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Topic: Howard Boys Trial and song "Pat Around"
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untanglingwebs
El Supremo

How to Make a RICO Case Against Gangs
It isn’t easy using this “nuclear option” against gangsters, but nothing you can legally do will hit them harder.
9
November 20, 2008 | by Richard Valdemar - Also by this author

One morning in May 1992, Ana Lizarraga hurriedly packed a few things into her van as she prepared to drive to the funeral of her mother. Lizarraga was a 49-year-old gang counselor for the Los Angeles Community Youth Services. She was an exceptional counselor, having relatives who were gang members in both Sureño and their rivals, the Norteño Gangs.

Lizarraga's gang knowledge had landed her a position as a technical advisor on the Edward James Olmos' film, "American Me." She had even played a small part in the film.

However unknown to most of Los Angeles, Olmos' movie had disrespected and offended the Mexican Mafia prison gang by depicting the fictional prison rape of one of its respected founders. This was cause enough for the other two technical advisers both of whom were Mafia members, "Rocky" Luna and "Charlie Brown" Manriquez, to be murdered. Later In covertly monitored Mexican Mafia meetings, I would learn that Olmos himself was marked for death.

On Lancaster Avenue, in the shadow of the Los Angeles General Hospital USCMC, Lizarraga stood on the driveway near the driver's door of her van. Her son was on the passenger side getting ready to open the door. They were startled to see two males walk quickly up her driveway and approached Ana. The men were dressed in dark clothing and their faces were covered with stocking masks.

Before Ana Lizarraga could react, she was cut down by multiple shots from both gunmen. The masked shooters stood over her and fired point blank, hitting her 13 times. Like the death scene in some gangster movie Lizarraga's body jerked and twisted in slow motion as the bullets ripped and tore through her and impacted on the driveway.

A lone LAPD Officer, Thomas Lira, happened to be passing by in his patrol car and witnessed the cold-blooded shooting. As the two masked suspects fled, one of them fired at the LAPD Officer. Units responding to Lira's request for assistance captured one of the shooters, Jose "Joker" Gonzales, a Big Hazard gang member. But the unidentified second shooter escaped.

"Joker" Gonzales was eventually convicted of the murder of Ana Lizzaraga, gang worker and grandmother, under California state laws.

And since the killing was ordered by the Mexican Mafia prison gang, his conviction later became one of the predicate acts used to convict 21 of 22 Mexican Mafia Members and associates in a 1995 federal criminal conspiracy trial. This was the first time the Racketeer Influenced and Corrupt Organization (RICO) statutes were used against a "violent gang" in California.

The federal RICO law was enacted in 1970 and codified as Chapter 96 of Title 18 of the U.S. Code. It was intended to combat traditional organized crime groups and Italian Mafia figures. Some suggest that the name RICO was a clever reference by the author of the law, G. Robert Blakey, to a character played by Edward G. Robinson in the classic gangster movie "Little Caesar."

The genius of the RICO statutes is that they work perfectly against organized criminal gangs. Any member of any criminal enterprise can be charged with RICO racketeering if he can be shown to have committed two of 27 federal or eight state charges within a 10-year period as part of the enterprise. A person can be charged even if that person did not directly commit the crime but only agreed to the commission or conspired with the perpetrators in any way.

Guilty verdicts result in sentences of 20 years per count and fines up to $25,000. In addition a pre-trial financial restraining order can be obtained to seize all the defendant's assets and forfeitable property. This prevents the organization from liquidating the proceeds of its racketeering enterprise before a guilty verdict can be obtained. Even the private individuals victimized by the enterprise can file civil suits to recover treble damages.

The very definition of a criminal gang begs prosecution under RICO. A gang is a group of three or more persons who have a common identifying sign, symbol or name, and whose members individually or collectively engage in a pattern of criminal activity for the furtherance of the gang.

Gang members know that RICO can ruin their lives. The Mexican Mafia in particular understood the implications of the RICO act. They purposely avoided a formalized structure, hierarchy, a written constitution, or codified code of conduct to avoid the fate their mentors, the Italian Mafia, suffered under RICO prosecutions.

State conspiracy laws and the federal RICO act are the tools tailor-made to combat criminal gangs. In my opinion the highly touted gang injunctions are difficult and costly to establish. They are extremely manpower intensive and usually duplicate gang-limiting conditions already available through good probation and parole conditions. Some of them are unnecessarily restrictive and could result in negative case law decisions.

