SC Hells Angels Indictment of May 17, 2012

~
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION
UNITED STATES OF AMERICA )
Crim. No. ~ : 12cr 4-30
)
VS. )
) 18 U.S.C. 1962(c)
DANIEL EUGENE BIFIELD ) 18 U.S.C. 1962(d)
a/kla Diamond Dan ) 18 U.S.C. 921
MARK WILLIAM BAKER ) 18 U.S.C. 922(d)
a/kla Lightning ) 18 U.S.C. 922(g)(1)
DAVID CHANNING OILER ) 18 U.S.C. 922(k)
alkla Gravel Dave ) 18 U.S.C. 924(a)(1)(B)
BRUCE JAMES LONG ) 18 U.S.C. 924(a)(2)
a/kla Bruce-Bruce ) 18 U.S.C. 924(c)
RICHARD THROWER ) 18 U.S.C. 924(h)
a/kla Little Mark ) 18 U.S.C. 981 (a)(1)
a/kla Rat ) 18 U.S.C. 982
DAVID ALLEN PRYOR ) 18 U.S.C. 1951
alkla Yard Owl ) 18 U.S.C. 1956(a)(3)(B)
JAMES FREDERICK KEACH, JR ) 18 U.S.C. 1963(a)(I)
a/kla Big Fred ) 18 U.S.C. 1963(a)(2)
FRANK ENRIQUEZ, JR. ) 18 U.S.C. 1963(a)(3)
alkla Big Frank ) 18 U.S.C. 1963(m)
DONALD BOERSMA ) 21 U.S.C. 841(a)(1)
alkla Brooklyn Don ) 21 U.S.C. 841(b)(1)(A)
a/kla Brooklyn Donnie ) 21 U.S.C. 841(b)(I)(B)
LISA ELLEN BIFIELD ) 21 U.S.c. 841(b)(1)(C)
alkla Lisa Ellen Meyers ) 21 U.S.C. 841(b)(1)(E)
alkla Lisa Ellen Stockton ) 21 U.S.C. 841(b)(2)
JOHANNA LOOPER ) 21 U.S.C. 846
alkla JoJo ) 21 U.S.C. 853
KERRY CHITWOOD ) 21 U.S.C. 881
CARLOS HERNANDEZ ) 26 U.S.C. 5845(a)(7)
RONALD DEAN BYRUM, JR ) 26 U.S.C. 5861(d)
alkla Big Ron ) 26 U.S.C. 5871
TRENT ALLEN BROWN ) 28 U.S.C. 2461(c)
JAMES RHODUS ) 18 U.S.C. 2
alkla Sonny )
BRUCE RANSON WILSON )
a/kla Diesel )
THOMAS MCMANUS PLYLER ) INDICTMENT
alkla Uncle Tom ) (SEALED)
JAMIE HOBBS LONG )
SOMYING ANDERSON )
alkla Ying
3:12-cr-00430-CRI *SEALED* Date Filed 05/17/12 Entry Number 3 Page 1 of 80
COUNT 1
(Racketeering)
THE GRAND JURY CHARGES:
Introduction
1. At all times relevant to this Indictment, the Defendants, DANIEL EUGENE BIFIELD,
a/kJa Diamond Dan; MARK WILLIAM BAKER, a/kJa Lightning; DAVID
CHANNING OILER, a/kJa Gravel Dave; BRUCE JAMES LONG, a/kJa Bruce-
Bruce; RICHARD THROWER, a/kJa Little Mark, alkla Rat; DAVID ALLEN
PRYOR, alkla Yard Owl; JAMES FREDERICK KEACH, JR, a/kJa Big Fred;
FRANK ENRIQUEZ, JR., alkla Big Frank; DONALD BOERSMA, a/kJa Brooklyn
Don, a/kJa Brooklyn Donnie; LISA ELLEN BIFIELD, alkla Lisa Ellen Meyers,
a/kJa Lisa Ellen Stockton; and JOHANNA LOOPER, a/kJa JoJo, and others, both
known and unknown to the Grand Jury, were members and associates ofthe Rock Hell
City (SC) Nomad Chapter of the Hells Angels, a criminal enterprise whose members and
associates engaged in criminal activity, including narcotics distribution, arson, trafficking
in stolen property, money laundering, extortion, prostitution, firearms violations, and
conspiracy to do the same.
2. At various times relevant to this Indictment,
(a) The Hells Angels Motorcycle Club, better known as (and hereinafter referred to
as) the Hells Angels, was an international organization with hundreds of Chapters
and thousands of members. The Rock Hell City Nomad Chapter of the Hells
Angels was one of several Chapters based in South Carolina.
(b) Within the United States, the Hells Angels was composed of individual Chapters
in various locations throughout the United States. Members of the Hells Angels
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belonged to a specific Chapter, and answer to the officers for that Chapter. Rock
Hell City Nomad Chapter ofthe Hells Angels like each Hells Angels Chapter
was an organized enterprise that adhered to a hierarchical chain of command with
a president, vice-president, treasurer/secretary, and sergeant at anns/enforcer, as
well as general members. Each officer had specific obligations.
(c) Chapter meetings were held regularly and are referred to as "church." Only full
patched members were allowed to attend "church."
(d) The Chapter President has ultimate decision-making authority for the activities of
the enterprise, reported directly to regional officers of the Hells Angels, and was
required to attend regularly-held regional meetings. Representatives of Hells
Angels Chapters on the East Coast met periodically, including during East Coast
Officer Meetings (ECOM). The location of the ECOM rotated from state to state.
The ECOM agenda items included, but are not limited to: Hells Angels Chapter
updates, Hells Angels world events, Hells Angels world votes, and Hells Angels
financial matters. In addition, Hells Angels Chapters were required to pay
Chapter dues to the Hells Angels national officers for the Hells Angels world
wide organization.
(e) In and around 2008, the Rock Hell City Nomad Chapter of the Hells Angels was
started in South Carolina under the leadership of DANIEL EUGENE BIFIELD,
a/kla Diamond Dan. Prior to 2008, the Enterprise operated as God's Few, an
independent motorcycle club. God's Few was patched over into the Rock Hell
City Nomad Chapter of the Hells Angels. This Chapter developed to be active in
and around the Rock Hill and Lexington areas of South Carolina. The Chapter
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officers were elected, and Chapter members were identified by the apparel
("colors") and emblems ("patches") they wore.
(f) Full membership in Hells Angels was referred to as "full-patch," in reference to a
member's ability only with the authority of the Enterprise to wear the full
Hells Angels three-piece patch on jackets and vests. The full patch included the
club emblem (i.e., winged death head), surrounded by a top "rocker" with the
words "Hells Angels" and a bottom "rocker" identifying the territory being
claimed. The official colors of the Hells Angels patch were red lettering displayed
on a white background (hence the club's nickname "The Red and White").
Members of the Hells Angels may also wear a diamond-shaped one-percenter
patch (displaying "1 %" in red on a white background with a red border). The
term one-percenter reflected the Hells Angels' recognition that its members are
among the one percent of motorcyclists who are non-law-abiding outlaws.
(g) Prospective members were brought into the Chapters through a lengthy process
designed to measure a prospective member's commitment to the Hells Angels and
to guard against law enforcement infiltration. After associating with the Hells
Angels for a period oftime, an individual may be identified as a "hang-around"
and may do menial tasks and other duties to gain the respect of the members.
After a period of time "hang-arounds" may be sponsored by a Hells Angel
member and may become a prospective member (or "prospect") for that Chapter.
While a prospective member, one must follow the orders of full-patched members
and run various errands. This can include participation in legal and illegal
activities. After a period of time, if the prospective member receives the
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unanimous vote of all Chapter members, he is allowed to become a full member
of the Hells Angels. A prospect may wear only the bottom rocker of the Hells
Angels patch. Associates of Hells Angels who are not members including the
Hells Angels members' girlfriends and wives, who are referred to as "old ladies"
- may wear the number "81," as in "Support 81." The "8" and "1" stand for the
respective positions in the alphabet of Hand A.
(h) Membership in the Hells Angels was limited to white males. Members also had
to own one or more American-made motorcycles (predominately Harley
Davidson).
(i) Like other Hells Angels, members ofthe Rock Hell City Nomad Chapter paid
dues and assessments to the Chapter and to the national Hells Angels. The Rock
Hell City Nomad Chapter also raised money from the sale of support gear at
parties, including items such as t-shirts and stickers. These funding techniques
were used to fund the continued operation of the Chapter and the international
Hells Angels organization. Funding from members was also used to create a legal
defense fund to cover members' criminal legal fees resulting from prosecutions
for conducting club business, including acts of violence. Funding for the Rock
Hell City Nomad Chapter was also generated through illegal activities, as
members and associates engaged in illegal activity pay a percentage of proceeds
of, or surrender some of the assets derived from, criminal activities to the Chapter
and leadership. Additionally, individuals engaged in illegal activity with members
and associates of the Rock Hell City Nomad Chapter paid kickbacks to the
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Chapter and its leadership in exchange for conducting illegal activity with
members and associates of the Rock Hell City Nomad Chapter.
G) After its formation, the Rock Hell City Nomad Chapter began to "patch over"
various local Outlaw Motorcycle Gang Chapters into the Red Devils Motorcycle
Club (RDMC), which was a Hells Angels support motorcycle club (hereinafter a
"support club"). A support club for the Hells Angels was a motorcycle club that
supports the Hells Angels through attending various functions, taking orders from
the Hells Angels, and providing security for Hells Angels members and events.
The Hells Angels often recruited new prospects from these various support clubs.
The RDMC was required to pay a monthly assessment to the local Hells Angels
Chapter. This money was used in furtherance of the local Hells Angels Chapter's
activities.
(k) The Hells Angels required the return of all vestments of membership when an
individual was no longer an active member. Hells Angels also required that
members and other persons outdate or color-over tattoos which served as
vestments of membership in Hells Angels.
(1) Rock Hell City Nomad Chapter utilized a clubhouse located at 4542 Doby Bridge
Road, Fort Mill, South Carolina 29707. The RDMC Rock Hell Chapter and
members of the Rock Hell City Nomad Chapter utilized a clubhouse located at
3969 Linda Drive, Rock Hill, South Carolina 29730. The RDMC River City
Chapter utilized a clubhouse located at 5622 Highway 302, West Columbia, South
Carolina 29170.
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3. The Rock Hell City Nomad Chapter of the Hells Angels, including its leadership,
membership, and associates, constituted an "enterprise" as defined by Title 18, United
States Code, Section 1961(4) (hereinafter, "the Enterprise"), that is, a group of
individuals associated in fact. At all times relevant and as described in greater detail
below, the Rock Hell City Nomad Chapter's officers, members, prospects, and associates
participated in the operation and management of the Rock Hell City Nomad Chapter's
affairs. The Enterprise constituted an ongoing organization whose members functioned
as a continuing unit for the common purpose of achieving the objectives of the
Enterprise. The Enterprise was engaged in, and its activities affected, interstate and
foreign commerce.
Purposes of the Enterprise
4. The purposes of the Enterprise consisted of the following:
(a) Preserving, protecting, and expanding the power, territory, and profits ofthe
Enterprise through the use of intimidation, extortion, narcotics distribution,
money laundering, arson, and acts and threats of violence.
