.,-

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

UNITED STATES OF AMERICA 

V. 

DEXSTIN BRYANT, 

also known as "Dex," 

TREMAINE BRENT, 

also known as "Bud," 

JOHNNIE GRANT, 

also known as "Johnno," 

TEVIN ALVERIO, 

also known as "Tevo," 

JARVIS BLAIR, 

SHAUNTRELL HARRIS, 

also known as "Trell," 

ENRIQUE HOLLINS, 

also known as "Rique," 

SHARONDA HOSEY, 

also known as "Ronda," 

JUSTIN JOHNSON, 

also known as "BB," 

TY JUAN MCDOWELL, 

also known as "Weezy," 

RIKITA MITCHELL, 

ALLEN WASHINGTON, 

also known as "Peanut," 

PAUL WILKINS, 

INA WILLIAMS, 

WONSHON DONAHUE, 

OSHA Y KELLEY, and 

DOROTHY WILLIAMS 

Violations: Title 21, United States 

Code, Sections 846 and 841(a)(l); 

Title 18, United States Code, 

Sections 922(g)(l), 924(c)(l)(A), and 

2 

20 CR 577 

SUPERSEDING INDICTMENT 

JUDGE DOW JR. 

MAGISTRATE JUDGE VALDEZ

FILED 1/28/2021

CLERT S G. BRUTON H A URT K, U.S. DISTRICT CO

1*
COUNT ONE

The SPECIAL JANUARY 2020 GRAND JURY charges:

1. From in or around April 23, 2020 and continuing through in or around

September L, 2020, at Chicago, in the Northern District of Illinois, Eastern Division,

and elsewhere,

DEXSTIN BRYANT, also known as "Dex,"

TREMAINE BRENT, also known as "Bud,"

JOHNNIE GRANT, also known as "Johnno,"

TEVIN ALVERIO, also known as "Tevo,"

sHAUNTRE LL 

Jrffi?JH:t,,*n 

as "rrerr, "

ENRIQUE HOLLINS, also known as "Rique,"

SHARONDA HOSEY, also known as "Ronda,"

JUSTIN JOHNSON, also known as "8B,"

TYJUAN MCDOWELL, also known as "Weezy,"

RIKITA MITCHELL,

ALLEN WASHINGTON, also known as "Peanut,"

PAUL WILKINS,

INA WILLIAMS,

WONSHON DONAHUE,

OSHAY KELLEY, and

DOROTIIY WILIAMS

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

to the Grand Jury, to knowingly and intentionally possess with intent to distribute

and distribute a controlled substance, namely a mixture and substance containing a

detectable amount of fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-piperindinyl]

propanamide), a Schedule II Controlled Substance, a mixture and substance

containing a detectable amount of heroin, a Schedule I Controlled Substance, and a

mixture and substance containing a detectable amount of cocaine base, a Schedule II

Controlled Substance, in violation of Title 21, United States Code, Section 8a1(a)(1);
In violation of Title 21, United States Code, Section 846.

2. With respect to DEXSTIN BRYANT, TREMAINE BRENT, and

JOHNNIE GRANT, the offense involved 400 grams or more of a mixture and

substance containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-

phenylethyl)-4-piperindinyll propanamide), a Schedule II Controlled Substance, 100

grams or more of a mixture and substance containing a detectable amount of heroin,

a Schedule I Controlled Substance, and 28 grams or more of a mixture and substance

containing a detectable amount of cocaine base, a Schedule II Controlled Substance,

in violation of Title 21, United States Code, Section 841(a)(1);

3. With respect to TEVIN ALVERIO, JARVIS BLAIR, SHAUNTRELL

HARRIS, ENRIQUE HOLLINS, STIARONDA HOSEY, JUSTIN JOHNSON,

TYJUAN MCDOWELL, RIKITA MITCHELL, ALLEN WASHINGTON, PAUL

WILKINS, and INA WILLIAMS, the offense involved 40 grams or more of a mixture

and substance containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-

phenylethyl)-4-piperindinyll propanamide), a Schedule II Controlled Substance, a

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

Controlled Substance, and a mixture and substance containing a detectable amount

of cocaine base, a Schedule II Controlled Substance, in violation of Title 21, United

States Code, Section 8a1(a)(1);

