shepperson indictments

~G/DISILMP: USA02009ROO I07

~FILED LE,NTEREO- __ ,LODGED __ ," RECEIVED

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA

v.

CHINUA SHEPPERDSON,a/k/a "Nu,"a/k/a "NuNu,"a/k/a "King Nu,"

REMYHEATH,a/k/a "Remy,"a/k/a "King Remy,"a/k/a "King Mellow," and

BRANDON SMITH,a/k/a "Little One,"a/k/a "King Little One,"

Defendants

***********************

* * * * *

OCT 2 7 2010AT G.REENBEl T

ClERI( u.s. OISTRICTCOURTS~ DISTRICTOF MARYLANO-----~-t8U1i

CRIMINAL NO. AW-09-598

(Conspiracy to Participate in aRacketeering Enterprise, 18 U.S.C.~ 1962(d); Arson, 18 U.S.C. ~ 844(i);Using and Carrying a Firearm Duringand in Relation to a Crime of Violence,18 U.S.c. ~ 924(c); Interference withCommerce by Robbery, 18 U.S.C. ~1951; Murder in Aid of Racketeering,18 U.S.c. ~ 1959(a)(I); AttemptedMurder in Aid of Racketeering, 18U.S.c. ~ 1959(a)(5); Murder ResultingFrom Using and Carrying a FirearmDuring and in Relation to a Crime ofViolence, 18 U.S.c. ~ 924U); Aiding andAbetting, 18 U.S.c. ~ 2)

SUPERSEDING INDICTMENT(as to captioned Defendants only)

COUNT ONE

(Conspiracy to Participate in Racketeering Activity)

The Grand Jury for the District of Maryland charges that:

Introduction

1. At all times relevant to this Superseding Indictment, the following defendants and

others known and unknown to the Grand Jury were members and associates of the Almighty Latin

King and Queen Nation ("ALKQN" or "Latin Kings"), a criminal organization involved in the

Case 8:09-cr-00598-AW Document 377 Filed 10/27/10 of 28

commission of numerous acts of violence in the District of Maryland and elsewhere: CHINUA

SHEPPERDSON, a/k/a "Nu," a/k/a "NuNu," a/k/a "King Nu," REMY HEATH, a/kla "Remy,"

a/kla "King Remy," a/kla "King Mello," and BRANDON SMITH, a/kla "Little One," a/k/a

"King Little One." The following coconspirators were also members of the Latin Kings: Erick

Roman, a/kla "Erick Javier Sierra," a/kla "Malian-T," a/kla "King Malian-T," Matthew

Aguilar, a/kla "Mateo," a/kla "King Mateo," Miguel Castillo, a/kla "Colombia," a/kla "King

Colombia," Miguel Cruz, a/k/a "Skibee," a/k/a "King Skibee," Joseph Deleon, a/kla "Spirit,"

a/kla "King Spirit," Andres Echevarria, a/kla "B-Boy," a/kla "King B-Boy," Julio Kilgore,

a/kla "Murda," a/kla "King Murda," Erick Martinez, a/kla "Eazie," a/k/a "King Eazie,"

Melvin Nolasco, a/k/a "Joker," a/kla "King Joker," Senni Nolasco, a/k/a "Cano," a/kla "King

Cano," Francisco Ortiz, a/kla "Francis Gabriel Ortis," a/kla "Pone," a/kla "King Pone,"

Roddy E. Paredes, Jr., a/kla "Guate," a/k/a "King Guate," Leuri Read, a/k/a "Kampana,"

a/kla "King Kampana," Alejandro Rodriguez, a/kla "Sombra," a/kla "King Sombra," Nelson

Santos, a/kla "Nelly," a/kla "King Nelly," and Hugo Soto-Moran, a/kla "Vision," a/k/a "King

Vision."

2. The Latin Kings are a violent street gang with thousands of members across the

United States and overseas.

3. The traditional power centers of the Latin Kings, and members of the gang's national

leadership structure, are predominantly located in the Chicago (known as "KMC" or the

"Motherland") and New York (referred to as the "Bloodline") metropolitan areas.

