearm would be used in furtherance
of a drug trafficking crime and a crime of violence, to wit, conspiracy to possess with intent to
distribute controlled substances, in violation of Title 21, United States Code, Section 846, and
conspiracy to commit extortion under color of omeial right, in violation of Title 18, United States
Code, Section 1951(a), as set forth in Counts One and Two of this Superseding Indictment and
incorporated here.
18 U.S.C. S 924(h)
18 U.S.C. S2
23
FORFEITURE ALLEGATION
Narcotics Forfeiture
I. As a result of the offenses set forth in Counts One, Eight, Eleven, and Sixteen of the
Superseding Indictment, the defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
shall forfeit to the United States any and all property constituting, or derived from, any proceeds
obtained directly or indirectly, as a result of said ofTenses, and all property traceable to such property
obtained directly or indirectly as a result of any such violation.
2. If any of the property described in paragraph 1 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 person;
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 subdivided
without difficulty; it is the intent of the United States, pursuant to Title 21,
United States Code, Section 853(p) to seek forfeiture of any other property
of the defendant.
24
Firearms Forfeiture
3. As a result of the offenses set forth in Counts Three, Five, Seven, Ten, Thirteen,
Fifteen, Eighteen, Twenty, Twenty-One, and Twenty-Two of the Superseding Indictment, the
defendants,
SINISA SIMIC, and

MIRZA KUNJUNDZIC,
shall forfeit to the United States the firearms identified in those counts of the Superseding Indictment
and involved in said offenses.
2 I U.S.c. S 853
28 U.S.C. S 246 I(c)
18 U.S.C. S 924(d)
Rod J. R enstein
United Sta es Attorney
A TRUE BILL: ...--... /I
SIGNATURE REDACTED
I Date: March~, 2011
./ For(Json
25

Sinisa Simic Indictment

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Case 8:10-cr-00639-PJM Document 36 Filed 03/14/11 Page 1 of 25

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA *

The Grand Jury for the District of Maryland charges that:

At all times relevant to this Superseding Indictment:

the Prince George's County Police Department ("PGCPD").

2. Defendant MIRZA KUNJUNDZIC was a resident of Virginia.

Maryland and elsewhere, the defendants,

SINISA SIMIC, and

containing a detectable amount of cocaine, a Schedule II controlled substance.

The Orand Jury for the District of Maryland further charges:

I. Paragraphs I and 2 of Count One are incorporated here.

$1.01 on the sale of each pack of cigarettes.

tax stamps indicating that state taxes had been paid.

Maryland and elsewhere, the defendants,

SINISA SIMIC, and

cigarettes in Maryland, Virginia and elsewhere.

The Grand Jury for the District of Maryland further charges:

I. Paragraphs I and 2 of Count One are incorporated here.

of Maryland and elsewhere, the defendants,

SINISA SIMIC, and

to wit, conspiracy to possess with intent to distribute controlled substances, in violation of

One and Two of this Superseding Indictment and incorporated here.

2. On or about September 9, 2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

laws by the PGCPD.

The Grand Jury for the District of Maryland further charges:

2. On or about September 9, 2009, in the District of Maryland and elsewhere, the

SINISA SIMIC, and

in Count Four of this Superseding Indictment and incorporated here.

2. On or about September 14,2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

laws by the PO CPO.

The Grand Jury for the District of Maryland further charges:

SINISA SIMIC, and

in Count Six of this Superseding Indictment and incorporated here.

The Grand Jury for the District of Maryland further charges:

1. Paragraphs I and 2 of Count One are incorporated here.

2. On or about October 7, 2009, in the District of Maryland and elsewhere,

SINISA SIMICt and

did knowingly and intentionally distribute a quantity of a mixture or substance containing a

detectable amount of cocaine, a Schedule II controlled substance.

2. On or about October 7, 2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

laws by the PGCI'D.

The Grand Jury for the District of Maryland further charges:

2. On or about October 7, 2009, in the District of Maryland and elsewhere, the

SINISA SIMIC, and

The Grand Jury for the District of Maryland further charges:

1. Paragraphs I and 2 of Count One arc incorporated here.

2. On or about October 22,2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

did knowingly and intentionally distribute a quantity of a mixture or substance containing a

detectable amount of cocaine, a Schedule II controlled substance.

2. On or about October 22, 2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

laws by the POCPD.

The Grand Jury for the District of Maryland further charges:

SINISA SIMIC, and

2. On or about October 29, 2009, in the District of Maryland and elsewhere,

SINISA SIMIC, and

laws by the POCPD.

The Grand Jury for the District of Maryland further charges: