OTF Indictment

Case 2:24-cr-00621-MRA Document 1 Filed 10/17/24 Page 1 of 18 Page ID #:1
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10/17/2024
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CDO
8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 June 2024 Grand Jury
11 UNITED STATES OF AMERICA, CR No. 2:24-cr-00621-MRA
12 Plaintiff, I N D I C T M E N T
13 v. [18 U.S.C. § 1958(a): Conspiracy

and Use of Interstate Facilities
14 KAVON LONDON GRANT, to Commit Murder-For-Hire
aka “Cuz,” Resulting in Death; 18 U.S.C.
15 aka “Vonnie,” §§ 924(c)(1)(A)(iii),
DEANDRE DONTRELL WILSON, (c)(1)(B)(ii), (j)(1): Use, Carry,
16 aka “DeDe,” and Discharge of Firearms and
KEITH JONES, Machinegun, and Possession of Such
17 aka “Flacka,” Firearms, in Furtherance of a
DAVID BRIAN LINDSEY, Crime of Violence, Resulting in
18 aka “Browneyez,” and Death; 18 U.S.C. § 922(o):
ASA HOUSTON, Possession of a Machinegun; 18
19 aka “Boogie,” U.S.C. §§ 981(a)(1)(C), 924(d)(1),
and 28 U.S.C. § 2461(c): Criminal
20 Defendants. Forfeiture]
21
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23
24 The Grand Jury charges:

25 INTRODUCTORY ALLEGATIONS
26 1. At times relevant to this Indictment, defendants KAVON
27 LONDON GRANT, also known as (“aka”) “Cuz,” aka “Vonnie,” DEANDRE
28 DONTRELL WILSON, aka “DeDe,” ASA HOUSTON, aka “Boogie,” and
1 Co-Conspirators 1-5 were members or associates of an organization
2 called Only the Family, or “OTF” which, among other things, produced
3 and sold hip hop music from artists primarily from the Chicago,
4 Illinois area. Defendants KEITH JONES, aka “Flacka,” and DAVID BRIAN
5 LINDSEY, aka “Browneyez,” were members of other gangs in Chicago,
6 Illinois.
7 2. On or about November 6, 2020, D.B., a high-ranking OTF
8 member, got into a physical altercation with T.B. at a nightclub in
9 Atlanta, Georgia. During the fight, an associate of T.B. pulled out
10 a gun and shot D.B. multiple times, killing him. After the murder,
11 Co-Conspirator 1 made clear, in coded language, that Co-Conspirator 1
12 would pay a bounty or monetary reward, and/or make payment to anyone
13 who took part in killing T.B. for his role in D.B.’s murder.
14 3. On or about August 18, 2022, the conspirators learned that
15 T.B. was staying at a hotel in Los Angeles, California. As alleged
16 in Counts One and Two, after learning of T.B.’s location, defendants
17 WILSON, JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 traveled
18 from Chicago, Illinois, to Los Angeles, California, for the purpose
19 of murdering T.B. On that same day --- August 18, 2022 --- defendant
20 GRANT also traveled by private jet to Los Angeles, California.
21 4. As alleged in Counts One and Two, on August 19, 2022,
22 defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and
23 Co-Conspirator 2 used two vehicles to track, stalk, and attempt to
24 kill T.B. by gunfire --- including with a fully automatic firearm ---
25 resulting in the death of S.R.
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1 COUNT ONE
2 [18 U.S.C. § 1958(a)]
3 [ALL DEFENDANTS]
4 Paragraphs 1 through 4 of the Introductory Allegations of this
5 Indictment are re-alleged and incorporated here.
6 A. OBJECT OF THE CONSPIRACY
7 Beginning on a date unknown, but no later than on or around

