BGF RICO Indictment

CJF/JMW
USAO2008R00860
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA * FILED UNDER SEAL

*
v. *
* CRIMINAL NO. WDQ 09-183
ERIC BROWN, *
a/k/a “E,” * (Conspiracy to Participate in a
a/k/a “EB,” * Racketeering Enterprise, 18 U.S.C.
RAY OLIVIS, * § 1962(d); Conspiracy to Distribute and
a/k/a “Ronnie Hargrove,” * Possess with Intent to Distribute
a/k/a “Uncle Ray,” * Controlled Substances, 21 U.S.C. § 846;
a/k/a “Unc,” * Conspiracy to Launder Monetary
a/k/a “Ray Ray,” * Instruments, 18 U.S.C. § 1956(h);
DEITRA DAVENPORT, * Conspiracy to Interfere with Commerce
a/k/a “Sister D,” * by Robbery, 18 U.S.C. § 1951;
RAINBOW WILLIAMS, * Possession of a Firearm in Furtherance
RANDOLPH EDISON, * of a Crime of Violence, 18 U.S.C. §
a/k/a “Uncle Rudy,” * 924(c); Possession of a Firearm by a
KEVIN GLASSCHO, * Felon, 18 U.S.C. § 922(g); Possession of
a/k/a “KG,” * a Firearm in Furtherance of a Drug
CASSANDRA ADAMS, * Trafficking Offense; 18 U.S.C. § 924(c);
ZACHARY NORMAN, * Aiding and Abetting, 18 U.S.C. § 2)
a/k/a “Zack,” *
ALICIA SIMMONS, *
TODD DUNCAN, *
a/k/a “Donnie,” *
KIMBERLY McINTOSH, *
a/k/a “Kim McCintosh,” *
a/k/a “Sister Kim” *
a/k/a “Sis,” *
a/k/a “Kimberly Jones,” *
DUCONZE CHAMBERS, *
a/k/a “Ducon,” *
a/k/a “Dookie,” *
DAVON McFADDEN, *
a/k/a “Ben,” *
JAMES HARRIED, *
a/k/a “Smiley,” *
ERIK USHRY, *
a/k/a “E,” *
*
Defendants, *
*
*******
SUPERCEDING INDICTMENT
COUNT ONE
(Conspiracy to Participate in Racketeering Activity)
The Grand Jury for the District of Maryland charges that:
Introduction
1. The Black Guerilla Family (“BGF”), also known as the “Black Family,” the
“Family” or the “Black Vanguard,” is a nationwide gang operating in prison facilities and major
cities throughout the United States. Founded in California in the 1960s and introduced into the
Maryland correctional system in the mid 1990s, BGF is now one of the most powerful gangs in
the state. Although traditionally a prison-based gang, BGF in Maryland is increasingly active
and well organized on the streets of Baltimore City, Maryland.
2. At all times relevant to this Indictment, BGF factions existed in various prison
facilities in Maryland, including, among others, North Branch Correctional Institution (“NBCI”),
Western Correctional Institution (“WCI”), Eastern Correctional Institution (“ECI”), Roxbury
Correctional Institution, Maryland Correctional Institution – Jessup (“MCI-J”), Maryland
Correctional Institution – Hagerstown, Baltimore City Correctional Center (“BCCC”), and
Metropolitan Transition Center (“MTC”), Baltimore City Detention Center (“BCDC”).
3. At all times relevant to this Indictment, BGF factions existed throughout
Baltimore City.
4. At all times relevant to this Indictment, BGF leaders, collectively known as the
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“Supreme Bush,” directed the activities of BGF members in Maryland. Reflecting the
paramilitary nature of the BGF, the “Supreme Bush” was organized according to a strict rank
structure which included a Supreme Commander, Lieutenant Commander and Ministers of
Justice, Defense, Finance, Intelligence and Education. Within each correctional institution and
neighborhood of Baltimore City in which BGF had established a presence, a local organizational
structure was put in place. These so-called “Bubble Regimes” mirrored the structure of the
Supreme Bush and so included its own Commander, Lieutenant Commander and various
ministers. The commander of each “Bubble Regime” was appointed by, and reported to, the
Supreme Bush.
5. At all times relevant to this Indictment, BGF members were required to follow
a strict code of conduct. BGF members who failed to adhere to this code were subjected to
various forms of discipline, to include physical violence.
6. At all times relevant to this Indictment, BGF members were expected to recruit
new members (known as “Seeds”) into BGF and familiarize those new members with the
history, doctrine and code of conduct of the organization.
7. At all times relevant to this Indictment, BGF members engaged in various
criminal activities on the streets of Baltimore City, including, but not limited to, drug-trafficking,
extortion, robbery, bribery and money laundering, retaliation against witnesses and obstruction
of justice.
8. At all times relevant to this Indictment, BGF members engaged in various
criminal activities inside the Maryland Correctional System, including but not limited to, drug-
trafficking, extortion, robbery, bribery and money laundering, retaliation against witnesses and
obstruction of justice.
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9. At all times relevant to this Indictment, members of BGF arranged for the
smuggling of narcotics, cellular telephones, tobacco, food and other contraband prohibited by
correctional facility regulations into Maryland correctional facilities.
10. At all times relevant to this Indictment, members of BGF recruited and paid
employees of prison facilities, including corrections officers, to assist BGF and its members in
the smuggling of contraband, the collection of intelligence and in the concealment of BGF’s
criminal activities.
