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· .......•, , Case: 4:11-cr-00246-CDP -FRB..... , Doc. #: 2 Filed: 06/09/11 ··.,····Page: 1 of 40 PageID #: 60 .. ·1 , ... I
UNITED STATES DISTRlCT COURT EASTERN DISTRlCT OF MISSOURlEASTERN DMSION
EASTERN.U.^ S.^ DISTRICT WSTRICI^ COURll llli MIJ
SUPPRESSE 'EICE ~ JUN 09 201l
Count I Counts I, IX, XIV, XV, XVII Counts I, VIII CountsCounts-I, II, Ill, VII I, II, Ill, XIV Counts I, IVCounts I, IX Counts I, IX, X CountsCounts I,I, XIX Counts I, XII, XIII, XVI, XVII CountsCounts I,I, XIVXI, XIV Counts I, XIV
Counts I, XV
CountsCounts I,I, XIVV
Counts I, VI
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4
Plaintiff,
Defendants.
v.
UNITED STATES OF AMERlCA,
JAMES C. SMITII, a/k/a "Animal,"ALLAN HUNTER, a/k/a "Dog," FREDERlCK MORGAN, a/k/a "Low Rider," DOMINIC HENLEY, alk/a "Bishop,"TIMOTIIY BALLE, a/k/a "T," LAWRENCE PINKSTON, a/k/a "Pac," MAURICE THOMAS,BRYANT PALMER, a/k/a "Dot," TONEY SIMS, a/k/a "Big T," "Tone,"
ANTHONY ROBINSON, a/k/a "Blade,"THOMAS BAILEY a/k/a,^ "Que",^ "Q-Ball ",
JERRY ELKINS, a/k/a "Shakka," "Shaca," MARSHALL FRY, a/k/a "Bo," "Big Bo," RASHEED JAMAL BRANDON,a/k/a "Diamond," CARLYLE FLEMING, _WALTER LEE, a/k/a "Lil Dude," a/k/a "Thundercat," "Jermaine Fleming," CARLOS WESLEY ROSE, SR., and alk/a "Pit Bull," NORMAN VICK, a/k/a "Justice,"
INDICTMENT
The Grand Jury charges:
INTRODUCTION
The Racketeering Enterprise
- At all times relevant to the Indictment, in the Eastern District of Missouri and elsewhere, the Defendants, . ~ ; (^) .. ", I " ,^ .,^.^ ,.^1 •••••^ '.
UNITEDEASTERN STATES DISTRlCT DISTRlCT OF MISSOURI COURT
EASTERN DMSION
JUN 0 9 2011 ~STER~^ U.^ S.^ DISTRICT DISTRIGI^ COURlj D~ IIlI
Counts I, XIV
Counts I, V
CountCounts 1 I, IX, XIV, XV, XVII
Counts Counts ~~ VIUII, III, XIV
Counts·~ ~ III, vn
Counts Counts ~~ IVIX
Counts I, IX, X
Counts I, X
Counts r, IX Counts r, XlI, XllI. XVI, xvn
Counts Counts T, T. XIV Xl, XlV
Counts I, XIV
Counts I, XV
Counts T, VI
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4
Plaintiff,
Defendants.
v.
UNITEDSTATESOF~C~
JAMES C. SMIlli, aIkIa "Animal,"
ALLAN HUNTER, aIkIa "Dog,"
FREDERJCK MORGAN, aIkIa "Low Rider,"
TIMOTHYDOMINIC^ HENLEY, BALLE, aIkIa^ aIkIa "T,"^ "Bisbop,"
LAWRENCEMAURICE mOMAS, PINKSTON, aIkIa "Pac,"
BRYANT PALMER, aIkIa "Dot,"
TONEYTHOMAS SIMS, BAILEY, alkJa "BigalkJa T,""Que," "Tone." "Q-Ball,"
ANmONY ROBINSON, aIkIa "Blade,"
JERRY MARSHALL ELKINS, FRY, aIkIa alkJa "Sbakka," "Bo:' "Big "Sbaca," Bo,"
RASHEED alkJa JAMAL "Diamond," BRANDON,
WALTER LEE, aIkIa "Lil Dude,"
CARLYLE alkJa FLEMING, "Thundercat,". "Jermaine Fleming,"
CARLOS alkJa WESLEY "Pit Bull," ROSE, SR.,
and NORMAN VrCK, a/kIa "Justice,"
INDICTMENT
The Grand Jury charges:
INTRODUCTION
The Racketeerine: Enterprise
1. At all times relevant to the Indicbnent, in the Eastern District of Missouri and
elsewhere, the Defendants,
I :' ,^.^ •^ -."^ ~^ t^ •^ I^ "...^ '-
UNITED STATES DISTRlCT COURT
EASTERN DISTRlCTEASTERN DMSION OF MISSOURI^ JUN^ 0 9^2011
fASTERK^ U.^ S.^ DISTRICT DISTRICl^ COURli 06 MlI
Counts I, XV
Count!
Counts I, IX, XlV, XV, XVlJ
Counts I, vm Counts ~ II, m, XlV Counts·~Counts I, II,IV m, VII
Counts ~ IX
Counts r, IX. X
CountsCounts I,I, XIX
Counts I, XII, xm, ~ XVlJ
Counts^ Counts^ r, I,^ XlV XJ, XlV
Couots I, XlV
Counts I, XlV
Counts I, V
Counts I, VI
: lil~300 246COP )
4
Plaintifl;
Defendants.
Y.
UNITED STATES OF AMERICA,
JAMES C. SMITH, aIkIa 'Animal,"
ALLANFREDERICK MORGAN, HUNTER, aIkIa "Dng," aIkIa 'Low Rider:
DOMINIC HENLEY, aIkIa 'Bishop:
TIMOlllY BALLE, LAWRENCE PINKSTON, aIkIa 'T: aIkIa "Pac,"
MAURlCE lllOMAS,
BRYANT PALMER, aIkIa "Dot,"
TONEY THOMAS BAlLEY, SIMS, alkJa aJk/a"Big T,""Que," "Tooe," hQ_Ball,"
ANTHONY ROBINSON,JERRY ELKINS, aIkIa "Sbakka," "Shaca,' aIkIa "Blade,"
MARSHALL FRY, aJk/a ".&:' "Big Bo,"
RASHEED alkJa JAMAL BRANDON, "Diamond,"
WALTER LEE, aIkIa "Lit Dude,"
CARLYLE a/kJa FLEMING, "Thundercat,". "Jermaine Fleming,"
CARLOS a/k/a WESLEY ROSE, SR., "Pit Bull,"
and
NORMAN VrCK. a/k/a "Justice,"
!NDICfMENT
The Grand Jury charges:
INTRODUcnON
The Racketeerine: Enterprise
1. At aJl times relevant to the lndicbnent, in the Eastern District of Missouri and
elsewhere, tbe Defendants,
Case: 4:11-cr-00246-CDP -FRB Doc. #: 2 Filed: 06/09/11 Page: 2 of 40 PageID #: 61
· I .... ........^ ·····
JAMES C. SMITH, a/kJa "Animal," FREDERICK MORGAN,ALLAN HUNTER, alkla "Dog," a/kJa "Low Rider," DOMINIC HENLEY, alkla "Bishop,"TIMOTHY BALLE, a/kJa "T," LAWRENCE PINKSTON, alkla "Pac," BRYANT PALMER,MAURICE THOMAS, a/kJa "Dot," THOMAS BAILEY,TONEY SIMS,^ a/kJa a/kJa^ "Big T," "Tone," "Que," "Q-Ball," ANTHONY ROBINSON, a/kJa "Blade," JERRY ELKINS,MARSHALL FRY, a1k/a a1k1a "Shakka," "Shaca," "Bo," "Big Bo," RASHEED JAMAL BRANDON, a/kJa "Diamond," CARLYLE FLEMING,WALTER a1kJa^ LEE, alkla "Lil Dude, " "Thundercat," "Jermaine Fleming," CARLOS (^) NORMANWESLEY ROSE,VICK, SR,a/kJa alkla "Pit Bull," and "Justice,"
and others, were members and associates of the Wheels of Soul, also mown as "was," a criminal organization that was engaged in and has engaged in acts of violence, including murder, attempted murder, robbery, and assault with a deadly weapon, and also engaged in the distribution of controlled substances, specifically cocaine base ("crack"), and extortion. The Wheels of Soul, including its leadership, members, and associates, constitutes an "enterprise" as defmed by Title 18, United States Code, Section 1961(4), that is, a group of individuals associated-in-fact. The Wheels of Soul enterprise constitutes an ongoing organization whose members function as a continuing unit for a common purpose of achieving the objectives of the enterprise, which was engaged in, and the activities of which affected, interstate commerce. Purposes of the Enterprise
- The purposes of the enterprise include the following: a. Promoting and enhancing the prestige, reputation and position of the enterprise with respect to rival criminal organizations;
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JAMESALLAN HUNTER, alk/a "Dog," C. SMITH, alkJa "Animal,"
FREDERICK MORGAN, alkJa "Low Rider,"
DOMINIC HENLEY, alk/a "Bishop,'
LAWRENCE PINKSTON, alk/a "Pac,"TIMOTHY BALLE, alk/a "T,"
BRYANT PALMER, alk/a "Dot,"MAURICE THOMAS,
THOMAS BAILEY, alk/a "Que,TONEY SIMS, alkJa "Big T," "Tone,"I' "Q-Ball,"
ANTHONY ROBINSON, alk/a "Blade,"
.JERRY ELKINS, alk/a "Shakka,I' "Shaca,"
RASHEED JAMAL BRANDON, alkJaMARSHALL FRY, a/k/a "Bo," "Big Bo," "Diam~Dd,"
. WALTER LEE, alk/a "Lil Dude, II
CARLYLE FLEMING, alkla "Thundercat," "Jermaine Fleming,"
CARLOS WESLEY ROSE,NORMAN VICK, alkJa "Justice," SR, alk/a "Pit Bull," and
and others, were members and associates of the 'Wheels of Soul, also known as "was," a criminal organization that was engaged in and has engaged in acts of Violence, including murder, attempted murder, robbery, and assault with a deadly weapon, and also engaged in the distribution of controlled substances, specifically cocaine base ("crack"), and extortion. The Wheels of Soul, including its leadership, members, and associates, constitutes an "enterprise" as defmed by Title 18, Umted States Code, Section 1961(4), that is, a group of individuals associated-in-fact. The Wheels of Soul enterprise constitutes an ongoing organization whose members function as a continuing unit for a common purpose of achieving the objectives of the enterprise, which was engaged in, and the activities of which affected, interstate corrunerce.