8 August 18, 2022, and continuing to on or about August 19, 2022, in
9 Los Angeles County, within the Central District of California, and
10 elsewhere, defendants KAVON LONDON GRANT, also known as (“aka”)
11 “Cuz,” aka “Vonnie,” DEANDRE DONTRELL WILSON, aka “DeDe,” KEITH
12 JONES, aka “Flacka,” DAVID BRIAN LINDSEY, aka “Browneyez,” and ASA
13 HOUSTON, aka “Boogie,” and co-conspirators known and unknown,
14 conspired and agreed with each other to knowingly use facilities of
15 interstate and foreign commerce, namely, airplanes, cars, cell
16 phones, and the internet, with intent that the murder of T.B. be
17 committed in violation of the laws of any State, namely, the State of
18 California, as consideration for the receipt of, and consideration
19 for a promise and agreement to pay, anything of pecuniary value,
20 namely, money and lucrative music opportunities with OTF, in
21 violation of Title 18, United States Code, Section 1958(a).
22 The use of interstate facilities to commit murder that was the
23 object of the conspiracy resulted in the death of S.R.
24 B. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE
25 ACCOMPLISHED
26 The object of the conspiracy was to be accomplished, in
27 substance, as follows:
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1 1. Co-Conspirator 1 would place bounties on individuals that
2 Co-Conspirator 1 and other OTF members wanted to kill, including T.B.
3 As part of the bounty, co-conspirators known and unknown, including
4 defendant WILSON, would pay anyone who took part in the killing of
5 T.B. and/or reward individuals with lucrative music opportunities
6 with OTF.
7 2. Co-conspirators known and unknown, including defendant
8 WILSON, would recruit others, including defendants JONES, LINDSEY,
9 and HOUSTON, and Co-Conspirator 2, to find, track, and kill T.B.
10 3. Defendant GRANT would procure cars, ski masks, and firearms
11 that would be used by co-conspirators to find, track, and kill T.B.
12 4. Using a credit card associated with OTF, Co-Conspirator 3
13 would purchase airplane tickets for the co-conspirators to fly to
14 California and murder T.B.
15 5. Defendants WILSON, JONES, LINDSEY, and HOUSTON, and
16 Co-Conspirator 2, would travel from Chicago, Illinois to Southern
17 California via airplane to find, track, and kill T.B.
18 6. Defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and
19 Co-Conspirator 2, would travel throughout Los Angeles County via cars
20 procured by defendant GRANT to find, track, and kill T.B.
21 7. Defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and
22 Co-Conspirator 2, would communicate via cell phone to coordinate
23 logistics to find, track, and kill T.B.
24 8. Defendants JONES and LINDSEY, and Co-Conspirator 2, would
25 fire multiple shots at T.B., killing S.R., who was a passenger in
26 T.B.’s vehicle.
27 9. Defendant WILSON would pay the bounty or monetary reward,
28 and/or cause payment to be made for the killing of S.R., on behalf of

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1 co-conspirators known and unknown, to the conspirators hired to kill
2 T.B.
3 C. OVERT ACTS
4 On or about the following dates, in furtherance of the

5 conspiracy and to accomplish its object, defendants GRANT, WILSON,
6 JONES, LINDSEY, and HOUSTON, and Co-Conspirators 1-5, and others
7 known and unknown, committed various overt acts in Los Angeles
8 County, within the Central District of California, and elsewhere,
9 including, but not limited to, the following:
10 Overt Act No. 1: Following the killing of D.B. on or about
11 November 6, 2020, Co-Conspirator 1, using coded language, told
12 defendant WILSON, Co-Conspirators 2, 4, and 5, and others that
13 Co-Conspirator 1 would pay a bounty or monetary reward to anyone who
14 took part in the killing of T.B.
15 Overt Act No. 2: On August 18, 2022, one or more
16 co-conspirators, including Co-Conspirator 4, learned that T.B. was
17 visiting California and staying at a hotel in Los Angeles.
18 Overt Act No. 3: On August 18, 2022, defendant GRANT flew
19 from Miami, Florida to Los Angeles, California on a private jet, so
20 that defendant GRANT could help coordinate the murder of T.B.
21 Overt Act No. 4: On August 18, 2022, co-conspirators,
22 including Co-Conspirator 5, asked Co-Conspirator 2 to travel to
23 Southern California later that day.
24 Overt Act No. 5: On August 18, 2022, defendant WILSON
25 recruited defendants JONES and LINDSEY to travel to California for
26 the purpose of murdering T.B. and helped facilitate such travel by,
27 among other things, texting Co-Conspirator 3 biographical information
28 about defendants JONES and LINDSEY so that Co-Conspirator 3 could
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1 book flights to Southern California, specifically: defendant JONES’
2 name, date of birth, and a picture of defendant JONES’ ID card; and
3 defendant LINDSEY’s name, date of birth, and a picture of defendant
4 LINDSEY’s ID card.
5 Overt Act No. 6: On August 18, 2022, Co-Conspirator 1 texted
6 Co-Conspirator 3: “Don't book no flights under no names involved wit

