Queensberry Indictment

CDS DISTRIBUTION NOT MARIJUANA, CONSPIRACY

Stte of Mryland,Cty of Bltmore, to wit:IN THE CIRCUIT COURT FOR BALTIMORE CITY

Date of Offense: September 2015THROUGH THE PRESENT

Location: BALTIMORE CITY

Complainant: Set. Chris TallevDet. Magsie Hall

INDICTMENTThe Jurors of the State of Maryland for the body of the City of Baltimore, do on their

oath present that the aforesaid DEFENDANT, late of said City, from September 8, 2015, throughthe present, in the City of Baltimore, State of Maryland, unlawfully did conspire with certainother persons whose names are known and unknown to the Jurors, to distribute and dispensecontrolled dangerous substances, including but not limited to Cocaine (Schedule II), in or aroundQueensberry and Oakley Avenues, Baltimore City, Maryland, in violation of the Common Lawand Criminal Law Article, Section 5-602, of the Maryland Code; against the peace, governmentand dignity of the State.

Overt Acts in Furtherance of the Conspiracv

1. On September 8, 2015, at or near the intersection of Queensberry and Oakley Avenues,Derrick HOLMES distributed cocaine to UC 1430.

2. On September 17,2015, at or near the intersection of Queensberry and Oakley Avenues,Tino HAYES distributed cocaine to UC 49.

3. On October 7,2015, in or near the 2900 block of Oakley Avenue,distributed cocaine to UC 1430.

4. On October 29,2015, in or near the 4900 block of Queensberry Avenue, Darryl HARRISand Derrick HOLMES distributed cocaine to UC 1430.

5. On November 9, 2015, in or near the 4800 block of Palmer Avenue,distributed cocaine to UC 1430.

The State of Maryland

TINO HAYES

Defendant(s):

-vs-


6. On November 9,2015, in or near the 3100 block of Oakley Avenue, Tino HAYES,Darryl HARRIS distributed cocaine, and used a juvenile to distribute cocaine, to UC 951 .

7. On November 10, 2015, in or near the 3000 block of Oakley Avenue, Darryl HARRISdistributed cocaine to UC 1430.

8. On November 10, 2015, in or near the 4800 block of Palmer Avenue, Tino HAYESpossessed with the intent to distribute cocaine.

9. On November 10, 2015, in or near the 3100 block of Oakley Avenue, Tino HAYESdistributed cocaine to UC 951.

10. On November 17,2015, at or near the intersection of Palmer and Oakley Avenues, TinoHAYES distributed cocaine to UC 1430.

[Common Law; CR 5-602;5-601] 2C0696

SECOND COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on September 17, 2015, at ornear the intersection of Queensberry and Oakley Avenues, in the City of Baltimore, State ofMaryland, did possess a controlled dangerous substance of Schedule Number II, to wit: Cocaine,in sufficient quantity reasonably to indicate under all circumstances an intent to distribute anddispense a controlled dangerous substance, in violation of Criminal Law Article, Section 5-602(2) of the Maryland Code; against the peace, government and dignity of the State.

lcR 5-602(2)13 0233

THIRD COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on September 17,2015, at ornear the intersection of Queensberry and Oakley Avenues, in the City of Baltimore, State ofMaryland, did distribute and dispense a controlled dangerous substance of Schedule Number II,to wit: Cocaine, which is a Narcotic Drug, to UC 49, in violation of Criminal Law Article,Section 5-602(1) of the Maryland Code; against the peace, government and dignity of the State.

lcR s-602(t)12 06e6

FOURTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on September 17,2015, at or

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near the intersection of Queensberry and Oakley Avenues, in the City of Baltimore, State ofMaryland, did possess a controlled dangerous substance of Schedule Number II, to wit: Cocaine,in violation of Criminal Law Article, Section 5-601(a)(1) of the Maryland Code; against thepeace, government and dignity of the State.

ICR s-60l(axl)l 4 3ss0

FIFTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on September 17,2015, at ornear the intersection of Queensberry and Oakley Avenues, in the City of Baltimore, State ofMaryland, did possess a controlled dangerous substance of Schedule II, to wit: Cocaine insufficient quantity to indicate an intent to distribute the said substance within 1000 feet of theproperty of Pimlico Elementary/Middle School.

