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REDACTED FILED
COPY
SEALEDUNI TED STATES DISTRICT COURT
APR 1 7 2019
WESTERN DISTRICT OF TEXAS CL T CLERK
OF TEXAS
SAN ANTOMO DIVISION BY
UNITED STATES OF AMERICA ItFM
1
Plaintiff, § ) COUNT 1: Vio: 21 U.S.C. § 84
§ 841(a)(1) & 841(b)(1)(B)/(C):
VS. § Conspiracy to Possess with intent
§ to Distribute Cocaine Base,
DEUANDRE JERMORE WILLIAMS (1), § Methamphetamine, and Cocaine
aka "DRE" § ) COUNTS 2-4: Vio: 21 U.S.C. §
aka "D.R.E." § 841(a)(1) & 841(b)(1)(B), 18 U.S.C.
JTJSTIN TREMAYNE WOOLEY (2), § § 2: Possession with intent to
aka "JTJTT" § Distribute Cocaine Base and
DEREK DESHON WILLIAMS (3), § Methamphetamine, Aiding and
JOHNNY EARL IITJGHES (4), § Abetting
ANDRE JARRELL WILLIAMS (5), § ) COUNT 5: Vio: 21 U.S.C. §
aka "RED" § 841(a)(1) & 841(b)(1)(B):
FREDDIE LEE SCOTT (6), § Possession with intent to Distribute
aka "LIL FREDDIE" § Methamphetamine
MARSHALL LEE BRADDY (7), § COUNTS 6-10: Yb: 21 U.S.C. §
DARRIAL GENE CARTER (8); § 841(a)(1) & 841(b)(1)(B), 18 U.S.C.
aka "BOOTCIIIE" § § 2: Possession with intent to
aka "DC" § Distribute Methamphetamine and
SALVADOR BARRIOS-MESAS (9), § Cocaine, Aiding and Abetting
aka "JORGE UGARTE" §
CYNTHIA CORINA VALDEZ (10), §
§
Defendants. §
§
THE GRAND JURY CHARGES:
COUNT ONE
[21 U.S.C. § 846, 841(a)(1) & 841(b)(1)(B)I(C)]
Beginning on or about June 1, 2016, the exact date unknown, and continuing until the date
of this indictment, in the Western District of Texas, Defendants,
DEUANDRE JERMORE WILLIAMS (1),
JIJSTIN TREMAYNE WOOLEY (2),
DEREK DESHON WILLIAMS (3),
JOHNNY EARL HUGHES (4),
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ANDRE JARRELL WILLIAMS (5),
FREDDIE LEE SCOTT (6),
MARSHALL LEE BRADDY (7),
DARRIAL GENE CARTER (8),
SALVADOR BARRIOS-MESAS aka "JORGE UGARTE" (9), and
CYNTHIA CORINA VALDEZ (10),
knowingly and intentionally conspired, combined, confederated, and agreed together, and with
each other, and with others, to commit the following offenses against the United States: to
distribute a controlled substance, which offense involved cocaine base, methamphetamine, and
cocaine, Schedule II Controlled Substances, in violation of Title 21, United States Code Sections
841(a)(1) and 841(b)(1)(A), 841(b)(1)(B) and 841(b)(1)(C).
QUANTITY OF CONTROLLED SUBSTANCE INVOLVED IN THE CONSPIRACY
The quantity of the mixture or substance containing a controlled substance involved in the
conspiracy and attributable to each Defendant as a result of each Defendant's own conduct and as
a result of the conduct of other conspirators reasonably foreseeable to each Defendant is as follows:
DEFENDANT QUANTITY
Deuandre Williams (1) 28 grams or more of a mixture or substance containing a detectable
amount of cocaine base;
50 grams or more of a mixture or substance containing a detectable
amount of methamphetamine;
A mixture or substance containing a detectable amount of cocaine, its
salts, optical and geometric isomers, and salts of isomers;
Justin Wooley (2) 50 grams or more of a mixture or substance containing a detectable
amount of methamphetamine;
500 grams or more of a mixture or substance containing a detectable
amount of cocaine, its salts, optical and geometric isomers, and salts
of isomers;
Derek Williams (3) 50 grams or more of a mixture or substance containing a detectable
amount of methamphetamine;
2
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Johnny Hughes (4) 500 grams or more of a mixture or substance containing a detectable
amount of cocaine, its salts, optical and geometric isomers, and salts
of isomers;
Andre Williams (5) 28 grams or more of a mixture or substance containing a detectable
amount of cocaine base;
50 grams or more of a mixture or substance containing a detectable
amount of methamphetamine;
A mixture or substance containing a detectable amount of cocaine, its
salts, optical and geometric isomers, and salts of isomers;
Freddie Scott (6) 50 grams or more of a mixture or substance containing a detectable
amount of methamphetamine;
A mixture or substance containing a detectable amount of cocaine
base;
Marshall Braddy (7) 28 grams or more of a mixture or substance containing a detectable
amount of cocaine base;
50 grams or moreof a mixture or substance containing a detectable
amount of methamphetamine;
Darrial Carter (8) 50 grams or moreof a mixture or substance containing a detectable
amount of methamphetainine;
Salvador Barrios-Mesas (9) 500 grams or more of a mixture or substance containing a detectable
amount of cocaine, its salts, optical and geometric isomers, and salts
of isomers;
Cynthia Valdez (10) 28 grams or more of a mixture or substance containing a detectable
amount of cocaine base;
All in violation of Title 21, United States Code, Section 846.
