UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No: ---------- -- 8 U.S.C. § 1324(a)(l)(A)(iv) 

8 U.S.C. § 1326(a) 

UNITED STATES OF AMERICA, 

vs. 

DOYLE CLEARE, 

a/k/a "Rickie Williams," 

and HOWARD WRIGHT, 

Defendants. 

I -------------

INDICTMENT 

The Grand Jury charges that: 

COUNTS 1-6 

Between on or about October 25, 2022, and continuing through on or about October 30, 

2022, in the Special Maritime and Territorial Jurisdiction of the United States, and elsewhere, with 

Palm Beach County, in the Southern District of Florida, being the district to which the offender was 

first brought, the defendant, 

DOYLE CLEARE, 

a/k/a "Rickie Williams," 

did knowingly encourage and induce an alien, as set forth in Counts 1 through 6 below, to come 

to, enter, and reside in the United States, knowing and in reckless disregard of the fact that such 

coming to, entry, and residence is and will be in violation oflaw, said conduct placing in jeopardy 

the life of any person: 

Count 

1 HOW ARD WRIGHT 

22-80180-Cr-Cannon/Reinhart

TM Nov 15, 2022 West Palm Beach

Case 9:22-cr-80180-AMC Document 8 Entered on FLSD Docket 11/15/2022 Page 1 of 6
Count Alien 

2 L.H. 

3 L.F.T. 

4 M.A.D-M 

5 A.I.G. 

6 H.A.C. 

All in violation of Title 8, United States Code, Section 1324(a)(l)(A)(iv) and (a)(l)(B)(iii), 

and Title 18, United States Code, Section 2. 

COUNT7 

. Between on or about October 25, 2022, and continuing through on or about October 30, 

2022, in the Special Maritime and Territorial Jurisdiction of the United States, and elsewhere, with 

Palm Beach County, in the Southern District of Florida, being the district to which the offender was 

first brought, the defendant, 

DOYLE CLEARE, 

a/k/a "Rickie Williams," 

an alien, having previously been removed and deported from the United States on or about June 15, 

1993, and August 11 , 2000, entered, and attempted to enter, the United States, knowingly and 

unlawfully, without the Attorney General of the United States or his/her successor, the Secretary of 

Homeland Security (Title 6, United States Code, Sections 202(3), 202( 4), and 557) having expressly 

consented to such alien reapplying for admission to the United States, in violation of Title 8, United 

States Code, Section 1326(a) and (b)(2). 

2 

Case 9:22-cr-80180-AMC Document 8 Entered on FLSD Docket 11/15/2022 Page 2 of 6
COUNTS 

Between on or about October 25, 2022, and continuing through on or about October 30, 

2022, in the Special Maritime and Territorial Jurisdiction of the United States, and elsewhere, with 

Palm Beach County, in the Southern District of Florida, being the district to which the offender was 

first brought, the defendant, 

HOWARD WRIGHT, 

an alien, having previously been removed from the United States on or about January 22, 2004, and 

September 12, 2012, entered, and attempted to enter, the United States, knowingly and unlawfully, 

without the Attorney General of the United States or his/her successor, the Secretary of Homeland 

Security (Title 6, United States Code, Sections 202(3), 202( 4), and 557) having expressly consented 

to such alien reapplying for admission to the United States, in violation of Title 8, United States 

Code, Section 1326(a) and (b)(l). 

NIO GONZALEZ 

TATES ATTORNEY 

JOHN C. McMILLAN 

ASSISTANT UNITED STATES ATTORNEY 

A TRUE BILL: 

FOREPERSON 

3 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

UNITED STATES OF AMERICA CASE NO. ________________ _ 

\'. 

DOYLE CLEARE CERTIFICATE OF TRIAL ATTORNEYit 

and HOWARD WRIGHT, 

Superseding Case Information: 

Defendants. 