Purposes of the Enterprise
- The purposes of the enterprise include the following: a. Promoting and enhancing the prestige, reputation and position of the enterprise with respect to rival criminal organizations;
"'., I .•^ I^ i'
JAMESALLAN HUNTER, C. SMITH, a/kIa "Animal," aIkIa "Dog,"
FREDERICK MORGAN, a/kJa "Low Rider,"
DOMINIC HENLEY, alkla "Bishop,"TIMOTHY BALLE, aJkIa "T,"
LAWRENCE PINKSTON, alklaMAURICE THOMAS, "Pac,"
TONEY Sf.MS, a/kIa "Big T," "Tone,"BRYANT PALMER, afkJa "Dot,"
THOMAS BAILEY, a/kIa "Que," "Q_BaU,"
. JERRYANTHONY ROBINSON, aIkIa "Blade," ELKINS, afkla "Shakka," "Sbaca,"
MARSHALL FRY, aJkJa "Bo," "Big Bo,"
RASHEED WALTER JAMAL LEE, BRANDON, a/kIa aIkIa "Lil Dude, "Diam~nd," II
CARLYLE FLEMING, aJkla "Thundereat," "Jermaine Fleming,"
CARLOS WESLEY ROSE, SR, a/kla "Pit Bull," and
NORMAN VICK, aJk/a "Justice,"
and others, were members and associates of the Wheels of Soul, also Imown as "WOS," a
criminal organization that was engaged in and has engaged in acts of Violence, including murder,
attempted murder, robbery, and assault with a deadly weapon, and also engaged in the distribution of controlled substances, specifically cocaine base ("crack"), and extortion. The Wheels of Sow, including its leadership, members, and associates, constitutes. an "enterprise" as defined by Title 18, United States Code, Section 1961 (4), that is, a group of individuals associated·in-fact. The Wheels of Sou! enterprise constitutes an ongoing organization whose members function as a continuing unit for a common purpose of achieving the objectives of the enterprise, which was engaged in, and the activities of which affected, interstate commerce.
Purposes of the Enterprise
- The purposes of the enterprise include the following: a. Promoting and enhancing the prestige, reputation and position of the enterprise with respect to rival criminal organizations;
Case: 4:11-cr-00246-CDP -FRB--:'--1^ I' Doc. #: 2 Filed: 06/09/11 Page: 4 of 40 PageID #: 63I^ ,"."^ -^ -0-----,:-0-
groups share this collective designation, they are not typically aligned with each other. Rather, the various Outlaw Motorcycle Gangs maintain rivalries amongst each other, competing for prestige, territory, and national recognition. These rivalries are often fierce and commonly erupt in violence. WOS has variously feuded with other motorcycle clubs such as the Street Soldiers, Hells Lovers, and Outkast. The feud with Outkast has reached nationwide proportions and remains ongoing.
- Membership in the WOS is fonnal and organized. Membership is denoted by the wearing of a Wheels of Soul "patch," or "colors." The "colors" consist of a black vest adorned with several patches worn on the back. The patches consist of the name "Wheels of Soul" displayed on the top and bottom of the "wing and wheel" center patch. A patch displaying the name of the State where the member's chapter is located is displayed on the bottom of the vest. The front of the vest is used to designate the member's rank and/or status. Members commonly refer to the WOS collectively as "the Nation."
- A small percentage ofWOS members have achieved "1 %er" or "diamond" status. Members must earn the 1%'er diamond and/or have another diamond member vouch that they deserve a 1%' er diamond. Members who have a I %' er diamond patch are considered particularly criminal and violent. The term "one percenter," or "I %er" is a commonly utilized tenn within
the motorcycle club culture, meant to describe the one percent of motorcycle enthusiasts who
routinely engage in significant criminal activity. The manner in which the diamond patch is earned is prohibited as a topic of discussion among non-diamond members. Frequently, at regional and national gatherings, meetings are held for diamond members only. At these
meetings, club business pertaining to diamond members is discussed.
groups share this collective designation, they are not typically aligned with each other. Rather, the various Outlaw Motorcycle Gangs maintain rivalries amongst each other, competing for prestige, territory, and national recognition. These rivalries are often fierce and commonly erupt in violence. WOS has variously feuded with other motorcycle clubs such as the Street Soldiers, Hells Lovers, and Outkast. The feud with Outkast has reached nationwide proportions and remains ongoing.
5. Membership in the WOS is fonnal and organized. Membership is denoted by the
wearing of a Wheels of Soul "patch," ·or "colors." The "colors" consist of a black vest adorned with several patches worn on the back. The patches consist of the name "Wheels of Soul" displayed on the top and bottom of the "wing and wheel" center patch. A patch displaying the name of the State where the member's chapter is located is displayed on the bottom of the vest. The front of the vest is used to designate the member's rank and/or status. Members commonly refer to the WOS collecti vely as "the Nation."
- A small percentage ofWOS members have achieved "l%er" or "diamond" status. Members must earn the I%'er diamond and/or have another diamond member vouch that they deserve a 1%'er diamond. Members who have a 1%'er diamond patch are considered particularly criminal and violent. The term "one percenter," or "1 %er" is a commonly utilized term within the motorcycle club culture, meant to describe the one percent of motorcycle enthusiasts who routinely engage in significant criminal activity. The manner in which the diamond patch is earned is prohibited as a topic of discussion among non-diamond members. Frequently, at regional and national gatherings, meetings are held for diamond members only. At these meetings, club business pertaining to diamond members is discussed.
,
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groups share this collective designation, they are not typically aligned with each other. Rather, the various Outlaw Motorcycle Gangs maintain rivalries amongst each other. competing for prestige, territory, and national recognition. These rivalries are often fierce and commonly erupt in violence. was has variously feuded with other motorcycle clubs such as the Street Soldiers, Hells Lovers, and Outkast. The feud with Outkast bas reached nationwide proportions and remains ongoing.
- Membership in the was is fonnal and organized. Membership is denoted by the wearing of a Wheels of Soul "patch," ·or "colors." The "colors" consist of a black vest adorned with several patches worn on the back. The patches consist of the name "Wheels of Soul" displayed on the top and bottom of the "wing and wheel" center patch. A patch displaying the name of the State where the member's chapter is located is displayed on the bottom of the vest. The frout of the vest is used to designate the member's rank and/or status. Members commonly refer to the WOS collecti vely as "the Nation."
- A small percentage of was members have achieved" t %er" or "diamond" status. Members must earn the t %'er diamond and/or have another diamond member vouch that they deserve a 1%'er diamond. Members who have a 1%'er diamond patch are considered particularly criminal and violent. The lenu "one percenter," or "1 %er" is a commonly utilized term within
the motorcycle club culture, meant to describe the one percent ofmotorcyc1e enthusiasts who
routinely engage in significant criminal activity. The manner in which the diamond patch is earned is prohibited as a topic of discussion among non-diamond members. Frequently. at regional and national gatherings, meetings are held for diamond members only. At these
meetings, club business pertaining to diamond members is discussed.
Case: 4:11-cr-00246-CDP -FRB....... I^ Doc. #: 2 I·^ Filed: 06/09/11 Page: 5 of 40 PageID #: 64:^ I^ ,^ ..^ ,^ ·········:···1^ I
- In order to obtain membership, an individual must first be accepted as a "Prospect." As a "Prospect," the applicant is not permitted to wear the "colors" of WOS until he is accepted as a full member, also known as a "fully-patched member." Rather, he wears a different patch denoting his status as a "Prospect." As a "Prospect," an applicant is subordinate to every fully-patched member ofWOS. Ifgiven an order by a fully-patched member, a "Prospect" must complete the assigned task without hesitation or question. Should a "Prospect" fail to obey a direct order from a fully-patched member, penalties range from violent assault to expulsion from the club.
