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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

UNITED STATES OF AMERICA, ) INDICTMENT


)
Plaintiff, )
)
v. ) CASE NO.__________________________
) Title 21, Section 846, United States
LENNON HAYES, ) Code
aka TONE ) Title 21, Sections 841(a)(1),
ROBERTO CALDERON, ) (b)(1)(A), and (b)(1)(C), United
aka PUERTO RICAN ROB, ) States Code
DEMOND STEELE, ) Title 21, Section 843(b), United
aka MAD DOG, ) States Code
TARA JONES, ) Title 18, Section 922(g)(1), United
) States Code
EDWARD JONES,
aka SMITTY, ) Title 18, Section 924(c)(1)(A),
) United States Code
MAZZARNEY HARDY,
) Title 18, Section 1952(a)(3),
aka BUB-G,
) United States Code
MICHAEL GINN,
) Title 18, Section 2, United States
STEVE HOLLINS, Code
)
CUPREE HOWARD,
)
aka STANK,
)
MARCUS GARMON,
)
aka SLIM,
)
ASHLEY KRIEDMAN-CRIDER,
)
RICKELL FIELDS,
)
aka KELL,
)
MARRICO KING,
)
TERRANCE JONES,
)
aka BLACK,
)
NATASHA BROOKINS,
)
JAMES ALEXANDER,
)
VANNESS OLIVER,
1
aka NESS, )
JAQUIS MORDICA, )
aka JAQ, )
Defendants. )
)

COUNT 1

The Grand Jury charges:

Beginning at least as early as June of 2015, and continuing through October of 2017, the

exact dates to the Grand Jury unknown, in the Northern District of Ohio, Eastern Division, and

elsewhere, LENNON HAYES, aka TONE; ROBERTO CALDERON, aka PUERTO RICAN

ROB; DEMOND STEELE, aka MAD DOG (MD); TARA JONES; EDWARD JONES, aka

SMITTY; MAZZARNEY HARDY, aka BUB-G; MICHAEL GINN; STEVE HOLLINS;

CUPREE HOWARD, aka STANK; MARCUS GARMON, aka SLIM; ASHLEY KRIEDMAN-

CRIDER; RICKELL FIELDS, aka KELL; MARRICO KING; TERRANCE JONES, aka

BLACK; NATASHA BROOKINS; JAMES ALEXANDER; VANNESS OLIVER, aka NESS;

and JAQUIS MORDICA, aka JAQ, the defendants herein, and others known and unknown did

unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree together and

with each other, and with diverse others known and unknown to the Grand Jury, to possess with

the intent to distribute, and to distribute at least one kilogram or more of a mixture or substance

containing a detectable amount of heroin, a Schedule I controlled substance, in violation of Title

21, United States Code, Sections 841(a)(1), and (b)(1)(A).

MANNER AND MEANS OF THE CONSPIRACY

A. It was part of the conspiracy that co-conspirators obtained heroin from suppliers

in the Mansfield, Ohio, and Chicago, Illinois, areas and elsewhere, which they then redistributed

in the area around Mansfield, Ohio.

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B. It was further part of the conspiracy that LENNON HAYES and EDWARD

JONES obtained large quantities of heroin from ROBERTO CALDERON in Chicago, Illinois,

which they redistributed in the Mansfield, Ohio area.

C. It was further part of the conspiracy that LENNON HAYES and EDWARD

JONES distributed the heroin to other traffickers in Mansfield, Ohio, and elsewhere, including

DEMOND STEELE; TARA JONES; MAZZARNEY HARDY; MICHAEL GINN; STEVE

HOLLINS; CUPREE HOWARD; MARCUS GARMON; ASHLEY KRIEDMAN-CRIDER;

RICKELL FIELDS; MARRICO KING; TERRANCE JONES; NATASHA BROOKINS; JAMES

ALEXANDER; VANNESS OLIVER; and JAQUIS MORDICA.

D. It was further part of the conspiracy that LENNON HAYES, RICKELL FIELDS,

and EDWARD JONES traveled to Chicago to purchase heroin from ROBERTO CALDERON.

E. It was further part of the conspiracy that LENNON HAYES and TARA JONES,

used their residence, located at 575 Crescent Avenue, Mansfield, Ohio, for the purpose of storing

and distributing heroin.

F. It was further part of the conspiracy that MAZZARNEY HARDY used his

residence, located at 278 South Main Street, Mansfield, Ohio, for the purpose of storing and

distributing heroin.

G. It was further part of the conspiracy that EDWARD JONES used his residences,

located at 371 2nd Avenue and 743 Bowman Avenue, Mansfield, Ohio, for the purpose of storing

and distributing heroin.

H. It was further part of the conspiracy that STEVE HOLLINS and CUPREE

HOWARD used their residence located at 204 Linden Road, Mansfield, Ohio, for the purpose of

storing and distributing heroin.

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I. It was further part of the conspiracy that the co-conspirators conducted counter-

surveillance of law enforcement and shared information with each other about law enforcement

presence.

J. It was further part of the conspiracy that the co-conspirators shared information

about drug traffickers who had been arrested to warn co-conspirators not to conduct business

with the drug traffickers who had been arrested.

K. It was further part of the conspiracy that the co-conspirators conducted drug

trafficking activity by using cellular telephones to make and receive telephone calls and to send

and receive text or other electronic messages. To reduce the risk of being detected by law

enforcement, and to conceal the identity of the person using the device, co-conspirators often

used cellular telephones that had been obtained in the names of other persons or in fictitious

names. It was further part of the conspiracy that the co-conspirators, when using cellular phones

or text messaging to conduct drug trafficking activity, used slang terms, street terminology, or

code words or phrases to obscure and to disguise the true nature of their activities and the true

meaning of their conversations.

L. It was further part of the conspiracy that LENNON HAYES and EDWARD

JONES and others possessed and used firearms or other weapons to protect their drug trafficking

activities.

ACTS IN FURTHERANCE OF THE CONSPIRACY

In furtherance thereof, and to effect the goals and conceal the existence of the conspiracy,

the defendants and others performed acts furtherance of the conspiracy in the Northern District

of Ohio and elsewhere, including, but not limited to the following:

1. On September 22, 2015, at approximately 5:03 p.m., a person cooperating with

law enforcement (hereinafter referred to as Source 1), called LENNON HAYES to arrange the
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purchase of $150 of heroin. Subsequently, Source 1 met E.D. (a person known to the Grand

Jury, but not indicted herein) in the vicinity of Superior Street and Bowers Avenue in Mansfield,

Ohio. During the meeting, E.D. sold Source 1 1.31 grams of heroin for $150.

2. On April 22, 2016, at approximately 8:34 p.m., a person cooperating with law

enforcement (hereinafter referred to as Source 2) met EDWARD JONES in the area of

Antibus Place and Lexington Avenue, Mansfield, Ohio. During the meeting, JONES sold

Source 2 .53 grams of heroin for $50.

3. On May 5, 2016, at approximately 3:52 p.m., a person cooperating with law

enforcement (hereinafter referred to as Source 3) met EDWARD JONES in an alley near the

area of Hammond Avenue, south of Granite Street, Mansfield, Ohio. During the meeting,

JONES sold Source 3 .59 grams of heroin for $60.

4. On May 13, 2016, at approximately 6:09 p.m., a person cooperating with law

enforcement (hereinafter referred to as Source 4) met EDWARD JONES in the area of Massa

Avenue and Lexington Avenue, Mansfield, Ohio. During the meeting, JONES sold Source 4 .35

grams of heroin for $60.

5. On December 19, 2016, at approximately 4:32 p.m., a person cooperating with

law enforcement (hereinafter referred to as Source 5) met EDWARD JONES at 743 Bowman

Street, Mansfield, Ohio. During the meeting, JONES sold Source 5 1.22 grams of heroin for

$80.

6. On January 4, 2017, at approximately 7:40 p.m., Source 5 met LENNON HAYES

on Massa Avenue in Mansfield, Ohio. During the meeting, HAYES sold Source 5 1.45 grams of

heroin for $100.

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7. On January 10, 2017, at approximately 5:17 p.m., Source 5 met LENNON

HAYES in the vicinity of 382 Lexington Avenue, Mansfield, Ohio. During the meeting, HAYES

sold Source 5 1.6 grams of heroin for $100.

8. On January 11, 2017, at approximately 5:49 p.m., Source 5 met EDWARD

JONES at 743 Bowman Street, Mansfield, Ohio. During the meeting, JONES sold Source 5 2.01

grams of heroin for $100.

9. On January 12, 2017, at approximately 4:49 p.m., Source 5 met JAMES

ALEXANDER in the parking lot of Rite Aid, 875 Lexington Avenue, Mansfield, Ohio. During

the meeting, ALEXANDER sold Source 5 1.31 grams of heroin for $100.

10. On January 25, 2017, at approximately 5:50 p.m., a person cooperating with law

enforcement (hereinafter referred to as Source 6) met JAMES ALEXANDER near the

intersection of Lexington Avenue and Trimble Road in Mansfield, Ohio. During the meeting,

ALEXANDER sold Source 6 .56 grams of heroin for $50.

11. On January 30, 2017, at approximately 7:06 p.m., Source 5 met MARRICO

KING at the intersection of 2nd Avenue and Madison Avenue in Mansfield, Ohio. During the

meeting, KING sold Source 5 .93 grams of heroin for $50.

12. On January 31, 2017, at approximately 5:38 p.m., Source 5 met MARRICO

KING in the area of 2nd Avenue and Auburn Avenue in Mansfield, Ohio. During the meeting,

KING sold Source 5 .94 grams of heroin for $50.

13. On February 1, 2017, at approximately 4:25 p.m., Source 5 called NATASHA

BROOKINS on the telephone about the purchase of heroin. After the call, at approximately 4:48

p.m., Source 5 met EDWARD JONES at 743 Bowman Street, Mansfield, Ohio, and purchased

.55 grams of heroin for $25.

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14. On February 2, 2017, at approximately 2:14 p.m., Source 5 met NATASHA

BROOKINS at 743 Bowman Street, Mansfield, Ohio. During the meeting, BROOKINS sold

Source 5 .92 grams of heroin for $50.

15. On February 9, 2017, at approximately 4:57 p.m., Source 5 met NATASHA

BROOKINS at 743 Bowman Street, Mansfield, Ohio. During the meeting, BROOKINS sold

Source 5 .82 grams of heroin for $50.

16. On February 15, 2017, at approximately 8:38 p.m., a person cooperating with law

enforcement (hereinafter referred to as Source 7) met LENNON HAYES in the vicinity of

Lexington Avenue and Ruth Avenue, Mansfield, Ohio. During the meeting, HAYES sold Source

7 1.5 grams of heroin for $100.

17. On April 13, 2017, Source 4 called VANNESS OLIVER on the telephone to

purchase heroin. Subsequently, Source 4 met VANNESS OLIVER in the parking lot area of 201

North Mulberry Street, Mansfield, Ohio. During the meeting, OLIVER sold Source 4 .43 grams

of heroin for $50.

18. On April 25, 2017, VANNESS OLIVER possessed drug paraphernalia; a Smith

and Wesson handgun, serial number ECA1027; 19.39 grams of cocaine; 26.53 grams of heroin;

and 22 foil packages containing 18.4 grams of Suboxone, inside of his residence located at 119

Boughton Avenue, Mansfield, Ohio.

19. On April 25, 2017, VANNESS OLIVER possessed $3,472.

20. On May 13, 2017, at approximately 1:16 p.m., Source 7 met LENNON HAYES at

305 Marion Avenue, Mansfield, Ohio. During the meeting, HAYES sold Source 7 1.33 grams of

heroin of $100.

21. On May 17, 2017, LENNON HAYES possessed 1.14 grams of heroin and $403.

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22. On June 30, 2017, Source 7 called LENNON HAYES on the telephone. During

the call, an individual identifying himself as STEVE (STEVE HOLLINS) answered the phone.

Source 7 asked how much heroin Source 7 could get for $200. HOLLINS replied that Source 7

could get 5 grams.