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4. The Latin Kings have a detailed and uniform organizational structure, which is

outlined - along with various "prayers," codes of behavior, and rituals - in a written "manifesto"

widely distributed to members throughout the country.

5. At the local level, groups of Latin Kings are organized into "tribes," which are

traditionally anchored to a geographic area. A tribe can contain anywhere from a few dozen to a few

hundred members, depending on the area. Within each tribe, the leader is known as the "Inca," or

"First Crown," while other leadership positions can include: the "Cacique" or "Second Crown"; the

"Enforcer" or "Third Crown"; the "Treasurer" or "Fourth Crown"; and the "Secretary" or "Fifth

Crown." Each position in the tribe has defined responsibilities, and members are required to follow

the instructions and directives of the gang's leadersh"ip. Members of the Latin Kings are also

traditionally given "King Names" or "Queen Names," which are names other than their legal names,

by which they are known to members of the gang and to others on the street. Typically, each

member pays dues to the tribe, and dues are collected, and gang business is discussed, at weekly

meetings. On a semi-regular basis, larger meetings involving all of the tribes in a given area or

region - called "universals" - are held, at which larger issues concerning the gang as a whole and

cooperation among tribes is discussed. All of the tribes in a given state or region traditionally report

to, and pay dues to, the state or regional leadership.

6. The state or regional hierarchy generally mirrors the organizational structure of the

tribes in that there is a state or regional Inca, state or regional Cacique, and so forth, although some

locations have a slightly modified structure based on local practices. These state or regional leaders

then report to the national leadership of the Latin Kings, who advise and direct local leaders.

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7. Latin King leaders have the authority within the gang to order "missions," and mete

out punishment. A "mission" is an assignment given to a subordinate Latin King member that will

serve a purpose for the Latin King nation. The "missions" can range from a leader ordering a

"physie" (beating) to a "B.O.S." (beat down on sight), meaning the assault of a rival gang member

or a Latin King member who has committed a violation of the Latin King rules, to a "green light"

or "T.O.S." (terminate on sight), meaning the murder of a rival gang member or of a Latin King

member who may have committed an egregious violation of the gang's rules. Failure to perform a

"mission" results in the assigned member being in violation of the rules. Punishment for failing to

complete the "mission" can range anywhere from a beating to death.

8. Members of the Latin Kings greet each other, and show their membership in the gang,

using a set of hand-signs, each intended to evoke the shape of a crown. In addition, Latin Kings

often greet one another, demonstrate their allegiance to the gang, or simply announce their arrival

or presence in a particular area, by exclaiming "ADR" or "Amor De Rey," which means "King's

Love" in Spanish. Other phrases unique to the Latin King lexicon include "360," "ALKN,"

"ALKQN " "Crown" "Lion" "Lion Tribe" "Motherland" "KMC " "Kingism " and "Bloodline", " , " , .

The Latin Kings employ a robust symbology as well, often using depictions of three- or five-pointed

crowns, lions, and Inca- or Aztec-inspired artwork to demonstrate their affiliation. Members will

often have tattoos incorporating one or more of the aforementioned phrases or symbols, the crown

and lion being the most prominent. The gang also incorporates these phrases and symbols into

graffiti, which they use to mark their territory or announce their presence in a particular area. The

colors associated with the Latin Kings are black and gold, and members of the Latin Kings often

demonstrate their affiliation with the Latin Kings by wearing clothing containing the colors black

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and gold, or incorporating some of the gang's other symbols or phrases.

9. The Latin King members communicate with members of their own tribe as well as

with members across the United States in person and through the use of the telephone and Internet.

10. The Latin Kings have operated in the District of Maryland since at least 2007, and

members in Maryland have reported to both Chicago and New York-based leadership.

