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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA : CRIMINAL NO. 19-218

v. : DATE FILED:

SHAQUILE W. NEWSON : VIOLATIONS:


a/k/a ARaw,”
a/k/a “San,” : 18 U.S.C. ' 1962(d) (conspiracy to
ALEXANDER M. MALAVE participate in a racketeering enterprise -
a/k/a “Buju,” : 1 count)
a/k/a “Ace,” 18 U.S.C. ' 1594(c) (conspiracy to commit
KARVARISE E. PERSON : sex trafficking by force, fraud, and
a/k/a “Crazy K,” coercion, and of a minor - 1 count)
a/k/a “Killa,” : 18 U.S.C. ' 1591(a), (b)(1) (sex trafficking
a/k/a “K,” by force, fraud, and coercion - 7 counts)
FATIEMA S. BIVENS : 18 U.S.C. ' 1959(a)(1) (murder in aid of
ISAIAH ROWE racketeering activity – 1 count)
a/k/a “Izzy,” : 18 U.S.C. ' 1959(a)(5) (attempted murder
JAMES GOODE in aid of racketeering activity – 3 counts)
a/k/a “Jamil,” : 18 U.S.C. ' 1959(a)(1) (kidnapping in aid
YOJANG TORRES-ROSARIO of racketeering activity - 2 counts)
a/k/a “Domi,” : 18 U.S.C. ' 1959(a)(3) (assault with a
RICHARD POULSON dangerous weapon in aid of racketeering
a/k/a “ATL,” : activity - 1 count)
JESSICA LOPEZ 18 U.S.C. ' 1959(a)(3) (assault causing
a/k/a “Mother of the Sevens,” : serious bodily injury in aid of
RYAN NUNEZ racketeering activity – 1 count)
TYASHIA MONROE : 18 U.S.C. ' 2251(a) (production of child
a/k/a “Little Baby,” pornography – 1 count)
WENDY ESPADA : 18 U.S.C. ' 2252(a)(2), (b)(1) (distribution
MICHAEL DIAZ-WALKER of child pornography – 1 count)
a/k/a “Big Mike” : 18 U.S.C ' 2252(a)(4)(B), (b)(2)
(possession of child pornography – 1 count
: 18 U.S.C. ' 924(c) (use and carry firearm
during and in relation to a crime of
: violence – 1 count)
18 U.S.C. ' 922(g) (felon in possession of a
: firearm - 2 counts)
18 U.S.C. ' 2 (aiding and abetting)
Notice of forfeiture (4 counts)
SUPERSEDING INDICTMENT

COUNT ONE

THE GRAND JURY CHARGES THAT:

INTRODUCTION

1. At various times relevant to this Superseding Indictment, the defendants,

SHAQUILE W. NEWSON, a/k/a “Raw,” a/k/a “San,” ALEXANDER M. MALAVE, a/k/a

“Buju,” a/k/a “Ace,” KARVARISE E. PERSON, a/k/a “Crazy K,” a/k/a “Killa,” a/k/a “K,”

FATIEMA S. BIVENS, ISAIAH ROWE, a/k/a “Izzy,” JAMES GOODE, a/k/a “Jamil,”

YOJANG TORRES-ROSARIO, a/k/a “Domi,” RICHARD POULSON, a/k/a “ATL,” JESSICA

LOPEZ, a/k/a “Mother of the Sevens,” RYAN NUNEZ, TYASHIA MONROE, a/k/a “Little

Baby,” WENDY ESPADA, Savion Garcia, a/k/a “Quiet,” and others known and unknown to the

grand jury, were members and associates of the “Sevens,” a criminal organization whose

members and associates engaged in acts of violence, including murder, attempted murder,

kidnapping, assault, robbery, sex trafficking by force, fraud, or coercion, sex trafficking of a

minor, and trafficking in controlled substances, and which operated principally in a boarding

house, located at 125-127 S. 4th Street, Reading, Pennsylvania, and its surrounding areas,

hereinafter referred to as the “Boarding House.”

2. The Sevens were formed by defendants SHAQUILE W. NEWSON and

ALEXANDER M. MALAVE to control the activities in and around the Boarding House with a

focus on making money from illegal activities, including sex trafficking by force, fraud, and

coercion, sex trafficking of minors, and trafficking in controlled substances.

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3. The Sevens’ name is derived from the word “loyalty,” which has seven letters.

The Sevens are a violent neighborhood gang specific to the Boarding House. The Sevens’

members are members of other gangs including the Gangster Disciples, Crips, and Bloods. The

Sevens’ members “tied” their respective gang flags and agreed to work together.

4. The Sevens held periodic meetings to discuss increasing their membership

through recruitment, initiating new gang members, establishing and enforcing rules, increasing

revenue through drug trafficking and sex trafficking, punishing rule violators, and more.

5. The Sevens controlled the Boarding House through fear and intimidation. The

Sevens guarded the doors to the Boarding House, including permitting and denying entrance,

keeping watch for law enforcement activity, controlling the flow of drug customers, and

threatening and assaulting anyone who violated a rule, disrespected a gang member, disrespected

their control of the Boarding House, or refused to obey their commands.

6. The Sevens taxed residents of the Boarding House who had not joined the Sevens

and who wanted to sell controlled substances in the Boarding House by either a fee of $47.00

daily or 47% of their daily sales. Permission to sell controlled substances in the Boarding

House was only given when the Sevens no longer had any controlled substances left to sell on a

given day and the required tax was paid. The Sevens also collected a “homage” fee from each

member to be used to assist other Sevens’ gang members when needed, including for potential

bail money.

THE RACKETEERING ENTERPRISE

7. The Sevens, including its leadership, members, and associates, constituted an

“enterprise,” as that term is defined by Title 18, United States Code, Section 1961(4), that is, a

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group of individuals associated in fact. The enterprise was engaged in, and its activities

affected, interstate and foreign commerce. The enterprise constituted an ongoing organization

whose members and associates functioned as a continuing unit for a common purpose of

achieving the objectives of the enterprise.

PURPOSES OF THE ENTERPRISE


8. The purposes of the enterprise included the following:

a. Enriching the members and associates of the enterprise through, among

other things, sex trafficking and drug trafficking.

b. Preserving and protecting the power, territory, operations, prestige, and

profits of the enterprise through the use of intimidation, violence, threats of violence, assaults,

attempted murder, and murder.

c. Keeping victims in fear of the enterprise and in fear of its members and

associates through threats of violence and violence.

d. Concealing the enterprise and the activities of its members and associates

from law enforcement through criminal activity, including but not limited to threatening witness

and victims, who were perceived as potential witnesses against members and associates of the

enterprise.