23. On July 13, 2017, Source 7 called LENNON HAYES on the telephone to

coordinate a purchase of heroin. During the call, HAYES instructed Source 7 to meet with

CUPREE HOWARD to complete the sale. Subsequently, at approximately 7:56 p.m., Source 7

met CUPREE HOWARD at 204 South Linden Road, Mansfield, Ohio. During the meeting,

HOWARD sold Source 7 1.46 grams of heroin for $100.

24. On July 26, 2017, at approximately 12:03 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, HAYES asked, Where you at, man? JONES stated,

I'm comin'. HAYES stated, Where you at? Where you at? Naw, naw. JONES stated, I'm

on my way right now. HAYES stated, Ain't now when you comin'. Where you at? JONES

stated, I was at the bakery. HAYES stated, Hey, where, where all the money that you made

yesterday, from ASHLEY (KRIEDMAN-CRIDER)? JONES stated, Do what? HAYES

stated, Money from ASHLEY yesterday. JONES stated, Oh, it's in my purse. HAYES

stated, What it doin' in your purse? JONES stated, 'Cause I was, I was goin', um, pay my

fine. HAYES stated, You was gonna pay your fine. How much is it, man? Hey look, stop,

hey. JONES stated, It's, uh, one twenty ($120). HAYES stated, For me, so I can know

what's goin' on. Stop doin' that, man. Stop every time you do somethin' you put it in your purse.

Right? Put it up (together with money from all drug sales), alright? Like I do for me. Every time

you do that man. JONES stated, Alright.

25. On July 26, 2017, at approximately 1:44 p.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, HAYES stated, Man, this ni**a got an AR-
8
15, (assault rifle) brand new, Joe. Seven hundred ($700). JONES stated, Who? For how

much? HAYES stated, I can't tell you over the phone. For seven hundred ($700). This is right.

This is right, right. JONES stated, I, I didn't pay that for mine. I don't know what they gonna

give a motherfu**er up there for that . . . . HAYES stated, This the s**t the police be havin'

when they get out they car in Chicago, though. JONES stated, Yeah, same thing. HAYES

stated, Man, where you at? JONES stated, He don't want to trade? HAYES stated, Naw, he,

he don't do that. He needs the money. He don't do that. JONES stated, Oh yeah, alright.

HAYES stated, Where you at? JONES stated, I'll bump it to you in a minute. HAYES

stated, Alright.

26. On July 26, 2017, at approximately 2:43 p.m., LENNON HAYES called MAR-

CUS GARMON on the telephone. During the call, GARMON stated, Yeah. HAYES stated,

What up? GARMON stated, S**t, I'm trying clean and the old lady (heroin customer)

popped over here and said she had a new phone, she couldnt call nobody she didnt know what

to do. HAYES stated, Oh, she been textin. GARMON stated, See, I just gave her your

number and God d**n she talkin about she had fifty ($50). HAYES stated, Alright. GAR-

MON stated, I done gave her that seven (.7 grams of heroin for $50). HAYES stated, Al-

right.

27. On July 26, 2017, at 9:09 p.m., ASHLEY KRIEDMAN-CRIDER sent a text

message to LENNON HAYES, which stated, Hey around 2 230 tonight I'm gonna need 3 or 4

(grams of heroin) answer me then "Brian N Ashley."

28. On July 26, 2017, at 9:17 p.m., LENNON HAYES sent a text message to

ASHLEY KRIEDMAN-CRIDER, which stated, ok.

29. On July 27, 2017, at approximately 12:28 p.m., LENNON HAYES called

EDWARD JONES on the telephone. During the call, JONES stated, Oh, alright, well I'm gonna
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end up, I'm gonna end up comin to Linden in a minute. Cause lil, what's her name over there.

But this ni**a hung up on me today, man. Call me, text me talkin about I'm, I'm some fake ass

s**t and then he called me. Hung up the phone on me. HAYES stated, Who? JONES stated,

Uh, MD (DEMOND STEELE). HAYES stated, Nah, what? JONES stated, One of his

people, one of his people (STEELEs drug customer) got my number but they had my number

since, since motherf**king Florence. HAYES stated, Oh s**t. Later in the conversation,

HAYES stated, So, so, so check this out. How, how, how, you plannin on those people got your

number though? JONES stated, I think, he, he has, I don't. He sayin he, I think he got Terrell

back doin the thing and they probably, he actually he, he probably texts and callin all his people

(drug customers) sayin what's goin on? I'm back down. Everything they (drug customers)

order, everything they order. You know what I'm sayin? And callin everybody and s**t and

probably askin where you been? S**t, I don't know. But, the bi**h (drug customer) wasn't even

talkin about me. The bi**h was talkin about, man I used to mess dude and them for a long time

man. She (drug customer) was talkin about Ness (VANNESS OLIVER). HAYES stated,

Yeah. JONES stated, Yeah, but man. HAYES stated, So, so, so, so you been. You been to

the. . . JONES stated, Yeah, I been knew her since, uh, since, um, she came off, she came off

the, the, the, whats her name, that Ness (OLIVER) gave me. She (drug customer) came off the

phone Ness (VANNESS OLIVER) gave us. HAYES stated, Okay so, so, so you don't have to

explain yourself to nobody man. F**k dude, man. JONES stated, Yeah.

30. On July 27, 2017, at approximately 12:45 p.m., LENNON HAYES called MAR-

CUS GARMON on the telephone. During the call, GARMON stated, What up my dude?

HAYES stated, Hey, when was the last time you fu**ed with Pops Smokey (heroin supplier)?

Down there, uh . . . . GARMON replied, I, I was texting everybody yesterday and let them

know like we got some decent s**t (heroin). I ain't been fu**in with, I ain't fu**ed with him in
10
a minute though. That's why I was texting everybody, I had texted yesterday too. HAYES

stated, They still got that van? GARMON stated, That blue van? Yeah, that's his homie's

van. HAYES stated, His homie f**k (sell heroin) around too though, right? GARMON

stated, Yeah, his homie f**k (sells heroin) around too. That's who stay in the Stimens apart-

ments, his homie do. HAYES stated, I'm fixin go, I'm fixin to go put a note on his window,

man. GARMON stated, Yeah. HAYES stated, Cause they at work right? GARMON

stated, Yeah, they workin, you can't get in the motherfu**er, that's what made me text the

motherfu**er, like, when I was texting motherfu**ers (heroin customers) yesterday let them

know we got decent s**t (heroin). HAYES stated, Look, the bitch (heroin customer) here, the

bitch here, SMITTY (EDWARD JONES) got the bitch down there. Guess he got the bike and

want to show it to her. She, she, she, she, called and textin the s**t out of me. GARMON

laughed. HAYES stated, And then asked STEVE (STEVE HOLLINS) to call me, you know

what I'm saying? Look. GARMON replied, Right. HAYES stated, STEVE (HOLLINS)

where you at? I'm like, I'm like, s**t, I'm in the crib. You know, I was over there at the new

house. I'm like, I'm in the crib. He like, I'm on Linden. I already know. I already know when

he say somethin like that, that somethin goin down was wrong. GARMON stated, Right.

HAYES stated, And then I, I call up and I was like what's up? She was like, never mind. I was

like, what's up. She was like, never mind. So she, STEVE (HOLLINS) already got ahold to me.

You know what I'm sayin? GARMON stated, Right, yup, you know how that s**t goes. S**t,

man. HAYES stated, Oh, MD (DEMOND STEELE), MD and SMITTY (EDWARD JONES)

are to it now. GARMON asked, To what? HAYES replied, Uh, he called me. I didn't, I, you

know I just got up but, uh, SMITTY (JONES) called me. I called SMITTY (JONES). SMITTY

(JONES) was like, MD (STEELE), I wanna. SMITTY (JONES) know one of MD's (STEELEs)

customers for a minute now. So, I guess I don't know. Somewhere MD (STEELE) found out he

11
(heroin customer) be goin (buying heroin) to SMITTY (JONES), you know what I'm sayin? He

called SMITTY (JONES) like, that's some low ass s**t. I don't . . . I'm fixin to check his ass,

you know what I'm sayin? Like, man, quit sayin my name, man.

31. On July 27, 2017, at approximately 6:45 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, HAYES stated, Tell me where you at! On Mulberry?

Where you at? Tell me where you at! Please. JONES stated, Yeah, by Mulberry. HAYES

stated, . . . three (3 grams of heroin) to ASHLEY (KRIEDMAN-CRIDER) and them (drug

customers). Been calling me. JONES stated, Bye.

32. On July 27, 2017, at 6:48 p.m., LENNON HAYES sent a text message to TARA

JONES which stated, Make it 3.

33. On July 27, 2017, at 6:49 p.m., LENNON HAYES received a text message from

TARA JONES, which stated, 3 of .3 (three .3 gram doses of heroin).

34. On July 27, 2017, at approximately 7:04 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, JONES stated, "Yeah." HAYES stated, "Hey, where

you at?" JONES replied, "I seen 'em. I couldn't get through. There was a damn car there that

ran out of gas that was blockin' the fu**ing alley." HAYES stated, "Alright. Where you at now?"

TARA JONES stated, "I seen 'em (drug customers) already."

35. On July 27, 2017, at 8:53 p.m., LENNON HAYES received a text message from

TARA JONES, which stated, Yo money (from heroin sale to KRIEDMAN-CRIDER) is at the

house.

36. On July 28, 2017, at 12:27 p.m., ASHLEY KRIEDMAN-CRIDER sent a text

message to LENNON HAYES, which stated, Tone (HAYES) I need 2 (two half grams of

heroin) "Brian N Ashley."

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37. On July 28, 2017, at approximately 1:00 p.m., LENNON HAYES called TARA

JONES on the telephone. During the conversation, HAYES stated, Take ASHLEY

(KRIEDMAN-CRIDER) two threes (two separate bags of heroin weighing .3 grams) . . . .

Later in conversation, JONES stated, Alright, yeah, sure. Yep, got it. HAYES stated,

Alright.

38. On July 28, 2017, at approximately 6:05 p.m., LENNON HAYES called TARA

JONES on the telephone. During the conversation, HAYES stated, You took that, you took that

stuff (heroin) out of that other bag? That little bag? JONES asked, The what? HAYES stated,

The stuff (heroin), out the little bag. JONES stated, Yeah, that was left outta there and made

them two (2 units of heroin), that's in the cabinet that ASHLEY (KRIEDMAN-CRIDER) didn't

buy. HAYES stated, You got two (units of heroin) in the cabinet? JONES asked, Huh?

Yeah. HAYES stated, You got two? Alright. JONES replied, Yeah, that's the two. Yeah, I

told you I put them back.

39. On July 28, 2017, at approximately 7:28 p.m., LENNON HAYES contacted

MAZZARNEY HARDY on the telephone. During the call, HARDY stated, Yo, yo. HAYES

stated, In about five minutes ASHLEY (KRIEDMAN-CRIDER) gonna be at the house, she

need two 3s (2 .3 doses of heroin). HARDY stated, Alright. HAYES stated, Alright.

40. On July 28, 2017, at approximately 7:42 p.m., LENNON HAYES called

ASHLEY KRIEDMAN-CRIDER on the telephone. During the call, KRIEDMAN-CRIDER

stated, Can you bring me two (two unit doses of heroin)? I need em separate. HAYES stated,

Alright. KRIEDMAN-CRIDER stated, How long? HAYES stated, Walk, walk to, back in

the alley by BUB's (MAZZARNEY HARDY) house. KRIEDMAN-CRIDER stated, Alright.

HAYES stated, Alright.

13
41. On July 28, 2017, at approximately 9:12 p.m., KRIEDMAN-CRIDER called

LENNON HAYES on the telephone. During the call, HAYES stated, What's up? KRIED-

MAN-CRIDER stated, Hey, I'll be over in like three minutes. I need three (3 unit doses of her-

oin). HAYES stated, Alright. KRIEDMAN-CRIDER stated, Alright.

42. On July 29, 2017, at approximately 1:49 p.m., LENNON HAYES called

MAZZARNEY HARDY on the telephone. During the call, MAZZARNEY HARDY stated, Yo

yo. LENNON HAYES stated, When you back around, Kells (RICKELL FIELDS) brother

needs another whole (one gram of heroin). MAZZARNEY HARDY stated, Alright.

