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__________________________________________________________

UNITED STATES DISTRICT COURT DISTRICT OF KANSAS

UNITED STATES OF AMERICA, PLAINTIFF,

vs. CASE NO. ____________ Filed Under Seal

ADOLFO BARRAGAN-RODRIGUEZ (01), a.k.a. “Adolfo Barragan,” a.k.a. “Big Mike,”

MICHELLE BELAIR (02), a.k.a. “Michelle Perez-Hernandez,”

JOSE MEDINA-BENUTO (03), MICHAEL PRICE (04),

a.k.a. “Mike Price,” JOSEPH JONES (05),

a.k.a. “Joey Jones,” LINDA HARDIN (06), HEATHER HURLEY (07), DANIEL A. RICE (08), NICHOLAS CASARONA (09), JOSE RUIZ (10),

DEFENDANTS.

SEALED INDICTMENT

THE GRAND JURY CHARGES:

AT ALL TIMES MATERIAL TO THIS INDICTMENT:

INTRODUCTION

1) During a period of time beginning on a date unknown, but before

August 12, 2016, and continuing until on or about May 17, 2017, the above

captioned defendants were engaged in a conspiracy with each other and with others

17-40043-01-10-DDC

Case 5:17-cr-40043-DDC Document 34 Filed 05/31/17 of 35

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known and unknown to distribute and possess with the intent to distribute

methamphetamine. To further their goals, the defendants participated in overt and

substantive acts intended to promote, manage, and carry-out their unlawful

activities to include, but not limited to, developing sources of supply for

methamphetamine, planning and coordinating the logistics necessary to import and

transport methamphetamine, using interstate facilities and transportation to

communicate, plan, acquire, transport, and otherwise facilitate their illegal

activities, possessing and distributing methamphetamine, collecting and laundering

the proceeds of distribution, and acquiring and using assets, including personal,

real, and business property, through the proceeds of their illegal scheme or to

facilitate their unlawful activities.

2) Adolfo Barragan-Rodriguez a.k.a. “Adolfo Barragan” a.k.a. “Big Mike,”

was a resident of Topeka, Kansas and since on or before December 1, 2016, operated

a pizza restaurant, “Pronto Pizza,” located on 6th Avenue in Topeka, Kansas which

he used to traffic, in whole or in part, methamphetamine. Barragan-Rodriguez used

a California based source of supply and other associates to acquire distributable

quantities of methamphetamine that were transported in interstate commerce to

Topeka, Kansas. Once in Topeka, Kansas, the methamphetamine was stored at

various locations, to include 1111 SW 10th Avenue, Apt. B., Topeka, Kansas, and

1121 SE 6th Avenue, Topeka, Kansas, and elsewhere, and distributed to and by

named and unnamed coconspirators, and others known and unknown.

3) Michelle Belair a.k.a. “Michelle Perez-Hernandez,” was a Topeka,

Kansas resident and associate of Barragan-Rodriguez, Mike Price, Joey Jones, Jose


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Ruiz, Dan Rice, and others known and unknown. Belair trafficked

methamphetamine acquired from Barragan-Rodriguez to both retail distributors

including, but not limited to, Mike Price and Joey Jones, and retail customers, and

others known and unknown in the Topeka, Kansas, area. Through Belair’s efforts,

and the efforts of those she supervised, she acquired proceeds of drug sales,

delivered drug proceeds, and laundered monetary instruments through financial

transactions at the Prairie Band Pottawattamie Casino in Jackson County, Kansas.

4) Jose Medina-Benuto was a Topeka, Kansas, resident and an associate

and relative of Barragan-Rodriguez. Medina-Benuto assisted Barragan and other

coconspirators, namely Linda Hardin, M.J., and R.W., in acquiring and distributing

distributable quantities of methamphetamine and collecting drug proceeds from the

sales of distribution. Medina-Benuto used communications facilities and faculties

in interstate commerce to assist Barragan-Rodriguez in the distribution of

methamphetamine.

