RE-INDICTMENT 3/ IN THE SUPERIOR COURT OF THE STATE OF ... · jermaine dollard harold ellington richard ellington tyron friend edward gaitlin alia grier st. claire jackson lebron

R E - I N D I C T M E N T

IN T H E S U P E R I O R C O U R T O F T H E S T A T E O F D E L A W A R E

3/

S T A T E O F D E L A W A R E

V.

C H R I S T O P H E R A N D E R S O N D A M O N A N D E R S O N C H A N D E L B A T H E A I R A B R O W N J E F F R E Y B U L L O C K M I C H A E L C A R P E N T E R C L A R E N C E C H A R L E S J E R M A I N E D O L L A R D H A R O L D E L L I N G T O N R I C H A R D E L L I N G T O N T Y R O N F R I E N D E D W A R D G A I T L I N A L I A G R I E R S T . C L A I R E J A C K S O N L E B R O N J O N E S N A K I S H A J O N E S E R I C L L O Y D S H E R I S H M I L L E R L E R O Y M I T C H E L L T R A M O N T M I T C H E L L A P R I L P R I T C H E T T M I C H A E L P R I T C H E T T J E R O M E P R I T C H E T T M A R K P U R N E L L T Y R O N E R O A N E

D A M I E N R O B I N S O N C H A R M A I N E S A U N D E R S Q U I N T O N T U R N E R D W A Y N E W H I T E N Y E E S H A W H I T E a//k/a N Y E E S H A R I N G ( ; O L D R A S H E E D W H I T E X A V I E R W I L S O N W I L L I A M W I S H E R M I C H A E L W O O D L E N

I N D I C T M E N T B Y T H E G R A N D J U R Y

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1710006528/1710006355 I.D. # 1710006760 L I ) . # 1710006763 / 1708020995 I.D. # 1710006764 I.D. # 1710006768

L I ) . # 1710006778 I .D. # 1710006781 I .D. # 1710006785 I .D. # 1710006788 / 1709004017 I .D. # 1710006790

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The Grand Jury charges C H R I S T O P H E R A N D E R S O N , D A M O N A N D E R S O N ,

C H A N D E L B A T H E A , I R A B R O W N , J E F F R E Y B U L L O C K , M I C H A E L

C A R P E N T E R , C L A R E N C E C H A R L E S , J E R M A I N E D O L L A R D , H A R O L D

E L L I N G T O N , R I C H A R D E L L I N G T O N , T Y R O N F R I E N D , E D W A R D G A I T L I N ,

A L I A G R I E R , ST. C L A I R E J A C K S O N , L E B R O N J O N E S , N A K I S H A J O N E S , E R I C

L L O Y D , L E R O Y M I T C H E L L , T R A M O N T M I T C T I E E E , A P R I L P R I T C H E T T ,

M I C H A E L P R I T C H E T T , J E R O M E P R I T C H E T T , M A R K P U R N E L L , T Y R O N E

R O A N E , D A M I N E R O B I N S O N , C H A R M A I N E S A U N D E R S , Q U I N T O N T U R N E R ,

D W A Y N E W H I T E , N Y E E S H A W H I T E a/k/a N Y E E S H A R I N G G O L D , R A S H E E D

W H I T E , X A V I E R W I L S O N , W I L L I A M W I S H E R , and M I C H A E L W O O D E E N , with

the following offenses:

COUNT ONE. A FKLONY

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C R I M I N A L R A C K E T E E R I N G in violation o f Title 11, Section 1503(a) o f the

Delaware Code.

D W A Y N E WHITE, on or between the 1 d a y o f January, 2015, and the 15 ' day o f

October, 2017, in the County o fNew Castle, State o f Dclawai'e, did associate wi th an enterprise

to conduct, or participate in the conduct o f the affairs o f the enterprise, tlirough a pattern o f

racketeering activity, or collection o f unlawful debts, by facilitating the sale or distribution o f

controlled substances as referenced in this Count, or by facilitating the transfer o f monies

relevant to the sale or distribution o f said controlled substances, or by participating in the

activities o f drug dealing, or in furtherance o f the sale or distribution o f said controlled

substances, or by tampering with evidence or witnesses. The specific acts referenced in this

Count are as follows:

1. D W A Y N E WHITE, on or between the U ' day o f January, 2015 and the 15 ' day o f October, 2017, did deliver or possess with intent to deliver more than 4 grams of a morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described in 16 Dei. Code § 4714, or any mixture containing any such controlled substance,

thereby engaging in conduct constituting Drug Dealing Heroin, Tier 4 or higher, i n violation of 16 Del. Code Section 4752(1).

2. D W A W H WHITE, on or between the E^ day o f January, 2015 and the 15"'day o f October, 2017, did possess more than 5 grams of a morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described in 16 Del. Code § 4714. or any mixture containing any such controlled substance, thereby engaging in conduct constituting Aggravated Pos.session o f Heroin, Tier 5 or higher, in violation o f 16 Del Code Section 4752(3).

3. D W A Y N E WHITE, on or between the E^ day o f February and the 7" day o f September, 2017, did manufacture, or possess wi th intent to manufacture 20 grams or more o f a Schedule I I controlled substance, cocaine or crack cocaine, or a mixture containing cocaine, thereby engaging in conduct constituting Drug Dealing Cocaine, in violation of 16 Del. Code Section 4752(1).

4. D W A Y N E WHITE, on or between the 1" day of .lanuary, 2015 and the 15 ' day o f October, 2017, did knowingly acquire or maintain an interest in, conceal, possess, transfer, or transport the proceeds o f criminal activity, or did knowingly conduct, supervise, or facilitate a transaction involving the proceeds o f criminal activity, tliereby engaging in conduct constituting the offense o f Money Laundering, in violation of 11, Dei. Code Section 951.

5. D W A Y N E WHITE, on or about the 11'^ day o f August, 2017, when intending that ancUher person engage in conduct constituting a class A felony, did solicit, request, command, importune or otherwise attempt to cause another person. Ira Brown, to engage in conduct which would constitute the felony or an attempt to commit tlie felony, or which would establish the other's complicity in its commission or attempted commission, thereby engaging in conduct constituting Criminal Solicitation, in violation o f 11, Del. Code Section 503.

6. D W A Y N E WHITE, on or about the 22" ^ and 23^^ days o f June, 2017, did knowingly offer, confer, or agree to confer any benefit upon a witness or a person about to be called as a witness in any official proceeding upon agreement or understanding that the testimony o f the witness w i l l thereby be influenced, thereby engaging in conduct constituting Bribing a Witness, in violation o f 11 Del. Code Section 1261.

7. D W A Y N E WHITE, on or about the 5 ' day o f September, 2017, did agree w i th Wil l iam Wisher to commit the offenses o f Drug Dealing Heroin Tier 4 or higher, Aggravated Possession o f Heroin Tier 5 or higher, and Possession o f a Firearm During the Commission ol'a Felony or by a Person Prohibited, and one, the other or each o f them engaged in conduct constituting the felony or felonies, by committing an over act in furtherance o f the conspiracy, thereby engaging in conduct constituting the felony o f Conspiracy in the Second Degree in violation o f 11 Del. Code Section 512.