DEFENDANTS’ ROLES IN THE ENTERPRISE


9. The defendants participated in the operation and management of the enterprise as

follows:

a. Defendant SHAQUILE W. NEWSON was a co-founder of the Sevens and

Top General. Defendant NEWSON gave orders and sanctioned and approved all activities of

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the Sevens’ members and activity occurring in and surrounding the Boarding House, including

drug trafficking, sex trafficking by force, and sex trafficking of minors. Defendant NEWSON

attended and led Sevens meetings.

b. Defendant ALEXANDER M. MALAVE was a co-founder of the Sevens

and a General. Defendant MALAVE was also a Bloods gang member. Defendant MALAVE

ensured gang rules were followed, by force when necessary, and through punishment by physical

assaults when rules were violated. Defendant MALAVE recruited and attempted to recruit

females to engage in commercial sexual encounters. Defendant MALAVE attended and led

Sevens meetings.

c. Defendant KARVARISE E. PERSON was a General of the Sevens as well

as an advisor based on his extensive gang history and membership with the Gangster Disciples.

Defendant PERSON assisted the Sevens in creating rules for the gang, including determining

what rates to charge for sexual encounters, and recruiting women and minors to engage in

commercial sexual encounters. Defendant PERSON used physical force, including murder and

attempted murder, to promote adherence to gang rules and as punishment for rule violations.

Defendant PERSON attended and sometimes led Sevens meetings.

d. Defendant FATIEMA S. BIVENS was a member and associate of the

Sevens. Defendant BIVENS was also a Crip gang member. Defendant BIVENS was a

Seven’s money-maker and engaged in drug trafficking and commercial sexual encounters for

money, and forced and attempted to force other women and minors to engage in commercial

sexual encounters. Defendant BIVENS attended and participated in Sevens meetings.

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e. Defendant ISAIAH ROWE and Savion Garcia were both guards of the

Boarding House and enforcers in the Sevens gang. Defendant ROWE and Garcia were tasked

with controlling access to, and maintaining physical security for, the Boarding House, including

watching for police activity on the block, handling the traffic of drug customers coming to the

Boarding House, guarding women and minors to ensure they did not flee, and recruiting women

and girls for commercial sexual encounters. Defendant ROWE and Garcia attended and

participated in Sevens meetings.

f. Defendant JAMES GOODE was a member and associate of the Sevens.

Defendant GOODE supplied controlled substances to the Sevens in the Boarding House for

resale, and recruited and attempted to recruit minors and women for commercial sexual

encounters. Defendant GOODE attended and participated in Sevens meetings.

g. Defendant YOJANG TORRES-ROSARIO was a member of the Sevens.

Defendant TORRES-ROSARIO assisted in the recruitment of females for commercial sexual

encounters, engaged in drug trafficking, acted as security for the Sevens, and participated in

robberies and meted out punishments on behalf of the Sevens, including by physical assault.

Defendant TORRES-ROSARIO attended and participated in Sevens meetings.

h. Defendant RICHARD POULSON was a member of the Sevens.

Defendant POULSON assisted in recruiting women and minors for commercial sexual

encounters, and carried out assaults and robberies on behalf of the Sevens. Defendant

POULSON attended and participated in Sevens meetings.

i. Defendant JESSICA LOPEZ was a member of the Sevens and was

referred to as the “Mother of the Sevens.” Defendant LOPEZ received controlled substances

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from defendant JAMES GOODE to be sold by the Sevens’ members inside the Boarding House.

Defendant LOPEZ collected money from commercial sex trafficking customers for the Sevens.

Defendant LOPEZ rented hotel rooms in her name for use by the Sevens’ leadership. Defendant

LOPEZ attended and participated in Sevens meetings.

j. Defendant RYAN NUNEZ was a member of the Sevens. Defendant

NUNEZ engaged in drug trafficking and participated in robberies and meted out punishments on

behalf of Sevens, including by physical assault. Defendant NUNEZ attended and participated in

Sevens meetings.

m. Defendant TYASHIA MONROE was a member of the Sevens.

Defendant MONROE participated in, and aided and abetted, robberies and handed out

punishments. Defendant MONROE assisted in packaging drugs for sale for the Sevens.

Defendant MONROE attended and participated in Sevens meetings.

n. Defendant WENDY ESPADA was a member of the Sevens, Defendant

ESPADA assisted in the recruitment of women and minors for commercial sex trafficking,

engaged in commercial sex trafficking, took photographs for commercial sex trafficking online

advertisements, posted commercial sex trafficking advertisements online, and sold controlled

substances for the Sevens. Defendant ESPADA attended and participated in Sevens meetings.

MANNER, MEANS, AND METHODS OF THE ENTERPRISE

10. Among the manner, means and methods by which members and their associates

conducted and participated in the conduct of the affairs of the enterprise were the following:

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a. Members and associates of the enterprise committed, attempted, and

threatened to commit acts of violence, including murder, attempted murder, kidnapping, violent

assaults, and robbery, to protect and expand the enterprise’s criminal operation.

b. Members and associates of the enterprise used force, threats of force,

fraud, and coercion to cause women to engage in commercial sex acts, and caused minors to

engage in commercial sex acts.

c. Members and associates of the enterprise promoted a climate of fear

through violence and threats of violence.

d. Members and associates of the enterprise carried firearms, knives, bats,

batons, and other weapons to promote the climate of fear, protect their criminal activities, and

control and punish individuals in and around the Boarding House.

e. Members and associates of the enterprise controlled commercial sex

trafficking and drug trafficking in and around the Boarding House.

f. Members and associates of the enterprise demanded and enforced a tax

from individuals who did not belong to the Sevens who sold controlled substances in the

Boarding House.

g. Members and associates of the enterprise guarded the Boarding House and

controlled access to the Boarding House, including by drug customers.

h. Members and associates of the enterprise controlled the assignment and

access to rooms in the Boarding House, including forcing entry into rooms, taking over rooms,

and evicting residents, including through the use of physical force.

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i. Members and associates of the enterprise held meetings to discuss

increasing the Sevens’ revenue through sex trafficking and drug trafficking as well as rules,

punishments, membership, and more.

