Case Document 163 Filed 05/06/15 PageslmmaICE'a?g?tm407 .12) u} 1 I IN THE UNITED STATES DISTRIC COURTMAY .. 5 FOR THE NORTHERN DISTRICT OF TEXAS NORTHERN DISTRICT OF TEXAS FILED 0 DALLAS DIVISION CLERK, U.S. DISTRICT COURT RV Deputy UNITED STATES OF AMERICA TO BE FILED UNDER SEAL V. GAS PIPE, INC. (7) AMY LYNN, INC. (8) GERALD SHULTS (9) (aka. ?Jerry?) AMY HERRIG (10) ROLANDO ROJAS (11) (aka. RYAN YARBRO (12) JOHN BEN LINCOLN (13) CHRISTOPHER RAMIREZ (14) DANIEL CAILLIER (15) KENDALL SILVA (16) ELIZABETH WALKER (17) BRIDGETT PAYROT (18) JASON LYON (19) JOSHUA CAMPBELL (20) MICK CLARK (21) BRANDON SCHUBERT (22) JACKIE RANDALL-KING (23) HOLLY PATTERSON (24) BRAD BADER (25) TRAVIS LOVIN (26) JENNIFER DUNN (27) PATRICK SHANAHAN (28) CAROLYN SETTLEMIRE (29) TOM SCOTT (30) RAPIDS CAMP LODGE, INC. (31) RIDGLEA COMPLEX MANAGEMENT, INC. (32) Criminal N0. (Supersedes Indictment returned on August 5, 2014) SUPERSEDING INDICTMENT The Grand Jury Charges: Indictment Page 1 Case Document 163 Filed 05/06/15 Page 2 of 38 PageID 408 Introduction 'At all times material to this indictment: 1. Gerald ?Jerry?) Shults owned Gas Pipe, Inc. and Amy Lynn, Inc., which maintained locations throughout Texas and New Mexico, including locations in Austin, Albuquerque, Arlington, Dallas, Fort Worth, Garland, and Plano. I 2. Gas Pipe, Inc. and Amy Lynn, Inc. sold millions of dollars in products commonly referred to as ?spice? in the ?designer? or drug market. ?Spice? is a common street term referring to a smokeable organic plant substance that has been combined with a cannabinoid. The cannabinoids contained in the ?spice? distributed by Gas Pipe, Inc. and Amy Lynn, Inc. was typically considered Schedule I controlled substances or controlled substance analogues. In an effort to perpetuate an illusion of legality surrounding their distribution of ?spice,? Gas Pipe, Inc. 39 CC and Amy Lynn, Inc. marketed and sold these products as ?herbal incense, potpourri,? or ?aroma therapy products,? to the general public throughout Texas and New Mexico, claiming these products were ?not for human consumption.? 3. Amy Herrig is the daughter of Gerald ?Jerry?) Shults and was the ?the lady who [ran] the Gas Pipe.? i 4. Rolando Rojas served as the General Manager of Gas Pipe, Inc. and was the ?person in charge? when Amy Herrig and Gerald erry?) Shults were not available. 5. Ryan Yarbro served as the buyer for Amy Lynn, Inc. and Gas Pipe, Inc. and was in charge of Amy Lynn, Inc.?s manufacturing of ?spice.? Indictment Page 2 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 3 of 38 PageID 409 6. John Ben Lincoln, Christopher Ramirez, and Daniel Caillier served as area managers of various Gas Pipe, Inc. retail locations. 7. Kendall Silva served as the store manager for the Gas Pipe, Inc. retail location located at 4420 Maple, Dallas, Texas. 8. Elizabeth Walker served as the store manager for the Gas Pipe, Inc. retail location located at 9515 Skillman, Dallas, Texas. 9. Bridgett Payrot served asithe store manager for the Gas Pipe, Inc. retail location located at 1407 N. Collins, Arlington, Texas. 10. Jason Lyon served as the store manager for the Gas Pipe, Inc. retail location located at 701 E. 5th Street, Austin, Texas. 11. Joshua Campbell served as the store manager for the Gas Pipe, Inc. retail location located at 8508 Central SE, Albuquerque, New Mexico. 12. Mick Clark served as the store manager for the Gas Pipe, Inc. retail location located at 8519 Burnet Road, Austin, Texas. 13. Brandon Schubert served as the store manager for the Gas Pipe, Inc. retail location located at 18613 Marsh Lane, Dallas, Texas; 14. Jacqueline Randall-King served as the store manager for the Gas Pipe, Inc. retail location located at 1725 N. Central, Plano, Texas. 15. Holly Patterson served as the store manager for the Gas Pipe, Inc. retail location located at 6033 Camp Bowie, Fort Worth, Texas; 16. Brad Bader served as the store manager for the Gas Pipe, Inc. retail location located at 2053 W. Northwest Highway, Dallas, Texas; Indictment Page 3 Case Document 163 Filed 05/06/15 Page 4 of 38 PageID 410 17. Travis Lovin served as the store manager for the Gas Pipe, Inc. retail location located at 130 E. Bardin Road, Arlington, Texas; 18. Jennifer Dunn served as the store manager for the Gas Pipe, Inc. retail location located at 5707 Broadway, Garland, Texas; 19. Patrick Shanahan served as the store manager for the Gas Pipe, Inc. retail location located at 8521 Golf Course, Albuquerque, New Mexico; 20. Carolyn Settlemire served as the of?ce manager and bookkeeper for Amy Lynn, Inc. and Gas Pipe, Inc. 21. Thomas Scott served as a general contractor for Gas Pipe, Inc. and Amy Lynn, Inc.?s building projects. In addition, Thomas Scott provided supplies for the sole purpose of manufacturing and producing the ?spice? distributed by Gas Pipe, Inc. and Amy Lynn, Inc. 22. The United States Food and Drug Administration is the federal agency of the United States charged with protecting the health and safety of the American public by ensuring that drugs sold to the public are safe and effective for their intended uses and that the drugs bear labeling that enables consumers to use them in a safe manner. The responsibilities include regulating the manufacturing, labeling, and distribution of drugs shipped or received in interstate commerce. 23. To legally introduce, deliver for introduction, or cause the delivery or introduction for delivery of a drug into interstate commerce, all persons are required to comply with all applicable provisions of the federal Food, Drug and Cosmetic Act Indictment Page 4 Case Document 163 Filed 05/06/15 Page 5 of 38 PageID 411 and its implementing regulations found in Title 21 of the Code of Federal Regulations. 24. Under the FDCA, drugs are de?ned as, among other things, articles intended for use in the cure, mitigation, treatment or prevention of disease in people; articles (other than food) intended to affect the structure or function of the human body; and articles intended for use as components of drugs. The FDCA prohibits the introduction of misbranded drugs into interstate commerce. 