USAO:MWC2011R00433

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v. ERICK WILSON, DAVID MARQUISE HOWARD, REGINA MCCULLOM, a/k/a Regina Wilson, GLORIA JEANETTE MARTINO, a/k/a Net, a/k/a Netty, and MATTHEW MACE, Defendants. : : : : : : : : : : : : : CRIMINAL NO. L-11-494

(Conspiracy to Interfere with Commerce by Robbery, 18 U.S.C. 1951(a); Interference with Commerce by Robbery, 18 U.S.C. 1951(a); Possession of a Firearm in Furtherance of a Crime of Violence, 18 U.S.C. 924(c); Possession of a Firearm by a Convicted Felon, 18 U.S.C. 922(g)(1); Accessory after the Fact, 18 U.S.C. 3; Possession of a Machine Gun, 18 U.S.C. 922(o); Aiding and Abetting, 18 U.S.C. 2; Forfeiture, 18 U.S.C. 981(a)(1)(C)) ...oOo...

SUPERSEDING INDICTMENT COUNT ONE (Conspiracy) The Grand Jury for the District of Maryland charges that: At all times material to this Superseding Indictment, 1. Dunbar Armored was a corporation headquartered at 50 Schilling Road, Hunt Valley, Among other

Maryland and with numerous branches located throughout the United States.

services, Dunbar Armored provides armored transportation of currency and other valuables to banks, retailers, and other businesses engaged in interstate commerce, and is a business which is engaged in and affects interstate commerce. 2. ERICK WILSON was a resident of Columbia, Maryland and the son of REGINA

MCCULLOM, a/k/a Regina Wilson, who was a resident of Laurel, Maryland. 3. DAVID MARQUISE HOWARD was a resident of Baltimore, Maryland and

Hyattsville, Maryland and the boyfriend of GLORIA JEANETTE MARTINO a/k/a Net a/ka Netty, with whom he has a child in common. GLORIA JEANETTE MARTINO is a resident of Hyattsville, Maryland. 4. MATTHEW MACE was a resident of Olney, Maryland and a friend and former co-

worker of ERICK WILSON. 5. Between in or about May 2008 and continuing through May 2011, in the District of

Maryland, the defendants, ERICK WILSON, DAVID MARQUISE HOWARD and REGINA MCCULLOM, a/k/a Regina Wilson, did knowingly and willfully combine, conspire, confederate and agree with each other and with others known and unknown to the Grand Jury to obstruct, delay and affect commerce, as that term is defined in 18 U.S.C. 1951, and the movement of articles and commodities in such commerce, by robbery as that term is defined in 18 U.S.C. 1951, and by committing and threatening physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce. Ways, Manner and Means of the Conspiracy 6. It was part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, and others known and unknown to the Grand Jury, robbed, at gunpoint, employees of commercial armored vehicles carrying large amounts of United States currency. 7. It was further a part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, and others known and unknown to the Grand Jury, seized the United States currency and guns that the employees were carrying. 2

8.

It was further a part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, and others known and unknown to the Grand Jury, purchased throw-away cars from non-commercial and independent sellers, which they used during the commission of the robberies in order to conceal their true identities. 9. It was further a part of the conspiracy that ERICK WILSON and DAVID

MARQUISE HOWARD wore disguises during the commission of the robberies in order to conceal their true identities. 10. It was further a part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, REGINA MCCULLOM a/k/a Regina Wilson, GLORIA MARTINO, a/k/a Net, a/k/a Netty, and others known and unknown to the Grand Jury, purchased and used disposable cellular telephones to use during and after the commission of the robberies in order to conceal their true identities. 11. It was further a part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, REGINA MCCULLOM a/k/a Regina Wilson, and others known and unknown to the Grand Jury, staged vehicles and drivers in order to facilitate their quick flight from the robberies. 12. It was further a part of the conspiracy that ERICK WILSON, DAVID MARQUISE