7 me.”
8 Overt Act No. 7: On August 18, 2022, using a credit card
9 ending in -2039 (“OTF Credit Card 1”), Co-Conspirator 3 purchased
10 airplane tickets for defendants WILSON, JONES, LINDSEY, and HOUSTON,
11 and Co-Conspirator 2 to travel from Chicago, Illinois to San Diego,
12 California that same day.
13 Overt Act No. 8: On August 18, 2022, Co-Conspirator 3
14 confirmed to defendant WILSON via text message that defendants
15 WILSON, JONES, and LINDSEY had the same airline ticket confirmation.
16 Overt Act No. 9: On August 18, 2022, defendant WILSON
17 messaged a friend on Instagram: “On my way to LA.”
18 Overt Act No. 10: On August 18, 2022, defendant HOUSTON texted
19 Co-Conspirator 3: “On got clear im 15 minutes away from airport.”
20 Overt Act No. 11: On August 18, 2022, defendants WILSON,
21 JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 flew from Chicago,
22 Illinois to San Diego, California via the airplane tickets procured
23 by Co-Conspirator 3 using OTF Credit Card 1.
25 JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 traveled towards
26 Los Angeles County in a car to meet with defendant GRANT.
27 Overt Act No. 13: On August 18, 2022, defendant GRANT
28 purchased four black ski masks from a sporting goods store in Los
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1 Angeles County using cash.
2 Overt Act No. 14: On August 18, 2022, using a credit card
3 ending in -1015 (“OTF Credit Card 2”), defendant GRANT rented a hotel
4 room for the co-conspirators located in Los Angeles, California (the
5 “Universal City Hotel”).
6 Overt Act No. 15: On August 18, 2022, in or around Los
7 Angeles, California, defendant GRANT met with the co-conspirators and
8 provided defendants JONES and LINDSEY, and Co-Conspirator 2 with
9 firearms --- including a firearm that had been modified to operate as
10 a fully automatic machinegun --- to kill T.B.
11 Overt Act No. 16: On August 18, 2022, defendant GRANT provided
12 two cars for defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON,
13 and Co-Conspirator 2 to use to find, track, and kill T.B. --- a white
14 BMW sedan (the “BMW”) from a rental company in Los Angeles County,
15 and a white Infiniti sedan (the “Infiniti”) with a fake license
16 plate.
17 Overt Act No. 17: On August 18, 2022, defendants GRANT,
18 WILSON, JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 traveled in
19 the BMW and the Infiniti to a hotel in downtown Los Angeles,
20 California where T.B. was staying (the “Downtown L.A. Hotel”) to
21 find, track, and kill T.B.
22 Overt Act No. 18: On August 19, 2022, using the BMW and
23 Infiniti, defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and
24 Co-Conspirator 2 traveled to the Downtown L.A. Hotel where T.B. was
25 staying to find, track, and kill T.B.
28 Co-Conspirator 2 followed and tracked T.B.’s black Escalade to a
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1 marijuana dispensary located on Flower Street, in Los Angeles,
2 California.

5 Co-Conspirator 2 followed and tracked T.B.’s black Escalade to a
6 clothing store located on Melrose Avenue, in West Hollywood,
7 California. The below image shows the BMW and Infiniti following the
8 black Escalade in which T.B. and S.R. were passengers, as the black
9 Escalade traveled towards the clothing store.
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3 Co-Conspirator 2 tracked T.B.’s black Escalade to a gas station
4 located on Beverly Boulevard, in Los Angeles, California (the
5 “Beverly Gas Station”).
6 Overt Act No. 22: On August 19, 2022, defendant HOUSTON drove
7 the Infiniti to an alley behind the Beverly Gas Station and parked
8 the vehicle, so that defendants JONES and LINDSEY, and Co-Conspirator
9 2 could attempt to murder T.B.
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1 Overt Act No. 23: On August 19, 2022, at the Beverly Gas
2 Station, defendants JONES and LINDSEY, and Co-Conspirator 2 used the
3 firearms procured by defendant GRANT --- including the fully
4 automatic firearm --- to shoot at T.B.’s car, striking and killing
5 S.R., who was standing next to T.B.’s car while T.B. was inside. The
6 images below show defendants JONES and LINDSEY, and Co-Conspirator 2
7 firing their guns at T.B.’s black Escalade.
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1 Overt Act No. 24: On August 19, 2022, in the Infiniti driven
2 by defendant HOUSTON, defendants JONES and LINDSEY, and
3 Co-Conspirator 2 fled the alley behind the Beverly Gas Station after
4 the conspirators shot and killed S.R.
5 Overt Act No. 25: On August 19, 2022, defendants GRANT,
6 WILSON, JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 traveled to

