FILED25 1..Tlt~ '14 07:55USDC·ORP 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

UNDER 

SEAL 

UNITED STATES OF AMERICA 

v. 

FABIAN SANDOVAL-RAMOS, 

PLACIDO RAMIREZ-CORONEL, 

RAUL ARCILA, 

SHANE GLENN BAKER, 

MICHAEL JAMES ROSA, and 

MORGAN ELIZABETH GODVIN, 

Defendants. 

Case No. 3 '.14~-CY--- 002lc 1-BR_ 

INDICTMENT 

21 U.S.C. §§ 84l(a)(l), (b)(l)(C) 

21 U.S.C. §§ 841(b)(l)(A)(i) 

21 U.S.C. §§ 841(b)(l)(B)(i) 

21u.s.c.§846 

21 u.s.c. § 853 

18 u.s.c. § 2 

*UNDER SEAL* 

THE GRAND JURY CHARGES: 

COUNT 1: 

[Conspiracy to Distribute Heroin Resulting in Death] 

21 U.S.C. §§ 846, 84l(a)(l), 841(b)(l)(C) 

On or between March 20 and April 4, 2014, in the District of Oregon, defendants 

FABIAN SANDOVAL-RAMOS, PLACIDO RAMIREZ-CORONEL, RAUL ARCILA, 

SHANE GLENN BAKER, MICHAEL JAMES ROSA and MORGAN ELIZABETH 

GODVIN, did knowingly and willfully combine, conspire, confederate and agree with each 

other and with others both known and unknown to the Grand Jury, to distribute heroin, a 

Schedule I controlled substance, in violation of Title 21, United States Code, Sections 84l(a)(l) 

and 846. The Grand Jury further charges that this conspiracy distributed heroin, the use of 

which resulted in the death of another person, to wit: defendants conspired to distribute heroin 

which was ultimately used by victim "J.D." in Washington County, Oregon, whose use of said 

Case 3:14-cr-00267-BR Document 1 Filed 06/25/14 Page 1 of 6
... · 

heroin caused his death, all in violation of Title 21, United States Code, Sections 841(a)(l), 

(b )(1 )(C), and Title 18, United States Code, Section 2. 

COUNT 2: 

[Conspiracy to Distribute Heroin] 

21 U.S.C. §§ 846, 841(a)(l), 841(b)(l)(A)(i) 

Beginning in February 2014 and continuing through April 2014, in the District of 

Oregon, defendants FABIAN SANDOVAL-RAMOS, PLACIDO RAMIREZ-CORONEL, 

RAUL ARCILA, and SHANE GLENN BAKER did knowingly and willfully combine, 

conspire, confederate and agree with each other and with others both known and unknown to the 

Grand Jury, to distribute heroin, a Schedule I controlled substance, in violation of Title 21, 

United States Code, Sections 841(a)(l) and 846. The Grand Jury further charges, pursuant to 

Title 21, United States Code, Section 841(b)(l)(A)(i), that this violation involved 1,000 grams or 

more of a mixture or substance containing a detectable amount of heroin. 

COUNT3: 

[Conspiracy to Distribute Heroin] 

21 U.S.C. §§ 846, 841(a)(l), 841(b)(l)(B)(i) 

Beginning in a time unknown in 2013 and continuing through April 2014, in the District 

of Oregon, defendants SHANE GLENN BAKER, MICHAEL JAMES ROSA and MORGAN 

ELIZABETH GODVIN did knowingly and willfully combine, conspire, confederate and agree 

with each other and with others both known and unknown to the Grand Jury, to distribute heroin, 

a Schedule I controlled substance, in violation of Title 21, United States Code, Sections 

84l(a)(l) and 846. The Grand Jury further charges, pursuant to Title 21, United States Code, 

Section 84l(b)(l)(B)(i), that this violation involved 100 grams or more of a mixture or substance 

containing a detectable amount of heroin. 

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COUNT 4: 

[Distribution of Heroin] 

21 U.S.C. §§ 841(a)(l), 84l(b)(l)(C) 

On or about March 29, 2014, in the District of Oregon, defendant MORGAN 

ELIZABETH GODVIN did knowingly and intentionally distribute heroin, a Schedule I 

controlled substance, in violation of Title 21, United States Code, Sections 84l(a)(l) and 

841 (b )(1 )( C). 

COUNT 5: 

[Possession with the Intent to Distribute Heroin] 

21 U.S.C. §§ 84l(a)(l), 841(b)(l)(C) 

On or about March 29, 2014, in the District of Oregon, defendants MICHAEL JAMES 

ROSA and MORGAN ELIZABETH GODVIN did knowingly and intentionally possess with 

the intent to distribute heroin, a Schedule I controlled substance, in violation of Title 21, United 

States Code, Sections 84l(a)(l) and 84l(b)(l)(C). 