5) Mike Price and Joey Jones were both Topeka, Kansas, residents and

primary distributors for Belair. Methamphetamine acquired by Belair was

provided to Price and Jones for distribution to other distributors and retail

customers, both known and unknown, of the drug trafficking organization. Their

efforts allowed wholesale quantities of methamphetamine acquired by Barragan

through interstate means to reach users and retail distributors in the Topeka,

Kansas, area including Heather Hurley.

6) Linda Hardin was a Topeka, Kansas resident and associate of

Barragan-Rodriguez, Medina-Benuto, and others. Hardin participated in the


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conspiracy by distributing methamphetamine, receiving methamphetamine shipped

in interstate commerce, and introducing would-be distributors, namely M.J. and

R.W., and others into the organization. Hardin also participated in the efforts of

the conspiracy by acquiring and delivering drug proceeds to Barragan.

7) Heather Hurley was a Topeka, Kansas resident and retail distributor

of methamphetamine. Hurly participated in the conspiracy by acquiring

distributable quantities of methamphetamine from Price, Belair, and others for

distribution to retail distributors and end users.

8) Daniel Rice, a.k.a. Dan Rice, was a methamphetamine user and

distributor who received distributable quantities of methamphetamine from

Barragan and sold to Michelle Belair and others. Rice also owned, used, and

maintained a house which he used to distribute methamphetamine and to store

methamphetamine on behalf of the coconspirators.

9) Nicholas Casarona was a resident of Topeka, Kansas and associate of

Belair, Ruiz, and others. Casarona received distributable quantities of

methamphetamine from Belair and Ruiz for distribution in the Topeka, Kansas,

area.

10) Jose Ruiz was a resident of Topeka, Kansas and maintained a premise

at 421 Pinecrest in Topeka, Kansas, for the purposes of using and distributing

methamphetamine. Ruiz was a principal associate of Belair who assisted her in the

distribution of methamphetamine and acquisition of drug proceeds including

distributing methamphetamine to Nicholas Casarona and others.


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11) The combined efforts of the conspiracy resulted in the distribution of

more than 4.5 kilograms of methamphetamine and included the following violations

of federal law:


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COUNT 1 CONSPIRACY TO POSSESS WITH THE INTENT TO DISTRIBUTE AND

DISTRIBUTE A CONTROLLED SUBSTANCE

Beginning on a date unknown to the Grand Jury but on or before the 12th

day of August, 2016, and continuing to on or about the 17th Day of May 2017, in the

District of Kansas and elsewhere, the defendants,

ADOLFO BARRAGAN-RODRIGUEZ (01), MICHELLE BELAIR (02),

JOSE MEDINA-BENUTO (03), MICHAEL PRICE (04), JOSEPH JONES (05), LINDA HARDIN (06),

HEATHER HURLEY (07), DANIEL A. RICE (08),

NICHOLAS CASARONA (09), and JOSE RUIZ (10),

combined, conspired, confederated, and agreed together with each other, and with

other persons known and unknown to the Grand Jury to possess with the intent to

distribute and distribute more than 50 grams of methamphetamine, a Schedule II

controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1)

and (b)(1)(A).

The amount involved in the conspiracy attributable to each defendant as a

result of his own conduct, and the conduct of other conspirators reasonably

foreseeable to him is more than 50 grams of methamphetamine in violation of Title

21, United States Code, Section 841(b)(1)(A),

All in violation of Title 21, United States Code, Section 846 with reference to

Title 18, United States Code, Section 2.


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COUNT 2 LAUNDERING OF MONETARY INSTRUMENTS

On or about the 12th day of November, 2016, in the District of Kansas, the

defendant,

MICHELLE BELAIR, did knowingly and intentionally conduct and attempt to conduct a financial

transaction affecting interstate and foreign commerce, which involved the proceeds

of a specified unlawful activity, that is, proceeds derived from the distribution and

conspiracy to distribute methamphetamine, a Schedule II controlled substance,

with the intent to conceal or disguise the nature, location, source, ownership, and

control of the proceeds of specified unlawful activity, and while conducting and

attempting to conduct such financial transaction knew that the property involved in

the financial transaction represented the proceeds of some form of unlawful activity

all in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i) with

reference to Title 18, United States Code, Section 2.