11. At all times relevant to this Indictment, BGF members, with the assistance of
corrections officers and employees, engaged in an extortion scheme by which prison inmates
were required to pay for “protection.” Inmates who refused to pay for such “protection” were
targeted for violence by members of BGF.
12. At all times relevant to this Indictment, BGF members used the funds
procured through drug trafficking, extortion, and the sale of contraband to enrich themselves and
to further the activities of the organization, including, but not limited to drug-trafficking.
13. At all times relevant to this Indictment, BGF protected and broadened their
control of the Baltimore City drug trade through violence and intimidation.
14. At all times relevant to this Indictment, BGF protected and broadened their
control of the underground “prison economy” in Maryland correctional facilities through
violence and intimidation.
15. At all times relevant to this Indictment, the following defendants were
members or associates of BGF: ERIC BROWN, a/k/a "E," a/k/a "EB," RAY OLIVIS, a/k/a
"Ronnie Hargrove," a/k/a "Uncle Ray," a/k/a "Unc," a/k/a "Ray Ray," DEITRA
DAVENPORT, a/k/a "Sister D," RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a
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"Uncle Rudy," ZACHARY NORMAN, a/k/a "Zack," KEVIN GLASSCHO, a/k/a "KG,"
ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a
"Kim McCintosh," a/k/a "Sister Kim," a/k/a "Sis," a/k/a "Kimberly Jones," DUCONZE
CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," DAVON McFADDEN, a/k/a "Ben," JAMES
HARRIED, a/k/a "Smiley," and ERIK USHRY, a/k/a "E."
The Racketeering Enterprise
16. BGF, including its leadership, members and associates, constituted an
“enterprise” as defined in Section 1961(4) of Title 18, United States Code, 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
functioned as a continuing unit for the common purpose of achieving the objectives of the
enterprise.
Purposes of the Enterprise
17. The purposes of the enterprise included the following:
a. Preserving and protecting the power, territory and profits of the
enterprise through the use of violence, threats of violence, intimidation, extortion, armed
robbery, money laundering, bribery, and narcotics trafficking;
b. Promoting and enhancing the enterprise and its members’ and
associates’ activities through the use of violence, threats of violence, intimidation, extortion,
armed robberies, money laundering, bribery, and narcotics trafficking, retaliation against
witnesses and obstruction of justice;
c. Keeping victims and potential victims in fear of the enterprise and in
fear of its members and associates, through violence and threats of violence;
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d. Generating financial profits for the furtherance of the enterprise in
Maryland;
e. Providing financial support and information to gang members,
including those who were incarcerated for committing acts of violence or other offenses; and
f. Providing assistance to other gang members who committed crimes for
and on behalf of the gang in order to hinder, obstruct and prevent law enforcement officers from
identifying the offender, apprehending the offender and trying and punishing the offender.
The Racketeering Conspiracy
18. Beginning on a date unknown to the Grand Jury, but at least in or about 2006,
and continuing through the date of this Indictment, in the District of Maryland and elsewhere,
the defendants,
ERIC BROWN,
a/k/a “E,”
a/k/a “EB,”
RAY OLIVIS,
a/k/a “Ronnie Hargrove,”
a/k/a “Uncle Ray,”
a/k/a “Unc,”
a/k/a “Ray Ray,”
DEITRA DAVENPORT,
a/k/a “Sister D,”
RAINBOW WILLIAMS,
RANDOLPH EDISON,
a/k/a “Uncle Rudy,”
KEVIN GLASSCHO,
a/k/a “KG,”
ZACHARY NORMAN,
a/k/a “Zack,”
ALICIA SIMMONS,
TODD DUNCAN,
a/k/a "Donnie,"
KIMBERLY McINTOSH,
a/k/a "Kim McCintosh,"
a/k/a "Sister Kim,"
a/k/a "Sis,"
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a/k/a "Kimberly Jones,"
DUCONZE CHAMBERS,
a/k/a "Ducon,"
a/k/a "Dookie,"
DAVON McFADDEN,
a/k/a "Ben,"
JAMES HARRIED,
a/k/a "Smiley,"
ERIK USHRY, a/k/a "E,"
each being a person employed by and associated with BGF, an enterprise engaged in, and the
activities of which affected, interstate and foreign commerce, together with others known and
unknown to the Grand Jury, did knowingly and intentionally conspire to conduct and participate,
directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of
racketeering activity, as defined in Sections 1961(1) and (5) of Title 18, United States Code,
which pattern of racketeering activity consisted of multiple acts involving narcotics trafficking,
indictable under 21 U.S.C. §§ 841 and 846; multiple acts involving robbery in violation of
Maryland Criminal Law Code Section 3-402 and the Common Law of Maryland, extortion, in
violation of Maryland Criminal Law Code Section 3-701, and bribery in violation of Maryland
Criminal Law Code Section 9-201; and multiple acts indictable under 18 U.S.C. § 1513
(retaliation against a witness or an informant); 18 U.S.C. § 1956(h) (money laundering); and 18
U.S.C. § 1951 (interference with commerce by robbery).