25. A drug is misbranded unless its labeling bears adequate directions for all intended uses under 21 U.S.C. 352(f). Drugs that lack any directions for use are misbranded per se. A drug is also misbranded if its labeling is false or misleading in any particular way under 21 U.S.C. 352(a). False assertions in labeling accompanying - products during importation can also render a drug misbranded. 26. It is a Violation of 21 U.S.C. 331(a) to cause the introduction and deliVery for introduction into interstate commerce any drug that is adulterated and misbranded. Indictment Page 5 Case Document 163 Filed 05/06/15 Page 6 of 38 PageID 412 Count One Conspiracy to Defraud the United States (Violation of 18 U.S.C. 371) 27. The allegations in paragraphs 1 26 are incorporated by reference as if fully rewritten herein. 28. From at least on or about March 1, 2011 and continuing until on or about June 4, 2014, in the Northern District of Texas and elsewhere, the defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, Amy Herrig, Rolando Rojas, Ryan Yarbro, John Ben Lincoln, Christopher Ramirez, Daniel Caillier, Kendall Silva, Elizabeth Walker, Bridgett Payrot, Jason Lyon, Joshua Campbell, Mick Clark, Brandon Schubert, Jackie Randall-King, Holly Patterson, Brad Bader, Travis Levin, Jennifer Dunn, Patrick Shanahan, Carolyn Settlemire, and Thomas Scott, did knowingly conspire, confederate, and agree with each other, and others known and unknown to the Grand Jury, to defraud the United States Food and Drug Administration an agency of the United States, for the purpose of impeding, impairing, obstructing, and defeating their lawful governmental functions of regulating drug labeling and approving new drugs, before introduction into interstate commerce; and to commit certain offenses against the United States, that is to Violate 21 U.S.C. 331, 333(a)(2), and 352 by introducing or delivering an adulterated or misbranded drug into interstate commerce with the intent to defraud or mislead. Manner and Means of the Conspiragv 29. As part of the conspiracy to defraud, the defendants purchased, possessed, packaged, labeled, marketed, distributed and sold substances containing Indictment Page 6 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 7 of 38 PageID 413 cannabinoids such as: IWH-250, l, 5F-PB-22, FUB- PB-22, THJ-2201 and throughout the Northern District of Texas and elsewhere. 30. It was further part of the conspiracy to defraud that the defendants would purchase prepackaged ?spice? from manufacturers both in Texas and across the country. These ?spice? products would then be delivered to the Gas Pipe, Inc. and Amy Lynn, Inc. warehouse located at 5800 Maple, Dallas, Texas, prior to being distributed to each of the Gas Pipe, Inc. retail locations. These ?spice? products would ultimately be marketed, distributed, and sold labeled as ?herbal incense,? ?potpourri,? or ?aroma therapy products? under brand names such as: ?Headhunter,? ?Black Label,? ?Scentsi Star,? ?Assassin Revolution,? ?Afghan Ice,? ?No More Mr. Nice Guy,? ?Sour ?iBlown,? ?Venom,? ?Apollo 13,? ?Trinity,? ?Alien,? and ?Plur.? Each of these products were labeled ?not for human consumption? and many stated ?100% cannabinoid free? even though each of these products contained a cannabinoid that the defendants intended for human consumption as a drug. Overt Acts of the Conspiracy 31. To effect the object of the conspiracy, the defendants and others performed overt acts in the Northern District of Texas and elsewhere, including but not limited to the following acts: a. On or about November 22, 2013, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 1407 Collins Street, Arlington, Texas. The packaging failed to contain adequate labeling and/or contained Indictment Page 7 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 8 of 38 PageID 414 false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid FUBINACA, and the product was intended for individuals to smoke and ingest; b. On or about November 22, 2013, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 130E. Bardin Road, Arlington, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and, Schedule 1 controlled substance 1, and the product was intended for individuals to smoke and ingest; c. On or about December 4, 2013, undercover of?cers purchased ?spice? labeled as ?Apollo 13?from the Gas Pipe retail location at 8508 Central Avenue SE, Albuquerque, New Mexico. The packaging failed to contain adequate labeling and/or contained false information such as: ?for aromatherapy only,? and ?not for humans to consume, ingest, or inhale,? when in fact it contained the cannabinoid and Schedule 1 controlled substance analogue PB-22, and the product was intended for individuals to smoke and ingest; d. On or about December 4, 2013, undercover officers purchased ?spice? labeled as ?Venom? from the Gas Pipe retail location at 8521 Golf Course Road, Albuquerque, New Mexico. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain any cannabinoids or controlled substances,? when in fact it contained the Indictment Page 8 Case Document 163 Filed 05/06/15 Page 9 of 38 PageID 415 cannabinoids and Schedule I controlled substances 144 and l, and the product was intended for individuals to smoke and ingest; e. On or about December 11, 2013, undercover of?cers purchased ?spice? labeled as from the Gas Pipe retail location at 1725 Central Expressway, Plano, Texas. The packaging failed to contain adequate labeling and/or contained false 33 CC information such as: ?premium blend potpourri,? ?not for sale to minors, not for human consumption,? and ?50 state legal premium potpourri,? when in fact it contained the cannabinoid and Schedule I controlled substance 1, and the product was intended for individuals to smoke and ingest; f. On or about December 11, 2013, undercover of?cers purchased ?spice? labeled as ?Afghan Ice? from the Gas Pipe retail