When physical and electronic surveillance tactics, good informant development and the cooperation of narcotics units, parole and probation agencies are used to target violent criminal gangs, prosecution under state conspiracy and the federal RICO are the way to go.
But there are hurdles to jump.

First, I would solicit a memo of understanding with as many law enforcement entities as possible in the affected jurisdictions. This memo would form a multi-jurisdictional gang task force targeting the gang as a criminal enterprise and enumerate the level of cooperation each entity was willing to commit. How many investigators? How much of the budget? Who would prosecute?

This brings us to one of the RICO hurdles, getting the U.S. Attorney's Office to consider a RICO prosecution. There seems to be no clear guidelines as to when a U.S. Attorney should prosecute a case under federal laws.

Each local USA Office seems to have great autonomy in this consideration. In this case smaller cities may have the advantage since the Assistant U.S. Attorney in these offices might not be as busy as in large cities. In my experience some Assistant U. S. Attorneys are looking for "sexy" cases to fill out their political résumés and might respond to some heavy lobbying by a police chief or local sheriff.

The recent highly publicized RICO case against the Aryan Brotherhood is an example of how these cases work. That case was developed by detectives "Barnie" Barnett and Roger Harryman from the Prison Gang Section of the Los Angeles Sheriff's Department. It was updated and advanced over the years by LASD Detectives Ed Godfrey, Mark Lillianfield and Mike McCravy, but the L.A. U.S. Attorneys Office took no interest in it until it was presented to them by federal agents from the BATF. So maybe you might need a federal agency to sponsor your task force in order to get the U.S. Attorney on board.

A RICO trial usually consists of two phases.

First you must prove the criminal organization or enterprise exists.

Secondly, you must prove that those charged in the indictment have each committed at least two acts of racketeering activity, one within the recent proscribed period and the second within 10 years. These are called "predicate acts" and they show a pattern of criminal acts as opposed to individual acts if they "have the same or similar purpose, results, participants, victims, or methods of commission, or otherwise are interrelated by distinguishing characteristics and are not isolated events."

The mere indictment of individuals under the RICO statutes usually results in many of the defendants pleading guilty to lesser charges. In the Mexican Mafia RICO of 1995, 22 defendants were originally indicted, all but 13 plead guilty. The trial resulted in 12 convictions and only one acquittal.

The plot-driving device in the recent Batman movie, "The Dark Knight," is the Gotham District Attorney's use of the RICO act against the leaders of Gotham City's criminal elite. But it doesn't have to be a fantasy. You can do this in the real world against real-world gangsters. You can form a gang task force against your local criminal organizations and be a real hero.
Post Sat Jun 28, 2014 8:48 am 
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untanglingwebs
El Supremo

RICO convictions send several Hawaiian Gardens gang members to federal prison
Jose Luis Orozco sits in court during his arraignment for murder of Los Angeles County sheriff's deputy Jerry Ortiz. (AP photo)

Streetgangs.com Staff
January 11, 2011
LOS ANGELES – The lead defendant in a federal RICO indictment that was brought as part of the nation’s largest-ever gang sweep was sentenced today to 30 years in federal prison for helping coordinate the racketeering activities of the Varrio Hawaiian Gardens street gang and distributing large quantities of narcotics.

George Manuel Flores, also known as Boxer, 43, was sentenced by United States District Judge Dale S. Fischer, who is presiding over the 57-defendant racketeering indictment that was the centerpiece of “Operation Knock Out” in 2009.

Flores was the lead defendant in the RICO indictment, a longtime member of the Hawaiian Gardens gang, and a sometimes “shot-caller” who was able to issue orders to other gang members and collect “taxes” from drug dealers.

Flores pleaded guilty on March 26, 2010 to five counts: racketeering conspiracy; conspiracy to distribute and possess with the intent to distribute crack cocaine, methamphetamine, heroin, and marijuana; two counts of possession with the intent to distribute heroin; and being a felon in possession of ammunition.

In court documents filed in relation to today’s sentencing hearing, prosecutors pointed out that Flores was a longtime drug dealer, who was “a blight on the city of Hawaiian Gardens. For over a decade, [Flores] ran what are fairly described as several illegal drug ‘supermarkets’ from houses in Hawaiian Gardens that were open 24 hours a day, seven days a week, at which his customers could buy the drug of their choice.”

