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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA
v. D-1 ANTONIO CLARK, alkla "Cheeto (^) I" D-2 ARAMIS WILSON, alkla "Ace" D-3 TYRONE PRICE, a/kla "Price (^) I" D-4 JONATHAN KINCHEN, alkla "Deago," D-5 KOJUAN LEE, a/kla "Juan," D-6 KIRSHEAN NELSON, D-7 DION ROBINSON, alkla "Doggy,"
INDICTMENT
THE GRAND JURY CHARGES:
COUNT ONE
Case:2: 15-cr-20472Judge: Edmunds, Nancy G. MJ: Majzoub, Mona Filed: 07-29-2015 At K. 04:32PM INDI USA V. SEALED MATTER (DA)
18 U.S.C. § 1959(a)(5);
18 U.S.C. § 1959(a)(3);
18 U.S.C. § 924(c);
18 U.S.C. § 922(g); 18 U.S.C. § 2
18 U.S.C. §§ 1959(a)(5)- Attempted Murder in Aid of Racketeering
D-1 ANTONIO CLARK
D-2 ARAMIS WILSON
The Enterprise
- The Almighty Vice Lord Nation, commonly referred to as the "Vice Lords" (hereinafter referred to as the "Vice Lords"), is a national gang founded in Chicago, Illinois. There are various "sets," "decks," or
"branches" within the Vice Lords, which are expected to assist one another, collaborate with one another on criminal activities, and answer to the gang's leaders in Chicago, Illinois, and Detroit, Michigan. Some of these sets are the Insane Vice Lords, Imperial Insane Vice Lords, Traveling Vice Lords, Conservative Vice Lords, the Mafia Insane Vice Lords, and the Insane Goon Gang.
- The Vice Lords have a hierarchical chain of command. There are "kings" and "princes" that rule the Vice Lords. In particular locations, "universal elites" run the particular sets within an area or city. These universal elites are ranked as five-star (highest), three-star, and one-star. There are "enforcers" who enact the orders of the universal elite by directing "lieutenants" to maintain discipline within a particular branch by administering. beatings or fines. Other Vice Lord members are known as "soldiers" or "foot soldiers." Vice Lords must follow the orders of their leaders. These orders from Vice Lord leaders include, but are not limited to, retaliation against rival gangs, orders to assault other gang members, armed robberies, and other crimes and acts of violence.
- The Vice Lords utilize a variety of unifying marks, manners, and identifiers, including "gang signs," clothing, and tattoos that are specific to the organization. A common symbol is the five-pointed star which
attendance at meetings, the payment of dues, and assisting fellow members in crimes and acts of violence, if so ordered. The organization imposes punishment upon members, generally referred to as "violations," including beatings, for violations of these rules.
- Vice Lords are prohibited from speaking to outsiders about the Vice Lords or from cooperating with law enforcement authorities. Engaging in such activity would result in a violation, meaning physical injury or death. Attempts to leave or withdraw from the Vice Lords oftentimes results in a "beat out," a physical beating by multiple Vice Lords members, or a "green light,'' an order to kill. The incident on May 7, 2015, as further described in Counts One - Eight, resulted from V.T. and S.T.'s attempts to leave the Traveling Vice Lord set.
- The Vice Lords share close relationships with the Phantom Outlaw Motorcycle Club (hereinafter referred to as the "Phantoms"), including sharing common leaders in the Eastern District of Michigan. Multiple Vice Lords members are also Phantoms members. Among other things, Vice Lords and Phantoms share common identification marks on their clothing and other paraphernalia. At least one shared leader between the Vice Lords and Phantoms called upon and utilized the services of the Vice Lords to further the goals of the Phantoms and achieve its purposes,
including by using the Vice Lords to enforce discipline within the Phantoms, to search for rivals of the Phantoms, and to carry out acts of violence on the Phantoms' behalf. The same shared leader between the two organizations used the Phantoms to advance the interests of the Vice Lords, and vice versa, including the use of one organization to attack the rival of another. Also, the same shared leader between the two organizations held Vice Lord meetings and conducted Vice Lord business at the Phantoms' clubhouse in Detroit, Michigan. Members of the Phantoms attended Vice Lord meetings, and vice versa.
- Although falling under the Almighty Vice Lord Nation, disputes and rivalries do arise between some of the respective branches, including recruitment of members between branches.