COUNT 6: 

[Possession with the Intent to Distribute Methamphetamine] 

21 U.S.C. §§ 841(a)(l), 841(b)(l)(C) 

On or about March 29, 2014, in the District of Oregon, defendant MICHAEL JAMES 

ROSA did knowingly and intentionally possess with the intent to distribute methamphetamine, a 

Schedule II controlled substance, in violation of Title 21, United States Code, Sections 84l(a)(l) 

and 841 (b )(1 )(C). 

COUNT 7: 

[Possession of a Firearm in Furtherance of Drug Trafficking] 

21 U.S.C. §§ 84l(a)(l), 841(b)(l)(B)(i) 

On or about March 29, 2014, in the District of Oregon, defendant MICHAEL JAMES 

ROSA did knowingly possess a firearm: a Smith and Wesson .40 caliber pistol, model SSW 40F, 

bearing serial number P AJ287 5, in furtherance of a drug trafficking crime for which he may be 

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Case 3:14-cr-00267-BR Document 1 Filed 06/25/14 Page 3 of 6
prosecuted in a court of the United States, to wit: Conspiracy to Distribute Heroin (as alleged in 

Count 3), Possession with Intent to Distribute Heroin and Methamphetamine (as alleged in 

Counts 5 and 6) all in violation of Title 18, United States Code, Section 924( c ). 

COUNT 8: 

[Distribution of Heroin] 

21 U.S.C. §§ 841(a)(l), 84l(b)(l)(C) 

On or about March 30, 2014, in the District of Oregon, defendant SHANE GLENN 

BAKER did knowingly and intentionally distribute heroin, a Schedule I controlled substance, in 

violation of Title 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C). 

COUNT 9: 

[Possession with the Intent to Distribute Heroin] 

21 U.S.C. §§ 841(a)(l), 841(b)(l)(B)(i) 

On or about March 31, 2014, in the District of Oregon, defendants PLACIDO 

RAMIREZ-CORONEL and RAUL ARCILA did knowingly and intentionally distribute 

heroin, a Schedule I controlled substance, in violation of Title 21, United States Code, Section 

84l(a)(l). The Grand Jury further charges, pursuant to Title 21, United States Code, Section 

841(b)(l)(B)(i), that this violation involved 100 grams or more of a mixture or substance 

containing a detectable amount of heroin. 

COUNT 10: 

[Possession with the Intent to Distribute Heroin] 

21 U.S.C. §§ 841(a)(l), 84l(b)(l)(B)(i) 

On or about April 2, 2014, in the District of Oregon, defendants PLACIDO RAMIREZCORONEL and RAUL ARCILA did knowingly and intentionally distribute heroin, a Schedule 

I controlled substance, in violation of Title 21, United States Code, Section 841(a)(l). The 

Grand Jury further charges, pursuant to Title 21, United States Code, Section 841(b)(l)(B)(i), 

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Case 3:14-cr-00267-BR Document 1 Filed 06/25/14 Page 4 of 6
that this violation involved 100 grams or more of a mixture or substance containing a detectable 

amount of heroin. 

CRIMINAL FORFEITURE ALLEGATION - CONTROLLED SUBSTANCES 

Upon conviction for any of the offenses alleged in Counts 1 through 11 of this 

indictment, FABIAN SANDOVAL-RAMOS, PLACIDO RAMIREZ-CORONEL, RAUL 

ARCILA, SHANE GLENN BAKER, MICHAEL JAMES ROSA and MORGAN 

ELIZABETH GODVIN, defendants herein, shall forfeit to the United States pursuant to Title 

21 United States Code, Section 853, any and all property constituting or derived from any 

proceeds the said defendants obtained directly or indirectly as a result of the said violation and 

any and all property used or intended to be used in any manner or part to commit and to facilitate 

the commission of the violations alleged in Counts 1-11 of this Indictment. 

II 

II 

II 

II 

II 

II 

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CRIMINAL FORFEITURE ALLEGATION 

Upon conviction of the offense alleged in Count 7of this indictment, defendant 

MICHAEL JAMES ROSA, shall forfeit to the United States pursuant to Title 18, United States 

Code, Section 924( d), and Title 28, United States Code, Section 2461 ( c ), the firearm and all 

associated ammunition involved in that offense, including without limitation: 

1. a Smith and Wesson .40 caliber pistol, model SSW40F, bearing serial number 

PAJ2875 

2. gun magazine containing 15 rounds 

·~ DATED this fJ.. '-\ day of June 2014. 

Presented by: 

S. AMANDA MARSHALL 

AH K. BOLSTAD, OSB #052039 

Assistant United States Attorney 

A TRUE BILL. 

OFFICIATING FOREPERSON 

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