U.S.

Department of Justice
United States Attorney
District of Maryland


Robert R. Harding Suite 400 DIRECT: 410-209-4845
Chief of Narcotics 36 S. Charles Street MAIN: 410-209-4800
Robert.Harding@usdoj.gov Baltimore, MD 21201-3119 FAX: 410-962-3124

J une 6, 2014
ALL DEFENSE COUNSEL,
Hon. Ellen L. Hollander
Via Email
Re: United States v. White et al,
Criminal NO. ELH-13-0151
Dear Counsel and J udge Hollander:

We write to inform you that the government will ask the Grand J ury to supersede the
Superseding Indictment in the captioned case within a few weeks. Because of the motions and trial
schedule, no new defendants will be added. Defendants who have pled will not be included. There
will be new substantive counts resulting from the search warrants executed last November.
Specifically, there will be new charges under 21 U.S.C. 841 against defendants Ricks and
Wortham. In addition, the time period of the conspiracy counts will be extended to encompass the
time of the search warrant executions, and there will be some minor changes to the language of the
speaking section of Count One to discuss methods, means and purposes of the RICO enterprise
that have come into clearer light as the investigation has progressed. There may be some other minor
changes.

We have previously written to all counsel to provide dates for the review of physical
evidence at the FBI offices in Woodlawn. The subpoenaed personnel files for DPSCS employees
should be available on these days. As these are confidential, absent a court order, we will make
available to each attorney only the personnel file for that attorneys client. These files were initially
screened by a taint AUSA to remove compelled statements. Undersigned counsel have not seen
these compelled statements, but they too will be provided to the counsel for any DPSCS employee
who requests them. We will pass along the request to the taint AUSA, who is Barbara Sale.

Very truly yours,

Rod J . Rosenstein
United States Attorney

By:_____/s/______________________
Robert R. Harding
Ayn B. Ducao
Assistant United States Attorneys
Case 1:13-cr-00151-ELH Document 852 Filed 06/06/14 Page 1 of 1