8. D W A Y N E WHri 'E, on or about the 1T" day o f March, 2017, did agree wi th Xavier Wilson to commit the offenses o f Drug Dealing Heroin Tier 4 or higher, or Aggravated Possession o f Heroin Tier 5 or higher, and one, the other or each o f them engaged in conduct constituting the felony or felonies, by committing an over act in furtherance o f tlie conspiracy, thereby engaging in conduct constituting the felony o f Conspiracy in the Second Degree, in violation o f 11 Del. Code Section 512.

9. D W A T O E WHITE, on or about the 19 ' day o f A p r i l , 2017, did agree with Tyrone Roane to commit the offenses o f Drug Dealing Cocaine Tier 4 or higher, or Aggravated Possession o f Cocaine Tier 5 or higher, and one, the other or each o f them engaged in conduct constituting the felony or felonies, by committing an over

act in furtherance of the conspiracy, thereby engaging in conduct constituting the felony o f Conspiracy inthe Second Degree, in violation of 11 Del. Code Section 512.

10. D W A Y N E WHITE, on or about the 28 ' day of August, 2017, did agree with Charmaine Saunders to commit the offenses of Drug Dealing Heroin Tier 4 or higher, Aggravated Possession o f Heroin Tier 5 or higher, Drug Dealing Cocaine Tier 4 or higher, or Aggravated Possession of Cocaine bier 5 or higher, and one, the other or each o f them engaged in conduct constituting the felony or felonies, by committing an over act in furtherance o f the conspiracy, thereby engaging in conduct constituting the felony o f Conspiracy in the Second Degree, in violation o f 11 Del. Code Section 512.

11. D W A Y N E WHITE.' on or about the 23'" day of June, 2017, did agree wi th Tramont Mitchell to commit the offenses o f Drug Dealing Heroin l l e r 4 or higher, or Aggravated Possession of Heroin Tier 5 or higher, and one, the other or each o f them engaged in conduct constituting the felony or felonies, by committing an over act in furtherance o f the conspiracy, thereby engaging in conduct constituting the felony o f Conspiracy in the Second Degree, in violation o f 11 Del, C. Section 512.

12. D W A Y N E WHITE, on or between the 25"^ and 27'^' days o f August, 2017, did threaten to commit a crime likely to cause death or serious physical injury to another, and then did intentionally cause damage to tangible property o f another person, thereby engaging in conduct constituting Terroristic Tlireatening and Criminal Mischief in violation o f 11 Del. Code Sections 621 and 811.

13. D W A Y N E WHITE, on or about the 7'^' day o f September. 2017, did illegally possess a controlled substance, promethazine wi th codeine, a controlled substance as described in 16 Del. Code Section 4722, thereby engaging in conduct constituting Illegal Possession of a Controlled Substance in violation o f 11 Del. Code Section 4763(a).

14. D W A Y N E WHITE, on or between the 1 day o f January, 2015 and the 15'^ day o f October, 2017, did wil l ful ly attempt to evade or defeat any tax imposed by Title 4 or by Title 30 o f the Delaware Code or the payment thereol', other than Section 3002 and Chapters 51 and 52 o f Title 30, thereby engaging in conduct constituting Attempt to Evade or Defeat tax, in violation o f 30 Del. Code Section 571.

COUNT TWO. A FELONY

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C O N S P I R A C Y T O C O M M I T R A C K E T E E R I N G in violation o f Title 11, Section

1503 o f the Delaware Code.

CHRISTOPHER ANDERSON. D A M O N ANDERSON. C H A N D E L B A T H E A , I R A

B R O W N , JEEFREY B U L L O C K . M I C H A E L CARPENTER, CLARENCE CHARLES,

JERMAINE D O L L A R D , H A R O L D ELLINGTON, RICHARD E L L I N G T O N , T Y R O N

FRIEND, E D W A R D G A I T L I N , A L I A GRIER, ST. CLAIRE JACKSON, LEBRON JONES,

N A K I S H A JONES, ERIC L L O Y D , SHERISH M I L L E R , LEROY M I T C H E L L , T R A M O N T

M I T C H E L L . APRIL PRITCHEIT , M I C H A E L PRITCHETT, JEROME PRITCHETT, M A R K

PURNELL, TYRONE ROANE, D A M I N E ROBINSON, C H A R M A I N E SAUNDERS,

Q U I N T O N TURNER, D W A Y N E WHITE, NYEESHA WHITE, RASHEED W H I T E , X A V I E R

WILSON. W I L L I A M WISHER, and M I C H A E L W O O D L E N between the U ' day o f January,

2015, and the 15 ^ day o f October, 2017, inthe County o fNew Castle, State o f Delaware, when

intending to promote or facilitate the affairs o f the enterprise referred to in Count I o f this

Indictment, herein incorporated by reference, did agree with one, the other, or all , that one, the

other, or all o f tliem would engage in conduct constituting the felony o f Criminal Racketeering,

as defined by Title 11. Section 1503(a) o f the Delaware Code, and that one or the other, or each

of them, did commit an over act in furtherance o f the conspiracy, as set forth in paragraphs /

through 14 of Count I o f this Indictment.

COUNT THREE. A FELONY

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D R U G D E A L I N G H E R O I N in violation of'Fitle 16, Section 4752(1) o f the Delaware

Code.

CHRISTOPHER ANDERSON, D A M O N ANDERSON, JEFFREY B U L L O C K ,

M I C H A E L CARPENTER, CLARENCE CHARLES, JERMAINE D O L L A R D . R I C H A R D

E L L I N G T O N , H A R O L D E L L I N G T O N , T Y R O N FRIEND, E D W A R D G A I T L I N , ST.

C L A I R E JACKSON. JEROME PRITCHETT, TYRONE ROANE, QUINTON TURNER,

D W A Y N E WHITE, RASHEED WHITE, W I L L I A M WISHER, M I C H A E L WOODTEN, on or

between the U^ day o f January, 2015 and the 15 ' day o f October, 2017, inthe County o fNew

Castle, State o f Delaware, did knowingly deliver or possess with intent to deliver 4 grams or

more o f morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described in

16 Del. Code § 4714, or any mixture containing any such controlled substance.

COUNT FOUR. A FELONY #N m

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 o f the

Delaware Code.

QUINTON TURNER and D W A Y N E WHITE, on or between the 8" day of August and

the 7' ' day o f September, 2017, in the County ofNew Castle, State o f Delaware, when intending

to promote or facilitate the commission o f Drug Dealing as set forth in Count Three, which is

incorporated herein by reference, did agree with each other to commit said crime and one or

more o f them did commit and overt act in pursuance of said conspiracy by engaging in conduct

constituting said felony or attempt to commit said felony by committing some other overt step in

pursuance o f the conspiracy.

COUNT FIVE, A FELONY #N #N

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 o f the

Delaware Code.

CHRISTOPHER ANDERSON and D W A Y N E WHITE, on or between the 8 ^ day o f

August and the 7* day o f September, 2017, in the County ofNew Castle, State o f Delaware,

when intending to promote or facilitate the commission o f Drug Dealing as set forth i n Count

Three, which is incorporated herein by reference, did agree with each other to commit said crime

and one or more o f them did commit and overt act in pursuance o f said conspiracy by engaging

in conduct constituting said felony or attempt to commit said felony by committing some other

overt step in pursuance o f the conspiracy.

