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4:16-cv-04074-SLD # 1

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E-FILED

Friday, 15 April, 2016 03:30:52 PM


Clerk, U.S. District Court, ILCD
IN THE UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF ILLINOIS
ROCK ISLAND DIVISION
UNITED STATES OF AMERICA,

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Plaintiff,
vs.
APPROXIMATELY 64 DOGS,
Defendants.

No:

16-4074

VERIFIED COMPLAINT FOR FORFEITURE


NOW COMES the plaintiff, the United States of America, by and through its
attorneys, James A. Lewis, United States Attorney for the Central District of Illinois, and
Gail L. Noll, Assistant United States Attorney, and respectfully states as follows:
1.

The defendants, approximately 64 dogs, are subject to seizure and forfeiture

to the United States, pursuant to 15 U.S.C. 1177 (confiscation of gambling devices) and 7
U.S.C. 2156(f) (animals involved in a violation of the Animal Welfare Act), as the
defendants were involved in, in any manner or part, to commit and/or to facilitate the
commission of a violation of 7 U.S.C. 2156 (animals involved in a violation of the Animal
Welfare Act) and 15 U.S.C. 1172-1175 (animals used as gambling devices).
2.

This Court has jurisdiction pursuant to 28 U.S.C. '' 1345 and 1355.

3.

This action is brought in the Central District of Illinois, Rock Island Division,

as the events which are the subject of this matter occurred in Rock Island County, Illinois,

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and will remain within the jurisdiction of this Court throughout the pendency of this
action.
4.

The defendants are approximately 64 dogs.

Factual Basis
5.

Confidential sources and cooperating witnesses have provided information

to law enforcement that several individuals in the Quad Cities area have been involved or
participated in an illegal dog fighting operation, including gambling on dog fights, in
Illinois and other states, including Iowa, Alabama, and Mississippi, and have
purchased/transported dogs from Ohio, Pennsylvania, Alabama, and Mississippi. These
individuals include but not limited to, Quintin Clemons (Clemons), Algerron Goldsmith,
Sr. (Goldsmith), Simmeon Hall (Hall), Ryan Hickman (R. Hickman), Marcus Holmes
(Holmes), Sherrick Houston (Houston), Willie Jackson (Jackson), Jaquan Jones (Jones),
Stantrel Knight (Knight), Denzell Lee (Lee), Andre Lidell (Lidell), Timon Mayfield
(Mayfield), Demarlo McCoy (McCoy), Terrill McDuffy (McDuffy), Derrick Nephew
(Nephew), Torrie Roberts (Roberts), and Darrick Rodgers (Rodgers). Some of the
confidential sources and cooperating witnesses also told law enforcement that they
themselves were present and participated in the illegal dog fighting activities and had dog
fighting videos and photographs which corroborated their stories and revealed that the
above individuals, and others, were present and engaged in the illegal dog fighting
operation.

4:16-cv-04074-SLD # 1

6.

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On December 17, 2014, law enforcement executed a search warrant for

narcotics and to search cellular telephones at Lidells residence. During the search, Iesha
Jones and Lidell were present. A cellular telephone seized from the residence revealed a
video of Lidell and a Confidential Source #1 (CS #1) actively fighting pit bull dogs.
7.

On April 22, 2015, law enforcement arrested CS #1 on federal drug and

firearm charges, who consented to a search of his/her cellular telephone where multiple
videos related to dogfighting were discovered on his phone. CS #1 told agents that he/she
attended a dog fight at McDuffys residence in 2013 where McCoy and others were present,
and attended three separate dog fights at Jacksons residence where R. Hickman, Lidell,
Goldsmith and Chris Hickman were present. CS #1 advised that R. Hickman video
recorded one of the fights using a tablet computer device and Goldsmith also video
recorded the fight with a cellular telephone. CS #1 also reported that Todd (Phillip
Todd Schauland) had trained fighting dogs for Hall.
8.