The Racketeering Enterprise

11. The Latin Kings, including its leadership, members, and associates, constitute an

"enterprise" as defined in Section 1961(4) of Title 18, United States Code, that is, a group of

individuals associated in fact that engaged in, and the activities of which affected, interstate and

foreign commerce. The enterprise constitutes an ongoing organization whose members function as

a continuing unit for a common purpose of achieving the objectives of the enterprise.

Purposes of the Enterprise

12. The purposes of the enterprise, include, but are not limited to, the following:

a. Preserving and protecting the power, territory, operations, and prestige of the

enterprise through the use of intimidation, violence, threats of violence, and destruction of property;

b. Promoting and enhancing the enterprise and the activities of its members

and associates;

c. Keeping victims, members, and associates in fear of the enterprise and in fear

of its members and associates through intimidation, violence, threats of violence, and destruction of

property;

d. Preserving and protecting the enterprise and its leaders by keeping its

members and associates from cooperating with law enforcement through intimidation, violence,

5


threats of violence, and destruction of property; and

e. Providing support to gang members who are charged with, or incarcerated for,

gang-related activities.

The Racketeering Conspiracy

13. Beginning on a date unknown to the Grand Jury and continuing through in or about

November 2009, in the District of Maryland and elsewhere, the defendants,

CHINUA SHEPPERDSON,a/k/a "Nu,"

a/k/a "NuNu,"a/k/a "King Nu,"REMYHEATH,alk/a "Remy,"

a/k/a "King Remy,"a/k/a "King Mello," and

BRANDON SMITH,a/k/a "Little One,"

a/k/a "King Little One,"

each being a person employed by and associated with the Latin Kings, an enterprise, which engaged

in, and the activities of which affected, interstate and foreign commerce, together with Erick

Roman, a/k/a "Erick Javier Sierra," a/k/a "Malian-T," a/k/a "King Malian-T," Matthew

Aguilar, a/k/a "Mateo," a/k/a "King Mateo," Miguel Castillo, a/k/a "Colombia," a/k/a "King

Colombia," Miguel Cruz, a/k/a "Skibee," a/k/a "King Skibee," Joseph Deleon, a/k/a "Spirit,"

a/k/a "King Spirit," Andres Echevarria, a/k/a "B-Boy," a/k/a "King B-Boy," Julio Kilgore,

a/k/a "Murda," a/k/a "King Murda," Erick Martinez, a/k/a "Eazie," a/k/a "King Eazie,"

Melvin Nolasco, a/k/a "Joker," a/k/a "King Joker," Senni Nolasco, a/k/a "Cano," a/k/a "King

Cano," Francisco Ortiz, a/k/a "Francis Gabriel Ortis," a/k/a "Pone," alk/a "King Pone,"

Roddy E. Paredes, Jr., a/k/a "Guate," a/k/a "King Guate," Leuri Read, a/k/a "Kampana,"

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a/k/a "King Kampana," Alejandro Rodriguez, a/k/a "Sombra," a/k/a "King Sombra," Nelson

Santos, a/k/a "Nelly," a/k/a "King Nelly," and Hugo Soto-Moran, a/k/a "Vision," a/k/a "King

Vision," and others known and unknown to the Grand Jury, did knowingly and intentionally

conspire to conduct and participate, directly and indirectly, in the conduct of the affairs of the

enterprise through a pattern of racketeering activity, as defined in Sections 1961(1) and (5) of Title

18, United States Code, including racketeering activity for which the maximum penalty includes life

imprisonment, involving multiple acts indictable under the following provisions of federal law:

a. 18 U.S.c. S 1951 (interference with commerce by threats or violence);

b. 18 U.S.C. S 1512 (witness tampering); and

c. Multiple acts involving first degree murder, second degree murder, attempted

murder, conspiracy to commit murder, robbery, conspiracy to commit robbery, arson, attempted

arson, and conspiracy to commit arson, chargeable under the following provisions of state law:

1. Maryland Code, Criminal Law SS 2-20 1,2-204,2-205,2-206, 1-20 I,

1-202, and the Common Law of Maryland (first degree murder, second degree murder, attempted

murder and conspiracy to commit murder);

II. Maryland Code, Criminal Law SS 3-402, 3-403, 1-202, and the

Common Law of Maryland (robbery and conspiracy to commit robbery);

Ill. Maryland Code, Criminal Law SS 6-102, 6-103, 6-109,1-201,1-202,

and the Common Law of Maryland (arson, attempted arson, and conspiracy to commit arson).