4. With respect to WONSHON DONAHUE, OSHAY KELLEY, and

DOROTIIY WILLIAMS, the offense involved a mixture and substance containing a

detectable amount of fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-piperindinyl]
propanamide), a Schedule II Controlled Substance, and a mixture and substance

containing a detectable amount of heroin, a Schedule I Controlled Substance, in

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

5. Before defendant DEXSTIN BRYANT committed the offense charged in

Count One, DEXSTIN BRYANT had a fi.nal conviction for a serious drug felony,

namely, manufacture/delivery of cocaine, in violation of 72O ILCS 5701401(C)(2), in

the Circuit Court of Cook County, Illinois, Docket No. 11 CR 0431401, for which the

defendant served a term of imprisonment of more than 12 months, and for which he

was released from serving any term of imprisonment related to that offense within

15 years of the commencement of the instant offense.

6. Before defendant JOHNNIE GRANT committed the offense charged in

Count One, JOHNNIE GRANT had a final conviction for a serious drug felony,

namely, delivery of controlled substance, in violation of 720 ILCS 570/401(d)(1), in

the Circuit Court of Cook County, Illinois, Docket No. 12 CR 1162401, for which the

defendant served a term of imprisonment of more than 12 months, and for which he

was released from serving any term of imprisonment related to that offense within

15 years of the commencement of the instant offense.

7. Before defendant JUSTIN JOHNSON committed the offense charged in

Count One, JUSTIN JOHNSON had a final conviction for a serious violent felony,

namely, aggravated vehicular hijacking, in violation of 720ILCS 5/18-3, in the Circuit

Court of Cook County, Illinois, Docket No. 16 CR 1242302, for which the defendant

served a term of imprisonment of more than 12 months.
8. Before defendant PAUL WILKINS committed the offense charged in

Count One, PAUL WILKINS had a final conviction for a serious drug felony, namely,

manufacture/delively of heroin, in violation of 720ILCS 57AAO\c)(1), in the Circuit

Court of Cook County, Jllinois, Docket No. 13 CR 1419401, for which the defendant

served a term of imprisonment of more than L2 months, and for which he was released

from serving any term of imprisonment related to that offense within 15 years of the

commencement of the instant offense.
COUNT TWO

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about June 12, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SIIARONDA HOSEY, also known as "Ronda,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[].-(2-phenylethyl)-4piperindinyll propanamide), a Schedule II Controlled

Substance, and a mixture and. substance containing a d.etectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 841(a)(1).
COUNT THREE

The SPECIAL JANUARY kOkOGRAND JURY further charges:

On or about June L3, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

INA WILLIAMS and,

TYJUAN MCDOWELL, also known as "Weezy,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and 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.
COUNT FOUR

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about June 15, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

TEVIN AL\IERIO, also known as "Tevo,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[I--(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 841(aX1).
COUNT FT\M

The SPECIAL JANUARY 2O2O GRAI{D JURY further charges:

On or about June L6, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JUSTIN JOHNSON

also known as "BB,'i

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 8a1(a)(1).
COUNT SD(

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about June 23, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

OSIIAY KELLEY,

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindiny[ propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 8a1(aX1).
COUNT SE\IEN

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about June 24, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

ruSTINJOHNSON,

also known as "BB,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[L-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(a)(1).
COUNT EIGHT

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about June 25, 2020, at approximately lL:54 8.8., at Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

JUSTIN JOHNSON,

also known as "BB,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance cont4ining a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 841(a)(1).
COUNT NINE

The SPECIAL JANUARY 2020 GRAND JURY turther charges:

On or about June 25, 2020, at approximately 6:47 p.m., at Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

JUSTIN JOHNSON,

also known as "BB,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and 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).
COUNT TEN

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about June 27, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

TYJUAN MCDOWELL,

also known as "Weezy,"

defend.ant herein, did knowingly and intentionally distribute a controlled substance,

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and. a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 8al(a)(1) and Title 18,

United States Code, Section 2.
COUNT ELE\TEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about June 29, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SIIARONDA HOSEY, also known as "Ronda,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Sehedule II Controlled

Substance, and 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).
COUNT TTTIEL\TE

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about July 4, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SHARONDA HOSEY, also known as "Ronda,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(a)(1).
COUNT THIBTEEN

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about July 6, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JUSTIN JOHNSON,

also known as "BB,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controll,ed

Substance, and a mixture and substance containilg a detectable amount of heroin, a

Sched.ule I Controlled Substance;