43. On July 29, 2017, at approximately 7:14 p.m., RICKELL FIELDS called LEN-

NON HAYES on the telephone. During the call, HAYES stated, Yeah, man. FIELDS stated,

Hey, um Douglas is here. He wants two wholes (2 grams of heroin). HAYES stated, What?

FIELDS stated, Douglas, Katie's brother he wants two wholes (two grams of heroin). HAYES

stated, How much he got? FIELDS stated, How much you got? Hundred ($100)? HAYES

stated, Alright. FIELDS stated, Hey, and he wants um, like, make a half out of that. Like

separate a half from that. HAYES stated, Man I'm fixin to make two wholes (2 grams of her-

oin) and when he, when he get it. He can do it. FIELDS stated, Alright. HAYES stated, Al-

right.

44. On July 30, 2017, at approximately 8:48 a.m. LENNON HAYES made a tele-

phone call to DEMOND STEELE's known telephone number, which was answered by an un-

known female. During the call, the unknown female stated, "Hello." HAYES stated, "Hey, go

on get your little paper (money) ready, man." The unknown female stated, "I'll have him

(STEELE) call you in a second, alright." HAYES stated, "Hey, oh, hey tell him, tell him, tell him

get it (money) together we (HAYES, EDWARD JONES, and RICKELL FIELDS) fittin to leave

(drive to Chicago) in the next hour."


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45. On July 30, 2017, at approximately 9:29 a.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the call, HAYES stated, "Yeah." STEELE stated,

"Yeah, I don't know what happened, I lost the call." HAYES stated, "Yeah." STEELE stated,

"Yeah, I'm ready (has the money for the re-supply of heroin)." HAYES stated, "Alright, right,

I'm fittin come get it (money).

46. On July 30, 2017, at approximately 10:09 a.m., LENNON HAYES called MI-

CHAEL GINN on the telephone. During the call, GINN stated, "Yo." HAYES stated, "Where

you at?" GINN stated, "S**t, I'm at the crib." HAYES stated, "Hey, when you wake up take that

(money) . . . ." GINN stated, "A huh." HAYES stated, "Take that. When you wake up, take,

take that, take that to what you, what you got, take that (money) onto Second, for me, to my

house." GINN asked, "On Second?" HAYES stated, "Yeah." GINN stated, "Alright." HAYES

stated, "And I'll get up (meet) with you later on like late, late tonight." GINN stated, "Alright."

HAYES stated, "I'm fittin, I fittin hit it now (leaving for Chicago to buy heroin)." GINN stated,

"Alright, call me when you get back." HAYES stated, "Alright."

47. On July 30, 2017, at approximately 10:33 a.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the call, STEELE stated, "Hello." HAYES stated,

"Hey, see if you can grab some rubber bands." STEELE stated, "Alright." HAYES stated, "I'm

fittin to pull up."

48. On July 30, 2017, at approximately 10:47 a.m." LENNON HAYES called

DEMOND STEELE on the telephone. During the call, HAYES stated, "That's enough (money)

for a four zero (40 grams of heroin). It's ah . . . it's fifty dollars. . . I'm gonna give this to Kell

(RICKELL FIELDS). You (STEELE) just hit her (FIELDS) with the rest (money) when you

come back." STEELE stated, "Ok." HAYES stated, "I'm gonna get this fifty (50 grams of her-

oin), it's, it was twenty six fifty ($2,650). I'm gonna get this fifty (50 grams), you just hit her
15
(FIELDS) with the rest . . ." STEELE stated, "Ok." HAYES stated, "Alright." STEELE stated,

"Alright."

49. On July 30, 2017, at approximately 10:55 a.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, JONES stated, "Yeah. HAYES stated,

"Where you all at, man?" JONES stated, "I'm right here in the back. Come and pull up."

50. On July 30, 2017, at approximately 1:59 p.m., LENNON HAYES called MI-

CHAEL GINN on the telephone. During the call, GINN stated, "Yo." HAYES stated, "Hey, how

much, how much does you, how much left? Like how much, how much (money) you got?"

GINN stated, "All of it (money), maybe one (short $1,000)." HAYES stated, "Huh?" GINN

stated, "All of it (money) but a grizzle ($1,000)." HAYES stated, "Alright, go on take it over

there." GINN stated, "I'm waitin on my mom come pick up, pick up my kids. She gonna pick

em up right now." HAYES stated, "Ok let me know." GINN stated, "Alright."

51. On July 30, 2017, at 2:28 p.m., LENNON HAYES sent a text message to ROB-

ERTO CALDERON, which stated, We gonna get at u in a min please make mine saperate 145

(145 grams of heroin packaged separately).

52. On July 30, 2017, at 2:28 p.m., LENNON HAYES received a text message from

ROBERTO CALDERON, which stated, ok.

53. On July 30, 2017, at 2:32 p.m., LENNON HAYES sent a text message to ROB-

ERTO CALDERON, which stated, Couple hours.

54. On July 30, 2017, at approximately 4:23 p.m., STEVE HOLLINS called LEN-

NON HAYES on the telephone. During the call, HAYES stated, "Yeah, yeah." HOLLINS

stated, "Hey, he said, what you want me to put (cut) on this twenty-five (25 grams of heroin)?"

HAYES stated, "That's, thats Mike, right?" HOLLINS stated, "He gone, um." HAYES replied,

"Alright, G know what to do, SMITTY (EDWARD JONES) told him what to do. Tell em, ask
16
didn't SMITTY (JONES) tell you what to do?" HOLLINS asked unknown male, "Did SMITTY

(JONES) tell you what to do?" Unknown male stated, "Yeah . . . . HOLLINS stated, "Okay,

yeah I know, alright." HAYES stated, "Alright."

55. On July 30, 2017, at approximately 6:03 p.m., LENNON HAYES called MAR-

CUS GARMON on the telephone. During the call, GARMON stated, "What up, fam?" HAYES

stated, "Man this motherfu**er (EDWARD JONES) he just, he done called me to let them bring

them things (guns) down there. So we all, we here, we we comin'. Now, he (JONES) wanna go

up to the motherfu**in' hotel downtown with the things (money), ni**a. And, and every exit

closed, so we gotta go around s**t." GARMON stated, "Who?" HAYES stated, "Who you think

man? Who you think always tryin' to bring them things (guns) up here, man?" GARMON stated,

"Really?" HAYES stated, "Yeah, he (JONES) came . . . first of all then I'm tryin' to leave, he got

to do this, he got to do that. I was like ah, alright, I'm fittin' to go get Kell (RICKELL FIELDS)

and the money. Imma meet you right here by the thang, you know what I'm sayin?" GARMON

stated, "Right." HAYES stated, "The mother fu**er, I'll meet you on Second. The mother

fu**er, I get on Second, I go get Kell (FIELDS), get the money, go to MD (DEMOND STEELE)

crib, get his money. The motherfu**er still over there talkin to Taj. You know what I'm sayin?

It's like he (JONES) slow man. Like, it's like, you know what I'm sayin?" GARMON stated,

"Yeah, man . . . got no more of that s**t down there?" Later in the conversation, HAYES stated,

"This dude, ain't gonna be here till the morning." GARMON stated, "Man, that's crazy. Damn,

SMITTY (EDWARD JONES) trippin man." HAYES stated, "Man I ain't even wanna bring them

things (guns) and then, then, I kinda, I told him (JONES) naw, I kinda told him naw, then when I

came, he, he had, I said, are you tryin to sneak them motherfu**in things (guns). He was like, I

wasn't sneakin, I was gonna ask. I said, man, you know once they saw lights come on get out the

car, what you gonna say?" GARMON stated, "Hell yeah, ain't no hidin' that s**t (guns)."

17
HAYES stated, "And then, he (JONES), he, he, picked the thing up with the tire and put it (guns)

down there man you got a big ass, you understand me, you think that thing (trunk) gonna close?

Hell, naw."

56. On July 30, 2017, at approximately 6:10 p.m., LENNON HAYES called STEVE

HOLLINS on the telephone. During the call, HOLLINS stated, "Ya?" HAYES stated, "You take

it to him?" HOLLINS stated, "Getting ready to take it over there now." HAYES stated, "How

long you think you goin to be?" HOLLINS stated, "I just talk to him." HAYES stated, "Huh, I

say how long you gonna be, cause I got some people comin." HOLLINS stated, "I just got off

the phone with him. S**t, about ten minutes." HAYES stated, "Alright." HOLLINS stated,

"Yep."

57. On July 31, 2017, at approximately 9:57 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, CALDERON stated, "Yo." HAYES

stated, "Hey, what's up?" CALDERON stated, "Yeah, I'm gonna give him a couple minutes. I'm

waitin' on him to call me back now." HAYES stated, "Oh, you talked to him?" CALDERON

stated, "Yeah." HAYES stated, "Alright, you, you ain't goin with SMITTY (EDWARD

JONES)?" CALDERON stated, "I'm just waitin' on Big Bro (unknown heroin supplier) to uh,

just hit me back . . . just, I already hollered at him." HAYES stated, "No, I'm talkin' about you,

uh, you holler (talk) at SMITTY (JONES)?" CALDERON stated, "Yeah, SMITTY (JONES)

supposed to been comin' here. Where I'm at." HAYES stated, I knew your ass was goin' down

there." CALDERON stated, "I ain't get no . . . yet. That's why, that's how I'm getting my s**t

(supply of heroin)." HAYES stated, "Oh, alright." CALDERON stated, "Alright."

58. On July 31, 2017, at approximately 10:15 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, CALDERON stated, "Yo." HAYES

stated, "Where you at?" CALDERON stated, "I'm, what, you . . ." HAYES stated, "You all ain't,
18
you all ain't met, you all ain't met uh, you ain't, you all ain't met up yet?" CALDERON stated,

"I'm by myself . . . ni**a. I'm waitin' on, I'm waitin' on uh, SMITTY (EDWARD JONES) to pull

up right now." HAYES stated, "Well, I'm fittin to pull up, man." CALDERON stated, "Alright."

HAYES stated, "Where, where, down there?" CALDERON stated, "I'm on Sacramento. Right

off the E way (street in Chicago, Illinois)." HAYES stated, "Alright, here I come. Here I come."

59. On July 31, 2017, at approximately 10:25 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, CALDERON stated, "Yo." HAYES

stated, "How you get, where, where to come to, I'm down there. CALDERON stated, Im

downstairs too, SMITTY (JONES) just got here too. I'm on my way downstairs. Come to the

front door. It's the first parking lot." HAYES stated, "The first what?" CALDERON stated,

"Yeah, the first parking lot. Across the street from the Maxwell's." HAYES stated, "Alright . . .

across the street, alright." CALDERON stated, "Alright."

60. On July 31, 2017, at approximately 10:37 a.m., LENNON HAYES arrived at a

residence located at 2950 West Harrison Street, Chicago, Illinois, and then exited the residence

approximately ten minutes later with EDWARD JONES. Later, HAYES and JONES departed

the residence in HAYES' rental car.

61. On July 31, 2017, at approximately 11:35 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, CALDERON stated, "Yo." HAYES

stated, "I'm, come on, open the door." CALDERON stated, "Room 702. He's going to buzz you

up."

62. On July 31, 2017, at approximately 1:08 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, JONES stated, "Yeah." HAYES stated, "Hey, go, go,

go, go to BUB-G (MAZZARNEY HARDY) and get that six (6 grams of heroin) and take it to

Tony and get that money." JONES stated, "Oh." HAYES stated, "Huh?" TARA JONES stated,
19
"Alright." Later in the conversation, HAYES stated, "Go to the front of ASHLEY house (ASH-

LEY KRIEDMAN-CRIDER). Dont park in front of ASHLEYs house. Go down some. Go

down a little bit. I'm gonna tell him (HARDY) to come out with the six (6 grams of heroin)."

JONES stated, "Alright."

63. On July 31, 2017, at approximately 1:16 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, HAYES stated, "You say how much you need?"

JONES stated, "I'd say at least two-fifty ($250)." HAYES stated, "Alright, Tony gonna give you

two hundred ($200) and then I'm, I'm gonna . . . by Mario have to get a hundred." JONES stated,

"Alright."