- When wearing their "colors," members (and "Prospects," who wear a different patch) are required to be in possession of a "kit." The kit includes, among other things, a weapon of choice (preferably a firearm, although members have also begun carrying hammers and/or knives), pen, paper, needle, thread and flashlight.. Failure to carry a "kit" while wearing the WOS "colors" or "Prospect" patch results in punishments ranging from fines to demotion to physical assault.
- The was enterprise is governed by a hierarchical structure. The Mother Chapter and its officers, located in Philadelphia, Pennsylvania, control the entire organization. The entire organization is divided into Regions, each with its own officers. Those Regional officers are subordinate to the Mother Chapter and govern the respective Chapters within their assigned region. Every WOS OMG Chapter, including the Mother Chapter, has ruling Officers. The organizational structure remains consistent through all levels of the WOS OMG nation meaning there are National, Regional, and Local Chapter Presidents, Vice Presidents, Secretaries, Treasurers, Business Managers and Sergeant at Arms.
·. ",. .,^ ,^ ,^ ,^ ,^ ,'.,
- In order to obtain membership, an individual must first be accepted as a "Prospect." As a "Prospect," the applicant is not permitted to wear the "colors" ofWOS until he is accepted as a full member, also mown as a "fully-patched member." Rather, he wears a different patch denoting his status as a "Prospect." As a "Prospect," an applicant is subordinate
to every fully-patched member ofWOS. Ifgiven an order by a fully-patched member, a
"Prospect" must complete the assigned task without hesitation or question. Should a "Prospect" fail to obey a direct order from a fully-patched member, penalties range from violent assault to expulsion from'the club.
- When wearing their "colors," members (and "Prospects," who wear a different patch) are required to be in possession of a "kit." The kit includes, among other things, a weapon of choice (preferably a firearm, although members have also begun carrying hanuners and/or knives), pen, paper, needle, thread and flashlight. Failure to carry a "kit" while wearing the was
"colors" or "Prospect" patch results in punishments ranging from fines to demotion to physical
assault.
- The was enterprise is govem~ by a hierarchical struchlre. The Mother Chapter and its officers. located in Philadelphia, Pennsylvania, control the entire organization. The entire organization is divided into Regions, each with its own officers. Those Regional officers are subordinate to the Mother Chapter and govern the respective Chapters within their assigned region. Every WOS OMG Chapter, including the Mother Chapter, has ruling Officers. The organizational struchlre remains consistent through all levels of the WOS OMG nation meaning there are National, Regional, and Local Chapter Presidents, Vice Presidents, Secretaries, Treasurers, Business Managers and Sergeant at Anus.
········;···1 • ._.^ I^ ,^ •^ I^ 1'-
7. In order to obtain membership, an individual must first be accepted as a
"Prospect." As a "Prospect/' the applicant is not permitted to wear the "colors" of WOS until he is accepted as a full member, also known as a "fully-patched member." Rather, he wears a different patch denoting his status as a "Prospect." As a "Prospect," an applicant is subordinate
to every fully-patched member of WOS. Ifgiven an order by a fully-patched member, a
"Prospect" must complete the assigned task without hesitation or question. Should a "Prospect"
fail to obey a direct order from a fully-patched member, penalties range from violent assault to expulsion from the club.
8. When wearing their "colors," members (and "Prospects," who wear a different
patch) are required to be in possession of a "kit." The kit includes, among other things, a weapon of choice (preferably a firearm, although ,members have also begun carrying hammers and/or knives), pen, paper, needle, thread and flashlight. ,Failure to carry a "kit" while wearing the was "colors" or "Prospect" patch results in punishments ranging from fines to demotion to physical assault.
- The was enterprise is govem~ by a hierarchical structure. The Mother Chapter and its officers, located in Philadelphia, Pennsylvania, control the entire organization. The entire organization is divided into Regions, each with its own officers. Those Regional officers are subordinate to the Mother Chapter and govern the respective Chapters within their assigned region. Every WOS OMG Chapter, including the Mother Chapter, has ruling Officers. The organizational structure remains consistent through all levels of the WOS OMG nation meaning there are National, Regional, and Local Chapter Presidents, Vice Presidents, Secretaries, Treasurers, Business Managers and Sergeant at Anns.
·... ,Case: 4:11-cr-00246-CDP -FRB (^) Doc. #: 2I I···. (^) Filed: 06/09/11•^ "<^ J^ ,.^ Page: 7 of 40 PageID #: 66O.^ I^ :^.
unless otherwise directed by the membership. The Treasurer may perform other such duties with the approval of the membership for the morale and social welfare of the club.
- At each level of the WOS structure, the Business Manager's duties include review and approval of any proposed equipment purchases. The Business Manger conducts fmancial transactions, and is frequently tasked with arranging parties and other social events hosted by the was. These events generate income for the chapter.
- At each level of the was structure, the Sergeant at Arms is most often referred to as the "Enforcer." The Enforcer deals with club "business," some of which may be criminal. The Enforcer also frequently calls chapter meetings to order for the President and ensures the meetings are secure by enforcing rules prohibiting the use of cell phones during meetings. Enforcers are expected to protect the Presidents at all times and to assist the Presidents in preserving order. Enforcers inspect members for the presence of their "kits" when wearing colors. Enforcers are responsible for ensuring that members present at meetings are in good
standing, and they present any new "Prospects" for approval. Ifthe "Prospect" is not approved,
the Enforcer is responsible for escorting him off the premises. The Enforcer is also Road Captain for organized club rides and responsible for bike inspection.
- Every was member is required to swear an oath to the organization. Specifically, each member must aver: "I , as a representative of this Nation hereby solemnly swear to uphold all rules, regulations, and bylawsby my superiors and give full respect to all members of this Nation to obey all orders given of National staff. Not even under the threat of death will I deny any of my brothers or sisters. I will continue to make myself awareoath freely and will defend this Nation until of all intentions of the Wheels my death." of Soul Nation. I take this
, ,"'. ... ',; .. ','.'., '.'
unless otherwise directed by the membership. The Treasurer may perform other such duties with the approval of the membership for the morale and social.welfare of the club,
- At each level of the WOS strucrure, the Business Manager's duties include review and approval of any proposed equipment purchases. The Business Manger conducts fmancial transactions, and is frequently tasked with arranging parties and other social events hosted by the was. These events generate income for the chapter.
- At each level oftbe was structure, the Sergeant at Arms is most often referred to as the "Enforcer." The Enforcer deals with club "business," some of which may be criminal. The Enforcer also frequently calls chapter meetings to order for the President and ensures the meetings are secure by enforcing rules prohibiting the use of cell phones during meetings,
Enforcers are expected to protect the Presidents at all times and to assist the Presidents in
preserving order. Enforcers inspect members for the presence of their "kits" when wearing colors. Enforcers are responsible for ensuring that members present at meetings are in good
standing, and they present any new "Prospects" for approval. If the "Prospect" is not approved,
the Enforcer is responsible for escorting him off the premises. The Enforcer is also Road Captain for organized club rides and responsible for bike inspection.
- Every was member is required to swear an oath to the organization. Specifically, each member must aver:
to uphold"I^ aU rules, regulations, and bylaws, as a representative^ ofoftrus^ this Nation hereby solemnly swear Nation to obey ali orders given
by my superiors and give full respect to all members of National staff. Not even under the threat of death will I deny any of my brothers or sisters. ] will continue to make myself aware of all intentions of the Wheels of Soul Nation. I take this oath freely and will defend this Nation until my death."
",- ,
unless otherwise directed by the membership_ The Treasurer may perform other such duties with the approval ofthe membership for the morale and social.welfare of the club.
14. At each level of the was structure, the Business Manager's duties include review
and approval of any proposed equipment purchases. The Business Manger conducts fmancial transactions, and is frequently tasked with arranging parties and other social events hosted by the
was. These events generate income for the chapter.
I s. At each level of the was structure, the Sergeant at Arms is most often referred to
as the "Enforcer." The Enforcer deals with club "business," some of which may be criminal. The Enforcer also frequently calls chapter meetings to order for the President and ensures the meetings are secure by enforcing rules prohibiting the use of cell phones during meetings. Enforcers are expected to protect the Presidents at all times and to assist the Presidents in preserving order. Enforcers inspect members for the presence of their "kits" when wearing colors. Enforcers are responsible for ensuring that members present at meetings are in good standing, and they present any new "Prospects" for approval. lithe "Prospect" is not approved, the Enforcer is responsible for escorting him off the premises. The Enforcer is also Road Captain for organized club rides and responsible for bike inspection.
16. Every was member is required to swear an oath to the organization.
Specifically, each member must aver:
to uphold"I^ aU rules, regulations, and bylaws, as a representative^ ofof^ this Nation hereby solemnly swearthis Nation to obey ali orders given
by my superiors and give full respect to all membersunder the threat of death will I deny any of my brothers of National staff. Not evenor sisters. ] will continue to make myself aware of all intentions of the Wheels of Soul Nation. I take this oath freely and will defend this Nation until my death."
