As alleged in the indictment (see WDWV-ECF)
Defendants:
Lenin Erasmo Luna Mota, also known as “Papi,” 48, of Hagerstown, MD and the Dominican Republic
Juan Manuel De La Rosa-Tejeda, also known as “Little Papi,” 35, of Hagerstown, MD and the Dominican Republic
Daniel Inoa-Rodriguez, also known as “Danny,” 21, of Hagerstown, MD
Shawn Gorsira, 50, of Hagerstown, MD
Ana Ercilia Luna, 36, of Hagerstown, MD and the Dominican Republic
Stephany Rodriguez, 32, of Hagerstown, MD
Dominick Mickens, 38, of Hagerstown, MD
Jackie Devon Thompson, 41, of Frederick, MD
Tyrone Lewis, Aka Roc, 42, of Hagerstown, MD
Alan Clark Tolliver, 41, of Hagerstown, MD
Miguel Angel Santiago Caraballo, 30, of Chambersburg, PA
Carl Lomax Wynn, 56, of Hagerstown, MD
Marcus Deon Longus, 27, of Hagerstown, MD
Thomas Moore, 38, of Hagerstown, MD
Samuel Rose, 48, of Martinsburg, WV
Deondre Trayham, 32, of Martinsburg, WV
Branden Watson, 38, of Martinsburg, WV
Caleb Sinclair, 35, of Martinsburg, WV
Destiny Dabbs, 29, of Martinsburg, WV
Felicia Johnson, 34, of Martinsburg, WV
Brian C. Dixon, 49, of Martinsburg, WV
Christina Anders, 25, of Hagerstown, MD
Edwin Orrillio, also known as “J Money,” 34, of Hagerstown, MD
Paul David Fairburn, 26, of Hagerstown, MD
Edson Velasquez-Lopez, 50, of Martinsburg, WV
Chelsea Nicole Pinkcett, 33, of Martinsburg, WV
Daniel Hardy, 33, of Martinsburg, WV
Eliseo Rozas, 43, of Berkeley Springs, WV
Ron Bowers, 52, of Martinsburg, WV
Angela Dawn Gregory, 47, of Martinsburg, WV
Demitre Mccoy White, 40, of Martinsburg, West Virginia
Devron Jerel Brown, also known as “Country,” 33, of Martinsburg, WV
Lester Luna, 27, of Hagerstown,MD
Carlos M. Nunez-Arias, also known as “Charlote,” 51, of Hagerstown, MD
Charges in the Indictment
18 U.S.C. § 2 - Aiding and Abetting (a) Whoever commits an offense against the United States or aids, abets, counsels, commands, induces or procures its commission, is punishable as a principal
18 U.S.C. § 1956(h)) -Laundering of monetary instruments (h) Any person who conspires to commit any offense defined in this section or section 1957 shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy.
18 U.S.C. § 1957 - Engaging in monetary transactions in property derived from specified unlawful activity…Whoever, in any of the circumstances set forth in subsection (d), knowingly engages or attempts to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity, shall be punished as provided in subsection (b). - the Government must prove all five elements (inclusively it’s not an “either or”)
FIRST, the defendant must knowingly engage or attempt to engage in a monetary transaction;
SECOND, the defendant must know that the transaction involved criminally derived property;
THIRD, the criminally derived property must be of a value greater than $10,000;
FOURTH, the criminally derived property must also, in fact, have been derived from a specified unlawful activity; and
FIFTH, the monetary transaction must have taken place [specify either]:
21 U.S.C. § 841(a)(1) - Distribution/Manufacturing/Possession with intent to Distribute -Statutory maximum generally is 20 years
21 U.S.C. § 841(b)(1)(A) - it shall be unlawful for any person knowingly or intentionally—See pages 1 thru 3 of embedded statute - but generally speaking;
(1)to manufacture, distribute, or dispense, or possess with intent to manufacture,distribute, or dispense, a controlled substance; or
(2)to create, distribute, or dispense, or possess with intent to distribute or dispense, a counterfeit substance.