HOWARD, REGINA MCCULLOM a/k/a Regina Wilson, and others known and unknown to the Grand Jury, rented hotel rooms in cash on the days of the various robberies, where they met and divided the stolen currency and arranged for the disposal of the stolen guns. 13. It was further a part of the conspiracy that ERICK WILSON, DAVID

MARQUISE HOWARD, GLORIA MARTINO, a/k/a Net, a/k/a Netty, and others known and unknown to the Grand Jury, rented multiple commercial storage units under different

names in the District of Maryland and elsewhere in order to hide stolen currency as well as the guns used in the commission of the robberies. Overt Acts 14. In furtherance of the conspiracy, and to effect the objects thereof, the defendants

and their co-conspirators performed, participated in and did the following acts in the District of Maryland, among others: a. On or about May 22, 2008, at approximately 11:30 a.m., ERICK

WILSON and REGINA MCCULLOM, a/k/a Regina Wilson, and other co-conspirators staged a gunpoint robbery at 1111 19th Street, NW in Washington D.C., where ERICK WILSON, then an employee of Dunbar Armored, pretended to be surprised by the robbers who stole approximately $210,000.00 in United States currency during one of ERICK WILSONs scheduled cash deliveries. b. On or about April 29, 2009, at approximately 10:22 a.m., ERICK

WILSON, and other co-conspirators, robbed at gunpoint employees of Dunbar Armored at 11261 New Hampshire Avenue, Silver Spring, Maryland, and stole approximately $160,000.00 in United States currency and a handgun belonging to a Dunbar employee. c. On or about April 29, 2009, REGINA MCCOLLUM a/k/a Regina

Wilson, drove with ERICK WILSON and a co-conspirator to an apartment complex in Silver Spring, Maryland, and waited in the vehicle while ERICK WILSON and the co-conspirator robbed employees of Dunbar Armored at 11261 New Hampshire Avenue, Silver Spring, Maryland. d. On or about April 29, 2009, REGINA MCCOLLUM, a/k/a Regina

Wilson, met up with ERICK WILSON and a co-conspirator in her vehicle at an apartment complex in Silver Spring, Maryland and accepted a duffle bag containing United States currency and a handgun from the robbery. e. On or about April 29, 2009, REGINA MCCOLLUM, a/k/a Regina

Wilson, rented and paid for a hotel room at a Holiday Inn at 7900 Washington Boulevard, Columbia, Maryland using proceeds from the April 29, 2009 robbery and brought the duffle bag to the room for ERICK WILSON and DAVID MARQUISE HOWARD. f. On or about November 7, 2009, ERICK WILSON, with the assistance of

another female, purchased a pistol-grip Mossburg 500A 12-gauge Persuader shotgun from Just Guns, Inc. at 7715 Harford Road, Baltimore, Maryland.

g.

On or about December 23, 2009, at approximately 12:00 p.m., ERICK

WILSON, and other co-conspirators, used the pistol-grip Mossburg shotgun to rob employees of Dunbar Armored at 3582 International Drive, Silver Spring, Maryland, and stole approximately $154,000.00 in United States currency and a handgun belonging to the Dunbar employee. h. On or about April 18, 2010, MATTHEW MACE rented a storage unit in

Columbia, Maryland which was used by ERICK WILSON to store United States currency stolen during robberies, an M16 assault rifle, additional parts for the M16, and a handgun used in the robberies of December 27, 2010 and April 4, 2011, described below. i. On or about May 17, 2010, at approximately 8:52 a.m., ERICK WILSON

rented a U-Haul truck from Pacos Paint at 7731 Washington, Boulevard, Jessup, Maryland, and returned the truck to the same location at approximately 11:27 a.m..

j.