- At various times relevant to this Indictment, ANTONIO CLARK, ARAMIS WILSON, TYRONE PRICE, JONATHAN KINCHEN, KOJUAN LEE, KIRSHEAN NELSON, DION ROBINSON, and others, were members and associates of the Vice Lords, a criminal organization whose members and associates engaged in acts of violence, including conspiracy to commit murder and attempted murder, robbery, narcotics trafficking, and witness intimidation, and which operated principally in Detroit, Michigan.
- 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. Members of the enterprise and their associates committed, conspired, attempted and threatened to commit acts of violence including acts involving murder, robbery, and assaults with dangerous weapons, to protect and expand the enterprise's criminal operations. b. Members of the enterprise and their associates promoted a climate of fear through violence and threats of violence. c. Members of the enterprise and their associates used and threatened to use physical violence against various individuals. d. Members of the enterprise and their associates distributed controlled substances. e. Members of the enterprise and their associates committed armed robberies.
- The Vice Lords enterprise, through its members and associates, engaged in racketeering activity as defined by Sections 1959(b)(1) and 1961(1) of Title 18, United States Code, namely acts involving murder and robbery in violation of Michigan State Law, acts
involving dealing in controlled substances indictable under 21 U.S .C. §§
841 and 846, and acts indictable under 18 U.S.C. § 1512 (witness intimidation).
- On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, ANTONIO CLARK and ARAMIS WILSON, did, for the purpose of maintaining and increasing position in the Vice Lords, an enterprise engaged in racketeering activity, knowingly and unlawfully attempt to murder V.T.; in violation of Michigan Compiled Laws, Sections 750.316(1) and 750.92. All in violation of Title 18, United States Code, Section 1959(a)(5). COUNT TWO 18 U.S. C.§§ 1959(a)(3); 2- Assault with a Dangerous Weapon in Aid of Racketeering D-1 ANTONIO CLARK D-2 ARAMIS WILSON D-3 TYRONE PRICE D-4 JONATHAN KINCHEN D-5 KOJUAN LEE D-6 KIRSHEAN NELSON D-7 DION ROBINSON
- Paragraphs One -Thirteen of Count One are re-alleged herein as if fully incorporated in this Count.
- On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, ANTONIO CLARK, ARAMIS WILSON, TYRONE PRICE, JONATHAN KINCHEN, KOJUAN LEE, KIRSHEAN NELSON,
COUNT FOUR 18 U.S. C.§§ 1959(a)(3); 2- Assault with a Dangerous Weapon in Aid of Racketeering D-1 ANTONIO CLARK D-2 ARAMIS WILSON D-3 TYRONE PRICE D-4 JONATHAN KINCHEN D-5 KOJUAN LEE D-6 KIRSHEAN NELSON D-7 DION ROBINSON
- Paragraphs One - Thirteen of Count One are re-alleged herein as if fully incorporated in this Count.
- On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, ANTONIO CLARK, ARAMIS WILSON, TYRONE PRICE, JONATHAN KINCHEN, KOJUAN LEE, KIRSHEAN NELSON, DION ROBINSON, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the Vice Lords, an enterprise engaged in racketeering activity, knowingly and unlawfully assault T.T.-1 with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and 2.
COUNT FIVE
18 U.S. C.§§ 1959(a)(3); 2- Assault with a Dangerous Weapon in Aid of Racketeering D-1 ANTONIO CLARK D-2 ARAMIS WILSON D-3 TYRONE PRICE D-4 JONATHAN KINCHEN D-5 KOJUAN LEE D-6 KIRSHEAN NELSON D-7 DION ROBINSON
- Paragraphs One -Thirteen of Count One are re-alleged herein as if fully incorporated in this Count.
- On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, ANTONIO CLARK, ARAMIS WILSON, TYRONE PRICE, JONATHAN KINCHEN, KOJUAN LEE, KIRSHEAN NELSON, DION ROBINSON, and others, known and unknown to the grand jury, aided and abetted by each other and others known and unknown to the grand jury, did, for the purpose of maintaining and increasing position in the Vice Lords, an enterprise engaged in racketeering activity, knowingly and unlawfully assault S.T. with a dangerous weapon; in violation of Michigan Compiled Laws, Sections 750.82 and 767.39. All in violation of Title 18, United States Code, Sections 1959(a)(3) and 2.
. COUNT SEVEN
18 U.S. C.§§ 924(c); 2- Use and Carry of a Firearm During, and in
Relation to, a Crime of Violence
D-1 ANTONIO CLARK
D-2 ARAMIS WILSON
On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, and elsewhere, ANTONIO CLARK and ARAMIS WILSON, did aid and abet each other in knowingly, intentionally, and unlawfully using and carrying a firearm during and in relation to a crime of violence for which they may be prosecuted in a court of the United States, that is, attempted murder in aid of racketeering, as alleged in Counts One and Three, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(c) and 2.