(b) Enriching the members and associates of the Enterprise through, among other
things, intimidation, extortion, narcotics distribution, money laundering, arson,
trafficking in stolen goods, prostitution, and firearms trafficking.
(c) Promoting and enhancing the Enterprise, the Enterprise's reputation, and its
members' and associates' activities.
(d) Assisting, supporting, and obtaining assistance and support from, the regional,
national, and international Hells Angels in their activities, including: legal
matters, rivalries (such as the rivalry with the Outlaws Motorcycle Club),
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exchanging information about current membership, exchanging information about
criminal investigations, relying on other Hells Angels Chapter members to assist
the enterprise in furthering its criminal conduct, and aiding and protecting other
Hells Angels' members in their criminal activity.
(e) Using the enterprise to facilitate the possession and use of controlled substances.
(f) Funding the operation ofthe Hells Angels.
(g) Promoting a climate of fear and keeping victims, potential informants, witnesses,
and others in fear of the Enterprise and in fear of its members and associates
through violence and threats of violence.
Roles of the Defendants
5. Leading up to and at the time of indictment, the Defendants charged in Count One
maintain the following roles within the Rock Hell City Nomad Enterprise:
(a) Defendant DANIEL EUGENE BIFIELD, a/kJa Diamond Dan, was a full-patch
member of the Rock Hell City Nomad Chapter of the Hells Angels. At the time
of this Indictment, he was the Vice-President of the Rock Hell City Nomad
Chapter and previously served as the President of the Rock Hell City Nomad
Chapter.
(b) Defendant MARK WILLIAM BAKER, a/kJa Lightning, was a full-patch
member of the Rock Hell City Nomad Chapter of the Hells Angels. At the time
of this Indictment, he was the President of the Rock Hell City Nomad Chapter.
As President, MARK WILLIAM BAKER, a/kJa Lightning, has ultimate
decision-making authority for the activities ofthe Enterprise, including directing,
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sanctioning, approving, and permitting other members to engage in criminal
activities.
(c) Defendant DAVID CHANNING OILER, alkla Gravel Dave, was a full-patch
member of the Rock Hell City Nomad Chapter of the Hells Angels.
(d) Defendant BRUCE JAMES LONG, a/kfa Bruce-Bruce, was a full-patch
(e) Defendant RICHARD THROWER, a/kla Little Mark, alkla Rat, was a full
patch member of the Rock Hell City Nomad Chapter of the Hells Angels.
(f) Defendant DAVID ALLEN PRYOR, alk/a Yard Owl, was a full-patch member
of the Red Devils Motorcycle Club. At the time of this Indictment, he was the
President ofthe Red Devils Motorcycle Club in Rock Hill, SC.
(g) Defendant JAMES FREDERICK KEACH, JR, a/k/a Big Fred, was a former
full-patch member ofthe Red Devils Motorcycle Club. Until in or around
February 2012, JAMES FREDERICK KEACH, JR, a/k/a Big Fred, was an
active member ofthe Red Devils Motorcycle Club.
(h) Defendant FRANK ENRIQUEZ, JR., a/kla Big Frank, was a full-patch
(i) Defendant DONALD BOERSMA, a/k/a Brooklyn Don, alk/a Brooklyn
Donnie, was a prospect ofthe Rock Hell City Nomad Chapter of the Hells
Angels.
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(j) Defendant LISA ELLEN BIFIELD, a/k/a Lisa Ellen Meyers, a/k/a Lisa Ellen
Stockton, was the wife of Defendant DANIEL EUGENE BIFIELD, a/k/a
Diamond Dan (referred to in the Enterprise as his "old lady").
(k) Defendant JOHANNA LOOPER, a/k/a JoJo, was a "hang around" with the
Rock Hell City Nomad Chapter of the Hells Angels.
Means and Methods of the Enterprise
6. Among the means and methods by which the Defendants and their associates conducted
and participated in the conduct of the affairs of the Enterprise were the following:
(a) Officers in the Rock Hell City Nomads Chapter, including DANIEL EUGENE
BIFIELD, a/k/a Diamond Dan; and MARK WILLIAM BAKER, a1k/a
Lightning, participated in the operation and management of the enterprise, and
directed, sanctioned and approved other members ofthe enterprise to carry out
acts in furtherance of the operation and management of the enterprise. Full
members of the Rock Hell City Nomad Chapter directed, sanctioned and approved
non-member associates of the Hells Angels to carry out acts in furtherance of the
operation and management of the enterprise.
(b) Members of the Enterprise and their associates conspired to commit, threatened to
commit, and committed racketeering acts, including narcotics trafficking, money
laundering, and arson to protect and expand the Enterprise's criminal operations.
(c) Members of the Enterprise and their associates promoted a climate of fear through
intimidation, violence, and threats of violence.
(d) Members of the Enterprise and their associates possessed, transported, and
trafficked firearms, for various purposes, including protection and intimidation,
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and to otherwise further the goals of the Enterprise. The Enterprise members and
associates would transfer and sell firearms to persons the Enterprise members and
associates knew and had reasonable cause to believe were convicted felons (that
is, persons who had been convicted of a crime punishable by imprisonment for a
term exceeding one year). The Enterprise members and associates would transfer
and sell to persons firearms, which the Enterprise members and associates knew
and had reasonable cause to believe were to be used to commit crimes of violence
and drug trafficking crimes.
(e) Members of the Enterprise and their associates trafficked in cocaine,
methamphetamine, oxycodone, hydrocodone, clonazepam, and other controlled
substances, and conspired to do the same.
(f) Members of the Enterprise and their associates trafficked in stolen property and
engaged in prostitution, and conspired to do the same.
(g) Members of the Enterprise and their associates claimed geographic territories as
the exclusive territory of the Hells Angels and asserted that no other motorcycle
clubs could operate or display "colors" within said territories without the consent
of the Hells Angels.
(h) Members of the Enterprise and their associates committed acts of violence,
intimidation, and threats against members and associates of rival motorcycle
clubs.
(i) Members ofthe Enterprise and their associates used threats, intimidation, and
physical force against individuals with the intent to hinder, delay, and prevent the
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communication to law enforcement authorities of information related to the
commission and probable commission of criminal offenses.
7. Beginning at a time unknown to the grand jury, but beginning at least in or around 2008,
and continuing thereafter, up to and including the date ofthis Indictment, in the District
of South Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alkla
Diamond Dan; MARK WILLIAM BAKER, a/k/a Lightning; DAVID CHANNING
OILER, a/k/a Gravel Dave; BRUCE JAMES LONG, a/k/a Bruce-Bruce; RICHARD
THROWER, alk/a Little Mark, alkla Rat; DAVID ALLEN PRYOR, alkla Yard
Owl; JAMES FREDERICK KEACH, JR, alk/a Big Fred; FRANK ENRIQUEZ,
JR., alkla Big Frank; DONALD BOERSMA, alkla Brooklyn Don, a/k/a Brooklyn
Donnie; LISA ELLEN BIFIELD, a/k/a Lisa Ellen Meyers, alk/a Lisa Ellen
Stockton; and JOHANNA LOOPER, a/k/a JoJo, with each other and with others both
known and unknown to the grand jury, being persons employed by and associated with
the Enterprise known as the Hells Angels Rock Hell City Nomad Chapter of the Hells
Angels, an Enterprise which engaged in, and the activities of which affected, interstate
commerce, knowingly and intentionally conducted and participated, directly and
indirectly, in the conduct ofthe affairs ofthat Enterprise through a pattern ofracketeering
activity; that is, to wit: the commission ofthe racketeering acts set forth below and
described as Racketeering Acts 1 through' 43; all in violation of Title 18, United States
Code, Section 1962( c).
8. Racketeering Act 1 - Conspiracy to Distribute Narcotics
Beginning at a time unknown to the grand jury but beginning at least in or around 2010,
and continuing thereafter, up to and including the date of this Indictment, in the District of South
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Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alk/a Diamond Dan;
MARK WILLIAM BAKER, a/kJa Lightning; DAVID CHANNING OILER, a/kJa Gravel
Dave; BRUCE JAMES LONG, alkla Bruce-Bruce; RICHARD THROWER, alk/a Little
Mark, a/kla Rat; DAVID ALLEN PRYOR, a/kla Yard Owl; FREDERICK KEACH, JR,
alkla Big Fred; FRANK ENRIQUEZ, JR., alk/a Big Frank; DONALD BOERSMA, alk/a
Brooklyn Don, alk/a Brooklyn Donnie; LISA ELLEN BIFIELD, alk/a Lisa Ellen Meyers,
a/kIa Lisa Ellen Stockton; and JOHANNA LOOPER, a/kla JoJo, knowingly and intentionally
did combine, conspire and agree with each other and others, both known and unknown to the
grand jury, to knowingly, intentionally, and unlawfully possess with intent to distribute and
distribute cocaine, methamphetamine, and oxycodone, Schedule II controlled substances,
hydrocodone, a Schedule III controlled substance, and c1onazepam, a Schedule IV controlled
substance, said conspiracy involving 5 kilograms or more of a mixture and a substance
containing cocaine, 50 grams or more of actual methamphetamine, and 500 grams or more of a
mixture and substance containing methamphetamine, and thereby violated the narcotics laws of
the United States, to wit, Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A),
841(b)(1)(C), 841(b)(1)(E), and 841(b)(2); all in violation of Title 21, United States Code,
Section 846.
9. Racketeering Act 2 - Narcotics Distribution
On or about July 22,2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, a/kla Diamond Dan, and LISA ELLEN
BIFIELD, a/kla Lisa Ellen Meyers, alkla Lisa Ellen Stockton, knowingly, intentionally, and
unlawfully did possess with intent to distribute and did distribute a quantity of cocaine, a
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Schedule rr controlled substance, in violation of Title 21, United States Code, Sections 84l(a)(I)
and 841 (b)(1)(C), and Title 18, United States Code, Section 2.
On or about August 5,2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, aIkIa Diamond Dan, BRUCE JAMES LONG,
aIkIa Bruce-Bruce, and LISA ELLEN BIFIELD, alkla Lisa Ellen Meyers, a/kla Lisa Ellen
Stockton, knowingly, intentionally, and unlawfully did possess with intent to distribute and did
distribute a quantity of cocaine, a Schedule II controlled substance, in violation of Title 21,
United States Code, Sections 841(a)(1) and 841 (b)(1)(C), and Title 18, United States Code,
Section 2.
On or about August 30, 2011, in the District of South Carolina and elsewhere, the
Defendant, BRUCE JAMES LONG, alkla Bruce-Bruce, knowingly, intentionally, and
Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(1)
and 841(b)(1)(C).
On or about September 19,2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, a/kla Diamond Dan, BRUCE JAMES LONG,
alkla Bruce-Bruce, and LISA ELLEN BIFIELD, aIkIa Lisa Ellen Meyers, alkla Lisa Ellen
Stockton, knowingly, intentionally, and unlawfully did possess with intent to distribute and did
distribute a quantity of cocaine, a Schedule II controlled substance, in violation of Title 21,
14
United States Code, Sections 841 (a)(1) and 84 I (b)(l)(C), and Title 18, United States Code,
Section 2.
On or about September 23,2011, in the District of South Carolina and elsewhere, the
Defendant, BRUCE JAMES LONG, a/kla Bruce-Bruce, knowingly, intentionally, and
Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1)
and 841 ("t>)(1 )(C).