19. It was 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.
Manner and Means of the Conspiracy
20. Among the manner and means by which the defendants and others conducted
and participated in the conduct of the conspiracy were the following:
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a. BGF members and associates distributed controlled substances,
including heroin to customers in the Baltimore area.
b. BGF members and associates smuggled controlled substances,
including heroin, to incarcerated BGF members for distribution within Maryland prison
facilities.
c. BGF members and associates smuggled tobacco, cellular telephones,
food and other contraband to incarcerated BGF members for distribution within Maryland prison
facilities.
d. Corrections officers and other employees, including ALICIA
SIMMONS and others, assisted incarcerated BGF members in smuggling drugs and other
contraband into prison facilities, often in exchange for money and other compensation.
e. BGF members used the proceeds of extortion, and the sale of narcotics
and contraband to enrich themselves and to further the activities of the organization, to include
narcotics trafficking.
f. BGF members laundered the proceeds of their illicit activities through
the use of pre-paid debit cards (commonly referred to as “Green Dot Cards”), gift cards and other
means.
g. BGF members used violence and the threat of violence to coerce
incarcerated persons to pay protection money to BGF.
h. BGF members committed and caused to be committed acts of violence
in furtherance of the gang’s activities, to include robberies of drug dealers and others, assaults of
rival gang members and individuals suspected of cooperating with law enforcement, and assaults
of fellow BGF members for violations of BGF rules and protocols.
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i. BGF members used contraband cellular telephones in prison facilities to
coordinate the smuggling of contraband into the prison facilities; to notify one another about
gang members who were arrested or incarcerated; to discuss police interactions with gang
members; to share with one another the identities of individuals who may be cooperating with
law enforcement and propose actions to be taken against those individuals; and to intimidate
potential witnesses.
j. BGF members and associates conducted counter-surveillance of law
enforcement officers in an attempt to prevent law enforcement officers from detecting their
illegal activities.
k. BGF members and associates kept and maintained firearms to protect
themselves, to protect BGF assets (e.g., narcotics and the proceeds of BGF’s criminal activities),
and to commit acts of violence when necessary to protect or further the interests of the gang.
Overt Acts
21. In or about October 2006 to November 2006, ERIC BROWN ordered
the assault of a BGF member in retaliation for an unpaid debt owed to BGF.
22. In 2007, Corrections Officers at the Maryland Correctional Institution, Jessup
(“MCI-J”) smuggled narcotics, including heroin, to BGF members at the facility. BGF members
then sold the narcotics and a percentage of the proceeds of the sale of these narcotics were then
contributed to the BGF’s central “treasury” at the facility. In return for smuggling contraband
into the facility, Corrections Officers received either cash or pre-paid debit cards from BGF
members.
23. In 2007, ALICIA SIMMONS, a Corrections Officer, regularly smuggled
narcotics to known BGF members incarcerated at MCI-J. In return for smuggling the contraband
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into the facility, SIMMONS received cash and pre-paid debit cards.
24. In 2007, ALICIA SIMMONS, a Corrections Officer, smuggled a cellular
telephone to a BGF members incarcerated at MCI-J. In return for smuggling the contraband into
the facility, SIMMONS received cash and pre-paid debit cards.
25. Between in or about September 2007 and October 2007, RAY OLIVIS
transferred approximately $1,185.00 into a pre-paid debit card account. These funds
represented, at least in part, the proceeds of the BGF’s illegal activities, to include extortion and
drug trafficking.
26. Between in or about 2008 and 2009, Corrections Officers smuggled
marijuana to BGF members incarcerated at the Baltimore City Detention Center (“BCDC”).
BGF members then sold the marijuana and a percentage of the proceeds of the sales of that
marijuana were contributed to the BGF “treasury” at the facility.
27. Between in or about 2008 and 2009, Corrections Officers smuggled cell
phones and alcohol into BCDC at the direction of BGF members. In return for smuggling
contraband into the facility, guards received either cash or pre-paid debit cards from BGF
members.
28. Between in or about April 2008 and December 2008, ERIC BROWN
drug trafficking.
29. Between in or about April 2008 and May 2008, DEITRA DAVENPORT
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drug trafficking.
30. Between in or about July 2008 and April 2009, a Corrections Officer
affiliated with BGF transferred approximately $750.00 into a pre-paid debit card account. These
funds represented, at least in part, payments by BGF members to the Corrections Officer for