Case: 4:11-cr-00246-CDP -FRB Doc. #: 2 Filed: 06/09/11 Page: 8 of 40 PageID #: 67
,
.-. I I
- The entire WOS organization is subject to the terms of a Constitution and bylaws. This Constitution applies to all members, regardless of rank or status, as well as "Prospects." This Constitution outlines, among other things: the requirement to pay dues to the organization, the procedure for punishing offenses against the WOS Constitution, the establishment of officers, the wearing of patches, members' attendance at WOS functions, the prohibition of discussing WOS business with non-members, the visitation of fellow WOS members who are incarcerated, and other aspects of the WOS yulture. WOS members are forbidden to carry a copy of the Constitution on their person, lest a copy fall into the hands of law enforcement. Severe punishments are mandated where a member is discovered to be in possession of a copy of the Constitution.
Roles of the Defendants
JAMES C. SMITH, alk/a "Animal" - National Vice President (philadelphia, PA)
ALLAN HUNTER, alkJa "Dog" - Regional Vice President (Chicago, IL)
FREDERICK MORGAN, alk/a "Low Rider" - Regional Vice President (youngstown, OH)
DOMINIC HENLEY, alkJa "Bishop" - Chapter President (St. Louis, MO)
TIMOTHY BALLE, alk/a "T" - Fonner Member (St. Louis, MO)
LAWRENCE PINKSTON, alk/a "Pac" - Former Vice President (St. Louis, MO)
MAURICE THOMAS - associate; brother to Allan ffiJNTER
BRYANT PALMER, alkJa "Dot" - Member (Chicago, IL)
TONEY SIMS, a/kIa "Big T," "Tone" - Member (Chicago, IL)
THOMAS BAILEY, a/kIa "Que,''''Q-Ball'' - Vice President West Side (Chicago, IL)
ANTHONY ROBINSON, alkJa "Blade" - Regional Enforcer (Chicago, IL)
., I ,.
- The entire was organization is subject to the terms of a Constitution and bylaws. This Constitution applies to all members, regardless of rank or status, as well as "Pros~ects." This Constitution outlines, among other things: the requirement to pay dues to the organization, the procedure for punishing offenses against the WOS Constitution, the establislunent of officers, the wearing of patches, members' attendance at WOS functions, the prohibition of discussing was business with non-members, the visitation of fellow WOS members who are incarcerated,
and other aspects of the was Gulture. was members are forbidden to carry a copy of the
Constitution on their person, lest a copy fall into the hands of law enforcement. Severe puoishments are mandated where a member is discovered to be in possession of a copy of the Constitution. Roles of the Defendants JAl\1ES C. SMlTH, alk/a "Animal" - National Vice President (philadelphia, PA) ALLAN HUNTER, afkIa "Dog" - Regional Vice President (Chicago, IL)
FREDERICK MORGAN, aIkIa "Low Rider" - Regional Vice President (Youngstown, OH)
DOMINIC HENLEY, alkla "Bishop" - Chapter President (St. Louis, Ma) TIMOTHY BALLE, aIkIa liT" - Former Member (St. Louis, MO) LAWRENCE PINKSTON, afkIa "Pac" - Former Vice President (St. Louis, MO) MAURICE THOMAS - associate; brother to Allan HUNTER• BRYANT PALMER, aIkIa "Dot" - Member (Chicago, IL) TONEY SIMS, aJkIa "Big T,1t "Tone" - Member (Chicago, IL) THOMAS BAlLEY, afkIa "Que,""Q-BaU" - Vice President West Side (Chicago, IL) ANTHONY ROBINSON, alkla "Blade" - Regional Enforcer (Chicago, IL)
,
, ". '..······:··1 , •• ..^ I^ ,'.
- The entire was organization is subject to the tenns ofa Constitution and bylaws. This Constitution applies to all members, regardless of rank. or status, as well as "Pros~ects." This Constitution outlines, among other things: the requirement to pay dues to the organization, the procedure for punishing offenses against the WOS Constitution, the establislunent of officers, tbe wearing of patches, members' attendance at was functions. the prohibition of discussing was business with non~members, the visitation of fellow WOS members who are incarcerated, and other aspects of the was ~ulture. WOS members are forbidden to carry a copy of the Constitution on their person, lest a copy fall into the hands oflaw enforcement. Severe punishments are mandated where a member is discovered to be in possession of a copy of the Constitution. Roles of the Defendants JAMES C. SMITH, alk/a "Animal" - National Vice President (philadelphia, PA) ALLAN HUNTER. afkJa "Dog" - Regional Vice President (Chicago, IL)
FREDERICK MORGAN, a/kfa "Low Rider" - Regional Vice President (Youngstown, OH)
DOMlNlC HENLEY, alkla "Bishop" - Chapter President (St. Louis, MO) TIMOTHY BALLE, a/kfa "T" - Former Member (S1. Louis, MO) LAWRENCE PINKSTON, afkJa "Pac" - Former Vice President (St. Louis, MO) MAURICE THOMAS - associate; brother to Allan HUNTER• BRYANT PALMER, alkla "Dot" ~ Member (Chicago, ll.) TONEY SIMS, aJkIa "Big T,rI "Tone" - Member (Chicago, IL) THOl\1AS BAlLEY, afkJa "Que,""Q-BaU" - Vice President West Side (Chicago, IL) ANTHONY ROBINSON, a/kla "Blade" - Regional Enforcer (Chicago, lL)
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CARLOS WESLEY ROSE, SR., alk/a "Pit Bull," andNORMAN VICK, alk/a "Justice," together with others, being members and associates of the was enterprise, an enterprise that engaged in activities which affected interstate commerce, lmowingly and intentionally conspired to conduct and participate, directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity, as that term is defined by Title 18, United States Code, Section 1961(1) and (5), consisting of multiple acts involving narcotics trafficking, including cocaine and cocaine base ("crack"), in violation of the laws of the United States, namely: A. 21 U.S.C. §846 and 841 (a)(l) (involving narcotics trafficking and conspiracy to .. commit narcotics trafficking, including cocaine and cocaine base ("crack")); of multiple acts indictable under the following provisions of federal law:
B. 18 U.S.C. §1512 (tampering with a victim, witness, or informant)
and multiple acts chargeable under the following provisions of state law: C. Murder in the Second Degree, in·violation of Mo. Rev. Stat. 565. D. Assault in the First Degree (Attempted Murder), in violation of Mo. Rev. Stat.
E. Robbery, in violation of Mo. Rev. Stat. 569. F. Murder in the Second Degree, 720 ILCS 5/9- G. Attempt to commit murder, in violation of 720 ILCS 5/8-4 and 5/9- H. Conspiracy to commit murder, in violation of 720 ILCS 5/8-2 and 5/9-
1. Intimidation, in violation of 720 ILCS 5/12-
J. Arson, in violation of720 ILCS 5/20-
K. Murder, in violation ofObio R.c. §2903.
•• I .-"'. .,'^ t^ ,^ I ,-.'..^ .--^ '-~^ ,
CARLOS (^) NORMANWESLEY ROSE, SR., alk/a VICK, alkla "Justice," "Pit Bull," and together with others, being members and associates of the was enterprise, an enterprise that engaged in activities which affected interstate commerce, knowingly and intentionally conspired to conduct and particjpate, directly and indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity, as that term is defined by Title 18, United States Code, Section 1961(1) and (5), consisting of multiple acts involving narcotics trafficking, including cocaine and cocaine base ("crack"), in violation of the laws of the United States, namely: A. 21 U.S.C. §846 and 841(a)(1) (involving narcotics trafficking and conspiracy to
. commit narcotics trafficking, including cocaine and cocaine base ("crack")); of multiple acts indictable under the following provisions of federal law: B. 18 U.S.C. §l5l2 (tampering with a victim, witness, or informant) and multiple acts chargeable wIder the following provisions of state law: C. Murder in the Second Degree, in'violation of Mo. Rev. Stat. 565. D. Assault in the First Degree (Attempted Murder), in violation of Mo. Rev. Stat.
E. Robbery, in violation of Mo. Rev. Stat. 569. F. Murder in the Second Degree, 720 [LCS 5/9- G. Attempt to commit murder, in violation of 7.20 ILCS 5/8-4 and 5/9- H. Conspiracy to commit murder, in violation of720 ]LCS 5/8~2 and 5/9-
I. lntimidation, in violation of 720 ILeS 5/12-
J. Arson, in violation of 720 [LCS 5120- K. Murder, in violation ofObio R.e. §2903.
- I '. • I • •• • ~ • (^) " I '.' • -,.,--,.'._' I
CARLOS WESLEY ROSE, SR., alk/a "Pit Bull," and
NORMAN VICK, aMa "Justice,"
together with others, being members and associates of the WOS enterprise, an enterprise that engaged in activities which affected interstate commerce, knowingly and intentionally conspired to conduct and participate, directly and indirectly, in the conduct of the affairs of the enterprise
through a pattern of racketeering activity, as that tenn is defined by Title 18, United States Code,
Section 1961(1) and (5), consisting of multiple acts involving narcotics trafficking, including cocaine and cocaine base ("crack"), in violation of the laws of the United States, namely: A. 21 U.S.C. §846 and 841(a)(1) (involving narcotics trafficking and conspiracy to
. commit narcotics trafficking, including cocaine and cocaine base ("crack")); of multiple acts indictable under the following provisions of federal law: B. 18 U.S.C. §1512 (tampering with a victim, witness, or informant) and multiple acts chargeable under the following provisions of state law: C. Murder in the Second Degree, in' violation of Mo. Rev. Stat. 565.