THE RACKETEERING CONSPIRACY

11. From at least as early as in or about December 2017 to on or about March 13,

2019, in Reading, in the Eastern District of Pennsylvania and elsewhere, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”
FATIEMA S. BIVINS,
ISAIAH ROWE,
a/k/a “Izzy,” and
JAMES GOODE,
a/k/a “Jamil,”
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”
RICHARD POULSON,
a/k/a “ATL,”
JESSICA LOPEZ,
a/k/a “Mother of the Sevens,”
RYAN NUNEZ,
TYASHIA MONROE,
a/k/a “Little Baby,” and
WENDY ESPADA,

being persons employed by and associated with an enterprise known as the “Sevens,” more fully

described in paragraphs 1 through 10, which enterprise was engaged in, and the activities of

which affected, interstate and foreign commerce, knowingly and unlawfully conspired and

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agreed, together, and with others known and unknown to the grand jury, to violate Title 18,

United States Code, Section 1962(c), that is, to conduct and participate, directly and indirectly, in

the conduct of the affairs of such enterprise through a pattern of racketeering activity, as defined

in Title 18, United States Code, Section 1961(1) and (5), which consisted of:

a. multiple acts involving murder chargeable under Title 18, Pennsylvania

Consolidated Statutes Annotated, Sections 2502, 901, and 903, of the laws of the

Commonwealth of Pennsylvania;

b. multiple acts indictable under Title 18, United States Code, Section 1591

(relating to trafficking in persons);

c. multiple acts indictable under Title 18, United States Code, Section 2251

(relating to the production of child pornography);

d. multiple acts involving kidnapping, chargeable under Title 18,

Pennsylvania Consolidated Statutes Annotated, Sections 2901, 901, and 903, of the laws of the

Commonwealth of Pennsylvania;

e. multiple acts involving robbery, chargeable under Title 18, Pennsylvania

Consolidated Statutes Annotated, Sections 3701, 901, and 903, of the laws of the

Commonwealth of Pennsylvania; and

f. multiple offenses involving dealing in controlled substances in violation of

Title 21, United States Code, Sections 841 and 846.

12. It was part of the conspiracy that each defendant agreed that a conspirator would

commit at least two acts of racketeering in the conduct of the enterprise’s affairs.

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OVERT ACTS
13. In furtherance of the conspiracy, and to effect the object of the conspiracy, the

defendants, and others known and unknown to the grand jury, committed the following overt

acts, among others, in the Eastern District of Pennsylvania:

In or about February 2018:

(1) Defendant KARVARISE E. PERSON attempted to recruit Victim #1, who

is known to the grand jury, for commercial sex trafficking for the Sevens by force, fraud, and

coercion.

(2) Individual #1, known to the grand jury, and others unknown, assaulted

Victim #1 in the Boarding House, including cutting her hair with garden shears, and threatening

to put a bag on her head and to take her for a “trunk ride.”

(3) Defendants SHAQUILE W. NEWSON, ALEXANDER M. MALAVE,

KARVARISE E. PERSON, and others unknown to the grand jury, kidnapped and violently

assaulted Victim #2, who is known to the grand jury, including with a knife.

(4) On or about April 21, 2018, defendants KARVARISE E. PERSON and

ALEXANDER M. MALAVE, armed with a firearm, assaulted and shot Victim #3, who is

known to the grand jury, in the Boarding House.

From in or about May 2018 to in or about December 2018:

(5) Defendants SHAQUILE W. NEWSON, KARVARISE E. PERSON, and

YOJANG TORRES-ROSARIO forced Victim #4, who is known to the grand jury, to engage in

commercial sexual encounters for the Sevens gang by force, fraud, and coercion.

(6) Defendant KARVARISE E. PERSON assaulted Victim #4 by forcefully

shoving a baton against her throat.


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(7) Defendant YOJANG TORRES-ROSARIO threatened to assault Victim #4

for not engaging in commercial sexual encounters.

(8) On or about May 27, 2018, defendants ALEXANDER M. MALAVE and

Person #2, who is known to the grand jury, attempted to force Victim #5, who is known to the

grand jury, to engage in commercial sexual encounters by kidnapping her, attempting to force

her to use controlled substances, and threatening her with violence.

From in or about August 2018 to in or about December 2018:

(9) Defendant JAMES GOODE raped Minor #1, who is known to the grand

jury and who was 17-years old at the time, in the Boarding House.

(10) Defendants JAMES GOODE and RICHARD POULSON, and Savion

Garcia attempted to recruit, and aided and abetted the recruitment of, Minor #1, through force,

fraud, and coercion, to engage in commercial sexual encounters.

In or about September and October 2018:

(11) Defendants ALEXANDER M. MALAVE, JAMES GOODE, and

YOJANG TORRES-ROSARIO recruited Victim #6, who is known to the grand jury, and

attempted to do so, to engage in sex trafficking by force, fraud, and coercion.

(12) Defendant ALEXANDER M. MALAVE threatened Victim #6 to cause

her to engage in commercial sexual encounters, by telling her that if she failed to engage in

sexual encounters or failed to return to the Boarding House, she “would be stabbed.”

(13) Defendant ALEXANDER M. MALAVE held a knife to Victim #6’s

throat as punishment for not earning enough money through commercial sexual encounters.

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(14) Defendant JAMES GOODE held a gun to Victim #6’s head as punishment

because he believed she “snitched” on him.

(15) Defendant ALEXANDER M. MALAVE forced Victim #6 to have sexual

contact with him.

(16) Defendant JAMES GOODE forced Victim #6 to have sexual contact with

him.

(17) Defendant YOJANG TORRES-ROSARIO forced Victim #6 to have

sexual contact with him.

From in or about October 2018 to on or about December 10, 2018:

(18) Defendants SHAQUILE W. NEWSON, KARVARISE E. PERSON, and

FATIEMA S. BIVENS and Savion Garcia recruited Minor #2, who is known to the grand jury,

and who was 17 years of age at the time, to engage in commercial sex acts.

(19) Defendants KARVARISE E. PERSON and FATIEMA S. BIVENS

created sexually explicit images of Minor #2 to use in advertisements for commercial sexual

encounters on the skipthegames.com website.

(20) Defendant SHAQUILE W. NEWSON and Savion Garcia forced Minor #2

to have sexual relations with each of them, to test her sexual performance for commercial sexual

encounters.

(21) Defendant KARVARISE E. PERSON kidnapped, threatened, and

assaulted Minor #2 for not obeying a command, by dragging and pulling her down a hallway in

the Boarding House, putting a knife to her neck, locking her in a room naked, and keeping her

there for days.

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(22) Defendant KARVARISE E. PERSON forced Minor #2 to have a sexual

encounter with Person #3, unknown to the Grand Jury, while defendant PERSON held a gun to

Minor #2’s head.

(23) Defendant KARVARISE E. PERSON kidnapped, threatened, and

assaulted Minor #2, including with a baton and a hammer, and locked her naked in a dog kennel

overnight in the Boarding House.

(24) Defendant WENDY ESPADA took photographs of Minor #2 for use in

online advertisements for commercial sex trafficking, and at the direction of defendant

KARVARISE E. PERSON, used photographs she took and those supplied to her by defendant

PERSON to create photograph collages for use in online advertisements for commercial sexual

encounters.