COUNT TWO
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2]
That on or about August 21, 2018, in the Western District of Texas, Defendants,
DEUANDRE JERMORE WILLIAMS (1), and
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ANDRE JARRELL WILLIAMS (5),
aided and abetted by each other, did knowingly, intentionally and unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 28 grams or more of a mixture
or substance containing a detectable amount of cocaine base, a Schedule II Controlled Substance,
in violation of Title 21, United States Code, Sections 841 (a)(1) and 841 (b)(l )(B) and 18 U.S.C.
§
2.
COUNT THREE
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2]
That on or about September 5, 2018, in the Western District of Texas, Defendants,
DEUANDRE JERMORE WILLIAMS (1),
ANDRE JARRELL WILLIAMS (5), and
MARSHALL LEE BRADDY (7),
aided and abetted by each other, did knowingly, intentionally and unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 28 grams or more of a mixture
or substance containing a detectable amount of cocaine base, a schedule II Controlled Substance,
and 50 grams or more of a mixture or substance containing a detectable amount of
methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II Controlled Substance, in
violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(B) and 18 U.S.C.
§ 2.
COUNT FOUR
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2]
That on or about October 11-12, 2018, in the Western District of Texas, Defendants,
DEUANDRE JERMORE WILLIAMS (1),
ANDRE JARRELL WILLIAMS (5), and
CYNTHIA CORINA VALDEZ (10),
aided and abetted by each other, did knowingly, intentionally and unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 28 grams or more of a mixture
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or substance containing a detectable amount of cocaine base, a Schedule II Controlled Substance,
in violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(B) and 18 U.S.C.
§
2.
COUNT FWE
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B)]
That on or about October 24, 2018, in the Western District of Texas, Defendant,
FREDDIE LEE SCOTT (6),
did knowingly, intentionally and unlawfully possess with the intent to distribute, a controlled
substance, which offense involved 50 grams or more of a mixture or substance containing a
detectable amount of methamphetamine, its salts, isomers, or salts of its isomers, a Schedule II
Controlled Substance, in violation of Title 21, United States Code, Sections 841 (a)( 1) and
841 (b)(l)(B).
COUNT SIX
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2J
That on or about November 16, 2018, in the Western District of Texas, Defendant,
JUSTIN TREMAYNE WOOLEY (2)
aided and abetted by each other, did knowingly, intentionally and unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 500 grams or more of a mixture
or substance containing a detectable amount of cocaine, its salts, optical and geometric isomers,
and salts of isomers, a Schedule II Controlled Substance, in violation of Title 21, United States
Code, Sections 841(a)(1) and 841(b)(1)(B) and 18 U.S.C. § 2.
COUNT SEVEN
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2]
That on or about December 10, 2018, in the Western District of Texas, Defendants,
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JtJSTIN TREMAYNE WOOLEY (2), and
DEREK DESHON WILLIAMS (3),
aided and abetted by each other, did knowingly, intentionally and
unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 50
grams or more of a mixture
or substance containing a detectable amount of
methamphetamine, its salts, isomers, or salts of its
isomers, a Schedule IT Controlled Substance, in violation of Title 21, United States Code,
Sections
841(a)(1) and 841(b)(l)(B) and 18 U.S.C. § 2.
COUNT EIGHT
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. 2]
§
That on or about January 9, 2019, in the Western District of Texas,
Defendants,
JEJSTIN TREMAYNE WOOLEY (2), and
DARRIAL GENE CARTER (8),
aided and abetted by each other, did knowingly, intentionally and
unlawfully possess, and attempt
to posses, with the intent to distribute, a controlled substance,
which offense involved 50 grams or
more of a mixture or substance containing a detectable amount of
methamphetamine, its salts,
isomers, or salts of its isomers, a Schedule II Controlled Substance, in
violation of Title 21, United
States Code, Sections 841(a)(l) and 841(b)(1)(B) and 18 U.S.C.
§ 2.
COUNT NINE
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 U.S.C. § 2]
That on or about January 24, 2019, in the Western District of
Texas, Defendants,
JUSTIN TREMAYNE WOOLEY (2),
JOHNNY EARL HUGHES (4), and
SALVADOR BARRIOS-MESAS aka "JORGE UGARTE" (9),
aided and abetted by each other, did knowingly, intentionally and
unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 500
grams or more of a mixture
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or substance containing a detectable amount of cocaine, its salts, optical and geometric isomers,
and salts of isomers, a Schedule II Controlled Substance, in violation of Title 21, United States
Code, Sections 841(a)(1) and 841(b)(1)(B) and 18 U.S.C. § 2.
COUNT TEN
[21 U.S.C. § 841(a)(1) & 841(b)(1)(B) and 18 u.s.c. § 2J
That on or about January 24, 2019, in the Western District of Texas, Defendants,
JUSTIN TREMAYNE WOOLEY (2), and
DEREK DESIION WILLIAMS (3)
aided and abetted by each other, did knowingly, intentionally and unlawfully possess with the
intent to distribute, a controlled substance, which offense involved 50 grams or more of a mixture
or substance containing a detectable amount of methamphetamine, its salts, isomers, or salts of its
isomers, a Schedule II Controlled Substance, in violation of Title 21, United States Code, Sections
841(a)(1) and 841(b)(1)(B) and 18 U.S.C. § 2.
JOHN F. BASH
UNITED STATES ATTORNEY
BY:
ERIC FUCIS
Assistant United States Attorney