In relation to the narcotics conspiracy count to which he pleaded guilty, Flores specifically admitted that he was responsible for the distribution of more than 30 kilograms of heroin, more than 4.5 kilograms of crack cocaine, more than 1.5 kilograms of pure methamphetamine, more than 15 kilograms of narcotics that contained methamphetamine, and more than 100 kilograms of marijuana.

“Mr. Flores was a leader in a criminal enterprise that tormented the City of Hawaiian Gardens for decades,” said United States Attorney André Birotte Jr. “The law-abiding residents of Hawaiian Gardens deserve safe neighborhoods, and this prosecution will go a long way toward restoring order to a community that was once under the thumb of criminal thugs and drug dealers.”

Jose Luis Orozco sits in court during his arraignment for murder of Los Angeles County sheriff's deputy Jerry Ortiz. (AP photo)
The racketeering case of United States v. Flores, et al. was one of seven multi-defendant indictments issued by federal grand juries. During Operation Knock Out, authorities seized approximately 33 pounds of methamphetamine, additionally quantities of other narcotics and approximately 125 firearms.

“This is a perfect example of how federal laws can be used to impact gang crime,” said John A. Torres, Special Agent in Charge of the ATF Los Angeles Field Division. “Flores’ sentencing today in federal court is the final nail in the coffin for these gang members who prey on the weak and defenseless. The neighborhood of Hawaiian Gardens is much safer with Flores in prison for a long, long time.”

The investigation into the Varrio Hawaiian Gardens (VHG) gang began after the fatal shooting of Los Angeles Sheriff’s Deputy Jerry Ortiz, who was gunned down on June 24, 2005 by a gang member he was attempting to arrest on suspicion of shooting an African-American man. While the gang member, Jose Orozco, was quickly apprehended and currently sits on death row, the shooting of Deputy Ortiz sparked an investigation that culminated with two takedowns in 2009 that saw approximately 170 gang members and associates being taken into custody on federal charges.

Steven Martinez, Assistant Director in Charge of the FBI in Los Angeles, said: “The prosecution of VHG members ensure they no longer pose a threat to residents of the Hawaiian Gardens community, in which Flores and his gang associates formerly thrived. The prosecution also renders justice for the family of deputy Jerry Ortiz, whose senseless death was not forgotten.”

Some defendants charged as a result of the investigation are awaiting trial, but many have pleaded guilty, with sentences as long as nearly 25 years in prison being imposed. Some of the significant sentences include:

• Marcos Romero, also known as Tortas, 45, was sentenced on November 22, 2010 to 291 months in prison, which is running consecutively to a nearly four-year sentence he has already served on a federal immigration charge. According to sentencing papers filed by the government, Romero was one of the primary wholesalers of narcotics to the Hawaiian Gardens gang members.
• Brian Viramontes, also known as Looney, 36, was sentenced on September 13, 2010 to 210 months in federal prison. Viramontes, who was a shot caller in the gang, pleaded guilty to distributing methamphetamine and possessing a firearm in relation to his drug trafficking activities.
• Edward Solarzano, also known as Little Turtle, 32, was sentenced on November 29, 2010 to 188 months in prison after pleading guilty to racketeering conspiracy and drug trafficking conspiracy.
• Frank Wayne Henley, also known as Spanky, 40, was sentenced on November 1, 2010 to 262 months in prison. According to court documents, Henley is a member of the Nazi Low Riders, who supplied members of the Hawaiian Gardens gang with methamphetamine and heroin.

Operation Knock Out was an investigation into Varrio Hawaiian Gardens conducted by the Los Angeles High Intensity Drug Trafficking Area (HIDTA) Task Force, which is comprised of agents and officers with the Los Angeles County Sheriff’s Department; the Drug Enforcement Administration; the Federal Bureau of Investigation; the Bureau of Alcohol, Tobacco, Firearms and Explosives; U.S. Immigration and Customs Enforcement’s Homeland Security Investigations; and IRS – Criminal Investigation.
Timothy J. Landrum, DEA Special Agent in Charge in Los Angeles, commented:

“Today’s sentencing sends a clear message that DEA will to continue to work with our law enforcement partners to ensure that those responsible for propagating violence and distress in our neighborhoods are brought to justice.”