64. On July 31, 2017, at approximately 1:32 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, JONES stated, "Yeah." HAYES stated, ". . . Mario?"

JONES stated, "No, I'm at his house now." HAYES stated, "Huh?" JONES stated, "I'm at his

house now. Call him and tell him I'm outside." HAYES stated, "He, he not outside?" JONES

stated, "No." HAYES stated, "You in the back?" JONES stated, "Yeah, I'm in the back." HAYES

stated, "Alright."

65. On July 31, 2017, at 1:36 p.m., TARA JONES sent a text message to LENNON

HAYES, which stated, Seen him.

66. On July 31, 2017, at approximately 1:36 p.m., TARA JONES called LENNON

HAYES on the telephone. During the call, HAYES stated, "Hello." JONES stated, "Tell BUB

(MAZZARNEY HARDY) to come outside." HAYES stated, "Yeah." JONES stated, "Tell BUB

(HARDY) to come outside." HAYES stated, "Alright."

67. On July 31, 2017, at 1:38 p.m., TARA JONES sent a text message to LENNON

HAYES, which stated, Seen him (HARDY) too.

20
68. On July 31, 2017, at approximately 4:46 p.m., LENNON HAYES called MAZ-

ZARNEY HARDY on the telephone. During the call, HARDY stated, "Yo, yo." HAYES stated,

"Hey so, so, so what you ready, you ready for some more (heroin)?" HARDY stated, "Yeah."

HAYES stated, "Huh?" HARDY stated, "Yep." HAYES stated, "Hey look. I don't, I dont, I

dont want you to pay me off until you flip it (sell your supply of heroin), until you flip yourself

for fifty-three (53 grams of heroin)." HARDY stated, "Alright." HAYES stated, "So take your

time and do what you gotta do. But imma tell you what you can do. Cause it's kinda fu**ed up,

I see what you was trying to do . . . STANK (CUPREE HOWARD) is coming tomorrow."

HARDY stated, "Alright." HAYES stated, "Early in the morning, tell STANK (HOWARD) to

look out for . . . hey and tell him go to, go to my dude." HARDY stated, "Alright."

69. On July 31, 2017, at approximately 8:24 p.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, HAYES stated, "Suppose to be one forty (140

grams of heroin). Can't be right." JONES stated, "Yeah." HAYES stated, "Hey, man you got to

check your s**t (heroin), yours or mine because this can't be. How much (heroin) did you get all

together? Tell the truth. Because this can't be right." JONES stated, "Say what?" HAYES

stated, "How much (heroin) did you get all together cause my s**t (heroin) off ten (10 grams)."

JONES stated, "Nah, he (ROBERTO CALDERON) said you suppose to have one-thirty (130

grams of heroin)." HAYES stated, "What?" JONES stated, "That's what he (CALDERON) told

you, you told me you had one-thirty (130 grams of heroin)." HAYES stated, "Hell no! JONES

stated, "How much is that?" HAYES stated, "He (CALDERON) told you I got one thirty (130

grams of heroin)?" JONES stated, "He (CALDERON) said you suppose to have one-thirty (130

grams) or some s**t . . . . HAYES stated, "Man, I only got, I only I . . . man." JONES stated, "I

know how mine (heroin) was wrapped. Mine was wrapped, I ain't lying."

21
70. On July 31, 2017, at approximately 9:10 p.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the call, STEELE stated, "Hello?" HAYES

asked, "You at the crib?" STEELE stated, "Yeah, I am about to be at the crib." HAYES stated,

"Alright, I be." Later in the conversation, STEELE stated, "I am about to pull up." HAYES

stated, "Alright, I be right there." STEELE stated, "Okay."

71. On July 31, 2017, at approximately 9:20 p.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the conversation, STEELE stated, "Hello?"

HAYES stated, "Yeah, you hear me?" STEELE stated, "Is you outside?" HAYES stated, "Yeah."

DEMOND STEELE stated, "Alright, here I come."

72. On July 31, 2017, LENNON HAYES met MICHAEL GINN at 436 Central Ave-

nue, Mansfield, Ohio. Subsequently, HAYES left the residence and drove to 575 Crescent Street,

Mansfield, Ohio, where he met with DEMOND STEELE.

73. On August 1, 2017, at approximately 12:12 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, HAYES stated, "Where you at?" JONES asked, "At

the bakery. Why? Whats up? Whats up? Whats up?" HAYES stated, "Go home go home, get

all of that (heroin), all of that (heroin) up out of there and take it. Take it and put it up in the, uh,

trampoline." JONES stated, "Um, alright, I'm about . . . dropping everybody off still." HAYES

stated, "Man, f**k all that, go. Motherfu**er just seen a squad (police) outside." JONES stated,

"Um, alright." HAYES stated, "On the, it's on the side of thing, all of it (heroin), its, its, its, its, a

black bag and then its the ball. Put it, put it, the trampoline, don't let nobody go see you do it,

the kids, nobody." JONES stated, "Alright." HAYES stated, "Alright."

74. On August 1, 2017, at approximately 7:48 p.m., LENNON HAYES contacted

ASHLEY KRIEDMAN-CRIDER on the telephone. During the call, KRIEDMAN-CRIDER

stated, Hello? HAYES stated, What up? What up? What up? What up? KRIEDMAN-
22
CRIDER stated, I need one (1 gram of heroin). HAYES stated, Alright, go to the back.

KRIEDMAN-CRIDER stated, Alright.

75. On August 1, 2017, at approximately 8:26 p.m., LENNON HAYES called

ASHLEY KRIEDMAN-CRIDER on the telephone. During the call, KRIEDMAN-CRIDER

stated, Hello? HAYES stated, What up? KRIEDMAN-CRIDER stated, Nothin, I already

met BUB (MAZZARNEY HARDY) back there (alley behind 278 South Main Street, Mansfield,

Ohio). HAYES stated, Alright. KRIEDMAN-CRIDER stated, Alright.

76. On August 2, 2017, at approximately 7:13 a.m., LENNON HAYES received a text

message from DEMOND STEELE, which stated, Be careful out here today they (police) are out

here this morning brother be careful this is MD (STEELE).

77. On August 2, 2017, JACQUIS MORDICA possessed a black Titan handgun, se-

rial number #259552, at 278 S. Main Street, Mansfield, Ohio.

78. On August 2, 2017, MAZZARNEY HARDY possessed 2.86 grams of cocaine,

15.29 grams of heroin, a digital scale, and $3,192 in U.S. Currency at his residence located at

278 S. Main Street, Mansfield, Ohio.

79. On August 2, 2017, at approximately 5:38 p.m., RICKELL FIELDS sent a text

message to LENNON HAYES, which stated, My bro (drug customer) here he got 25 ($25).

80. On August 2, 2017, at 5:41 p.m., LENNON HAYES sent a text message to

RICKELL FIELDS, which stated, Tell him bud on da way 4 dat 25.

81. On August 3, 2017, at approximately 11:46 a.m., DEMOND STEELE called

LENNON HAYES on the telephone. During the call, STEELE stated, It's (drug sales) slow.

HAYES replied, Yeah, it's slow. STEELE stated, Work (drug sales) been slow. HAYES

stated, It's slower than a bi**h. STEELE stated, Man, slower than a bitch. HAYES stated,

23
Yeah, I don't know what you on now, I'm fixin to come up Friday (drive to Chicago for resup-

ply of heroin). STEELE stated, S**t, I need to probably go, I prolly, I prolly, I'm almost

through. I only got a ten (10 grams of heroin) left. HAYES stated, Just let me know when.

STEELE stated, Alright, I'm going to let you know. LENNON HAYES stated, Alright.

82. On August 4, 2017, at 5:43 p.m., ASHLEY KRIEDMAN-CRIDER sent a text

message to LENNON HAYES, which stated, Will u do 11 for 250 (11 half-gram packages for

$250) "Brian N Ashley".

83. On August 4, 2017, at approximately 5:44 p.m., ASHLEY KRIEDMAN-CRIDER

contacted LENNON HAYES on the telephone. During the call, HAYES stated, Ya. KRIED-

MAN-CRIDER stated, Okay look, bring them (packages of heroin). Make sure its the same

stuff (heroin) as you gave Mikey (drug customer) this morning. HAYES stated, Shut the f**k

up man. I got to go make em (packages of heroin). KRIEDMAN-CRIDER stated, Alright

bring em. Is it going to be the same stuff you gave Mikey this morning? HAYES stated, Man

shut the f**k up, ya. KRIEDMAN-CRIDER stated, Quit talkin to me like that. HAYES

stated, Alright man, I got to go make em, I got to go home. KRIEDMAN-CRIDER stated,

Alright, about how long. HAYES replied, About 15 to 20 minutes man I got to go make em.

KRIEDMAN-CRIDER stated, Alright, bye.

84. On August 5, 2017, at approximately 3:48 p.m., LENNON HAYES called CU-

PREE HOWARD on the telephone. During the call, HOWARD asked, What up? HAYES

stated, You, you, you got some pieces in my car, the . . . ? HOWARD stated, Not by itself.

HAYES stated, Huh? HOWARD stated, Not by itself. HAYES replied, Give me every bit

that you got of it (heroin) right now. HOWARD stated, Alright. HAYES asked, You hear

me? HOWARD stated, Alright.

24
85. On August 6, 2017, at approximately 8:25 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, CALDERON stated, Yo. HAYES

stated, What you need, that five ($500)? CALDERON stated, Yeah, that'll be cool. HAYES

stated, Alright. CALDERON stated, Alright.

86. On August 6, 2017, at 2:17 p.m., ASHLEY KRIEDMAN-CRIDER sent a text

message to LENNON HAYES, which stated, Tone I need 3 (3 half gram packages of heroin)

"Brian N Ashley".

87. On August 6, 2017, at approximately 2:29 p.m., LENNON HAYES called ASH-

LEY KRIEDMAN-CRIDER on the telephone. During the call, HAYES stated, What's, up?

What's up? What's up? KRIEDMAN-CRIDER stated, I need three (3 half gram packages of

heroin). HAYES stated, Alright. KRIEDMAN-CRIDER stated, Alright.

88. On August 6, 2017, at approximately 2:29 p.m., LENNON HAYES called MAZ-

ZARNEY HARDY on the telephone. During the call, HAYES stated, Hey, where you at?

HARDY stated, Yeah. HAYES asked, Crib? HARDY stated, You say what? HAYES

stated, You at the crib? HARDY stated, Yeah. HAYES stated, ASHLEY (KRIEDMAN-

CRIDER), three threes (3 half gram packages of heroin). HARDY stated, Alright.

89. On August 7, 2017, at approximately 9:40 a.m., LENNON HAYES called ROB-

ERTO CALDERON on the telephone. During the call, ROBERTO CALDERON stated, Yo.

LENNON HAYES stated, Hey, send me your name. ROBERTO CALDERON stated, Al-

right.

90. On August 7, 2017, at 9:41 a.m. LENNON HAYES received a text message from

ROBERTO CALDERON, which stated, Roberto Calderon.

25
91. On August 7, 2017, at 11:21 a.m., LENNON HAYES sent a text message to ROB-

ERTO CALDERON, which stated, 343 075 3657 (wire transfer number) lennon hayes wu

(Western Union).

92. On August 7, 2017, at 12:09 p.m., LENNON HAYES sent a text message to

ROBERTO CALDERON, which stated, West union.

93. On August 7, 2017, at approxiamtely12:45 p.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the call, HAYES stated, You said you was ready

(re-supply of heroin)? STEELE stated, Hell yeah. I'm, I'm out, I'm sellin' my old s**t (heroin)

I had. HAYES stated, What you tryin' to do (how much heroin)? STEELE stated, S**t, fifty

(50 grams of heroin). HAYES stated, Man . . . don't make no sense . . . alright. STEELE

stated, Why? What's up? HAYES replied, Naw, I could stand to get that too. I was tryin' to

went today and I could stand to get one of them too. STEELE stated, Oh yeah, I need that

motherfu**er. HAYES stated, Alright, let me call dude (ROBERTO CALDERON).