(25) Defendant KARVARISE E. PERSON took Minor #2 to various hotels

including: the Econo Lodge in Reading, Pennsylvania; the Inn at Reading in Wyomissing,

Pennsylvania; and Klein’s Motel in Temple, Pennsylvania; to cause her to engage in commercial

sex acts with unidentified men. The money Minor #2 earned through these sexual encounters

was taken by and given to defendants PERSON, SHAQUILE E. NEWSON, and ALEXANDER

M. MALAVE.

(26) Defendant FATIEMA S. BIVENS had Minor #2 engage in commercial

sex acts with men at a residence on N. 5th Street in Reading, Pennsylvania. Defendant BIVENS

kept all the money paid for the sexual encounters.

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(27) Defendant FATIEMA S. BIVENS supplied Minor #2 with drugs and

alcohol to coerce her to continue to engage in commercial sex acts for defendant BIVENS’

profit.

(28) On or about October 28, 2019, defendants ISAIAH ROWE, RICHARD

POULSON, and TYASHIA MONROE, while armed with knives, assaulted, stabbed, and

robbed, and aided and abetted the assaulting, stabbing, and robbing, of Victim #7, who is known

to the grand jury, at the Boarding House.

On or about November 1, 2018:

(29) Defendant JESSICA LOPEZ rented Rooms 29, 32, and 33 in the Boarding

House for use by members of the Sevens.

(30) Defendant JAMES GOODE knowingly possessed heroin, cocaine, and

marijuana, with the intent to distribute, at a residence located at a residence in Reading,

Pennsylvania.

(31) Defendant JAMES GOODE knowingly possessed a Sig Sauer P238

firearm bearing serial number 27A110132, loaded with 7 live rounds of ammunition, a Ruger

P89 firearm, bearing serial number 31370138, loaded with 14 live rounds of ammunition, and a

Smith & Wesson, SW40V firearm, bearing serial number PAN9353, loaded with 13 live rounds

of ammunition.

(32) On or about November 16, 2018, defendant KARVARISE E. PERSON,

assaulted and stabbed Victim #8, who is known to the grand jury, causing his death.

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(33) On or about November 19, 2018, defendants KARVARISE E. PERSON,

ALEXANDER M. MALAVE, and ISAIAH ROWE and Savion Garcia violently assaulted

Victim #9, who is known to the grand jury, including with a hammer.

(34) On or about November 28, 2018, defendant ISAIAH ROWE escorted

Minor #2 out of the Boarding House, to ensure she did not flee, and walked north on the block.

A few minutes later, both individuals returned to the Boarding House where defendant ROWE

unlocked the door and let Minor #2 enter.

(35) On or about November 29, 2018, Savion Garcia escorted Minor #2 out of

the Boarding House, to ensure she did not flee, and walked south on the block. A few minutes

later, both individuals returned to the Boarding House where Garcia unlocked the door to the

Boarding House and let Minor #2 enter.

(36) Between in or about November and in or about December 2018, defendant

KARVARISE E. PERSON assaulted Victim #10, who is known to the grand jury, with a

dangerous weapon by stabbing her in the thigh with a knife.

(37) On or about December 10, 2018, defendant KARVARISE E. PERSON

knowingly possessed a firearm, that is, a Lorcin, Model LT .25 caliber firearm, bearing serial

number LT22506.

(38) From in or about December 2018 to in or about January 2019, defendants

SHAQUILE W. NEWSON, FATIEMA S. BIVENS, and ISAIAH ROWE, and others known and

unknown to the grand jury, attempted to recruit Victim #11, who is known to the grand jury, to

engage in commercial sex acts through force, fraud, and coercion.

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(39) On or about January 6, 2019, defendants FATIEMA S. BIVENS and

YOJANG TORRES-ROSARIO punched and kicked Victim #11, who is known to the grand

jury, for not complying with the Sevens’ rules of the Boarding House, including not earning her

privilege to be in the Boarding House by engaging in commercial sex acts.

(40) On or about February 12, 2019, defendants ISAIAH ROWE, YOJANG

TORRES-ROSARIO, RICHARD POULSON, RYAN NUNEZ, and TYASHIA MONROE

robbed and violently assaulted Victim #12, who is known to the grand jury, in and around the

Boarding House.

(41) On or about March 4, 2019, defendants RICHARD POULSON, RYAN

NUNEZ, and Person #4, known to the grand jury, assaulted and robbed Victim #13, who is

known to the grand jury, in Room 22 of the Boarding House.

On or about March 13, 2019:

(42) Defendant SHAQUILE W. NEWSON knowingly possessed cocaine and

drug paraphernalia at a residence in Reading, Pennsylvania.

(43) Defendant SHAQUILE W. NEWSON knowingly possessed a Winchester

Model 120-12 gauge shotgun, bearing serial number L1427, with a barrel length of 13.5” and a

sawed-off stock at 1636 Cotton Street in Reading, Pennsylvania.

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NOTICE OF SPECIAL SENTENCING FACTORS

14. In or about February 2018, in the Eastern District of Pennsylvania, defendants

SHAQUILE W. NEWSON, ALEXANDER M. MALAVE, and KARVARISE PERSON

knowingly and unlawfully removed Victim #2 a substantial distance under the circumstances

from the place where Victim #2 was found, and unlawfully confined Victim #2 for a substantial

period in a place of isolation, with the intent to inflict bodily injury and terrorize Victim #2, in

violation of Title 18, Pennsylvania Consolidated Statutes Annotated, Section 2901(a).

15. On or about May 27, 2018, in the Eastern District of Pennsylvania, defendant

ALEXANDER M. MALAVE knowingly and unlawfully removed Victim #5 a substantial

distance under the circumstances from the place where Victim #5 was found, and unlawfully

confined Victim #5 for a substantial period in a place of isolation, with the intent to inflict bodily

injury and terrorize Victim #5, in violation of Title 18, Pennsylvania Consolidated Statutes

Annotated, Section 2901(a).

16. In or about February 2018, in the Eastern District of Pennsylvania, the defendant

KARVARISE E. PERSON, in and affecting interstate and foreign commerce, knowingly

recruited, enticed, harbored, transported, provided, obtained, and maintained, by any means,

Victim #1, knowing and in reckless disregard of the fact that means of force, threats of force,

fraud, coercion, and any combination of such means would be used to cause Victim #1 to engage

in a commercial sex act, in violation of Title 18, United States Code, Section 1591(a)(1), (b)(1).

17. In or about May 2018 to in or about December 2018, in the Eastern District of

Pennsylvania, the defendants SHAQUILE W. NEWSON, KARVARISE E. PERSON, and

YOJANG TORRES-ROSARIO, in and affecting interstate and foreign commerce, knowingly

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recruited, enticed, harbored, transported, provided, obtained, and maintained, by any means,

Victim #4, knowing and in reckless disregard of the fact that means of force, threats of force,

fraud, coercion, and any combination of such means, would be used to cause Victim #4 to

engage in a commercial sex act, and aided and abetted the same, in violation of Title 18, United

States Code, Section 1591(a)(1), (b)(1), and 2.