D. Assault in the First Degree (Attempted Murder), in violation of Mo. Rev. Stat.
E. Robbery, in violation of Mo. Rev. Stat 569.
F. Murder in the Second Degree, 720 ILCS 5/9- G. Attempt to commit murder, in viol~tion of720 ILCS 5/8-4 and 5/9-
H. Conspiracy to commit murder, in violation of 720 ILCS 5/8-2 and 5/9-
I. Intimidation, in violation of720 JLCS 5/12-
J. Arson, in violation of 720 ILCS 5/20- K. Murder, in violation of Ohio R.C. §2903.
.•<Case: 4:11-cr-00246-CDP -FRB.. ·:-·1 I Doc. #: 2 Filed: 06/09/11 Page: 11 of 40 PageID #: 70.....^ ······1^ i
L. Attempt to commit murder, in violation of Ohio R. C. §2923.02 and 2903. M. Kidnapping, in violation of Ohio R. C. §2905. N. Attempt to commit murder, in violation of Colorado R. S. A. §§18-3- and I 8-2-102.
It was a part of the conspiracy that each defendant agreed that a conspirator would
commit at least two acts of racketeering in the conduct of the affairs of the enterprise. In furtherance of the conspiracy and in order to effect the 0 bjects thereof, the defendants and their co-conspirators, both known and unknown to the Grand Jury, committed and caused to be committed the following OVERT ACTS, among others, in the Eastern District of Missouri, the Northern District oflllinois, and elsewhere: 19.1 On or about May 16,2009, DOMINIC HENLEY presided over a was meeting in St. Louis, Missouri, in which he instructed all WOS members and "Prospects" in attendance that they must be armed. He further explained that a WOS member in Gary, Indiana, had been threatened by a member of a rival OMG and that as a result, was members had been instructed to retaliate by robbing their rivals of their "colors," utilizing "any means necessary." HENLEY instructed was members that "when [they] feel like a mother fker did [them] wrong," they should retaliate, cautioning that they should not "kick off no shit that you can't finish. You can kick it off, then better fInish that mother fer. 'Cause you already know, we gotta play for keeps." 19.2 an or about May 27,2009, DOMINIC HENLEY, TIMOTHY BALLE, LAWRENCE PINKSTON and other was members attended a meeting in St. Louis, Missouri, in which DOMINIC HENLEY reminded the group that the was is an "outlaw club." He
defined "outlaw" as someone who "live[s] beyond the law, you know what I'm sayin? It ain't
.. ·· ..-:···-:··1 I·' •.....^.^ I^ ,.-^.^.^ ··.·,··········1^ i·^ .~^ ••^ L^ ;^ ••;^ •••••••
L. Attempt to commit murder, in violation of Ohio R. C. §2923.02 and 2903.
M. Kidnapping, in violation of Ohio R. C. §2905. N. Attempt to commit murder, in violation of Colorado R. S. A. §§ 18-3- and I8-2-1 02. It was a part of the conspiracy that each defendant agreed that a conspirator would commit at least two acts of racketeering in the conduct of the affairs of the enterprise.
In furtherance of the conspiracy and in order to effect the objects thereof, the defendants
and their co-conspirators, both known and unknown to the Grand Jury, committed and caused to be committed the following OVERT ACTS, among others, in the Eastern District of Missouri, the Northern District oflllinois, and elsewhere: 19.1 On or about May 16,2009, DOMINIC HENLEY presided over a WOS meeting
in St. Louis, Missouri, in which he instructed all WOS members and "Prospects" in attendance
that they must be armed. He further explained that a WOS member in Gary, Indiana, had been
threatened by a member of a rival OMG and that as a result, WOS members had been instructed to retaliate by robbing their rivals of their "colors," utilizing "any means necessary." HENLEY instructed was members that "when [they] feel like a mother fl'ker did [them] wrong," they should retaliate, cautioning that they should not "kick off no shit that you can't finish. You can kick it off, then better finish that mother fl'er. 'Cause you already know, we gotta play for keeps." 19.2 On or about May 27,2009, DOMINIC HENLEY, TIMOTHY BALLE, LAWRENCE PINKSTON and other was members attended a meeting in St. Louis, Missouri, in which DOMINIC HENLEY reminded the group that the was is an "outlaw club." He defined "outlaw" as someone who "live[s] beyond the law, you know what I'm sayin? It ain't II
, ,.^ I^ ,_.^ ",".'" "'1 • ",'^ L
L. Attempt to commit murder, in violation of Ohio R. C. §2923.02 and 2903.
M. Kidnapping, in violation afObio R. C. §2905.
N. Attempt to commit murder, in violation of Colorado R. S. A. §§ 18-3-
andI8-2-102. It was a part of the conspiracy that each defendant agreed that a conspirator would
corrunit at least two acts of racketeering in tbe conduct of the affairs of the enterprise.
In furtherance of the conspiracy and in order to effect the objects thereof, the defendants
and their co-conspirators, both known and unknown to the Grand Jury, committed and caused to be committed the following OVERT ACTS, among others, in the Eastern District of Missouri, the Northern District of Ulinois, and elsewhere: 19.1 00 or about May 16, 2009, DOMlNIe HENLEY presided over a was meeting in St. Louis, Missouri, in which he instructed aU was members and "Prospects" in attendance
that they must be armed. He further explained that a WOS member in Gary, Indiana, had been
threatened by a member of a rival OMG and that as a result, was members had been instructed to retaliate by robbing their rivals of their "colors," utilizing "any means necessary." HENLEY instructed was members that "when [they] feel like a mother f*ker did [them] wrong;' they should retaliate, cautioning that they should not "kick off no shit that you can't finish. You can kick it off, then better finish that mother f"'er. 'Cause you already know, we gotta play for keeps."
19.2 00 or about May 27, 2009, DOMINIC llliNLEY, TIMOTHY BALLE,
LAWRENCE PINKSTON and other was members attended a meeting in St. Louis, Missowi, in which DOMINIC HENLEY reminded the group that the was is an "outlaw club." He defined "outlaw" as someone who "Iive[s] beyond the law, you know what I'm sayin? It ain't II
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Missouri. DOMINIC HENLEY explained that was will control the "bike set" in St. Louis,
Missouri, and will detennine which clubs will be pennitted to form. 19.6 On or about August 10, 2009, DOMINIC HENLEY and TIMOTHY BALLE committed an armed robbery in St. Louis, Missouri, in which BALLE brandished a handgun and
ordered two individuals to remove their STL Riders "colors." After the robbery, was members
fled the scene with the "colors." 19.7 On or about August 15,2009, DOMINIC HENLEY, TIMOTHY BALLE and LAWRENCE PINKSTON were involved in a shooting incident in St. Louis, Missouri. Sin City Titans member K.B. was killed.
19.8 On or about August 16, 2009, LAWRENCE PINKSTON attended a was
meeting in St. Louis, Missouri. LAWRENCE PINKSTON admitted to being present at the August 15, 2009 shooting ofK.B. LAWRENCE PINKSTON claimed that during the incident, he attempted to shoot at KB, but his gunjammed. In a later conversation on the same day, LAWRENCE PINKSTON claimed that KB. pulled a gun first, but that KB. then "laid it on the ground." After that, according to LAWRENCE PINKSTON, K.B. walked by DOMINIC HENLEY, and "bumped" him, which prompted DOMINIC HENLEY to open flre. 19.9 On or about August 17,2009, in Chicago, l1linois, at approximately 4.:55 am., CARLYLE FLEMING shot victim R.T. in the abdomen at a club called the Howling Moon in
the presence of other was members.
19.10 On or about August 25, 2009, LAWRENCE PINKSTON attended a was
meeting in St. Louis, Missouri. During the meeting, LAWRENCE PINKSTON told fellow members that there was a warrant for his arrest resulting from the August 15, 2009 shooting of
13
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Missouri. DOMINIC HENLEY explained that was will control the "bike set" in St. Louis,
Missouri, and will determine which clubs will be permitted to fonn. 19,6 On or about August 10, 2009, DOMINIC HENLEY and TIMOTHY BALLE committed an anned robbery in St. Louis, Missouri, in which BALLE brandished a handgun and ordered two individuals to remove their sn Riders "colors." After the robbery, was members
fled the scene with the "colors."