21 U.S.C. § 841(b)(1)(B) - Five year mandatory minimum and maximum 40 years if; 5 grams or more of actual meth, 28 grams or more of crack, 50 grams or more of a mixture containing meth. 40 grams or more of fentanyl, 100 grams or more of heroin, 10 grams or more of PCP, 500 grams or more of cocaine, 1 gram or more of LSD, 100 kilogram or more of marijuana (or 100 or more plants)
21 U.S.C. § 843(b) - Prohibited acts C - (b) Communication facility -It shall be unlawful for any person knowingly or intentionally to use any communication fa- cility in committing or in causing or facilitat- ing the commission of any act or acts constitut- ing a felony under any provision of this sub- chapter or subchapter II of this chapter. Each separate use of a communication facility shall be a separate offense under this subsection. For purposes of this subsection, the term ‘‘commu- nication facility’’ means any and all public and private instrumentalities used or useful in the transmission of writing, signs, signals, pictures, or sounds of all kinds and includes mail, tele- phone, wire, radio, and all other means of com- munication
21 U.S.C. § 846 - prohibited acts C
The 30-count indictment (see WDWV-ECF) charges 34 people from West Virginia, Maryland, Pennsylvania, and the Dominican Republic for allegedly conducting a drug trafficking operation that included large amounts of heroin, fentanyl, cocaine base, and cocaine hydrochloride from Hagerstown, Maryland to locations in Berkeley County, West Virginia from August 2020 to June 2021.
seized during the investigation amounted to 8.6 kilograms of cocaine
1.02 kilograms of heroin,
and 12 ounces of cocaine base “crack,” with a street value of approximately $471,000
One thing to keep in mind - not ALL Defendants are charged with all thirty counts - so you need to be aware of that when reading the Indictment
Count One:
Conspiracy to Possess with Intent to Distribute and to Distribute Five Kilograms or More of a Mixture or Substance Containing Cocaine,
From on or about August 1, 2020, to on or about June 22, 2021, in Berkeley County, in the Northern District of West Virginia, and elsewhere, defendants LENIN ERASMO LUNA MOTA, aka“Papi,” and JUAN MANUEL DE LA ROSA-TEJEDA, aka “Little Papi,”
COUNT TWO
Conspiracy to Possess with Intent to Distribute and to Distribute Heroin, Fentanyl, Cocaine Base, and Cocaine Hydrochloride…looks like everyone in named as a Defendant as to Count Two
From on or about August 1, 2020, to on or about June 22, 2021, in Berkeley County, in the Northern District of West Virginia, and elsewhere, defendants LENIN ERASMO LUNA MOTA, aka“Papi,” JUAN MANUEL DE LA ROSA-TEJEDA, aka “Little Papi,” DANIEL INOA RODRIQUEZ, aka “Danny,” SHAWN GORSIRA, ANA ERCILIA LUNA, STEPHANY RODRIGUEZ, DOMINICK MICKENS, JACKIE DEVON THOMPSON, TYRONE LEWIS, aka“Roe,” ALAN CLARK TOLLIVER, MIGUEL ANGEL SANTIAGO CARABALLO, CARL LOMAX WYNN, MARCUS DEON LONGUS, THOMAS MOORE, SAMUEL ROSE, DANDRE TRAYHAM, BRANDEN WATSON, CALEB SINCLAIR, DESTINY DABBS, FELICIA JOHNSON, BRIAN C. DIXON, CHRISTINE ANDERS, EDWIN ORRILLIO, aka “J Money,” PAUL DAVID FAIRBURN, EDSON VELASQUEZ-LOPEZ, CHELSEA NICOLE PINKCETT, DANIEL HARDY, ELISEO JEROME ROZAS, RONALD MICHAEL BOWERS, ANGELA DAWN GREGORY, DEMITRE MCCOY WHITE, DEVRON JEREL BROWN, aka “Country,” LESTER LUNA, and CARLOS M. NUNEZ-ARIAS, aka “Charlote,” did unlawfully, knowingly, intentionally, and without authority combine, conspire, confederate, agree and have a tacit understanding together with each other and other persons to violate Title 21, United States Code, Section 841 (a)( 1).
COUNT THREE
Conspiracy to Launder Monetary Instruments
During a period commencing on or about August 1, 2020, and ending on or about June 22, 2021, in Berkeley County, in the Northern District of West Virginia, defendant LENIN ERASMO LTJNA MOTA, aka “Papi,” and LESTER LUNA did knowingly combine, conspire, and agree with each other and with other persons to commit offenses against the United States in violation of Title 18, United States Code, Section 1956 and Section 1957.
Based on the facts elucidated in the Indictment - the Defendants used a legitimate Brick and Mortar Store/Business Top3Source and YES you betcha I archived their Facebook Page, found here and their Facebook Store-front Reviews I AM HERE for it, all of it.
COUNT FOUR
Aiding and Abetting the Distribution of Cocaine Hydrochloride
On or about August 20, 2020, in Berkeley County, in the Northern District of West Virginia, defendants BRANDEN WATSON aided and abetted by SAMUEL ROSE, DESTINY DABBS, and CALEB SINCLAIR did unlawfully, knowingly, intentionally, and without authority, distribute a mixture and substance containing
…a detectable amount of cocaine hydrochloride, also known as “coke,” a Schedule II controlled substance, in exchange for $600 in United States currency; in violation of Title 18, United States Code, Section 2, and Title 21, United States Code, Sections 841 (a)(l) and 841 (b)(l)(C).