18. On or about May 27, 2018, in the Eastern District of Pennsylvania, the defendant

ALEXANDER M. MALAVE, in and affecting interstate and foreign commerce, knowingly

recruited, enticed, harbored, transported, provided, obtained, and maintained, by any means,

Victim #5, knowing and in reckless disregard of the fact that means of force, threats of force,

fraud, coercion, and any combination of such means, would be used to cause Victim #5 to

engage in a commercial sex act, and aided and abetted the same, in violation of Title 18, United

States Code, Sections 1591(a)(1), (b)(1), and 2.

19. From in or about August 2018 to in or about November 2018, in the Eastern

District of Pennsylvania, defendants JAMES GOODE and RICHARD POULSON in and

affecting interstate and foreign commerce, knowingly recruited, enticed, harbored, transported,

provided, obtained, and maintained, by any means, Minor #1, knowing and in reckless disregard

of the fact that Minor #1 had not attained the age of 18 years and would be caused to engage in a

commercial sex act, and knowing, and in reckless disregard of the fact, that means of force,

threats of force, fraud, coercion and any combination of such means would be used to cause

Minor #1 to engage in a commercial sex act, and having had reasonable opportunity to observe

Minor #1, and aided and abetted the same, in violation of Title 18, United States Code, Sections

1591(a)(1), (b)(1), (b)(2), (c), and 2.

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20. In or about September 2018 to in or about October 2018, in the Eastern District of

Pennsylvania, the defendants ALEXANDER M. MALAVE, JAMES GOODE, and YOJANG

TORRES-ROSARIO, in and affecting interstate and foreign commerce, knowingly recruited,

enticed, harbored, transported, provided, obtained, and maintained, by any means, Victim #6,

knowing and in reckless disregard of the fact that means of force, threats of force, fraud,

coercion and any combination of such means would be used to cause Victim #6 to engage in a

commercial sex act, and aided and abetted the same, in violation of Title 18, United States Code,

Sections 1591(a)(1), (b)(1), and 2.

21. From in or about October 2018 to on or about December 10, 2018, in the Eastern

District of Pennsylvania, defendants SHAQUILE W. NEWSON, KARVARISE E. PERSON,

and FATIEMA S. BIVENS, in and affecting interstate and foreign commerce, knowingly

recruited, enticed, harbored, transported, provided, obtained, and maintained by any means,

Minor #2, knowing and in reckless disregard of the fact that Minor #2 had not attained the age of

18 years and would be caused to engage in a commercial sex act, and knowing, and in reckless

disregard of the fact, that means of force, threats of force, fraud, coercion and any combination

of such means would be used to cause Minor #2 to engage in a commercial sex act, and having

had reasonable opportunity to observe Minor #2, and aided and abetted the same, in violation of

Title 18, United States Code, Sections 1591(a)(1), (b)(1), (b)(2), (c), and 2.

22. On or about November 16, 2018, in the Eastern District of Pennsylvania,

defendant KARVARISE E. PERSON knowingly and intentionally murdered Victim #8, by

beating and stabbing him, said killing was willful, deliberate, and premeditated, in violation of

Title 18, Pennsylvania Consolidated Statutes Annotated, Section 2502.

20
23. From in or about December 2018 to in or about January 2019, in the Eastern

District of Pennsylvania, defendants SHAQUILE W. NEWSON, ISAIAH ROWE, and

FATIEMA S. BIVENS, in and affecting interstate and foreign commerce, knowingly recruited,

enticed, harbored, transported, provided, obtained, and maintained, by any means, Victim #11,

knowing and in reckless disregard of the fact that means of force, threats of force, fraud,

coercion, and any combination of such means, would be used to cause Victim #11 to engage in a

commercial sex act, and aided and abetted the same, in violation of Title 18, United States Code,

Sections 1591(a)(1), (b)(1), and 2.

All in violation of Title 18, United States Code, Section 1962(d).

21
COUNT TWO
From at least in or about February 2018 to on or about March 13, 2019, in

Reading, in the Eastern District of Pennsylvania and elsewhere, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”
FATIEMA S. BIVINS,
ISAIAH ROWE,
a/k/a “Izzy,” and
JAMES GOODE,
a/k/a “Jamil,”
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”
RICHARD POULSON,
a/k/a “ATL,”
JESSICA LOPEZ,
a/k/a “Mother of the Sevens,”
RYAN NUNEZ,
TYASHIA MONROE,
a/k/a “Little Baby,”
WENDY ESPADA, and
MICHAEL DIAZ-WALKER

conspired and agreed, together and with others known and unknown to the grand jury, in and

affecting interstate and foreign commerce, to knowingly recruit, entice, harbor, transport,

provide, obtain and maintain by any means, females, knowing and in reckless disregard of the

fact that means of force, threats of force, fraud, coercion, and any combination of such means

would be used to cause the females to engage in a commercial sex act, and knowing and in

reckless disregard of the fact that a person who had not attained the age of 18 years would be
22
caused to engage in a commercial sex act, in violation of Title 18, United States Code, Section

1591.

MANNER AND MEANS

1. Paragraphs 10(a) through (e), (g), and (i) of Count One of this superseding

indictment are incorporated and realleged here.

2. Defendant MICHAEL DIAZ-WALKER was an associate of the Sevens.

Defendant DIAZ-WALKER assisted in posting advertisements for paid sexual encounters, took

photographs of females to be used in the advertisements, and drove females to the locations of

the sexual encounters.

OVERT ACTS

In furtherance of the conspiracy and to accomplish its objects, defendants

SHAQUILE W. NEWSON, ALEXANDER M. MALAVE, KARVARISE E. PERSON,

FATIEMA S. BIVENS, ISAIAH ROWE, JAMES GOODE, YOJANG TORRES-ROSARIO,

RICHARD POULSON, JESSICA LOPEZ, RYAN NUNEZ, TYASHIA MONROE, WENDY

ESPADA, MICHAEL DIAZ-WALKER, Savion Garcia, and others known and unknown to the

grand jury, committed the following overt acts, among others, in the Eastern District of

Pennsylvania and elsewhere:

1. Overt Acts (1), (2), (5) through (27), (29) through (31), (34) through (39),

and (43) of Count One of this superseding indictment are incorporated here.

In or about November 2018:

23
2. Defendant MICHAEL DIAZ-WALKER took sexually explicit images of

Minor #2, who is known to the grand jury, and who was 17 years of age at the time, to use in

advertisements for prostitution services on the skipthegames.com website.