COUNT SIX. A FELONY #N #N

C O N S P l l C \ C y S E C O N D D E G R E E in violation o f Title 11, Section 512 o f the

Delaware Code.

E D W A R D G A I T L I N and D W A Y N E WHITE, on or between the 8' day o f August and

the 7 '' day o f September, 2017, inthe County ofNew Castle, State o f Delaware, when intending

to promote or facilitate the commission o f Drug Dealing as set forth in Count Three, which is


more o f them did commit and overt act in pursuance o f said conspiracy by engaging in conduct

constituting said felony or attempt to commit said felon)' by committing some otlier overt step in


COUNT SEVEN. A FELONY

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C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 ofthe

Delaware Code.

RICHARD ELLlNOrON and D W A Y N E WHITE, on or between the 8 ' day o f August

and the 7 '' day o f September, 2017, in the County of New Castle, State o f Delaware, when

intending to promote or facilitate the commission o f Drug Dealing as set forth in Count Three,

which is incorporated herein by reference, did agree wi th each other to commit said crime and

one or more o f them did commit and overt act in pursuance o f said conspiracy by engaging in

conduct constituting said felony or attempt to commil said felony by committing some other


COUNT FIGHT. A FELONY

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Delaware Code.

JEFFREY B U L L O C K and D W A Y N E WHITE, on or between the 8* day o f August and

the 7" day o f September, 2017, in the County o f New Ca.stle, Stale o f Delaware, when intending

to promote or facilitate the commission o f Diug Dealing as set forth in Count Three, which is

incoiporated herein by reference, did agree wi th each other to commit said crime and one or



pursuance ofthe conspiracy.

COUNT NINE. A FELONY #N ^

m ' C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 ofthe

Delaware Code.

CLARENCE CHARLES and D W A Y N E WHITE, on or between the 8 ' day o f August

and the 7* day of September, 2017, in the County o f New Castle, State o f Delaware, when


which is incorporated herein by reference, did agree with each other to commit said crime and


conduct constituting said felony or attempt to commit said felony by committing some other


COUNT TEN. A FELONY

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C O N S P I R A C Y S E C O N D D E G R E E in violation of Title 11, Section 512 ofthe

Delaware Code.

M I C H A E L W O O D L E N and D W A W E W H I I E, on or between the 8"' day o f August

and the 7 '' day o f September, 2017, in the County o fNew Castle, State o f Delaware, when

intending to promote or facilitate the commission of Drug Dealing as set forth in Count Three,


one or more o f them did commil and overt act in pursuance o f said conspiracy by engaging in


overt step in pursuance ofthe conspiracy.

COUNT ELEVEN. A FELONY

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C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 1 L Section 512 ofthe

Delaware Code.

JEROME PRITCHETT and D W A Y N E WHITE, on or between the 8'" day o f August and

the 23'"' day o f August, 2017, in the County o fNew Castle, State o f Delaware, when intending to

promote or facilitate the commission o f Drug Dealing as set forth in Count Tliree, which is


more o f them did commil and overt act in pursuance o f said conspiracy by engaging in conduct



COUNT I ' W E L V E . A FELONY m m


Delaware Code.

T Y R O N E ROANE and D W A Y N E WHITE, on or between the U ' day o f January and the

7*' day o f September, 2017, in the County o fNew Castle, State o f Delaware, when intending to

promote or facilitate the commission o f Drug Dealing as set forth in Count Three, which is

incorporated herein by reference, did agree wi th each other to commit said crime and one or




COUNT THlRTEEN. A FELONY

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m C O N S P I R A C Y S F X O N D D E G R E E in violation o f Title 11. Section 512 o f the

Delaware Code.

T Y R O N FRIEND and D W A Y N E WHITE, on or between the 1 day o f January 2015

and the 7''' day o f September, 2017, in the County ofNew Castle. State o f Delaware, when





ox ert step in pursuance o f the conspiracy.

COUNT FOURTEEN. A FELONY

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Delaware Code.

M I C H A E T CARPENTER and D W A Y N E WHITE, on or between the 8*" day o f August

and the 7 '' day o f September, 2017, in the County ofNew Castle, State ofDelaware, when

intending to promote or facilitate the commission o f Ding Dealing as set forth in Count 'Hiree,


one or more o f them did commil and oveit act in pursuance o f said conspiracy by engaging in

conduct constituting said felony or attempt to commil said felony by committing some other


COUNT FIFTEEN. A FELONY

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C O N S P I R A C Y SECOND DEGREE in violation o f Title 1! , Section 512 ofthe

Delaware Code.

H A R O L D ELLINGT ON and D W A Y N E W H I TE, on or between the 8 '' day o f August

and the V"" day o f September, 2017, in the County ofNew Castle, Stale ofDelaware, when

intending to promote or facilitate the eommission o f Drug Dealing as set forth in Count Three,

which is incoiporated herein by reference, did agree with each other to commit said crime and




COUNT SIXTEEN. A FELONY

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C O N S P I R A C Y SECOND D E G R E E in violation o f Title I E Section 512 ofthe

Delaware Code.

RASHEED WHITE and D W A Y N E WHITE, on or between the V day o f January 2015

and the 7"' day o f September, 2017, in the County ofNew Castle, Stale ofDelaware, when






COUNT SEVENTEEN. A FELONY

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C O N S P I R A C Y S E C O N D D E G R E E in violation ofTi t lc 11, Section 512 o f the

Delaware Code.

C H A R M A I N E SAUNDERS and D W A Y N E WHITE, on or about the 28'^ day o f August,

2017, in the County ofNew Castle, State ofDelaware, when intending to promote or facilitate

the commission o f Drug Dealing as set forth in Count Three, which is incorporated herein by

reference, did agree with each other to commit said crime and one or more of them did commit

and overt act in pursuance o f said conspiracy by engaging in conduct constituting said felony or

attempt to commit said felony by committing some other overt step in pursuance ofthe

conspiracy.

COUNT EIGHTEEN. A FELONY

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m C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title I I , Section 512 ofthe

Delaware Code.

T R A M O N T M I T C H E L L and D W A Y N E WHITE, on or about the 23^'' day o f June,

2017, in the County of New Castle, State ofDelaware, when intending to promote or facilitate

the commission o f Drug Dealing as set forth in Count Three, which is incoiporated herein by

reference, did agree with each other to commit said crime and one or more of them did commil

and overt act in pursuance o f said conspiracy by engaging in conduct constituting said felony or

attempt to commit said felony by committing some other overt step in pursuance ofthe

conspiracy.

COUNT NINETEEN. A FELONY

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A G G R A V A T E D P O S S E S S I O N O F H E R O I N in violation o f Title 16, Section 4752(3)

of the Delaware Code.

C H A N D E L BATHEA, JEROME PRITCHETT, I 'YRONE ROANE, D W A Y N E

W H I T E , and W I L L I A M WISHER on or between the U' day o f January, 2015 and the 15'** day o f

October, 2017, in the County o fNew Castle, State ofDelaware, did knowingly possess 5 grams

or more o f a morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as

described in 16 Del. Code § 4714, or any mixture containing any such controlled substance.

COUNT TWENTY. A FELONY

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Delaware Code.