On or about October 18, 2011, in the District of South Carolina and elsewhere, the
Defendant, BRUCE JAMES LONG, aIkIa Bruce-Bruce, knowingly, intentionally, and
Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(I)
and 841 (b)(1)(C).
On or about November 5, 2011, in the District of South Carolina and elsewhere, the
Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(l)
and 841(b)(1)(C).
15
On or about November 30, 2011, in the District of South Carolina and elsewhere, the
Defendant, BRUCE JAMES LONG, aIkIa Bruce-Bruce, knowingly, intentionally, and
Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(I)
and 841 (b)(l)(C).
On or about December 9, 2011, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, a/k/a Gravel Dave, knowingly, intentionally, and
Schedule IT controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(1)
and 841(b)(1)(C).
On or about December 13, 2011, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, alk/a Gravel Dave, knowingly, intentionally, and
unlawfully did possess with intent to distribute and did distribute 5 grams or more of actual
methamphetamine, a Schedule II controlled substance, in violation of Title 21, United States
Code, Sections 841(a)(I) and 841(b)(I)(B).
On or about December 16,2011, in the District of South Carolina and elsewhere, the
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Schedule II controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l)
and 841(b)(1)(C).
20. Racketeering Act 13 - Attempted Narcotics Distribution
On or about December 22, 2011 through December 23, 2011, in the District of South
Carolina and elsewhere, the Defendant, DAVID CHANNING OILER, a/kla Gravel Dave,
knowingly, intentionally, and unlawfully did attempt to possess with intent to distribute 500
grams or more of more of a mixture and substance containing cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 841 (a)(1) and 841 (b)(1)(B); all
in violation of Title 21, United States Code, Section 846.
On or about December 23,2011, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, alkla Gravel Dave, knowingly, intentionally, and
Code, Sections 841(a)(1) and 841(b)(I)(B).
On or about January 10,2012, in the District of South Carolina and elsewhere, the
Code, Sections 841 (a)(l) and 841 (b)(1 )(A).
17
On or about January 18,2011 through January 24, 2012, in the District of South Carolina
and elsewhere, the Defendant, DAVID CHANNING OILER, a/kla Gravel Dave, knowingly,
intentionally, and unlawfully did attempt to possess with intent to distribute 500 grams or more
of a mixture and substance containing cocaine, a Schedule II controlled substance, in violation of
Title 21, United States Code, Sections 841(a)(1) and 841 (b)(1)(B); all in violation of Title 21,
United States Code, Section 846.
On or about January 31,2012, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, a/kla Gravel Dave, knowingly, intentionally, and
Code, Sections 841(a)(l) and 841 (b)(1)(A).
On or about January 31, 2012 through February 2, 2012, in the District of South Carolina
and elsewhere, the Defendant, DAVID CHANNING OILER, a/kla Gravel Dave, knowingly,
Title 21, United States Code, Sections 841(a)(1) and 841 (b)(1)(B); all in violation of Title 21,
On or about February 6,2012, in the District of South Carolina and elsewhere, the
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unlawfully did attempt to possess with intent to distribute 500 grams or more of a mixture and
substance containing cocaine, a Schedule II controlled substance, in violation of Title 21, United
States Code, Sections 841 (a)( 1) and 841 (b)( 1 )(B); all in violation of Title 21, United States
Code, Section 846.
On or about February 14,2012, in the District of South Carolina and elsewhere, the
Code, Sections 841 (a)(1) and 841 (b)(1)(A).
On or about March 1, 2012 through March 2, 2012, in the District of South Carolina and
elsewhere, the Defendant, DAVID CHANNING OILER, a/k/a Gravel Dave, knowingly,
Title 21, United States Code, Sections 841 (a)(1) and 841 (b)(1)(B); all in violation of Title 21,
On or about March 8, 2012, in the District of South Carolina and elsewhere, the
Code, Sections 841(a)(1) and 841 (b)(1)(A).
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On or about May 4, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/kla Big Fred, knowingly, intentionally, and unlawfully did
possess with intent to distribute and did distribute a mixture and substance containing
clonazepam, a controlled substance sold under the brand name Klonopin, a Schedule IV
controlled substance, in violation of Title 21, United States Code, Sections 841(a)(I) and
841 (b)(2).
On or about May 18,2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, alkla Big Fred, knowingly, intentionally, and unlawfully did
controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and
841 (b)(2).
On or about May 25,2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/kla Big Fred, knowingly, intentionally, and unlawfully did
. clonazepam, a controlled substance sold under the brand name Klonopin, a Schedule IV
controlled substance, in violation of Title 21 , United States Code, Sections 841 (a)( 1) and
841 (b)(2).
On or about June 22, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/kIa Big Fred, knowingly, intentionally, and unlawfully did
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841(b)(2).
On or about July 20, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/kIa Big Fred, knowingly, intentionally, and unlawfully did
c1onazepam, a controlled substance sold under the brand name Klonopin, a Schedule IV
841 (b)(2).
On or about August 17, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, alkla Big Fred, knowingly, intentionally, and unlawfully did
c1onazepam, a controlled substance sold under the brand name Klonopin, a Schedule IV
controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(l) and
841 (b)(2).
On or about April 11, 2012, in the District of South Carolina and elsewhere, the
Defendants, FRANK ENRIQUEZ, JR., alkla Big Frank, DONALD BOERSMA, alkla
Brooklyn Don, alkla Brooklyn Donnie, and JOHANNA LOOPER, alkla JoJo, knowingly,
intentionally, and unlawfully did possess with intent to distribute and did distribute a mixture and
substance containing oxycodone, sold under the brand name Percocet, a Schedule II controlled
21
substance, in violation of Title 21, United States Code, Sections 84 1(a)(l) and 841 (b)(l)(C), and
Title 18, United States Code, Section 2.
On or about April 25, 2012, in the District of South Carolina and elsewhere, the
Defendants, DONALD BOERSMA, alkla Brooklyn Don, a/kla Brooklyn Donnie, and
JOHANNA LOOPER, alkla JoJo, knowingly, intentionally, and unlawfully did attempt to
possess with intent to distribute and distribute a mixture and substance containing hydrocodone,
a Schedule III controlled substance, in violation of Title 21, United States Code, Sections
841(a)(1) and 841(b)(l)(E); all in violation of Title 21, United States Code, Section 846.
38. Racketeering Act 31 - Attempted Hobbs Act Robbery
In and around July 2011 through November 2011, in the District of South Carolina and
elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alkla Diamond Dan; BRUCE
JAMES LONG, alkla Bruce-Bruce; and LISA ELLEN BIFIELD, alkla Lisa Ellen Meyers,
aIkIa Lisa Ellen Stockton, knowingly and unlawfully did attempt to obstruct, delay and affect
interstate commerce and the movement of articles and commodities in such commerce by
robbery, as the terms "commerce" and "robbery" are defined in Title 18, United States Code,
Section 1951, in that the defendants did attempt to take controlled substances from individuals
they believed to be engaged in narcotics trafficking by means of actual and threatened force,
violence and fear of injury to said individuals; in violation of Title 18, United States Code,
Sections 1951 and 2.
In and around November 2011 through February 2012, in the District of South Carolina
and elsewhere, the Defendant, DAVID ALLEN PRYOR, alkla Yard Owl, knowingly and
unlawfully did attempt to obstruct, delay and affect interstate commerce and the movement of
articles and commodities in such commerce by robbery, as the terms "commerce" and "robbery"
22
are defined in Title 18, United States Code, Section 1951, in that the defendant did attempt to
take controlled substances from individuals he believed to be engaged in narcotics trafficking by
means of actual and threatened force, violence and fear of injury to said individuals; in violation
of Title 18, United States Code, Sections 1951 and 2.
In and around March 2012, in the District of South Carolina and elsewhere, the
Defendant, DAVID ALLEN PRYOR, alkla Yard Owl, knowingly and unlawfully did attempt
to obstruct, delay and affect interstate commerce and the movement of articles and commodities
in such commerce by robbery, as the terms "commerce" and "robbery" are defined in Title 18,
United States Code, Section 1951, in that the defendant did attempt to take controlled substances
from individuals he believed to be engaged in narcotics trafficking by means of actual and
threatened force, violence and fear of injury to said individuals; in violation of Title 18, United
States Code, Sections 1951 and 2.
41. Racketeering Act 34 - Money Laundering
On or about November 29,2011 through December 5, 2011, in the District of South
Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alk/a Diamond Dan,
and LISA ELLEN BIFIELD, a/k/a Lisa Ellen Meyers,alk/a Lisa Ellen Stockton, with the
intent to conceal and disguise the nature, location, source, ownership and control of property
believed to be the proceeds of specified unlawful activity, knowingly did conduct and attempt to
conduct a financial transaction affecting interstate and foreign commerce involving property
represented by a law enforcement officer and a person at the direction of and approval of a
federal official to be proceeds of specified unlawful activity, to wit: selling and otherwise dealing
in narcotic controlled substances, in violation of Title 21, United States Code, Sections 841 and
846, and interference with commerce by robbery, in violation of Title 18, United States Code,
Section 1951; all in violation ofTitle 18, United States Code, Sections 1956(a)(3)(B) and 2.
23
On or about November 30,2011 through December 6, 2011, in the District of South
Carolina and elsewhere, the Defendant, BRUCE JAMES LONG, a/kJa Bruce-Bruce, with the
intent to conceal and disguise the nature, location, source, ownership and control of property
believed to be the proceeds of specified unlawful activity, knowingly did conduct and attempt to
conduct a financial transaction affecting interstate and foreign commerce involving property
represented by a law enforcement officer and a person at the direction of and approval of a
federal official to be proceeds of specified unlawful activity, to wit: selling and otherwise dealing
in narcotic controlled substances, in violation of Title 21, United States Code, Sections 841 and
846, and interference with commerce by robbery, in violation of Title 18, United States Code,
Section 1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B).
On or about November 30, 2011 through December 13, 2011, in the District of South
Carolina and elsewhere, the Defendant, DAVID CHANNING OILER, alkla Gravel Dave,
with the intent to conceal and disguise the nature, location, source, ownership and control of
property believed to be the proceeds of specified unlawful activity, knowingly did conduct and
attempt to conduct a financial transaction affecting interstate and foreign commerce involving
property represented by a law enforcement officer and a person at the direction of and approval
of a federal official to be proceeds of specified unlawful activity, to wit: selling and otherwise
dealing in narcotic controlled substances, in violation of Title 21, United States Code, Sections
841 and 846, and interference with commerce by robbery, in violation of Title 18, United States
Code, Section 1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B).
On or about December 22, 2011 through December 23, 2011, in the District of South
Carolina and elsewhere, the Defendant, DANIEL EUGENE BIFIELD, alkla Diamond Dan,
24
with the intent to conceal and disguise the nature, location, source, ownership and control of
Code, Section 1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B) and
2.
On or about December 23,2011 through January 5,2012, in the District of South
Carolina and elsewhere, the Defendant, DANIEL EUGENE BIFIELD, a/kIa Diamond Dan,
, with the intent to conceal and disguise the nature, location, source, ownership and control of
Code, Section 1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B) and
2.