ICR s-627(a)l 1 0484

SIXTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said,City, on September 17,2015, at ornear the intersection of Queensberry and Oakley Avenues, in the City of Baltimore, State ofMaryland, did distribute to UC 49 a controlled dangerous substance of Schedule II, to wit:Cocaine within 1000 feet of the property of Pimlico Elementary'Middle School.

CPts-627(a)l I 0483

SEVENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, along with Darryl HARRIS anda known juvenile, on November 9,2015, at or near the 3100 block of Oakley Avenue, in the Cityof Baltimore, State of Maryland, did possess a controlled dangerous substance of ScheduleNumber II, to wit: Cocaine, in sufficient quantity reasonably to indicate under all circumstancesan intent to distribute and dispense a controlled dangerous substance, in violation of CriminalLaw Article, Section 5-602(2) of the Maryland Code; against the peace, govemment and dignityof the State.

lcR s-602(2)l3 0233

EIGHTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, along with Danyl HARRIS and

J


a known juvenile, on Novemb er 9, 2015, at or near the 3 1 00 block of Oakley Avenue, in the Cityof Baltimore, State of Maryland, did distribute and dispense a controlled dangerous substance ofSchedule Number II, to wit: Cocaine, which is a Narcotic Drug, to UC 951, in violation ofCriminal Law Article, Section 5-602(1) of the Maryland Code; against the peace, governmentand dignity of the State.

lcR s-602(t)12 06e6

NINTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, along with Darryl HARRIS anda known juvenile, on November 9,2015, at or near the 3100 block of Oakley Avenue, in the Cityof Baltimore, State of Maryland, did possess a controlled dangerous substance of ScheduleNumber II, to wit: Cocaine, in violation of Criminal Law Article, Section 5-601(a)(l) of theMaryland Code; against the peace, govemment and dignity of the State.

ICR s-601(axl)l 4 3ss0

TENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, along with Danyl HARRIS, anda known juvenile on November 9,2015, at or near the 3100 block of Oakley Avenue, in the Cityof Baltimore, State of Maryland, did possess a controlled dangerous substance of Schedule II, towit: Cocaine in suffcient quantity to indicate an intent to distribute the said substance within1000 feet of the property of Pimlico Elementary/Middle School.

lCP.s-627(a)l I 0484

ELEVENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, along with Darryl HARRIS, anda known juvenile on November 9,2015, at or near the 3100 block of Oakley Avenue, in the Cityof Baltimore, State of Maryland, did distribute to UC 49 a corrolled dangerous substance ofSchedule II, to wit: Cocaine within 1000 feet of the property of Pimlico Elementary/MiddleSchool.

ICR s-627(a)l 1 0483

TWELFTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, along with Darryl HARRIS, on

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November 9,2015, at or near the 3100 block of Oakley Avenue, in the City of Baltimore, Stateof Maryland, did unlawfully engage and use D.H., a minor, on behalf of DEFENDANT andDarryl HARzuS, for the purpose of distributing and delivering a controlled dangerous substanceof Schedule Number II, to wit: Cocaine, in sufficient quantity to reasonably indicate under all thecircumstances an intent to distribute the said substance.

ICR s-628(axl)] t s40e

THIRTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November I0,2015, at ornear the 4800 block of Palmer Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule Number II, to wit: Cocaine, in sufficient quantityreasonably to indicate under all circumstances an intent to distribute and dispense a controlleddangerous substance, in violation of Criminal Law Article, Section 5-602(2) of the MarylandCode; against the peace, government and dignity of the State.

lcR s-602(2)13 0233

FOURTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 10, 2015, at ornear the 4800 block of Palmer Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule Number II, to wit: Cocaine, in violation of CriminalLaw Article, Section 5-601(a)(1) of the Maryland Code; against the peace, government anddignity of the State.

ICR 5-601(axl)] 4 3ss0

FIFTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oathpresent that the aforesaid DEFENDANT, late of said city, on November 10,2015, at or near the4800 block of Palmer Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule II, to wit: Cocaine in suffrcient quantity to indicatean intent to distribute the said substance within 1000 feet of the property of PimlicoElementary/Middle School.