C H A N D E L B A T H E A and D W A Y N E WHITE, on or about the 6"* day o f September,

2017, in the County ofNew Castle, Stale o f Delaware, when intending to promote or facilitate

the commission o f Aggravated Possession as set forth in Count Nineteen, which is incorporated

herein by reference, did agree with each other to commit said crime and one or more o f them did

commit and overt act in pursuance o f said conspiracy by engaging in conduct constituting said

felony or attempt to commit said felony by committing some other overt step in pursuance ofthe

conspiracy.

COUNT T W E N T Y ONE. A FELONY

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CONSPmACY SECOND D E G R E E in violation o f Title 11, Section 512 ofthe

Delaware Code.

JEROME PRITCHETT and D W A Y N E WHITE, on or about the 23 '' day o f August,

2017 in the County ofNew Castle, State ofDelaware, when intending to promote or facilitate the

commission o f Aggravated Possession as set forth in Count Nineteen, which is incorporated

herein by reference, did agree wi th each other to commil said crime and one or more o f them did

commil and overt act in pursuance o f said conspiracy by engaging in conduct constituting said


conspiracy.

COUNT T W E N T Y TWO. A FELONY

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m C O N S P I R A C Y S E C O N D D E G R E E in violation o fTi t l c U , Section 512 ofthe

Delaware Code.

TYRONE ROANE and D W A Y N E WHITE, on or between the 27"^ day o f January and

the 11'^ day o f October, 2017, in the County o fNew Castle, State ofDelaware, when intending

to promote or facilitate the commission o f Aggravated Possession as set forth in Count Nineteen,

which is incorporated herein by reference, did agree wi th each other to commil said crime and




COUNT TWENTY THREE. A FELONY

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Delaware Code.

W I L L I A M WISHER and D W A Y N E WHITE, on or about the 5*'' day o f September,

2017, in the County o f New Castle, State ofDelaware, when intending to promote or facilitate


herein by reference, did agree with each other to commit said crime and one or more o f them did


felony or attempt to commit said felony by committing some other overt step in pursuance o f the

conspiracy.

COUNT T W E N T Y FOUR. A FELONY

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m C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 ofthe

Delaware Code.

C H A R M A I N E SAUNDERS and D W A Y N E WHITE, on or about the 28 ' day o f August.

2017, i n the County ofNew Castle, State ofDelaware, when intending to promote or facilitate


herein by reference, did agree wi th each other to commit said crime and one or more of them did

commit and overt act in pursuance oi'said conspiracy by engaging in conduct constituting said

felony or attempt to commil said felony by committing some other ox'ert step in pursuance o f the

conspiracy.

COUNT TWENTY FIVE. A FELONY

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D R l C D E A L I N G C O C A I N E in violation o f Title 16, Section 4752(1) o f the Delaware

Code.

CLARENCE CHARLES, JERMAINE D O L L A R D , TYRONE ROANE, H A R O L D

E L L I N G T O N , D W A Y N E WHITE, and W I L L I A M WISHER on or between the U ' day o f

January, 2015 and the 15 '' day o f October, 2017, in the County ofNew Castle, State o f

Delaware, did knowingly deliver or possess with intent to deliver 20 grams or more o f cocaine or

any mixture containing cocaine, a controlled substance as described in 16 Del. Code §

4716(b)(4), or did knowingly manufacture or possess wi th intent to manufacture or deliver 20

grams or more o f cocaine or a mixture containing cocaine.

COUNT TWENTY SIX. A FELONY

#N

#N


Delaware Code.

CLARENCE CHARLES and D W A Y N E MTIITE, on or between tlie \ day o f August

and the 2"' day o f September, 2017, inthe County o f New Castle, State ofDelaware, when

intending to promote or facilitate the commission o f Drug Dealing as set forth in Count Twenty

Five, which is incorporated herein by reference, did agree with each other to commit said crime




COUNT TWENTY SEVEN. A FELONY

#N __

UN

C O N S P I R A C Y SECOND DEGREE in violation o f Title 11, Section 512 o f the

Delaware Code.

TYRONE ROANE and D W A Y N E WHITE, on or between the 27 ' day o f January and

the 1 E' day o f October, 2017, in the County ofNew Castle, State ofDelaware, when intending

to promote or facilitate the commission o f Drug Dealing as set forth in Count Twenty Five,





COUNT TWENTY EIGHT. A FELONY

UN

#N

C O N S P I R A C Y SECOND D E G R E E in violation o f Title I I , Section 512 ofthe

Delaware Code.

JERMAINE D O L L A R D and D W A Y N E WHITE, on or between the 24''' day o f August

and the 5"' day o f September, 2017, inthe County ofNew Castle, State ofDelaware, when

intending to promote or facilitate the commission o f Drug Dealing as set forth in Count Twenty

Five, which is incorporated herein by reference, did agree with each other to commit said crime




COUNT TWENTY NINE. A FELONY

#N

UN

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 1 U Section 512 ofthe

Delaware Code.

I-IAROUD ELLINGTON and D W A Y N E WHITE, on or between the S"' day o f August

and the 7'*' day o f September. 2017, in the County ofNew Castle, State ofDelaware, when

intending to promote or facilitate the commission o f Drug Dealing as set forth in Count Tw^cnty

Five, W'hich is incorporated herein by reference, did agree with each other to commil said crime

and one or more o f them did commit and overt act in pursuance of said conspiracy by engaging


overt step in pursuance of the conspiracy.

COUNT THIRTY. A FELONY

#N

#N

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 1 U Section 512 ofthe

Delaware Code.

W I L L I A M WISHER and D W A Y N E WHITE, on or about the S"" day o f September,


the commission of Drug Dealing as set forth in Count Twenty Five, which is incorporated herein

by reference, did agree with each other to commit said crime and one or more of them did



conspiracy.

COITNT THIRTY ONE. A FELONY

#N

#N

C O N S P I R A C Y S E C O N D D E G R E E in violation ofTi t lc 1 E Section 512 o f the

Delaware Code.

CHARMATNE SAUNDERS and D W A T O E WHFfE, on or about the 28"' day o f August,


the commission o f Drug Dealing as set forth in Count Twenty Inve, which is incorporated herein

by reference, did agree with each other to commit said crime and one or more o f them did


felony or attempt to commit said felony by committing some other overt step in pursuance o f the

conspiracy.

COUNT T H I R T Y TWO. A FELONY

#N _ #N #N

# N #N #N

#N #N UN

#N

M O N E Y L A U N D E R I N G in violation o f Title H , Section 951 o f the Delaware Code.

D A M O N ANDERSON, JERMAINE D O L L A R D , H A R O L D E L L I N G T O N , E D W A R D

G A I T L I N , ERIC L L O Y D . D W A Y N E WHITE, NYEESHA WHITE, RASHEED WHITE, and

W I L L I A M WISHER, on or between the U ' day o f January, 2015 and the 15"' day o f October,

2017, did knowingly acquire or maintain an interest in, conceal, possess, transfer, or transport the

proceeds o f criminal activity, or did knowingly conduct, supervise, or facilitate a transaction

involving the proceeds o f criminal activity.

COUNT THIRTY THREE. A FELONY

UN

UN

C O N S P I R A C Y S E C O N D D E G R E E in violation of Title I I , Section 512 ofthe

Delaware Code.