25
On or about February 24, 2012, in the Dis.trict of South Carolina and elsewhere, the
Defendant, RICHARD THROWER, a/k/a Little Mark, a/k/a Rat, with the intent to conceal
and disguise the nature, 10cation, source, ownership and control of property believed to be the
proceeds of specified un1awful activity, knowingly did conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce involving property represented by a law
enforcement officer and a person at the direction of and approval of a federal official to be
proceeds of specified un1awful activity, to wit: selling and otherwise dealing in narcotic
controlled substances, in violation of Title 21, United States Code, Sections 841 and 846, and
interference with commerce by robbery, in violation of Title 18, United States Code, Section
1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B).
Defendant, DANIEL EUGENE BIFIELD, a/kIa Diamond Dan, with the intent to conceal and
disguise the nature, location, source, ownership and control of property believed to be the
proceeds of specified unlawful activity, knowingly did conduct and attempt to conduct a financial
proceeds of specified unlawful activity, to wit: selling and otherwise dealing in narcotic
1951; all in violation of Title 18, United States Code, Section 1956(a)(3)(B) and 2.
48. Racketeering Act 41- Money Laundering
On or about March 1,2012 through March 7, 2012, in the District of South Carolina and
elsewhere, the Defendant, MARK WILLIAM BAKER, a/k/a Lightning, with the intent to
26
conceal and disguise the nature, location, source, ownership and control of property believed to
be the proceeds of specified unlawful activity, knowingly did conduct and attempt to conduct a
financial transaction affecting interstate and foreign commerce involving property represented by
a law enforcement officer and a person at the direction of and approval of a federal official to be
controlled substances, in violation of TitIe 21, United States Code, Sections 841 and 846, and
1951; all in violation of Title 18, United States Code, Section 1956( a )(3 )(B).
Defendant, RICHARD THROWER, a/kla Little Mark, a/kla Rat, with the intent to conceal
and disguise the nature, location, source, ownership and control of property believed to be the
proceeds of specified unlawful activity, knowingly did conduct and attempt to conduct a financial
1951; all in violation of Title 18, United States Code, Section 1956(a)(3)(B).
50. Racketeering Act 43 - Arson
The Defendant, DANIEL EUGENE BIFIELD, alkla Diamond Dan, committed the
following acts, either of which alone constitutes Racketeering Act 43:
(a) On or about March 8, 2012, in the District of South Carolina, the Defendant,
DANIEL EUGENE BIFIELD, alkla Diamond Dan, wilfully and maliciously
did set a fire to, burn, and cause to be burned a building and property, which
27
resulted, directly and indirectly, in damage to the building and property; in
violation of Code of Laws of South Carolina, 16-11-110..
(b) On or about February 21,2012 through March 8, 2012, in the District of South
Carolina, the Defendant, DANIEL EUGENE BIFIELD, alkla Diamond Dan,
wilfully and maliciously did attempt to set a fire to and burn a building and
property; in violation of Code of Laws of South Carolina, 16-11-190.
All in violation of 18, United States Code, Section 1962( c).
COUNT 2
(Racketeering Conspiracy)
THE GRAND JURY FURTHER CHARGES:
51. The paragraphs 1 through 6 are realleged and incorporated by reference herein.
52. From beginning at least in or around 2008, and continuing thereafter, up to and including
the date of this Indictment, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, a/k/a Diamond Dan; MARK WILLIAM
BAKER, alk/a Lightning; DAVID CHANNING OILER, a/k/a Gravel Dave;
BRUCE JAMES LONG, alkla Bruce-Bruce; RICHARD THROWER, alkla Little
Mark, a/k/a Rat; DAVID ALLEN PRYOR, alkla Yard Owl; JAMES FREDERICK
KEACH, JR, a/k/a Big Fred; FRANK ENRIQUEZ, JR., alkla Big Frank; DONALD
BOERSMA, alkla Brooklyn Don, a/k/a Brooklyn Donnie; LISA ELLEN BIFIELD,
a/k/a Lisa Ellen Meyers, a/k/a Lisa Ellen Stockton; and JOHANNA LOOPER, alk/a
JoJo, with each other and with others both known and unknown to the grand jury, being
persons employed by and associated with the Enterprise known as the Hells Angels Rock
Hell City Nomad Chapter ofthe Hells Angels, as described in Paragraphs 1-6, an
28
Enterprise which engaged in, and the activities of which affected, interstate commerce,
knowingly and intentionally conspired to violate 18 U.S.C. 1962(c), that is, to conduct
and participate, directly and indirectly, in the conduct of the affairs of that Enterprise
through a pattern of racketeering activity consisting of multiple acts indictable under:
(a) 18 U.S.C. 1951 (Hobbs Act);
(b) 18 U.S.C. 1956(a)(3)(B) (Money Laundering);
multiple acts involving:
(a) Arson, chargeable under Code of Laws of South Carolina, 16-11-110 and
Code of Laws of South Carolina, 16-11-190;
and multiple acts involving narcotics trafficking, including cocaine, methamphetamine,
oxycodone, hydrocodone, and clonazepam, in violation of the laws ofthe United States
Sections 841 and 846 of Title 21, United States Code.
53. It was a part ofthe conspiracy that each defendant agreed that a conspirator would
commit at least two acts of racketeering activity in the conduct of the affairs ofthe
enterprise.
All in violation of Title 18, United States Code, Section 1962(d).
COUNT 3
(Narcotics Conspiracy)
54. Beginning at a time unknown to the grand jury but beginning at least in or around 2010,
and continuing thereafter, up to and including the date ofthis Indictment, in the District
of South Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alkla
Diamond Dan; MARK WILLIAM BAKER, a/k/a Lightning; DAVID CHANNING
29
OILER, a/kla Gravel Dave; BRUCE JAMES LONG, a/kla Bruce-Bruce;
RICHARD THROWER, a/kla Little Mark, alkla Rat; DAVID ALLEN PRYOR,
alkla Yard Owl; FREDERICK KEACH, JR, alkla Big Fred; FRANK ENRIQUEZ,
JR., alkla Big Frank; DONALD BOERSMA, a/kla Brooklyn Don, alkla Brooklyn
Donnie; LISA ELLEN BIFIELD, a/kla Lisa Ellen Meyers, alkla Lisa Ellen
Stockton; JOHANNA LOOPER, a/kla JoJo; KERRY CHITWOOD; CARLOS
HERNANDEZ; RONALD DEAN BYRUM, JR, alkla Big Ron; and TRENT ALLEN
BROWN, knowingly and intentionally did combine, conspire and agree with each other
and others, both known and unknown to the grand jury, to knowingly, intentionally, and
unlawfully possess with intent to distribute and distribute cocaine, methamphetamine, and
oxycodone, Schedule II controlled substances, hydrocodone, a Schedule III controlled
substance, and c1onazepam, a Schedule IV controlled substance, said conspiracy
involving 5 kilograms or more of a mixture and a substance containing cocaine, 50 grams
or more of actual methamphetamine, and 500 grams or more of a mixture and substance
containing methamphetamine, and thereby violated the narcotics laws ofthe United
States, to wit, Title 21, United States Code, Sections 841(a)(1), 841(b)(1)(A),
841(b)(1)(C), 841(b)(1)(E), 841(b)(2); all in violation of Title 21, United States Code,
Section 846.
COUNT 4
(Narcotics Distribution)
TIlE GRAND JURY FURTHER CHARGES:
55. On or about July 22, 2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, a/kla Diamond Dan, and LISA ELLEN
30
BIFIELD, alk/a Lisa Ellen Meyers, alkla Lisa Ellen Stockton, as principals, aiders,
and abettors, and as co-participants in jointly undertaken criminal activity, knowingly,
intentionally, and unlawfully did possess with intent to distribute and did distribute a
quantity of cocaine, a Schedule II controlled substance, in violation of Title 21, United
States Code, Sections 841(a)(1) and 841 (b)(1)(C), and Title 18, United States Code,
Section 2.
COUNTS
56. On or about August 5, 2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, a/kla Diamond Dan, BRUCE JAMES
LONG, alkla Bruce-Bruce, LISA ELLEN BIFIELD, a/kla Lisa Ellen Meyers, alk/a
Lisa Ellen Stockton, and SOMYING ANDERSON, alk/a Ying, as principals, aiders,
and abettors, and as co-participants injointly undertaken criminal activity, knowingly,
intentionally, and unlawfully did possess with intent to distribute and did distribute a
quantity of cocaine, a Schedule II controlled substance, in violation of Title 21, United
States Code, Sections 841(a)(I) and 841(b)(I)(C), and Title 18, United States Code,
Section 2.
COUNT 6
57. On or about August 30, 2011, in the District of South Carolina and elsewhere, the
31
Schedule II controlled substance, in violation of Title 21, United States Code, Sections
841(a)(1) and 841(b)(1)(C).
COUNT 7
58. On or about September 19, 2011, in the District of South Carolina and elsewhere, the
Defendants, DANIEL EUGENE BIFIELD, alkla Diamond Dan, BRUCE JAMES
LONG, alkla Bruce-Bruce, and LISA ELLEN BIFIELD, alkla Lisa Ellen Meyers,
aIkIa Lisa Ellen Stockton, as principals, aiders, and abettors, and as co-participants in
jointly undertaken criminal activity, knowingly, intentionally, and unlawfully did possess
with intent to distribute and did distribute a quantity of cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 841 (a)(1) and
841 (b)(I)(C), and Title 18, United States Code, Section 2.
COUNT 8
59. On or about September 23,2011, in the District of South Carolina and elsewhere, the
841(a)(1) and 841 (b)(l)(C).
32
COUNT 9
60. On or about October 18, 20 II, in the District of South Carolina and elsewhere, the
841(a)(l) and 841(b)(1)(C).
COUNT 10
61. On or about November 5, 2011, in the District of South Carolina and elsewhere, the
841 (a)(1) and 841 (b)(1 )(C).
COUNT 11
62. On or about November 30, 2011, in the District of South Carolina and elsewhere, the
841(a)(l) and 84 I (b)(l)(C).
33
COUNT 12
63. On or about December 9, 2011, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, a/kla Gravel Dave, knowingly, intentionally,
and unlawfully did possess with intent to distribute and did distribute a quantity of
cocaine, a Schedule II controlled substance, in violation of Title 21, United States Code,
Sections 841 (a)(l) and 84 I (b)(I)(C).
COUNT 13
64. On or about December 13,2011, in the District of South Carolina and elsewhere, the
Defendant, DAVID CHANNING OILER, a/kIa Gravel Dave, knowingly, intentionally,
and unlawfully did possess with intent to distribute and did distribute 5 grams or more of
actual methamphetamine, a Schedule II controlled substance, in violation of Title 21,
United States Code, Sections 841 (a)(l) and 841 (b)(1)(B).
COUNT 14
84l(a)(I) and 84 1 (b)(l)(C).
34
COUNT 15
(Attempted Narcotics Distribution)
66. On or about December 22, 2011 through December 23, 2011, in the District of South
Carolina and elsewhere, the Defendant, DAVID CHANNING OILER, alkla Gravel
Dave, knowingly, intentionally, and unlawfully did attempt to possess with intent to
distribute 500 grams or more of cocaine, a Schedule II controlled substance, in violation
ofTitIe 21, United States Code, Sections 841 (a)(1) and 841 (b)(1)(B); all in violation of
Title 21, United States Code, Section 846.