19,7 On or about August 15,2009, DOMINIC HENLEY, TIMOTHY BALLE and LAWRENCE PINKSTON were involved in a shooting incident in St. Louis, Missomi. Sin City Titans member K.B. was killed. 19,8 On or about August 16,2009, LAWRENCE PINKSTON attended a WOS
meeting in St Louis, Missouri. LAWRENCE PINKSTON admitted to being present at the
August 15, 2009 shooting afK.B. LAWRENCE PINKSTON claimed that during the incident,
he attempted to shoot at K.B, but his gunjammed. In a later conversation on the same day,
LAWRENCE PINKSTON claimed that KB. pulled a gun firs~ but that K.B. then "laid it on the
ground," After tha~ according to LAWRENCE PINKSTON, K.B. walked by DOMINIC
HENLEY, and "bumped" him, which prompted DOMINIC HENLEY to open fire,
19.9 On or about August 17,2009, in Chicago, TIlinois, at approximately 4.:55 a.m., CARLYLE FLEMING shot victim R.T. in the abdomen at a club called the Howling Moon in
the presence of other was members.
19,10 On or about August 25, 2009, LAWRENCE PINKSTON attended a WOS meeting in St. Louis, :Missouri. During the meeting, LAWRENCE PINKSTON told fellow members that there was a warrant for his arrest resulting from the August 15,2009 shooting of
Missouri. DOMINIC HENLEY explained that was will control the "bike set" in St. Louis, Missouri, and will determine which clubs will be permitted to form. 19.6 On or about August 10, 2009, DOMINIC HENLEY and TIMOTHY BALLE
committed an anned robbery in St. Louis, Missouri, in which BALLE brandished a handgun and
ordered two individuals to remove their STL Riders "colors." After the robbery, was members fled the scene with the "colors.ll 19.7 On or about August 15, 2009, DOMINIC HENLEY, TIMOTHY BALLE and LAWRENCE PINKSTON were involved in a shooting incident in St. Louis, Missow-i. Sin
City Titans member K.B. was killed.
19.8 Onor about August 16,2009, LAWRENCE PINKSTON attended a WOS
meeting in St. Louis, Missouri. LAWRENCE PINKSTON admitted to being present at the
August 15, 2009 shooting ofK.B. LAWRENCE PINKSTON claimed that during the incident, be attempted to shoot at K.B, but his gunjammed. In a later conversation on the same day,
LAWRENCE PINKSTON claimed that K.B. pulled a gun first, but that K.B. then "laid it on the
ground." After that, according to LAWRENCE PINKSTON, K.B. walked by DOMINIC
HENLEY, and "bumped" him, which prompted DOMINIC HENLEY to open fire.
19.9 On or about August 17,2009, in Chicago, Illinois, at approximately 4,:55 a.m., CARLYLE FLEMING shot victim R.T. in the abdomen at aclub called the Howling Moon in the presence of other was members. 19.10 On or about August 25,2009, LAWRENCE PINKSTON attended a WOS meeting in St. Louis, :M:issouri. During the meeting, LAWRENCE PINKSTON told feUow members that there was a warrant for his arrest resulting from the August 15, 2009 shooting of
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K.B. They also discussed DOMINIC HENLEY being wanted on robbery charges for having
stolen "colors" from "J Money" and his wife, who had called police. They also discussed what might happen to individuals who make robbery allegations to police. 19.11 On or about September 9, 2009, DOMINIC HENLEY stated that as a result of the August 15,2009 shooting ofK.B., every time DOMINIC HENLEY goes out, DOMINIC HENLEY has to be ready for a gunfight. DOMINIC HENLEY also explained that on August 15, 2009, a Sin City member named "Dre" had picked up K.Bo's gun and started shooting. 19.12 On or about September 11,2009, a group of was members including DOMINIC HENLEY and TONEY SIMS met and discussed, among other things, the August 15, shooting ofK.B. in St. Louis, Missouri. One unknown was member stated, "fk with one,. fk with all!" They then discussed various state gun laws, and one unknown was member remarked that of all the guns in the room, only one was legally carried. 19.13 On or about September 12,2009, a number of was members, including the late Regional President Myron Farris, DOMINIC HENLEY, CARLYLE FLEl\HNG, LAWRENCE PINKSTON, and others, attended a WOS meeting. During the meeting, Myron Farris, then the Regional President ofWOS, instructed the Sergeant at Arms to inspect the "Prospects" for their "kits." 19.14 On or about September 12,2009, WOS members DOMINIC HENLEY, LAWRENCE PINKSTON, the late Myron Farris, and others attended a was meeting in which they discussed the need to raise money for a fellow WOS member, who had been arrested for shooting a rival club member. Specifically, they announced that the same member needed $15,000 to pay his attorney. This debt was discussed as being the responsibility of was. At the
14
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KB. They also discussed DOMINIC HENLEY being wanted on robbery cbarges for having stolen "colors" from "1 Money" and his wife, who had called police. They also discussed what might happen to individuals who make robbery allegations to police. 19.11 On or about September 9, 2009, DOMINIC HENLEY stated that as a result of the August 15,2009 shooting o[K.B., every time DOMINIC HENLEY goes ou~ DOMINIC HENLEY has to be ready [or a gunfight. DOMINIC HENLEY also explained that on
August 15, 2009, a Sin City member named "Dre" had. picked up K.B.'s gun and started shooting.
19.12 On or about September 11,2009, a group of was members including DOMINIC HENLEY and TONEY SIMS met and discussed, alnong other things, the August 15, shooting ofK.E. in S1. Louis, Missouri. One unknown was member stated, "f*k with one,. f"'k with all!" They then discussed various state gun laws, and one unknown was member remarked that of all the guns in the room, only one was legally carried. 19.13 On or about September 12,2009, a munber of was members, including the late Regional President Myron Farris, DOMINIC HENLEY, CARLYLE FLEl\1ING, LAWRENCE PINKSTON, and others, attended a was meeting. During the meeting, Myron Farris, then the Regional President of was, instructed the Sergeant at Arms to inspect the "Prospects" for their "kits." 19.14 On or about September 12, 2009, WOS members DOMINIC HENLEY, LAWRENCE PINKSTON, the late Myron Farris, and others attended a was meeting in which they discussed the need to raise money for a fellow was member, who bad been arrested for shooting a rival club member. Specifically, they announced that the same member needed $15,000 to pay his attorney. This debt was discussed as being the responsibility of WQS. At the
14
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KB. They also discussed DOMINIC HENL.EY being wanted on robbery charges for having stolen "colors" from "] Money" and his wife, who had called police. They also discussed what might happen to individuals who make robbery allegations to police. 19.11 On or about September 9, 2009, DOMINIC HENLEY stated that as a result of the August 15, 2009 shooting ofK.B., every time DOMINIC HENLEY goes out, DOMINIC HENLEY has to be ready for a gunfight. DOWNIC HENLEY also .explained that on August 15,2009, a Sin City member named "Dre" had picked. up K.B.'s gun and. started shooting. 19.12 On or about Septembe~ 11,2009, a group of was members including DOMINIC HENLEY and TONEY SIMS met and discussed, among other things, the August 15, shooting of K.B. in St. Louis, Missouri. One unknown was member stated, "f" k with one,. f*k with all!" They then discussed various state gun laws, and one unknown WOS member remarked that of all the guns in the room, only one was legally carried. 19.13 On or about September 12, 2009, a number of WOS members, including the late Regional President Myron Farris, DOMINIC HENLEY, CARLYLE FLEl\1lNG, LAWRENCE PINKSTON, and others, attended a was meeting. During the meeting, Myron Farris, then the Regional President of was, instructed the Sergeant at Arms to inspect the "Prospects" for their "kits." 19.14 On or about September 12, 2009, was members DOMINIC HENLEY, LAWRENCE PINKSTON, the late Myron Farris, and others attended a WOS meeting in which they discussed the need to raise money for a fellow was member, who had been arrested for shooting a rival ~lub member. Specifically, they announced that the same member needed $15,000 to pay his attorney. This debt was discussed as being the responsibility of was. At the
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fight at the "Dirty Dozen" motorcycle club in Chicago, Illinois. He further reported that he shot another individual in the stomach at a club called "Highlight Moon" on an unknown date at 4: in the morning. CARLYLE FLEMING informed his fellow WOS member that he would have killed the victim, but that his gun jammed and the victim ran away. CARLYLE FLEMING stated that he left before police arrived, and went to Indianapolis, Indiana. 19.18 During that same September 12,2009 conversation, CARLYLE FLEMING told
the same WOS member that if be were in charge, he would expel LAWRENCE PINKSTON
from WOS until LAWRENCE PINKSTON "took care of' the person who shot DOMINIC HENLEY. CARLYLE FLEMING explained that he would provide LAWRENCE PINKSTON with the "artillery" and give him a time-frame of a few days to a week. He stated that he would give LAWRENCE PINKSTON a stolen motorcycle so he could get away more quickly. CARLYLE FLEMING then stated tbat if LA WRENCE PINKSTON failed again, LAWRENCE PINKSTON "would not be breathing anymore" because CARLYLE FLEMING
would "literally take him out." CARLYLE FLEMING later brandished a handgun and talked
about LAWRENCE PINKSTON not being a killer, despite being among killers. 19.19 On or about September 12,2009, during a continued conversation about LAWRENCE PINKSTON and his unacceptable response on August 15,2009, FREDERICK MORGAN instructed other WOS members that when discussing firearms over the phone, they should refer to fIrearms as "bottles of wine." FREDERICK MORGAN then discussed that LAWRENCE PINKSTON needed to "take care of' the person who shot DOMINIC HENLEY.