D A M O N ANDERSON and D W A Y N E WHITE, on or between the 8'" day o f August and

7'" day o f September, 2017, in the County ofNew Castle, State ofDelaware, when intending to

promote or facilitate the commission o f Drug Dealing as set forth in Count Thirty Two, which is





COUNT THIRTY FOUR. A FELONY

#N _._

UN


Delaware Code.

JERMAINE D O L L A R D and D W A Y N E WHITE, on or between the 8'" day o f August,

2017 and 7'" day o f September. 2017, inthe County o f New Castle, State ofDelaware, when

intending to promote or facilitate the commission o f Drug Dealing as set forth in Count Thirty

Two, which is incorporated herein by reference, did agree with each other to commit said crime

and one or more o f them did commit and ovett act in pursuance o f said conspiracy by engaging

in conduct constituting said felony or attempt to comrnit said felony by committing some other


C:OUNT THIRTY FIVE. A FELONY

#N__

UN

C O N S P I R A C Y S E C O N D D E G R E E in violation o fTi t l c 11, Section 512 ofthe

Delaware Code.

H A R O L D E L L I N G T O N and D W A Y N E WHITE, on or between the 8'" day o f August,

2017 and 7'" day o f September, 2017, in the County o fNew Castle, State ofDelaware. when


Two, which is incorporated herein by reference, did agree wi th each other to commit said crime




COUNT T H I R T Y SIX. A FELONY

#N

#N

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title I I , Section 512 ofthe

Delaware Code.

E D W A R D G A I T L I N and D W A Y N E WHITE, on or between the 8'" day o f August and

the 7"" day o f September, 2017, in the County o f New Castle, Slate ofDelaware, when intending

to promote or facilitate the commission o f Drug Dealing as set forth in Count Thirty Two, which

is incorporated herein by reference, did agree with each other to commit said crime and one or




COUNT THIRTY SEVEN. A FELONY

#N

#N

C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title I E Section 512 ofthe

Delaware Code.

ERIC L L O Y D and D W A Y N E WHITE, on or between the U ' day of January, 2015 and

the 15'" day o f October, 2017, in the County o f New Castle, State ofDelaware, when intending

to promote or facilitate the commission o f Drug Dealing as set forth in Count Thirty Two, which

is incorporated herein by reference, did agree wi th each other to commit said crime and one or

more o f them did commit and overt act in pursuance of said conspiracy by engaging in conduct



COUNT T H I R T Y EIGHT. A FELONY

# N _ _ _ _

#N


Delaware Code.

NYEESHA WHITE and D W A Y N E WHITE, on or between the U' day o f .lanuary, 2015

and the 15'" day o f October, 2017, in the County ofNew Castle, State ofDelaware, when



and one or more o f tliem did commit and overt act in pursuance o f said conspiracy by engaging



COUNT THIRTY NINE. A FELONY

m #N


Delaware Code.

W I L L I A M WISHER and D W A Y N E WHITE, on or between the U ' day o f March and

tlie 5"' day o f September, 2017, in the County o f New Castle, State o f Delaware, when intending

to promote or facilitate the commission of Drug Dealing as set forth in Count Thi i ly Two, which

is incorporated herein by reference, did agree with each other to commit said crime and one or

more of tliem did commit and overt act in pursuance o f said conspiracy by engaging in conduct



COUNT FORTY. A FELONY

# N _ _

m C O N S P I R A C Y S E C O N D D E G R E E in violation o f Title 11, Section 512 o f the

Delaware Code.

RASHEED WHITE and DWA^TJE WHITE, on or between the U ' day o f January, 2015

and the 15'" day o f October, 2017, in the County o f New Castle, State o f Dclawaie, when






COUNT FORTY QNH. A FELONY

#N

m C R I M I N A L S O L I C I T A T I O N in violation of Title 11, Section 503 ofthe Delaware

Code.

I R A BROWN and D W A Y N E WHITE, on or about the 27'" day o f August, 2017, when

intending that another person engage in conduct constituting a class A felony, did solicit, request,

command, importune or otherwise attempt to cause another person, Ira Brown, to engage in

conduct which would constitute the felony or an attempt to commit the felony, or which would

establish the other's complicity in its commission or attempted commission.

COUNT FORTY TWO. A FELONY

#N

#N_

C O N S P I R A C Y F I R S T D E G R E E in violation o f Title 11, Section 513 ofthe Delaware

Code.

IRA BROWN and D W A Y N E WHITE, on or about the 27'" day o f August, 2017, in the

County o f New Castle, Slate o f Delaware, when intending to promote or facilitate the

commission o f a Class A Felony to a witness against Michael Pritchett, did agree with each other

to commit said crime and one or more o f them did commit and overt act in pursuance o f said

conspiracy.

COUNT FORTY THREE. A FELONY

#N m m # N _ .

A G G R A V A T E D A C T O F I N T I M I D A T I O N in violation o f Title 11, Section 3533 o f

the Delaware Code.

LEROY M I T C H E L L , M I C H A E L PRITCHEIT, M A R K PURNELL, and D W A Y N E

WHITE on or between the 9"' day o f June and the 27"' day o f August, 2017, in the County o f

New Castle, Stale ofDelaware, did knowingly and with malice attempt to prevent or dissuade a

witness or victim from attending or giving testimony in any trial, proceeding or inquiry

authorized by law, and did so accompanied by an express or implied threat o f force or violence

upon a victim or a witness, or did so in furtherance o f a conspiracy as set forth in Count Two o f

this indictment.

COUNT FORTY FOUR. A FELONY

#N

B R I B I N G A W I T N E S S in violation o f Title 11, Section 1261 ofthe Delaware Code.

D W A Y N E WHITE, on or about the 22"" and 23^" days o f June, 2017, in the County o f

New Castle, State ofDelaware, did knowingly offer, confer, or agree to confer any benefit upon

a witness or a person about to be called as a witness in any official proceeding upon agreement

or understanding that the testimony ofthe witness w i l l thereby be inllucnccd.

COUNT FORTY FIVE. A MISDEMEANOR

#N

T E R R O R I S T I C T H R E A T E N I N G in violation o f Title 11, Section 621 ofthe Delaware

Code.

D W A Y N E W HITE, on or between the 25'" and 27'" days o f August, 2017, in the Coutny

o fNew Castle, State ofDelaware, did thi'eaten to commit a crime likely to cause death or serious

physical injury to another.

COUNT FORTY SIX. A MISDEMEANOR

#N

m

C R M I N A L M I S C H I E F in violation o f Title 11, Section 811 ofthe Delaware Code.

D A M I E N ROBINSON and D W A Y N E WHITE, on or between the 25'" and 27'" days o f

August, 2017, in the County ofNew Castle, State ofDelaware, did intentionally cause damage to

tangible property o f another person.

COUNT FORTY SEVEN. A MISDEMEANOR # N _

I L L E G A L P O S S E S S I O N O F A C O N T R O L L E D S U B S T A N C E in violation o f Title

16, Section 4763(a) of the Delaware Code.

D W A Y N E WHITE, on or about the 7"' day o f September, 2017, in the County o fNew

Castle, State ofDelaware, did illegally possess a controlled substance, promethazine wi th

codeine, a controlled substance as described in 16 Del. Code Section 4722.

COUNT FORTY EIGHT. A FELONY

m m

A T T E M P T T O E V A D E O R D E F E A T T A X i n violation o f Title 30, Section 571 ofthe

Delaware Code.