assistance in facilitating the gang’s activities.
31. Between in or about October 2008 and May 2009, a Corrections Officer
affiliated with BGF transferred approximately $1,615.00 into a pre-paid debit card account.
These funds represented, at least in part, payments by BGF members to the Corrections Officer
for assistance in facilitating the gang’s activities.
32. Between in or about November 2008 and February 2009, RAINBOW
WILLIAMS transferred approximately $2,185.00 into a pre-paid debit card account. These
funds represented, at least in part, the proceeds of the BGF’s illegal activities, to include
extortion and drug trafficking.
33. On or about November 18, 2008, during an intercepted phone conversation, a
BGF member at NBCI asked ERIC BROWN to arrange for a female courier to smuggle
contraband into NBCI.
34. Between in or about January 2009 and March 2009, a Corrections Officer
affiliated with BGF, smuggled contraband to BGF members at MTC. This contraband was
either used by BGF members or sold to other inmates and the proceeds used to further BGF
activities.
35. Between in or about October 2008 and March 2009, a Corrections Officer
affiliated with BGF, smuggled contraband to BGF members inside of Maryland correctional
facilities. This contraband was either used by BGF members or sold to other inmates and the
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proceeds used to further BGF activities.
36. Between in or about January 2009 and March 2009, ERIC BROWN directed
a Corrections Officer affiliated with BGF to smuggle heroin to BGF members at MTC.
37. In or about January 2009 to April 2009, ERIC BROWN extorted a
fellow inmate for protection from violence at the hands of BGF members.
38. Between in or about January 2009 to April 2009, ERIC BROWN assaulted
an inmate who failed to make a timely extortion payment to BGF.
39. In February 2009, during an intercepted phone conversation, ERIC
BROWN directed DEITRA DAVENPORT to deliver “five cans” of suspected contraband to
RAINBOW WILLIAMS who would, in turn, have the contraband smuggled into MTC.
BROWN also instructed DAVENPORT to give WILLIAMS $300 for payment to a
corrections employee who was helping BGF smuggle contraband into the prison.
40. On or about February 23, 2009, ERIC BROWN provided $50.00 to a
Corrections Officer affiliated with BGF via pre-paid debit card.
41. On or about February 24, 2009, during an intercepted phone conversation,
ERIC BROWN requested that a correctional employee affiliated with BGF smuggle contraband
into MTC.
42. On or about February 25, 2009, during an intercepted phone conversation,
ERIC BROWN directed RAINBOW WILLIAMS to deliver suspected narcotics to a
Corrections Officer affiliated with BGF so that the Corrections Officer could smuggle the
narcotics into MTC.
43. On or about February 27, 2009, during an intercepted phone conversation, a
Corrections Officer affiliated with BGF informed ERIC BROWN that she had spent the money
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loaded onto her pre-paid debit card.
44. In or about March 2009, a Corrections Officer affiliated with BGF attempted
to smuggle two cell phones into MTC on behalf of ERIC BROWN.
45. On or about March 1, 2009, during an intercepted phone conversation with
another BGF member, ERIC BROWN explained that RAINBOW WILLIAMS had attempted
to smuggle contraband into BROWN at MTC via a pair of tennis shoes but that the attempt had
been discovered by corrections officials.
46. On or about March 1, 2009, during an intercepted phone conversation,
KEVIN GLASSCHO told ERIC BROWN that GLASSCHO and GLASSCHO’s wife,
CASSANDRA ADAMS, had spent the previous day distributing drugs to GLASSCHO’S
customers.
47. In or about March 2009 to April 2009, KEVIN GLASSCHO provided
heroin to BGF members in various Maryland correctional institutions.
48. On or about March 8, 2009, during an intercepted phone conversation, a
Corrections Officer affiliated with BGF explained to ERIC BROWN, that she had smuggled a
cellphone battery to an inmate and that the inmate wanted to contact BROWN.
49. On or about March 8, 2009, during an intercepted phone conversation, ERIC
BROWN and a federal inmate discussed the fact that ALICIA SIMMONS, a Corrections
Officer, was smuggling contraband into the prisoners at the MCAC. The federal inmate asked
BROWN to speak to SIMMONS about smuggling contraband into the facility on behalf of the
inmate.
ERIC BROWN directed a Corrections Officer affiliated with BGF to smuggle contraband into
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MTC. The Corrections Officer told BROWN, “Okay I’m going to work on that today.”
ERIC BROWN, RANDOLPH EDISON, RAY OLIVIS, and ZACHARY NORMAN,
discussed an attempted commercial robbery to have been committed by EDISON, NORMAN
and another individual. NORMAN, OLIVIS and EDISON discussed retaliating against a
suspected informant whose cooperation with law enforcement thwarted the attempted robbery.
OLIVIS promised to deal with the informant, telling NORMAN “We need to know where [the
informant] at. I’ll be on top of all of it.” During the same conversation, ZACHARY NORMAN