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On or about the 13th day of December, 2016, in the District of Kansas, the

defendant,












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COUNT 4 POSSESSION WITH THE INTENT TO DISTRIBUTE AND

DISTRIBUTION OF A CONTROLLED SUBSTANCE

On our about the 14th day of December, 2016, in the District of Kansas, the defendant,

MICHELLE BELAIR,

knowingly and intentionally possessed with the intent to distribute and distributed

a mixture and substance containing methamphetamine, a Schedule II controlled

substance, in the quantities below described in violation of Title 21, United States

Code, Section 841(a)(1) with reference to Title 21, United States Code, Sections

841(b)(1)(C), and Title 18, United States Code, Section 2.


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On or the 23rd day of December, 2016, in the District of Kansas, the

defendant,












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On our about the 28th day of December, 2016, in the District of Kansas, the defendants,

MICHELLE BELAIR, and MICHAEL PRICE,



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

reference to Title 21, United States Code, Sections 841(b)(1)(C), and Title 18, United

States Code, Section 2.



On our about the 3rd day of January, 2017, in the District of Kansas, the defendants,



more than 5 grams of methamphetamine, a Schedule II controlled substance, in

violation of Title 21, United States Code, Section 841(a)(1) with reference to Title

21, United States Code, Sections 841(b)(1)(B), and Title 18, United States Code,

Section 2.


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On or about the 6th day of January, 2017, in the District of Kansas, the

defendant,

MICHELLE BELAIR,

knowingly engaged and attempted to engage, in a monetary transaction by,

through, or to a financial institution, affecting interstate or foreign commerce, in

criminally derived property of a value greater than $10,000, that is, the deposit,

withdraw, and exchange, of United States Currency, such property having been

derived from a specified unlawful activity, that is, the distribution and conspiracy to

distribute methamphetamine, a schedule II controlled substance in violation of Title

18, United States Code, Sections 1957 and 2.

COUNT 9 DISTRIBUTION OF A CONTROLLED SUBSTANCE

On or about the 11th day of January, 2017, in the District of Kansas, the defendant,

HEATHER HURLEY,

knowingly and intentionally distributed a mixture and substance containing

methamphetamine, a Schedule II controlled substance, in violation of Title 21,

United States Code, Section 841(a)(1), with reference to Title 21, United States

Code Section 841(b)(1)(C).


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COUNT 10

POSSESSION WITH THE INTENT TO DISTRIBUTE AND DISTRIBUTION OF A CONTROLLED SUBSTANCE

On about the 22nd day of February, 2017, in the District of Kansas, and

elsewhere, the defendant,

ADOLFO BARRAGAN-RODRIGUEZ, knowingly and intentionally possessed with the intent to distribute and distributed

more than 500 grams of a mixture and substance containing methamphetamine, a

Schedule II controlled substance, in violation of Title 21, United States Code,

Section 841(a)(1), with reference to Title 21, United States Code, Section

841(b)(1)(A), and Title 18, United States Code, Section 2.

COUNT 11

POSSESSION WITH THE INTENT TO DISTRIBUTE AND DISTRIBUTION OF A CONTROLLED SUBSTANCE

On about the 1st day of March, 2017, in the District of Kansas, the

defendant,

ADOLFO BARRAGAN-RODRIGUEZ, knowingly and intentionally possessed with the intent to distribute and distributed


violation of Title 21, United States Code, Section 841(a)(1), with reference to Title

21, United States Code, Section 841(b)(1)(A), and Title 18, United States Code,

Section 2.