D W A Y N E WHITE and NYEESHA W H I I E , on or between the U ' day o f January, 2015

and the 15'" day o f October, 2017, in the County o fNew Castle, State ofDelaware, did wi l l fu l ly

attempt to evade or defeat any tax imposed by Title 4 or by Title 30 ofthe Delaware Code or the

payment thereof, other than Section 3002 and Chapters 51 and 52 o f Title 30.

COUNT FORTY NINE. A FELONY

#N #N m T A M P E R I N G W I T H P H Y S I C A L E V I D E N C E in violation o f Title 11, Section 1269

of the Delaware Code.

C H A N D E L BATHEA, SHERISH M I L L E R , D W A Y N E WHITE on or about 6"' day o f

September, 2017, in the County ofNew Castle, State ofDelaware, believing that certain physical

evidence, heroin, was about to be produced or used in a prospective official proceeding and

intending to prevent its production, or use, did knowingly and unlawfully attempt to suppress it

in an act o f concealment, alteration, or destruction, by throwing it out a vehicle window.

COUNT FIFTY. A FELONY

#N

T A M P E R I N G W I T H P H Y S I C A L E V I D E N C E in violation o f Title 11, Section 1269

ofthe Delaware Code.

CLARENCE CHARLES on or about 2U ' day o f August, 2017, in the County o f New

Casllc. State ofDelaware. believing that certain physical evidence, heroin, was about to be

produced or used in a prospective oITicial proceeding and intending to prevent its production, or

use, did knowingly and unlawfully attempt to suppress it in an act o f concealment, alteration, or

destruction, by throwing it out a vehicle window.

COUNT FIFTY ONE. A FELONY

m #N ^ ^ ^ ^ ^ # N _

D R U G D E A L I N G C O D E I N E in violation o f Title 16, Section 4754 ofthe Delaware

Code.

H A R O L D E L L I N G T O N , ST. CLAIRE JACKSON, and N A K I S H A JONES, on or

between the U ' day o f January, 2015 and the 15"' day o f October, 2017, in the County o fNew

Castle, Stale o f Delaware, did b iowingly deliver or possess with intent to deliver a promethazine

with codeine, or any o f its salts, or dihydrocodeine, ethylmorphine, or atropine sullatc, in excess

of the amounts set forth under 16 Del. Code Section 4722(b}.

COUNT FIFTY TWO. A FHLQNY

#N

H I N D E R I N G P R O S E C U T I O N in violation o f Title 11, Section 1244 ofthe Delaware

Code.

NYEESI l A W H l ' I E, on or between the 17'" day o f August and the 4'" day o f September,

2017, in the County ofNew Castle, State ofDelaware, wi t l i intent to prevent, hinder or delay the

discovery or apprehension of, or the lodging o f a criminal charge against, a person whom the

person accused of hindering prosecution knows has committed acts constituting a crime, did

warn the person o f impending discovery or apprehension or did suppress, by an act o f

concealment, alteration or destruction, any physical evidence which might aid in the discovery or

apprehension ofthe person or in the lodging o f a criminal charge against the person.

COUNT FIFTY THREE. A FELONY

#N

H I N D E R I N G P R O S E C U T I O N in violation o f Title I E Section 1244 ofthe Delaware

Code.

APRIL PRITCHETT, on or between the 7'" day o f June and 27'" day o f June, 2017, in the

County o f New Castle, State ofDelaware, with intent to prevent, hinder or delay the discovery or

apprehension of, or the lodging o f a criminal charge against, a person whom the person accused

of hindering prosecution knows has committed acts constituting a crime, did w arn the person o f

impending discover)' or apprehension or did suppress, by an act o f concealment, alteration or

destruction, any physical evidence which might aid in the discovery or apprehension o f the

person or in the lodging o f a criminal charge against the person.

COUNT FIF ' IT hOUR. A FELONY

#N #N ^ #N__

#N m

POSSESSION OF A F I R E A R M D U R I N G T H E C O M M I S S I O N OF A F E L O N Y in

violation o f Title 11, Section 1447A ofthe Delaware Code.

C H A N D E L BATHEA, .lEROME PRITCHETT, D W A Y N E WHITE, NYEESHA W H I T E

and W I L L I A M WISHER on or between the U' day o f January, 2015 and the 5'" day ofSeptember,

2017, in the County ofNew Castle, State ofDelaware, did knowingly possess a firearm, as defined

by Title I I , Section 222 o f tlic Delaware Code o f 1974, as amended, during the commission o f

Criminal Racketeering as set forth in 11 Del. Code Section 1503, or Drug Dealing or Aggravated

Possession of Heroin or Cocaine, felonies as set forth in Counts Three, Nineteen and Twenty Five

of this indictment, which arc incorporated herein by reference.

COUNT FIFTY FIVE. A FELONY

#N

A T T E M P T E D S T R U C T U R I N G in violation o f Title 11, Section 531 ofthe Delaware

Code.

L E B R O N JONES, on or about the 6"' day ofSeptember, in the County o f New Castle,

State ofDelaware, did with the purpose o f evading a transaction reporting requirement o f this

State or o f 31 U.S.C. § 5311 et seq. or 31 C.E.R. § 103 et scq., or any rules or regulations

adopted under those chapters and sections, caused or attempt to caused a financial institution,

including a video lottery facility, foreign or domestic money transmitter or an authorized

delegate thereof, cheek casher, person engaged in a trade or business or any other individual or

cntity required by stale or federal law to file a report regarding currency transactions or

suspicious transactions to fail to file a report, or did attempt to structui'e or assist in structuring,

any transaction with one or more financial institutions, including a video lottery facility, foreign

or domestic money transmitters or an authorized delegate thereof check cashers, persons

engaged in a trade or business or any other individuals or entities required by state or federal law

to flic a report regarding currency transactions or suspicious transactions, which acts, under the

circumstances as he believed them to be. constituted a substantial step in a course o f conduct

planned to culminate in the commission of Structuring, in violation o f 11 Del. Code Section

951(0(3Hg).

COUNT FIFTY SIX. A f E L O N Y #N

D R U G D E A L I N G H E R O I N in violation o f Title 16, Section 4752(1) ofthe Delaware

Code.

W I L L I A M WISHER on or about the 5'" day of September, 2017, in the County o f N e w

Castle, State ofDelaware, did knowingly deliver or possess with intent to deliver 4 grams or

more o f morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described in

16 Del. Code § 4714, or any mixture containing any such controlled substance.

COUNT FIF FY SEVEN. A I 'ELONY

#N



W I L L I A M WISHER on or about the 5"' day o f September, 2017, in the County o fNew

Castle, State ofDelaware, did iaiowingly possess 5 grams or more o f a morphine, opium, any

salt, isomer or salt o f an isomer thereof, or heroin as described in 16 Del. Code § 4714, or any

mixture containing any such controlled substance.

COUNT FIFTY EIGHT. A FELONY

#N

D R U G D E A L I N G C O C A I N E in violation o f Title 16, Section 4752(1) ofthe Delaware

Code.

W I L L I A M WISHER on or about the 5'" day ofSeptember, 2017, in the County o f New

Castle, State o f Delaware, did knowingly deliver or pcsscss with intent to deliver 10 grams or more

of cocaine or any mixture containing cocaine, a controlled substance as described in 16 Del. Code

§ 4716(b)(4).

