8ACR 309,0

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UNITED STATES DISTRICT C,URT RECE,YED

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) No.

v.

I,ABRY JONES,

alkla "T,il f,411y,"

MARSIIA FOUNTAIN, and

JAMAR SPENCER, )

. alkJa"Red," "Freckles' ) Under SeaI

COUNT ONE

)

) viotutiorriTitl" 18, united states

) Code, Section 1956(aXB)(A); and

) Title 21, Urrited States Code,

) Sections 841(a)(1) and 846

CUDSEKE]{DAII

rhe spE CIAL JANUARv zo LIcRAND ruRy .6.,#IGIS[RAIE JUreE V' ALOEZ

1. Begirudng on or about August 6,20L8, and continuing until on or aboqt

September 3,20L9, at Chicago, in the Northern District of lllinois, Eastern Division,

and elsewhere,

I,ABRY JONE S, aIH a AT,i1 1-,;,gxly,,

MARSIIA FOUNTAIN, and

JAMAR SPENCER, aIKI; "Red," .,FrecKles,,,

defendants herein, did conspire with each other, and with ofhers known and unknown

to the Grand J*y, to knowingly and intentionally possess with intent to distribute

and distribute a controlled substance, namely- a quantity of a mixture and substence

sonfaining a detectable amount of heroin, a Schedule f Controlled Substance, fo

violation of Title 21, United States Code, Section 8a1(a)(1);

In violation of Title 2L, United States Cod.e, Section 846.
Z. With respect to LARRY JONES, the offense involved 100 grams or more

of a mixture and substance containing a detectable amount of heroin, a Schedule I

Controlled Substance

B. Before I"ARRY JONES committed the offense charged in this eount,

LARRY JOI{ES had a fina1 conviction for a serious .violent felony; namely, a

conviction in Case Number 97 CR 1538201 (Circuit Court of Cook County, Illinois)

for attempted murder, in violation of 720ILCS 5/9-1(aX1), for which he served mote

than 12 months 6f imprisonment.

4. Before JAMAR SPEI\TCER committed the offense charged in this count,

JAMAR SPENCER had a final conviction for a serious drug felony, namely, a

conviction in Case Number 06 CR L750401(Circuit Court of Cook County, Illinois),

for manufacture or delivery of a controlled substance, in violation of 720 ILCS

b70l407,for wh'ich he served- a term of imprisonment of more than 12 months and for

which he was released from serving any term of imprisonment telated to that offense

within 15 years of the commencement of the instant offense-
COUNT TWO

The SPECIAL JANUARY 20Lg GRAND JURY further charges:

On or about August 6, 2018, at Chicago, in the Northern District of Illinois,

Easterp Division, and elsewhere,

LARRY JONES, alWa "Lil Larry,'f and

MARSHA FOUNTAIN,

defendants herein, did knowingly and intentionally distribute a controlled substance,

namely, a quantif,y of a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 841(a)(1), and Title 18,

United States Code, Section 2.

3
COUNT THREE

The SPECIAL JANUARY 2019 GRAND ruRY fiuther charges:

On or about August 6, 2078, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

LARRY JONES, alkl a "Li. La:rry,

defendant herein, with intent to promote the carrying on of specified unlawful

activity, did knowingly conduct and attem.pt to cond"uct a financial transaction

affecting interstate and foreign commerce, involving property represented by a

confidentia-l source to be proceeds of specific unlawfirl activity, namely, the felonious

buyrng and selling and otherwise deali:rg in a controlled substance;

In violation of Title 18, Uuited States Code, Section 1956(a)(3)(A).

4
COUNT FOUR

The SPECIAL JANU-A-RY 2079 GRAND JURY further charges:

On or about August L5, 20L8, at Chicago, in the Northern District of lllinois,

Eastern Division, and elsewhere,

LARRY JONES, alkla"Lil Larry,"

defendant herein, d.id, knowingly and intentionaliy distribute a controlled substance,

namely, a quantity of a mixtrere and substance containing a detectable amount of

heroin, a Schedule I Controlted Substance;

In violation of Title 21, United States Cod.e, Section S41(a)(1), and Title 18,

United States Code, Section 2.

5
COUNT FNTE

The SPECIAL JANUARY 2019 GRAND JURY further charges:

On or about Septembe r L9,201-8, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

I,ARRY JONES, alH a "I'Ll. Larry,"

d.efendant herein, did.knowingly and intentionally distribute a controlled substance,

namely, a quantity of a mixture and substance containing a detectable amount of

heroia, a Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 841(a)(1).

