UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

UNITED STATES OF AMERICA,

Plaintiff,

v.

1. KENIKO DUANE BLAND,
2. J ACQUELYN GINA BURNES,
3. ANGELA CARTER,
4. DIONTRE RAMONE HILL, and
5. RAHEEM ABDUL LEE WATKINS,

Defendants.
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INDICTMENT

18 U.S.C. 371
18 U.S.C. 922(a)(6)
18 U.S.C. 922(d)(1)
18 U.S.C. 922(g)(1)
18 U.S.C. 922(n)
18 U.S.C. 924(a)(1)(A)
18 U.S.C. 924(a)(1)(D)
18 U.S.C. 924(a)(2)


THE UNITED STATES GRAND J URY CHARGES:
COUNT 1
(Conspiracy)

1. From at least on or about December 30, 2013, and continuing up to and
including the date of this Indictment, in the State and District of Minnesota, the
defendants,
KENIKO DUANE BLAND,
JACQUELYN GINA BURNES,
ANGELA CARTER,
DIONTRE RAMONE HILL, and
RAHEEM ABDUL WATKINS,

did knowingly conspire, combine, confederate and agree with each other and with other
persons known and unknown to the Grand J ury to:
(A) make false statements with regard to the acquisitions of firearms from licensed
dealers, in violation of Title 18, United States Code, Section 922(a)(6);
(B) transfer and dispose of firearms to persons they knew and had reasonable cause to
know were under indictment for and had been convicted of a crime punishable by
imprisonment for a term exceeding one year, in violation of Title 18, United States
Code, Section 922(d)(1);
(C) possess firearms which had traveled in and affected interstate and foreign
commerce after having been convicted of a crime punishable by imprisonment for
a term exceeding one year, in violation of Title 18, United States Code, Section
922(g)(1); and
(D) receive firearms which had traveled in and affected interstate and foreign
commerce while being under indictment for a crime punishable by imprisonment
for a term exceeding one year, in violation of Title 18, United States Code, Section
922(n).
PURPOSE OF THE CONSPIRACY
2. It was the purpose of the conspiracy for defendants to obtain firearms and
ammunition for members of the conspiracy who were prohibited by the laws of the
United States from possessing and receiving firearms which had traveled in or affected
interstate or foreign commerce.
MANNER AND MEANS
3. As part of the conspiracy:
a. Defendants BURNES and CARTER would purchase firearms,
ammunition, and accessories from a federal firearms licensee and execute paperwork
falsely representing that they were the actual buyer of the firearms;
b. Defendants BURNES and CARTER would then provide the firearms,
ammunition, and accessories to other members of the conspiracy, including defendants
BLAND and HILL;
c. Defendants would at times obtain firearms from other persons to be
provided to other members of the conspiracy; and
d. Defendants BURNES, CARTER, HILL, and BLAND would share
firearms with others, including defendant WATKINS, who was also prohibited by law
from possessing firearms or ammunition.
OVERT ACTS
4. In furtherance of the conspiracy and to effect the objects of the conspiracy,
the following overt acts, among others, were committed in the District of Minnesota:
a. On or about J anuary 21, 2014, defendant CARTER bought a Ruger 9mm
semi-automatic pistol from Bills Gun Shop & Range, a federal firearms licensee
(hereinafter FFL), and provided a false address on required paperwork.
b. On or about J anuary 21, 2014, defendant BURNES bought a box of
ammunition at Bills Gun Shop & Range.
c. On or about J anuary 25, 2014, defendant BURNES bought a Ruger .380
caliber semi-automatic pistol from Bills Gun Shop & Range and represented that she
was the actual buyer of the firearm, when in fact she acquired the firearm on behalf of
another person.
d. On or about February 3, 2014, defendant BURNES bought a Glock 9mm
semi-automatic pistol and a matching 33 round magazine from Bills Gun Shop & Range.
When purchasing the firearm, defendant BURNES represented that she was the actual
buyer of the firearm, when in fact she acquired the firearm on behalf of another person.
e. On or about February 7, 2014, defendant BLAND telephoned Bills Gun
Shop & Range at approximately 3:42 p.m. A little over an hour later, at approximately
4:58 p.m., defendant CARTER bought a Glock .40 caliber semi-automatic pistol, a
matching 15 round magazine, and two boxes of .40 caliber ammunition from Bills Gun
Shop & Range. CARTER again provided a false address on required paperwork.
f. On or about February 11, 2014, defendants BLAND, CARTER, and HILL
jointly possessed the following firearms: the Glock .40 caliber semi-automatic pistol
defendant CARTER purchased on February 7, 2014, the Ruger 9mm semi-automatic
pistol defendant CARTER purchased on J anuary 21, 2014, and the Glock 9mm semi-
automatic pistol with extended magazine that BURNES purchased on February 3, 2014.
g. Between February 12, 2014, and February 19, 2014, defendants BLAND,
BURNES, CARTER, and HILL developed a story to (1) explain the presence of the
three guns in defendant CARTERs car on February 11, 2014, and (2) exonerate
defendants BLAND and HILL, who were both prohibited at the time from possessing
firearms.
h. On several occasions between February 12, 2014, and February 19, 2014,
defendants BLAND, BURNES, CARTER, HILL, and WATKINS discussed the
obtaining new firearms to replace the firearms that were seized on February 11, 2014.
i. On February 18, 2014, defendant BURNES, at the direction of defendant
HILL, drove defendant BLAND to a location to obtain a firearm.
j. On February 24, 2014, defendant BURNES bought a Glock .40 caliber
semi-automatic pistol from Bills Gun Shop & Range and represented that she was the
actual buyer of the firearm, when in fact she acquired the firearm on behalf of another
person.
k. On February 27, 2014, defendant BURNES made false statements to a
federal law enforcement agent from the Bureau of Alcohol, Tobacco, Firearms &
Explosives (ATF) stating that the guns she had purchased from Bills Gun Shop &
Range on J anuary 25, 2014, and on February 3, 2014, were stolen.
l. On February 27, 2014, defendant BURNES, after speaking with the ATF
agent, called her local police department and falsely reported that the Ruger .380 semi-
automatic pistol she had purchased on J anuary 25, 2014, had been stolen three weeks
earlier.
m. On March 3, 2014, defendant BURNES made false statements to an ATF
agent stating that the guns she had purchased from Bills Gun Shop & Range on J anuary
25, 2014, and on February 3, 2014, were stolen.
n. On or about April 18, 2014, defendant WATKINS possessed two firearms.
5. All in violation of Title 18, United States Code, Section 371.