STEELE stated, Alright.

94. On August 8, 2017, at approximately 1:41 p.m., LENNON HAYES called

ROBERTO CALDERON on the telephone. During the call, HAYES asked, What I owe you?

CALDERON stated, Huh? HAYES stated, I owe you for what (supply of heroin)?

CALDERON stated, It, it was, um, fifteen ($1,500), and, and, and um, and that nick-nack

(gun). HAYES stated, Oh, it was fifteen ($1,500). CALDERON stated, Dude (EDWARD

JONES) had the fifteen. HAYES stated, No, what I owe you, fuck him (JONES).

CALDERON stated, Oh, yeah. What you wondering what it was? HAYES stated, Man, it was

ten of them, man. CALDERON stated, Ok, you owe me five and ten, ok then, you know what

it is then, it ain't nothin but another six hundred ($600). HAYES stated, So I front you the five

26
($500), the six ($600). CALDERON stated, Yeah. HAYES stated, Alright, you get three

($300) today, man. CALDERON stated, Alright, it's a ten four . . . all that. HAYES stated,

Uh, uh, I, I want ah, s**t, ah, hold on talk to him (JONES), let me see something, talk to him.

EDWARD JONES got on the phone and stated, Yeah, what up? CALDERON stated, Yo.

JONES stated, S**t, I'm fixin to text you the number. Thats a five . . . Thats, thats, not the

other, that ain't what, you know what I'm sayin, got nothing to do what he's doing, so whatever

he tells you, that's how. CALDERON stated, Alright. JONES stated, Uh, . . . .

CALDERON stated, . . . Got some of my extra or what. You got some of them extras . . . for

me or what? JONES stated, Yeah. I got . . . . CALDERON stated, Oh, okay . . . that's all

that matter. JONES stated, That ain't gonna be, that ain't gonna be included though.

CALDERON stated, Alright. JONES stated, . . . Oh, the extras? CALDERON stated,

Yeah. JONES stated, Yeah, he say he (HAYES) want the one ten (110 grams of heroin) plus

the nifties. CALDERON stated, Huh? JONES stated, One ten (110 grams of heroin), plus

whatever else. CALDERON stated, Oh, the extras? JONES stated, He got one ten (110

grams of heroin) plus the extras and whatever he. CALDERON stated, Oh, okay, okay.

Whatever, whatever they gonna do for him? JONES stated, Yeah. CALDERON stated,

Alright. JONES replied, S**t, you can give me uh, s**t, sixty-five (65 grams of heroin). I

got, I got some of that (money) I owe you. Or whatever. CALDERON replied, You said fifty-

five? JONES stated, No, sixty-five (65 grams of heroin). CALDERON stated, Huh? Say it

again. JONES stated, Six five. CALDERON stated, Okay. JONES replied, Or whatever

else you wanna do. But that ain't includin', that ain't includin' what I gotta give you.

CALDERON stated, Okay, okay, that's a ten four. I'm, I'm fixin' to do that now. JONES

stated, Alright.

27
95. On August 8, 2017, at approximately 1:52 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, HAYES stated, What you doin'? JONES replied,

Nothin', uh, mom just came and got me. HAYES stated, Alright, when you get, when you get

back in town, make a seven (.7 grams of heroin), and a one (one gram of heroin), a, uh, whole

one. JONES stated, Okay. HAYES stated, And, uh, take it to STEVE (STEVE HOLLINS)

on uh. JONES asked, Harker? HAYES stated, On Linden. JONES stated, Oh, Linden.

Later in the conversation, JONES stated, A seven and a whole one. HAYES stated, Yeah, a

whole seven and then a whole one. JONES stated, Alright. HAYES stated, No, make it a

seven (.7 grams of heroin) and an eight (.8 grams of heroin). F**k, dude. Make a whole seven

and eight, hey.

96. On August 9, 2017, at approximately 2:39 p.m., LENNON HAYES called TARA

JONES on the telephone. During the call, JONES stated, Yeah. HAYES asked, Where you

at? JONES stated, Still at the house. HAYES stated, I'm fixin' to send somebody (heroin

customer). JONES stated, What? HAYES stated, I'm fixin' to send somebody (heroin

customer) else. JONES asked, To do what? HAYES stated, Two, uh, eights. Two sevens

(two .7 gram packages of heroin). Two sevens . . . . JONES stated, Alright.

97. On August 9, 2017, at 11:28 p.m., RICKELL FIELDS sent a text message to

LENNON HAYES, which stated, Is them ni**as (drug dealers) gonna pay me soon cause i dont

do s**t (drive to Chicago to pick up heroin) for free.

98. On August 10, 2017, at approximately 7:03 p.m., LENNON HAYES called

RICKELL FIELDS on the telephone. During the call, FIELDS stated, Hello? HAYES stated,

What's up? FIELDS stated, What you doin? HAYES stated, I'm on house arrest, man.

They, they, they locked me up for, uh, a warrant. I just got out. FIELDS stated, Are you

fu**ing serious? HAYES stated, Naw, I'm playin. I'm playin with you like that. FIELDS
28
stated, Oh, my God, wow. HAYES stated, BUB (MAZZARNEY HARDY) fixin to bring

you somethin(drugs). I'm fixin to call him tell him. Tell MD (DEMOND STEELE) to take that

money over, over there. I'll call you back in a minute. FIELDS stated, Alright, wow.

99. On August 10, 2017, at approximately 7:07 p.m., LENNON HAYES called

CUPREE HOWARD on the telephone. During the call, HOWARD stated, Yeah. HAYES

stated, MD (DEMOND STEELE) you give me that money yet? HOWARD stated, Damn, I

forgot to give it to you, yup. HAYES replied, How much he, how much he give you?

HOWARD stated, Two hundred ($200). HAYES stated, Alright, I'm fixin to send Kell

(RICKELL FIELDS) for it. CUPREE HOWARD stated, Alright.

100. On August 10, 2017, at approximately 7:08 p.m., LENNON HAYES called

RICKELL FIELDS on the telephone. FIELDS stated, Hello? HAYES stated, Go, go, STANK

(CUPREE HOWARD) got two hundred ($200) for you. BUB (MAZZARNEY HARDY) been

over there yet? FIELDS stated, No. HAYES stated, Huh? FIELDS stated, No. HAYES

stated, Well, go get that two hundred from STANK (HOWARD) then. BUB (HARDY) gonna

bring you something (heroin). FIELDS stated, Alright.

101. On August 11, 2017, at approximately 2:56 p.m., LENNON HAYES called MAZ-

ZARNEY HARDY on the telephone. During the call, HAYES asked, You, you, you got the

money you owe me from the last bag (supply of heroin)? HARDY stated, Yeah, three hundred

($300). HAYES stated, Yeah. HARDY stated, Yeah. HAYES stated, Bring, bring it to

me, man, I'm about to pay this fu**in rent man. HARDY stated, Alright. HAYES stated,

Alright.

102. On August 11, 2017, at approximately 8:56 p.m., LENNON HAYES called

DEMOND STEELE on the telephone. During the call, HAYES stated, You, you, you got that

(money)? STEELE stated, I can get it in the morning. HAYES stated, Alright, alright.
29
STEELE stated, I got to go to the bank and s**t. HAYES stated, About what time you

thinkin because. . . I'm gonna tell you what I'm tryin to do. She, she, she, I, I shouldn't do it but

me and SMITTY (EDWARD JONES) goin to give the ni**a three-fifty ($350) a piece and than,

ah . . . I got to pay that rent too but we gonna give that ni**a three-fifty ($350) a piece so he can

get everything he need in the joint. STEELE stated, Ok. HAYES stated, Yeah, and I got to

pay that . . . . STEELE stated, . . . Like nine, ten o'clock. HAYES stated, I don't know. I

don't talk to her, so I don't know what time she leavin so . . . you know what I'm sayin?

STEELE stated, I'll have it early, early in the morning dude. HAYES stated, Alright.

STEELE stated, Trust me, I . . . . HAYES responded, How much, what, what you owe me

like five fifteen ($515) or somethin? STEELE stated, Yep, some s**t like that, yep.

103. On August 12, 2017, at approximately 8:02 p.m., LENNON HAYES called

CUPREE HOWARD on the telephone. During the conversation, HAYES stated, Man, please,

go buy me half gallon, man. I'll pay you for it when you get here. HOWARD stated, Now

what? HAYES stated, Half a gallon. HOWARD stated, Man, first off, that ni**a MD

(DEMOND STEELE) man, he ain't even come around. HAYES stated, Say what? CUPREE

HOWARD stated, . . . That ni**a MD (STEELE) didn't even come there, he got nothin to sell

after . . . HAYES stated, No, no, no, no, he got a little (heroin) left. He was just over here.

HOWARD stated, Um. HAYES stated, He got a little bit (heroin), whatever he had, he tryin

to get rid of, he got a little bit left. HOWARD stated, Oh. HAYES stated, He say he gonna

do it. I talked to him, he was over here.

104. On August 12, 2017, at approximately 8:57 p.m., LENNON HAYES phone, used

by an unknown female (UF), called CUPREE HOWARD on the telephone. During the call,

HOWARD stated, Yeah. UF stated, Hey, um, he (HAYES) said we can bring a fifty ($50

worth of heroin) if you got it. HOWARD asked, A fifty? UF stated, Yeah.
30
105. On August 12, 2017, at approximately 9:01 p.m., CUPREE HOWARD called

LENNON HAYES on the telephone call. During the call, HAYES stated, Yo. HOWARD

stated, What up? HAYES stated, Bring a, bring a fifty ($50 worth of heroin). HOWARD

stated, Alright, she (UF) told me. HAYES stated, Bring a blunt too. Couple blunts. HOW-

ARD stated, Alright. HAYES stated, Alright. Subsequently, HOWARD arrived at HAYES

residence located at 575 Crescent Avenue, Mansfield, Ohio.

106. On August 14, 2017, at approximately 6:56 p.m., RICKELL FIELDS called

LENNON HAYES on the telephone. During the conversation, HAYES stated What up? What

up? What up? What up? FIELDS stated, Ay, ay, what you doin? HAYES stated, Still got

my daughter, what's up? FIELDS replied, Um, I was just seeing what you was doin. My um,

my brother's got twenty-five ($25 to buy heroin). HAYES replied, Uh, alright, give me a

minute. FIELDS stated, Alright.

107. On August 14, 2017, at approximately 8:54 p.m., LENNON HAYES called MAZ-

ZARNEY HARDY on the telephone. During the call, HARDY stated, Yeah? HAYES stated,

"Hey take Brandon (drug customer) two eight's (two .8 gram doses of heroin), he got a hundred

($100). HARDY asked, Two eight's? HAYES stated, "Yeah. HARDY stated, Alright.

108. On August 15, 2017, at approximately 5:00 p.m., MICHAEL GINN called LEN-

NON HAYES on the telephone. During the call, HAYES asked, Who is this? GINN stated,

Mike. HAYES stated, Huh? GINN stated, Mike. HAYES replied, Aw, what up Mike,

what up? Later in the conversation, GINN stated, This ni**a (heroin supplier) down here from

Akron, this ni**a (supplier) got this s**t (heroin) boy. I dont know, I need somebody to try it

(heroin). Its white though. Later in the conversation, GINN stated, Huh? HAYES stated,

"I'll get somebody (drug tester) to do it . . . . GINN stated, I'm at my Mom . . . Shay. Meet me

on, on the east somewhere. HAYES stated, "I'm on house arrest man. GINN stated, Youre
31
on house arrest? HAYES stated, "Yeah. GINN stated, What the hell, for what? HAYES

stated, "Gonna be on this s**t another week. Some old ass traffic s**t, man, from 2015.

GINN stated, Uh, s**t can you have somebody meet me over there on Second? HAYES

stated, "Yeah. GINN stated, Call me back. HAYES stated, "Yeah, where you gonna be on

2nd? GINN stated, I can be there right now. HAYES stated, "Alright, get on over there. . .

I'll call dude (drug tester). GINN stated, Alright.