CS #1 reviewed videos and photographs from his/her cellular telephone and

two cellular telephones that belonged to Jones, Lidell and Hall, which depicted pit bull
breed dogs in several dog fights that occurred: (a) in Jacksons basement in late 2014
(around November 1, 2014) between Chaos Junior and Brisko; (b) at Lidells residence
on or about November 7, 2014, November 27, 2014, and December 9, 2014; (c) at least three
dog fights in McCoys basement between Willie and McCoys brindle colored pit bull
dog, between Bully Junior and Meathead, and Bully Junior and Sosa in April 2015;
and (d) at Mayfields house on April 26, 2015, which depicted Halls light-tan colored pit

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bull dog named GTO Caesar fighting another pit bull where CS #1 also identified Lidells
dark brown colored pit bull named Brisko. In these videos and photographs, CS #1
identified Jackson, Lidell, R. Hickman, Knight, Hall, Nephew, Clemons, McCoy,
Goldsmith, Chris Hickman, Ira L. Clark, Mario L. Welch, and Jaylin Johnson as being
present during the dog fights based on visual identification or voice recognition.
9.

CS #1 also reported that he/she has attended dog fights: (a) at Holmes

residence when Holmes entered a dog, owned by another person, into the fight; (b) in the
basement of Houstons residence on two separate occasions where Rogers, Houston,
McCoy, and Giorgio Williams were in attendance; (c) at Jacksons residence when CS #1
and Lidell fought their dogs. Additionally, CS #1 said that Jones fights pit bull dogs,
trains pit bull dogs, and gambles on dog fighting and that Mayfield is a dogfighting
spectator and a possible promoter.
10.

Confidential Source #2 (CS #2) was interviewed by law enforcement and

reported that he/she attended a dog fight on April 25, 2015 in the basement of Roberts
residence where Roberts charged $5.00 per person as an entry fee. Lidell, Clemons, Roberts,
Jones, Knight, McDuffy, McCoy and Tabius Mayfield (Mayfields brother) were present for
this dog fight between Lidells brown pit bull dog and another brown colored pit bull dog
owned by Clemons. (CS #2) said that after Lidells dog won the fight, Clemons killed his
dog by hanging it in front of those present.
11.

(CS #2) was present at two separate dog fights in the spring of 2015 at

McCoys residence between McCoys dog and Clemons dog and between Halls dog and

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McCoys dog, and attended a dog fight at Lees residence in May 2015 between Knights pit
bull dog and Lees pit bull. After Knights dog lost the fight, Knight hung the dog by the
neck until it died in the presence of himself, Hall, McCoy, McDuffy, and Lee.
12.

(CS #2) told agents that he/she, Hall and Schauland traveled to Cleveland,

Ohio in April 2015 to purchase a tan colored pit bull for fighting, which was kept at Rogers
and Andrewnett Walkers residence. (CS #2) also traveled to Pittsburg, Pennsylvania with
Hall, McDuffy and Schauland in May 2015 to purchase a dark brown colored pit bull. (CS
#2) said that McDuffy fights dogs for money at his residence in Iowa and has shared the
responsibilities of training, purchasing, and raising dogs with Hall. (CS #2) also said that
McCoy shared the responsibilities of training, purchasing, and raising fighting dogs with
Lee, Knight shared the responsibilities of training, purchasing, and raising fighting dogs
with Hall, and R. Hickman shared the responsibilities of training, purchasing, and raising
fighting dogs with Lidell.
13.

(CS #2) reviewed dog fighting videos located on Halls cellular telephone,

which depicted two pit bull breed dogs fighting in the presence of Hall, McCoy, Knight,
Quantrel Knight, Lee, Clemons, Giorgio Williams, and Demetrius Anderson. (CS #2)
identified these individuals by voice recognition.
14.