14. It was a further part of the conspiracy that each defendant agreed that a conspirator

would commit at least two acts of racketeering activity in the conduct of the affairs of the enterprise.

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Means and Methods of the Enterprise

15. Among the means and methods by which the defendants and their associates

conducted and participated in the conduct of the affairs of the Latin Kings were the following:

a. Members of the Latin Kings and their associates used intimidation,

violence, and threats of violence, including assaults with deadly weapons, to preserve, expand, and

protect the enterprise's territory and activities.

b. Members of the Latin Kings and their associates used intimidation,

violence, and threats of violence, including assaults with deadly weapons to promote and enhance

its prestige, reputation, and position in the community.

c. Members of the Latin Kings and their associates used intimidation, violence,

and threats of violence to create a climate of fear to maintain control over victims, witnesses,

members and associates.

d. Members of the Latin Kings used intimidation, violence, and threats of

violence, including assault with deadly weapons, to discipline enterprise members and associates

who had violated enterprise rules.

e. Members of the Latin Kings engaged in illegal firearms transactions to

further the activities of the enterprise and its members and associates.

f. Members of the Latin Kings purchased, maintained and possessed deadly

weapons to further the activities of the enterprise and its members and associates.

g. Members of the Latin Kings recruited and used juveniles to commit violent

acts for the benefit of the enterprise.

h. Members of the Latin Kings used intimidation, violence, and threats of

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violence to protect their enterprise from the activities of rival gangs, including but not limited to MS-

13 and Los Surenos.

16. It was further part of the conspiracy that the defendants and other members and

associates of the Latin Kings would and did agree that acts of murder, including deliberate,

premeditated and willful murder and attempted deliberate, premeditated and willful murder, and

other acts of violence, would be committed by members and associates of the Latin Kings against

its members in order to impose discipline within the gang, and against others in order to protect and

further the interests of the Latin Kings and its members. For example, the following acts were

committed by members and associates of the Latin Kings:

a. On or about July 24,2007, defendant CHINUA SHEPPERDSON, also

known as "Nu," "NuNu," and "King Nu," feloniously, attempted to willfully and with deliberately

premeditated malice, kill A.S., C.S. and L.J. , in violation of Maryland Code, Criminal Law Article

2-205.

b. On or about April 25, 2008, defendant CHINUA SHEPPERDSON, also

known as "Nu," "NuNu," and "King Nu," feloniously, willfully and with deliberately premeditated

malice, killed John Realpe-Montoya, in violation of Maryland Code, Criminal Law Article

2-201 (a)(l).

c. On or about April 25, 2008, defendant CHINUA SHEPPERDSON, also

known as "Nu," "NuNu," and "King Nu," feloniously killed John Realpe-Montoya in the

perpetration of robbery, in violation of Maryland Code, Criminal Law Article 2-201 (a)(4)(ix).

d. On or about January 31,2009, defendant BRANDON SMITH, also known

as "Little One," and "King Little One," feloniously, attempted to willfully and with deliberately

9


premeditated malice, kill J.G., in violation of Maryland Code, Criminal Law Article 2-205.

e. On or about July 8, 2009, defendant BRANDON SMITH, also known as

"Little One," and "King Little One," feloniously, attempted to willfully and with deliberately

premeditated malice, kill F.C., in violation of Maryland Code, Criminal Law Article 2-205.