COUNT 16
Defendant, DAVID CHANNING OILER, alkla Gravel Dave, knowingly, intentionally,
and unlawfully did possess with intent to distribute and did distribute 5 grams or more of
actual methamphetamine, a Schedule II controlled substance, in violation of Title 21,
United States Code, Sections 841 (a)( 1) and 841 (b )( 1 )(B).
35
COUNT 17
68. On or about January 10,2012, in the District of South Carolina and elsewhere, the
Defendants, DAVID CHANNING OILER, a/k1a Gravel Dave, and KERRY
CHITWOOD, as principals, aiders, and abettors, and as co-participants in jointly
undertaken criminal activity, knowingly, intentionally, and unlawfully did possess with
intent to distribute and did distribute 50 grams or more of actual methamphetamine, a
841(a)(1) and 841(b)(1)(A), and Title 18, United States Code, Section 2.
COUNT 18
69. On or about January 18,2012 through January 24,2012, in the District of South Carolina
and elsewhere, the Defendants, DAVID CHANNING OILER, a/kIa Gravel Dave, and
KERRY CHITWOOD, as principals, aiders, and abettors, and as co-participants in
jointly undertaken criminal activity, knowingly, intentionally, and unlawfully did attempt
to possess with intent to distribute 500 grams or more of cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 841(a)(1) and
841 (b)(l)(B); all in violation of Title 21, United States Code, Section 846, and Title 18,
36
COUNT 19
70. On or about January 31,2012, in the District of South Carolina and elsewhere, the
Defendants, DAVID CHANNING OILER, a/kIa Gravel Dave, and KERRY
CHITWOOD, as principals, aiders, and abettors, and as co-participants injointly
undertaken criminal activity, knowingly, intentionally, and unlawfully did possess with
intent to distribute and did distribute 50 grams or more of actual methamphetamine, a
841(a)(1) and 841 (b)(1)(A), and Title 18, United States Code, Section 2.
COUNT 20
71. On or about January 31,2012 through February 2,2012, in the District of South Carolina
and elsewhere, the Defendants, DAVID CHANNING OILER, a/klaGravel Dave, and
KERRY CHITWOOD, as principals, aiders, and abettors, and as co-participants in
jointly undertaken criminal activity, knowingly, intentionally, and unlawfully did attempt
to possess with intent to distribute 500 grams or more of cocaine, a Schedule II controlled
substance, in violation of Title 21, United States Code, Sections 841(a)(1) and
841(b)(1)(B); all in violation of Title 21, United States Code, Section 846, and Title 18,
37
COUNT 21
72. On or about February 6, 2012, in the District of South Carolina and elsewhere, the
unlawfully did attempt to possess with intent to distribute 500 grams or more of cocaine,
a Schedule II controlled substance, in violation of Title 21, United States Code, Sections
841 (a)(1) and 841 (b)(1 )(8); all in violation of Title 21, United States Code, Section 846.
COUNT 22
73. On or about February 14,2012, in the District of South Carolina and elsewhere, the
Defendant, DA VID CHANNING OILER, alkla Gravel Dave, knowingly, intentionally,
and unlawfully did possess with intent to distribute and did distribute 50 grams or more
of actual methamphetamine, a Schedule II controlled substance, in violation of Title 21,
United States Code, Sections 841(a)(I) and 841(b)(I)(A).
COUNT 23
74. On or about March 1, 2012 through March 2,2012, in the District of South Carolina and
elsewhere, the Defendants, DAVID CHANNING OILER, a/kla Gravel Dave, and
RONALD DEAN BYRUM, JR, alkla Big Ron, as principals, aiders, and abettors, and
as co-participants in jointly undertaken criminal activity, knowingly, intentionally, and
unlawfully did attempt to possess with intent to distribute 500 grams or more of cocaine,
38
COUNT 26
77. On or aboufMay 18, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/k1a Big Fred, knowingly, intentionally, and unlawfully
did possess with intent to distribute and did distribute a mixture and substance containing
controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(1) and
841 (b)(2).
COUNT 27
78. On or about May 25, 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, alkla Big Fred, knowingly, intentionally, and unlawfully
controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and
841(b)(2).
40
COUNT 28
(Possession of a Firearm in Furtherance Drug Trafficking)
79. In or around May 2011, in the District of South Carolina, the Defendant, JAMES
FREDERICK KEACH, JR, a/kIa Big Fred, knowingly did use and carry a firearm
during, and in relation to, and did possess the firearm in furtherance of, a drug trafficking
crime for which he may be prosecuted in a court of the United States; in violation of Title
18, United States Code, Section 924( c).
COUNT 29
80. On or about June 22, 2011, in the District of South Carolina, the Defendant, JAMES
clonazepam, a controlled substance sold under the brand name Klonopin, a Schedule N
controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(1 ) and
841 (b)(2).
41
COUNT 30
81. On or about July 20, 2011, in the District of South Carolina, the Defendant, JAMES
controlled substance, in violation of Title 21, United States Code, Sections 841 (a)(1 ) and
841 (b)(2).
COUNT 31
82. On or about August 17, 2011, in the District of South Carolina, the Defendant, JAMES
841 (b)(2).
42
COUNT 32
83. On or about April 11,2012, in the District of South Carolina and elsewhere, the
Defendants, FRANK ENRIQUEZ, JR., a/k/a Big Frank, DONALD BOERSMA,
alk/a Brooklyn Don, alk/a Brooklyn Donnie, and JOHANNA LOOPER, alk/a JoJo,
as principals, aiders, and abettors, and as co-participants in jointly undertaken criminal
activity, knowingly, intentionally, and unlawfully did possess with intent to distribute and
did distribute a mixture and substance containing oxycodone, sold under the brand name
Percocet, a Schedule II controlled substance, in violation of Title 21, United States Code,
Sections 841 (a)(1) and 841 (b)(1)(C), and Title 18, United States Code, Section 2.
COUNT 33
84. On or about April 25, 2012, in the District of South Carolina and elsewhere, the
Defendants, DONALD BOERSMA, alk/a Brooklyn Don, alk/a Brooklyn Donnie, and
JOHANNA LOOPER, alk/a JoJo, as principals, aiders, and abettors, and as
co-participants in jointly undertaken criminal activity, knowingly, intentionally, and
unlawfully did attempt to possess with intent to distribute and distribute a mixture and
substance containing hydrocodone, a Schedule III controlled substance, in violation of
Title 21, United States Code, Sections 841(a)(I) and 841(b)(1)(E); all in violation of Title
21, United States Code, Section 846, and Title 18, United States Code, Section 2.
43
COUNT 34
(Attempted Hobbs Act Robbery)
85. In and around July 2011 through November 2011, in the District of South Carolina and
elsewhere, the Defendants, DANIEL EUGENE BIFIELD, alkla Diamond Dan;
BRUCE JAMES LONG, aIkIa Bruce-Bruce; and LISA ELLEN BIFIELD, alkla Lisa
Ellen Meyers, aIkIa Lisa EDen Stockton, knowingly and unlawfully did attempt to
obstruct, delay and affect interstate commerce and the movement of articles and
commodities in such commerce by.robbery, as the terms "commerce" and "robbery" are
defined in Title 18, United States Code, Section 1951, in that the defendants did attempt
to take controlled substances from individuals they believed to be engaged in narcotics
,
trafficking by means of actual and threatened force, violence and fear of injury to said
individuals; in violation of Title 18, United States Code, Sections 1951 and 2.
COUNT 35
86. In and ar:ound November 2011 through February 2012, in the District of South Carolina
and elsewhere, the Defendant, DAVID ALLEN PRYOR, alkla Yard Owl, knowingly
and unlawfully did attempt to obstruct, delay and affect interstate commerce and the
movement of articles and commodities in such commerce by robbery, as the terms
"commerce" and "robbery" are defined in Title 18, United States Code, Section 1951, in
that the defendant did attempt to take controlled substances from individuals he believed
to be engaged in narcotics trafficking by means of actual and threatened force, violence
44
and fear of injury to said individuals; in violation of Title 18, United States Code,
Sections 1951 and 2.
COUNT 36
87. In and around March 2012, in the District of South Carolina and elsewhere, the
Defendant, DAVID ALLEN PRYOR, aIkIa Yard.Owl, knowingly and unlawfully did
attempt to obstruct, delay and affect interstate commerce and the movement of articles
and commodities in such commerce by robbery, as the terms "commerce" and "robbery"
are defined in Title 18, United States Code, Section 1951, in that the defendant did
attempt to take controlled substances from individuals he believed to be engaged in
narcotics trafficking by means of actual and threatened force, violence and fear of injury
to said individuals; in violation of Title 18, United States Code, Sections 1951 and 2.
COUNT 37
(Money Laundering)
88. On or about November 29,2011 through December 5, 2011, in the District of South
Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, a/kla Diamond
Dan, and LISA ELLEN BIFIELD, a/kla Lisa Ellen Meyers, a/kla Lisa Ellen
Stockton, as principals, aiders, and abettors, and as co-participants in jointly undertaken
criminal activity, with the intent to conceal and disguise the nature, location, source,
ownership and control of property believed to be the proceeds of specified unlawful
activity, knowingly did conduct and attempt to conduct a financial transaction affecting
45
interstate and foreign commerce involving property represented by a law enforcement
officer and a person at the direction of and approval of a federal official to be proceeds of
specified unlawful activity, to wit: selling and otherwise dealing in narcotic controlled
substances, in violation of Title 21, United States Code, Sections 841 and 846, and
interference with commerce by robbery, in violation of Title 18, United States Code,
Section 1951; all in violation of Title 18, United States Code, Sections 1956(a)(3)(B) and
2.
COUNT 38
(Money Laundering)
89. On or about November 30,2011 through December 6, 2011, in the District of South
Carolina and elsewhere, the Defendant, BRUCE JAMES LONG, a/k/a Bruce-Bruce,
with the intent to conceal and disguise the nature, location, source, ownership and control
of property believed to be the proceeds of specified unlawful activity, knowingly did
conduct and attempt to conduct a financial transaction affecting interstate and foreign
commerce involving property represented by a law enforcement officer and a person at
the direction of and approval of a federal official to be proceeds of specified unlawful
activity, to wit: selling and otherwise dealing in narcotic controlled substances, in
violation of Title 21, United States Code, Sections 841 and 846, and interference with
commerce by robbery, in violation of Title 18, United States Code, Section 1951; all in
violation of Title 18, United States Code, Section 1956(a)(3)(B).
46
COUNT 39
(Money Laundering)
THE GRAND JURy FURTHER CHARGES:
90. On or about November 30, 20 II through December 13, 2011, in the District of South
Carolina and elsewhere, the Defendant, DAVID CHANNING OILER, alkla Gravel
Dave, with the intent to conceal and disguise the nature, location, source, ownership and
control of property believed to be the proceeds of specified unlawful activity, knowingly
did conduct and attempt to conduct a financial transaction affecting interstate and foreign
violation of Title 18, United States Code, Section 1956(a)(3)(B).