3. Defendant MICHAEL DIAZ-WALKER, took Minor #2 to various hotels

including: the Econo Lodge in Reading, Pennsylvania, 19601; the Inn at Reading in

Wyomissing, Pennsylvania; and Klein’s Motel in Temple; to cause her to engage in sexual

encounters with unidentified men. The money Minor #2 earned through these sexual encounters

was taken by defendants SHAQUILE W. NEWSON, ALEXANDER M. MALAVE, and

KARVARISE E. PERSON.

All in violation of Title 21, United States Code, Section 1594(c).

24
COUNT THREE

THE GRAND JURY FURTHER CHARGES THAT:

In or about February 2018, in Reading, in the Eastern District of Pennsylvania,

defendant

KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

in and affecting interstate commerce, knowingly recruited, enticed, harbored, transported,

provided, obtained, and maintained, by any means, Victim #1, knowing and in reckless disregard

of the fact that means of force, threats of force, fraud, coercion, and any combination of such

means, would be used to cause Victim #1 to engage in a commercial sex act, and attempted to do

so.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1) and 1594.

25
COUNT FOUR
THE GRAND JURY FURTHER CHARGES THAT:
1. At all times relevant to this superseding indictment, the Sevens, as

described more particularly in paragraphs 1 through 10 of Count One of this superseding

indictment, which paragraphs are realleged and incorporated by reference as though set forth

fully herein, including its leaders, members, and associates, constituted an enterprise, as that term

is defined in Title 18, United States Code, Section 1959(b)(2), namely, the Sevens, that is, a

group of individuals associated in fact which was 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 a common purpose of achieving the

objectives of the enterprise.

2. At all times relevant to this superseding indictment, the Sevens, through

its members and associates, engaged in racketeering activity as defined in Title 18, United States

Code, Sections 1959(b)(1) and 1961(1), namely acts involving murder, kidnapping, and robbery

in violation of the laws of the state of Pennsylvania, and offenses involving dealing in controlled

substances in violation of Title 21, United States Code, Sections 841 and 846, acts indictable

under Title 18, United States Code, Section 1591 (relating to trafficking in persons) and Title 18,

United States Code, Section 2251 (relating to child exploitation).

3. In or about February 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
26
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,” and
KARVARISE E. PERSON
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

and others unknown to the grand jury, knowingly and intentionally kidnapped, assaulted with a

dangerous weapon, and maimed Victim #2, known to the grand jury, and aided and abetted the

same, by confining him, and beating and slicing his mouth with a knife, in violation of the laws

of the Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania Consolidated Statutes

Annotated, Sections 2901(a), 2702(a)(1) and (4) and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(1), (2), and (3)

and 2.

27
COUNT FIVE
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about April 21, 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,” and
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

knowing and intentionally attempted to murder, and assaulted with a dangerous weapon, Victim

#3, known to the grand jury, by shooting him with a firearm, and aided and abetted the same, in

violation of the laws of the Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania

Consolidated Statutes Annotated, Sections 2502, 2702(a)(4), 901(a), and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and (5) and 2.

28
COUNT SIX

THE GRAND JURY FURTHER CHARGES THAT:

On or about April 21, 2018, in Reading, in the Eastern District of Pennsylvania,

defendants

ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,” and
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

knowingly used, carried, brandished, and discharged, and aided and abetted the same, a firearm,

during and in relation to a crime of violence, as charged in Count Five, for which they may be

prosecuted in a court of the United States, that is, attempted murder and assault with a dangerous

weapon, in aid of racketeering, in violation of Title 18, United States Code, Sections 1959(a)(3)

and (5).

In violation of Title 18, United States Code, Sections 924(c) and 2.

29
COUNT SEVEN
THE GRAND JURY FURTHER CHARGES THAT:

From in or about May 2018 to in or about December 2018, in Reading, in the

Eastern District of Pennsylvania, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,” and
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”

in and affecting interstate commerce, knowingly recruited, enticed, harbored, transported,

provided, obtained, and maintained, by any means, Victim #4, who is known to the grand jury,

knowing and in reckless disregard of the fact that means of force, threats of force, fraud,

coercion, and any combination of such means, would be used to cause Victim #4 to engage in a

commercial sex act, and attempted to do so, and aided and abetted the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1), 1594,

and 2.

30
COUNT EIGHT
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about May 27, 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendant

ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace”

and Person #2, known to the grand jury, knowingly and intentionally kidnapped, and aided and

abetted the same, Victim #5, who is known to the grand jury, in violation of the laws of the

Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania Consolidated Statutes

Annotated, Section 2901(a) and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(1) and 2.

31
COUNT NINE

THE GRAND JURY FURTHER CHARGES THAT:

On or about May 27, 2018, in Reading, in the Eastern District of Pennsylvania,

defendant

ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”

and Person #2, known to the grand jury, in and affecting interstate commerce, knowingly

recruited, enticed, harbored, transported, provided, obtained, and maintained, by any means,

Victim #5, who is known to the grand jury, knowing and in reckless disregard of the fact that

means of force, threats of force, fraud, coercion and any combination of such means would be

used to cause Victim #5 to engage in a commercial sex act, and attempted to do so, and aided

and abetted the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1) and 1594

and 2.

32
COUNT TEN
THE GRAND JURY FURTHER CHARGES THAT:

From in or about August 2018 to in or about November 2018, in Reading, in the

Eastern District of Pennsylvania, defendants

JAMES GOODE,
a/k/a “Jamil,”
RICHARD POULSON,
a/k/a “ATL,”

and Savion Garcia, in and affecting interstate commerce, knowingly recruited, enticed, harbored,

transported, provided, obtained, and maintained, by any means, Minor #1, who is known to the

grand jury, knowing and in reckless disregard of the fact that Minor #1 had not attained the age

of 18 years and would be caused to engage in a commercial sex act, and knowing, and in reckless

disregard of the fact, that means of force, threats of force, fraud, coercion and any combination

of such means would be used to cause Minor #1 to engage in a commercial sex act, and having

had reasonable opportunity to observe Minor #1, and attempted to do so, and aided and abetted

the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1), (b)(2), (c), 1594,

and 2.

33
COUNT ELEVEN
THE GRAND JURY FURTHER CHARGES THAT:

In or about September 2018 to in or about October 2018, in Reading, in the

Eastern District of Pennsylvania, defendants

ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”
JAMES GOODE,
a/k/a “Jamil,” and
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”

in and affecting interstate commerce, knowingly recruited, enticed, harbored, transported,

provided, obtained and maintained, by any means, Victim #6, who is known to the grand jury,

knowing and in reckless disregard of the fact that means of force, threats of force, fraud,

coercion and any combination of such means would be used to cause Victim #6 to engage in a

commercial sex act, and attempted to do so, and aided and abetted the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1), 1594,

and 2.

