Case 1:10-cr-00265-RCL Document 3 Filed 09/28/10 Page 1 of 4

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Holding a Criminal Term

Grand Jury Sworn in on May 15, 2009

UNITED STATES OF AMERICA, : CRIMINAL NO.

:
v. : GRAND JURY ORIGINAL
:
CURTIS M. HOUSTON, : VIOLATIONS: 21 U.S.C. § 846
also known as C, : (Conspiracy to Distribute and Possess With
also known as Long Dog, : Intent to Distribute 5 Kilograms or More of
: Cocaine and 50 Grams or More of Cocaine
TYRONE W. GLOSTER, : Base)
also known as Freaky, : 21 U.S.C. § 853
: (Criminal Forfeiture)
SAQUON K. BETHEA, :
also known as Quon, :
also known as Q, :
:
ELLIOTT F. DAVIS, :
also known as L, :
:
WILLIAM R. A. SMITH, :
also known as Anwan, :
also known as Ant, :
also known as Anwur, :
:
JIMMY L. HAIRSTON, :
:
WYATT E. ROBINSON, :
:
RICKY CHADWICK, :
:
Defendants. :
:

INDICTMENT

The Grand Jury charges that:

 Case 1:10-cr-00265-RCL Document 3 Filed 09/28/10 Page 2 of 4

COUNT ONE

From on or about October 1, 2008, to on or about August 1, 2010, within the District of

Columbia and elsewhere, CURTIS M. HOUSTON, also known as C, also known as Long Dog,

TYRONE W. GLOSTER, also known as Freaky, SAQUON K. BETHEA, also known as Quon,

also known as Q, ELLIOTT DAVIS, also known as L, WILLIAM R. A. SMITH, also known as

Anwan, also known as Ant, also known as Anwur, JIMMY L. HAIRSTON, WYATT E.

ROBINSON, RICKY CHADWICK and MARK D. SMITH, a co-conspirator not indicted herein,

did knowingly and willfully combine, conspire, confederate and agree together and with other

persons both known and unknown to the Grand Jury, to unlawfully, knowingly and intentionally

distribute and possess with intent to distribute a mixture and substance containing a detectable

amount of cocaine, a Schedule II narcotic drug controlled substance, and the amount of said mixture

and substance was 5 kilograms or more, in violation of Title 21, United States Code, Sections

841(a)(1) and 841(b)(1)(A)(I), and a mixture and substance containing a detectable amount of

cocaine base, also known as crack, a Schedule II narcotic drug controlled substance, and the amount

of said mixture and substance was 50 grams or more, in violation of Title 21, United States Code,

Sections 841(a)(1), 841(b)(1)(A)(ii), and 841(b)(1)(A)(iii).

(Conspiracy to Distribute and Possess with Intent to Distribute 5 Kilograms or More

of Cocaine and 50 Grams or More of Cocaine Base, in violation of Title 21, United States
Code, Section 846)

FORFEITURE ALLEGATION

1. The allegations contained in Count One of this Indictment, Conspiracy to Distribute

and Possess with Intent to Distribute 5 Kilograms or More of Cocaine and 50 Grams or More of

Cocaine Base, in violation of Title 21, United States Code, Section 846, are hereby realleged and

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incorporated by reference for the purpose of alleging forfeiture pursuant to Title 21, United States

Code, Section 853.

2. Pursuant to Title 21, United States Code, Section 853, upon conviction of an offense

in violation of Title 21, United States Code, Section 846, the defendants shall forfeit to the United

States of America any property constituting, or derived from, any proceeds obtained, directly or

indirectly, as the result of such offense and any property used, or intended to be used, in any manner

or part, to commit, or to facilitate the commission of, the offense.

The property to be forfeited includes, but is not limited to, the following:

(a) Money Judgment:

(i) a sum of money that is equal to the amount of money constituting,

or derived from, proceeds obtained, directly or indirectly, as a result
of the offense alleged in Count One.

(b) U.S. Currency

(i) $5,617 in U.S. Currency, which represents a sum of money constituting, or

derived from, proceeds obtained, directly or indirectly, as a result of the offense
alleged in Count One.

3. If any of the property described above, as a result of any act or omission

of the defendants:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

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e. has been commingled with other property which cannot be divided without

difficulty;

the United States of America shall be entitled to forfeiture of substitute property pursuant to Title

21, United States Code, Section 853(p).

(Criminal Forfeiture, in violation of Title 21, United States Code, Section 853)

A TRUE BILL:

FOREPERSON.

Attorney of the United States in

and for the District of Columbia.