On or about May 17, 2010, at approximately 10:25 a.m., ERICK

WILSON and a co-conspirator used a short-barreled shotgun to rob employees of Dunbar Armored at 13311 New Hampshire Avenue, Silver Spring, Maryland, stole approximately $73,000.00 in United States currency and a Dunbar employee handgun and fled in a U-Haul truck. k. On or about December 27, 2010, at approximately 12:42 p.m., ERICK

WILSON, DAVID MARQUISE HOWARD, and other co-conspirators robbed, at gunpoint, employees of Dunbar Armored at 4715 Dorsey Hall Drive, Ellicott City, Maryland, and stole approximately $32,000.00 in United States currency and a Dunbar employee handgun. l. On or about December 27, 2010, ERICK WILSON delivered a bag

containing items stolen during the 4715 Dorsey Hall Drive robbery to a co-conspirator in a waiting vehicle with whom he then later met, along with DAVID MARQUISE HOWARD, in order to divide the stolen currency. m. On or about April 4, 2011, at approximately 9:57 a.m., ERICK

WILSON, DAVID MARQUISE HOWARD, and other co-conspirators robbed, at gunpoint, employees of Dunbar Armored at 11900 Old Columbia Pike, Silver Spring, Maryland, and stole approximately $136,000.00 in United States currency and the handgun of the Dunbar employee. n. On or about April 6, 2011, GLORIA MARTINO, a/ka Net, a/k/a

Netty, rented a storage unit in Aston, Pennsylvania, which was used by DAVID MARQUISE HOWARD to store robbery proceeds and other items. o. In or about May, 2011, GLORIA MARTINO, a/ka Net, a/k/a

Netty, agreed to hold and safeguard United States currency, which was money stolen by

DAVID MARQUISE HOWARD and ERICK WILSON, in the robbery of a Dunbar Armored vehicle on April 4, 2011. p. In or about May, 2011, DAVID MARQUISE HOWARD buried

$10,000.00 of U.S. currency stolen during the April 4, 2011 robbery in a disposable cellular telephone box at the corner of Eldorado Avenue and Carleview Road in Baltimore, Maryland.

18 U.S.C. 1951(a)

COUNT TWO (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about April 29, 2009, in the District of Maryland, the defendants, ERICK WILSON and REGINA MCCULLOM, a/k/a Regina Wilson, did knowingly and intentionally obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code 1951, and the movement of articles and commodities in such commerce, by robbery, as that term is defined in Title 18, United States Code, Section 1951, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, that is, the defendants ERICK WILSON and REGINA MCCULLOM, a/k/a Regina Wilson, did unlawfully take personal property consisting of United States currency in the amount of $160,000.00, more or less, from the persons of employees of Dunbar Armored, against their will, by means of actual and threatened force, violence, and fear of injury to their persons and by threatening physical injury and death to said employees by means of a firearm and deadly weapon. 18 U.S.C. 1951 18 U.S.C. 2

COUNT THREE (Use of a Firearm During a Crime of Violence) The Grand Jury for the District of Maryland further charges that: The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are incorporated here. 2. On or about April 29, 2009, in the District of Maryland, the defendants, ERICK WILSON and REGINA MCCULLOM, a/k/a Regina Wilson, did knowingly possess and brandish a firearm in furtherance of a crime of violence, and did use, carry and brandish a firearm during a crime of violence, that is, conspiracy to interfere with commerce by robbery, and interference with commerce by robbery, as more fully set forth in Counts One and Two of this Superseding Indictment. 18 U.S.C. 924(c)(1)(A)(i) and (ii) 18 U.S.C. 2

COUNT FOUR (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about December 23, 2009, in the District of Maryland, the defendant, ERICK WILSON, did knowingly and intentionally obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code 1951, and the movement of articles and commodities in such commerce, by robbery as that term is defined in Title 18, United States Code, 1951, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, in that the defendant ERICK WILSON, did unlawfully take personal property consisting of United States currency in the amount of $154,000.00, more or less, from the persons of employees of Dunbar Armored, against their will, by means of actual and threatened force, violence, and fear of injury to their persons and by threatening serious physical injury and death to said employees by means of a firearm and deadly weapon. 18 U.S.C. 1951 18 U.S.C. 2