and RAY OLIVIS discussed plans to assault an inmate suspected of being involved in the
murder of NORMAN’s brother. OLIVIS told NORMAN, “Alright Bear, I’m already on top of
that man.”
KEVIN GLASSCHO instructed CASSANDRA ADAMS to return home so that she could help
GLASSCHO count the proceeds of the day’s drug transactions.
KEVIN GLASSCHO and CASSANDRA ADAMS discussed structuring the deposits of the
proceeds of narcotics sales in order to evade detection by law enforcement.
ERIC BROWN and another BGF member arranged for the delivery of contraband to an
unidentified individual outside of MTC who would then deliver the contraband to BROWN
inside of the prison.
55. Between on or about March 28, 2009 and April 14, 2009, $2,250.00 was
transferred into a pre-paid debit card account registered to KEVIN GLASSCHO and
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CASSANDRA ADAMS. These funds represented, at least in part, the proceeds of drug
trafficking.
56. In April 2009, during an intercepted phone conversation, ERIC BROWN
and DEITRA DAVENPORT discussed the smuggling of food, alcohol and cigars to BGF
members at MTC.
57. Between on or about April 1, 2009 and April 10, 2009, $2,000.00 was
transferred into a pre-paid debit card account registered to CASSANDRA ADAMS. These
funds represented, at least in part, the proceeds of drug trafficking by BGF and its associates.
58. On or about April 2, 2009, during an intercepted phone conversation, an
unidentified individual discussed paying KEVIN GLASSCHO for drugs via a pre-paid debit
card.
59. On or about April 5, 2009, during an intercepted phone conversation, RAY
OLIVIS, RAINBOW WILLIAMS and several other BGF members conducted a conference
call in which OLIVIS discussed day-to-day operations, violations of BGF protocols and
sanctions that should be ordered against members who had violated those protocols.
60. On or about April 9, 2009, during an intercepted phone conversation,
RAINBOW WILLIAMS arranged for the purchase of a quantity of drugs from an another
individual.
61. On or about April 13, 2009, RAINBOW WILLIAMS organized a meeting
of over 100 BGF members at Druid Hill Park in Baltimore. Attendees of the meeting possessed,
among other things, a firearm, BGF related promotional literature, BGF t-shirts emblazoned with
the slogan, "Revolution is the Only Solution," and a document listing BGF members who have
violated BGF rules and the sanctions imposed for those violations.
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62. On or about April 15, 2009, RAINBOW WILLIAMS possessed thirty-eight
rounds of .357 ammunition, as well as BGF promotional literature, manuals and lessons plans.
63. On or about April 15, 2009, KEVIN GLASSCHO and CASSANDRA
ADAMS possessed, at their home, BGF promotional materials, correspondence with
incarcerated individuals, a large sum of United States currency and a Taurus 9mm pistol.
64. On or about April 15, 2009, KEVIN GLASSCHO possessed, at a stash
location, approximately one hundred grams of heroin. GLASSCHO possessed the heroin with
the intent to distribute it.
65. On or about December 15, 2009, KIMBERLY McINTOSH sold five grams
of heroin to a fellow BGF member for $400.00.
66. On or about December 15, 2009, LAMONT CROOKS provided 20 grams
of heroin to ERIK USHRY and one gram of heroin to KIMBERLY McINTOSH.
67. On or about December 21, 2009, KIMBERLY McINTOSH sold a quantity
of heroin to a fellow BGF member for $800.00.
68. On or about December 28, 2009, during an intercepted telephone
conversation, DUCONZE CHAMBERS admitted that he was selling heroin for TODD
DUNCAN.
69. On or about February 8, 2010, during an intercepted telephone conversation,
DUCONZE CHAMBERS offered to assist another individual in finding a new source of
cocaine.
TODD DUNCAN and another individual discussed a drug debt owed to DUNCAN.
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an unidentified individual asked DUCONZE CHAMBERS if he knew of a Corrections Officer
that would assist in the smuggling of contraband into the Brockbridge Correctional Facility, a
Maryland correctional facility. CHAMBERS told the individual that he knew a corrections
officer that would be of assistance.
JAMES HARRIED was overheard directing an associate to sell a quantity of narcotics.
73. On or about March 2, 2010, during an intercepted telephone conversation,
JERMAIN DAVIS and TODD DUNCAN discussed DAVIS’s role in selling narcotics for
DUNCAN and DAVIS’s near arrest by the Baltimore Police Department for drug trafficking.
TODD DUNCAN and DAVON McFADDEN discussed whether McFADDEN was going to
participate in a drug transaction with an associate of DUNCAN.
DAVON McFADDEN called TODD DUNCAN to warn him that law enforcement was in the
vicinity of Biddle Street and Greenmount Avenue, an area where McFADDEN was selling
narcotics.
DAVON McFADDEN informed TODD DUNCAN that an associate named “Trap” had been
arrested shortly after obtaining narcotics from McFADDEN.
JERMAIN DAVIS told TODD DUNCAN that DAVIS had been processing narcotics provided
by DUNCAN, but that the quality of the drugs was poor. DAVIS then recommended adding a