In violation of fitle 21, United States Code, Section 841(a)(1).
COUNT FOURTEEN

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about July 13, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

TYJUAN MCDOWELL,

also known as "Weezy,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Code, Section 841(aX1).
COUNT FIFTEEN

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about August 5, 2020, at approximately 4:10 p.m., Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

ALLEN WASHINGTON,

also known as "Peanut,"

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

namely a mixture and substance containing a detectable amount of cocaine base, a

Schedule II Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(a)(1) and Title 18,

United States Code, Section 2.
COUNT SD(TEEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August 5, 2020, at approximately 5:03 p.m., Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

TYJUAN MCDOWELL,

also known as "Weezy," and,

ALLEN WASHINGTON,

also known as "Peanut,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance, and a mixture and substance containing a

detectable amount of cocaine base, a Schedule II Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(aX1) and Title 18,

United States Code, Section 2.
COUNT SEVENTEEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August 6, 2020, at approximately 12:23 p.D., at Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

PAUL WILKINS and

DOROT}IY WILLIAMS,

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance, and a mixture and substance containing a

detectable amount of cocaine base, a Schedule II Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(aX1) and Title 18,

United States Code, Section 2.
COUNT EIGHTEEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August 6, 2020, at approximately 1:14 p.m., at Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

PAUL WILKINS and

DOROTTIY WILLIAMS,

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

namely a mixture and substance containing a detectable amount of cocaine base, a

Schedule II Controlled Substance;

In violation of fitle 21, United States Code, Section 8a1(a)(1) and Title 18,

United States Code, Section 2.
COUNT MNETEEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August 6, 2020, at approximately 5:31 p.m., at Chicago, in the

Northern District of Illinois, Eastern Division, and elsewhere,

PAUL WILKINS and

DOROTHY WILLIAMS,

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance, and a mixture and substance containing a

detectable amount of cocaine base, a Schedule II Controlled Substance;

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

United States Code, Section 2.
COUNT TWENTY

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August LL, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JOHNME GRANT,

also known as "Johnno,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance, and a mixture and substance containing a

detectable amount of cocaine base, a Schedule II Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(aX1).
COUNT TVYENTY-ONE

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about August l!, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

RIKITA MITCHELL and

JARYIS BI"AIR,

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

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

United States Code, Section 2.
COUNT rTYENTY-TVYO

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about August L2, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

PAUL WILKINS,

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

namely a mixture and eubstance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of fitle 21, United States Cod.e, Section 8a1(a)(1).
COUNT TVTIENTY-THREE

The SPECIAL JANUARY 2020 GRAND JURY turther charges:

On or about August 13, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JUSTIN JOHNSON,

also known as "BB,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and 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).
COUNT TWENTY.FOUR

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about August 25, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

ENRIQUE HOLLINS,

also known as "Rique,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance, and a mixture and substance containing a detectable amount of heroin, a

Schedule I Controlled Substance;

In violation of Title 21, United States Code, Section 8a1(a)(1).
COUNT TWENTY.FIVE

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about September t, 2020 at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JARVIS BI,AIR,

defendant herein, did knowingly possess with intent to distribute a controlled

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

fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II

Controlled Substance, a mixture and substance containing a detectable amount of

heroin, a Schedule I Controlled Substance, and a mixture and substance containing

a detectable amount of cocaine base, a Schedule II Controlled Substance;

In violation of Title 21, United States Code, Section 841(aX1).
COUNT TVTIENTY-SD(

The SPECIAL JANUARY 2020 GRA.ND JURY further charges:

1. On or about September l, 2020 at Chicago, in the Northern District of

Illinois, Eastern Division, and elsewhere,

JOHNNIE GRANT,

also known as "Johnno,"

defendant herein, did knowingly possess, with intent to distribute, a controlled

substance, namely 40 grams or more of a mixture and substance containing a

detectable amount of fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-piperindinyl]

propanamide), a Schedule II Controlled Substance, a mixture and substance

containing a detectable amount of heroin, a Schedule I Controlled Substance, and 28

grams or more of a mixture and substance containing a detectable amount of cocaine

base, a Schedule II Controlled Substance;

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

2. Before defendant JOHNNIE GRANT committed the offense charged in

Count One, JOHNNIE GRANT had a final conviction for a serious drug felony,

namely, delivery of controlled substance, in violation of 720ILCS 570/401(d)(1), in

the Circuit Court of Cook County, Illinois, Docket No. 12 CR L162401, for which the

defendant served a term of imprisonment of more than 12 months, and for which he

was released from serving any term of imprisonment related to that offense within