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COUNT FIVE (Use of a Firearm During a Crime of Violence) The Grand Jury for the District of Maryland further charges that: On or about December 23, 2009, in the District of Maryland, the defendants, ERICK WILSON, the defendant herein, did knowingly possess a firearm in furtherance of a crime of violence, and did use, carry and brandish a firearm during a crime of violence, that is, conspiracy to interfere with commerce by robbery, and interference with commerce by robbery, as more fully set forth in Counts One and Four of this Superseding Indictment. 18 U.S.C. 924(c)(1)(A)(i) and (ii) 18 U.S.C. 2

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COUNT SIX (Felon in Possession of a Firearm) The Grand Jury for the District of Maryland further charges that: On or about December 23, 2009, in the District of Maryland, the defendant, ERICK WILSON, having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly and unlawfully possess one or more firearms in and affecting commerce. 18 U.S.C. 922(g)(1) 18 U.S.C. 2

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COUNT SEVEN (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about May 17, 2010, in the District of Maryland, the defendant, ERICK WILSON, the defendant herein, did knowingly and intentionally obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code 1951, and the movement of articles and commodities in such commerce, by robbery, as that term is defined in Title 18, United States Code, Section 1951, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, that is, the defendant ERICK WILSON, did unlawfully take personal property consisting of United States currency in the amount of $73,000.00, more or less, from the persons of employees of Dunbar Armored, against their will, by means of actual and threatened force, violence, and fear of injury to their persons and by threatening serious physical injury and death to said employees by means of a firearm and deadly weapon. 18 U.S.C. 1951 18 U.S.C. 2

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COUNT EIGHT (Use of a Firearm During a Crime of Violence) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about May 17, 2010, in the District of Maryland, the defendant, ERICK WILSON, did knowingly possess a firearm in furtherance of a crime of violence, and did use, carry and brandish a firearm, that is a short-barreled shotgun, during a crime of violence, that is, conspiracy to interfere with commerce by robbery, and interference with commerce by robbery, as more fully set forth in Counts One and Seven of this Superseding Indictment. 18 U.S.C. 924(c)(1)(A)(i) and (ii) & (B)(i) 18 U.S.C. 2

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COUNT NINE (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about December 27, 2010, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, did knowingly and intentionally obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code 1951, and the movement of articles and commodities in such commerce, by robbery as that term is defined in Title 18, United States Code, 1951, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, in that the defendants ERICK WILSON and DAVID MARQUISE HOWARD, did unlawfully take personal property consisting of United States currency in the amount of $32,000.00, more or less, from the persons of employees of Dunbar Armored, against their will, by means of actual and threatened force, violence, and fear of injury to their persons and by threatening serious physical injury and death to said employees by means of a firearm and deadly weapon. 18 U.S.C. 1951 18 U.S.C. 2

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COUNT TEN (Use of a Firearm During a Crime of Violence) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about December 27, 2010, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, did knowingly possess a firearm in furtherance of a crime of violence, and did use, carry and brandish a firearm during a crime of violence, that is, conspiracy to interfere with commerce by robbery, and interference with commerce by robbery, as more fully set forth in Counts One and Nine of this Superseding Indictment. 18 U.S.C. 924(c)(1)(A)(i) and (ii) 18 U.S.C. 2

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COUNT ELEVEN (Felon in Possession of a Firearm) The Grand Jury for the District of Maryland further charges that: On or about December 27, 2010, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, each having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly and unlawfully possess one or more firearms in and affecting commerce.