new quantity of higher quality narcotics in order to improve the marketability of the finished
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product.
TODD DUNCAN and another individual discussed a commercial robbery and auto theft
committed by the individual. During the conversation, DUNCAN demanded that he be provided
with a “cut” of the proceeds.
TODD DUNCAN asked JERMAIN DAVIS to meet him at KIMBERLY McINTOSH’s home
and provide DUNCAN with empty gelatin capsules for packaging heroin.
TODD DUNCAN instructed JERMAIN DAVIS to recover a quantity of drugs from
KIMBERLY McINTOSH’s residence and deliver the drugs to DUNCAN. DAVIS was then
intercepted explaining to McINTOSH that DUNCAN needed the drugs stored at McINTOSH’s
home.
TODD DUNCAN and KIMBERLY McINTOSH discussed the quality of a recent supply of
heroin that DUNCAN and McINTOSH had received and processed.
TODD DUNCAN and KIMBERLY McINTOSH discussed DUNCAN selling heroin to
McINTOSH and DAVON McFADDEN.
JERMAIN DAVIS informed DUCONZE CHAMBERS that DAVIS was selling 300 to 400
units of heroin on behalf of TODD DUNCAN per day. DAVIS further informed CHAMBERS
that DUNCAN was providing low quality heroin for processing and sale and that DAVIS had to
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mix DUNCAN’s drugs with higher quality drugs he was receiving from another source in order
to improve the marketability of the heroin.
TODD DUNCAN directed JON BRICE to test the quality of heroin provided by DUNCAN. In
an intercepted phone conversation a short time later, BRICE informed DUNCAN that the
quality of the heroin was high.
TODD DUNCAN directed RONALD SCOTT to retrieve drug packaging paraphernalia from
KIMBERLY McINTOSH’s home and deliver it to DUNCAN.
TODD DUNCAN told JON BRICE that he needed access to BRICE’s home so that he could
mix and package a quantity of heroin.
KIMBERLY McINTOSH was overheard discussing her plan to have each BGF commander
raise $3,000 from his subordinates and transfer those funds to BGF’s central “treasury.”
JAMES HARRIED and DUCONZE CHAMBERS discussed attending a meeting of BGF
members at KIMBERLY McINTOSH’s residence.
TODD DUNCAN and JAMES HARRIED discussed collecting dues from fellow BGF
members in order to post the bail for an incarcerated member. These dues were paid, at least in
part, with the proceeds of BGF narcotics trafficking.
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TODD DUNCAN informed DAVON McFADDEN that JERMAIN DAVIS had been arrested
after law enforcement raided DAVIS’s home. McFADDEN reported that he had recently given
drugs to DAVIS.
DAVON McFADDEN was overheard directing DUCONZE CHAMBERS to collect $25.00
from each BGF member under CHAMBERS’s command. McFADDEN informed
CHAMBERS that McFADDEN would collect the money and forward the funds to BGF’s
central “treasury.”
JAMES HARRIED informed TODD DUNCAN that DAVON McFADDEN had collected
membership dues from BGF members and that he, HARRIED, would deliver a written record of
which BGF members had paid their fees to KIMBERLY McINTOSH. These dues were paid,
at least in part, with the proceeds of BGF narcotics trafficking.
TODD DUNCAN and another BGF member discussed the identification by law enforcement of
KIMBERLY McINTOSH as a high-ranking BGF member and the danger that McINTOSH
would pose to the organization if she decided to cooperate with law enforcement.
94. On or about April 12, 2010, DAVON McFADDEN possessed handwritten
records of drug transactions, several gelatin capsules of heroin and $2,536.00 in U.S. currency.
95. On or about April 12, 2010, KIMBERLY McINTOSH possessed at her
place of work, a ballistic vest (body armor) as well as letters to BGF members, BGF promotional
literature and BGF administrative paperwork.
96. On or about April 12, 2010, KIMBERLY McINTOSH possessed at her
20
home, located at 1120 Homewood Avenue, Baltimore, Maryland, letters to BGF members, BGF
promotional literature, and BGF administrative paperwork.
NOTICE OF SPECIAL SENTENCING FACTORS
Beginning in or about 2006, and continuing through and including the date of this indictment,
both dates being approximate and inclusive, within the District of Maryland and elsewhere, the
defendants, ERIC BROWN, a/k/a "E," a/k/a "EB," RAY OLIVIS, a/k/a "Ronnie
Hargrove," a/k/a "Uncle Ray," a/k/a "Unc," a/k/a "Ray Ray," DEITRA DAVENPORT,
a/k/a "Sister D," RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a "Uncle Rudy,"
ZACHARY NORMAN, a/k/a "Zack," KEVIN GLASSCHO, a/k/a "KG," ALICIA
SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a "Kim
McCintosh," a/k/a "Sister Kim," a/k/a "Sis," a/k/a "Kimberly Jones," DUCONZE
CHAMBERS, a/k/a "Ducon," a/k/a "Dookie," DAVON McFADDEN, a/k/a "Ben," JAMES
HARRIED, a/k/a "Smiley," and ERIK USHRY, a/k/a "E," knowingly and intentionally
conspired to distribute and possess with the intent to distribute one kilogram or more of a
mixture or substance containing a detectable amount of heroin, a Schedule I controlled
dangerous substance in violation of Title 21, United States Code, Sections 846 and 841(a)(1)
and (b)(1)(A).
18 U.S.C. § 1962
21
COUNT TWO
(Conspiracy to Distribute and Possess with the