7 a hamburger restaurant in Los Angeles County, where the
8 co-conspirators discussed, among other things, payments to defendants
9 JONES and LINDSEY for the shooting earlier that day.
10 Overt Act No. 26: On August 19, 2022, using OTF Credit Card 1,
11 Co-Conspirator 3 purchased airline tickets from San Diego,
12 California, to Chicago, Illinois, for defendants WILSON, JONES,
13 LINDSEY, and HOUSTON, and Co-Conspirator 2.
15 JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 flew back to
16 Chicago, Illinois from San Diego, California.
17 Overt Act No. 28: Following S.R.’s murder, defendant WILSON
18 paid defendants JONES and LINDSEY on behalf of a co-conspirator for
19 their role in the murder.
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1 COUNT TWO
2 [18 U.S.C. §§ 1958(a), 2(a)]
3 [ALL DEFENDANTS]
4 Beginning on a date unknown, but no later than on or around
5 August 18, 2022, and continuing to on or about August 19, 2022, in
6 Los Angeles County, within the Central District of California, and
7 elsewhere, defendants KAVON LONDON GRANT, also known as (“aka”)
8 “Cuz,” aka “Vonnie,” DEANDRE DONTRELL WILSON, aka “DeDe,” KEITH
9 JONES, aka “Flacka,” DAVID BRIAN LINDSEY, aka “Browneyez,” and ASA
10 HOUSTON, aka “Boogie,” and co-conspirators known and unknown, each
11 aiding and abetting the other, knowingly used facilities of
12 interstate and foreign commerce, namely, airplanes, cars, cell
13 phones, and the internet, with intent that the murder of T.B. be
14 committed in violation of the laws of any State, namely, the State of
15 California, as consideration for the receipt of, and consideration
16 for a promise and agreement to pay, anything of pecuniary value,
17 namely, money and lucrative music opportunities with OTF, resulting
18 in the death of S.R.
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1 COUNT THREE
2 [18 U.S.C. §§ 924(c)(1)(A)(iii), (B)(ii), (j)(1), 2(a)]
3 [ALL DEFENDANTS]
4 On or about August 19, 2022, in Los Angeles County, within the
5 Central District of California, defendants KAVON LONDON GRANT, also
6 known as (“aka”) “Cuz,” aka “Vonnie,” DEANDRE DONTRELL WILSON, aka
7 “DeDe,” KEITH JONES, aka “Flacka,” DAVID BRIAN LINDSEY, aka
8 “Browneyez,” and ASA HOUSTON, aka “Boogie,” together with
9 Co-Conspirator 2, each aiding and abetting the other, knowingly used
10 and carried firearms, including a firearm that defendants GRANT,
11 WILSON, JONES, LINDSEY, and HOUSTON knew to be a machinegun, during
12 and in relationship to, and possessed such firearms in furtherance
13 of, a crime of violence, namely, Use of Interstate Facilities to
14 Commit Murder-For-Hire Resulting in Death, in violation of Title 18,
15 United States Code, Section 1958(a), as charged in Count Two of this
16 Indictment, and, in so doing, discharged the firearms, resulting in
17 the death of S.R.
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1 COUNT FOUR
2 [18 U.S.C. § 922(o)]
3 [DEFENDANT JONES]
4 On or about August 19, 2022, in Los Angeles County, within the
5 Central District of California, defendant KEITH JONES, aka “Flacka,”
6 knowingly possessed a machinegun, as defined in Title 18, United
7 States Code Section 921(a)(3), and Title 26, United States Code,
8 Section 5845(b), namely, a 10mm caliber firearm equipped with an
9 auto-sear conversion device which was designed and intended, solely
10 and exclusively, for use in converting a weapon into a machinegun,
11 which defendant JONES knew to be a machinegun.
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1 FORFEITURE ALLEGATION ONE
2 [18 U.S.C. §§ 981(a)(1)(C), 924(d)(1); 28 U.S.C. § 2461(c)]
3 1. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Sections 981(a)(1)(C), 924(d)(1), and Title 28,
7 United States Code, Section 2461(c), in the event of any defendant’s
8 conviction of the offenses set forth in any of Counts One and Two of
9 this Indictment.
10 2. Any defendant so convicted shall forfeit to the United
11 States of America the following:
12 (a) All right, title, and interest in any and all
13 property, real or personal, constituting, or derived from, any
14 proceeds traceable to any of the offenses;
15 (b) All right, title, and interest in any firearm or
16 ammunition involved in or used in any such offense and
17 (c) To the extent such property is not available for
18 forfeiture, a sum of money equal to the total value of the property
19 described in subparagraphs (a) and (b).
20 3. Pursuant to Title 21, United States Code, Section 853(p),
21 as incorporated by Title 28, United States Code, Section 2461(c), any
22 defendant so convicted shall forfeit substitute property, up to the
23 value of the property described in the preceding paragraph if, as the
24 result of any act or omission of said defendant, the property
25 described in the preceding paragraph or any portion thereof (a)
26 cannot be located upon the exercise of due diligence; (b) has been
27 transferred, sold to, or deposited with a third party; (c) has been
28 placed beyond the jurisdiction of the court; (d) has been