Overt Acts

17. In furtherance of the conspiracy and to achieve the objectives thereof, at least one of

the conspirators performed and caused to be performed at least one of the following overt acts,

among others, in the District of Maryland and elsewhere:

a. In or about the Spring 2007, Miguel Cruz and Erick Roman established the

Maryland Latin Kings, calling the tribe the Royal Lion Tribe of Maryland.

b. In or about the Spring 2007, Alejandro Rodriguez kept and stored guns for

Erick Roman.

c. In or about May 2007, Erick Roman communicated by telephone with Latin

King national leaders regarding the operations of the Latin King tribe in Maryland.

d. On or about June 1,2007, Alejandro Rodriguez and Erick Roman traveled

from Maryland to Chicago, Illinois to meet with Latin King members and leaders.

e. On or about July 24, 2007, CHINUA SHEPPERDSON firebombed an

occupied residence at the Marylander Condominiums in Langley Park, Maryland.

f. In or about August or September 2007, Erick Martinez, Francisco Ortiz,

Roddy E. Paredes, Jr., Erick Roman, and other Latin King members and associates, armed with

deadly weapons, hunted for members of MS-13 in order to shoot the members of this rival gang.

g. In or about the late Summer 2007, Miguel Castillo, Joseph Deleon, Melvin

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Nolasco, Senni Nolasco, Francisco Ortiz, Erick Roman, and other Latin King members and

associates committed a home invasion robbery of a drug dealer at the Marylander Condominiums

in Langley Park, Maryland.

h. On or about December 14,2007, Melvin Nolasco, Roddy E. Paredes, Jr.,

Erick Roman, Nelson Santos, CHINUA SHEPPERDSON, Hugo Soto-Moran, and other Latin

King members and associates participated in the armed robbery of a prostitute at a motel in Laurel,

Maryland.

1. In or about December 2007, while at a Latin King meeting, Francisco Ortiz,

Erick Roman, and other Latin King members and associates attempted to shoot F.C. in the leg for

wanting to "drop his crown" and leave the gang.

J. In or about December 2007, Joseph Deleon, Francisco Ortiz, Erick

Martinez, and other Latin King members and associates beat, kicked and stabbed a suspected

member of the gang MS-13 near the Marylander Condominiums in Langley Park, Maryland.

k. In or about December 2007, Hugo Soto-Moran video-taped a Latin King

party attended by Erick Roman, Joseph Deleon, Melvin Nolasco, Senni Nolasco, and Francisco

Ortiz during which Erick Roman received a Latin King tattoo.

I. On or about December 31,2007, while in a car driven by Hugo Soto-Moran,

Miguel Cruz, Erick Roman and others participated in the beating of Joseph Deleon, administered

as punishment for a violation of Latin King rules.

m. On or about January 4,2008, Roddy E. Paredes, Jr. attempted to murder C.P.

by shooting c.P. seven times at the Marylander Condominiums in Langley Park, Maryland.

n. On or about January 8, 2008, Erick Roman ordered Miguel Castillo and

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Hugo Soto-Moran to firebomb a residence in Rockville, Maryland.

o. In or about February 2008, Roddy E. Paredes, Jr., Erick Roman, and

another Latin King member met and agreed to murder a security guard at an apartment complex near

the Marylander Condominiums in Langley Park, Maryland.

p. On or about February 28, 2008, Roddy E. Paredes, Jr. told another Latin

King member that he had targeted another house for a home invasion from which they would get

"paid" at least $100,000.

q. On or about April 25, 2008, Roddy E. Paredes, Jr., Erick Roman, and

CHINUA SHEPPERDSON conspired to rob and murder, and did rob and murder, John Realpe

Montoya behind the Marylander Condominiums in Langley Park, Maryland.

r. On or about July 17, 2008, Roddy E. Paredes, Jr. requested an electronic

version of the manifesto from the national leadership of the Latin Kings.

s. On or about August 22, 2008, in a telephone conversation with Francisco

Ortiz, Melvin Nolasco stated that Latin King members who had not been paying dues "would get

fixed."