Intent to Distribute Controlled Substances)
The Grand Jury for the District of Maryland further charges that:
1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are re-
alleged and incorporated by reference as though fully set forth herein.
2. Beginning on a date unknown to the Grand Jury, but at least in or about
2006 through the date of this Indictment, in the District of Maryland and elsewhere, the
defendants,
ERIC BROWN,
a/k/a “E,”
a/k/a “EB,”
RAY OLIVIS,
a/k/a “Unc,”
DEITRA DAVENPORT,
RAINBOW WILLIAMS,
RANDOLPH EDISON,
ZACHARY NORMAN,
a/k/a “Zack”
KEVIN GLASSCHO,
a/k/a “KG,”
CASSANDRA ADAMS,
ALICIA SIMMONS,
TODD DUNCAN,
a/k/a "Donnie,"
KIMBERLY McINTOSH,
a/k/a "Kim McCintosh,"
a/k/a "Sister Kim,"
a/k/a "Sis,"
a/k/a "Kimberly Jones,"
DUCONZE CHAMBERS,
a/k/a "Ducon,"
a/k/a "Dookie,"
22
DAVON McFADDEN,
a/k/a "Ben,"
JAMES HARRIED,
a/k/a "Smiley,"
ERIK USHRY, a/k/a "E,"
did knowingly and intentionally combine, conspire, confederate, and agree with each other and
with others known and unknown to the Grand Jury to distribute and possess with intent to
distribute one kilogram or more of a mixture or substance containing a detectable amount of
heroin, a Schedule I controlled substance, in violation of Title 21, United States Code, Section
841(a)(1).
21 U.S.C. § 846
23
COUNT THREE
(Conspiracy to Commit Money Laundering)
1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are
re-alleged and incorporated by reference as though fully set forth herein.
2. From at least September 2007 to the date of this Indictment, in the District
of Maryland and elsewhere, the defendants,
ERIC BROWN,
a/k/a “E,”
a/k/a “EB,”
RAY OLIVIS,
a/k/a “Unc,”
DEITRA DAVENPORT,
RAINBOW WILLIAMS,
RANDOLPH EDISON,
KEVIN GLASSCHO,
a/k/a “KG,”
CASSANDRA ADAMS,
did knowingly and intentionally combine, conspire, confederate, and agree with each other and
with others known and unknown to the Grand Jury to conduct and attempt to conduct financial
transactions affecting interstate commerce, by transferring funds by wire or other means which
in fact involved the proceeds of specified unlawful activities, that is, extortion, narcotics
trafficking, and bribery knowing that the property involved in the financial transaction
represented the proceeds of some form of unlawful activity and with the intent to conceal and
promote the carrying on of the specified unlawful activities, to wit: extortion, narcotics
trafficking, and bribery, in violation of Title 18 United States Code, Section 1956(a)(1).
24
18 U.S.C. § 1956(h)
25
COUNT FOUR
(Conspiracy to Interfere with Commerce Through Robbery)
1. Paragraphs 1 to 17 and 20 to 96 of Count One of this Indictment are re-alleged
and incorporated by reference as though fully set forth herein.
2. On or about March 13, 2009, in the District of Maryland, the defendants,
RANDOLPH EDISON,
ZACHARY NORMAN,
a/k/a “Zack,”
did knowingly and willfully combine, conspire, confederate, and agree with each other and
others known and unknown to obstruct, delay, and affect commerce and the movement of an
article and commodity in commerce by robbery, as that term is defined in Title 18, United States
Code, Section 1951(b)(1), by the unlawful taking of narcotics proceeds from the person and
presence of victims.
18 U.S.C. § 1951
26
COUNT FIVE
(Possession of a Firearm in Furtherance of a Crime of Violence)
1. Paragraph 1 to 17 and 20 to 96 of Count One of this Indictment is re-alleged
2. On or about March 13, 2009, in the District of Maryland, the defendants,
RANDOLPH EDISON,
ZACHARY NORMAN,
a/k/a “Zack,”
did knowingly possess a firearm in furtherance of a crime of violence for which they may be
prosecuted in a court of the United States, that is, Conspiracy to Interfere with Commerce by
Robbery, in violation of Title 18, United States Code, Section 1951, as set forth in Count Four of
this Indictment.
18 U.S.C. § 924(c)
18 U.S.C. § 2
27
COUNT SIX
(Possession of Ammunition by a Felon)
On or about April 15, 2009, in the District of Maryland, the defendant,
RAINBOW WILLIAMS,
having been convicted of a crime punishable by imprisonment for a term exceeding one year, did
knowingly possess ammunition, to wit: 38 rounds of .357 ammunition, in and affecting
commerce.
18 U.S.C. § 922(g)(1)
28
COUNT SEVEN
(Possession of a Firearm by a Felon)
On or about April 15, 2009, in the District of Maryland, the defendant,
KEVIN GLASSCHO,
a/k/a “KG”
having been convicted of a crime punishable by imprisonment for a term exceeding one year, did
knowingly possess a firearm, to wit: one Taurus 9mm pistol with an obliterated serial number, in
and affecting commerce.
18 U.S.C. § 922(g)(1)
29
COUNT EIGHT
(Possession of a Firearm in Furtherance of a Drug Trafficking)
1. Paragraph 1 to 17 and 20 to 96 of Count One of this Indictment is re-alleged
2. On or about April 15, 2009, in the District of Maryland, the defendant,
KEVIN GLASSCHO
a/k/a “KG”
did knowingly possess a firearm, to wit: one Taurus 9mm pistol with an obliterated serial
number, in furtherance of a drug-trafficking crime for which he may be prosecuted in a court of
the United States, to wit, conspiracy to distribute and possess with intent to distribute controlled
substances, in violation of Title 21, United States Code, Section 846, as set forth in Count Two
of this Indictment.
18 U.S.C. § 924(c)
Rod J. Rosenstein
United States Attorney
A TRUE BILL:
Foreperson Date
30