On May 21, 2015, law enforcement arrested Hall outside of Houstons

residence and seized his (Halls) cellular telephone. A search warrant was obtained and
executed on Halls cellular telephone on May 27, 2015, which revealed multiple dog
fighting videos and several text messages between Hall and other parties named in this

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complaint discussing details of dogs, dogfighting, and the travel and purchase of dogs for
the purpose of fighting. Specifically, agents observed text messages: (a) between Lidell
and Hall which stated Can i put tha boi n basement til morning im Rollin him tomorrow n
im fin go byt house ova here I was jt wlkin him which agents are aware that rolling or a
roll is the controlled pitting of dogs against one another as a fighting training exercise;
and (b) between Hall and Knight which stated We can hook ceaser at 46 for $1,500 in
Texas for 1x winner my buddy Nem got a camp for us to jump on they betting with us an
say they will do his keep which agents knew that keep is the rigorous diet and exercise
program designed to prepare and condition a dog for a contract match/fight.
15.

On June 11, 2015, agents executed a search warrant at Jones residence and

seized his cellular telephone. On July 15, 2015, a search warrant was executed on Jones
cellular telephone which revealed dog fighting videos.
16.

Law enforcement seized Mayfields cellular telephone during a November

2015 search warrant which contained two videos of a pit bull dog growling and pulling on
a spring pole and rope with its mouth (a male voice called the dog Tyson) and where a
female child is displayed with a pit bull puppy and approaching two other pit bull dogs
who are behind a fenced or caged area. A spring pole is a rope, hide, inner tubing, or other
device suspended from a strong spring attached to a tree limb, rafter, or pole, which is used
to strengthen a dogs bite and neck muscles.
Facebook Accounts
17.

R. Hickmans public Facebook profile(s), user name Fred Hickman,

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revealed images and posts of pit bull breed dogs and comments indicating his
involvement in the breeding of suspected fighting dogs. According to the Facebook
profile, R. Hickman was an online member of several suspected dogfighting related
groups including but not limited to New and Used Slat Mills (a slatmill is a type of
treadmill whose running surface is composed of wooden slats used to train fighting dogs)
and several kennel groups portraying pit bull breed dogs.
18.

Goldsmiths Facebook profile, user name Ron Hall Goldsmith included

images of pit bull breed dogs and videos wherein Goldsmith was tagged in by Clemons
which are videos of pit bull puppies in cages and comments about them being for-sale.
Goldsmith was also tagged in a video from Mike Reese displaying a pit bull dog
training on an identifiable flirt pole (a long pole with a hide or fur lure attached which is
moved around by a trainer), which comments by Mike Reese stating deer hide on a flirt
pole. Goldsmith is an online member of several suspected dogfighting related groups.
19.

Houstons public Facebook profile(s), user name Sed Houston, revealed

that Houston liked pages related to pit bull breed dogs.


20.

Jacksons public Facebook profile, user name Will Jackson (Willie Jay),

included images of pit bull breed dogs.


21.

Jones public Facebook profile, user name Jaquan Tip Jones, contained

images of pit bull breed dogs and an uploaded video of a pit bull dog and pit bull puppy
outside in a yard.

Jones also liked several pages related to pit bull breed dogs and

kennels suspected of being related to dogfighting.

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22.

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Knights public Facebook profile(s), user name Stan Knight (S Tro) and

Stan Knight Sr, contained images of pit bull breed dogs and an uploaded video of a pit
bull dog and pit bull puppy outside in a yard. Knight also liked several pages related to
pit bull breed dogs and kennels suspected of being related to dogfighting to include
Game Bred Pits which is a term used by dogfighting groups online and that the
definition of game is for courage, aggression, and tenacity of a dog to not give up in
fight. Knight is also an online member of several suspected dogfighting related groups
including but not limited to GR Ceaser Blood.
23.

Lidells public Facebook profile(s), user name Yank Bo, contained images

and posts of pit bull breed dogs and has liked over 70 pages related to kennels and pit
bull dogs suspected of being related to dogfighting activities. As example, Lidell has
liked pages such as Gameness 4ever, Nu-stock Horse and Dog all purpose healing
cream (works wonders), and Carolina Treadmills.
24.