location at 18613 Marsh Lane, Suite 500, Dallas, Texas. The packaging failed to contain adequate labeling and/or. contained 33 ?6 false information such as: ?not for human consumption,? ?lab certi?ed, this product does not contain. . .any illegal substances,? and ?this product is in compliance with all federal laws,? when in fact it contained the cannabinoid and Schedule I controlled substance l, and the product was intended for individuals to smoke and ingest; g. On or about December 11, 2013, undercover of?cers purchased ?spice? labeled as from the Gas Pipe retail location at 18613 Marsh Lane, Dallas, Texas. The packaging failed to contain adequate'labeling and/or contained false information such as: ?lab certi?ed legal,? and ?this product is designed, marketed, and sold strictly as potpourri and is not for human consumption. . .intended for adult use only, keep away Indictment Page 9 Case Document 163 Filed 05/06/15 Page 10 of 38 PageID 416 from children? when in fact it contained the cannabinoid and Schedule I controlled substance 1, and the product was intended for individuals to smoke and ingest; h. On or about December 11, 2013, undercover of?cers purchased ?spice? labeled as ?Afghan Ice? from the Gas Pipe retail location at 4420 Maple Avenue, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?lab certi?ed,? ?this product does not contain. . .any illegal substances,? and ?this product is in compliance with all federal laws,? when in fact it contained the cannabinoid and Schedule I controlled substance 1, and the product was intended for. individuals to smoke and ingest; i. On or about December 11, 2013, undercover of?cers purchased ?spice? labeled as ?Black Label? from the Gas Pipe retail location at 4420 Maple Avenue, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?100% cannabinoid free,? when in fact it contained the cannabinoid and Schedule I controlled substance l, and the product was intended for individuals to smoke and ingest; j. On or about December 16, 2013, undercover of?cers purchased ?spice? labeled as ?Sour from the Gas Pipe retail location at 9515 Skillman Street, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?100% cannabinoid free,? when in fact it contained the cannabinoid AB-FUBINACA, and the product was intended for individuals to smoke and ingest; Indictment Page 10 Case Document 163 Filed 05/06/15 Page 11 of 38 PageID 417 k. On or about December 16, 2013, undercover of?cers purchased ?spice? labeled as from the Gas Pipe retail location at 9515 Skillman Street, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?lab certi?ed legal,? and ?this product is designed, marketed, and sold strictly as potpourri and is not for human consumption. . .intended for adult use only, keep away from children? when in fact it contained the cannabinoid AB- FUBINACA, and the product was intended for individuals to smoke and ingest; 1. On or about December 16, 2014, undercover of?cers purchased ?spice? labeled as ?Forty-Two Degrees? from the Gas Pipe retail location at 2053 W. Northwest Highway, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?100% cannabinoid free,? when in fact it contained the cannabinoid AB-FUBINACA, and the product was intended for individuals to smoke and ingest; In. On or about December 17, 2013, undercover of?cers purchased ?spice? labeled as ?Venom? from the Gas Pipe retail location at 6033 Camp Bowie Blvd., Fort Worth, Texas. The paCkaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain any cannabinoids or controlled substances,? when in fact it contained the cannabinoid AB-FUBINACA, and the product was intended for individuals to smoke and ingest; n. On or about December 17, 2014, undercoVer of?cers purchased ?spice? labeled as ?iBlown? from the Gas Pipe retail location at 6033 Camp Bowie Blvd., Fort Indictment Page .11 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 12 of 38 PageID 418 Worth, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?this product contains no banned substances,? ?this package contains a proprietary blend or organic herbs combined with arti?cial extracts and colors. . ?not for human consumption? and ?for aromatherapy use only,? when in fact it contained the cannabinOid and Schedule I controlled substance 1, and the product was intended for individuals to smoke and ingest; o. On or about December 18, 2014, undercover of?cers purchased ?spice? labeled as ?Forty?Two Degrees? from the Gas Pipe retail location at 701 5th Street, Austin, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?100% cannabinoid free,? when in fact it contained the cannabinoid AB-FUBINACA, and the product was intended for individuals to smoke and ingest; p. On or about December 18, 2014, undercover of?cers purchased ?spice? labeled as ?iBlown? from the Gas Pipe retail location at 701 5th Street, Austin, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?this product contains no banned substances,? ?this package contains a 3: cc' proprietary blend or organic herbs combined with arti?cial extracts and colors. . ., not for human consumption? and ?for aromatherapy use only,? when in fact it contained the cannabinoid and the product was intended for individuals to smoke and ingest; q. On or about December 18, 2014, undercover of?cers purchased ?spice? labeled as ?Scentsi Star? from the Gas Pipe retail location at 8519 Burnet Road, Austin, Indictment Page 12 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 13 of 38 PageID 419 Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?100% cannabinoid free,? when in fact it contained the cannabinoid and Schedule I controlled substance 1, and the product was intended for individuals to smoke and ingest;- r. On or about January 7, 2014, undercover of?cers purchased ?spice? labeled as ?No More Mr. Nice Guy? from the Gas Pipe retail location at 8508 Central Avenue SE, Albuquerque, New Mexico. The packaging failed to contain adequate labeling 33 CC and/or contained false information such as: ?1.00% cannabinoid free, not made for