BGF RICO Indictment

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BGF RICO Indictment

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CJF/JMW

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA * FILED UNDER SEAL

(Conspiracy to Participate in Racketeering Activity)

The Grand Jury for the District of Maryland charges that:

and well organized on the streets of Baltimore City, Maryland.

Western Correctional Institution (“WCI”), Eastern Correctional Institution (“ECI”), Roxbury

Correctional Institution, Maryland Correctional Institution – Jessup (“MCI-J”), Maryland

Correctional Institution – Hagerstown, Baltimore City Correctional Center (“BCCC”), and

Metropolitan Transition Center (“MTC”), Baltimore City Detention Center (“BCDC”).

3. At all times relevant to this Indictment, BGF factions existed throughout

structure which included a Supreme Commander, Lieutenant Commander and Ministers of

various forms of discipline, to include physical violence.

history, doctrine and code of conduct of the organization.

7. At all times relevant to this Indictment, BGF members engaged in various

8. At all times relevant to this Indictment, BGF members engaged in various

correctional facility regulations into Maryland correctional facilities.

targeted for violence by members of BGF.

control of the underground “prison economy” in Maryland correctional facilities through

violence and intimidation.

DAVENPORT, a/k/a "Sister D," RAINBOW WILLIAMS, RANDOLPH EDISON, a/k/a

ALICIA SIMMONS, TODD DUNCAN, a/k/a "Donnie," KIMBERLY McINTOSH, a/k/a

HARRIED, a/k/a "Smiley," and ERIK USHRY, a/k/a "E."

The Racketeering Enterprise

16. BGF, including its leadership, members and associates, constituted an

foreign commerce. The enterprise constituted an ongoing organization whose members

Purposes of the Enterprise

17. The purposes of the enterprise included the following:

a. Preserving and protecting the power, territory and profits of the

robbery, money laundering, bribery, and narcotics trafficking;

b. Promoting and enhancing the enterprise and its members’ and

witnesses and obstruction of justice;

c. Keeping victims and potential victims in fear of the enterprise and in

e. Providing financial support and information to gang members,

f. Providing assistance to other gang members who committed crimes for

The Racketeering Conspiracy

(retaliation against a witness or an informant); 18 U.S.C. § 1956(h) (money laundering); and 18

U.S.C. § 1951 (interference with commerce by robbery).

Manner and Means of the Conspiracy

and participated in the conduct of the conspiracy were the following:

including heroin to customers in the Baltimore area.

b. BGF members and associates smuggled controlled substances,

c. BGF members and associates smuggled tobacco, cellular telephones,

d. Corrections officers and other employees, including ALICIA

f. BGF members laundered the proceeds of their illicit activities through

g. BGF members used violence and the threat of violence to coerce

incarcerated persons to pay protection money to BGF.

h. BGF members committed and caused to be committed acts of violence

of fellow BGF members for violations of BGF rules and protocols.

j. BGF members and associates conducted counter-surveillance of law

k. BGF members and associates kept and maintained firearms to protect

21. In or about October 2006 to November 2006, ERIC BROWN ordered

22. In 2007, Corrections Officers at the Maryland Correctional Institution, Jessup

23. In 2007, ALICIA SIMMONS, a Corrections Officer, regularly smuggled

24. In 2007, ALICIA SIMMONS, a Corrections Officer, smuggled a cellular

the facility, SIMMONS received cash and pre-paid debit cards.

26. Between in or about 2008 and 2009, Corrections Officers smuggled

marijuana were contributed to the BGF “treasury” at the facility.

assistance in facilitating the gang’s activities.

for assistance in facilitating the gang’s activities.

32. Between in or about November 2008 and February 2009, RAINBOW

extortion and drug trafficking.

33. On or about November 18, 2008, during an intercepted phone conversation, a

contraband into NBCI.