COUNT EIGHT
18 U.S.C. §§ 924(c); 2- Use and Carry of a Firearm During, and in Relation to, a Crime of Violence D-1 ANTONIO CLARK D-2 ARAMIS WILSON D-3 TYRONE PRICE D-4 JONATHAN KINCHEN D-5 KOJUAN LEE D-6 KIRSHEAN NELSON D-7 DION ROBINSON
On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, and elsewhere, ANTONIO CLARK, ARAMIS WILSON, TYRONE PRICE, JONATHAN KINCHEN, KOJUAN LEE, KIRSHEAN NELSON, DION ROBINSON, and others, known and unknown to the Grand Jury, did aid and abet each other in knowingly, intentionally, and unlawfully using and carrying a firearm during and in relation to a crime of violence for which they may be prosecuted in^ a court of the United States, that is, assault with a dangerous weapon in aid of racketeering, as alleged in Count Two and Counts Four - Six, and said firearm was discharged, in violation of Title 18, United States Code, Sections 924(c) and 2. COUNT NINE
18 U.S.C. § 922(g)(1)- Felon in Possession of a Firearm
D-1 ANTONIO CLARK
D-2 ARAMIS WILSON
On or about May 7, 2015, in the Eastern District of Michigan, Southern Division, defendant ANTONIO CLARK and ARAMIS WILSON, after having previously been convicted of at least one crime punishable by imprisonment for a term exceeding one year (felony offense), did knowingly and unlawfully possess a firearm, said firearm having previously traveled in
Case:2: 15-cr- United States District CourtEastern District of Michigan Criminal Case C< Judge: Edmunds, NancyMJ: Majzoub, Mona K.^ G. Filed: INDI USA 07-29-2015 V. SEALED At 04: MA32PMITER (DA) NOTE: It is the responsibility of the Assistant U.S. Attorney signing this form to co ... ,...ww .• ----· -·-·• ... ___. __,... .. This matter was opened in the USAO prior to August 15, 2008 [ ] Companion Case Number: 13-cr- This may be a companion case based upon LCrR 57.10 (b)(4) 1 : (^) Judge Assigned: Borman Yes (^) No AUSA's Initials: Case Title: USA v. Antonio Clark ~~~~~~~~-------------------------------- et al. County where offense occurred: Wayne County and Elsewhere Check One: (^) [81 Felony D Misdemeanor 0Petty {lndictment/ lndictment/______ lnformation ---lnformation --- (^) based upon prior complaintno prior complaint. [Case number : ___ lndictment/ ___ lnformation --- based upon LCrR 57.10 (d) [Complete Superseding section below].
Superseding to Case No: ----------------------------- Judge:
D D Corrects errors; no additional charges or defendants.Original case was terminated; no additional charges or defendants.
BInvolves,Embraces same subject matter but adds the additional defendants or charges below:^ for^ plea^ purposes, different charges or adds counts.
Defendant name Charges Prior^ Complaint^ (if^ applicable) See Attachment
Please take noticethe above captioned case. that the below listed Assistant United States Attorney is the attorney of record for July 29, 2015 Date (^) Assistant UnitedChnstopher Graveline States Attorney (^211) Detroit, W. Fort Street,Ml 48226-3277 Suite 2001 Phone: 313-226-9155Fax: 313-226- E-Mail address: [email protected] Bar#: P ' Companion cases are matterssame transaction or occurrence. Cases may in which it appears that be companion cases (1) substantia l evenly though one of them may havesimilar evidence will be offered al at ready trial , been terminated. (2) the same or related parties are present. and the cases arise out of the04/
UNITED STATES DISTRICT COURT EASTERN SOUTHERN DISTRICT DIVISION OF MICHIGAN UNITED STATES OF AMERICA (^) NO. v. D-1 (^) ANTONIO CLARK, D-2^ alkfa^ "Cheeto," ARAMIS WILSON, alkfa "Ace" D-3 (^) TYRONE PRICE, alkfa "Price (^) I" 0-4 (^) JONATHAN KINCHEN, alkfa "Deago," D-5 (^) KOJUAN LEE, alkfa "Juan," D-6 KIRSHEAN NELSON, D-7 DION -ROBINSON, alkfa "Doggy," I
HON.
18 U.S.C. § 1959(a)(5);
18 U.S.C. § 1959(a)(3);
18 U.S.C. § 924(c);
1818 U.S.C.U.S.C. §§ 922(g); 2