1. On or about August 22, 2008, Senni Nolasco stated in a telephone

conversation with Francisco Ortiz that there would be physical beatings for anyone who did not pay

dues at a Latin King meeting.

u. On or about August 31, 2008, Joseph Deleon, Melvin Nolasco, Senni

Nolasco, Francisco Ortiz and other Latin King members from Maryland attended a Latin King

meeting in Staten Island, New York to discuss Latin King business with members from New York.

v. On or about September 2, 2008, REMY HEATH, Julio Kilgore, Melvin

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Nolasco, Senni Nolasco, and Francisco Ortiz went to the Annapolis Mall in Annapolis, Maryland

wearing Latin King beads and colors.

w. On or about September 26, 2008, Melvin Nolasco and Francisco Ortiz

discussed appointing Leuri Read to "Third Crown," or "Enforcer," because "all he thinks about is

violence." Nolasco stated that all Read talks about is "breaking peoples' heads and shooting

people." Ortiz interrupted Nolasco and cautioned him not to talk about shooting people over the

telephone.

X. On or about October 4, 2008, Francisco Ortiz, Leuri Read and other Latin

King members and associates traveled from Maryland to Philadelphia, Pennsylvania to attend a Latin

King meeting.

y. On or about October 5, 2008, Francisco Ortiz called another Latin King,

whom Francisco Ortiz believed had stripped him from power, and left several voice mail messages,

stating in part: "I'm gonna cut your fucking fingers off. I'm gonna cut your fucking tongue so you

can't speak no more on behalfofnobody you aren't safe nowhere ... I'm going to cut your head

off and put it on my mantle ... I love war I was the third suprema ... I get a hard-on fucking

killing [people]."

z. On or about October 10,2008, Francisco Ortiz issued a "d.o. " (direct order)

for everyone to take down any photographs of "hammers and knives" on their MySpace pages or

"catch a physie" (get a beat down) due to his belief that the police wanted "to do RICO on all of

[them ]."

aa. In or about the Fall 2008, Francisco Ortiz appointed Andres Echevarria as

the "Third Crown," or "Enforcer," of the Maryland Latin Kings.

13


bb. In or about October 2008, Francisco Ortiz appointed Julio Kilgore as the

"Second Crown," or "Cacique,"ofthe Maryland Latin Kings.

cc. On or about November 1,2008, Andres Echevarria, Julio Kilgore and other

Latin King members and associates participated in the assault and stabbing of L.Q. in Wheaton,

Maryland.

dd. On or about November 2, 2008, Senni Nolasco collected dues from Latin

King members in attendance at a meeting.

ee. In or about November 2008, Francisco Ortiz appointed REMY HEATH as

the Second Crown, or "Cacique," of the Maryland Latin Kings, and REMY HEATH accepted the

position.

ff. On or about January 17,2009, BRANDON SMITH fired shots at members

of MS-13 at the Amazura Night Club in Queens, New York.

gg. On or about January 19, 2009, REMY HEATH, Francisco Ortiz, Leuri

Read, and BRANDON SMITH put a plan in place to assault a Latin Queen in order to influence,

prevent, or change her testimony regarding the possession of an unregistered firearm charge for

which other Latin King members had just been sentenced in the United States District Court for the

District of Maryland.

hh. On or about January 31,2009, Leuri Read, BRANDON SMITH, the "Third

Crown," or "Enforcer," at the relevant time, and other Latin King members and associates held lO.

at gunpoint and sliced him with a knife for violating Latin King rules.

11. On or about February 3, 2009, REMY HEATH, Melvin Nolasco, Francisco

Ortiz, BRANDON SMITH, and other Latin King members and associates created a "hit list"

14


containing names of Maryland Latin King members.

JJ. In or about March 2009, the Maryland Latin Kings met and voted Melvin

Nolasco as the "First Crown," or "Inca," for the State of Maryland.

kk. In or about the Summer 2009, Joseph Deleon appointed Matthew Aguilar

as the Third Crown, or "Enforcer" for the State of Maryland, and Matthew Aguilar accepted the

position.

