IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA §

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SEALED

Case No. 4:24-CR-19

Judge Jordan

FIRST SUPERSEDING INDICTMENT

THE UNITED STATES GRAND JURY CHARGES:

Cou t One

Violatio : 21 U.S.C. § 846

(Conspiracy to Possess with Intent

to Manufacture, Distribute and

Dispense A Controlled Substance

Analogue)

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That from sometime in or about January 2022, and continuously thereafter up to and

including the date of this First Supersedin Indictment, in the Easte District of Texas and

elsewhere,

Christopher Dale Julian

defendants, did knowingly and intentionally combine, conspire, and agree with each other

and other persons known a d unknown to the United States Grand Jury, to knowingly nd

intentionally possess with the intent to distribute mixtures or substances containing

detectable amounts of a Schedule 1 controlled substance, to wit: ADB-BUTINACA, and

MDMB-4en-PINACA, a violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(c); knowing that

the substance was intended for human consumption as provided in 21 U.S.C. § 813.

All in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C) and 846.

Count Two

Violation: 18 U.S.C. § 1956(h)

(Conspiracy to Commit Money

Laundering in Violation of 18

U.S.C. § 1956(a)(l)(B)(i))

That from sometime in or about Janua y 2022 and continuously thereafter up to and

including the date of this First Superseding Indictment, in the Eastern District of Texas and

elsewhere.

Christopher Dale Julian

First Superseding Indictment - Page 2

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defe dants, did knowingly, willf lly, and unlawf lly combine, conspire, confederate, and

a ree together and with each other, and with others known and unknown to the Grand Jury,

to commit certain offenses against the United States, to-wit: to knowingly conduct and

attempt to conduct financial transactions affecting interstate and foreign commerce that

involved the proceeds of a specified unlawfill activity, that is, Conspiracy to Possess with

Intent to Distribute a Controlled Substance, to-wit: controlled substance analogues, as

described in Count One of this First Superseding Indictment, knowing that the transaction

was designed in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of the specified unlawful activity, and that while

conducting and attempting to conduct such financial transactions, knew that the property

involved represented the proceeds of some form of unlawful activity, in violation of 18

U.S.C. § 1956(a)(l)(B)(i).

All in violation of 18 U.S.C. § 1956(h).

Count Three

Violation: 21 U.S.C. § 846

(Conspiracy to Possess with Intent

to Manufacture, Distribute and

Dispense A Controlled Substance

Analogue)

That from sometime in or about January 2022, and continuously thereafter up to and

including the date of this Indictment, in the Easte District of Texas and elsewhere,

First Superseding Indictme t - Page 3

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defendants, did knowingly and intentionally combine, conspire, and agree with each other

and other persons known and unknown to the United States Grand Jury, to knowingly and

intentionally possess with the intent to distribute mixtures or substances containing

detectable amounts of a Schedule 1 controlled substance, to wit: ADB-BUTINACA, and

l lDMB-4en-PINACA, a violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(c); knowing that

the substance was intended for human consumption as provided in 21 U.S.C. § 813.

All in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(C) and 846.

Count Four

Violation: 18 U.S.C. § 1956(h)

(Conspiracy to Commit Money

Laundering in Violation of 18

U.S.C. § 1956(a)(l)(B)(i))

That from sometime in or about January 2022 and continuously thereafter up to and

including the date of this First Superseding Indictment, in the Eastern District of Texas and

elsewhere.

First Supersedi g Indictment - Page 4

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defendants, did knowingly, willfully, and unlawfully combine, conspire, confederate, and

agree together and with each other, and with others known and unknown to the Grand Jury,

to commit certain offenses against the United States, to-wit: to knowingly conduct and

attempt to conduct financial transactions affecting interstate and foreign commerce that

involved the proceeds of a specified unlawful activity, that is, Conspiracy to Possess with

Intent to Distribute a Controlled Substance, to-wit: controlled substance analogues, as

described in Count Three of this First Superseding Indictment, knowing that the transaction

was designed in whole or in part to conceal and disguise the nature, location, source,

ownership, and control of the proceeds of the specified unlawful activity, and that while

conducting and attempting to conduct such financial transactions, knew that the property

involved represented the proceeds of some form of unlawful activity, in violation of 18

U.S.C. § 1956(a)(l)(B)(i).

All in violation of 18 U.S.C. § 1956(h).

NOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

(Pursuant to 21 U.S.C. § 853 and 18 U.S.C. § 982(a)(1))

As a result of committing the offense charged in Counts One, Two, Three, and Four

of this First Superseding Indictment, the defendants shall forfeit to the United States any

property constituting, or derived from, proceeds obtained directly or indirectly, as the result

of the offenses alleged in this First Superseding Indictment and any property they may have

used or intended to be used to commit or facilitate the offenses.

If any of the property described above as being subject to forfeiture as a result of

any act or omission of the defendantsFirst Superseding Indictment - Page 5

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(1) cannot be located upon the exercise of due diligence;

(2) has been transferred or sold to, or deposited with a

third person;

(3) has been placed beyond the jurisdiction of the court;

(4) has been substantially diminished in value; or

(5) has been commingled with other property which

cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), to seek forfeiture

of any other property of the defendants up to the value of the above forfeitable property,

including but not limited to all property, both real and personal owned by the defendants.

By virtue of the commission of the offenses alleged in this First Superseding

Indictment, any and all interest the defendants have in the above-described property is

vested in and forfeited to the United States.

A TRUE BILL

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

CHRISTOPHER T. RAPP

Assistant United States Attorney

GRAND JURY FOREPERSON

Date

First Superseding Indictment - Page 6

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA SEALED

NOTICE OF PEN LTIES

Counts One an Three

Violation: 21 U.S.C. § 846

Pen lty: Iinprisoimient not to exceed 20 years; a fine not to exceed $1 million, or

both; a term of supe vised release of at least 3 years.

No. 4:24-CR-19

Judge Jordan

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Special Assessment: $100.00

Notice of Penalty - Page 1

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Counts Two and Four

Violation: 18 U.S.C. § 1956(h)

Penalty: Not more than 20 years imprisonment; a fine not to exceed $500,000 or

twice the pecuniary gain or loss, and a term of supervised release of not

more than 3 years if the conspiracy is to violate 18 U.S.C. § (a)(l)(B)(i);

Special Assessment: $100.00

Notice of Penalty - Page 2

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