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COUNT 12 ATTEMPTED INTERSTATE TRANSPORTATION IN AID OF RACKETEERING

On or about the 13th day of March, 2017, in the District of Kansas and


ADOLFO BARRAGAN-RODRIGUEZ,

used and attempted to a facility in interstate and foreign commerce, namely:

Federal Express, a commercial mail carrier, with the intent to distribute proceeds of

an unlawful activity, namely, the distribution of methamphetamine, a Schedule II

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

from the State of Kansas to the State of California, and thereafter performed and

attempted to perform an act to distribute the proceeds of such unlawful activity,

namely, rendering a package containing drug proceeds to a Federal Express

employee for shipment in violation of Title 18, United States Code, Section

1952(a)(1).

COUNT 13 ATTEMPTED POSSESSION WITH THE INTENT TO DISTRIBUTE

A CONTROLLED SUBSTANCE

Between on or about the 24th day of March, 2017, and the 27th day of March,

2017, in the District of Kansas, the defendant,

LINDA HARDIN, knowingly and intentionally attempted to possess with the intent to distribute a

mixture and substance containing methamphetamine, a Schedule II controlled

substance, in violation of Title 21, United States Code, Section 846, with reference

to Title 21, United States Code, Section 841(a)(1) and (b)(1)(C), and Title 18, United



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COUNT 14 USE OF A COMMUNICATION FACILITY TO FACILITATE

A FELONY CONTROLLED SUBSTANCE OFFENSE On or about the 27th day of March, 2017, in the District of Kansas and



did knowingly and intentionally use any communication facility, namely, a cell

phone, in facilitating the commission of any act or acts constituting a felony under

Title 21, United States Code, Sections 846, that is the offenses set forth in Count 1

of this Indictment, all in violation of Title 21, United States Code, Section 843(b).


A FELONY CONTROLLED SUBSTANCE OFFENSE On or about the 28th day of March, 2017, in the District of Kansas and


LINDA HARDIN,






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A FELONY CONTROLLED SUBSTANCE OFFENSE

On or about the 31st day of March, 2017, in the District of Kansas and







COUNT 17

USE OF A COMMUNICATION FACILITY TO FACILITATE A FELONY CONTROLLED SUBSTANCE OFFENSE

On or about the 31st day of March, 2017, in the District of Kansas and


JOSE MEDINA-BENUTO,






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On about the 1st day of April, 2017, in the District of Kansas, the defendant,




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

reference to Title 21, United States Code, Section 841(b)(1)(C), and Title 18, United



A FELONY CONTROLLED SUBSTANCE OFFENSE On or about the 3rd day of April, 2017, in the District of Kansas and


HEATHER HURLEY,






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On our about the 3rd day of April, 2017, in the District of Kansas, the defendants,




violation of Title 21, United States Code, Section 841(a)(1) with reference to Title

21, United States Code, Section 841(b)(1)(B) and Title 18, United States Code,

Section 2.


A FELONY CONTROLLED SUBSTANCE OFFENSE On or about the 4th day of April, 2017, in the District of Kansas and








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On or about the 4th day of April, 2017, in the District of Kansas and


MICHELLE BELAIR,














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JOSEPH JONES,








JOSE MEDINA-BENUTO,






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LINDA HARDIN,







elsewhere, the defendants,

MICHELLE BELAIR, and JOSEPH JONES,






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MICHELLE BELAIR,








MICHELLE BELAIR,






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On about the 19th day of April, 2017, in the District of Kansas, the

defendants,

ADOLFO BARRAGAN-RODRIGUEZ, and JOSE MEDINA-BENUTO,



violation of Title 21, United States Code, Section 841(a)(1), with reference to Title

21, United States Code, Section 841(b)(1)(A), and Title 18, United States Code,

Section 2.

COUNT 31 ATTEMPTED POSSESSION WITH THE INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE

On or about the 28th day of April, 2017, in the District of Kansas, the

defendant,

NICHOLAS CASARONA,

knowingly and intentionally attempted to possess with the intent to distribute a

mixture and substance containing a detectable quantity of methamphetamine, a

Schedule II controlled substance, in violation of Title 21, United States Code,

Section 846, with reference of Title 21, United States Code, Section 841(a)(1) and

(b)(1)(C) and Title 18, United States Code, Section 2.