COUNT FIFTY NINE. A FELONY

#N

A G G R A V A T E D P O S S E S S I O N O F C O C A I N E in violation o f Title 16, Section

4752(3) ofthe Delaware Code.

W I L L I A M WISHER on or about the 5'" day ofSeptember, 2017, in the County o fNew

Castle, State ofDelaware, did knowingly possess 10 grams or more o f cocaine or any mixture

containing cocaine, a controlled substance as described in 16 Del. Code § 4716(b)(4).

COUNT SIXTY. A FELONY

#N

P O S S E S S I O N O F A F I R E A R M D U R I N G T H E C O M M I S S I O N O F A F E L O N Y in

violation o f Title I I , Section 1447A ofthe Delaware Code.

W I L L I A M WISHKR on or about the 5'" day o f September, 2017, in the County o f New

Castle. State ofDelaware, did knowingly possess a firearm, as defined by Title 11, Section 222 of

the Delaware Code o f 1974, as amended, during the commission o f Drug Dealing Heroin,

Aggravated Possession of Heroin. Drug Dealing Cocaine or Aggravated Possession of Cocaine,

felonies as set forth in Counts Fifty Six, Fifty Seven, Fifty Eight or Fifty Nine o f this indictment,

which are incorporated herein by relerence.

COUNT SIXTY ONE. A FEI.ONY

#N

P O S S E S S I O N O R C O N T R O L O F A F I R E A R M B Y A P E R S O N P R O H I B I T E D in

violation o f Title 11, Section 1448 of the Delaware Code.

W I L L I A M WISHER on or about the 5'" day o f September, 2017, in the County o f N e w

Castle, State ofDelaware. did knowingly own, possess or control a firearm as defined under

Title 11, Section 222 o f the Delaware Code o f 1974, after having been convicted in Case

Number 0402002084, in the Superior Court o f the Slate ofDelaware, on or about November 4,

2005, to tlie felony charge or chai'ges o f Trafficking Cocaine Over 100 grams. Possession wi th

Intent to Deliver, or Conspiracy Second Degree.

COUNT SIXTY TWO. A FELONY

# N _

P O S S E S S I O N O R C O N T R O L O F A M M U N I T I O N B Y A P E R S O N P R O H I B I T E D

in violation o f Title 11, Section 1448 ofthe Delaware Code.

W I L L I A M WISHER on or about the 5'" day o f September, 2017, i n the County o f N e w

Castle, State ofDelaware, did knowingly own. possess or control ammunit ion for a firearm as

defined by the Delaware Code o f 1974, after having been convicted in Case Number

0402002084, in the Superior Court o f the Slate ofDelaware, on or about November 4, 2005, to

the felony charge or charges o f Trafficking Cocaine Over 100 grams. Possession w i t h Intent to

Deliver, or Conspiracy Second Degree.

COUNT SIXTY THREE. A MISDEMEANOR

#N

P O S S E S S I O N O F D R U G P A R A P H E R N A L I A in violation o f Title 16, Section

4771 (a) o f the Delaware Code.

W I L L I A M WISHER on or about the 5'" day o f September, 2017, in the County o f N e w

Castle, State ofDelaware, did knowingly use or possess wi th intent to use drug paraphernalia

as defined in 16 Del . Code Section 4701(17) to pack, re-pack, weight, store or contain a

controlled substance.

COUNT SIXTY FOUR. A FELONY

#N


Code.

TYRONE ROANE on or about the 19'" day o f Apr i l . 2017, in the County o fNew Castle,

State o f Delaware, did, along wi th Anthony Dixon, knowingly deliver or possess wi th intent to

deliver 20 grains or more o f cocaine or any mixture containing cocaine, a controlled substance as

described in 16 Del. Code § 4716(b)(4).

COUNT SIXTY FIVE. A FELONY

m A G G R A V A T E D P O S S E S S I O N O F C O C A I N E in violation o f Title 16, Section


TYRONE ROANE on or about the 19'" day o f Apr i l , 2017, did, along with Anthony

Dixon, knowingly possess 25 grains or more of cocaine or any mixture containing cocaine, a

controlled substance as described in 16 Del. Code § 4716(bX4).

COUNT SIXTY SIX. A FELONY #N

C O N S P I R A C Y S E C O N D D E G R E E in violation o fTi t l c I I , Section 512 ofthe

Delaware Code.

T Y R O N E ROANE, on or about the 19'" day o f A p r i l 2017, in the County ofNew Castle,

State o f Delaware, when intending to promote or facilitate the commission of Drug Dealing or

Aggravated Possession as set forth in Counts Sixty Four or Sixty Five o f this indictment, which

are incorporated herein by reference, did agree wi th Anthony Dixon that one, the other, or both

o f them would commit Drug Dealing or Aggravated Possession and one, the other or each o f

them did commit an overt act in pursuance o f said conspiracy by engaging in conduct

constituting Drug Dealing or Aggravated Possession or some otlier over act in furtherance o f the

conspiracy.

COUNT SIXTY SEVEN. A M I S D E M E A N O R

#N

D R I V I N G A V E H I C L E W H I L E L I C E N S E I S S U S P E N D E D O R R E V O K E D in

violation o fT i t l c 21, Section 2756(a) of the Delaware Code.

T Y R O N E ROANE, on or about the 19'" day o f A p r i l . 2017, in the County o f N e w Castle,

State ofDelaware, d id congregate w i th others or prowl in a place at a l ime or in a manner not

usual for law-abiding individuals under circumstances that warrant alarm for the safet)' o f

persons or property in the vicini ty , especially i n l ight of the crime rate in the relevant area.

COUNT SIXTY EIGHT. A V I O L A T I O N

#N

E X P I R E D R E G I S T R A T I O N in violation o f Title 21 , Section 2115(1) ofthe Delaware

Code.

TYRONE ROANE, on or about the 19'" day of Apr i l , 2017, in the County o fNew Castle,

Slate ofDelaware, did operate a motor vehicle upon a public roadway which was not registered or

which did not have attached thereto and displayed thereon unexpired registration plates.

COUNT SIXTY NINE. A FELONY # N _

#N_

D R U G D E A L I N G H E R O I N in violation o f Title 16, Section 4752(1) o f the Delaware

Code.

TYRONE ROANE and C H A R M A I N E SAUNDERS on or about the 28'" day of August,

2017, in the County ofNew Castle, Stale ofDelaware, did knowingly deliver or possess wi th

intent to deliver 4 grams or more o f morphine, opium, any salt, isomer or salt o f an isomer

thereof, or heroin as described in 16 Del. Code § 4714, or any mixture containing any such

controlled substance.

COUN r SEVENTY. A FELONY

#N

#N_ ^



TYRONE ROANE and C H A R M A I N E SAUNDERS on or about the 28'" day o f August,

2017, inthe County ofNew Castle, Slate ofDelaware, did knowingly possess 5 grams or more

of a morphine, opium, any salL isomer or salt of an isomer thereof, or heroin as described in 16

Del. Code § 4714, or any mixture containing any such controlled substance.

COUNT SHVCNTY ONE. A FELONY

#N

UN_

D R U G D E A L I N G C O C A I N E in violation o f ditle 16, Section 4752(1) ofthe Delaware

Code.