Court Division: (Select One) 

Miami Key West 

FIL ✓ WPB _ FTP 

Newdefendant(s) Yes 

Number of new defendants 

Total number of counts 

No 

I. I have carefully considered the allegations of the indictment, the number of defendants, the number of 

probable witnesses and the legal complexities of the Indictment/Information attached hereto. 

2. I am aware that the information supplied on this statement will be relied upon by the Judges of this 

Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial 

Act, Title 28 U.S.C.Section3161. 

3. Interpreter: (Yes or No) No 

List language and/or dialect 

4. This case will take .1:.1_ days for the parties to try. 

5. Please check appropriate category and type of offense listed below: 

(Ch,ct only oue) (Cbed ouly oue) 

I 0 to 5 days I Petty 

II 6 to 10 days Minor 

III 11 to 20 days Misdem. 

IV 21 to 60 days Felony ✓ 

V 61 days and over 

6. Has th is case previously been fi led in this District Court? (Yes or No) 

If yes: Judge Case No. 

No 

-------------- (Attach copy of dispositive order) 

Has a complaint been filed (Yes or No) Yes in this matter? 

If yes: Magistrate Case No. 22-8506-WM (Cleare). and22-8507-WM (Wright) 

Related miscellaneous numbers: 

Defendant(s) in federa l custody as of 

Defendant(s) in state custody as of 

Rule 20 from the District of 

11/02/2022 

Is this a potential death penalty case? (Yes or No) 

7. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office 

prior to August 9, 20 13 (Mag. Judge Alicia 0 . Valle)? Yes No 1 

8. Does this case originate from a matter pendjng in the Northern Region of the U.S. Attorney's Office 

prior to August 8, 20 14 (Mag. Judge Shaniek Maynard)? Yes No ✓ 

9. Does this case originate from a matter pending · 

pri or to October 3, 2019 (Mag. Judge Jared Stra 

*Penalty Sheet(s) attached REV 6/5/2020 

Case 9:22-cr-80180-AMC Document 8 Entered on FLSD Docket 11/15/2022 Page 4 of 6
UNITED ST A TES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: _ __.cD~O-=Y--=L=E'-C=L=E=Aa..=:RE=-, =a/=k/,_,,a,_'...,,_'Ri~· c::.:ki""'·-'<--e _,_W!..::i~ll~iam=s:......" ________ _ 

Case No: -------------------------------

Counts #: 1-6 

Encouraging or Inducing an Alien to Come to or Enter the United States 

Title 8, United States Code, Section 1324(a)(l)(A)(iv), 1324(a)(l)(B)(iii) 

*Max.Term oflmprisonment: 20 years 

* Mandatory Min. Term oflmprisonment (if applicable): not applicable 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 

* Special Assessment: $100.00 

Immigration consequences of removal (deportation) from the United States upon 

conviction 

Count#: 7 

Re-entry After Deportation (Aggravated Felon) 

Title 8, United States Code, Section 1326(a) and (b)(2) 

*Max.Term oflmprisonment: 20 years 

* Mandatory Min. Term oflmprisonment (if applicable): not applicable 

* Max. Supervised Release: 3 years 

* Max. Fine: $250,000 

* Special Assessment: $100.00 

Immigration consequences of removal (deportation) from the United States upon 

conviction 

*Refers only to possible term of incarceration, supervised release and fines. It does not include 

restitution, special assessments, parole terms, or forfeitures that may be applicable. 

Case 9:22-cr-80180-AMC Document 8 Entered on FLSD Docket 11/15/2022 Page 5 of 6
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

PENALTY SHEET 

Defendant's Name: HOWARD WRIGHT 

Case No: -----------------------------

Count#:8 

Re-entry After Deportation (Felony) 

Title 8, United States Code, Section 1326(a) and (b)(l) 

* Max. Term of Imprisonment: 10 years 

* Mandatory Min. Term oflmprisonment (if applicable): not applicable 

* Max. Supervised Release: 3 years 

*Max.Fine: $250,000.00 

* Special Assessment: $100.00 

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