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ICR s-627(a)] 1 0484


SIXTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 10, 2015, at ornear the 3 100 block of Oakley Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule Number II, to wit: Cocaine, in sufficient quantityreasonably to indicate under all circumstances an intent to distribute and dispense a controlleddangerous substance, in violation of Criminal Law Article, Section 5-602(2) of the MarylandCode; against the peace, government and dignity of the State.

[cR s-602(2)]3 0233

SEVENTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 10, 2015, at ornear the 3100 block of Oakley Avenue, in the City of Baltimore, State of Maryland, diddistribute and dispense a controlled dangerous substance of Schedule Number II, to wit: Cocaine,which is a Narcotic Drug, to UC 951, in violation of Criminal Law Article, Section 5-602(1) ofthe Maryland Code; against the peace, government and dignity of the State.

lcR s-602(t)1206e6

EIGHTEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 10,2015, at ornear the 3 100 block of Oakley Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule Number II, to wit: Cocaine, in violation of CriminalLaw Article, Section 5-601(a)(1) of the Maryland Code; against the peace, government anddignity of the State.

ICR s-601(ax1)l 4 3ss0

NINETEENTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, on November 10,2015, at or nearthe 3100 block of Oakley Avenue, in the City of Baltimore, State of Maryland, did possess acontrolled dangerous substance of Schedule II, to wit: Cocaine in sufficient quantity to indicatean intent to distribute the said substance within 1000 feet of the property of PimlicoElementary/Middle School.

6

ICR 5-627(a)] I 0484


TWENTIETH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, on November 10,2015, at or nearthe 3100 block of Oakley Avenue, in the City of Baltimore, State of Maryland, did distribute toUC 49 a controlled dangerous substance of Schedule II, to wit: Cocaine within 1000 feet of theproperty of Pimlico Elementary/Middle School.

ICR s-627(a)l 1 0483

T\ilENTY-FIRST COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 17,2015, at ornear the intersection of Palmer Avenue and Oakley Avenue, in the City of Baltimore, State ofMaryland, did possess a controlled dangerous substance of Schedule Number II, to wit: Cocaine,in suffrcient quantity reasonably to indicate under all circumstances an intent to distribute anddispense a controlled dangerous substance, in violation of Criminal Law Article, Section 5-602(2) of the Maryland Code; against the peace, govemment and dignity of the State.

lcR s-602(2)13 0233

TWENTY-SECOND COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November I7, 2015, at ornear the intersection of Palmer Avenue and Oakley Avenue, in the City of Baltimore, State ofMaryland, did distribute and dispense a controlled dangerous substance of Schedule Number II,to wit: Cocaine, which is a Narcotic Drug, to UC 1430, in violation of Criminal Law Article,Section 5-602(1) of the Maryland Code; against the peace, government and dignity of the State.

lcR s-602(r)12 06e6

TWENTY.THIRD COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said City, on November 17,2015, at ornear the intersection of Palmer Avenue and Oakley Avenue, State of Maryland, did possess acontrolled dangerous substance of Schedule Number II, to wit: Cocaine, in violation of CriminalLaw Article, Section 5-601(a)(1) of the Maryland Code; against the peace, govemment anddignity of the State.

7

ICR 5-601(axl)l 4 3ss0


T\ryENTY.FOURTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, on November 17,2015, at or nearthe intersection of Palmer Avenue and Oakley Avenue, in the City of Baltimore, State ofMaryland, did possess a controlled dangerous substance of Schedule II, to wit: Cocaine insufficient quantity to indicate an intent to distribute the said substance within 1000 feet of theproperty of Pimlico Elementary/Middle School.

ICR 5-627(a) I 0484

TWENTY.FIFTH COUNT

The Jurors of the State of Maryland for the body of the City of Baltimore, do on theiroath present that the aforesaid DEFENDANT, late of said city, on November 10,2015, at or nearthe intersection of Palmer Avenue and Oakley Avenue, in the City of Baltimore, State ofMaryland, did distribute to UC 49 a controlled dangerous substance of Schedule II, to wit:Cocaine within 1000 feet of the property of Pimlico Elementary/Middle School.

ICP.s-627(a)] 1 0483

Brian E. FroshMaryland Attorney General

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Queensberry Indictment

Documents

Transcript of Queensberry Indictment