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1 substantially diminished in value; or (e) has been commingled with
2 other property that cannot be divided without difficulty.
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1 FORFEITURE ALLEGATION TWO
2 [18 U.S.C. § 924(d)(1); 28 U.S.C. § 2461(c)]
3 1. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Section 924(d)(1), and Title 28, United States
7 Code, Section 2461(c), in the event of any defendant’s conviction of
8 the offenses set forth in any of Counts Three and Four of this
9 Indictment.
10 2. Any defendant so convicted shall forfeit to the United
11 States of America the following:
12 (a) All right, title, and interest in any firearm or
13 ammunition involved in or used in any such offense; and
14 (b) To the extent such property is not available for
15 forfeiture, a sum of money equal to the total value of the property
16 described in subparagraph (a).
17 3. Pursuant to Title 21, United States Code, Section 853(p),
18 as incorporated by Title 28, United States Code, Section 2461(c), any
19 defendant so convicted shall forfeit substitute property, up to the
20 value of the property described in the preceding paragraph if, as the
21 result of any act or omission of said defendant, the property
22 described in the preceding paragraph or any portion thereof (a)
23 cannot be located upon the exercise of due diligence; (b) has been
24 transferred, sold to, or deposited with a third party; (c) has been
25 placed beyond the jurisdiction of the court; (d) has been
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1 substantially diminished in value; or (e) has been commingled with
2 other property that cannot be divided without difficulty.
4 A TRUE BILL
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6 /S/
Foreperson
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8 E. MARTIN ESTRADA
United States Attorney
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11 MACK E. JENKINS
Assistant United States Attorney
12 Chief, Criminal Division
13 IAN V. YANNIELLO
14 Chief, General Crimes Section
15 DANIEL H. WEINER
16 International Narcotics, Money
Laundering, and Racketeering
17 Section
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OTF Indictment

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OTF Indictment

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Case 2:24-cr-00621-MRA Document 1 Filed 10/17/24 Page 1 of 18 Page ID #:1