15 years of the commencement of the instant offense.
COUNT TWENTY-SEVEN

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about September 1,2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JOHNNIE GRANT,

also known as "Johnno,"

defendant herein, knowing that he had previously been convicted of a crime

punishable by a term of imprisonment exceeding one year, did knowingly possess in

and affecting interstate commerce a firearm, namely, (i) a Smith & Wesson, model M

& P Shield, 9 millimeter pistol, bearing serial number JEP475L; (ii) a Walther, model

Creed, 9 millimeter pistol, bearing serial number FCRI061; and (iii) a loaded Smith

& Wesson, model M & P Shield, 9 millimeter pistol, bearing serial number RDP8774,

which firearm had traveled in interstate commerce prior to defendant's possession of

it;

In violation of Tit1e 18, United States Code, Section 922(dG).
COUNT TWENTY-EIGHT

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about September L,2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

JOHNNIE GRANT,

also known as "Johnno,"

defendant herein, did knowingly possess a firearm, namely, (i) a Smith & Wesson,

model M & P Shield, 9 millimeter pistol, bearing serial number JEP475L; (ii) a

Walther, model Creed, 9 millimeter pistol, bearing serial number FCRI061; and (iii)

a Smith & Wesson, model M&P Shield, millimeter pistol, bearing serial number

RDP8774, in furtherance of a drug trafficking crime for which defendant may be

prosecuted in a court of the United States, namely, possession with intent to

distribute a controlled substance, in violation of Title 21, United States Code, Section

841(a)(1), as charged in Count Tlventy Six of this Indictment;

In violation of Title 18, United States Code, Section 92a(c)(1)(A).
COUNT TWENTY-MNE

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about August 29, 2019, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SHAUI{ITRELL FIARRIS,

also known as "Trel1,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance;

In violation of fitle 21, United States Code, Section 841(aX1).
COUNT THIRTY

The SPECIAL JANUARY 2O2O GRAND JURY turther charges:

On or about September 3, 2019, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

SHAUNTRELL HARRIS,

also known as o'Trell,"

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance;

In violation of Title 21, United States Code, Section 8a1(aX1).
COUNT THIRIY.ONE

The SPECIAL JANUARY 2O2O GRAND JURY further charges:

On or about January 8, 2020, at Chicago, in the Northern District of Illinois,

Eastern Division, and elsewhere,

WONSHON DONAHUE,

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

namely a mixture and substance containing a detectable amount of fentanyt (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance;

In violation of Title 21, United States Code, Section 8a1(aX1).
COUNT THIRTY.TWO

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about February 4, 2020, at Chicago, in the Northern District of lllinois,

Eastern Division, and elsewhere,

WONSHON DONAHUE,

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

namely a mixture and substance containing a detectable amount of fentanyl (Nphenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled

Substance;

In violation of Title 21, United States Code, Section 8a1(a)(1).
FORFEITURE ALLEGATION

The SPECIAL JANUARY 2020 GRAND JURY further alleges:

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

Section 841 as set forth in this Indictment, defendant shall forfeit to the United States

of America any property which constitutes and is derived from 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 Title 21, United States Code, Section 853(a).

2. In addition, defendant shall forfeit to the United States of America, any

firearm, magazine, and ammunition involved in and used in any offense of conviction,

as provided in Tit1e 18, United States Code, Section 924(d)(1) and Title 28, United

States Code, Section 1461(c);

3. The property to be forfeited includes, but is not limited to:

a. $6,450 in United States Currency;

b. a Smith &Wesson, model M &P Shield,9millimeterpistol,

bearing serial number JEP475L, and associated ammunition;

c. a Walther, model Creed, 9 millimeter pistol, bearing serial

number FCRI061, and associated ammunition;

d. a Smith &Wesson, modelM & P Shield,9millimeterpistol,

bearing serial number RDP8774, and associated ammunition;

e. three firearm magazines;

t. ammunition; and
g. the telephone number (312) 447-4490

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

by a 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 of the Court; has been substantially diminished in value; or has been

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

United States of America shall be entitled to forfeiture of substitute property, as

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

A TRUE BILL:

FOREPERSON

Signed by Timothy J. Storino on behalf of the

UMTED STATES ATTORNEY