109. On August 16, 2017, at approximately 8:28 a.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, HAYES stated, Guess who popped up last

night ni**ar? JONES stated, You say Trigg came over there? HAYES stated, Huh?

JONES stated, You say Trigg came over there? HAYES stated, I say, guess who popped up?

JONES stated, I dont know. HAYES stated, Evil E. JONES stated, Oh yeah. HAYES

stated, Huh? JONES stated, Yeah. Later during the conversation, JONES stated, I caught

him comin down 2nd man, late as hell. HAYES stated, Evils what? JONES stated, I

pulled up on 2nd to do somethin last night, he comin down 2nd from what its name, just

creepin and s**t. Right? Man what you do. . . down the . . . for? HAYES stated, Oh s**t

man. JONES stated, You gave him some? HAYES stated, Huh? JONES stated, You gave

him some? HAYES stated, Man, he gonna come this morning man. He caught me drunk

n****r. He caught me drunk. JONES stated, He tryin to hit a lick around . . . I told him to

pick five up in the morning from, from BLACK (TERRANCE JONES). HAYES stated, Huh?

JONES stated, I told him to get five from BLACK (TERRANCE JONES) for the morning.

HAYES stated, Hey man. I dont know though. JONES stated, You probably said youd give

him twenty. HAYES stated, Who me? JONES stated, Yeah. HAYES stated, Hell, naw. I

give his ass ten ni**ar. I will hit the s**t outta . . . too. I mean five. JONES stated, Mm, hm,

right. HAYES stated, . . . and I aint gonna let, man, Im gonna ask him man. Im gonna have

32
a talk with him Joe . . . Im like man, f**k you cant hold on no s**t, you a boss. That the case,

you should go back to work for SMITTY (EDWARD JONES). Im gonna tell him that.

110. On August 16, 2017, at approximately 2:28 p.m., LENNON HAYES called

MAZZARNEY HARDY on the telephone. During the call, HARDY stated, Yo, yo. HAYES

replied, Rickell's (FIELDS) brother comin. Cut him two sevens (2 .7 gram doses of heroin).

He (drug customer) got money. HARDY stated, Alright. HAYES stated, Alright. HARDY

stated, Who you say? Brandon? HAYES stated, Yeah, Brandon.

111. On August 16, 2017, at approximately 10:04 p.m., LENNON HAYES called

MAZZARNEY HARDY on the telephone. During the call, HARDY stated, Yeah, yeah.

HAYES stated, Take uh, three eights (3 .8 gram doses of heroin) to Brandon (drug customer).

HARDY stated, Alright.

112. On August 17, 2017, at approximately 7:58 p.m., LENNON HAYES called MAR-

CUS GARMON on the telephone. During the call, GARMON stated, What up hoe? HAYES

stated, S**t . . . but motherfu**er . . . got to get a g ($1000) every Sunday. Like, like, like fif-

teen hundred ($1,500) every Sunday. Like you comin you, you know what I'm sayin? GAR-

MON stated, You say, you say what now? HAYES stated, I, I, I, I, I'm talkin to you though.

I'll break it down like, somethin like SMITTY (EDWARD JONES) do, you know what I'm

sayin. Like, I, I, I, I, give up the . . . then we just. I don't care how no motherfu**er feel like we

just give up, give up ah, we give up a three five. A three-five (.35 gram dose of heroin) for the,

ah, for the fifty ($50) and a seven (.7 gram dose of heroin) for the, for the hundred ($100).

GARMON stated, Right. HAYES stated, The motherfu**er (subordinate heroin dealers to

HAYES) get like fifteen ($1,500) a week. GARMON stated, Motherfu**er (subordinate her-

oin dealers to HAYES) get fifteen ($1,500) a week. HAYES stated, Yeah, but that's just the,

you know what I'm sayin. So a motherfu**er (subordinate heroin dealer) can know. Know what
33
they doin (how much they are making weekly) so I can know what I'm getting off of it. GAR-

MON stated, Right. HAYES stated, But a motherfu**er (subordinate heroin dealers to

HAYES) still do fifteen ($1,500) a week. It's better than what a motherfu**er makin now.

GARMON stated, Yeah. HAYES stated, You know what I'm sayin'? GARMON stated,

Right. HAYES stated, If . . . motherfu**ers . . . fifteen. I know you be up with it. I'm talkin

about dude, you know what I'm sayin? Like . . . . GARMON stated, Right. HAYES stated,

I'm tryin to see how MD (DEMOND STEELE) do (manages) his s**t (drug business), you

know what I'm sayin? Like, if I can just find the line, a motherfu**er (drug customer) come

with forty ($40). A motherfu**er come with fifty ($50). We're really gonna do like a fifty ($50)

for a three-five (.35 gram does of heroin) and a . . . GARMON stated, Um, hm. HAYES

stated, And a seven (.7 gram dose of heroin) for a bill ($100), you know what I'm sayin?

GARMON stated, Right. HAYES stated, And the motherfu**er (subordinate drug dealer)

just, just get paid, paid by the week. GARMON stated, Right. HAYES stated, Until that

motherfu**er (subordinate drug dealer) build up (drug customers) till we know what we doin,

you know what I'm sayin? GARMON stated, Exactly, yeah, hell yeah. HAYES stated, And,

and s**t you know it's goin to pop up we're goin, we goin to have, we gonna have the real s**t

(quality heroin). GARMON stated, Right. HAYES stated, But I want to wait till you come

cause you know I can work with you. I, I can get you what (heroin) you need, I can't, I can't, I

can't work with dude, you know what I'm sayin? Like, if you come and we don't get it all off in

a week (heroin supply sold during the week). You know, I know we is but, you know what I'm

sayin, we don't. I know I can be like SLIM (GARMON), woo, woo. You know what I'm

sayin? I can't do that with him. That's why I want you. GARMON stated, Right. HAYES

stated, But, I want you to be here when I do it. You know what I'm sayin? When you come

back. GARMON stated, Right, right. HAYES stated, Analyze what we can do. 'Cause you

34
really the only motherfu**er (drug dealer) that don't be spendin no money you know what I'm

sayin. GARMON stated, Right. HAYES stated, Like that. GARMON stated, Ah, huh.

HAYES stated, Or, or, or a motherfu**er, motherfu**er. I don't know how MD (STEELE) do

it. A motherfu**er do it like MD (STEELE) do it like put thirty (30 grams of cut) on a fifty (50

grams of heroin) and you get this off that and you know what I'm sayin? GARMON stated,

Right. HAYES stated, I don't know, man. GARMON stated, Damn motherfu**ers s**t I'll

be down there. Um, probably, what's today Thursday? HAYES stated, Cause, cause, I'm

gonna say this, I don't, cause I'm gonna say this right now y'all, y'all (subordinate drug dealers to

HAYES) ain't makin nothin (no money). I ain't makin nothin. The quicker the s**t (heroin)

look, I buy, I buy, I buy, I buy, I buy a fifty (50 grams of heroin). I pay thirty-two ($3,200) for it.

At least let me make twenty-five ($2,500) off the s**t (heroin). You know what I'm sayin?

GARMON stated, Right. HAYES stated, But the faster it go, I wouldn't mind cause it the

fast it go, motherfu**er wouldn't mind cause twenty-five ($2,500) is going to come like that, you

see what I'm sayin? GARMON stated, Right, right exactly. HAYES stated, You know what

I mean? GARMON stated, Hell, yeah. HAYES stated, That's what I'm sayin. That's why I

say and we only got to tell the people, just when the people come we can give it to them. They be

like whats this s**t. Man, you gonna, you gonna understand when, you know what I'm sayin?

You gonna understand when you do it. Put all the lines together, all the lines together and that

motherfu**er pop off everybody just take turns. You . . . . GARMON stated, Right, yep,

s**t. HAYES stated, You know what I'm sayin? GARMON stated, Hell yeah, I'm down

f**k it, see how that s**t goin go. HAYES stated, That's why I want you come down here

and we, we just pop off a fifty (50 grams of heroin). Put thirty (30 grams of cut) on a fifty (50

grams of heroin) and let me see what I get off it (amount of money from selling that mixture).

Either, either a motherfu**er (subordinate heroin dealer to HAYES) get somethin off that or the

35
motherfu**er (subordinate heroin dealer to HAYES) get paid fifteen ($1,500) a week. But I

want to talk to you cause you know you is gonna get some money. I don't need no desperate

motherfu**er, you know what I'm sayin. GARMON stated, Right, yeah, s**t, I'm have to . . .

now. HAYES stated, Now, it's just me and you, me and you holler (talk) about this. We, this

what me and you gonna do. Motherf**ker gotta roll, roll with the programs. You know what I'm

sayin'? GARMON stated, Alright. HAYES stated, Aint no more, I'm talkin' about no more

hittin' (diluting) that shit (heroin). Makin' this into that and that into this. A motherfu**er put,

even if a motherfu**er (drug dealer) do twenty . . . at a time, the mother fu**er put like ten (10

grams of cut) on the twenty-five (25 grams of heroin). You know what I'm sayin'? GARMON

stated, Right. HAYES stated, The motherfu**ers, you know what I'm sayin'? Man . . . see

how it go. GARMON stated, Right, right, exactly, yeah. HAYES stated, Alright. GAR-

MON stated, Alright.

113. On August 18, 2017, at approximately 7:32 p.m., EDWARD JONES called LEN-

NON HAYES on the telephone. During the call, JONES stated, Which one you, what you

want, the whole one thing? LENNON HAYES stated, Ya, the whole ten (10 grams of heroin).

EDWARD JONES stated, Alright. LENNON HAYES stated, Alright.

114. On August 19, 2017, at approximately 8:39 a.m., CUPREE HOWARD called

LENNON HAYES on the telephone. During the call, HOWARD stated, You got a twenty ($20

worth of heroin) over there? HAYES stated, What you . . . yeah. HOWARD stated, I say

you alright, I . . . come get it. HAYES stated, Alright.

115. On August 19, 2017, at approximately 2:44 p.m., LENNON HAYES called

JACQUIS MORDICA on the telephone. During the call, MORDICA stated, Yo. HAYES

stated, Hey, make uh, Cindy (drug customer) an eight (.8 gram dose of heroin). MORDICA

36
stated, Alright. HAYES stated, Want me to send her to the alley (behind 278 S. Main Street,

Mansfield, Ohio)? MORDICA stated, Yeah, this, this JACQUIS, I got 'em though. HAYES

stated, Alright. MORDICA stated, Okay.

116. On August 20, 2017, at approximately 1:07 p.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, JONES stated, Yeah. HAYES asked, "Talk

to MD (DEMOND STEELE)? JONES stated, Yeah. HAYES stated, "Huh? JONES stated,

Yeah, he called me. HAYES stated, "Aw, he just called me. You aint, you aint tell him?

JONES stated, "Naw, I ain't told him (STEELE) s**t. I told him I got my four. I ain't tell him

nothin' 'bout it. JONES stated, That's what I'm sayin. HAYES stated, He's, hes (STEELE)

sellin wrong anyway. JONES stated, Who over there fu**in with that water? HAYES

stated, Ay, you say he's selling wrong anyway, right? JONES stated, Yeah, he's . . . like that

anyway, so. HAYES stated, "So, he's the best man for it, s**t. JONES stated, Yep, cause if

I, if I, if I f**k with whats his name (an unknown drug supplier), I was gonna try to put a one on

it (adding cut to the heroin) like you be doin, but s**t. I'd fu**in waste my money doin that.

I'd have to . . . myself then. HAYES stated, Hell no, oh. . . Man, just be like, man, me and

dude was talkin man, get you some seventy-five s**t. Know what I'm sayin? JONES stated,

Yeah, I'm puttin it all, uh, you say what? HAYES stated, "Be like me and you was talkin

'bout, I was like, I can't make . . . say, and he said you was gonna be out man. I got some for

you. I need seventy-five (75 grams of heroin). JONES stated, Damn. HAYES stated, "What

you was gonna hit or what? JONES stated, Damn, I told him (CALDERON) seventy (70

grams of heroin). HAYES stated, "That's cool. You gonna . . . long as you make some.