COUNT FIVE
Distribution of Cocaine Base
On or about August 21, 2020, in Berkeley County, in the Northern District of West Virginia, defendants SAMUEL ROSE and BRANDEN WATSON did unlawfully, knowingly, intentionally, and without authority, distribute a mixture and substance containing a detectable amount of …
...cocaine base, also known as “crack,” a Schedule II controlled substance, in exchange for $1,100 in United States currency; in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(l)(C).
COUNT SIX
Distribution of Heroin
On or about August 21, 2020, in Berkeley County, in the Northern District of West Virginia, defendants SAMUEL ROSE and BRANDEN WATSON did unlawfully, knowingly, intentionally, and without authority, distribute a mixture and substance containing a detectable amount of …
…heroin, a Schedule I controlled substance, in exchange for $600 in United States currency; in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C).
COUNT SEVEN
Distribution of Cocaine Base
On or about August 25, 2020, in Berkeley County, in the Northern District of West Virginia, defendants SAMUEL ROSE and BRANDEN WATSON did unlawfully, knowingly, intentionally, and without authority, distribute a mixture and substance containing a detectable amount of cocaine base…
.. also known as “crack,” a Schedule II controlled substance, in exchange for $1,000 in United States currency; in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C).
COUNT EIGHT
Distribution of a Heroin and Fentanyl Mixture
On or about August 25, 2020, in Berkeley County, in the Northern District of West Virginia, defendants SAMUEL ROSE and BRANDEN WATSON did unlawfully, knowingly, intentionally, and without authority, distribute a mixture and substance containing a detectable amount of heroin, a Schedule I controlled substance, and fentanyl, a Schedule II controlled substance, in exchange for $600 in United States currency; in violation of Title 21, United States Code, Sections 841 (a)( 1) and 841 (b)(1 )(C).
An no there is (at the time of this publication an open source link to the 36 page indictment, so I paid the $3.00 and uploaded it to my Scribd Account, found here) because I’m trying really hard not to be a document hoarding “oh look at me” Asshole so YES I want my readers to have access to public federal court documents
https://www.scribd.com/document/517613716/USA-v-LUNA-MOTA-Aka-Papi-Et-Al-34-Defendants
I personally found page 35 the most interesting because that’s a lot of money that was seized in advance of the Notice of Forfeiture:
FORFEITURE ALLEGATION pursuant to the Federal Controlled Substance Act;
Title 21, United States Code, Section 853 and Title 21, United States Code, Sections 841 and 846, the government will seek the forfeiture of property as part of the sentence imposed in this case; that is, the forfeiture of any property used, or intended to be used, to commit or to facilitate the commission of the above referenced offense, and any property constituting, or derived from, proceeds obtained directly or indirectly, as a result of such offense, including the following items:
$30,000 seized from Daniel Inoa-Rodriquez on March 30, 2021;
$227,000 in Top 3 Sources’ Fulton Bank account;
$121,670 seized on June 22, 2021;
$27,230 seized on June 22, 2021;
$4,116 seized from Miguel Angel Santiago Caraballo’s residence on June 22, 2021;
Firearms also seized: 12. A R.G. Industries, .22 revolver, bearing serial number 785567 from Shawn Gorsira’ s residence; 13. Four rounds of .22 caliber ammunition seized from Shawn Gorsira’ s residence…
And your prerequisite multimedia video of the newly unsealed 30 count indictment because I needed a decent laugh so I included the Top 3 Sources Facebook reviews - my god that was a lot of fun and based on a cursory query in a factual recognition software at least 4 of the defendants are in the April 30, 2020 Facebook Video
—yes for purported unemployed chain smoking, alcoholic bored housewife (because I don’t use LinkedIn LOLS) it sure seems like I have various research tools that are widely used in the legal community —but wait then I’ll be accused of improperly using my employers resources?
Oh FFS and LOL so which is it am I employed or not? Make up your damn besmirching and uniformed minds -it’s exhausting keeping up with the various smears… me laughs and laughs and laughs. Notice how none of the Voldemorts won’t come here? Because the fact I was targeted with a calibrated DDOS attack - come on in my lids’ trolls the water is warm-ish.
Also wanna see what my husband of 18 years bought me as an early anniversary gift? Because unlike my stalkers I’d never cheat on my spouse. I took my wedding vows seriously — pity that you didn’t. Close your legs to married people
Oh frabjous joy when you were wed to Mr. Spicy! Happy anniversary! (Closing your legs is just generally good advice.)
Happy Anni! Also yay DOJ and boo cheaters