11. On or about July 7, 2009, Matthew Aguilar acted as the get-away driver as

Joseph Deleon and other Latin King members and associates participated in attacking and stabbing

M.O. at Wheaton Regional Park in Wheaton, Maryland.

mm. On or about July 8, 2009, Francisco Ortiz, Leuri Read, BRANDON

SMITH and other Latin King members and associates attempted to murder F.C. by beating him with

a wooden object and by stabbing him.

nn. In or about the Summer 2009, Matthew Aguilar agreed to run background

checks on new members and members under investigation.

18 U.S.c. 9 1962(d)

15


COUNT TWO

(Arson)

The Grand Jury for the District of Maryland further charges that:

On or about July 24, 2007, in the District of Maryland, the defendant,

CHINUA SHEPPERD SON,a/k/a "Nu,"a/k/a "NuNu,"a/k/a "King Nu,"

did maliciously damage and destroy and attempt to damage and destroy, by means of fire and

explosive, real and personal property, to wit: a condominium unit, located at 7981 Riggs Road,

Apartment #3, Langley Park, Maryland, which unit was used in an activity affecting interstate

commerce.

18 U.S.C. S 844(i)18 U.S.C. S 2

16


COUNT THREE

(Using and Carrying a Firearm (Destructive Device)During and in Relation to a Crime of Violence)


1. Paragraphs 1 through 17 of Count One, and Count Two, are incorporated here.

2. On or about July 24,2007, in the District of Maryland, the defendant,


a/k/a "NuNu,"a/k/a "King Nu,"

did knowingly use, carry and discharge a firearm, namely a destructive device, during and in relation

to a crime of violence for which he may be prosecuted in a court of the United States, to wit,

conspiracy to participate in a racketeering enterprise and arson as set forth in Counts One and Two,

which are incorporated here.

18 U.S.C. S 924(c)18 U.S.C. S 2

17


COUNT FOUR

(Interference with Commerce by Robbery)


On or about December 14, 2007, in the District of Maryland, the defendant,

CHINUA SHEPPERDSON,alk/a "Nu,"a/k/a "NuNu,"a/k/a "King Nu,"

did unlawfully obstruct, delay, and affect, and attempt to obstruct, delay and affect, commerce and

the movement of articles and commodities in such commerce, by robbery, in that the defendant did

unlawfully take and obtain United States currency and personal property from the person of and in

the presence ofP.B. and A.G., against their will, by means of actual and threatened force, violence,

and fear of immediate injury to their person.

18 U.S.c. S 195118 U.S.C. S 2

18


COUNT FIVE

(Using and Carrying a Firearm During and in Relation to a Crime of Violence)


1. Paragraphs 1 through 17 of Count One, and Count Four, are incorporated here.

2. On or about December 14, 2007, in the District of Maryland, the defendant,


did knowingly use, carry and brandish a firearm during and in relation to a crime of violence for

which he may be prosecuted in a court of the United States, to wit, conspiracy to participate in a

racketeering enterprise and interference with commerce by robbery as set forth in Counts One and

Four, which are incorporated here.

18 U.S.c. S 924(c)18 U.S.c. S 2

19


COUNT SIX

(Murder in Aid of Racketeering)


1. At all times relevant to this Superseding Indictment, the Latin Kings, as more fully

described in Paragraphs 1 through 10 and 12 of Count One, which are realleged and incorporated

by reference as though set forth fully herein, constituted an enterprise as defined in Title 18, U.S.C.

S 1959(b )(2), namely, the Latin Kings, 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 the common

purpose of achieving the objectives of the enterprise.

2. At all times relevant to this Superseding Indictment, the above-described enterprise,

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

States Code, Sections 1959(b)(1) and 1961(1), involving multiple acts indictable under 18 U.S.C.

S 1951 (interference with commerce by threats or violence) and 18 U.S.C. S 1512 (witness

tampering) and multiple acts involving murder, attempted murder, conspiracy to commit murder,

arson, attempted arson, conspiracy to commit arson, robbery and conspiracy to commit robbery,

which are indictable under Maryland law.

