RSGB Indictment

I Case 3:15-cr-00174-JCH Document 1 Filed 09/30/15 Page 1 of 18
United States District Court

District of Connecticut
FILED AT NEW HAVEN
UNITED STATES DISTRICT COURT Ll [Q_20I5
DISTRICT 0 F CONNECT! CUT _,R=-o-:-b-e-,-rta--;D:::-_-,:.a~~~l:t.r:.'ij
GRAND JURY N-14-1
UNITED STATES OF AMERICA CRIMINAL NO. 3:15CR f14 (/\\1\/T)

v. VIOLATIONS:
18 U.S.C. 1962(c) (Engaging in a pattern of
JEFFREY BENTON, a.k.a. "Tall Man" racketeering activity)
and "Fresh";
KEITH YOUNG, a.k.a. "Capo," "Bapo" 18 U.S.C. 1962(d) (Conspiracy to engage in a
and "Poncho"; pattern of racketeering activity)
ROBERT SHORT, a.k.a. "Santana";
TREVOR MURPHY, a.k.a. "Snookie"; 18 U.S.C. 1959(a)(l) (VCAR murder)
ROBERT HARRIS, a.k.a. "Skully
Mack"; and 18 U.S.C. 1959(a)(3) (VCAR assault with a
CHRISTOPHER GRAHAM, a.k.a. dangerous weapon)
"Ugg"
18 U.S.C. 1959(a)(4) (VCAR threat to commit
crime of violence)
18 U.S.C. 1959(a)(5) (VCAR conspiracy to

commit murder)
18 U.S.C. 1951 (a) (Conspiracy to interfere with

commerce by robbery)
18 U.S.C. 1956(a)(l)(A)(i) (Money laundering)
18 U.S.C. 924(c) (Carrying and using a firearm

during and in relation to a crime of violence)
18 U.S.C. 924(j)(l) (Causing the death of another

person through the use of a firearm in relation to a
crime of violence)
21 U.S.C. 841(a)(1) (Distribution of cocaine base)
18 U.S.C. 2 (Aiding and abetting)
INDICTMENT
The Grand Jury charges:

Case 3:15-cr-00174-JCH Document 1 Filed 09/30/15 Page 2 of 18
COUNT ONE
(Engaging in a pattern of racketeering activity)
The Enterprise
1. At all times relevant to this Indictment, the defendants JEFFREY BENTON,
a.k.a. "Tall Man" and "Fresh," KEITH YOUNG, a.k.a. "Capo," "Bapo" and "Poncho,"
ROBERT SHORT, a.k.a. "Santana," TREVOR MURPHY, a.k.a. "Snookie," ROBERT
HARRIS, a.k.a. "Skully Mack," CHRISTOPHER GRAHAM, a.k.a. "Ugg," and others known
and unknown, were members and associates of the Red Side Guerilla Brims, a criminal
organization whose members and associates engaged in narcotics distribution, and acts of
violence, including acts involving murder and robbery, and which operated principally in New
Haven, Connecticut.
2. The Red Side Guerilla Brims, including its leadership, members and associates,
constituted an "enterprise," as defined by Title 18, United States Code, Sections 1959(b)(2) and
1961 (4) (hereinafter "the enterprise"), that is, a group of individuals associated in fact which was
engaged in, and the activities of which affected, interstate and foreign commerce. The enterprise
constituted an ongoing organization whose members functioned as a continuing unit for a
common purpose of achieving the objectives of the enterprise.
3. The purposes ofthe enterprise included the following:
a. Enriching the members and associates of the enterprise through, among
other things, murder, attempted murder, robbery, and the distribution of narcotics.
b. Preserving and protecting the power, territory and profits of the enterprise
through the use of intimidation, violence, threats of violence, assaults, attempted murder and
murder.
2
c. Promoting and enhancing the enterprise and its members' and associates'
acti viti es.
d. Keeping victims, witnesses and rival gang members in fear of the
enterprise and in fear of its members and associates through threats of violence and violence.
Role ofthe Defendants
4. SHORT, MURPHY, HARRIS, and GRAHAM were members of the enterprise,
and they acted under the direction of the leaders of the enterprise.
5. Under the direction of the leaders of the enterprise, SHORT, MURPHY,
HARRIS, and GRAHAM participated in unlawful and other activities in furtherance of the
conduct of the enterprise's affairs.
6. BENTON and YOUNG, who were both members of the enterprise and
participated in unlawful and other activities in furtherance of the conduct of the enterprise's
affairs, also held leadership roles within the enterprise at various times relevant to this
Indictment.
Means and Methods of the Enterprise
7. Among the means and methods by which BENTON, YOUNG, SHORT,
MURPHY, HARRIS, GRAHAM and their associates conducted and participated in the conduct
of the affairs ofthe enterprise were the following:
a. Members of the enterprise and their associates committed, attempted and
threatened to commit acts of violence, including murder and robbery, to protect and expand the
enterprise's criminal operations.
b. Members of the enterprise and their associates promoted a climate of fear
through violence, threats of violence and retaliation.
3
c. Members of the enterprise and their associates trafficked in cocaine and
cocaine base, Schedule II controlled substances.
d. Members of the enterprise engaged in money laundering to promote their
narcotics trafficking operation.
The Racketeering Violation
8. From approximately 2011 through in or about 2015, in the District of Connecticut
and elsewhere, defendants JEFFREY BENTON and KEITH YOUNG, together with others
known and unknown, being persons employed by and associated with the Red Side Guerilla
Brims, which was an enterprise engaged in, and the activities of which affected, interstate and
foreign commerce, unlawfully, and knowingly conducted and participated, directly and
indirectly, in the conduct of the affairs of that enterprise through a pattern of racketeering
activity, that is, through the commission of Racketeering Acts One through Seven, as set forth in
paragraphs Ten through Sixteen below.
The Pattern of Racketeering Activity
9. The pattern of racketeering activity as defined in Title 18, United States Code,
Sections 1961(1) and 1961(5), consisted ofthe following acts:
Racketeering_ Act One - Conspiracy to Distribute ocaine Base .and Money Lm:mderi 1g
10. The defendants JEFFREY BENTON and KEITH YOUNG, and others known and
unknown, committed the following acts, either of which alone constitutes the commission of
Racketeering Act One:
a. Conspiracy to Distribute Cocaine Base
From in or about 2011 through in or about 2012, in the District of Connecticut and the
District of Maine and elsewhere, the defendants JEFFREY BENTON and KEITH YOUNG, and
4
others known and unknown, unlawfully, intentionally and knowingly combined, conspired,
confederated and agreed together and with each other to distribute and possess with intent to
distribute a mixture and substance containing a detectable amount of cocaine base ("crack
cocaine"), a Schedule II controlled substance, in violation of Title 21, United States Code,
Sections 84l(a)(1), 841(b)(l)(C) and 846.
b. Conspiracy to Commit Money Laundering
From in or about August 2011 through in or about November 2011, in the District of
Connecticut, the District of Maine and elsewhere, the defendants JEFFREY BENTON and
KEITH YOUNG knowingly combined, conspired, confederated and agreed together and with
each other to conduct and attempt to conduct financial transactions affecting interstate and
foreign commerce, i.e., sending Western Union money transfers in amounts ranging from $500
to $2,500 from Bangor, Maine to New Haven, Connecticut, which transactions involved the
proceeds of a specified unlawful activity, that is, a conspiracy to distribute and to possess with
intent to distribute cocaine base ("crack cocaine"), in violation of Title 21, United States Code,
Section 846, with the intent to promote the carrying on of the specified unlawful activity, and
that while conspiring to conduct and attempt to conduct such financial transactions knew that the
property involved in the financial transactions represented the proceeds of some form of
unlawful activity, in violation of Title 18, United States Code, Sections 1956(a)(l)(A)(i) and