Leslie P. DeMarco, Special Agent in Charge of IRS – Criminal Investigation’s Los Angeles Field Office, stated: “Today’s sentencing of Varrio Hawaiian Gardens gang member George Flores to 30 years in federal prison demonstrates that crime does not pay. Flores’ sentencing brings to a close this chapter in the history of the community of Hawaiian Gardens and is representative of the successful implementation of federal laws in the investigation and prosecution of gang crime.”

Claude Arnold, Special Agent in Charge for ICE’s Homeland Security Investigations in Los Angeles, said: “The 30-year sentence for Mr. Flores should serve as a stern warning about the consequences awaiting gang members whose actions breed fear and violence in our communities. ICE’s Homeland Security Investigations will continue to work closely with its federal and local law enforcement counterparts to attack and dismantle these dangerous criminal organizations and see that those involved are brought to justice.”
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LEGAL ENTERTAI
- See more at: http://www.streetgangs.com/features/011110_hawaiian_gardens#sthash.gQJI3ibe.dpuf
Post Sat Jun 28, 2014 8:57 am 
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untanglingwebs
El Supremo

FBI — Two TTP Bloods Members Sentenced to Federal Prison ...
www.fbi.gov/baltimore/press-releases/2010/ba070910.htm Cached
Evidence was introduced that Mouzone and Fleming regularly met with other TTP gang ... members against rival gang ... of the RICO conspiracy and ...
How to Make a RICO Case Against Gangs - Gangs - POLICE Magazine

28 ALLEGED MEMBERS OF VIOLENT ‘TTP BLOODS’ GANG INDICTED ...
www.streetgangs.com/news/022808_ttp_bloods_indictment Cached
28 alleged members of violent ‘ttp bloods’ gang indicted on federal racketeering, drug and gun charges that may bring life in federal prison


www.atf.gov/press/releases/2010/06/062310-balt-ttp... Cached
062310 Balt Ttp Leader Sentenced On Racketeering.html /). ### Footer. Bureau of Alcohol, Tobacco, Firearms and Explosives United States Department of ...

28 Alleged Members of Violent 'TTP Bloods' Gang Indicted on ...
www.reuters.com/article/2008/02/25/idUS236386+25-Feb... Cached
28 Alleged Members of Violent 'TTP Bloods' Gang Indicted on Federal Racketeering, Drug and Gun Charges That May Bring Life in Federal Prison Indictment of ...

28 Alleged Members of Violent 'TTP Bloods' Gang Indicted on ...
www.prnewswire.com/news-releases/28-alleged-members-of... Cached
re> BALTIMORE, Feb. 25 /PRNewswire-USNewswire/ -- 28 Alleged Members of Violent 'TTP Bloods' Gang Indicted on Federal Racketeering, Drug and Gun Charges.

FBI — Final TTP Bloods Defendants Sentenced to Prison
www.fbi.gov/baltimore/press-releases/2011/final-ttp... Cached
TTP Bloods, a violent gang, ... crimes committed by gang members against rival gang members ... have been convicted of the RICO conspiracy and
Post Sat Jun 28, 2014 9:08 am 
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untanglingwebs
El Supremo

The issue of co-defendant statements to the FBI has been a real issue in this case. On June 12th the attorney for Jonathan Oldham, John Minock, filed a motion regarding these statements. The precipitating event was two rap videos that were played in court by the government on June 10th. The videos were recorded by co-defendant Leon Gills and posted on the internet on March 2014. I was concerned that this was allowed to occur in the Midland County Jail.

A. Gills" Statements (typed posts on Gills facebook page)

-"stop snitching and tell yo niggas to wit they broke ass
gloc glam entertainment March 10, 2014


-"have anyone seen keke this .. blossom rat ass ima boss u betta hope I don't get out ..... rat ass I had love for u bro email me
March 9, 2014

-"I swear I cant wait until I touchdown niggas gon touchback.... if these nasty ass bitches very wit rt ass niggas they rats too....
murdaville mafia March 9, 2014
Post Tue Jul 01, 2014 4:54 pm 
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untanglingwebs
El Supremo

continued:
-"this lee lee the gunman coming home soon vulgar language the feds free jig real nigga forever....vulgar language the south them nigg rat ... im taken over tat rap shit when I coe home I got fire for the streets... trial is May 12th b ther.. f.a and lil malc rats vulgar language them nigga."
March 9, 2014


Page 3 of the brief in support of the motion states "there are various rap videos on the site. In them, Gills is wearing Midland County jail attire and headphones."