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3. On or about April 25, 2008, in the District of Maryland, the defendant,


a/k/a "NuNu,"a/k/a "King Nu,"

did murder John Realpe-Montoya, in violation of Maryland Code, Criminal Law SS 2-201 and 2-

204, for the purpose of maintaining and increasing position in the Latin Kings, an enterprise engaged

in racketeering activity.

18 U.S.c. S 1959(a)(l)18 U.S.C. S 2

21


COUNT SEVEN

(Interference with Commerce by Robbery)


On or about April 25, 2008, in the District of Maryland, the defendant,


did unlawfully obstruct, delay, and affect, and attempt to obstruct, delay and affect, commerce and

the movement of articles and commodities in such commerce, by robbery, in that the defendant did

unlawfully take and obtain cocaine and a cellular phone and keys from the person of and in the

presence of John Realpe-Montoya, against his will, by means of actual and threatened force,

violence, and fear of immediate injury to his person.

18 U.S.c. S 195118 U.S.C. S 2

22


COUNT EIGHT



1. Paragraphs 1 through 17 of Count One, Count Six, and Count Seven, are

incorporated here.



did knowingly use, carry and discharge a firearm during and in relation to a crime of violence for


racketeering enterprise, murder in aid of racketeering and interference with commerce by robbery

as set forth in Counts One, Six and Seven, which are incorporated here.

18 U.S.C. S 924(c)18 U.S.C. S 2

23


COUNT NINE

(Murder Resulting From the Use and Carrying a FirearmDuring and in Relation to a Crime of Violence)


1. Paragraphs 1 through 17 of Count One, and Count Eight, are incorporated here.



in the course of committing a violation of 18 U.S.C. S 924(c) as set forth in Count Eight, which is

incorporated here, did cause the death of a person through the use of a firearm, which killing is a

murder as defined in 18 U.S.C. S 1111, in that the defendant, with malice aforethought, unlawfully

killed a human being, to wit, John Realpe-Montoya, willfully, deliberately, maliciously and with

premeditation.

18 U.S.c. S 924(j)18 U.S.C. S 2

24


COUNT TEN



1. Paragraphs 1 through 17 of Count One are incorporated here.

2. On or about January 17,2009, in the District of Maryland and elsewhere, the

defendant,



did knowingly use, carry and discharge a firearm during and in relation to a crime of violence for


racketeering enterprise as set forth in Count One, which is incorporated here.

18 U.S.C. S 924(c)18 U.S.C. S 2

25


COUNT ELEVEN

(Attempted Murder in Aid of Racketeering)


1. Paragraphs 1 and 2 of Count Six are incorporated here.

2. On or about January 31,2009, in the District of Maryland, the defendant,



did attempt to murder J.G., in violation of Maryland Code, Criminal Law ~~2-205, 2-206 and 1-201,

for the purpose of maintaining and increasing position in the Latin Kings, an enterprise engaged


18 U.S.C. ~ 1959(a)(5)18 U.S.C. ~ 2

26


COUNT TWELVE



1. Paragraphs 1 through 17 of Count One, and Count Eleven, are incorporated here.

2. On or about January 31, 2009, in the District of Maryland, the defendant,



did knowingly use, carry and brandish a firearm during and in relation to a crime of violence for


racketeering enterprise and attempted murder in aid of racketeering as set forth in Counts One and

Eleven, which are incorporated here.

18 U.S.C. 9 924(c)18 U.S.C. 92

27


COUNT THIRTEEN

(Attempted Murder in Aid of Racketeering)


1. Paragraphs 1 and 2 of Count Six are incorporated here.

2. On or about July 8, 2009, in the District of Maryland, the defendant,



did attempt to murder F.C., in violation of Maryland Code, Criminal Law SS 2-205, 2-206 and 1-

201, for the purpose of maintaining and increasing position in the Latin Kings, an enterprise engaged


18 U.S.C. S I959(a)(5)18 U.S.C. S 2

A TRUE BILL:

SIGNATURE REDACTEDForeperson

Date: /0 -.2. 7- 10

28

i&~J~(DL)United States Attorney


shepperson indictments

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