COUNT 2
(Causing False Statement To Be Maintained in Records Of A Federal Firearms Licensee)

6. On or about J anuary 21, 2014, in the State and District of Minnesota, the
defendant,
ANGELA YVONNE CARTER,
in connection with the acquisition of a firearm, specifically a Ruger 9mm semi-automatic
pistol bearing serial number 318-79390, knowingly made a false statement and
representation with respect to information required by the provisions of Chapter 44 of
Title 18, United States Code, to be kept in the records of Bills Gun Shop & Range, a
federal firearms licensee licensed under the provisions of Chapter 44 of Title 18, United
States Code, in that defendant executed a Bureau of Alcohol, Tobacco, Firearms, and
Explosives Form 4473, Firearms Transaction Record, representing that her current
residence address was a particular address on Fremont Avenue, Minneapolis, Minnesota,
whereas in truth and in fact, as defendant well knew, she no longer lived at the Fremont
Avenue address; all in violation of Title 18 United States Code, Section 924(a)(1)(A).
COUNT 3
(False Statement During Purchase Of A Firearm)

7. On or about J anuary 25, 2014, in the State and District of Minnesota, the
defendant,
JACQUELYN GINA BURNES,
in connection with the acquisition of a firearm, specifically a Ruger .380 caliber semi-
automatic pistol bearing serial number 323-90932, from Bills Gun Shop & Range, a
licensed dealer of firearms within the meaning of Chapter 44, Title 18, United States
Code, knowingly made a false and fictitious written statement to Bills Gun Shop &
Range, which statement was intended and likely to deceive Bills Gun Shop & Range as
to a fact material to the lawfulness of such sale of the said firearm to the defendant under
Chapter 44 of Title 18, in that the defendant represented that she was the actual buyer of
the firearm, when in fact she acquired the firearm on behalf of another person; all in
violation of Title 18, United States Code, Sections 922(a)(6) and 924(a)(2).

COUNT 4
(False Statement During Purchase Of A Firearm)

8. On or about February 3, 2014, in the State and District of Minnesota, the
defendant,
JACQUELYN GINA BURNES,
in connection with the acquisition of a firearm, specifically a Glock 9mm semi-automatic
pistol bearing serial number WGN926, from Bills Gun Shop & Range, a licensed dealer
of firearms within the meaning of Chapter 44, Title 18, United States Code, knowingly
made a false and fictitious written statement to Bills Gun Shop & Range, which
statement was intended and likely to deceive Bills Gun Shop & Range as to a fact
material to the lawfulness of such sale of the said firearm to the defendant under Chapter
44 of Title 18, in that the defendant represented that she was the actual buyer of the
firearm, when in fact she acquired the firearm on behalf of another person; all in violation
of Title 18, United States Code, Sections 922(a)(6) and 924(a)(2).