34
COUNT TWELVE

THE GRAND JURY FURTHER CHARGES THAT:

From in or about October 2018 to on or about December 10, 2018, in Reading, in

the Eastern District of Pennsylvania, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,” and
FATIEMA S. BIVENS

and Savion Garcia, in and affecting interstate commerce, knowingly recruited, enticed, harbored,

transported, provided, obtained, and maintained, by any means, Minor #2, who is known to the

grand jury, knowing and in reckless disregard of the fact that Minor #2 had not attained the age

of 18 years and would be caused to engage in a commercial sex act, and knowing and in reckless

disregard of the fact, that means of force, threats of force, fraud, coercion and any combination

of such means would be used to cause Minor #2 to engage in a commercial sex act, and having

had reasonable opportunity to observe Minor #2, and aided and abetted the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1), (b)(2),

(c), and 2.

35
COUNT THIRTEEN

THE GRAND JURY FURTHER CHARGES THAT:

On or about November 6, 2018, in Reading, in the Eastern District of

Pennsylvania, and elsewhere, defendants

FATIEMA S. BIVENS, and


MICHAEL DIAZ-WALKER,
a/k/a “Big Mike,”

employed, used, persuaded, induced, enticed, and coerced a minor, Minor #2, who is known to

the grand jury, to engage in sexually explicit conduct for the purpose of producing a visual

depiction of that conduct, that is, by sexually abusing Minor #2 and recording the abuse of Minor

#2, and the visual depiction was produced and transmitted using materials that had been mailed

and shipped and transported in and affecting interstate and foreign commerce by any means

including by computer, and aided and abetted the same.

In violation of Title 18, United States Code, Sections 2251(a) and (e) and 2.

36
COUNT FOURTEEN

THE GRAND JURY FURTHER CHARGES THAT:

On or about November 11, 2018, in Reading, in the Eastern District of

Pennsylvania, and elsewhere, defendant

MICHAEL DIAZ-WALKER,
a/k/a “Big Mike,”

knowingly distributed a visual depiction of Minor #2, using any means and facility of interstate

and foreign commerce, and that had been mailed and shipped and transported in and affecting

interstate and foreign commerce by any means, including by computer, the producing of which

involved the use of a minor engaged in sexually explicit conduct, and the visual depiction was of

such conduct.

In violation of Title 18, United States Code, Section 2252(a)(2), (b)(1).

37
COUNT FIFTEEN

THE GRAND JURY FURTHER CHARGES THAT:

On or about December 13, 2018, in Reading, in the Eastern District of

Pennsylvania, and elsewhere, defendant

MICHAEL DIAZ-WALKER,
a/k/a “Big Mike,”

knowingly possessed matter, that is, a LG Aristo 2 cellular telephone, model number LM-

X210MA, bearing IMEI 3576030929227110, which contained visual depictions of Minor #2 that

had been mailed and shipped and transported using any means and facility of interstate and

foreign commerce and in and affecting interstate and foreign commerce. The production of

these visual depictions involved the use of Minor #2 engaging in sexually explicit conduct and

the visual depictions were of such conduct.

In violation of Title 18, United States Code, Section 2252(a)(4)(B), (b)(2).

38
COUNT SIXTEEN

THE GRAND JURY FURTHER CHARGES THAT:


1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about October 28, 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

ISAIAH ROWE,
a/k/a “Izzy,”
RICHARD POULSON,
a/k/a “ATL,” and
TYASHIA MONROE,
a/k/a “Little Baby,”

knowingly and intentionally attempted to murder and assaulted with a dangerous weapon, Victim

#7, who is known to the grand jury, and aided and abetted the same, by beating, slicing and

stabbing him, in violation of the laws of the Commonwealth of Pennsylvania, that is, Title 18,

Pennsylvania Consolidated Statutes Annotated, Sections 2502, 901(a), 2702(a)(4), and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and (5) and

2.

39
COUNT SEVENTEEN

THE GRAND JURY FURTHER CHARGES THAT:


1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about November 16, 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendant

KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

knowingly and intentionally murdered Victim #8, known to the grand jury, by beating and

stabbing him, in violation of the laws of the Commonwealth of Pennsylvania, that is, Title 18,

Pennsylvania Consolidated Statutes Annotated, Section 2502.

All in violation of Title 18, United States Code, Section 1959(a)(1).

40
COUNT EIGHTEEN

THE GRAND JURY FURTHER CHARGES THAT:


1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about November 19, 2018, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,” and
ISAIAH ROWE,
a/k/a “Izzy,”

knowingly and intentionally attempted to murder and assaulted with a dangerous weapon, Victim

#9, and aided and abetted the same, by beating him including with a hammer, in violation of the

laws of the Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania Consolidated

Statutes Annotated, Sections 2502, 901(a), 2702(a)(4), and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and (5) and

2.

41
COUNT NINETEEN

THE GRAND JURY FURTHER CHARGES THAT:

On or about December 10, 2018, in Reading, in the Eastern District of

Pennsylvania, defendant

KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

knowing that he had been convicted in a court of the Commonwealth of Pennsylvania of a crime

punishable by imprisonment for a term exceeding one year, knowingly possessed a firearm, that

is, a Lorcin, Model LT, .25 caliber, bearing serial number LT22506, and the firearm was in and

affecting interstate and foreign commerce.

In violation of Title 18, United States Code, Section 922(g)(1).

42
COUNT TWENTY

THE GRAND JURY FURTHER CHARGES THAT:

From in or about December 2018 to in or about January 2019, in Reading, in the

Eastern District of Pennsylvania, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
ISAIAH ROWE,
a/k/a “Izzy,” and
FATEIMA S. BIVENS,

in and affecting interstate commerce, knowingly recruited, enticed, harbored, transported,

provided, obtained, and maintained, by any means, Victim #11, knowing and in reckless

disregard of the fact that means of force, threats of force, fraud, coercion and any combination of

such means would be used to cause Victim #11 to engage in a commercial sex act, and attempted

to do so, and aided and abetted the same.

In violation of Title 18, United States Code, Sections 1591(a)(1), (b)(1), 1594,

and 2.

43
COUNT TWENTY-ONE

THE GRAND JURY FURTHER CHARGES THAT:


1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

3. On or about February 12, 2019, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

ISAIAH ROWE,
a/k/a “Izzy,”
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”
RICHARD POULSON,
a/k/a “ATL,”
RYAN NUNUZ, and
TYASHIA MONROE,
a/k/a “Little Baby,”

knowingly and intentionally committed an assault resulting in serious bodily injury and aided

and abetted the same, of Victim #12, who is known to the grand jury, in violation of the laws of

the Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania Consolidated Statutes

Annotated, Sections 2702(a)(1) and 306.

In violation of Title 18, United States Code, Section 1959(a)(3).

44
COUNT TWENTY-TWO

THE GRAND JURY FURTHER CHARGES THAT:


1. Paragraphs 1 through 10 of Count One and Paragraphs 1 and 2 of Count

Four are realleged and incorporated by reference as though fully set forth herein.