JONES stated, Yeah, cause I'm gonna send it up there. I'm a, I'm gonna send it to what's his

name. He comin tonight. HAYES stated, "Who? JONES stated, He comin tomorrow

morning. Uh, uh, Chris Brown. HAYES stated, "Aw s**t. Might beat dude up. JONES
37
stated, Yep, I'm a, I, whatever he give me, I'm a shoot it to Chris Brown. S**t . . . come back. I,

I, I need it. I don't wanna, you know what I'm sayin? I did that for a reason, 'cause I need it.

HAYES stated, "I know. JONES stated, Cause I, I ain't goin til you goin. HAYES stated,

"Dude (HAYES heroin supplier CALDERON) called me already. Called me again today.

JONES stated, Aw, yeah, he (CALDERON) say he needs five hundred ($500). HAYES

stated, "Aw, I got it. JONES stated, Yeah, I told him I'd slide on you, slide over on you, and

drive it, if you need me to do it, and shoot it to em. HAYES stated, "Yeah, I got it. JONES

stated, Or, how you want to shoot it? HAYES stated, "I'm good sooner or later, just slide man.

Yeah. Mario won't answer the phone. But s**t he ready, told me he was. JONES stated, No,

the other one (supply of heroin) that I got, that one that I just got, Im fittin, Im fittin I'm to

f**k (dilute the heroin with cut) with that in a minute. HAYES stated, "Alright, let me know

what's goin on with that. JONES stated, Alright. HAYES stated, "Alright.

117. On August 20, 2017, at approximately 4:12 p.m., LENNON HAYES called

MAZZARNEY HARDY on the telephone. During the call, HARDY stated, Yo. HAYES

stated, Hey, that ni**a even answering the phone no more. My fault. HARDY stated, Al-

right. HAYES stated, Where y'all at? What you doin? HARDY stated, I'm on, I'm on ah . . .

Main. I'm waitin on a P (drug customer) right now. HAYES stated, Waitin on oh so you, so

y'all whipped a motherfu**er last night and you ain't called and told me nothin, man. I don't

f**k wit you no more. HARDY stated, Man that ni**a. HAYES stated, F**k you, man,

f**k you Joe. Tell Jaq (JAQUIS MORDICA). . . HARDY stated, Hey listen, listen. HAYES

stated, Fuck him, Joe. HARDY stated, Look, this ni**a, this ni**a. First time it looked like,

look, when we in that bitch, the ni**a walk up on me and s**t. HAYES stated, Nah, come

over here and tell me, man. When you serve your P (drug customer) you and Jaq (MORDICA)

38
come over here and tell me Joe. I want to hear this s**t. HARDY stated, It's, it's, it's your P

(drug customer). Its the cry baby lady. I'm waitin on her ass. HAYES stated, Alright.

118. On August 21, 2017, at approximately 3:33 p.m., LENNON HAYES called ED-

WARD JONES on the telephone. During the call, JONES stated, Yeah. HAYES stated,

Where you at? JONES stated, On Second. HAYES stated, Ah, I need like two or three (2

or 3 grams of heroin) of them man till later on. JONES stated, Huh? HAYES stated, I need

about two or three, two or three, two or three, till later on. JONES stated, Alright. HAYES

stated, Imma send huh, imma send Coop (C.M., a person known to the grand jury, but not

charged herein) over there. JONES stated, Who? HAYES stated, Coop (C.M.), my dude

Coop (C.M.). JONES stated, Oh, alright.

119. On August 21, 2017, C.M. possessed 2 grams of heroin on his person.

120. On August 21, 2017, at approximately 4:45 p.m., LENNON HAYES called

EDWARD JONES on the telephone. During the call, JONES stated, Yeah? HAYES stated,

Man how long ago he (C.M.) left? JONES stated, Who dude (C.M.)? HAYES stated,

Yeah. JONES stated, S**t, right when, I wasn't there I called huh, Wood told him to hit them.

He went straight out there and hit him (gave C.M. heroin). I don't know. HAYES stated,

Huh? JONES stated, I said I wasn't there, I called Wood, told him to do it. He went out there.

HAYES stated, Man, that ni**a (C.M.) ain't made it over here yet. Man, let me try him man.

JONES stated, . . . man I pull up over there, you know, he been gone. HAYES stated, Alright,

let me call him. JONES stated, Alright.

121. On August 21, 2017, at approximately 5:02 p.m., LENNON HAYES called

EDWARD JONES on the telephone. During the call, JONES stated, Yeah? HAYES stated,

Man, I just got ahold of . . . this ni**a (C.M.) taking a day, this ni**a (C.M.) taking all day. He

39
talking he (C.M.) got caught with it (police found the heroin on C.M.). He (C.M.) showed me a

paper (ticket), some, some, I don't even know. I, I, I balled the s**t up, you know how when I

caught my case they gave made me sign a paper (ticket) and let me go? He (C.M.) got some

s**t, I ain't read the s**t. I'm saying, man, come on, man, he talking about I got caught with it.

Look, I don't got nothing. What (how much heroin) you give him? JONES stated, S**t, I told

him, give him two or three (2 or 3 grams of heroin) whatever, whatever was in that little bag I

got, that was right there. HAYES stated, Man, this ni**a (C.M.) here man . . . He wants to

have some little paper (ticket), man he didn't get caught with this s**t (heroin), man. JONES

stated, Who was it, who was it? HAYES stated, My ni**a Coop (C.M.) that be, I have clean

up for me and s**t. JONES stated, The tall dude? HAYES stated, Nah, the white dude,

man. Not Otis, man, Coop (C.M.). I said, man, you didn't get caught with that one little ass bag,

man. He was like, stuffed it . . . woo, woo. Man, that little ass bag was not enough for them to

feel, man. JONES laughed. HAYES stated, Man, I could have smacked the s**t out of him,

man. He got this motherfu**ing paper (ticket), ni**a that s**t look like some s**t you done had

typed up already on some bulls**t. JONES stated, Yeah, what now? HAYES stated, S**t, I

gotta get it to you later, I don't got it, motherfu**er. JONES stated, Nah, I'm saying do you still

need something else (more heroin)? HAYES stated, Nah, BUB, BUB, BUB, I had BUB

(MAZZARNEY HARDY) to go do it because he was taking all day with that. JONES stated,

Oh alright, because I was bring something else (heroin) if you. HAYES stated, Man, I could

have smacked the s**t out of him (C.M.) man. I don't even know, I can't, I'm looking at the paper

he got the date on it right, I'm looking at the date, it got the date on it but I don't even know if its

that paper that they (police) give you. Because when I got mine, I balled that s**t up, I didn't

even look at it. JONES stated, Damn. HAYES stated, Man, on my momma. I don't know.

Slide through when you . . . . JONES stated, Alright.

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122. On August 22, 2017, at 12:12 a.m., LENNON HAYES sent a text message to CU-

PREE HOWARD, which stated, Give kell (RICKELL FIELDS) .8 for me (.8 grams of heroin).

123. On August 22, 2017, at approximately 3:34 p.m., LENNON HAYES called MAZ-

ZARNEY HARDY on the telephone. During the call, HARDY stated, Yo yo. HAYES stated,

Where you at? HARDY stated, On Linden. HAYES stated, Give ASHLEY (KRIEDMAN-

CRIDER), give ASHLEY that ten (10 .3 gram doses of heroin) for that two thirty ($230), I got

you. HARDY stated, You got ten, ten threes (10 .3 gram doses of heroin)? HAYES stated,

Ten threes, yeah ten threes. HARDY stated, Alright for two thirty ($230)? HAYES stated,

Huh? HARDY asked, You got the two thirty ($230)? HAYES stated, Yeah, yeah, I already

know I'm owed I'm going make something up with you on that. HARDY stated, Alright . . .

124. On August 23, 2017, at approximately 9:02 a.m., LENNON HAYES called CU-

PREE HOWARD on the telephone. During the call, HOWARD stated, Yo, yo. HAYES stated,

Take ASHLEY (KRIEDMAN-CRIDER) two (doses of heroin), I'll give you one to make it up.

HOWARD stated, Alright.

125. On August 24, 2017, at approximately 5:48 p.m., Source 3 contacted an individual

known as Red on the telephone about the purchase of heroin. After the call, at approximately

5:51 p.m., Source 3 met TERRANCE JONES at 271 Second Avenue, Mansfield, Ohio. During

the meeting, JONES sold Source 3 .89 grams of heroin for $50.

126. On August 24, 2017, at approximately 6:35 p.m., CUPREE HOWARD called

LENNON HAYES on the telephone. During the call, HAYES stated, S**t, we can't really do

nothin' till I go back to the store (re-supply of heroin). HOWARD stated, Man. I ain't sayin'

like that. This s**t . . . but I ain't seein' but four people (heroin customer) a day, man. I ain't

makin' a dime . . . . HAYES stated, Only thing I can say, man, we go, you sold that car?

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HOWARD stated, Huh? HAYES stated, You sold that car? HOWARD stated, I'm done

this s**t right now. I ain't made s**t. I've had . . . . Later, during the conversation, HAYES

stated, Listen what I'm sayin'. Listen what I'm sayin'. Listen what I'm sayin'. Listen what I'm

sayin'. I don't give a f**k about this. Motherfu**er just . . . when I come off this thing man, we

gonna, we gonna, we gonna, we gonna do a, do a, do a twenty-five (25 grams of cut) with a

thirty-five (35 grams of heroin). We gonna, we gonna pass that whole motherfu**in' thing out to

everybody (heroin customers). All the way around the world. We gonna get a new phone. We

gonna tell, we gonna, we gonna write that number down and put the s**t up in there. We gonna

pass out. Not the people that we know. F**k them. We passin' out to everybody in Little Ken-

tucky at their program. Everybody around this whole city. We gonna pass out. HOWARD

stated, Damn. I'm with ya, man. HAYES stated, You know what I'm sayin'? And then we

gonna get a new phone and regroup. Motherfu**er can't do nothin'. Man, I don't need, I don't

need, I know what you sayin', but I don't even wanna hear it, man, 'cause it's frustratin'. HOW-

ARD stated, Man, that s**t get real frustratin'. I'm only gettin' it to my girl and mother fu**in' .

. . . HAYES stated, Man, . . . motherfu**er . . . 'cause the truth be known, man, it's . . . fu**ed

up. 'Cause if I don't, if I don't, if I don't hurry up and at least get this off, and get back to the

store (drug supplier) before the seventh, that mean I gotta use all that money. I gotta use that

money to pay them mother fu**in' bills, man. HOWARD stated, Man, and I said bro, I gotta

pay bills over there. That's why I'm like, this s**t (drug dealing) more frustratin' . . . . HAYES

stated, Hey just, you got, get some . . . to send it to you. HOWARD stated, Who? HAYES

stated, The money. HOWARD stated, They ain't gonna hand a mother fu**er . . . 'cause they

might not have no more . . . if . . . got a ride, I'll see if she can do it. HAYES stated, Just, just,

just, just, just. HOWARDs response was unintelligible. HAYES stated, No, no, no, stay

there. Check it out. 'Cause my mama can send it to her account. Just, just get her, get her to take,

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take my mama the two. HOWARD stated, Alright, uh, no. I'm leavin' out Saturday. I just,

when I get up there. HAYES stated, Oh, yeah, yeah, yeah, yeah, yeah, yeah. I don't know man.

Just what it, I, I already told BUB (MAZZARNEY HARDY) like, I'm a, I'm a do the twenty-five

(25 grams of heroin) with the thang (cut). We, we changin' the price and all that. We gonna be

hurtin'. We might as well be hurtin' and try to build up somethin' (drug business) and be hurtin'

and have somethin' to go on that ain't goin'. HOWARD stated, Man, cause I'm sittin' up here

watchin' man. This man is movin' a motherfu**in' ten (10 grams of heroin) for MD (DEMOND

STEELE). HAYES stated, Right, 'cause he sellin' it raw (uncut heroin). But, I say it like this,

if we gonna be fu**ed up, we might as well be fucked up tryin' to build somethin' (drug busi-

ness) than be fu**ed up and got some. So, I rather be fu**ed up tryin' to build somethin' else. I

don't, f**k it man, alright.

All in violation of Title 21, United States Code, Section 846.

