IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF A ERICA §

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SEALED

No. 4:24-CRJxidge

J /

INDICTMENT

THE UNITED STATES GRAND JURY CHARGES:

Count One

Violation: 21 U.S.C. § 846

(Conspiracy to Possess with Intent

to Manufacture, Distribute and

Dispense A Controlled Substance

Analogue)

Indictment

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

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

Christopher Dale Julian

defendants, did knowin ly 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 cont olled substance, to wit: ADB-BUTINACA, and

IvIDMB-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

and including the date of this Indictment, in the Easte District of Texas and elsewhe e.

Christopher Dale Julian

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

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

Violation: 18 U.S.C. § 1956(h)

(Conspiracy to Connnit Money

Laundering in Violation of 18

U.S.C. § 1956(a)(l)(B)(i))

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

I dictment

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Ju y, 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, Consphacy to Possess

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

as described in Count One of this Indictment, knowing that the transaction was designed

in whole or in pail to conceal and disguise the nature, location, source, ownership, and

control of the proceeds of the specified unlawfill activity, and that while conducting and

attempting to conduct such financial transactions, knew that the property involved

represented the proceeds of some form of unlawfill activity, in violation of 18 U.S.C.

§ I956(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 hi or about January 2022, and continuously thereafter up to

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

I dictment

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defendants, did knowingly and intentionally combine, conspire, and ag ee with each other

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

and intentionally possess with the intent to dist ib te mixtures o substances containing

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

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

the substance was intended fo 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 f om sometime in o about January 2022 and continuously thereafte up to

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

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

agree together arrd with each other, and with others known and unknown to the G and

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

arrd attempt to conduct financial t ansactions affecting ir terstate ar d foreign conunerce

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

Indictment

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

as described in Count T ree of this 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).

A TRUE BILE

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

CHRISTOPHER T. RAPP

Assistant United States Attorney

GRAND JURY FOREPERSON

Date

Indictment

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA §

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SEALED

No. 4:24-CRNOTICE OF PENALTY

Counts One and Three

Violation: 21 U.S.C. § 846

Penalty: Imprisonment not to exceed 20 years; a fine not to exceed $1 million, or

both; a term of supervised release of at least 3 years.

Speci l Assessment: $100.00

Notice of Pe alty

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Counts Two and Four

Violation: 18U.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

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