*Video "free the gunman-gloc glam entertainment
"I got murder on my mind, murder on my heart. I will murder all those rat niggas at night. I'm the gunman from the Murda Ville and we murder niggas on sight" March 9, 2014

-"R.A.T.S," video lyrics
"Your momma a rat, your daddy a rat, kidnap your sons and your daughters , even your kids, they all rats. Blossom a rat, Malcom a rat. Miss Hannah freaky as hell bro said he stayed in that cat. Markus no different than Brandon, I hope (unintelligible) get wacked.... From Howard to the Drive, free Rell and free I. Feds tryin' to give me life, i you tell you gonna die. Malcolm is a rat, and Markus is a rat, and that's in black and white, so they can't take that back." March 10, 2014
Post Tue Jul 01, 2014 5:15 pm 
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untanglingwebs
El Supremo

Minock argues that under the Federal Rule of Evidence 801(d)(2)(E0 that " a statement by a co-conspirator during the course and in furtherane of the conspiracy " is not hearsay when introduced against a party. Minock cited three prerequisites that must be established by a preponderance of the evidence (1) that a conspiracy existed, (2) that a defendant against whom the statement is offered was a member of the conspiracy, and (3) that the statement was made during the course and in furtherance of the conspiracy, Unted States v Conrad, 507 F.3d424, 429 (6th Cir. 2007): United States v Warman, 578 F.3d(6th Cir. 2009)

Minock argued the statements of Gills were not in furtherance of the conspiracy. He also argued that giving limiting statements to the jury might not be "intrinsically ineffective".

Document #624
Post Tue Jul 01, 2014 5:33 pm 
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untanglingwebs
El Supremo

Docuument # 637 Government's response to Miock re: co-defendant statements

The government requested Minock's request to sever his client be denied. All of the other defendants, except Gills, also joined in Oldham's motion.

"On or about March 11, 2014, the government was made aware that defendants Jatimothy Walker, Jonathan Walker, Johnathan Oldham and leon Gills were accessing Facebook.com via a computer at the Midland County Jail.

The respective Facebook sites, with the exception of Jatimothy Walker,contained ecently posted information including photographs of defendantsand others flashing the Howard Boys/Murda Ville gang sign: photographs referencing Murda Ville and Howard Blocks; posts referencing threats to cooperating witnesses and their family members; posts containing PDF copies of over 20 statements of cooperating witnesses; and rap videos referencing the enterprise and their family members."
Post Tue Jul 01, 2014 5:55 pm 
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untanglingwebs
El Supremo

"On February 9, 2014, Oldham posted in regards to witnesses statements, 'I THIS .. DEVASTATED OVER THESE NIGGAS PAPERWORK ..BLACK AND WHITE DON'T LIE...SMH. YET AND STILL I REMAIN HUMBLE. " Other responded to this post.

March 11, 2014- Oldham sent a message to Gills asking Gills to "put something on there about a real nigga like me" and Gills agreed.

march 12, 2014, Oldham sent a photograph and clled it "feds dirty ass hell took picture when I first got something to change my life for...". Gills responded with "damn baby they is dirty fucked being indicted"
Post Tue Jul 01, 2014 6:05 pm 
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untanglingwebs
El Supremo

.March 12, 2014, Gills posts '' loyalty is my lifestyle...its not a act... its real... loyalty is thicker than blood" Oldham posted "real shit".

March 12,2014, fter Gills got Oldhams permission to post a photograph, Gills posted the photo of Oldham and Sean Cunningham flashing the "MV" , the Howard Boys/Murda Ville gang sign.

March 12, 2014, after a series of posts by Gills about coperting witnesses, Gills posted 'We ned t be lke Cali niggas and kill cops... mvM (Mudra Ville mafia) we da mf mob".

The government stated they believed Oldham's response characterized the
" nature of the conspiracy and the mutual understanding among conspirators, "bro wats understand (understood) don't have to be explained."

On March 11, 2014, "Gills and Jonathan Walker discussed a motion to reclude evidence of other acts which was pending at the time".
Post Tue Jul 01, 2014 6:20 pm 
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untanglingwebs
El Supremo

The government notified the defense on March 20, 2014 in their second amended notice of other acts (#429) regarding their intent to use these aforementioned information at trial.The also sent all counsel the screen shots of the posts as well as copies of Gills rap videos.