2. On or about March 4, 2019, in Reading, in the Eastern District of

Pennsylvania, for the purpose of maintaining and increasing position in the Sevens, an enterprise

engaged in racketeering activity, defendants

RYAN NUNEZ,
RICHARD POULSON,
a/k/a “ATL,”

and Person #4, known to the grand jury, knowingly and intentionally assaulted with a dangerous

weapon, and aided and abetted the same, of Victim #13, who is known to the grand jury, in

violation of the laws of the Commonwealth of Pennsylvania, that is, Title 18, Pennsylvania

Consolidated Statutes Annotated, Section 2702(a)(4), and 306.

All in violation of Title 18, United States Code, Sections 1959(a)(3) and 2.

45
NOTICE OF FORFEITURE - ONE

THE GRAND JURY FURTHER CHARGES THAT:

1. The allegations of Counts One of this indictment are incorporated here for the

purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section

1963, Pursuant to Rule 32.2, Federal Rules of Criminal Procedure, notice is hereby given to the

defendants that the United States will seek forfeiture as part of any sentence in accordance with

Title 18, United States Code, Section 1963 in the event of any defendant’s conviction under

Count One of this indictment.

2. Defendants:

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”
FATIEMA S. BIVINS,
ISAIAH ROWE,
a/k/a “Izzy,” and
JAMES GOODE,
a/k/a “Jamil,”
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”
RICHARD POULSON,
a/k/a “ATL,”
JESSICA LOPEZ,
a/k/a “Mother of the Sevens,”
RYAN NUNEZ,
TYASHIA MONROE,
a/k/a “Little Baby,” and
WENDY ESPADA

46
A. have acquired and maintained interests in violation of Title 18, United

States Code, Section 1962, which interests are subject to forfeiture to the United States pursuant

to Title 18, United States Code, Sections 1963(a)(1);

B. have interests in, securities of, claims against, or properties or contractual

rights affording a source of influence over the Enterprise in violation of Title 18, United States

Code, Section 1962, which are subject to forfeiture to the United States pursuant to Title 18,

United States Code, Section 1963(a)(2).

C. have property constituting and derived from proceeds obtained, directly

and indirectly, from the aforesaid racketeering activity, in violation of Title 18, United States

Code, Section 1962, which property is subject to forfeiture to the United States pursuant to Title

18, United States Code, Section 1963(a)(3).

3. The interests of the defendants subject to forfeiture to the United States pursuant

to Title 18, United States Code, Section 1962(a)(1), (a)(2), and (a)(3), include but are not limited

to:

A. any and all proceeds or property derived from proceeds traceable to the

racketeering activities alleged in Count One during the relevant time period alleged in this

indictment and all interests and proceeds traceable thereto,

B. a Lorcin, Model LT .25 caliber firearm, bearing serial number LT22506;

and

C. a Winchester, Model 120, 12 gauge shotgun, bearing serial number L1427.

4. If any of the above-described forfeitable property, as a result of any act or

omission of the defendants:

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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 18, United States Code, Section 1963(m), to

seek forfeiture of any other property of said defendants up to the value of the above forfeitable

property.

All pursuant to Title 18, United States Code, Section 1963.

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NOTICE OF FORFEITURE - TWO

THE GRAND JURY FURTHER CHARGES THAT:

As a result of the violations of Title 18, United States Code, Section 1594(c), set

forth in this indictment, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,”
ALEXANDER M. MALAVE,
a/k/a “Buju,”
a/k/a “Ace,”
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”
FATIEMA S. BIVINS,
ISAIAH ROWE,
a/k/a “Izzy,” and
JAMES GOODE,
a/k/a “Jamil,”
YOJANG TORRES-ROSARIO,
a/k/a “Domi,”
RICHARD POULSON,
a/k/a “ATL,”
JESSICA LOPEZ,
a/k/a “Mother of the Sevens,”
RYAN NUNEZ,
TYASHIA MONROE,
a/k/a “Little Baby,”
WENDY ESPADA, and
MICHAEL DIAZ-WALKER,
a/k/a “Big Mike,”

shall forfeit to the United States of America any property, real or personal, that was used or

intended to be used, in any manner or part, to commit, or to facilitate the commission of, the

violation of Title 18, United States Code, Section 1594(c), or any property, real or personal,

constituting or derived from, any proceeds that were obtained, directly or indirectly, as a result of

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such violation, as charged in this indictment.

All pursuant to Title 18, United States Code, Section 1594(d) and (e).

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NOTICE OF FORFEITURE - THREE

THE GRAND JURY FURTHER CHARGES THAT:

As a result of the violations of Title 18, United States Code, Sections 2251 and

2252, as set forth in this indictment, defendants

FATIEMA S. BIVENS, and


MICHAEL DIAZ-WALKER,
a/k/a “Big Mike,”

shall forfeit to the United States of America:

(a) any visual depiction, or any film, videotape, or other matter which

contains any child pornography, which was produced, transported, mailed, shipped, or received

as a result of such violations as charged in the indictment;

(b) any property, real or personal, constituting or derived from any

proceeds obtained directly or indirectly from such violations, pursuant to 18 U.S.C. § 2422(b);

and

(c) any property, real or personal, used or intended to be used to

commit or to facilitate the commission of such violations, including, but not limited to:

(1) an LG Aristo 2 cellular telephone, model number LM-

X210MA, bearing IMEI 3576030929227110.

If any of the property subject to forfeiture, as a result of any act or omission of the

defendant:

(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;

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(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;

it is the intent of the United States, pursuant to Title 18, United States Code, Sections 2428 and

2253(b), incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any

other property of the defendant(s) up to the value of the property subject to forfeiture.

All pursuant to Title 18, United States Code, Sections 2428 and 2253.

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NOTICE OF FORFEITURE - FOUR

THE GRAND JURY FURTHER CHARGES THAT:

1. As a result of the violations of Title 18, United States Code, Section

922(g) set forth in this indictment, defendants

SHAQUILE W. NEWSON,
a/k/a “Raw,”
a/k/a “San,” and
KARVARISE E. PERSON,
a/k/a “Crazy K,”
a/k/a “Killa,”
a/k/a “K,”

shall forfeit to the United States of America the firearm and ammunition involved in the

commission of such offense, including, but not limited to:

(a) a Lorcin, Model LT .25 caliber firearm, bearing serial number

LT22506; and

(b) a Winchester, Model 120, 12 gauge shotgun, bearing serial number

L1427.

All pursuant to Title 28, United States Code, Section 2461(c), and Title 18,

United States Code, Section 924(d).

A TRUE BILL:

GRAND JURY FOREPERSON

____
WILLIAM M. McSWAIN
United States Attorney

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