2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 1 of 9

Pg ID 351

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED STATES OF AMERICA, Plaintiff, v. GEORGE ARTHUR DODSON III, Defendant. / PRELIMINARY EXHIBIT LIST NOW COMES the United States of America, by and through its undersigned attorneys, and submits for the Courts consideration this preliminary exhibit list. The Government requests leave to amend this exhibit list prior to the start of trial. This Exhibit List is in numerical order, except for the machine guns and silencer charged in the First Superseding Indictment that do not bear a serial number and instead were provided unique ATF Exhibit numbers. For the jury and the Courts ease and to avoid confusion, those exhibits are given the same unique ATF Exhibit Numbers from the First Superseding Indictment in the attached Exhibit List. Respectfully submitted, BARBARA L. MCQUADE United States Attorney s/Kevin M. Mulcahy KEVIN M. MULCAHY DOUGLAS C. SALZENSTEIN Assistant United States Attorneys 211 W. Fort Street, Suite 2001 Detroit, MI 48226 Phone: (313) 226-9713 Dated: May 3, 2012 CRIMINAL NO. 11-20548 HONORABLE SEAN F. COX

2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 2 of 9

Pg ID 352

PRELIMINARY EXHIBIT LIST

Exhibit Number 1 2 3 4 5 6 7 8 9

Identification of Exhibit Mega Machine, Model M.M.S., .223 Caliber Rifle, bearing serial number MGA0104 Photograph of governments exhibit #1 as found at 6021 Tomer Road, Clayton Michigan Napkin with Su Press On contact information Photograph of George Dodsons Apartment Building Photograph of George Dodson mailing DIAS at the post office Photograph of George Dodson mailing DIAS at the post office Video of Special Agent Brian Luetke test firing governments exhibit #1 Shotgun news advertisement for Su Press On Copy of the envelope sent to Defendant from Special Agent Brian Luetke, using the undercover persona of Jeff Allen, purchasing a DIAS in response to Shotgun News Ad Copy of the Money Order sent by Jeff Allen to Su Press On, in the amount of $105 on March 7, 2011 Original of the receipt of the Money Order in governments exhibit #10 Envelope addressed to Jeff Allen from Su-Press-On with Postal Stamp dated March 17 Su-Press-On Handout that came inside governments exhibit 12 Drop-In-Auto-Sear sent by Dodson to Jeff Allen, contained within governments exhibit 12 Video of George Dodson at the Knob Creek (Kentucky) machine gun shoot 2

Witness Leslie Larson Leslie Larson Leslie Larson Leslie Larson Leslie Larson Leslie Larson Brian Luetke Brian Luetke Brian Luetke

10 11 12 13 14 15

Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke

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Filed 05/03/12 Pg 3 of 9

Pg ID 353

16 17 17A 17B 17C 17D 17E 313

Photograph of Dodsons Briefcase from 8/16/11 with contents shown George Dodsons briefcase (which contained contents) 2011 pocket calendar (inside of briefcase) Comerica checkbook for Su-Press-On checks (inside of briefcase) Comerica deposit book (inside of briefcase) Notebook of Dodsons writings (inside of briefcase) Bank stamp with Su-Press-On account number (inside of briefcase) DIAS and packaging ready for shipment to Chet Dewey of Oklahoma (found inside of George Dodsons briefcase at time of arrest) 1 of 2 DIASs and packaging ready for shipment to Jacob Whitehead of Oklahoma (found inside of George Dodsons briefcase at time of arrest) 2 of 2 DIASs removed from package ready for shipment to Jacob Whitehead of Oklahoma (found inside of George Dodsons briefcase at time of arrest) Stack of opened envelopes mailed to Su-Press-On, including Jeff Allen envelope United States Postal Service Insured Mail Receipts for 2006-2011, including one in large envelope with writing on the envelope United States Postal Service Insured Mail Receipt for Jeff Allen United States Postal Service Insured Mail Receipt for Mr. Azuurlin of 6021 Tomer Road, Clayton, Michigan United States Postal Service Insured Mail Receipt for Rafael Estevez of Moreno Valley, California Picture of stack of fliers for Su-Press-On from living room cabinet

Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke

314

Brian Luetke

315

Brian Luetke

18 19

Brian Luetke Brian Luetke

19A 19B

Brian Luetke Brian Luetke

19C 20

Brian Luetke Brian Luetke

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Filed 05/03/12 Pg 4 of 9

Pg ID 354

21 22 23 24 25 26 51A 51B 51C 51D 51E 51F 51G 51H 51I 51J 51K 51L 51M 51N 27 28

Stack of fliers for Su-Press-On from living room cabinet Orange hats and shirts with Supercrank on them Photograph #1 of Dodsons show kit from 8/16/11 Photograph #2 of Dodsons show kit from 8/16/11 Photograph #3 of Dodsons show kit from 8/16/11 Dodsons show kit DIAS recovered from Dodsons show kit on 8/16/11 with original bag containing all of Exhibits 51A-51N DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 DIAS recovered from Dodsons show kit on 8/16/11 Talley sheet showing sales of DIASs Envelope addressed to Su-Press-On at his PO Box, containing a templates for Sten receiver, with the words Sten Stuff on the back Book called How to Make Disposable Silencers Dodson writings regarding Low Boy silencer Su-Press-On informational material on silencer

Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke

29 30 31

Brian Luetke Brian Luetke Brian Luetke

2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 5 of 9

Pg ID 355

32

Silencer from basement storage unit (described in indictment as a metal cylindrical device approximately 4 1/8 inches in length and 1 1/8 inches in diameter) Picture of tools on living room table #1 Picture of tools on living room table #2 Picture of DIAS drawing on living room table Bag of tools seized from living room table Picture of drill press 1 Picture of drill press 2 Picture of drill press 3 Picture of the digital height gauge Picture of the grinder Skematics for DIASs Book called Semi Full Auto: AR15 Modification Manual Book called Converting the Armolite AR 180 Rifle to Full Auto With the Invisible Drop In Book called Converting the Colt AR15 Rifle from Semi-Automatic to Full Auto with this Invisible Drop In Money Order from Dodsons bank account for the DIAS sold to 6021Tomer Road Money Order from Dodsons bank account for the DIAS sold to Jeff Allen Money Order from Dodsons bank account for the DIAS sold to Rafael Estevez Bank Statement for George Dodsons Su-Press-On Account Tumbler seized from Metro Storage Facility Picture #1 of firearms and ammunition seized from U-Haul Storage Facility

Brian Luetke

33 34 35 36 37 38 39 40 41 42 43 44 45

Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke Brian Luetke

46 47 48 49 50 51

Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox

2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 6 of 9

Pg ID 356

52 53 54 55 56 283A 283B 283C 284 285 286 287 288 289 290 292 293 294 295 296 297 298 299 300 301 302

Picture #2 of firearms and ammunition seized from U-Haul Storage Facility Picture #3 of firearms and ammunition seized from U-Haul Storage Facility SPO metal punch found at U-Haul Storage Facility Bag of gun parts found at U-Haul Storage Facility Drill bit found at U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility 6

Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox

2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 7 of 9

Pg ID 357

303 304 79 57 58 242 243 275 277 278

DIAS seized from U-Haul Storage Facility DIAS seized from U-Haul Storage Facility Model 1919-type .30 caliber firearm, bearing no serial number Maxim-type, 7.62x 54R caliber firearm, bearing serial number M79 Model M2-type .50 BMG caliber firearm, bearing serial number SA0001 STEN-type 9mm caliber firearm, bearing no serial number .45 caliber firearm, of unknown manufacturer, and bearing no serial number Model M3A1 .45 ACP caliber receiver, bearing an obliterated serial number Model M3A1 .45 ACP caliber receiver, bearing an obliterated serial number Model M3A1 .45 ACP caliber receiver, bearing an obliterated serial number

Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox Jason Cox

59 60 61 62 63 64 65 66 67 68

Summary Exhibit #1: Description of the Su-Press-On Comerica Bank Account activity Summary Exhibit #2: 2006 Money Order Deposits Summary Exhibit #3: 2007 Money Order Deposits Summary Exhibit #4: 2008 Money Order Deposits Summary Exhibit #5: 2009 Money Order Deposits Summary Exhibit #6: 2010 Money Order Deposits Summary Exhibit #7: 2011 Money Order Deposits Summary Exhibit #8: Money Order Summary Deposits Summary Exhibit #9: Bar Chart of DIASs sold Certified Copy of Su-Press-Ons 2009 Michigan Individual Tax Returns and Supporting Documents 7

David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi David Dibiasi

2:11-cr-20548-SFC-LJM Doc # 55

Filed 05/03/12 Pg 8 of 9

Pg ID 358

69 70 71 72 73 74 75 76 77

Certified Copy of Su-Press-Ons 2010 Michigan Individual Tax Returns and Supporting Documents Picture of boiler room Picture of door inside boiler room Picture of lock on door inside boiler room CV of Michael Powell Animation of the DIAS and how it works Slides comparing M16 parts and AR15 parts Cutaway M16 demonstrative exhibit CV of Christopher Bartocci

David Dibiasi Jameel Gobah Jameel Gobah Jameel Gobah Michael Powell Michael Powell Michael Powell Michael Powell Christopher Bartocci

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Filed 05/03/12 Pg 9 of 9

Pg ID 359

CERTIFICATE OF SERVICE I hereby certify that on May 3, 2012, I electronically filed the foregoing document with the Clerk of the Court using the ECF system which will send notification of such filing to the following:

Sanford Schulman

s/Kevin M. Mulcahy KEVIN M. MULCAHY Assistant United States Attorney 211 W. Fort Street, Suite 2001 Detroit, MI 48226 Phone: (313) 226-9713