18 U.S.C. 922(g)(1) 18 U.S.C. 2

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COUNT TWELVE (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about April 4, 2011, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, did knowingly and intentionally obstruct, delay and affect, and attempt to obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code 1951, and the movement of articles and commodities in such commerce, by robbery as that term is defined in Title 18, United States Code, 1951, and committed and threatened physical violence to any person and property in furtherance of a plan and purpose to obstruct, delay and affect commerce, in that the defendants ERICK WILSON and DAVID MARQUISE HOWARD, did unlawfully take personal property consisting of United States currency in the amount of $136,000.00, more or less, from the persons of employees of Dunbar Armored, against their will, by means of actual and threatened force, violence, and fear of injury to their persons and by threatening serious physical injury and death to said employees by means of a firearm and deadly weapon. 18 U.S.C. 1951 18 U.S.C. 2

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COUNT THIRTEEN (Hobbs Act Robbery) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. On or about April 4, 2011, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, did knowingly possess a firearm in furtherance of a crime of violence, and did use, carry and brandish a firearm during a crime of violence, that is, conspiracy to interfere with commerce by robbery, and interference with commerce by robbery, as more fully set forth in Counts One and Twelve of this Superseding Indictment. 18 U.S.C. 924(c)(1)(A)(i) and (ii) 18 U.S.C. 2

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COUNT FOURTEEN (Felon in Possession of a Firearm) The Grand Jury for the District of Maryland further charges that: On or about April 4, 2011, in the District of Maryland, the defendants, ERICK WILSON and DAVID MARQUISE HOWARD, each having been convicted of a crime punishable by imprisonment for a term exceeding one year, did knowingly and unlawfully possess one or more firearms in and affecting commerce. 18 U.S.C. 922(g)(1) 18 U.S.C. 2

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COUNT FIFTEEN (Accessory After the Fact) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. From on or about April 4, 2011 through on or about May 19, 2011, in the District

of Maryland, the defendant, GLORIA MARTINO, a/k/a Net, a/k/a Netty, knowing that an offense against the United States had been committed, to wit, Conspiracy and Interference with Commerce by Robbery, did receive, relieve, comfort and assist the offenders, ERICK WILSON and DAVID MARQUISE HOWARD, in order to hinder and prevent the offenders apprehension, trial and punishment by providing, among other things, concealment and disposition of stolen United States currency involved in the aforementioned offenses against the United States as charged in this Superseding Indictment.. 18 U.S.C. 3

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COUNT SIXTEEN (Accessory After the Fact) The Grand Jury for the District of Maryland further charges that: 1. The allegations of Paragraph 1 through 4 and 6 through 14 of Count One are

incorporated here. 2. In or about May, 2011, in the District of Maryland, the defendant, MATTHEW MACE, knowing that an offense against the United States had been committed, to wit, Conspiracy and Interference with Commerce by Robbery, did receive, relieve, comfort and assist the offenders, ERICK WILSON and DAVID MARQUISE HOWARD, in order to hinder and prevent the offenders apprehension, trial and punishment by providing, among other things, concealment and disposition of stolen United States currency and a handgun involved in the aforementioned offenses against the United States as charged in this Superseding Indictment 18 U.S.C. 3

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COUNT SEVENTEEN (Possession of a Machine Gun) The Grand Jury for the District of Maryland further charges that: In or about May, 2011, in the District of Maryland, the defendants, ERICK WILSON, and MATTHEW MACE, did knowingly transfer and possess a machine gun, that is an M16 automatic rifle. 18 U.S.C. 922(o) 18 U.S.C. 2

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FORFEITURE 1. As a result of the violations of Title 18, United States Code, Section 1951 as set forth in this indictment, the named defendants shall forfeit to the United States of America any property, real or personal, that constitutes or is derived from proceeds traceable to the commission of such offenses, including, but not limited to, the sum of $765,000.00. 2. If any of the property subject to forfeiture, as a result of any act or omission of the defendants: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third party; (c) has been placed beyond the jurisdiction of the Court; (d) has been substantially diminished in value; or (e) has been commingled with other property which cannot be divided without difficulty; then it is the intent of the United States, pursuant to Title 28, United States Code, Section 2461(c), incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendant up to the value of the property subject to forfeiture. 28 U.S.C. 2461(c) 18 U.S.C. 981(a)(1)(C).

___________________________ ROD J. ROSENSTEIN United States Attorney A TRUE BILL: _____________________ Foreperson Date: ________________________

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