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COUNT 32 POSSESSION WITH THE INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE

On or about the 10th day of May, 2017, in the District of Kansas, the

defendant, DANIEL A. RICE,

knowingly and intentionally possessed with the intent to distribute more than 50

grams of methamphetamine, a Schedule II controlled substance, in violation of Title

21, United States Code, Section 841(a)(1), with reference of Title 21, United States

Code, Section 841(b)(1)(A).

COUNT 33 POSSESSION OF FIREARMS BY A PROHIBITED PERSON


defendant,

DANIEL A. RICE,

being a person who unlawfully uses and is addicted to methamphetamine, a

Schedule II controlled substance, knowingly and intentionally possessed firearms,

namely:

1. Savage, model 93R17, 17mm caliber rifle, serial number 0931653.

2. Remington, model 1100, 12 gauge shotgun, serial number N665603.

3. Winchester, model 9422, .22 caliber rifle, serial number F57674.

4. Remington, model 11A, 12 gauge shotgun, serial number 200639.

5. Savage, model 67, 12 gauge shotgun, serial number E144145.

6. Mossberg, model 500E, 410 gauge shotgun, serial number P774387.

7. Zastava, model Mark X, 7mm caliber rifle, serial number B96522.


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8. Remington, model 710, .270 caliber rifle, serial number 71042498.

9. Armscor, model AK22, .22 caliber rifle, serial number A755286.

10. Savage, model 67E, 12 gauge shotgun, serial number C025289.

11. Remington, model 870 Express, 12 gauge shotgun, serial number X096377M.

12. Bushmaster, model XM15-E2S, .223 caliber rifle, serial number L080277.

13. Norinco, model SKS, 7.62x39mm caliber rifle, serial number 1207055D.

14. Mossberg, model 800A, 308 caliber rifle, serial number 1047641.

15. Winchester, model 1200, 12 gauge shotgun, serial number 455001.

16. Winchester, model 12, 12 gauge shotgun, serial number 1069354.

17. Ithaca Gun Co., model 37, 12 gauge shotgun, serial number 278785.

18. Browning, model Light 12, 12 gauge shotgun, serial number 72G7405.

19. Remington, model 12A, .22 caliber rifle, serial number 500326.

20. Ruger, model 10/22, .22 caliber rifle, serial number 23593584.

21. Marlin, model 60, .22 caliber rifle, serial number 11366227.

22. Winchester, model 150, .22 caliber rifle, serial number B913828.

23. Winchester, model 190, .22 caliber rifle, serial number B1173455.

24. Winchester, model 94, 30-30 caliber rifle, serial number 1309716.

25. Smith & Wesson, model 1000S, 12 gauge shotgun, serial number HB63553.

26. High-Standard, model 200, 12 gauge shotgun not identified by serial number.


28. Uberti, Aldo, model 1860 Henry, 44-40 caliber rifle, serial number 14353.

29. Browning, model Auto 5, 16 gauge shotgun, serial number X84029.

30. Norinco, model 22ATD, .22 caliber rifle, serial number 206742.


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31. Remington, model 7400, .243 caliber rifle, serial number B8300724.

32. Romania, model M56, 7.62x39mm caliber rifle, serial number EF2292.

33. Mosin-Nagant, model M91/30, 7.62x54Rmm caliber rifle, serial number

9130184884.


35. Remington, model 1100, 20 gauge shotgun, serial number L320897X.

36. Winchester, model 94 Ranger, 30-30 caliber rifle, serial number 5634351.

37. Winchester, model 94, 30-30 caliber rifle, serial number 3297037.

38. Ruger, model Mini 14 Ranch Rifle, .223 caliber rifle, serial number

19503553.