TYRONE ROANE and C H A R M A I N E SAUNDERS on or about the 28'" day o f August,

2017, in the County ofNew Castle, Slate ofDelaware, did knowingly deliver or po.ssess with intent

to deliver 20 grams or more o f cocaine or any mixture containing cocaine, a controlled substance

as described in 16 Del. Code § 4716(b)(4).

COUNT SEVENTY T W O . A FELONY

m ^_ #N .



T Y R O N E ROANE and C H A R M A I N E SAUNDERS on or about tlie 28'" day o f August,

2017, did knowingly possess 25 grams or more o f cocaine or any mixture containing cocaine, a

controlled substance as described in 16 Del. Code § 4716(b)(4).

COUNT SEVENTY THREE. A FELONY #N

m


Delaware Code.

TYRONE ROANE and C H A R M A I N E SAUNDERS, on or about the 28'" day o f August,

2017, in the County of New Castle, State ofDelaware, when intending to promote or facilitate

the commission o f Drug Dealing or Aggravated Possession, as set forth in Counts Sixty Nine-

Seventy, Seventy One or Seventy Two, which arc incorporated herein by reference, did agree

wi th each other to commit said crime and one or more olThem did commit and overt act in

pursuance o f said conspiracy by engaging in conduct constituting said felony or attempt to

commit said felony by committing some other overt step in pursuance ofthe conspiracy.

COITNT SEVENTY FOUR. A MISDEMEANOR

# N _ _

P O S S E S S I O N O F M A R I J U A N A in violation o f Title 16, Section 4764(b) ofthe

Delaware Code.

T Y R O N E R O A N E and C H A R M A E N I E SAUT4DERS , on or about the 28'" day o f August,

2017, in the County o f New Castle, State ofDelaware, d id knowingly or intentionally use or

consume 1 ounce or less o f marijuana, a controlled substance as described in 16 De l . Code

Sections 4701 (26) and 4714(d)(19) and the offense occurred in a vehicle.

COUNT SEVENTY FIVE. A M I S D E M E A N O R

#N

#N

P O S S E S S I O N O F D R U G P A R A P H E R N A L I A i n violation o f Titlc 16, Section

4771 (a) o f the Delaware Code.

TYRONE ROANE and C H A R M A I N E SA1T4DERS , on or about the 28'" day o f August,

2017, in the County o f N e w Castle, State o f Delaware, d id knowingly use or possess w i th

intent to use drug paraphernalia as defined in 16 Del . Code Section 4701(17) to pack, re-pack,

weight, store or contain a controlled substance.

COUNT SEVENTY SIX. A MISDEMEANOR

m E N D A N G E R I N G T H E W E L F A R E O F A C H I L D in violation of Title 11, Section

1102(a)(4) oiThc Delaware Code.

TYRONE ROANE and C H A R M A I N E SAUNDERS , on or about the 28'" day o f August,

2017, in the County o f New Castle, State o f Delaware, did commit Drug Dealing or

Aggravated Possession knowing that said crime was witnessed either by sight or sound by

Major Thoman, a child less than 18 years o f age and a family member o f a defendant.

COUNT SEVENTY SEVEN. A FELONY

m


Code.

TYRONE ROANE on or about the 11'" day o f October, 2017, in the County o fNew Castle,

State ofDelaware, did knowingly possess with intent to deliver cocaine or any mixture containing

cocaine, a controlled substance as described in 16 Del. Code § 4716(b)(4), and the offense was

committed within 300 feet o f Thomas Edison Charter School, a protected school zone, as defined

in 16 Del. Code Section 4701(41), or wi thin 300 feet o f Brown Burton Winchester Park, a

protected park or recreation area, as defined in 16 Del. Code Section 4701(40).

COUNT SBVEN'I Y EIGHT. A FELONY

# N



TYRONE ROANE on or about the 1E" day o f October, 2017, did knowingly possess 5

grams or more o f cocaine or any mixture containing cocaine, a controlled substance as described

in 16 Del. Code § 4716(b)(4), and the offense was committed within 300 feet o f Thomas Edison

Charter School, a protected school zone, as defined in 16 Del. Code Section 4701(41), or within

300 feet o f Brown Burton Winchester Park, a protected park or recreation area, as defined in 16

Del. Code Section 4701(40).

COUNT SEVENTY NINE. A V I O L A T I O N

#N

L O I T E R I N G in violation ofTi t lc I I , Section 1321(5) ofthe Delaware Code.

T Y R O N E ROANE, on or about the 11"' day o f October, 2017, i n the County o f N e w

Castle, State o f Delaware, d id congregate wi th others or p rowl i n a place at a t ime or in a

manner not usual for law-abiding individuals under circumstances that warrant alarm for the

safety o f persons or property i n the vic ini ty , especially in light of the crime rate i n the relevant

area.

COUNT EIGHTY. A F H T O N Y

#N_

D R U G D E A L I N G H E R O I N in violation o f Title 16, Section 4752(1) ofthe Delaware

Code.

T R A M O N T M I T C H E L L , on or between the 23'" day of June, 2017, in the County o f

New Castle, State ofDelaware, did knowingly deliver or possess with intent to deliver 4 grams

or more o f morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described

in 16 Del. Code § 4714, or any mixture containing any such controlled substance.

COUN r EIGHTY ONE. A FELONY

# N

D R U G D E A L I N G H E R O I N in violation o f Title 16, Section 4752(1) of the Delaware

Code.

M I C H A E L PRITCHETT, on or about the 8th day of January, 2015. in the County o f New

Castle, State o f Delaware, did knowingly possess wi th intent to deliver 4 grams or more o f

morphine, opium, any salt, isomer or salt o f an isomer thereof, or heroin as described in 16 Del.

Code § 4714, or any mixture containing any such controlled substance.

COUNT EIGHTY T W O . A FELONY

#N__

A G G R A V . A T E D P O S S E S S I O N i n violation ofTi t lc 16, Section 4752(3) o f the Delaware

Code.

M I C H A E L PRITCHETT, on or about the 8th day of .lanuary, 2015. in the County o fNew

Castle, State ofDelaware, did knowingly possess 5 grams or more o f a morphine, opium, any

salt, isomer or salt o f an isomer thereof, or heroin as described in 16 Del. Code § 4714, or any

mixture containing any such controlled substance.

COUNT EIGHTY THREE. A FELONY

#N

C O N S P I R A C Y S E C O N D D E G R E E in violation of Title 11, Section 512 ofthe Delaware

Code.

M I C H A E L PRITCHETT on or about the 8lh day o f January, 2015, in the County o f New

Castle, State ofDelaware, when intending to promote or facilitate the commission olThe felony o f

Drug Dealing or Aggravated Possession of Heroin as set forth in Counts Eighty One or Eighty

Two o f this Indictment, which are incoiporated herein by reference, did agree with Malik Pritchett

that one, the other or each of them would commit the offenses and one, the other or each o f them

did commit an overt act in pursuance o f said conspiracy by engaging in conduct constituting said

Drug Dealing or Aggravated Possession o f Heroin or an attempt to commit the offenses, or by

committing some other overt act in pursuance ofthe conspiracy.

A TRUE B I L L

(FOTEPERSON)

M A T T H E W P. DENN A T T O R N E Y GENERAL

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