1956(h).
All in violation of Title 18, United States Code, Section 1962(c).
Racketeering Act Two - Conspiracy to Murder Carl Williams
11. On or about February 23, 2011, in the District of Connecticut, the defendant
JEFFREY BENTON, along with Luis Padilla, who is charged in a separate Information,
5
unlawfully, willfully, intentionally and knowingly conspired to murder Carl Williams, m
violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.
Racketeering Act Three -Felony Murder of Kevin Lee
12. On or about April 20, 2011, in the District of Connecticut, the defendant
JEFFREY BENTON, and others, including Rodrigo Ramirez, Luis Padilla and Miles Price, all of
whom are charged in separate Informations and/or Indictments, unlawfully, intentionally and
knowingly attempted to commit a robbery of Kevin Lee, a marijuana distributer, and, during the
course of attempting to commit the robbery, which was intended to provide monies to the Red
Side Guerilla Brims, caused the death of Kevin Lee, in violation of Conn. Gen. Stat. 53a-8(a)
and 53a-54c (Felony murder).
Racketeering Act Four- Murder of Donnell Allick
13. On or about June 24, 2011, in the District of Connecticut, the defendants
JEFFREY BENTON and KEITH YOUNG, along with Luis Padilla and Kavan Rogers, who are
charged in separate Informations and/or Indictments, with the intent to cause the death of another
individual, caused the death of Donnell Allick, in violation of Conn. Gen. Stat. 53a-8(a) and
53a-54a.
Racketeering Act Five- Conspiracy to Murder Darrick Cooper
14. On or about September 19, 2011, in the District of Connecticut, the defendants
JEFFREY BENTON and KEITH YOUNG, along with Robert Short, who is not charged in this
Count, unlawfully, willfully, intentionally and knowingly conspired to murder Darrick Cooper,
in violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.
Racketeering Act Six- Conspiracy to Murder Marquis Moore
15. On or about October 21, 2011, in the District of Connecticut, the defendant
6
JEFFREY BENTON, along with Harry Anderson, a.k.a. "Ace," who is charged in a separate
Indictment, unlawfully, willfully, intentionally and knowingly conspired to murder Marquis
Moore, in violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.
Racketeering Act Seven- Murder of Donald Bolden
16. On or about March 20, 2012, in the District of Connecticut, the defendant
JEFFREY BENTON, along with Marquise Harris, who was then a member of the Red Side
Guerilla Brims, but who has since been murdered, with the intent to cause the death of another
individual, caused the death of Donald Bolden, in violation of Conn. Gen. Stat. 53a-8(a) and
53a-54a.
All in violation of Title 18, United States Code, Section 1962(c).
COUNT TWO
(RICO Conspiracy)
17. The allegations in paragraphs 1-7 are incorporated by reference in this Count.
18. From in or about 2011 through 2015, in the District of Connecticut and elsewhere,
the defendants JEFFREY BENTON and KEITH YOUNG, being persons employed by and
associated with the above-described enterprise, that is, the Red Side Guerilla Brims, which was
engaged in, and the activities of which affected interstate and foreign commerce, unlawfully and
willfully did combine, conspire, confederate, and agree with each other, and with persons known
and unknown to the grand jury, to commit an offense against the United States, to wit: to violate
Title 18, United States Code, section 1962(c), that is, to conduct and participate directly and
indirectly, in the conduct of the affairs of the enterprise through a pattern of racketeering activity,
as that term is defined in Title 18, United States Code, Sections 1961 (1) and 1961 (5). The pattern
of racketeering activity through which the defendants agreed to conduct the affairs of the
enterprise consisted of the Racketeering Acts One through Seven set forth in paragraphs Ten
7
through Sixteen of this Indictment, incorporated by reference as if fully set forth herein. It was
part of the conspir~cy that each defendant agreed that a conspirator would commit two acts of
racketeering.
All in violation ofTitle 18, United States Code, Section 1962(d).
COUNT THREE
(VCAR Conspiracy to Murder Carl Williams)
19. The allegations in paragraphs 1-7 are incorporated by reference in this Count.
20. The Red Side Guerilla Brims, through its members and associates, engaged in
racketeering activity as defined in Title 18, United States Code, Sections 1959(b)(1) and 1961 (1 ),
namely acts involving murder and robbery, in violation of Connecticut state law, acts indictable
under Title 18, United States Code, Section 1956 (money laundering), and acts involving
narcotics trafficking, in violation ofTitle 21, United States Code, Sections 841(a)(1) and 846.
21. On or about February 23, 2011, in the District of Connecticut, the defendant
JEFFREY BENTON, a.k.a. "Tall Man" and "Fresh," for the purpose of maintaining and
increasing position in the Red Side Guerilla Brims, an enterprise engaged in racketeering
activity, as described above, together with Luis Padilla, who is charged in a separate Information,
unlawfully, willfully, intentionally and knowingly conspired to murder Carl Williams, in
violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.
All in violation ofTitle 18, United States Code, Section 1959(a)(5).
COUNT FOUR
(VCAR Felony Murder of Kevin Lee)
22 . The allegations in paragraphs 1-7 and 20 are incorporated by reference in this
Count.
8
23. On April 20, 2011, in the District of Connecticut, the defendant JEFFREY
BENTON, a.k.a. "Tall Man" and "Fresh," for the purpose of maintaining and increasing position
in the Red Side Guerilla Brims, an enterprise engaged in racketeering activity, as described
above, together with others, including Rodrigo Ramirez, Luis Padilla and Miles Price, all of
whom are charged in separate Informations and/or Indictments, murdered Kevin Lee; to wit
BENTON, Ramirez, Padilla and Price unlawfully, intentionally and knowingly attempted to
commit a robbery of Kevin Lee, a marijuana distributer, and, during the course of attempting to
commit the robbery, which was intended to provide monies to the Red Side Guerilla Brims,