39. Norinco, model SKS, 7.62x39 caliber rifle, serial number R22004858.

40. Winchester, model 74, .22 caliber rifle, serial number 92914.



43. Akkar Silah Sanayi (Charles Daly), model Field, 20 gauge shotgun, serial

number 2202607.

44. Savage, model 24, .22 caliber/410 gauge combination rifle/shotgun not

identified by serial number.

45. Savage, model Stevens 200, 308 caliber rifle, serial number G662044.

46. Harrington & Richardson, model 330, 30-06 caliber rifle, serial number

52611.

47. Browning, model T-Bolt, .22 caliber rifle, serial number 6525.

48. Savage, model Stevens 84C, .22 caliber rifle not identified by serial number.


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49. Arisaka, model Type 38, 7mm caliber rifle, serial number 96690.


51. CBC (Companhia Braziliera De Cartuchos), model 702 Plinkster, .22 caliber

rifle, serial number E0J156771.

52. Remington, model 341P, .22 caliber rifle, serial number 38504.


54. Remington, model 700, 25-06 caliber rifle, serial number G6888029.

55. Norinco, model 22ATD, .22 caliber rifle, serial number 815524.

56. Savage, model Springfield 53A, .22 caliber rifle not identified by serial

number.

57. Savage, model Stevens, .22 caliber rifle not identified by serial number.

58. Savage, model 24S-E, .22 caliber/410 gauge shotgun combination

rifle/shotgun, not identified by serial number.

59. Marlin, model 50, 20 gauge shotgun, serial number WIIHR.

60. Lefever, model Nitro Special, 12 gauge shotgun, serial number 208734.

61. HS Produkts (IM Metal), model XD40, .40 caliber pistol, serial number

US456159.

62. Taurus, model PT24/7 Pro DS, 9mm caliber pistol, serial number TDM35270.

63. Star, Bonifacio Echeverria, model Firestar (M40), .40 caliber pistol, serial

number 2004353.

64. Bryco Arms, model 48, .380 caliber pistol, serial number 038668.

65. Ruger, model Mark II Target, .22 caliber pistol, serial number 1600821.

66. Glock, model 17, 9mm caliber pistol, serial number TXN367.


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67. Llama (Gabilondo & CIA) model Mini Max, .45 caliber pistol, serial number

07041634898.

68. Echasa (Echave Y Arizmendi), model Fast, .22 caliber pistol, serial number

78052.

69. Lorcin Engineering, model L380, .380 caliber pistol, serial number 036947.

70. Charter Arms, model Pink Lady, .38 caliber revolver, serial number 1424990.

71. Davis Industries, model P380, .380 caliber pistol, serial number AP164447.

72. Taurus, model PT1911, .45 caliber pistol, serial number NFX39470.

73. Colt, model Gold Cup Trophy, .45 caliber pistol, serial number GCT12497.

74. Harrington & Richardson, model 922, .22 caliber revolver, serial number

M24512.

75. Interarms, model Virginian Dragoon, .44 caliber revolver, serial number

S18719.

76. Ruger, model Super Blackhawk, .44 caliber revolver, serial number 8237778.

77. Charter Arms, model Bulldog, .44 caliber revolver, serial number 211440.

78. High Standard, model Marshal, .22 caliber revolver, serial number 2248766.

79. Smith & Wesson, model 60, .38 caliber revolver, serial number R315000.

80. Beretta, model 950 BS, .25 caliber pistol, serial number BER35354V.

81. Reck, model Frontier, .22 caliber Derringer pistol, serial number 20012.

82. Harrington & Richardson, model 929, .22 caliber revolver, serial number

obliterated.

83. High Standard, model Sport King, .22 caliber pistol, serial number 30162.

84. Smith & Wesson, model 38, .38 caliber revolver serial number 305244.


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85. Henry Repeating Rifle Company, model H002 US Survival, .22 caliber rifle, serial number US004686.