human consumption,? when in fact it contained the cannabinoid FUBINACA, and the product was intended for individuals to smoke and ingest; 3. On or about March 4, 2014, undercover of?cers purchased ?Spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 1407 Collins Street, Arlington, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Schedule I controlled substance and the product was intended for individuals to smoke and ingest; t. On or about March 4, 2014, undercover of?cers purchased ?spice? labeled as ?Alien Loose Leaf? from the Gas Pipe retail location at 1407 Collins Street, Arlington, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain. . .any or naturally occurring cannabinoids,? when in fact it contained Indictment Page 13 Case Document 163 Filed 05/06/15 Page 14 of 38 PageID 420 the cannabinoid and Schedule I controlled substance analogue FUB-PB-22, and the product was intended for individuals to smoke and ingest; u. On or about March 10, 2014, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 6033 Camp Bowie Blvd, Fort Worth, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Schedule I controlled substance and the product was intended for individuals to smoke and ingest; v. On or about March 10, 2014, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 130 E. Bardin Road, Arlington, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Schedule I controlled substance AB-FUBINACA, and the product was intended for individuals to smoke and ingest; w. On or about March 11, 2014, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 4420 Maple Avenue, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Indictment Page 14 Case Document 163 Filed 05/06/15 Page 15 of 38 PageID 421 Schedule I controlled substance and the product was intended for individuals to smoke and ingest; - x. On or about March 11, 2014, undercover of?cers purchased ?spice? labeled as ?Alien Loose Leaf? from the Gas Pipe retail location at 4420 Maple Avenue, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain. . .any or naturally occurring cannabinoids,? when in fact it contained the cannabinoid and Schedule I controlled substance analogue FUB-PB-22, and the product was intended for individuals to smoke and ingest; On or about March 11, 2014, undercover of?cers purchased ?spice? labeled as ?Assassin Revolution? from the Gas Pipe retail location at 2053 W. Northwest Highway, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Schedule I controlled. substance AB-FUBINACA, and the product was intended for individuals to smoke and ingest; 2.. On or about March 11, 2014, undercover of?cers purchased ?spice? labeled as ?Alien Loose Leaf? from the Gas Pipe retail location at 2053 W. Northwest Highway, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain. . .any or naturally occurring cannabinoids,? when in fact it contained Indictment Page 15 Case DoCument 163 Filed 05/06/15 Page 16 of 38 PageID 422 the cannabinoid and Schedule I controlled substance analogue FUB-PB-22, and the product was intended for individuals to smoke and ingest; aa. On or about March 12, 2014, undercover of?cers purchased ?spice? labeled as ?Assassin RevolUtion? from the Gas Pipe retail location at 9515 Skillman Street, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption,? ?keep out of reach of children,? and ?for aromatherapy use only? when in fact it contained the cannabinoid and Schedule I controlled substance ABS-FUBINACA, and the product was intended for individuals to smoke and ingest; bb. On or about March 12, 2014, undercover of?cers purchased ?spice? labeled as ?Wolf Pack Rage? from the Gas Pipe retail location at 9515 Skillman Street, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?for aromatherapy use only,? ?use one 3 gram bag for 500 square foot area,? ?not for human consumption,? and ?does not contain any cannabinoids or controlled substances,? when in fact it contained the cannabinoid and Schedule I controlled substance AB-FUBINACA, and the product was intended for individuals to smoke and ingest; cc. On or about March 12, 2014, undercover of?cers purchased ?spice? labeled as ?Wolf Pack Rage? from the Gas Pipe retail location at 18613 Marsh Lane, Suite 500, Dallas, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?for aromatherapy use only,? ?use one 3 gram bag for 500 square foot area,? ?not for human consumption,? and ?does not contain any cannabinoids or Indictment - Page 16 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 17 of 38 PageID 423 controlled substances,? when in fact it contained the cannabinoid and Schedule 1 controlled substance AB-FUBINACA, and the product was intended for individuals to smoke and ingest; dd. On or about March 12, 2014, undercover of?cers purchased ?spice? labeled as ?Wolf Pack Rage? from the Gas Pipe retail location at 1725 Central Expressway, Plano, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?for aromatherapy use only,? ?use one 3 gram bag for 500 square foot area,? ?not for human consumption,? and ?does not contain any cannabinoids or controlled substances,? when in fact it contained the cannabinoid and Schedule I controlled substance and the product was intended for individuals to smoke and ingest; ee. On or about March 12, 2014, undercover officers purchased ?spice? labeled as ?Alien Loose Leaf? from the Gas Pipe retail location at 1725 Central Expressway, Plano, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?not for human consumption? and ?this product does not contain. . .any or naturally occurring cannabinoids,? when in fact it contained the cannabinoid and Schedule 1 controlled substance 5F-PB-22, and the product was intended for individuals to smoke and ingest; i ff. On or about April 30, 2014, undercover of?cers purchased ?spice? labeled as ?Plur? from the Gas Pipe retail location at 701 5th Street, Austin, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?put desired amount in an incense burner or dish,? ?use a lighter or match to ignite the Indictment Page 17 