caused the death of Kevin Lee, in violation of Conn. Gen. Stat. 53a-8(a) and 53a-54c (Felony
murder).
All in violation of Title 18, United States Code, Sections 2 and 1959(a)(l ).
COUNT FIVE
(VCAR Murder of Donnell Allick)
24. The allegations in paragraphs 1-7 and 20 are incorporated by reference in this
Count.
25. On or about June 24, 20 11, in the District of Connecticut, the defendants
JEFFREY BENTON, a.k.a. "Tall Man" and "Fresh," and KEITH YOUNG, a.k.a. "Capo,"
"Bapo" and "Poncho," for the purpose of maintaining and increasing position in the Red Side
Guerilla Brims, an enterprise engaged in racketeering activity, as described above, together with
others, including Luis Padilla and Kavon Rogers, both of whom are charged in separate
Informations and/or Indictments, unlawfully, willfully, intentionally and knowingly murdered
Donnell Allick, in violation of Conn. Gen. Stat. 53a-8(a) and 53a-54a.
All in violation of Title 18, United States Code, Sections 2 and 1959(a)(l ).
9
COUNT SIX
(VCAR Murder of Darrick Cooper)
Count.
27. On or about September 19,2011, in the District of Connecticut, the defendants
KEITH YOUNG, a.k.a. "Capo," "Bapo," and "Poncho" and ROBERT SHORT, a.k.a. "Santana,"
for the purpose of maintaining and increasing position in the Red Side Guerilla Brims, an
enterprise engaged in racketeering activity, as described above, unlawfully, willfully,
intentionally and knowingly murdered Darrick Cooper, in violation of Conn. Gen. Stat. 53a-
8(a) and 53a-54a.
All in violation of Title 18, United States Code, Sections 2 and 1959(a)(l).
COUNT SEVEN
(VCAR Conspiracy to Murder Marquis Moore)
Count.
activity, as described above, along with Harry Anderson, a.k.a. "Ace," who is charged in a
separate Indictment, unlawfully, willfully, intentionally and knowingly conspired to murder
Marquis Moore, in violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.
All in violation of Title 18, United States Code, Section 1959(a)(5).
10
COUNT EIGHT
(VCAR Murder/Felony Murder of Joseph Zargo)
Count.
31. On or about December 23, 2011, in the District of Connecticut, the defendant
TREVOR MURPHY, a.k.a. "Snookie," for the purpose of maintaining and increasing position in
the Red Side Guerilla Brims, an enterprise engaged in racketeering activity, as described above,
both (1) unlawfully, willfully, intentionally and knowingly murdered Joseph Zargo, in violation
of Conn. Gen. Stat. 53a-54a (Murder), and (2) unlawfully, intentionally and knowingly
attempted to commit a robbery of Joseph Zargo, a distributer of controlled substances, and,
during the course of attempting to commit the robbery, caused the death of Joseph Zargo, in
violation of Conn. Gen. Stat. 53a-54c (Felony murder).
All in violation of Title 18, United States Code, Section 1959(a)(l).
COUNT NINE
(Conspiracy to Interfere with Commerce by Robbery)
TREVOR MURPHY, a.k.a. "Snookie," together with others known and unknown to the Grand
Jury, did knowingly and willfully conspire to obstruct, delay and affect commerce, and the
movement of articles and commodities in commerce, by robbery.
In violation of Title 18, United States Code, Section 1951 (a).
COUNT TEN
(VCAR Murder of Donald Bolden)
Count.
34. On or about March 20, 2012, in the District of Connecticut, the defendant
11
activity, as described above, along with Marquise Harris, who was then a member of the Red
Side Guerilla Brims, but who has since been murdered, unlawfully, willfully, intentionally and
knowingly murdered Donald Bolden, in violation of Conn. Gen. Stat. 53a-8(a) and 53a-54a.
All in violation ofTitle 18, United States Code, Sections 2 and 1959(a)(1).
COUNT ELEVEN
(VCAR Assault with a Dangerous Weapon of Kevin Terry)
3 5. The allegations in paragraphs 1-7 and 20 are incorporated by reference in this
Count.
36. On or about December 23, 2014, in the District of Connecticut, the defendants
ROBERT HARRIS, a.k.a. "Skully Mack," and CHRISTOPHER GRAHAM, a.k.a. "Ugg," for
the purpose of maintaining and increasing position in the Red Side Guerilla Brims, an enterprise
engaged in racketeering activity, as described above, unlawfully, willfully, intentionally and
knowingly assaulted Kevin Terry with a dangerous weapon, in violation of Conn. Gen. Stat.
53a-8(a) and 53a-60(a)(2).
COUNT TWELVE
(VCAR Threatening to Commit Crime of Violence as to Kevin Terry)
3 7. The allegations in paragraphs 1-7 and 20 are incorporated by reference in this
Count.
ROBERT HARRIS, a.k.a. "Skully Mack," and CHRISTOPHER GRAHAM, a.k.a. "Ugg," for
the purpose of maintaining and increasing position in the Red Side Guerilla Brims, an enterprise
12
engaged in racketeering activity, as described above, unlawfully, willfully, intentionally and
knowingly threatened to commit a crime of violence as to Kevin Terry, in violation of Conn.
Gen. Stat. 53a-8(a) and 53a-6laa(a)(3).
(Money Laundering)
39. On or about the dates set forth below, in the District of Connecticut, the District
of Maine and elsewhere, the defendants JEFFREY BENTON, a.k.a. "Tall Man" and "Fresh,"
and KEITH YOUNG, a.k.a. "Capo," "Bapo" and "Poncho," and Rodrigo Ramirez, who is
charged in a separate Information, did knowingly conduct and attempt to conduct financial
transactions affecting interstate and foreign commerce, which transactions involved the proceeds
of a specified unlawful activity, that is, a conspiracy to distribute and to possess with intent to
distribute cocaine base ("crack cocaine"), with the intent to promote the carrying on of the
specified unlawful activity, and that while conducting and attempting to conduct such financial
transactions knew that the property involved in the financial transactions represented the
proceeds of some form ofunlawful activity:
COUNT DATE MONETARY TRANSACTION
13 August 8, 2011 Transfer of $2,500 via Western Union from Rodrigo Ramirez
in Bangor, Maine to JEFFREY BENTON in New Haven,
Connecticut.
14 August 11, 2011 Transfer of $1,500 via Western Union from Rodrigo Ramirez
Connecticut.
15 September 16, 2011 Transfer of $2,500 via Western Union from Rodrigo Ramirez,
Connecticut.
16 September 23, 2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
13
Bangor, Maine to JEFFREY BENTON m New Haven,