6
COUNT SIX

The SPECIAL JANUARY 2079 GRAND ruRY fwther charges:

7. On or about October 24,2078,' at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

LARRY JONES, aMa "LtJ Larry," arrd.

JAMAR SPENCER, alHa "Red," "Freckles,"

defendants herein, did knowingly and intentionally distribute a controlled substance,

namely, a quantrty of a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance;

In violation of Trtle 27, United States Code, Section 8a1(a)(1), and Title 18,

United States Code, Section 2.

2. Before JAMAR SPENCER committed the offense charged in this count,

JAMAR SPENCER had a fi.na1 conviction for a serious drug felony, name\y, a

conviction in Case Number 06 CR L75O4OL (Circuit Court of Cook County, Illinois),

for manufacture or delivery of a controlled substance, in violation of 720 IL'CS

570l40l,for which he served a term of imprisonment of more than l2months and for

l

which he was released from serving any term 6f imprisonment related to that offense

within 15 years of the commencement of the instant offense.
COUNT SEVEN

The SPECIAL JANUARY 2079 GRAND JURY turther charges:

On or about December 78,2A18, at Chicago, in the Northern District of lllinois,.

Eastern Division, and elsewhere,

I"ARRY JONES, alH a "LiJ Larty,"

defendant herein, did knowingly and intentionally distribute a controlled substance,

namely, a quantity of a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 841(aX1).

I
COUNT EIGHT

The SPECIAL JANUARY 2079 GRAND JURY further charges:

1. On or about February 20, zOLg, at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

I"ARRY JONES, alkl a "Lll Larry,"

' defendant herein, did knowingly and intentionally distribute a controlled substance,

. namely, a quantity of a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance;

In violation of Tit1e 21, United States Cod.e, Section 841(aX1).

2. Before LARRY JONES committed the offense charged in this count,

LARRY JONES had a fi.nat conviction for a serious violent felony, namely, a

conviction in Case Number 97 CR 1538201 (Circuit Court of Cook County, Illinois)

for attempted murder, in violation of 72A ILCS 519-L(a)(L), for which he served more

than 12 months of imprisonment.

I
COUNT NINE

The SPECIAL JANUARY 2019 GRAND JURY turther charges:

'L. about Septembe i 3, 2l]Lg,at Chicago, in the Northern District of

llinois, Eastern Division, and elsewhere,

LARRY JONES, alHa"Lil.Larry," and

MARSHA FOUNTAIN,

defendants herein, did knowingly and intentionally distribute a controlled substance,

namely, a quantif,y of a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance;

In rriolation of fitle 21, United States Code, Section 841(a)(1), and Title 18,

United States Code, Section 2.

2. Before LARRY JONES committed the offense charged in this count,

LARRY JONES 

. 

had a fi.na1 conviction for a serious violent fe].ony, namely, a

conviction in Case Number 97 CR11538201 (Circuit Court of Cook County, Illinois)

for attempted murder, in violation of 720ILCS 5/9-1(a)(1), for which he served more

than L2 months of imprisonment.

10
FORFEITURE ALLEGATION

The SPECIAL JANUARY 2019 GRAND JURY further atleges:

1. Upon conviction of an offense in violation of Title 21, United States Code,

, 

Sections Ba1(aX1) and 846, as set forth in this Indictment, defendants shall forfeit to

the United States of Americ a auy property which constitutes and is d.erived f+o*

proceeds obtained, directly and indirectly, as a resuLt of the offense; and any property

used, and intended to be used, in any manner and part, to commit and facilitate

commission of the offense, as provided in Titte 21, United States Code, Section 8b3(a).

2. Upon conviction of an offense in violation of Title 18, Uuited States Code,

Section 1956, as set forth in this fndictment, def,endant LARRY JONES shall forfeit

to the United .States of A-merica any property involved in such offense, and any

property traceable to such property, as provided in Titte 18, United States Code,

Section 982(a)(1).

3. If any of the property described above, as a result of any act or omission

by defendant: cannot be located upon the exercise of due diligence; has been

transferred or sold to, or deposited with, a third party; has been placed beyond the

jurisdiction qf the Court; has been substantially diminished in value; or has been

commingled with other property which cannot be divided without dfficulty, the

11
. United'states of America shall be entitled to forfeiture of substitute property, as.

provided in fitle 21, United.States Code, Section 853(p).

A TRUE BILL:

FOREPERSON

UNITED STATES ATTORNEY

L2