knowing and intentional participation in the illegal drug conspiracy charged in Count 1 of

the subject indictment.

Courle.00 bod. $—

RANDALL S, LOCKHART
Attorney for Defendant
Michigan Bar No. P48597

3 West Garden Street, Suite 200
Pensacola, Florida 32502

(850) 432-1418

g - 2B- 2010

Date

Rilly Column

BILLY RAY ROBERSON
Defendant

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Date

Respectfully submitted,

THOMAS P. SWAIM

North Carolina Bar No. 10064
Assistant United States Attorney
Northern District of Florida

21 East Garden Street, Suite 400
Pensacola, Florida 32502-5675
(850)444-4000

6fr/)0

Date


IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF FLORIDA
PENSACOLA DIVISION
UNITED STATES OF AMERICA
vs. Case No. 3:10cr57/MCR-1

BILLY RAY ROBERSON
/

FACTUAL SUMMARY IN SUPPORT OF GUILTY PLEA

The parties agree that the evidence at trial would establish the following:

That the defendant knowingly and intentionally participated with others (both
known and unknown) in the conspiracy identified in Count 1 of the subject indictment,
that the object of that conspiracy was to possess with intent to distribute cocaine, that the
amount of cocaine actually possessed and distributed by that conspiracy exceeded five
kilograms, and that all of this occurred during or within the time frame listed in Count 1
of the subject indictment.

The evidence to establish the defendant’s participation in this conspiracy would
include, but not be limited to, the testimony of two or more cooperating witnesses, the
testimony of multiple law enforcement officers, and the introduction of physical evidence
to include multiple kilograms of cocaine directly associated with the defendant, thousands
of dollars in illegal drug proceeds directly associated with the defendant, photographs

(and law enforcement testimony of surveillance) of drug related meetings in which the

FLED
-06/- 20170
CLERK, US. DISTRICT

COURT, NORTH. DIST. FLA.



defendant participated, and other business records and forensic evidence establishing the
defendant’s participation in the charged conspiracy.

That evidence would include, but not be limited to, that on or about April 21,
2010, the defendant and others transported multiple kilograms of cocaine from Texas to
Pensacola for distribution, and that this was just the latest in a series for trips in which the
defendant, or others on his behalf, transported well in excess of five (5) kilograms of
cocaine from Texas to Pensacola for distribution. The evidence at trial would show that
with regard to the trip on or about April 21, 2010, the defendant went to a location at the
College Trace Apartments, and specifically apartment 1404, for the purpose of off
loading some or all of that cocaine from the vehicle used to transport it from Texas to
Pensacola, and then begin (along with others) the distribution of the off loaded cocaine to
multiple third parties in Pensacola. The evidence at trial would further show that the
defendant would travel to multiple other locations in Pensacola in furtherance of this
conspiracy, and meet with other co-conspirators in furtherance of the distribution of said
cocaine, and that these locations included the Extended Stay America Hotel in Pensacola
(which is directly in front of the College Trace Apartments), and the Motel 6 located on
Plantation Road.

With regard to the Motel 6 location, the evidence would show that the defendant
would, among other things, transport to this location illegal drug proceeds generated from
the sale of kilogram levels of cocaine, and that the defendant would also transport to the

Motel 6 location drug related packaging materials for use by the defendant and others in,

2


among other things, “repackaging” said currency for concealment and transportation
across state lines to Texas, all done in furtherance of the charged conspiracy. As a result
of these activities, the evidence at trial would further show that co-conspirators of the
defendant wrapped (for the purpose of concealment and transportation across state lines)
thousands of dollars of known illegal drug proceeds, using packaging materials supplied
for this purpose by the defendant, and that these co-conspirators then concealed those
proceeds in various locations inside a Freightliner tractor trailer truck that was parked in
the parking lot of the Motel 6. The evidence at trial would further show that the
defendant also maintained in excess of $10,000 in known illegal drug proceeds on his
person, above and beyond any proceeds referenced above.

The evidence at trial would also include the seizure of at least two (2) kilograms
of cocaine at the Motel 6 that is directly associated with the defendant, and that this
cocaine was only a portion of the load transported from Texas to Pensacola for
distribution by the defendant and others on or about April 21, 2010.

As indicated, the evidence at trial would also include additional forensic evidence,
phone and business records, and live testimony of both civilian, law enforcement and

expert witnesses, all of which would establish beyond a reasonable doubt the defendants

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