Connecticut.
17 September 23, 2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
Bangor, Maine to JEFFREY BENTON in New Haven,
Connecticut.
18 November 7, 2011 Transfer of$1,150 via Western Union from KEITH YOUNG in
Connecticut.
19 November 14,2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
Connecticut.
20 November 14, 2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
Connecticut.
21 November 14, 2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
Connecticut.
22 November 15,2011 Transfer of $500 via Western Union from Rodrigo Ramirez in
Connecticut.
All in violation of Title 18, United States Code, Sections 1956(a)(l )(A)(i) and 2.
COUNT WENTY-THREE
(Using a firearm during and in relation to a crime of violence)
40. On or about June 24, 2011, in the District of Connecticut, the defendant
JEFFREY BENTON, a.k.a. "Tall Man" and "Fresh," during and in relation to a crime of
violence for which he may be prosecuted in a court of the United States, to wit: the crime
charged in Count Five (VCAR murder in violation of 18 U.S.C. 1959(a)(l )) of this Indictment,
did knowingly and intentionally cause the death of Donnell Allick through the use of a firearm,
which killing is a murder as defined in Title 18, United States Code, Section 1111 (a).
In violation ofTitle 18, United States Code, Sections 924(c) and 9240)(1).
14
COUNT TWENTY -FOUR