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 18 of 38 PageID 424 incense,? ?allow the exotic aroma to ?ll the air bringing you the feelings of peace, love, unity, and respect,? and ?not for human consumption,? when in fact it contained the cannabinoid and Schedule 1 controlled substance analogue THJ-2201, and the product was intended for individuals to smoke and ingest; gg. On or about April 30, 2014, undercover of?cers purchased ?spice? labeled as ?Plur? from the Gas Pipe retail location at 8519 Burnet Road, Austin, Texas. The packaging failed to contain adequate labeling and/or contained false information such as; ?put desired amount in an incense burner or dish,? ?use a lighter or match. to ignite the incense,? ?allow the exotic aroma to ?ll the air bringing you the feelings of peace, love, unity, and respect,? and ?not for human consumption,? when in fact it contained the cannabinoid and Schedule I controlled substance analogue THJ-2201, and the product was intended for individuals to smoke and ingest; hh. On or about May 6, 2014, undercover of?cer-s purchased ?spice? labeled as ?Plur? from the Gas Pipe retail location at 5707 Broadway Blvd, Garland, Texas. The packaging failed to contain adequate labeling and/or contained false information such as: ?put desired amount in an incense burner or dish,? ?use a lighter or match to ignite the incense,? ?allow the exotic aroma to ?ll the air bringing you the feelings of peace, love, unity, and respect,? and ?not for human consumption,? when in fact it contained the cannabinoid and Schedule I controlled substance analogue and the product was intended for individuals to smoke and ingest; 32. All in Violation of 18 U.S.C. 371, the penalty for which is set forth in 21 U.S.C. 331 and 333(a)(2). Indictment Page 18 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 19 of 38 PageID 425 Count Two Conspiracy to Distribute a Controlled Substance (Violation of 21 U.S.C. 846) 33. Beginning on or about February 11, 2014, and continuing through on or 7 about June 4, 2014, in the Northern District of Texas and elsewhere, defendants Gas Pipe, Inc., Amy Lynn, Inc? Gerald erry?) Shults, Amy Herrig, and Ryan Yarbro did conspire together, and with other individuals known and unknown to the grand jury, to knowingly and intentionally manufacture and distribute mixtures or substances containing detectable amounts of a Schedule I controlled substance, to wit: AB-FUBINACA and a Violation of 21 U.S.C. 841(a)(1) and 34. A11 in Violation of 21 U.S.C. 846, the penalty for which is set forth in 21 U.S.C. 841(a)(1) and Indictment Page 19 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 20 of 38 PageID 426 Count Three Distribution of a Controlled Substance Near a Public Playground (Violation of21 U.S.C. 841(a)(1) and 860 and 18 U.S.C. 2) 35. On or about March 11, 2014, in the Northern District of Texas and elsewhere, defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, Amy Herrig, and Ryan Yarbro, aided and abetted by each other, knowingly and intentionally distributed a mixture and substance containing a detectable amount of a Schedule I controlled substance, to wit: AB-FUBINACA, in Violation of 21 U.S.C. 841(a), within 1,000 feet of a public playground. 36. Allin Violation 841(a)(1) and 860; and 18 U.S.C. 2. Indictment Page 20 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 21 of 38 PageID 427 Count Four Conspiracy to Distribute a Controlled Substance Analogue (Violation of 21 U.S.C. 846) 37. Beginning on or about March 1, 2011, and continuing through on or about June 4, 2014, in the Northern District of Texas and elsewhere, Gas Pipe, Inc., Amy Lynn, Inc., Gerald (aka. ?Jerry?) Shults, Amy Herrig, and Ryan Yarbro did conspire together, and with other individuals, known and unknown to the grand jury, to knowingly and intentionally manufacture and distribute mixtures or substances containing detectable amounts of a Schedule I controlled substance analogue as de?ned in 21 U.S.C. 802(32), to wit: 1, PB-22, 22, and knowing that the substances were intended for human consumption as provided in 21 U.S.C. 813, a Violation of 21 U.S.C. 841(a)(1) and 38. All in Violation of 21 U.S.C. 846, the penalty for which is set forth in 21 U.S.C. 841(a)(1) and Indictment Page 21 Case Document 163 Filed 05/06/15 Page 22 of 38 PageID 428 Counts Five through Twelve Maintaining a Drug Involved Premise and Aiding and Abetting (Violation of21 U.S.C. 856(a)(1) and 18 U.S.C. 2) 39. On or about the dates for each count listed below in the Northern District of Texas, the defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, and Amy Herrig aided and abetted each other, to knowingly and intentionally maintain a place at the locations set forth below for. the purpose of manufacturing and distributing a Schedule I controlled substance and Schedule I controlled substance analogue as de?ned in 21 U.S.C. 802(32) knowing that the substances were intended for human consumption as provided in 21 U.S.C. 813. Count APPmXimate Description of the Substance Manufactured or Dates Location Distributed 5 4? 2125,11: 151111121 6 March 10, 2014 35533111), 32:12:86B1vd, substance 7 March 10, 2014 substance 8 March 11, 2014 substance 9 March 12, 2014 gallfassakltl?rggn Street, substance 10 March 129 2014 Sulte iglfquGIBCIEZZEtflled substance 11 May 6= 20 14 Elifaf?ftiisz 3:22:11: 11113531? 12 June 4, 2014 ggagfaidraglfa?venue, 3:212:13: ?st-13551? substance 40. Allin violation of21 U.S.C. 856(a)(1) and 18 U.S.C. 2. Indictment Page 22 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 23 of 38 PageID 429 Count Thirteen Maintaining Drug-Involved Premises in or Near Public Playground (Violation of21 U.S.C. 856(a)(1) and 860 and 18 U.S.C. 2) 41. On or about March 11, 2014, in the Northern District of Texas, the defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, and Amy Herrig aided and abetted each other, to knowingly and intentionally maintain a place at 4420 Maple Avenue, Dallas, Texas, for the purpose of distributing a Schedule I controlled substance, to wit: AB-FUBINACA, in Violation of 21 U.S.C. 856(a)(1); Within 1,000 feet of the real property comprising a public playground. 