86. Rohm, model Frontier Derringer, .357 caliber Derringer pistol, serial number 1669.

87. Ruger, model Blackhawk, .45 caliber revolver, serial number 4676510.

88. Ruger, model P89, 9mm caliber pistol, serial number 307-52559 (serial number is partially obliterated).

89. Becker & Hollander, model Beholla, .32 caliber pistol, serial number 36483.

90. Taurus, model Tracker, .22 caliber revolver, serial number CR790771.

91. Smith & Wesson, model 916, 12 gauge shotgun not identified by serial number.

92. Mossberg, model 351KA, .22 caliber rifle, serial number ACKROGRUV.

which had been shipped and transported in interstate and foreign commerce in

violation of Title 18, United States Code, Section 922(g)(3) and 924(a)(2).


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COUNT 34 POSSESSION OF A FIREARM BY A PROHIBITED PERSON


defendant, JOSE MEDINA-BENUTO,

being a person who unlawfully uses and is addicted to methamphetamine, a

Schedule II controlled substance, knowingly and intentionally possessed a firearm,

namely: a Star, Bonifacio Echeverria, Model B, 9mm pistol, serial number

268520, which had been shipped and transported in interstate and foreign

commerce in violation of Title 18, United States Code, Section 922(g)(3) and

924(a)(2).

COUNT 35 POSSESSION WITH THE INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE

WITHIN 1000 FEET OF A SCHOOL


defendants,

ADOLFO BARRAGAN-RODRIGUEZ, and JOSE MEDINA-BENUTO,

knowingly and intentionally possessed with the intent to distribute a mixture and

substance containing methamphetamine, a Schedule II controlled substance, within

one thousand feet of the real property comprising a private elementary school,

namely: Mater Dei Catholic School, a pre-kindergarten through eighth grade

elementary school, located in Topeka, Kansas, at 934 SW Clay Street, and

accredited by the States of Kansas, in violation of Title, 21 United States Code,

Sections 841(a)(1) and 860, with reference to Title 21, United States Code, Sections

841(b)(1)(C) and 860(a), and Title 18 United States Code, Section 2.


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FORFEITURE NOTICE

1. The allegations contained in Counts 1 –48 of this Indictment are

hereby re-alleged and incorporated by reference as if fully restated for the purpose

of alleging forfeitures pursuant to Title 18, United States Code, Sections 924, 981

and 982, Title 21, United States Code, Section 853, and Title 28, United States

Code, Section 2461(c).

CONTROLLED SUBSTANCES FORFEITURES

2. Pursuant to Title 21, United States Code, Section 853, upon conviction

for any of the offenses in violation of Title 21, United States Code, Sections 841,

843, 846, and 856, as set forth in Counts 1, 4, 6-7, 9-11, 13-32, of this Indictment,

the defendants,

ADOLFO BARRAGAN-RODRIGUEZ (01), MICHELLE BELAIR (02),

JOSE MEDINA-BENUTO (03), MICHAEL PRICE (04), JOSEPH JONES (05), LINDA HARDIN (06),

HEATHER HURLEY (07), DANIEL A. RICE (08),

NICHOLAS CASARONA (09), and JOSE RUIZ (10),

shall forfeit to the United States of America any property constituting or derived

from any proceeds obtained, directly or indirectly, as the result of such offenses, and

any property used or intended to be used, in any manner or part, to commit or to

facilitate the commission of the offenses. The property to be forfeited includes, but

is not limited to, the following:


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A. A forfeiture money judgment in the approximate amount of $275,000.000, which amount represents the proceeds derived from the commission of Count 1 of the Indictment for which the defendants are jointly and severally liable;

B. Approximately $14,900.00 in United States Currency seized by the Drug Enforcement Administration on March 13, 2017;

C. 2002 Dodge Ram 1500, VIN: 3D7HA18N12G148765; D. 2005 Cadillac Deville VIN: 1G6KD54Y95U115810;

E. 2006 Lexus, VIN: 2T2HA31U86C100845;

F. 2004 Acura Sedan, VIN: 19UUA66224A050118;

G. The real property described as 1512 SW Harrison Street, Topeka, Kansas, also identified as Orchard Place, Lot 560, Shawnee County, Kansas,