COUNT 5
(Causing False Statement To Be Maintained in Records Of A Federal Firearms Licensee)

9. On or about February 7, 2014, in the State and District of Minnesota, the
defendant,
ANGELA YVONNE CARTER,
in connection with the acquisition of a firearm, specifically a Glock .40 caliber semi-
automatic pistol bearing serial number WEW094, knowingly made a false statement and
representation with respect to information required by the provisions of Chapter 44 of
Title 18, United States Code, to be kept in the records of Bills Gun Shop & Range, a
federal firearms licensee licensed under the provisions of Chapter 44 of Title 18, United
States Code, in that defendant executed a Bureau of Alcohol, Tobacco, Firearms, and
Explosives Form 4473, Firearms Transaction Record, representing that her current
residence address was a particular address on Fremont Avenue, Minneapolis, Minnesota,
whereas in truth and in fact, as defendant well knew, she no longer lived at the Freemont
Avenue address; all in violation of Title 18, United States Code, Section 924(a)(1)(A).
COUNT 6
(Felon in Possession of a Firearm)

10. On or about February 11, 2014, in the State and District of Minnesota, the
defendant,

DIONTRE RAMONE HILL,

having previously been convicted of a crime punishable by imprisonment for a term
exceeding one year, namely:
Crime Place of
Conviction
Date Committed
(on or about)
Date Sentenced (on or
about)
Aggravated First Degree
Robbery
Hennepin
County, MN
March 23, 2011 March 6, 2012

knowingly possessed, in and affecting interstate and foreign commerce, the following
firearms:
Manufacturer of Firearm Type of Firearm Serial Number of Firearm

Glock

9mm semi-automatic pistol

WGN926

Ruger

9mm semi-automatic pistol

318-79390

Glock

.40 caliber semi-automatic
pistol

WEW094

all in violation of Title 18, United States Code, Sections 922(g)(1), and 924(a)(2).
COUNT 7
(Illegal Receipt Of A Firearm By a Person Under Indictment)

11. On or about February 11, 2014, in the State and District of Minnesota, the
defendant,

KENIKO DUANE BLAND,

who was then under Indictment for a crime punishable by imprisonment for a term
exceeding one year, namely:
Crime Place of Indictment Date of Indictment
(on or about)
Terroristic Threats Hennepin County, MN November 27, 2013

did willfully receive a firearm, that is the following firearms:

Manufacturer of Firearm Type of Firearm Serial Number of Firearm

Glock

9mm semi-automatic pistol

WGN926

Ruger

9mm semi-automatic pistol

318-79390

Glock

.40 caliber semi-automatic
pistol

WEW094

said firearms having been shipped and transported in interstate and foreign commerce; all
in violation of Title 18, United States Code, Sections 922(n) and 924(a)(1)(D).
COUNT 8
(False Statement During Purchase Of A Firearm)

12. On or about February 24, 2014, in the State and District of Minnesota, the
defendant,
JACQUELYN GINA BURNES,
in connection with the acquisition of a firearm, specifically a Glock, .40 caliber semi-
automatic pistol bearing serial number TFA445, from Bills Gun Shop & Range, a
licensed dealer of firearms within the meaning of Chapter 44, Title 18, United States
Code, knowingly made a false and fictitious written statement to Bills Gun Shop &
Range, which statement was intended and likely to deceive Bills Gun Shop & Range as
to a fact material to the lawfulness of such sale of the said firearm to the defendant under
Chapter 44 of Title 18, in that the defendant represented that she was the actual buyer of
the firearm, when in fact she acquired the firearm on behalf of another person; all in
violation of Title 18, United States Code, Sections 922(a)(6) and 924(a)(2).

COUNT 9
(Felon in Possession of a Firearm)

13. On or about a date unknown to the Grand J ury, but at least as early as April
4, 2014, and as late as April 18, 2014, in the State and District of Minnesota, the
defendant,

RAHEEM ABDUL LEE WATKINS,

having previously been convicted of a crime punishable by imprisonment for a term
exceeding one year, namely:
Crime Place of
Conviction
Date Committed
(on or about)
Date Sentenced (on or
about)
Aggravated First Degree
Robbery
Hennepin
County, MN
March 23, 2011 October 3, 2011

knowingly possessed, in and affecting interstate and foreign commerce, the following
firearms:
Manufacturer of Firearm Type of Firearm Serial Number of Firearm

Uunknown

9mm semi-automatic pistol

5063

Smith & Wesson

.40 caliber semi-automatic
pistol

DSE3079 (partially
obliterated)

all in violation of Title 18, United States Code, Sections 922(g)(1), and 924(a)(2).


FORFEITURE ALLEGATIONS
If convicted of any count of this Indictment, the defendants,
KENIKO DUANE BLAND,
JACQUELYN GINA BURNES,
ANGELA CARTER,
DIONTRE RAMONE HILL, and
RAHEEM ABDUL WATKINS,

shall forfeit to the United States any firearms, accessories, and ammunition involved in or
used in connection with each such violation including, but not limited to, the following:
Manufacturer of Firearm Type of Firearm Serial Number of Firearm

Ruger

9mm semi-automatic pistol

318-79390

Ruger .380 caliber semi-automatic
pistol
323-90932

Glock

9mm semi-automatic pistol

WGN926

Glock

.40 caliber semi-automatic
pistol

WEW094
Glock .40 caliber semi-automatic
pistol
TFA445

Unknown

9mm pistol

5063

Smith & Wesson

.40 caliber pistol

DSE3079 (partially
obliterated)

and any associated ammunition, pursuant to Title 18, United States Code, Section
924(d)(1), and Title 28, United States Code, Section 2461(c).

A TRUE BILL

______________________________ ______________________________
UNITED STATES ATTORNEY FOREPERSON