COUNT 2

The Grand Jury further charges:

On or about September 22, 2015, in the Northern District of Ohio, Eastern Division,

LENNON HAYES and others known and unknown to the Grand Jury, did knowingly and

intentionally distribute approximately 1.31 grams of a mixture or substance containing a

detectable amount of heroin, a Schedule I controlled substance, in violation of Title 21, United

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

COUNT 3

The Grand Jury further charges:

On or about April 22, 2016, in the Northern District of Ohio, Eastern Division, EDWARD

JONES did knowingly and intentionally distribute approximately .53 grams of a mixture or

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substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 4

The Grand Jury further charges:

On or about May 5, 2016, in the Northern District of Ohio, Eastern Division, EDWARD

JONES did knowingly and intentionally distribute approximately .59 grams of a mixture or

substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 5

The Grand Jury further charges:

On or about May 13, 2016, in the Northern District of Ohio, Eastern Division, EDWARD

JONES did knowingly and intentionally distribute approximately .35 grams of a mixture or

substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 6

The Grand Jury further charges:

On or about December 19, 2016, in the Northern District of Ohio, Eastern Division,

EDWARD JONES did knowingly and intentionally distribute approximately 1.22 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

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COUNT 7

The Grand Jury further charges:

On or about January 4, 2017, in the Northern District of Ohio, Eastern Division,

LENNON HAYES did knowingly and intentionally distribute approximately 1.45 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 8

The Grand Jury further charges:

On or about January 10, 2017, in the Northern District of Ohio, Eastern Division,

LENNON HAYES did knowingly and intentionally distribute approximately 1.5 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 9

The Grand Jury further charges:

On or about January 11, 2017, in the Northern District of Ohio, Eastern Division,

EDWARD JONES did knowingly and intentionally distribute approximately 2.01 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 10

On or about January 12, 2017, in the Northern District of Ohio, Eastern Division, JAMES

ALEXANDER did knowingly and intentionally distribute approximately 1.31 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

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COUNT 11

The Grand Jury further charges:

On or about January 25, 2017, in the Northern District of Ohio, Eastern Division, JAMES

ALEXANDER did knowingly and intentionally distribute approximately .56 grams of a mixture

or substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 12

The Grand Jury further charges:

On or about January 30, 2017, in the Northern District of Ohio, Eastern Division,

MARRICO KING did knowingly and intentionally distribute approximately .93 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 13

The Grand Jury further charges:

On or about January 31, 2017, in the Northern District of Ohio, Eastern Division,

MARRICO KING did knowingly and intentionally distribute approximately .94 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 14

The Grand Jury further charges:

On or about February 1, 2017, in the Northern District of Ohio, Eastern Division,

NATASHA BROOKINS and EDWARD JONES did knowingly and intentionally distribute

approximately .55 grams of a mixture or substance containing a detectable amount of heroin, a

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

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

COUNT 15

The Grand Jury further charges:

On or about February 2, 2017, in the Northern District of Ohio, Eastern Division,

NATASHA BROOKINS did knowingly and intentionally distribute approximately .92 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 16

The Grand Jury further charges:

On or about February 9, 2017, in the Northern District of Ohio, Eastern Division,

NATASHA BROOKINS did knowingly and intentionally distribute approximately .82 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 17

The Grand Jury further charges:

On or about February 15, 2017, in the Northern District of Ohio, Eastern Division,

LENNON HAYES did knowingly and intentionally distribute approximately 1.5 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

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COUNT 18

The Grand Jury further charges:

On or about April 25, 2017, in the Northern District of Ohio, Eastern Division,

VANNESS OLIVER did knowingly and intentionally possess with the intent to distribute

approximately 26.53 grams of a mixture or substance containing a detectable amount of heroin, a

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

and (b)(1)(C).

COUNT 19

The Grand Jury further charges:

On or about April 25, 2017, in the Northern District of Ohio, Eastern Division,

VANNESS OLIVER did knowingly and intentionally possess with the intent to distribute

approximately 19.39 grams of a mixture or substance containing a detectable amount of cocaine,

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

841(a)(1) and (b)(1)(C).

COUNT 20

The Grand Jury further charges:

On or about April 25, 2017, in the Northern District of Ohio, Eastern Division,

VANNESS OLIVER, having been previously convicted of a crime punishable by imprisonment

for a term exceeding one year, that is: Felonious Assault, a felony in the 2nd degree, Case

Number 2005CR0068, Richland County Common Pleas Court, on or about April 20, 2005, did

knowingly possess in and affecting interstate commerce a firearm, to wit: one Smith and Wesson

handgun, serial number #ECA1027, and ammunition; in violation of Title 18, United States

Code, Section 922(g)(1).

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COUNT 21

The Grand Jury further charges:

On or about May 13, 2017, in the Northern District of Ohio, Eastern Division, LENNON

HAYES did knowingly and intentionally distribute approximately 1.33 grams of a mixture or

substance containing a detectable amount of heroin, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNT 22

The Grand Jury further charges:

On or about May 17, 2017, in the Northern District of Ohio, Eastern Division, LENNON

HAYES did knowingly and intentionally possess with the intent to distribute approximately 1.14

grams of a mixture or substance containing a detectable amount of heroin, a Schedule I

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

(b)(1)(C).

COUNT 23

The Grand Jury further charges:

On or about July 13, 2017, in the Northern District of Ohio, Eastern Division, LENNON

HAYES and CUPREE HOWARD did knowingly and intentionally distribute approximately 1.46

grams of a mixture or substance containing a detectable amount of heroin, a Schedule I

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

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

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COUNT 24

The Grand Jury further charges:

On or about July 31, 2017, in the Northern District of Ohio, Eastern Division, LENNON

HAYES, EDWARD JONES, and RICKELL FIELDS did travel in interstate commerce between

the State of Ohio and the State of Illinois, with the intent to promote, manage, establish, carry on,

and facilitate the promotion, management, establishment, and carrying on of an unlawful activity,

to wit: a business enterprise involving the distribution of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and 846, and the said

defendants, LENNON HAYES, EDWARD JONES, and RICKELL FIELDS, thereafter, did

perform and attempt to perform acts to promote, manage, carry on, and facilitate the promotion,

management, and carrying on of said unlawful activity.

All in violation of Title 18, United States Code, Sections 2 and 1952(a)(3).

COUNT 25

The Grand Jury further charges:

On or about August 2, 2017, in the Northern District of Ohio, Eastern Division,

MAZZARNEY HARDY and JACQUIS MORDICA did knowingly and intentionally possess

with the intent to distribute approximately 15.29 grams of a mixture or substance containing a

detectable amount of heroin, a Schedule I controlled substance, in violation of Title 21, United

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

COUNT 26

The Grand Jury further charges:

On or about August 2, 2017, in the Northern District of Ohio, Eastern Division,

MAZZARNEY HARDY and JACQUIS MORDICA did knowingly and intentionally possess

with the intent to distribute approximately 2.86 grams of a mixture or substance containing a
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detectable amount of cocaine, a Schedule II controlled substance, in violation of Title 21, United

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

COUNT 27

The Grand Jury further charges:

On or about August 2, 2017, in the Northern District of Ohio, Eastern Division,

JACQUIS MORDICA, having been previously convicted of a crime punishable by imprisonment

for a term exceeding one year, that is: Other Amount Narcotic Schedule 1 & 2, a felony in the

4th degree, Case Number 2009CR0543101, Cook County Common Pleas Court, on or about

June 4, 2009, did knowingly possess in and affecting interstate commerce a firearm, to wit: a

black Titan handgun, serial number #259552, and ammunition; in violation of Title 18, United

States Code, Section 922(g)(1).

COUNT 28

On or about August 2, 2017, in the Northern District of Ohio, Eastern Division, JACQUIS

MORDICA, did knowingly possess a firearm in furtherance of a drug trafficking crime, for which

said defendant may be prosecuted in a court of the United States, that is, Conspiracy to Possess

with the Intent to Distribute and to Distribute Heroin, in violation of Title 21, United States Code,

Sections 841(a)(1) and (b)(1)(A), as charged in Count 1, and/or Possession with the Intent to

Distribute Heroin and Cocaine, in violation of Title 21, United States Code, Sections 841(a)(1) and

(b)(1)(C) and Title 18, Section 2, United States Code, as charged in Counts 25 and 26 of the

Indictment, in violation of Title 18, United States Code, Section 924(c)(1)(A), and punishable

under Title 18, Section 924(c)(1)(A)(i), United States Code.

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COUNT 29

The Grand Jury further charges:

On or about August 24, 2017, in the Northern District of Ohio, Eastern Division,

TERRANCE JONES did knowingly and intentionally distribute approximately .89 grams of a

mixture or substance containing a detectable amount of heroin, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C).

COUNTS 30-41

The Grand Jury further charges:

On or about the dates and approximate times listed below, in the Northern District of

Ohio, Eastern Division, and elsewhere, the defendants listed below did knowingly and

intentionally use a communication facility, to wit: a telephone, to facilitate acts constituting a

felony under Title 21, United States Code, Section 846:

Count Defendants Date Time


30 LENNON HAYES July 26, 2017 2:43 p.m.
MARCUS GARMON
31 LENNON HAYES July 28, 2017 6:05 p.m.
TARA JONES
32 LENNON HAYES July 30, 2017 10:33 a.m.
DEMOND STEELE
33 LENNON HAYES July 30, 2017 1:59 p.m.
MICHAEL GINN
34 LENNON HAYES July 30, 2017 4:23 p.m.
STEVE HOLLINS
35 LENNON HAYES July 31, 2017 9:57 a.m.
ROBERTO CALDERON
36 LENNON HAYES July 31, 2017 4:46 p.m.
MAZZARNEY HARDY
37 LENNON HAYES August 4, 2017 5:43 p.m.
ASHLEY KRIEDMAN-CRIDER

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38 LENNON HAYES August 10, 2017 7:08 p.m.
RICKELL FIELDS
39 LENNON HAYES August 19, 2017 2:44 p.m.
JACQUIS MORDICA
40 LENNON HAYES August 20, 2017 1:07 p.m.
EDWARD JONES
41 LENNON HAYES August 24, 2017 6:35 p.m.
CUPREE HOWARD

All in violation of Title 21, United States Code, Section 843(b).

FORFEITURE

The Grand Jury further charges:

For the purpose of alleging forfeiture pursuant to 21 U.S.C. 853, 18 U.S.C. 924(d)(1)

and 28 U.S.C. 2461(c), the allegations of Counts 1 through 23, and Counts 25 through 29,

inclusive, are incorporated herein by reference. As a result of the foregoing offenses, LENNON

HAYES, aka TONE; ROBERTO CALDERON, aka PUERTO RICAN ROB; DEMOND

STEELE, aka MAD DOG (MD); TARA JONES; EDWARD JONES, aka SMITTY;

MAZZARNEY HARDY, aka BUB-G; MICHAEL GINN; STEVE HOLLINS; CUPREE

HOWARD, aka STANK; MARCUS GARMON, aka SLIM; ASHLEY KRIEDMAN-CRIDER;

RICKELL FIELDS, aka KELL; MARRICO KING; TERRANCE JONES, aka BLACK;

NATASHA BROOKINS; JAMES ALEXANDER; VANNESS OLIVER, aka NESS; and

JAQUIS MORDICA, aka JAQ, the defendants herein, shall forfeit to the United States any and

all property constituting, or derived from, any proceeds they obtained, directly or indirectly, as

the result of such violations; any and all of their property used or intended to be used, in any

manner or part, to commit or to facilitate the commission of such violations; and, any and all

property (including firearms and ammunition) involved in or used in the commission of such

violations; including, but not limited to, the following:

a. Smith and Wesson handgun, serial number #ECA1027, and ammunition, and
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b. a black Titan handgun, serial number #259552, and ammunition.

A TRUE BILL.

Original document - Signatures on file with the Clerk of Courts, pursuant to the E-Government
Act of 2002.

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United States v. Lennon Hayes, et al.

A TRUE BILL.

___________________________
FOREPERSON

_________________________________
JUSTIN E. HERDMAN
United States Attorney

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