The government stated the motion was untimely as the defendants were notified of the government's intent to use this material on March 20, 2014. The defense waited nearly three months to make the motion to sever..
Post Tue Jul 01, 2014 6:34 pm 
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untanglingwebs
El Supremo

Pg 5 of 17 THE EVIDENCE CONTAINED ON GILLS FACEBOOK SITE IS EVIDENCE OF THE EXISTENCE OF THE CONSPIRACY AND IS THEREFORE ADMISSABLE AGAINST ALL DEFENDANTS

"An association-in-fact enterprise is a group of people associated together for a common purpose of engaging in a course of conduct. Boyle v United state, 566 U.S. 938, 946 (2009). Among the various purposes of the Howard Boys enterprise is "protecting... the authority, reputation, and standing of the Howard Boys through the use of intimidation [and] threats... and [p]rotecting the enterprise and its members and associates from detection, apprehension: and prosecution by law enorcement authorities." (R. 191: Indictment Count 1, paragraph 3,6)
Post Tue Jul 01, 2014 6:46 pm 
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untanglingwebs
El Supremo

"Moreover, the means and methods of the enterprise include the intimidation of witnesses 'to deter them from providing information to law enforcement and to enforce a 'No snitching' code'. (r. 191 Indictment, Count One paragraph 13)"

The government defended the use of of the Facebook posts by Gills as aa furtherance of the purposes of the enterprise by attempting to discourage witnesses from testifying. Malcolm Evans now declines to testify because of threats aginst his sister and family. Other defendants joined Gills in this threatening activity.

"The 'various criminal activities' of rcketering confederates are admissable against each defendant to prove (l) the existence and nature nature of the RICO enterprise and nature of the RICO enterprise and (ll) a pattern of racketeering activity of each defendant by providing the requisuite relationship and continuity of illegal activities." United States v DiNome, 954 F 2d 839, 844 (2ndCir. 1992)
Post Tue Jul 01, 2014 7:04 pm 
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untanglingwebs
El Supremo

The government stated that because they were required to prove the existence of a racketeering enterprise, the evidence of witness intimidation, if they challenge the enterprise, would be admissible even in separate trials. United states v Escobar, 462 Fed Appx, 58,66 (2nd Cir. 2012)

"The Sixth Circuit has permitted the admission of such evidence of uncharged acts, both where committed by a defendant and where committed by co-conspirators. See united States v Fowler, United State v Hohn, 293 Fed Appx., 395, 402-403 (6thCir. 2008) The Government addressed this issue extensively in two filings related to the introduction of other acts of evidence. (R. 429;R 465). Moreover the Court issued a lengthy opnion addressing this precise issue (R 572)."
Post Tue Jul 01, 2014 11:39 pm 
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untanglingwebs
El Supremo

In this 17 page brief, the government describes a similar situation within the prosecution of the Baltimore gang, known as the Tree Top Piru (TTP), a subset of a Blood gang. United States v Thomas, 490 Fed Appx. 514, 516 (4th circuit. 2012).

Minock, on Oldham's behalf, alleged the conspiracy ended in 2012, when the defendants were arrested and incarcerated. The government's position is "[A] RICO conspiracy is complete... only when the purposes of the conspiracy have either been accomplished or abandoned." United States v Salerno,868 F.2d. 524, 534, (2nd Cir. 1989) more citations available.
Post Tue Jul 01, 2014 11:56 pm 
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untanglingwebs
El Supremo

Pg 11 of 17

The government states the objects of the conspiracy were not completed with the arrest of the defendants and cites their actions after their arrests.

R 392: Notice of other acts paragraph 12 -The fight between members of the Howard Boys and the T-Hood at the Midland County jail on April 22, 2013,

R 429: Second amended notice ofother acts paagraph 14- Wtness tampering, threats, intimidation and other enterprise evidence via Facebook, January 2, 2014-March 18, 2014.

"A statement is made in furtherance of a conspiracy if it was intended to promote conspiratorial objectives; it need not actually further the conspiracy." United States v Carter, 14 F.3d 1150, 1156 (6th Cir. 1994) There is no question that Gills statements threatening witnesses were intended to promote the conspiratorial objectives of the enterprise, Because Gills statements were made in the the course and furtherance of the enterprise of the conspiracy, these statrments are admissable against all defendants."
Post Wed Jul 02, 2014 6:51 am 
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