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-CRJudge

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)

Indictme t

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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 District of Texas and elsewhere.

Samantha Reyes

defendants, did kno ingly 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

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

and including the date of tlris Indictment, in the Easte Distr ict of Texas and elsewhere,

Samantha Reyes

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

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

Violation: 18 U.S.C. § 1956(h)

(Conspiracy to Cor nit 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

Indictment

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Juiy, 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 Dist ibute 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 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 unlawfill 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,

I dictme t

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defendants, did knowingly and intentionally combine, conspire, and a ree 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 mixhires 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 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 Indictment, in the Easte Dist ict of Texas and elsewhere.

defendants, did knowingly, willfiilly, and unlawfiilly combine, conspi e, confederate, and

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

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

and attempt to conduct financial transactions affecting interstate and foreign conunerce

that involved the proceeds of a specified unlawfill 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 Three of this Indictment, lenowing 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 BILL

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

CHRISTOPHER T. RAPP

Assistant United States Atto ey

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 te of supervised release of at least 3 years.

Special Assessment: $100.00

Notice of Penalty

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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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