42. Allin Violation of21 U.S.C. 856(a)(1) and 860; and 18 U.S.C. 2. Indictment Page 23 Case Document 163 Filed 05/06/15 Page 24 of 38 PageID 430 Counts Fourteen through Sixteen Importation of a Controlled Substance Analogue and Aiding and Abetting (Violation of21 U.S.C. 952 and 960 and 18 U.S.C. 2) 43. On or about the dates listed in each count below, the defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, Amy Herrig, Ryan Yarbro, and Carolyn Settlemire did aid and abet each other to intentionally and knowingly import into the United States a mixture and substance containing detectable amounts of a Schedule I controlled substance analogue as de?ned in 21 U.S.C. 802(32) knowing that the substances were intended for human consumption as provided in 21 U.S.C. 813. Count Approximate Date Substance Transaction Purchased kilogram quantity of the controlled substance analogue 2201 from Debora Labs in Denmark, and the THJ-2201 was imported from Denmark or China 14 April 24, 2014 THJ-2201 Purchased kilogram quantity of the controlled substance analogue THJ- 2201 from Debora Labs in Denmark, and the THJ-2201 was imported from Denmark or China 15 May 13, 2014 THJ-2201 Purchased kilogram quantity of the controlled Substance analogue THJ- 2201 from Debora Labs in Denmark, and the THJ-2201 was imported from Denmark or China 16 May 20, 2014 44. Allin Violation of21 U.S.C. 952 and 960 and 18 U.S.C. 2. Indictment Page 24 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 25 of 38 PageID 431 Count Seventeen Conspiracy to Commit Money Laundering [Violation of 18 U.S.C. 1956(h)] 45. From at least on or about March 1, 2011, through June 4, 2014, in the Northern District of Texas and elsewhere, the defendants Gas Pipe, Inc., Amy Lynn, Inc., Gerald erry?) Shults, Amy Herrig, Carolyn Settlemire, Rapids Camp I Lodge, Inc., and Ridglea Complex Management, Inc. did knowingly combine, conspire, and agree with each other and with other persons known and unknown to the grand jury to commit offenses against the United States in violation of 18 U.S.C. 1956 and 1957, to wit: 5 a. To knowingly conduct and attempt to conduct ?nancial transactions affecting interstate commerce and foreign commerce, which transactions involved the proceeds of speci?ed unlawful activity, that is, conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug-involved premise, and importation of a controlled substance analogue, knowing that the transactions were designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of speci?ed unlaw?il activity, and that while conducting and attempting to conduct such ?nancial transactions, knew that the property involved in the ?nancial transactions represented the proceeds of some form of unlawful activity, in violation of 18 U.S.C. b. To transport, transmit and transfer and attempt to transport, transmit and transfer a monetary instrument and funds from a place in the United States to and through Indictment Page 25 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 26 of 38 PageID 432 a place outside the United States with the intent to promote the carrying on of speci?ed unlawful activity, in violation of 18 U.S.C. and c. To knowingly engage and attempt to engage, in monetary transactions by, through or to a ?nancial institution, affecting interstate and foreign commerce, in criminally derived property of a value greater than $10,000, with such property having been derived from a speci?ed unlawful activity, that is, conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug?involved premise, importation of a controlled substance analogue, and continuing a criminal enterprise, in violation of 18 U.S.C. 1957. Manner and Means 46. It was part of the conspiracy that the defendants and other persons both known and unknown to the Grand Jury would: a. Transfer the proceeds earned from the conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug-involved premise, and importation of a controlled substance analogue from multiple -Wells Fargo bank accounts to various ?nancial accounts maintained at UBS Financial Services; b. Use and dispose'the proceeds acquired from the conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug-involved premise, and importation of a controlled substance analogue to purchase various materials, equipment, and real property to Indictment Page 26 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 27 of 38 PageID 433 continue the manufacturing and distribution of ?spice? in the Northern District of Texas and elsewhere; 0. By concealing the source and nature of the proceeds derived from the conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug-involved premise, and importation of a controlled substance analogue by purchasing assets through a seemingly unrelated and totally different business entity; and d. Comingling the proceeds derived from the conspiracy to distribute a controlled substance, conspiracy to distribute a controlled substance analogue, wire fraud, mail fraud, maintaining a drug-involved premise, and importation of a controlled substance analogue with legitimately earned assets in an effort to conceal the true source and nature of the criminal derived funds; 47. All in violation of 18 U.S.C. 1956(h), the penalty for which is set forth in . 