H. The real property described as 1823 NW Fairmont Street, Topeka, Kansas, also identified as Lot 14, Block A, Sun Valley Subdivision, Shawnee County, Kansas;

I. The real property described as 2430 SE Colorado Avenue, Topeka, Kansas, also identified as Lot 1, McLaughlin’s Subdivison, Shawnee County, Kansas;

J. A Star Bonifacio Echeverria, Model B, 9mm pistol, serial

number 268520 and ammunition;

K. All firearms described in Count 33 of this Indictment and incorporated by reference herein.


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FIREARMS FORFEITURES 3. Pursuant to Title 18, United States Code, Section 924(d) and Title 28,

United States Code, Section 2461(c), upon conviction for the offense in violation of

Title 18, United States Code, Section 922, as set forth in Count 34 of this

Indictment, the defendant, JOSE MEDINA-BENUTO, shall forfeit to the United

States of America, any firearms and ammunition used or involved in the

commission of the offense, including, but not limited to, a Star Bonifacio Echeverria,

Model B, 9mm pistol, serial number 268520 and ammunition.

4. Pursuant to Title 18, United States Code, Section 924(d) and Title 28,

United States Code, Section 2461(c), upon conviction for the offense in violation of

Title 18, United States Code, Section 922, as set forth in Count 33 of this

Indictment, the defendant, DANIEL A. RICE, shall forfeit to the United States of

America any firearms and ammunition used or involved in the commission of the

offense, including, but not limited to, all firearms described in Count 33 of this

Indictment and incorporated by reference herein.

MONEY LAUNDERING FORFEITURES

5. Pursuant to Title 18, United States Code, Section 982, upon conviction

for the offenses in violation of Title 18, United States Code, Section 1956, as set

forth in Counts 26-29 of this Indictment, the defendant MICHELLE BELAIR,

shall forfeit to the United States of America any property, real or personal, involved

in such offenses, or any property traceable to such property, including but not

limited to, the following:


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A. A forfeiture money judgment in an amount equal to the value of

the property involved in Counts 2, 3, 5, and 8 of the Indictment.

ITAR FORFEITURES

6. Pursuant Title 18, United States Code, Section 981(a)(1)(C) and Title

28, United States Code, Section 2461(c), upon conviction for the offenses in violation

of Title 18, United States Code, 1952, as set forth in Count 12 of this Indictment,

the defendant,

ADOLFO BARRAGAN-RODRIGUEZ, shall forfeit to the United States of America, any property, real or personal, which

constitutes or is derived from proceeds traceable to the offenses. The property to be

forfeited includes, but is not limited to, the following:

A. A forfeiture money judgment in an amount that equals the

proceeds derived from the commission of Count 12.

SUBSTITUTE PROPERTY

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

omission of the defendants:

A. cannot be located upon the exercise of due diligence;

B. has been transferred or sold to, or deposited with, a third party; C. has been placed beyond the jurisdiction of the court;

D. has been substantially diminished in value; or

E. has been commingled with other property which cannot be divided without difficulty,

the United States of America shall be entitled to forfeiture of substitute property of


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the defendants pursuant to Title 21, United States Code, ' 853(p).

All in violation of Title 18, United States Code, Sections 924, 981 and 982, Title 21,

United States Code, Section 853, and Title 28, United States Code, Section 2461(c).

A TRUE BILL.

May 31, 2017 s/Foreperson DATE FOREPERSON OF THE GRAND JURY Skipper Jacobs #26848 for Thomas E. Beall, #19929 UNITED STATES ATTORNEY DISTRICT OF KANSAS 444 SE Quincy, Suite 290 Topeka, KANSAS 66683 Phone: (785) 295-2850 Fax: (785) 295-2853 [email protected] [It is requested that trial be held in Topeka, Kansas.]


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