8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 June 2024 Grand Jury

11 UNITED STATES OF AMERICA, CR No. 2:24-cr-00621-MRA

13 v. [18 U.S.C. § 1958(a): Conspiracy

24 The Grand Jury charges:

1 Co-Conspirators 1-5 were members or associates of an organization

5 LINDSEY, aka “Browneyez,” were members of other gangs in Chicago,

7 2. On or about November 6, 2020, D.B., a high-ranking OTF

8 member, got into a physical altercation with T.B. at a nightclub in

9 Atlanta, Georgia. During the fight, an associate of T.B. pulled out

11 Co-Conspirator 1 made clear, in coded language, that Co-Conspirator 1

12 would pay a bounty or monetary reward, and/or make payment to anyone

14 3. On or about August 18, 2022, the conspirators learned that

15 T.B. was staying at a hotel in Los Angeles, California. As alleged

16 in Counts One and Two, after learning of T.B.’s location, defendants

17 WILSON, JONES, LINDSEY, and HOUSTON, and Co-Conspirator 2 traveled

18 from Chicago, Illinois, to Los Angeles, California, for the purpose

20 GRANT also traveled by private jet to Los Angeles, California.

21 4. As alleged in Counts One and Two, on August 19, 2022,

22 defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and

23 Co-Conspirator 2 used two vehicles to track, stalk, and attempt to

25 resulting in the death of S.R.

2 [18 U.S.C. § 1958(a)]

4 Paragraphs 1 through 4 of the Introductory Allegations of this

5 Indictment are re-alleged and incorporated here.

6 A. OBJECT OF THE CONSPIRACY

7 Beginning on a date unknown, but no later than on or around

1 1. Co-Conspirator 1 would place bounties on individuals that

2 Co-Conspirator 1 and other OTF members wanted to kill, including T.B.

3 As part of the bounty, co-conspirators known and unknown, including

5 T.B. and/or reward individuals with lucrative music opportunities

7 2. Co-conspirators known and unknown, including defendant

8 WILSON, would recruit others, including defendants JONES, LINDSEY,

9 and HOUSTON, and Co-Conspirator 2, to find, track, and kill T.B.

10 3. Defendant GRANT would procure cars, ski masks, and firearms

11 that would be used by co-conspirators to find, track, and kill T.B.

12 4. Using a credit card associated with OTF, Co-Conspirator 3

13 would purchase airplane tickets for the co-conspirators to fly to

14 California and murder T.B.

15 5. Defendants WILSON, JONES, LINDSEY, and HOUSTON, and

16 Co-Conspirator 2, would travel from Chicago, Illinois to Southern

17 California via airplane to find, track, and kill T.B.

18 6. Defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and

19 Co-Conspirator 2, would travel throughout Los Angeles County via cars

20 procured by defendant GRANT to find, track, and kill T.B.

21 7. Defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and

22 Co-Conspirator 2, would communicate via cell phone to coordinate

23 logistics to find, track, and kill T.B.

24 8. Defendants JONES and LINDSEY, and Co-Conspirator 2, would

25 fire multiple shots at T.B., killing S.R., who was a passenger in

27 9. Defendant WILSON would pay the bounty or monetary reward,

28 and/or cause payment to be made for the killing of S.R., on behalf of

1 co-conspirators known and unknown, to the conspirators hired to kill

4 On or about the following dates, in furtherance of the

1 book flights to Southern California, specifically: defendant JONES’

2 name, date of birth, and a picture of defendant JONES’ ID card; and

3 defendant LINDSEY’s name, date of birth, and a picture of defendant

5 Overt Act No. 6: On August 18, 2022, Co-Conspirator 1 texted

6 Co-Conspirator 3: “Don't book no flights under no names involved wit

1 Angeles County using cash.

1 marijuana dispensary located on Flower Street, in Los Angeles,

4 Infiniti, defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and

2 Infiniti, defendants GRANT, WILSON, JONES, LINDSEY, and HOUSTON, and

3 Co-Conspirator 2 tracked T.B.’s black Escalade to a gas station

4 located on Beverly Boulevard, in Los Angeles, California (the

5 “Beverly Gas Station”).

2 Station, defendants JONES and LINDSEY, and Co-Conspirator 2 used the

3 firearms procured by defendant GRANT --- including the fully

4 automatic firearm --- to shoot at T.B.’s car, striking and killing

6 images below show defendants JONES and LINDSEY, and Co-Conspirator 2

7 firing their guns at T.B.’s black Escalade.

2 by defendant HOUSTON, defendants JONES and LINDSEY, and

4 the conspirators shot and killed S.R.

5 Overt Act No. 25: On August 19, 2022, defendants GRANT,