COUNT 40
(Money Laundering)
91. On or about December 22,2011 through December 23,2011, in the District of South
Carolina and elsewhere, the Defendants, DANIEL EUGENE BIFIELD, a/kIa Diamond
Dan, and JAMES RHODUS, a/kIa Sonny, as principals, aiders, and abettors, and as
co-participants in jointly undertaken criminal activity, with the intent to conceal and
disguise the nature, location, source, ownership and control of property believed to be the
proceeds of specified unlawful activity, knowingly did conduct and attempt to conduct a
financial transaction affecting interstate and foreign commerce involving property
47
represented by a law enforcement officer and a person at the direction of and approval of
a federal official to be proceeds of specified unlawful activity, to wit: selling and
otherwise dealing in narcotic controlled substances, in violation of Title 21, United States
Code, Sections 841 and 846, and interference with commerce by robbery, in violation of
Title 18, United States Code, Section 1951; all in violation of Title 18, United States
Code, Sections 1956(a)(3)(B) and 2.
COUNT 41
(Money Laundering)
92. On or about December 23,2011 through January 5, 2012, in the District of South
Carolina and elsewhere, the Defendant, DANIEL EUGENE BIFIELD, a/kla Diamond
Dan, with the intent to conceal and disguise the nature, location, source, ownership and
control of property believed to be the proceeds of specified unlawful activity, knowingly
did conduct and attempt to conduct a financial transaction affecting interstate and foreign
violation of Title 18, United States Code, Section 1956(a)(3)(B).'
48
COUNT 42
(Money Laundering)
93. On or about February 24,2012, in the District of South Carolina and elsewhere, the
Defendant, RICHARD THROWER, alkla Little Mark, a/kla Rat, with the intent to
conceal and disguise the nature, location, source, ownership and control of property
believed to be the proceeds of specified unlawful activity, knowingly did conduct and
attempt to conduct a financial transaction affecting interstate and foreign commerce
involving property represented by a law enforcement officer and a person at the direction
of and approval of a federal official to be proceeds of specified unlawful activity, to wit:
selling and otherwise dealing in narcotic controlled substances, in violation of Title 21,
United States Code, Sections 841 and 846; all in violation of Title 18, United States
Code, Sections 1956(a)(3)(B).
COUNT 43
(Money Laundering)
94. On or about March 1, 2012, in the District of South Carolina and elsewhere, the
Defendant, DANIEL EUGENE BIFIELD, a/kIa Diamond Dan, with the intent to
involving property represented by a person at the direction of and approval of a federal
official to be proceeds of specified unlawful activity, to wit: selling and otherwise dealing
49
in narcotic controlled substances, in violation of Title 21, United States Code, Sections
841 and 846, and interference with commerce by robbery, in violation of Title 18, United
States Code, Section 1951; all in violation of Title 18, United States Code, Sections
1956( a)(3)(B).
COUNT 44
(Money Laundering) .
95. On or about March 1,2012, through March 7, 2012, in the District of South Carolina and
elsewhere, the Defendant, MARK WILLIAM BAKER, alkla Lightning, with the intent
to conceal and disguise the nature, location, source, ownership and control of property
involving property represented by a person at the direction of and approval of a federal
official to be proceeds of specified unlawful activity, to wit: selling and otherwise dealing
in narcotic controlled substances, in violation of Title 21, United States Code, Sections
841 and 846, and interference with commerce by robbery, in violation of Title 18, United
States Code, Section 1951; all in violation of Title 18, United States Code, Sections
1956(a)(3)(B).
50
COUNT 45
(Money Laundering)
96. On or about March 5, 2012, in the District of South Carolina and elsewhere, the
Defendant, RICHARD THROWER, a/k/a Little Mark, a/k/a Rat, with the intent to
involving property represented by a law enforcement officer and a person at the direction
of and approval of a federal official to be proceeds of specified unlawful activity, to wit:
selling and otherwise dealing in narcotic controlled substances, in violation of Title 21,
United States Code, Sections 841 and 846; all in violation of Title 18, United States
Code, Sections 1956(a)(3)(B).
51
COUNT 46
(Firearms)
97. On or about April 28, 2011, in the District of South Carolina, the Defendants, DANIEL
EUGENE BIFIELD, alk/a Diamond Dan, and LISA ELLEN BIFIELD, a/k/a Lisa
Ellen Meyers, a/k/a Lisa Ellen Stockton, as principals, aiders, and abettors, and as
co-participants in jointly undertaken criminal activity, knowingly did sell and dispose of a
firearm and ammunition, that is, a Ruger model LCR .38 caliber revolver and .38 caliber
ammunition, to an individual, knowing and having reasonable cause to believe that the
individual had been convicted of a crime punishable by imprisonment for a term
exceeding one year; in violation of Title 18, United States Code, Sections 922( d),
924(a)(2), and 2.
COUNT 47
(Firearms)
98. On or about June 14, 2011, in the District of South Carolina, the Defendants, DANIEL
EUGENE BIFIELD, alk/a Diamond Dan, JAMES FREDERICK KEACH, JR, a/k/a
Big Fred, and BRUCE RANSON WILSON, alk/a Diesel, as principals, aiders, and
abettors, and as co-participants in jointly undertaken criminal activity, knowingly did sell
and dispose of firearms, that is, three Taurus model 85 .38 caliber revolvers, to an
individual, knowing and having reasonable cause to believe that the individual had been
convicted of a crime punishable by imprisonment for a term exceeding one year; in
violation of Title 18, United States Code, Sections 922(d), 924(a)(2), and 2.
52
COUNT 48
(Firearms)
99. On or about June 14, 2011, in the District of South Carolina, the Defendants, DANIEL
EUGENE BIFIELD, alk/a Diamond Dan, and JAMES FREDERICK KEACH, JR,
a/kla Big Fred, as principals, aiders, and abettors, and as co-participants injointly
undertaken criminal activity, knowingly did sell and dispose of a firearm, that is, a Glock
model 19 9mm pistol, to an individual, knowing and having reasonable cause to believe
that the individual had been convicted of a crime punishable by imprisonment for a term
exceeding one year; in violation of Title 18, United States Code, Sections 922(d),
924(a)(2), and 2.
COUNT 49
(Firearms)
100. On or about July 21,2011, in the District of South Carolina, the Defendants, DANIEL
EUGENE BIFIELD, alk/a Diamond Dan, and LISA ELLEN BIFIELD, a/kla Lisa
Ellen Meyers, a/kla Lisa Ellen Stockton, as principals, aiders, and abettors, and as
co-participants in jointly undertaken criminal activity, knowingly did sell and dispose of a
firearm, that is, a Keltec model P32 .32 caliber pistol, to an individual, knowing and
having reasonable cause to believe that the individual had been convicted of a crime
punishable by imprisonment for a term exceeding one year; in violation of Title 18,
United States Code, Sections 922(d), 924(a)(2), and 2.
53
COUNT 50
(Firearms)
101. On or about July 21,2011, in the District of South Carolina, the Defendants, DANIEL
EUGENE BIFIELD, a/k/a Diamond Dan, and LISA ELLEN BIFIELD, a/k/a Lisa
Ellen Meyers, a/kIa Lisa Ellen Stockton, as principals, aiders, and abettors, and as
co-participants in jointly undertaken criminal activity, knowingly did transfer a firearm,
that is, a Keltec model P32 .32 caliber pistol, knowing that the firearm would be used in a
crime of violence and a drug trafficking crime; in violation of Title 18, United States
Code, Sections 924(h) and 2.
COUNT 51
(Firearms)
102. On or about August 5, 2011, in the District of South Carolina, the Defendant, LISA
ELLEN BIFIELD, a/kIa Lisa Ellen Meyers, a/k/a Lisa Ellen Stockton, knowingly did
sell and dispose of firearms, that is, a Fabrinor Firestorm Mini Compact .45 caliber pistol
and a Lorcin model L9 9mm pistol, to an individual, knowing and having reasonable
cause to believe that the individual had been convicted of a crime punishable by
imprisonment for a term exceeding one year; in violation of Title 18, United States Code,
Sections 922(d) and 924(a)(2).
54
COUNT 52
(Firearms)
103. On or about August 5,2011, in the District of South Carolina, the Defendant, LISA
ELLEN BIFIELD, alkla Lisa Ellen Meyers, alkla Lisa Ellen Stockton, knowingly did
transfer firearms, that is, a Fabrinor Firestonn Mini Compact.45 caliber pistol and a
Lorcin model L9 9mm pistol, knowing that the fireann would be used in a crime of
violence and a drug trafficking crime; in violation of Title 18, United States Code,
Section 924(h).
COUNT 53
(Firearms)
104. On or about September 19,2011, in the District of South Carolina, the Defendants,
DANIEL EUGENE BIFIELD, alkla Diamond Dan, and LISA ELLEN BIFIELD,
alkla Lisa Ellen Meyers, alkla Lisa Ellen Stockton, as principals, aiders, and abettors,
and as co-participants in jointly undertaken criminal activity, knowingly did sell and
dispose of firearms and ammunition, that is, a Smith and Wesson .45.caliber revolver, an
SCCY Industries model CPX-1 9mm pistol, and .45 caliber ammunition, to an individual,
knowing and having reasonable cause to believe that the individual had been convicted of
a crime punishable by imprisonment for a tenn exceeding one year; in violation of Title
18, United States Code, Sections 922(d), 924(a)(2), and 2.
55
COUNT 54
(Firearms)
105. On or about September 19,2011, in the District of South Carolina, the Defendants,
DANIEL EUGENE BIFIELD, aJk/a Diamond Dan, and LISA ELLEN BIFIELD,
alk/a Lisa Ellen Meyers, alk/a Lisa Ellen Stockton, as principals, aiders, and abettors,
and as co-participants in jointly undertaken criminal activity, knowingly did transfer
firearms, that is, a Smith and Wesson.45 caliber revolver and an SCCY Industries model
CPX-l 9mm pistol, knowing that the firearm would be used in a crime of violence and a
drug trafficking crime; in violation of Title 18, United States Code, Sections 924(h) and
2.
COUNT 55
(Firearms)
106. On or about September 20,2011, in the District of South Carolina, the Defendant,
JAMES FREDERICK KEACH, JR, alk/a Big Fred, knowingly did sell and dispose of
a firearm and ammunition, that is, an Armscor of the Philippines model 1911 .45 caliber
pistol and .45 caliber ammunition, to an individual, knowing and having reasonable cause
to believe that the individual had been convicted of a crime punishable by imprisonment
for a term exceeding one year; in violation of Title 18, United States Code, Sections
922(d) and 924(a)(2).
56
COUNT 56
(Firearms)
107. On or about September 21, 2011, in the District of South Carolina, the Defendant,
JAMES FREDERICK KEACH, JR, alkla Big Fred, knowingly did sell and dispose of
firearms, that is, a German Sports Guns (GSG) model GSG-1911 .22 caliber pistol and a
firearm silencer, to an individual, knowing and having reasonable cause to believe that
the individual had been convicted of a crime punishable by imprisonment for a term
exceeding one year; in violation ofTitle'18, United States Code, Sections 922(d) and
924(a)(2).
COUNT 57
(National Firearms Act)
JAMES FREDERICK KEACH, JR, alkla Big Fred, 'knowingly possessed a firearm as
defined by Title 26, United States Code, Sections 5845(a)(7), to wit, a silencer as defined
in Title 18, United States Code, Section 921, not registered to him in the National
Firearms Registration and Transfer Record; in violation of Title 26, United States Code,
Sections 5861(d), 5845(a)(7), and 5871.
57
COUNT 58
(Firearms)
BRUCE JAMES LONG, alkla Bruce-Bruce, knowingly did transfer firearms, that is, a
Norinco model SKS 7.62 caliber rifle and a Tanfoglio Titan model .25 caliber pistol,
knowing that the firearm would be used in a crime of violence and a drug trafficking
crime; in violation of Title 18, United States Code, Section 924(h).