...•.~ ..... ' ';"-1! .. , •••..^ I^ • ••• 1 I····· ••^ -.^1
fight at the "Dirty Dozen" motorcycle club in Chicago, Illinois. He further reported that he shot another individual in the stomach at a club called "Highlight Moon" on an unknown date at 4:
in the morning. CARLYLE FLEMING informed his fellow WOS member that he would have
killed the victim, but that his gun jammed and the victim ran away. CARLYLE FLEMING
stated that he left before police arrived, and went to Indianapolis, Indiana.
19.18 During that same September 12,2009 conversation, CARLYLE FLEMING told
the same WOS member that if he were in charge, he would expel LAWRENCE PINKSTON
from WOS until LAWRENCE PINKSTON "took care of' the person who shot DOMINIC
HENLEY. CARLYLE FLEMING explained that he would provide LAWRENCE
PINKSTON with the "artillery" and give him a time-frame of a few days to a week. He stated
that he would give LAWRENCE PINKSTON a stolen motorcycle so he could get away more
quickly. CARLYLE FLEMING then stated that if LAWRENCE PINKSTON failed again,
LAWRENCE PINKSTON "would not be breathing anymore" because CARLYLE FLE:MING
would "literally take him out." CARLYLE FLE.MING later brandished a handgun and talked
about LAWRENCE PINKSTON not being a killer, despite being among killers.
19.19 On or about September 12,2009, during a continued conversation about LAWRENCE PINKSTON and his unacceptable response on August 15, 2009, FREDERICK MORGAN instructed other WOS members that when discussing firearms over the phone, they
should refer to firearms as "bottles of wine." FREDERICK MORGAN then discussed that
LAWRENCE PINKSTON needed to "take care of' the person who shot DOMINIC
HENLEY.
- • • ,'f'" ·";"~l J •• , • • .'...^ I^ •^ ';'^ .••~.^ ,'^ •^ •• .:"" •••••• ' •• 1 .' •••• •^ ,~,^1
fight at the "Dirty Dozen" motorcycle club in Chicago, Illinois. He further reported that he shot another individual in the stomach at a club called "Highlight Moon" on an unknown date at 4:
in the morning. CARLYLE FLEl\flNG informed his fellow was member that he would have
killed the victim, but that his gun jammed and the victim ran away. CARLYLE FLEMlNG stated that he left before police arrived, and went to Indianapolis, Indiana. 19.18 During that same September 12,2009 conversation, CARLYLE FLEl\fiNG told
the same was member that if he were in charge~ he would .expel LAWRENCE P~TON
from was until LAWRENCE PINKSTON "took care of' the person who shot DOMINIC
HENLEY. CARLYLE FLEMING explained that he would provide LAWRENCE PINKSTON with the "artillery" and give him a time-frame of a few days to a week. He stated that he would give LAWRENCE PINKSTON a stolen motorcycle so he could get away more quickly. CARLYLE FLEMING then stated that ifLA WRENCE PINKSTON failed again, LAWRENCE PINKSTON "would not be breathing anymore" because CARLYLE FLKMING
would "literally take him out." CARLYLE FLEMING later brandished a handgun and talked
about LAWRENCE PINKSTON not being a killer, despite being among killers. 19.19 Ort or about SeptembeI 12,2009, during a continued conversation about
LAWRENCE PINKSTON and his unacceptable response on August 15, 2009, FREDERICK
MORGAN instructed other WOS members that when discussing fireanns over the phone, they
should refer to firearms as "bottles of wine." FREDERICK MORGAN then discussed that
LA WRE· CE PINKSTON needed to "take care of' the person who shot DOMINIC HENLEY.
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19.20 During a September 13,2009 meeting, NORMAN VICK proposed having
females hold guns for was members when they are out. NORMAN VICK also proposed
carrying hammers as weapons instead of guns when they are in the city.
19.21 At that same September 13,2009 meeting, DOMINIC HENLEY informed was members that he wanted them to help out his wife ifhe got locked up. DOMINIC HENLEY also discussed the payment of dues, and conducting a fundraiser for was members in jail. DOMINIC HENLEY then required each was member to fill out an "emergency contactll form with their full names. He and fellow was member NORMAN VICK discussed concerns about the police finding the forms, with DOMINIC HENLEY explaining that if all someone does for the club is kill, and police only know that member by an alias, the forms would help police identify the person by real name. DOMINIC HENLEY then suggested that the forms be kept in a safe deposit box for that reason. 19.22 On or about October 3, 2009, the late Myron Farris, then the Midwest Region President of was, conducted a meeting at which numerous members, including FREDERICK MORGAN, NORMAN VICK, ALLAN HUNTER, CARLYLE FLEMING, ANTHONY ROBINSON, and others were in attendance. After extensive conversation regarding the was Constitution and rules, Myron Farris presided over a discussion about "G.G." and the "charges" against him. Following the discussion, Myron Farris decided that the IIcharges li^ against IIG.G.'I were dismissed. 19.23 On or about October 3, 2009, Myron Farris informed WOS members that the Chapter Presidents needed to begin raising money for a was member's defense. Myron Farris reported that since the WOS member was taking care of lithe Nation's" business, his defense is
17
"",'. '-:""'1 ,- _.^ ,
19.20 During a September 13,2009 meeting, NORl\1AN VICK proposed having females bold guns for was members when they are out. NORMAN VICK also proposed
carrying hammers as weapons instead of guns when they are in the city.
19.21 At that same September 13,2009 meeting, DOMINIC HENLEY informed was members that he wanted them to help out his wife ifhe got locked up. DOMINIC HENLEY also discussed the payment of dues, and conducting a fundraiser for was members in jail. DOMlNIC HENLEY then required each was member to fill out an "emergency contact" fonn with their full names. He and fellow was member NORMAN VlCK discussed concerns about the police finding the forms, with DOMJNIC HENLEY explaining that if all someone does for the club is kill, and police only know that member by an alias, the forms would help police identify the person by real name. DOMINIC HENLEY then suggested that the forms be kept in a safe deposit box for that reason. 19.22 On or about October 3, 2009, the late" Myron Farris, then the Midwest Region President of was ,conducted a meeting at which numerous members, including FREDERlCK MORGAN, NORMAN VlCK, ALLAN HUNTER, CARLYLE FLEMING, ANTHONY ROBINSON, and others were in attendance. After extensive conversation regarding the was Constitution and rules, Myron Farris presided over a discussion about "G.G." and the "charges" against him. Following the discussion, Myron Farris decided that the "charges" against "G.G." were dismissed. 19.23 On or about October 3, 2009, Myron Farris informed was members that the Chapter Presidents needed to begin raising money for a was member's defense. Myron Farris reported that since the was member was taking care of"tbe Nation's" business, his defense is
", " ,^ "^ _.^ ,
19.20 During a September 13,2009 meeting, NORMAN VICK proposed having
females hold guns for was members when they are out. NORMAN VICK also proposed
carrying hammers as weapons instead of guns when they are in tbe city.
19.21 At that same September 13,2009 meeting, DOMINIC HENLEY informed was
members that be wanted them to belp out his wife ifhe got locked up. DOMINIC HENLEY
also discussed the payment of dues, and conducting a fundraiser for was members in jail. DOMJNIC HENLEY then required each was member to fill out an "emergency contact" fonn with their full names. He and fellow was member NORMAN VICK discussed concerns about
the police finding the foons, with DOMINIC HENLEY explaining that if aU someone does for
the club is kill, and police only know that member by an alias, the forms would help police
identify the person by real name. DOl\UNlC HENLEY then suggested that the forms be kept in
a safe deposit box for that reason. 19.22 On or about October 3, 2009, the late Myron Farris, then the Midwest Region
President ofWOS, conducted a meeting at which numerous members, including FREDERICK
MORGAN, NORMAN VlCK, ALLAN HUNTER, CARLYLE FLEMING, ANTHONY ROBINSON, and others were in attendance. After extensive conversation regarding the was Constitution and rules, Myron Farris presided over a discussion about "G.G." and the "charges" against him. Following the discussion, Myron Farris decided that the "charges" against "G.G." were dismissed. 19.23 On or about October 3, 2009, Myron Farris informed was members that the Chapter Presidents needed to begin raising money for a was member's defense. Myron Farris reported that since the was member was taking care of "the Nation's" business, his defense is
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Not to talk to anyone without the "Wheel and Wing" about was business That was is a brotherhood, stating, "we will bleed for you, we will die for you" That they must support each otherthere and you leave me, you better hope to God I don't survive, because the fIrst in the street, warning, "If I'm in a situation out motherfker I'm looking for is the motherfker that left me."