41. On or about September 19, 2011, in the District of Connecticut, the defendant
ROBERT SHORT, a.k.a. "Santana," during and in relation to a crime of violence for which he
may be prosecuted in a court of the United States, to wit: the crime charged in Count Six (VCAR
murder in violation of 18 U.S.C. 1959(a)(l)) of this Indictment, did knowingly and
intentionally cause the death of Darrick Cooper through the use of a firearm, which killing is a
murder as defined in Title 18, United States Code, Section 1111 (a).
In violation of Title 18, United States Code, Sections 924(c) and 924(j)(l).
UNT TWEN'I Y-FIVE

TREVOR MURPHY, a.k.a. "Snookie," during and in relation to crimes of violence for which he
may be prosecuted in a court of the United States, to wit: the crimes charged in Counts Eight
(VCAR murder in violation of 18 U.S.C. 1959(a)(l )) and Nine (Hobbs Act robbery in violation
of 18 U.S.C. 1951) of this Indictment, did knowingly and intentionally cause the death of
Joseph Zargo through the use of a firearm, which killing is a murder as defined in Title 18,
United States Code, Section 1111(a).
In violation of Title 18, United States Code, Sections 924(c) and 924(j)(l ).
COUNT TWENTY -SIX

(Brandishing a firearm during and in relation to a crime ofviolence)
ROBERT HARRIS, a.k.a. "Skully Mack," and CHRISTOPHER GRAHAM, a.k.a. "Ugg," did
knowingly brandish, carry and use a firearm during and in relation to crimes of violence for
which they may be prosecuted in a court of the United States, that is, violations of Title 18,
15
United States Code, Sections 1959(a)(3) and 1959(a)(4), as set forth in Counts Eleven and
Twelve of this Indictment.
In violation ofTitle 18, United States Code, Sections 2 and 924(c)(1)(A).
COUNT TWENTY-SEVEN
(Distribution of cocaine base)
44. On or about June 3, 2014, in the District of Connecticut, the defendant ROBERT
HARRIS, a.k.a. "Skully Mack," along with Delton Pyles, who is charged in a separate
Information, did knowingly and intentionally possess with the intent to distribute and distribute a
mixture and substance containing a detectable amount of cocaine base ("crack cocaine"), a
Schedule II controlled substance.
In violation of Title 21, United States Code, Sections 841(a)(l) and 84l(b)(l)(C), and
Title 18, United States Code, Section 2.
COUNT TWENTY-EIGHT
45. On or about June 4, 2014, in the District of Connecticut, the defendant ROBERT
HARRIS, a.k.a. "Skully Mack," did knowingly and intentionally possess with the intent to
distribute and distribute a mixture and substance containing a detectable amount of cocaine base
("crack cocaine"), a Schedule II controlled substance.
In violation ofTitle 21, United States Code, Sections 841(a)(1) and 841(b)(l)(C).
COUNT TWENTY-NINE
(Possession with intent to distribute cocaine base)
CHRISTOPHER GRAHAM, a.k.a. "Ugg," did knowingly and intentionally possess with the
intent to distribute a mixture and substance containing a detectable amount of cocaine base
16
In violation ofTitle 21, United States Code, Sections 841(a)(l) and 841(b)(l)(C).
COUNT THIRTY
intent to distribute and distribute a mixture and substance containing a detectable amount of
cocaine base ("crack cocaine"), a Schedule II controlled substance.
In violation ofTitle 21, United States Code, Sections 841(a)(1) and 841(b)(l)(C).
COUNT THIRTY-ONE
COUNT THlRTY-TWO
In violation ofTitle 21, United States Code, Sections 841(a)(l) and 841(b)(1)(C).
C UNT TrURTY-THREE
17
COUNT THIRIY-THREE
COU THIRTY-F Lm.