COUNT 59
(Firearms)
110. On or about November 5, 2011 through November 8, 2011, in the District of South
Carolina, the Defendant, DAVID ALLEN PRYOR, alkla Yard Owl, knowingly did sell
and dispose of a firearm and ammunition, that is, a Taurus model 605 .357 caliber
revolver and .357 caliber ammunition, to an individual, knowing and having reasonable
cause to believe that the individual had been convicted of a crime punishable by
imprisonment for a term exceeding one year; in violation of Title 18, United States Code,
Sections 922(d) and 924(a)(2).
58
COUNT 60
(Firearms)
111. On or about November 9,2011, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, alkla Yard Owl, knowingly did sell and dispose of a firearm and
ammunition, that is, a Mossberg model ATR .308 caliber rifle and .308 caliber
individual had been convicted of a crime punishable by imprisonment for a tenn
exceeding one year; in violation of Title 18, United States Code, Sections 922(d) and
924(a)(2).
COUNT 61
(Firearms)
.
112. On or about November 16,2011, in the District of South Carolina, the Defendant,
DAVID ALLEN PRYOR, a/kla Yard Owl, knowingly did sell and dispose of a fireann
and ammunition, that is, a Taurus "The Judge" model .45/.410 caliber revolver and .410
gauge ammunition, to an individual, knowing and having reasonable cause to believe that
the individual had been convicted of a crime punishable by imprisonment for a tenn
exceeding one year; in violation of Title 18, United States Code, Sections 922( d) and
924(a)(2).
59
COUNT 62
(Firearms)
113. On or about November 16, 2011, in the District of South Carolina, the Defendant,
DAVID ALLEN PRYOR, a/kIa Yard Owl, knowingly did transfer a firearm, that is, a
Taurus "The Judge" model .45/.410 caliber revolver, knowing that the firearm would be
used in acrime ofviolence and a drug trafficking crime; in violation of Title 18, United
States Code, Section 924(h).
COUNT 63
(Firearms)
DAVID ALLEN PRYOR, a/kla Yard Owl, knowingly did sell and dispose of firearms,
that is, a Maverick model 88 12-gauge shotgun and a Mossberg model 500 12-gauge
shotgun, to an individual, knowing and having reasonable cause to believe that the
924(a)(2).
60
COUNT64
(Firearms)
DAVID ALLEN PRYOR, alkla Yard Owl, knowingly did possess a firearm, that is, a
Maverick model 88 12-gauge shotgun, from which the manufacturer's serial number had
been removed, altered and obliterated; in violation of Title 18, United States Code,
Sections 922(k) and 924(a)(1)(B).
COUNT 65
(Firearms)
DAVID ALLEN PRYOR, alkla Yard Owl, knowingly did transfer firearms, that is, a
Maverick model 88 12-gauge shotgun and a Mossberg model 500 12-gauge shotgun,
knowing that the firearms would be used in a crime of violence and a drug trafficking
61
COUNT 66
(Firearms)
117. On or about December 8, 2011 through December 13,2011, in the District of South
Carolina, the Defendant, DAVID ALLEN PRYOR, alkla Yard Owl, knowingly did sell
and dispose of a firearm and ammunition, that is, a Ruger model P345D .45 caliber pistol
and .45 caliber ammunition, to an individual, knowing and having reasonable cause to
believe that the individual had been convicted of a crime punishable by imprisonment for
a term exceeding one year; in violation of Title 18, United States Code, Sections 922( d)
and 924(a)(2).
COUNT 67
(Firearms)
118. On or about December 8, 2011 through December 13, 2011, in the District of South
Carolina, the Defendant, DAVID ALLEN PRYOR, a/kla Yard Owl, knowingly did
transfer a firearm, that is, a Ruger model P345D .45 caliber pistol, knowing that the
firearm would be used in a crime of violence and a drug trafficking crime; in violation of
Title 18, United States Code, Section 924(h).
62
COUNT 68
(Firearms)
119. On or about December 9,2011, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/kJa Yard Owl, knowingly did sell and dispose of firearms and
ammunition, that is, a Maadi model RML .762 caliber rifle, a Mossberg model SOOA 12
gauge shotgun, and ammunition, to an individual, knowing and having reasonable cause
to believe that the individual had been convicted of a crime punishable by imprisonment
for a tenn exceeding one year; in violation of Title 18, United States Code, Sections
922(d) and 924(a)(2).
COUNT 69
(Firearms)
120. On or about December 9, 2011, in the District of South Carolina, the Defendant, DA YID
ALLEN PRYOR, a/kJa Yard Owl, knowingly did transfer fireanns, that is, a Maadi
model RML .762 caliber rifle and a Mossberg model SOOA l2-gauge shotgun, knowing
that the firearms would be used in a crime of violence and a drug trafficking crime; in
violation of Title 18, United States Code, Section 924(h).
63
COUNT 70
(Firearms)
121. On or about December 22, 2011, in the District of South Carolina, the Defendant,
DAVID ALLEN PRYOR, alk/a Yard Owl, knowingly did sell and dispose of a firearm
and ammunition, that is, a Bersa Thunder 380 model .380 caliber pistol and .380 caliber
924(a)(2).
COUNT 71
(Firearms)
THE GRAND mRY FURTHER CHARGES:
122. On or about December 22,2011, in the District of South Carolina, the Defendant,
DAVID ALLEN PRYOR, alk/a Yard Owl, knowingly did transfer a firearm, that is, a
Bersa Thunder 380 model .380 caliber pistol, knowing that the firearm would be used in a
Code, Section 924(h).
64
COUNT 72
(National Firearms Act)
123. On or about January 5, 2012, in the District of South Carolina, the Defendant, DAVID
CHANNING OILER, alkla Gravel Dave, knowingly possessed a fireann as defined by
Title 26, United States Code, Sections 5845(a)(7), to wit, a silencer as defined in Title 18,
United States Code, Section 921, not registered to him in the National Firearms
Registration and Transfer Record; in violation of Title 26, United States Code, Sections
5861(d), 5845(a)(7), and 5871.
COUNT 73
(Firearms)
124. On or about January 16,2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/kla Yard Owl, knowingly did sell and dispose of firearms and
ammunition, that is, a Romann model WASR-1O/63KR 7.62 caliber rifle, a Romarm
model WASR-1O/63KR 7.62 caliber rifle, and 7.62 caliber ammunition, to an individual,
a crime punishable by imprisonment for a tenn exceeding one year; in violation of Title
18, United States Code, Sections 922(d) and 924(a)(2).
65
COUNT 74
(Firearms)
ALLEN PRYOR, a/kJa Yard Owl, knowingly did transfer fireanns, that is, a Romarm
model WASR-IO/63KR 7.62 caliber rifle and a Romann model WASR-10/63KR 7.62
caliber rifle, kllowing that the fireanns would be used in a crime of violence and a drug
trafficking crime; in violation of Title 18, United States Code, Section 924(h).
COUNT 75
(Firearms)
ALLEN PRYOR, alkJa Yard Owl, knowingly did sell and dispose offireanns and
ammunition, that is, a Intratec model TEC22 .22 caliber pistol, a Romann model Draco
7.62 caliber pistol, a Romann model MlO-762 7.62 caliber rifle, and 7.62 caliber
924(a)(2).
66
COUNT 76
(Firearms)
ALLEN PRYOR, alkla Yard Owl, knowingly did transfer firearms, that is, a Intratec
model TEC22 .22 caliber pistol, a Romarm model Draco 7.62 caliber pistol, and a
Romarm model MlO-762 7.62 caliber rifle, knowing that the firearm would be used in a
COUNT 77
(Firearms)
128. On or about January 20, 2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, alkla Yard Owl, knowingly did sell and dispose of a firearm, that is,
a Romarm model W ASR-1 0/63KR 7.62 caliber rifle, to an individual, knowing and
United States Code, Sections 922(d) and 924(a)(2).
67
COUNT 78
(Firearms)
ALLEN PRYOR, a/kIa Yard Owl, knowingly did transfer a firearm, that is, a Romarm
model W ASR-I0/63KR 7.62 caliber rifle, knowing that the firearm would be used in a
COUNT 79
(Firearms)
130. On or about February 8, 2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/kIa Yard Owl, knowingly did sell and dispose of firearms and
ammunition, that is, a Beretta model 21 A .22 caliber pistol, an Intratec model TECDC9
9mm pistol, a Professional Ordinance Carbon 15 model .223 caliber rifle, a Norinco SKS
Sporter model 7.62 caliber rifle, a HiPoint model 995 9mm rifle, a Norinco model SKS
7.62 caliber rifle, a Norinco model SKS 7.62 caliber rifle, a Norinco model SKS 7.62
caliber rifle, .22 caliber ammunition, and .223 ammunition, to an individual, knowing and
United States Code, Sections 922(d) and 924(a)(2).
68
COUNT 80
(Firearms)
131. On or about February 8, 2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/k/a Yard Owl, knowingly did transfer firearms, that is, a Beretta
model 21 A .22 caliber pistol, an Intratec model TECDC9 9mm pistol, a Professional
Ordinance Carbon 15 model .223 caliber rifle, a Norinco SKS Sporter model 7.62 caliber
rifle, a HiPoint model 995 9mm rifle, a Norinco model SKS 7.62 caliber rifle, a Norinco
model SKS 7.62 caliber rifle, and a Norinco model SKS 7.62 caliber rifle, knowing that
the firearms would be used in a crime of violence and a drug trafficking crime; in
violation of Title 18, United States Code, Section 924(h) ..
COUNT 81
(Firearms)
132. On or about March 6, 2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, alk/a Yard Owl, knowingly did sell and dispose of firearms and
ammunition, that is, a Palmetto State Armory model P A -15 .223 caliber rifle, an FIE
Model D38 .38 caliber derringer, .223 ammunition, and .38 caliber ammunition, to an
individual, knowing and having reasonable cause to believe that the individual had been
convicted of a crime punishable by imprisonment for a term exceeding one year; in
violation of Title 18, United States Code, Sections 922(d) and 924(a)(2).
69
COUNT 82
(Firearms)
133. On or about March 6, 2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/k/a Yard Owl, knowingly did transfer firearms, that is, a Palmetto
State Armory model PA-15 .223 caliber rifle and an FIE Model D38 .38 caliber derringer,
knowing that the firearms would be used in a crime of violence and a drug trafficking
COUNT 83
(Firearms)
134. On or about March 19,2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, a/k/a Yard Owl, knowingly did sell and dispose of a firearm and
ammunition, that is, a Jimenez Arms model JA380 .380 caliber pistol and .380 caliber
924(a)(2).
70
COUNT 84
(Firearms)
135. On or about March 19,2012, in the District of South Carolina, the Defendant, DAVID
ALLEN PRYOR, alkla Yard Owl, knowingly did transfer a firearm, that is, a Jimenez
Arms model JA380 .380 caliber pistol, mowing that the firearm would be used in a crime
of violence and a drug trafficking crime; in violation of Title 18, United States Code,
Section 924(h).
