UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE INDICTMENT. Count One

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1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE UNITED STATES OF AMERICA, ) ) Plaintiff, ) No. 3:11-CR-69 v. ) ) JUDGES Phillips/Shirley MERRELL NEAL, ) MICHAEL NEAL, and ) BRANDON SCOTT HARRIS, ) ) Defendants. ) INDICTMENT Count One The Grand Jury charges that, from on or about April 1, 2011, through on or about May 21, 2011, in the Eastern District of Tennessee and elsewhere, defendants MERRELL NEAL, MICHAEL NEAL, and BRANDON SCOTT HARRIS did combine, conspire, confederate, and agree with one another and others to knowingly, intentionally, and without authority distribute, and possess with intent to distribute, five (5) kilograms or more of a mixture and substance containing a detectable amount of cocaine, and two-hundred and eighty (280) grams or more of a mixture and substance containing a detectable amount of cocaine base, also known as crack, Schedule II controlled substances. Object and Purpose The object and purpose of the conspiracy was to sell cocaine and cocaine base, also known as crack, to other drug dealers in and around Knoxville, Tennessee, to make money. Case 3:11-cr Document 14 Filed 05/24/11 Page 1 of 5 PageID #: 38

2 Methods and Means The defendants MERRELL NEAL, MICHAEL NEAL, and BRANDON SCOTT HARRIS, and others, used various methods and means to accomplish the object and purpose of the conspiracy, including, but not limited to, the following: a. Defendant MERRELL NEAL obtained multi-kilogram quantities of cocaine in the Chicago, Illinois, area, and transported that cocaine to Knoxville, Tennessee, for resale there; b. Defendant MICHAEL NEAL controlled and utilized a place of residence located at 637 South Beaman Street, Knoxville, Tennessee, as a location to store cocaine supplied by defendant MERRELL NEAL, to cook quantities of that cocaine into cocaine base, also known as crack, to serve as a location from which to sell cocaine and cocaine base, also known as crack, to other drug dealers, and to split up money, proceeds from the sale of drugs, among the members of the conspiracy; c. Defendant MICHAEL NEAL maintained firearms at a place of residence located at 637 South Beaman Street, Knoxville, Tennessee, to protect himself, defendant MERRELL NEAL, and others, their drugs, and the money earned from selling drugs; d. Defendant MERRELL NEAL, a Chicago member of the Gangster Disciples street gang, utilized defendant MICHAEL NEAL and a place of residence located at 637 South Beaman Street, Knoxville, Tennessee, as a foothold to establish a long-term and expanded drug dealing presence in Knoxville, Tennessee, through the prospective recruitment of new gang members and drug distributors in Knoxville, Tennessee; and e. Defendants MERRELL NEAL and BRANDON SCOTT HARRIS began cultivating a relationship in anticipation of defendant BRANDON SCOTT HARRIS relocating to Page 2 Case 3:11-cr Document 14 Filed 05/24/11 Page 2 of 5 PageID #: 39

3 Knoxville, Tennessee, from Chicago, Illinois, for the purpose of selling drugs supplied by defendant MERRELL NEAL; all in violation of 21 U.S.C. 846, 841(a)(1) and 841(b)(1)(A). Count Two The Grand Jury further charges that, on or about May 21, 2011, in the Eastern District of Tennessee, defendants MERRELL NEAL, MICHAEL NEAL, and BRANDON SCOTT HARRIS, aided and abetted by one another, did knowingly, intentionally, and without authority possess with intent to distribute five-hundred (500) grams or more of a mixture and substance containing a detectable amount of cocaine, a Schedule II controlled substance, in violation of 21 U.S.C. 841(a)(1) and 841(b)(1)(B), and 18 U.S.C. 2. Count Three The Grand Jury further charges that, on or about May 21, 2011, in the Eastern District of Tennessee, defendant MICHAEL NEAL did knowingly, intentionally, and without authority possess with intent to distribute twenty-eight (28) grams or more of a mixture and substance containing a detectable amount of cocaine base, also known as crack, a Schedule II controlled substance, in violation of 21 U.S.C. 841(a)(1) and 841(b)(1)(B). Count Four The Grand Jury further charges that, from on or about April 1, 2011, through on or about May 21, 2011, within the Eastern District of Tennessee, defendant MICHAEL NEAL did Page 3 Case 3:11-cr Document 14 Filed 05/24/11 Page 3 of 5 PageID #: 40

4 knowingly, intentionally and without authority maintain a place of residence at 637 South Beaman Street, Knoxville, Tennessee, for the purpose of distributing a quantity of a mixture and substance containing a detectable amount of cocaine and cocaine base, also known as crack, Schedule II controlled substances, all in violation of 21 U.S.C. 856(a)(1). Count Five Tennessee, defendant MICHAEL NEAL did knowingly possess a firearm in furtherance of a drug trafficking crime for which he may be prosecuted in a court of the United States, specifically, Counts One, Two, Three, and Four of this Indictment, the descriptions of which are hereby incorporated by reference as though fully set forth herein, all in violation of 18 U.S.C. 924(c). Count Six Tennessee, defendants MERRELL NEAL and BRANDON SCOTT HARRIS did knowingly possess a firearm in furtherance of a drug trafficking crime for which they may be prosecuted in a court of the United States, specifically, Counts One and Two of this Indictment, the descriptions of which are hereby incorporated by reference as though fully set forth herein, all in violation of 18 U.S.C. 924(c). Page 4 Case 3:11-cr Document 14 Filed 05/24/11 Page 4 of 5 PageID #: 41

5 Count Seven Tennessee, defendant MICHAEL NEAL, having previously been convicted in court of a crime punishable by a term of imprisonment exceeding one year, did knowingly possess, in and affecting commerce, firearms, namely, an Iberia, model.40 S&W,.40 caliber semi-automatic pistol, and a Smith & Wesson.38 caliber revolver, and ammunition, all in violation of 18 U.S.C. 922(g)(1). A TRUE BILL: s/ Foreperson FOREPERSON WILLIAM C. KILLIAN UNITED STATES ATTORNEY s/ Tracy L. Stone Tracy L. Stone Assistant United States Attorney Page 5 Case 3:11-cr Document 14 Filed 05/24/11 Page 5 of 5 PageID #: 42