A TRUEBILL
UNITED STATES OF AMERICA

G F ~' PERS
/s/
N
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I Case 3:15-cr-00174-JCH Document 1 Filed 09/30/15 Page 1 of 18

United States District Court

GRAND JURY N-14-1

UNITED STATES OF AMERICA CRIMINAL NO. 3:15CR f14 (/\\1\/T)

18 U.S.C. 1959(a)(5) (VCAR conspiracy to

18 U.S.C. 1951 (a) (Conspiracy to interfere with

18 U.S.C. 1956(a)(l)(A)(i) (Money laundering)

18 U.S.C. 924(c) (Carrying and using a firearm

18 U.S.C. 924(j)(l) (Causing the death of another

21 U.S.C. 841(a)(1) (Distribution of cocaine base)

18 U.S.C. 2 (Aiding and abetting)

The Grand Jury charges:

1. At all times relevant to this Indictment, the defendants JEFFREY BENTON,

ROBERT SHORT, a.k.a. "Santana," TREVOR MURPHY, a.k.a. "Snookie," ROBERT

constituted an ongoing organization whose members functioned as a continuing unit for a

common purpose of achieving the objectives of the enterprise.

3. The purposes ofthe enterprise included the following:

a. Enriching the members and associates of the enterprise through, among

acti viti es.

d. Keeping victims, witnesses and rival gang members in fear of the

Role ofthe Defendants

4. SHORT, MURPHY, HARRIS, and GRAHAM were members of the enterprise,

5. Under the direction of the leaders of the enterprise, SHORT, MURPHY,

conduct of the enterprise's affairs.

Means and Methods of the Enterprise

7. Among the means and methods by which BENTON, YOUNG, SHORT,

of the affairs ofthe enterprise were the following:

a. Members of the enterprise and their associates committed, attempted and

enterprise's criminal operations.

b. Members of the enterprise and their associates promoted a climate of fear

through violence, threats of violence and retaliation.

c. Members of the enterprise and their associates trafficked in cocaine and

cocaine base, Schedule II controlled substances.

d. Members of the enterprise engaged in money laundering to promote their

narcotics trafficking operation.

The Racketeering Violation

8. From approximately 2011 through in or about 2015, in the District of Connecticut

paragraphs Ten through Sixteen below.

The Pattern of Racketeering Activity

Sections 1961(1) and 1961(5), consisted ofthe following acts:

Racketeering Act One:

a. Conspiracy to Distribute Cocaine Base

Sections 84l(a)(1), 841(b)(l)(C) and 846.

b. Conspiracy to Commit Money Laundering

All in violation of Title 18, United States Code, Section 1962(c).

Racketeering Act Two - Conspiracy to Murder Carl Williams

unlawfully, willfully, intentionally and knowingly conspired to murder Carl Williams, m

violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.

Racketeering Act Three -Felony Murder of Kevin Lee

and 53a-54c (Felony murder).

Racketeering Act Four- Murder of Donnell Allick

Racketeering Act Five- Conspiracy to Murder Darrick Cooper

in violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.

Racketeering Act Six- Conspiracy to Murder Marquis Moore

Indictment, unlawfully, willfully, intentionally and knowingly conspired to murder Marquis

Moore, in violation of Conn. Gen. Stat. 53a-48(a) and 53a-54a.

Racketeering Act Seven- Murder of Donald Bolden

All in violation of Title 18, United States Code, Section 1962(c).

All in violation ofTitle 18, United States Code, Section 1962(d).