18 U.S.C. l956(a)(1). Indictment Page 27 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 28 of 38 PageID 434 Forfeiture Notice [21 U.S.C. 853(a) and 18 U.S.C. 982(a)(l)] Upon conviction for the offenses alleged in Counts Two through Sixteen of this indictment and pursuant to 21 U.S.C. 853(a), the defendants, Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, Amy Herrig, Ryan Yarbro, and Carolyn Settlemire shall forfeit to the United States of America all property, real or personal, constituting, or derived from, the proceeds obtained, directly or indirectly, as the result of the offense; and any property, real or personal, used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of the offense. Upon conviction for any of the offenses alleged in Count Seventeen of this Indictment and pursuant to 18 U.S.C. 982(a)(l), the defendants, Gas Pipe, Inc., Amy Lynn, Inc., Gerald ?Jerry?) Shults, Amy Herrig, Carolyn Settlemire, Rapids Camp Lodge, Inc., and Ridglea Complex Management, Inc. shall forfeit to the United States all property, real or personal, involved in, or traceable to property involved in, the respective offense, and includes, but is not limited to the following The specific property the government seeks to forfeit upon conviction of Counts Two through Seventeen includes, but is not limited to, the following: 1. The proceeds obtained as a result of the offense in Count 2, in the form of a money judgment. [sought from all defendants charged in this count] 2. The proceeds obtained as a result of the offense in Count 3, in the form of a money judgment. [sought from all defendants charged in this count] 3. The proceeds obtained as a result of the offense in Count 4, in the form of a money judgment. [sought from all defendants charged in this count] 4. The proceeds obtained as a result of the offense in Count 5, in the form of a money Indictment Page 28 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 29 of 38 PageID 435 10. 11. 12. 13. 14. 15. 16. 17. 18. judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 6, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 7, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 8, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 9, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 10, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 11, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 12, in the form of a money judgment. [sought from all defendants charged in this count] 7 The proceeds obtained as a result of the offense in Count 13, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 14, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 15, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 16, in the form of a money judgment. [sought from all defendants charged in this count] The proceeds obtained as a result of the offense in Count 17, in the form of a money judgment. [sought from all defendants charged in this count] Real property located at 1407 North Collins Street, Arlington, Texas; Real property located at 4418 Maple Avenue, Dallas, Texas; Indictment Page 29 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 30 of 38 PageID 436 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. Real property located at 701 E. 5th Street, Austin, Texas; Real property located at 9515 Skillrnan Street, Dallas, Texas; Real property located at 5800 Maple Avenue, Dallas, Texas; Real property located at 8519 Burnet Road, Austin, Texas; Real property located at 18613 Marsh Lane, Dallas, Texas; Real property located at 130 E. Bardin Road, Arlington, Texas; Real property located at 5707 Broadway Boulevard, Garland, Texas; Real property located at 5709 Broadway Boulevard, Garland, Texas; Real property located at 3341 Winthrop Avenue, Fort Worth, Texas; Real property located at 28927 Southeast Woods Road, Eagle Creek, Oregon; Real property located at 3320 Harvard Avenue, Highland Park, Texas; Real property located at 5502 East R.L. Thornton Freeway, Dallas, Texas; Real property located at 5506 East R.L. Thornton Freeway, Dallas, Texas; Real property located at 3309 Winthrop Avenue, Fort Worth, Texas; Real property located at 3327 3345 Winthrop Avenue, Fort Worth, Texas; Real property located at 6025 Camp Bowie Boulevard, Fort Worth, Texas; Real property located at 6033 Camp Bowie Boulevard, Fort Worth, Texas; Real property located at 407 CR 1609, Clifton, Texas; 1981 Cessna Conquest 441 ?Xed Wing multi-engine aircraft (Tail No. N441 1999 Cessna 208 Caravan fixed wing single-engine aircraft (Tail No. Indictment Page 30 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 7 Page 31 of 38 PageID 437 39. 1964 Dehavilland Beaver DHC-2 MK 1 (Tail No. 40. 1996 Pilatus ?xed wing single-engine aircraft (Tail No. 41. 1951 Piper PA-18 Cub ?xed wing single?engine aircraft (Tail No. 42. 1978 Delta Marine ?berglass ?shing vessel named ?Sea Witch;? 43. $6,210.29 in U.S. currency seized on June 4, 2014; 44. $7,072.63 in U.S. currency seized on June 4, 2014; 45. $4,102.06 in U.S. currency seized on June 4, 2014; 46. $10,870.61 in U.S. currency seized on June 4, 2014; 47. $1,329.00 in U.S. currency seized on June 4, 2014; 48. $1,415.00 in U.S. currency seized on June 4, 2014; 49. $3,541.32 in U.S. currency seized on June 4, 2014; 50. $8,017.59 in U.S. currency seized on June 4, 2014; 51. $8,242.00 in U.S. currency seized on June 4, 2014; 52. $5,658.37 in U.S. currency seized on June 4, 2014; 53. $9,781.76 in U.S. currency seized on June 4, 2014; 54. All funds in UBS Financial Services account ending in 6235 (approx. value of 55. All funds in UBS Financial Services account ending in 5092 (approx. value of 56. All funds in UBS Financial Services account ending in 0852 (approx. value of 57. All funds in UBS Financial Services account ending in 4980 (approx. value of Indictment Page 31 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 32 of 38 PageID 438 58. All funds in UBS Financial Services account ending in 8258 (approx. value of 59. All funds in UBS Financial Services account ending in 4875 (approx. value of 60. All funds in UBS Financial Services account ending in 4596 (approx. value of 61. All funds in UBS Financial Services account ending in 8402 (approx. value of 62. All funds in UBS Financial Services account ending in 7514 (approx. value of 63. $41,183.03 in funds seized from Wells Fargo Bank account ending in 3677; 64. $76,448.21 in funds seized from Wells Fargo Bank account ending in 8825; 65. $72,017.40 in funds seized from Wells Fargo Bank account ending in 9088; 66. $53,072.55 in funds seized from Wells Fargo Bankaccount ending in 3685; 67. $51,305.77 in ?inds seized from