MORGANThat Myron Farris was the Midwest Region President, and is his "right-hand man."^ FREDERICK
That there is an "ongoing situation" with the Sin City Desciples [sic} ThatWheel and Wing, you can consider' them your enemy until proven differently ifmembers are on the street and "there.is someone out there without the .. Consider that's your enemy." That their phone can be their worst enemy and that they must speak in code.
JAMES C. SMITH also passed out copies of the was Constitution.
19.28 At the same November 7,2009 meeting, FREDERICK MORGAN expressed
concern about the "feds" knowing everything they were doing, and that he would "part the ear" of anyone who talks to police.
19.29 Also at the November 7, 2009 meeting, an unknown was member complained
that the President of the Cincinnati Chapter had been stabbed seven times, and another member
stabbed twice. The unknown member expressed frustration that the was were "sitting around
asking what the fk we are doing when motherfkers stabbed our bros." He then explained that "these punk motherfkers out here pulling this God-damn bullst with us because there ain't s* t happening and that's up to everybody in here." The unknown member then urged fellow was that "they pulling this st 'cause they think they can get away with it." In response, was member "Baby Boy," agreed, "everybody need to grab their nuts and say f*k the police
'cause that's the only way it can be seen." A second unknown was member then added,
: '.:.. .. ··:.. ·······1 '.^ '.'^ I^ ,^ •.....^ ~^ I^ j"^ ".^.^ ····•··..^ :·'1^ ,.
- Not to talk to anyone without the "Wheel and Wing" about was business That was is a brotherhood., stating, "we will bleed for you, we will die for you" That they must support each otherthere and you leave me, you better hope in the street, warning, to God I don't survive, because the "If I'm in a situation out [lIst motherfker I'm looking for is the motherfker that left me."
That Myron Farris was the Midwest Region President, and FREDERICK
MORGAN is his "right-hand man."
That there is an "ongoing situation" with the Sin City Desciples [sic]
- ThatWheel and Wing, you can consider' them your enemy ifmembers 'are on tlH~ street and '~thereis someone out lll1til proven differently. them without the' Consider that's your enemy."
- That their phone can be their worst enemy and that they must speak in code. JAMES C. SMITH also passed out copies of the was Constitution.
19.28 At the same November 7,2009 meeting, FREDERICK MORGAN expressed
concern about the "feds" knowing everything they were doing, and that he would "part the ear" of anyone who talks to police. 19.29 Also at the November 7, 2009 meeting, an unlmown was member complained that the President of the Cincinnati Chapter had been stabbed seven times, and another member stabbed twice. The unknown member expressed frustration that the was were "sitting around asking what the fk we are doing when motherfkers stabbed our bros." He then explained that "these punk: motherfkers out here pulling this God-damn bullst with us because there ain't st happening and that's up to everybody in here." The unknown member then urged fellow was that "they pulling this st 'cause they think they can get away with it." In response, was member "Baby Boy," agreed, "everybody need to grab their nuts and say f* *k the police 'cause that's the only way it can be seen." A second unknown was member then added, 19
: :', ....•. ,^.
- Not to talk to anyone without the "Wheel and Wing" about was business That was is a brotherhood. stating, "we will bleed for you, we will die for you"
- That they must support each otherthere and you leave me, you better hope to God in the street, warning, I don't survive, because the "If I'm in a situation out rust
motherfker I'm looking for is the motherfker that left me."
That Myron Farris was the Midwest Region President, and FREDERICK
MORGAN is his "right·hand man." That there is an "ongoing situation" with the Sin City Desciples [sic] That ifmembers 'are on the street and "there is someoneWheel and Wing, you can consider' them your enemy until proven differently. out there without the Consider that's your enemy."
- That their phone can be their worst enemy and that they must speak in code. JA1\fES C. S'MITH also passed out copies of the was Constitution.
19.28 At the same November 7, 2009 meeting, FREDERICK MORGAN expressed
concern about the "feds" knowing everything they Were doing, and thai he would "part the ear" of
anyone who talks to police. 19.29 Also at the November 7, 2009 meeting, an unknown was member complained that the President of the Cincinnati Chapter had been stabbed seven times, and another member
stabbed twice. The unknown member expressed frustration that the was were "sitting around
asking what the fk we are doing when motherfkers stabbed our bros." He then explained that "these punk: motherfkers out here pulling this God-danm bulls"t with us because there ain't st happeniog and that's up to everybody in here." The unknown member then urged fellow was that "they pulling this st 'cause they thi.nk they can get away with it." In response, was member "Baby Boy," agreed., "everybody need to grab their nuts and say fk the police 'cause that^1 s the only way it can bc seen." A second unknown WOS member then added,
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"snitches are a dying breed," and a third unknown member stated that "you are supposed to give everything for this."
19.30 During the November 7, 2009 meeting, DOMINIC HENLEY lamented that "we
got too many brothers out here doing trying to be pseudo-outlaws, doing s*t they don't normally do. They put these rags on and do stupid s *t that we never would have been in if they had used their brain."
19.31 On or about December 2,2009, TIMOTHY BALLE sold a Norinco SKS 7.62 x
39 nun assault rifle, along with twelve (12) boxes of7.62 x 39 nun ammunition, to a known felon and f~llow was member, intending that the rifle would be used to retaliate for the
August 15, 2009 incident in which TIMOTHY BALLE and DONllNIC HENLEY were shot
by rival OMG member.
19.32 On or about January 15, 2010, JAMES C. SMITH, DOMINIC HENLEY and
other was members attended a was National meeting in Philadelphia, Pennsylvania. During
the meeting, JAMES C. SMITH stated, among other things:
was is "strictly outlaw"
Members must listen to Presidents. Disrespect will result in "splitting heads"
"Boss" is National President. JAMES C. S:MITH is National Vice-President. If a member is asked to do something by the National President or Vice President,
the member must do"Prospectll must immediately comply. it. If a "full colorll^ asks something of a "Prospect,II the
was members are "outlawsll^ and that if civilians step out of line, they will "get what's coming to them. is not "weekend warrior 1I S**t,1Iwas it is a lifestyle.members are to be "outlaw" at all times, and was
J ;: •• ,. ·······',··1 ,
"snitches are a dying breed," and a third unknown member stated that "you are supposed to give everything for this." 19.30 During the November 7, 2009 meeting, DOMlNIC HENLEY lamented that "we got too many brothers out here doing trying to be pseudo-outlaws, doing st they don't nonnaUy do. They put these rags on and do stupid st that we never would have been in if they had used their brain." 19.31 On or about December 2,2009, TIMOTHY BALLE sold a Norinco SKS 7.62 x
39 m.m assault rifle, along with twelve (12) boxes of7.62 x 39 mro ammunition, to a lmown
felon and fe:llow was member, intending that the rifle would be used. to retaliate for the August IS, 2009 incident in which TIMOTHY BALLE and DOMlNIC HENLEY were shot
by rival OMG member.
19.32 On or about January 15,2010, JAl\1ES C. SMITH, DOMINIC HENLEY and
other WOS members attended. a WOS National meeting in Philadelphia, Pennsylvania. During
the meeting, JAl\1ES C. S:MITH stated, among other things: was is "strictly outlaw"
Members must listen to Presidents. Disrespect will result in "splitting heads"
- "Boss" is National President. JAMES C. S:MITH is National Vice-President.
- If a member is asked to do something by the National President or Vice President,
the member must do"Prospect" must immediately comply. it. If a "full color" asks something of a "Prospect," the
WOS members ar~ "outlaws" and that if civilians step out ofline, they will "get what's coming to them." was members are to be "outlaw" at all times, and was is not "weekend warrior s**t," it is a lifestyle.
.. I (^) I ." (^) """"'1 I
"snitches are a dying breed," and a third unknown member stated that "you are supposed to give everything for this,ll 19.30 During the November 7,2009 meeting, DOMINIC HENLEY lamented that It we got too many brothers out here doing trying to be pseudo-outlaws, doing st they don't normally do. They put these rags on and do stupid st that we never would have been in if they had used their brain. It 19.31 On or about December 2,2009, TIMOTHY BALLE sold a Norinco SKS 7.62 x 39 mm assault rifle, along with twelve (12) boxes of7.62 x 39 rom ammunition, to a known felon and fe:llow was member, intendin,g that the rifle would be used to retaliate for the August 15,2009 incident in which TIMOTHY BALLE and DOl\fl.NIC HENLEY were shot by rival OMG member. 19.32 On or about January 15,2010, JAMES C. SMITH, DOMINIC HENLEY and other WOS members attended a was National meeting in Philadelphia, Pennsylvania. During
the meeting, JAMES C. SMITH stated, among other things:
WOS is Itstrictly outlaw"
Members must listen to Presidents. Disrespect will result in "splitting heads"
"Boss" is National President. JAMES C. SMITH is National Vice-President.
- Ifthe member must do it. a member is asked to do something by the National President If a "full color" asks something of a "Prospect," the or Vice President, "Prospect" must immediately comply. was members ar~ "outlawsu^ and that if civilians step out of line, they win "get what1s coming to them.'l was members are to be l'outlaw ll^ at all times, and was is not l'weekend warrior s**t/' it is a lifestyle.