COUNT 85
(Firearms)
THOMAS MCMANUS PLYLER, alk/a Uncle Tom, knowingly did sell and dispose of
a firearm, that is, a Smith and Wesson Model 10 .38 caliber revolver, to an individual,
a crime punishable by imprisonment for a term exceeding one year; in violation of Title
18, United States Code, Sections 922(d) and 924(a)(2).
71
COUNT 86
(Firearms)
137. On or about October 11,2011, in the District of South Carolina, the Defendants,
THOMAS MCMANUS PLYLER, alkla Uncle Tom, and JAMIE HOBBS LONG,
knowingly did sell and dispose of firearms, that is, a Remington model 870 Express 12
gauge shotgun and a Smith and Wesson Model SW 40VE .40 caliber pistol, to an
. individual, knowing and having reasonable cause to believe that the individual had been
convicted ofa crime punishable by imprisonment for a term exceeding one year; in
violation of Title 18, United States Code, Sections 922(d), 924(a)(2), and 2.
COUNT 87
(Firearms)
138. On or about October 18,2011, in the District of South Carolina, the Defendant,
THOMAS MCMANUS PLYLER, a/kla Uncle Tom, knowingly did sell and dispose of
a firearm, that is, a Ruger Mark III 22 pistol, to an individual, knowing and having
reasonable cause to believe that the individual had been convicted of a crime punishable
by imprisonment for a term exceeding one year; in violation of Title 18, United States
Code, Sections 922(d) and 924(a)(2).
72
COUNT 88
(Firearms)
139. On or about October 18,2011, in the District of South Carolina, the Defendant,
THOMAS MCMANUS PLYLER, a/kJa Uncle Tom, knowingly did transfer a firearm,
that is, a Ruger Mark III 22 pistol, knowing that the firearm would be used in a crime of
violence and a drug trafficking crime; in violation of Title 18, United States Code,
Section 924(h).
COUNTS 89 -91
(Felon in Possession)
140. That on or about the dates listed below, in the District of South Carolina, the Defendant,
DANIEL EUGENE BIFIELD, a/kJa Diamond Dan, having been convicted of a crime
punishable by imprisonment for a term exceeding one year, knowingly did possess in and
affecting commerce, the firearms and ammunition listed below, all of which had been
shipped and transported in interstate commerce:
DATE FIREARM & AMMUNITION
89 April 28, 2011
Ruger model LCR .38 caliber revolver and .38 caliber
ammunition
90 June 14,2011 Taurus .38 Special revolvers
91 July 21, 2011 Keltec model P32 .32 caliber pistol
All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2), and
924(e).
73
L
FORFEITURE ALLEGAnONS
RACKETEERING:
A. The allegations of Counts 1 and 2 of this indictment are hereby repeated,
realleged, and incorporated by reference herein. Pursuant to Title 18, United States Code,
Section 1963(a), upon conviction of the offenses set forth in Count 1 and Count 2, the
Defendants, DANIEL EUGENE BIFIELD, alkla Diamond Dan; MARK WILLIAM
BAKER, aIkIa Lightning; DAVID CHANNING OILER, aIkIa Gravel Dave;
BRUCE JAMES LONG, alkla Bruce-Bruce; RICHARD THROWER, aIkIa Little
Mark, alk/a Rat; DAVID ALLEN PRYOR, a/kla Yard Owl; JAMES FREDERICK
KEACH, JR, aIkIa Big Fred; FRANK ENRIQUEZ, JR., alk/a Big Frank; DONALD
BOERSMA, alkla Brooklyn Don, alkla Brooklyn Donnie; LISA ELLEN BIFIELD,
aIkIa Lisa Ellen Meyers, aIkIa Lisa Ellen Stockton; and JOHANNA LOOPER, aIkIa
JoJo, shall forfeit to the United States the following property:
(1) Any interest acquired or maintained in violation of Section 1962, which
interests are subject to forfeiture to the United States pursuant to Title 18, United
States Code, Section 1963(a)(I);
(2) Any interest in, security of, claim against, or property or contractual rights
of any kind affording a source over the Enterprise described in Count
1 which was established, operated, controlled, conducted and or participated in the
conduct of, in violation of section 1962; which interests are subject to forfeiture to
the United States pursuant to Title 18, United States Code, Section 1963( a)(2);
and
(3) Any property constituting or derived from proceeds obtained directly and
indirectly from racketeering activity in violation of Title 18, United States Code,
Section 1962, which interests are subject to forfeiture to the United States
pursuant to Title 18, United States Code, Section 1963(a)(3);
74
B. The interests of the defendants subject to forfeiture to the United States pursuant
to Title 18, United States Code Section 1963(a)(1); (a)(2), and (a)(3) include, but is not
limited to the following which the defendants are jointly and severally liable:
(1) Proceeds:
(a) at least $300,000
(2) Vehicles (including Motorcycles)
(a) 1997 Harley Davidson Motorcycle, VIN IHDIDDLI8VY613978,
registered to DAVID CHANNING OILER
(b) 2008 Harley Davidson Motorcycle, VIN IHDIFS4168Y674649,
registered to MARK WILLIAM BAKER
(c) 2009 Harley Davidson Motorcycle, VIN IHDIPX8199K97661O,
registered to DANIEL EUGENE BIFIELD
(d) 2006 Harley Davidson Motorcycle, VIN 1HD1KBWIX6Y616856,
registered to BRUCE JAMES LONG
(e) 2004 Harley Davidson Motorcycle, VIN 1HD1GKV194K311965,
registered to ROBERT DAVID PRYOR
(f) 2008 Harley Davidson Motorcycle, VIN 1HD1FC4148Y664661,
registered to JAMES FREDRICK KEACH, JR
(g) 1986 Harley Davidson Motorcycle, VIN 1HD1EHL17GY122342,
registered to RICHARD THROWER
(h) 2007 Harley Davidson Motorcycle, VIN IHDIFV4187Y611407,
registered to FRANK ENRIQUEZ, JR.
(i) 2000 Harley Davidson Motorcycle, VIN IHDIPAC66YY951191,
registered to DONALD BOERSMA
(3) Accounts
(a) Bank of America, Account # 223006385043 (BRUCE JAMES
LONG)
(b) Wachovia, Account # 1008882001231 (DAVID CHANNING
OILER)
75
(c) ArrowPointe Federal Credit Union, Account Number
428008251462 (RICHARD THROWER)
(d) Wachovia, Account Number 1010173121423 (MARK WILLIAM
BAKER)
(4) Real Property
(a) 4542 Doby Bridge Road, Fort Mill, South Carolina 29707
Titled in the name of: God's Few MC, Inc.
Parcel Number 0013-00-001.00
II. DRUG-TRAFFICKlNG OFFENSES:
A. Upon conviction for one or more felony violations of Title 21, United States
Code, Sections 841(a)(l) and 846, as charged in this Indictment, the Defendants,
DANIEL EUGENE BIFIELD, a/kIa Diamond Dan; MARK WILLIAM BAKER,
alkla Lightning; DAVID CHANNING OILER, a/kIa Gravel Dave; BRUCE JAMES
LONG, alkla Bruce-Bruce; RICHARD THROWER, alkla Little Mark, a/kla Rat;
DAVID ALLEN PRYOR, alkla Yard Owl; FREDERICK KEACH, JR, a/kIa Big
Fred; FRANK ENRIQUEZ, JR., alkla Big Frank; DONALD BOERSMA, a/kla
Brooklyn Don, alkla Brooklyn Donnie; LISA ELLEN BIFIELD, alkla Lisa Ellen
Meyers, alkla Lisa Ellen Stockton; JOHANNA LOOPER, alkla JoJo; KERRY
CHITWOOD; RONALD DEAN BYRUM, JR, a/kIa Big Ron; and TRENT ALLEN
BROWN, shall forfeit to the United States all of the Defendant's right, title and interest
in and to any property real and personal,
(1) constituting, or derived from any proceeds the Defendants obtained,
directly or indirectly, as the result of such violations, and all property
traceable thereto;
(2) used or intended to be used, in any manner or part, to commit or to
facilitate the commission of such violations; and,
76
(3) any firearm and ammunition (as defined in 18 U.S.C. 921) used or
intended to be used to facilitate the transportation, sale, receipt, possession
or concealment of controlled substances or any proceeds traceable thereto.
B. The property subject to forfeiture includes, but is not limited to, the following:
(I) Proceeds:
(a) A sum of money equal to all property the Defendants obtained as a
result of the drug offenses charged in the Indictment, that is a
minimum of$150,000 in United States currency, and all interest
and proceeds traceable thereto, for which the defendants are jointly
and severally liable.
(2) Vehicle
(a) 2012 Ford F250, VIN IFT7W2BT7CEA90805 (owned by TRENT
ALLEN BROWN)
III. MONEY LAUNDERING OFFENSES:
A. Upon conviction of one or more violations of Title 18, United States Code, Section
1956 (money laundering), as charged in this Indictment, the Defendants, DANIEL
EUGENE BIFIELD, alkla Diamond Dan; MARK WILLIAM BAKER, alkla
Lightning; DAVID CHANNING OILER, alkla Gravel Dave; BRUCE JAMES
LONG, aIkIa Bruce-Bruce; RICHARD THROWER, alkla Little Mark, alkla Rat;
LISA ELLEN BIFIELD, a/kla Lisa Ellen Meyers, alkla Lisa Ellen Stockton; and
JAMES RHODUS, alkla Sonny, shall forfeit to the United States, pursuant to Title 18,
United States Code, Sections 981(a)(l)(C), 982(a)(6) and Title 28, United States Code,
Section 2461 (c), any property, real or personal, which is involved in such violation or
which constitutes or is derived from proceeds traceable to such property.
B. The property subject to forfeiture includes, but is not limited to, the following:
(1) Proceeds:
77
(a) A minimum of approximately $143,000 in United States currency,
and all interest and proceeds traceable thereto, in that such sum
equals all property involved in the 1956 money laundering or
property traceable to the specified unlawful activity that the
Defendants obtained, directly or indirectly, as the result of their
violations of 18 U .S.C. 1956.
(2) Bank Accounts Utilized
(a) Bank of America, Account # 223006385043 (BRUCE JAMES
LONG)
(b) Wachovia, Account # 1008882001231 (DAVID CHANNING
OILER)
(c) Wachovia, Account Number 1010130101033 (JAMES RHODUS)
(d) ArrowPointe Federal Credit Union, Account Number
428008251462 (RICHARD THROWER)
(e) Wachovia, Account Number 1010173121423 (MARK WILLIAM
BAKER)
IV. If any of the property described above as being subject to forfeiture, as a result of any act
or omission ofthe Defendants-
A. Cannot be located upon the exercise of due diligence;
B. Has been transferred or sold to, or deposited with, a third person;
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
subdivided without difficulty;
it is the intention of the United States, pursuant to Title 18, United States Code, Section 1963(m)
and 982(b)(1), incorporating Title 21, United States Code, Section 853(P), to seek forfeiture of
any other property ofthe Defendants up to the value of the forfeitable property;
78
Pursuant to Title 18, United States Code, Sections 1963(a), 981(a)(1)(C), 982, Title 21,
United States Code, Sections 853 and 881and Title 28, United States Code, Section 2461(c).
79
BILL
Om)
UN1TED STATES ATTORNEY
80

SC Hells Angels Indictment of May 17, 2012

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SC Hells Angels Indictment of May 17, 2012

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IN THE UNITED STATES DISTRICT COURT

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