Wells Fargo Bank account ending in 3636; 68. $63,339.12 in funds seized from Wells Fargo Bank account ending in 3693; 69. $121,194.84 in ?inds seized from Wells Fargo Bank account ending in 2088; 70. $19,321.72 in funds seized from Wells Fargo Bank account ending in 2112; 71. $58,349.15 in funds seized from Wells Fargo Bank account ending in 2096; 72. $22,795.55 in funds seized from Wells Fargo Bank account ending in 6999; 73. $5,891.99 in funds seized from Wells Fargo Bank account ending in 9591; 74. $10,801.29 in funds seized from Wells Fargo Bank account ending in 2554; Indictment Page 32 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 33 of 38 PageID 439 7586. $378.89 in funds seized from Wells Fargo Bank account ending in 0014; $39,265.95 in funds seized from Wells Fargo Bank account ending in 3820; $122,473.50 in funds seized from Wells Fargo Bank account ending in 9344; $20,545.04 in funds seized from Wells Fargo Bank account ending in 2104; $94,992.31 in funds seized from Wells Fargo Bank account ending in 1866; Lots 2 3, Block 1; Lots 1, 2, 3, 4, 5 6, Block 2; and Lots 2 3, Block 3 within the Chuck-A-Lou Subdivision, a subdivision of Lot 3, US. Survey 7410, within Sections 4,5,8 9, Township 18 South, Range 44 West, Seward Meridian, aggregating 11.791 acres more or less; Lot 5, Block 3, Chuck-A-Lou Subdivision, according to the of?cial plat thereof, ?led under Plat Number 91-6, Records of the Kvichak Recording District, Third Judicial District, State of Alaska, A.P.N. Lots 7, 8, 9, 10, 11, 12, Block 3, Chuck?A-Lou Subdivision, Plat 91?6 a subdivision of Lot 3, US. Survey 7410, within protracted SecW., Seward Meridian, containing 1.617 acres, Kvichak Recording District, Third Judicial District, State of Alaska; Lot 7, US. Survey 3539, Records of the Kvichak Recording District, Third Judicial District, State of Alaska; The Southwest one-quarter of the Southeast one?quarter of the Southeast one? quarter, and the Southeast one-quarter of the Southwest one-quarter of the Southeast one-quarter in unsurveyed Section 36, Township 31 South, Range 29 West, Seward Meridian, Kodiak Recording District, Third Judicial District, State of Alaska, also known as TL 3608 Tr .9 Lot 6, Tract of the Alaska Native Claims Settlement Act (ANCSA) Section 14(e), Tracts at Karluk, Alaska, according to Plat No. 2000-3, located in the Kodiak Recording District, Third Judicial District, State of Alaska; Lot 13, Block 3, Chuck-A-Lou Subdivision, a subdivision of Lot 3, US. Survey 7410, within protracted SecW., Seward Meridian, Indictment Page 33 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 34 of 38 PageID 440 containing 1.617 acres, Records of the KVichak Recording District, Third Judicial District, State of Alaska; 87. Lot 6, Block 3, of Chuck?A-Lou Subdivision, according to Plat 9106, ?led in the KVichak Recording District, Third Judicial District, State of Alaska; 88. Lot 1, Block 3, Chuck?A?Lou Subdivision, according to the of?cial plat thereof, ?led under Plat Number 91-6 Third, Records of the KVichak Recording District, Third Judicial District, State of Alaska; FURTHER ON THIS Indictment Page 34 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 35 of 38 PageID 441 A TRUE Wt FOREMAN JOHN R. PARKER Acting 'e ates Attorney BRIAN Assistant United States Attorney Northern District of Texas Texas State Bar No. 24056908 1100 Commerce St., Third Floor Dallas, Texas 75242?1699 Telephone: 214.659.8600 E?mail: brian.poe@usdoi.gov MARTIN Assistant United States Attorney Northern District of Texas Texas State Bar No. 24032572 1100 Commerce St., Third Floor Dallas, Texas 75242-1699 Telephone: 214.659.8600 errin.martin@usdoi .ggv ates ttorney 00796455 1100 Com rce uite 300 Dallas, Texas 75242 Telephone: 214.659.8600 E?Mail: john.delagarza@usdoj. gov Indictment Page 35 Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 36 Of 38 PageID 442 -- FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION THE UNITED STATES OF AMERICA V. GAS PIPE, INC. (7) AMY LYNN, INC. (8) GERALD SHULTS (9) (A.K.A. AMY HERRIG (10) ROLANDO ROJAS (11) (A.K.A. RYAN YARBRO (12) JOHN BEN LINCOLN (13) CHRISTOPHER RAMIREZ (14) DANIEL CAILLIER (15) KENDALL SILVA (16) ELIZABETH WALKER (17) BRIDGETT PAYROT (18) JASON LYON (19) JOSHUA CAMPBELL (20) MICK CLARK (21) BRANDON SCHUBERT (22) JACKIE RANDALL-KING (23) HOLLY PATTERSON (24) BRAD BADER (25) TRAVIS LOVIN (26) JENNIFER DUNN (27) PATRICK SHANAHAN (28) CAROLYN SETTLEMIRE (29) TOM SCOTT (30) RAPIDS CAMP LODGE, INC. (31) RIDGLEA COMPLEX MANAGEMENT, INC. (32) Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 37 of 38 PageID 443 SEALED SUPERSEDING INDICTMENT (Supersedes Indictment returned on August 5, 2014) 18 U.S.C. 371 Conspiracy to Defraud the United States 7 21 U.S.C. 846 Conspiracy to Distribute a Controlled Substance 21 U.S.C. 841(a)(1) and 860 and 18 U.S.C. 2 Distribution of a Controlled Substance Near a Public Playground 21 U.S.C. 846 Conspiracy to Distribute a Controlled Substance Analogue 21 U.S.C. 856(a)(1) and 18 U.S.C. 2 Maintaining a Drug Involved Premise and Aiding and Abetting 21 U.S.C. 856(a)(1) and 860 and 18 U.S.C. 2 Maintaining Drug-Involved Premises in or Near Public Playground 21 U.S.C. 952 and 960 and 18 U.S.C. 2 Importation of a Controlled Substance Analogue and Aiding and Abetting 18 U.S.C. 1956(h) Conspiracy to Commit Money Laundering 21 U.S.C. 853(a) and 18 U.S.C. 982(a)(1) Forfeiture Notice 17 Counts A true bill rendered all/l DALLAS FOREPERSON Filed in open court this day of May, 2015. Case 3:14-cr-00298-M Document 163 Filed 05/06/15 Page 38 of 38 PageID 444 Warrants to be Issued: - GERALD (9), AMY HERRIG (10), ROLANDO ROJAS (11), RYAN YARBRO (12), JOHN BEN LINCOLN (13), CHRISTOPHER RAMIREZ (14), DANIEL CAILLIER (15), KENDALL SILVA (16), ELIZABETH WALKER (17), BRIDGETT PAYROT (18), JASON LYON (19) JOSHUA CAMPBELL (20), MICK CLARK (21), BRANDON SCHUBERT (22) JACKIE RANDALL-KING (23), HOLLY PATTERSON (24), BRAD BADER (25) TRAVIS LOVIN (26), JENNIFER DUNN SHANAHAN (28), SETTLEMIRE (29), TOM SC