McCoys public Facebook profile(s), user name DemarloFresh McCoy,

revealed a video of a pit bull breed dog jumping up on a suspected spring pole. According
to the Facebook profile, McCoy is an online member of several dogfighting related groups
including but not limited to New and Used Slat Mills (again a slatmill is a type of
treadmill whose running surface is composed of wooden slats used to train fighting dogs)
and has liked several pages related to pit bull dogs and suspected dogfighting including
Game Bred Pits.

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25.

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McDuffys public Facebook profile(s), user name Rell McDuffy, revealed

multiple images of pit bull breed dogs.


26.

On April 14, 2016, federal search warrants were executed to search the

following persons: McCoy, Knight, and McDuffy, and at the following addresses:
514 14th Avenue, Rock Island, Illinois (Residence of R. Hickman)
508 6th Street, Rock Island, Illinois (Residence of Holmes)
1605 5th Street, Rock Island, Illinois (Residence of Houston)
1213 14th Street, Rock Island, Illinois (Residence of Goldsmith)
1514 9th Street, Rock Island, Illinois (Residence of Jackson)
1009 10th Avenue, Rock Island, Illinois (Residence of Jones)
4002 20th Avenue, Rock Island, Illinois (Residence of Knight)
804 15th Avenue, Rock Island, Illinois (Residence of Lidell)
914 14th Avenue, Rock Island, Illinois (Residence of Mayfield)
410 7th Street, Rock Island, Illinois (Residence of McCoy)
1842 West 8th Street, Davenport, Iowa (Residence of McDuffy)
27.

After executing these search warrants, as well as a consent search at 816 21st

Street, Rock Island, Illinois, law enforcement discovered approximately 64 dogs at the
following locations:
Address
514 14th Ave, Rock
Island, IL

Adults

Puppies
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508 6th Street, Rock


Island, IL
1605 5th Street, Rock
Island, IL
1213 14th Street, Rock
Island, IL
1514 9th Street, Rock
Island, IL
1009 10th Ave, Rock
Island, IL
4002 20th Ave, Rock
Island, IL
804 15th Avenue,
Rock Island, IL
914 14th Ave, Rock
Island, IL
410 7th Street, Rock
Island, IL
1842 West 8th Street,
Davenport, IA
816 21st Street, Rock
Island, IL

28.

The defendants are in custody of the United States. The Federal Bureau of

Investigation has requested assistance from The American Society for the Prevention of
Cruelty to Animals (ASPCA) Field Investigations and Response group who assisted with
on-scene seizure, processing, triage, transport, and sheltering of the defendants seized.
ASPCA will provide veterinary examinations, forensic processing, shelter, food, and other
care as necessary.
29.

Based on the detailed facts above, which support a reasonable belief that the

government will be able to meet its burden of proof at trial, the defendants are subject to
seizure and forfeiture to the United States, pursuant to 15 U.S.C. 1177 (confiscation of
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gambling devices) and 7 U.S.C. 2156(f) (animals involved in a violation of the Animal
Welfare Act), as the defendants were involved in, in any manner or part, to commit
and/or to facilitate the commission of a violation of 7 U.S.C. 2156 (animals involved in a
violation of the Animal Welfare Act) and 15 U.S.C. 1172-1175 (animals used as gambling
devices).
WHEREFORE, the United States of America prays that this Court forfeit the
defendants, to the United States of America for disposition according to law, for the
issuance of a Warrant in Rem, for costs of suit and for such other and further relief as the
Court may deem necessary.
Respectfully submitted,
JAMES A. LEWIS
UNITED STATES ATTORNEY
By:

s/Gail L. Noll
Gail L. Noll, IL Bar No. 6243578
United States Attorney=s Office
318 South Sixth Street
Springfield, IL 62701
Telephone: 217-492-4450
Fax: 217-492-4888
Email: gail.noll@usdoj.gov

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VERIFICATION
Pursuant to 28 U.S.C. '1746, I declare under penalty of perjury that the foregoing
is true and correct based on information and belief.
Executed on this 15th day of April, 2016.
s/Paul Girskis
Special Agent Paul Girskis
Federal Bureau of Investigation

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