148.

Sample Indictment—Conspiracy and Aid and Abet—18 U.S.C. § § 241, 924(c), 2

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION UNITED STATES of AMERICA, v. SEAN CHRISTIAN TARRANT JON LANCE JORDAN MICHAEL LEWIS LAWRENCE CHRISTOPHER BARRY GREER DANIEL ALVIS WOOD ____________________________ INDICTMENT THE GRAND JURY CHARGES THAT: The Confederate Hammerskins was at all times referred to in this indictment a "Skinhead" group located in Dallas, Texas, which advocated white supremacy and separation of Black, Hispanic, Jewish and other minority persons from white persons. The defendants SEAN CHRISTIAN TARRANT, JON LANCE JORDAN, MICHAEL LEWIS LAWRENCE, CHRISTOPHER BARRY GREER, and DANIEL ALVIS WOOD were associated with the Confederate Hammerskins at all times in which they are referred to in this indictment. Robert E. Lee Park was at all times referred to in this indictment a public park administered by the City of Dallas. Temple Shalom was at all times referred to in this indictment a congregation of Jewish persons who worshipped in Dallas, Texas. The Jewish Community Center of Dallas was at all times referred to in this indictment a corporation, whose members were both Jewish and non-Jewish, which provided facilities and programs for its members in Dallas, Texas. COUNT ONE Beginning in or about June, 1988, and continuing until in or about October, 1988, in and near Robert E. Lee Park, a public park in Dallas in the Northern District of Texas, defendants SEAN CHRISTIAN TARRANT, JON LANCE JORDAN, MICHAEL LEWIS LAWRENCE, CHRISTOPHER BARRY GREER, and DANIEL ALVIS WOOD did willfully conspire and agree with each other and other persons, known and unknown to the grand jury, to injure, oppress, threaten and intimidate Black and Hispanic citizens of the United States in the free exercise and enjoyment of the right secured to them by the Constitution and laws of the United States to the full and equal enjoyment of the services, facilities, privileges, advantages and accommodations of any place of public accommodation without discrimination on the ground of race, color or national origin. It was part of the plan and purpose of this conspiracy that the defendants would join with others in Robert E. Lee Park to chase, assault and beat Black and Hispanic persons in order to prevent them from enjoying the use of Robert E. Lee Park, which was a symbol to the defendants of white supremacy. OVERT ACTS In furtherance of the conspiracy and to accomplish its objective the conspirators committed the following overt acts, among others, in the Northern District of Texas: Sometime between June and August, 1988, at 817 Nash Street in Garland, Texas, SEAN CHRISTIAN TARRANT and CHRISTOPHER BARRY GREER expressed to co-conspirators, who were associated with the Confederate Hammerskins, their concern and dissatisfaction about the presence of Black persons in Robert E. Lee Park. On several occasions sometime between June and August, 1988, SEAN CHRISTIAN TARRANT, CHRISTOPHER BARRY GREER and JON LANCE JORDAN, along with other co-conspirators from the Confederate Hammerskins, patrolled Robert E. Lee Park in the late evening hours intent upon chasing Black and other minority persons out of the park and did in fact chase Black and other minority persons out of the park. On one occasion in the late evening hours during July or August, 1988, SEAN CHRISTIAN TARRANT, CHRISTOPHER BARRY GREER and JON LANCE JORDAN and numerous Confederate Hammerskins co-conspirators patrolled the park and intimidated several Hispanic persons into leaving the park and also assaulted two Black men. On or about August 9, 1988, MICHAEL LEWIS LAWRENCE, SEAN CHRISTIAN TARRANT, CHRISTOPHER BARRY GREER and numerous Confederate Hammerskin co-conspirators went to Robert E. Lee Park intent upon chasing Black and other minority persons out of the park. On or about August 9, 1988, MICHAEL LEWIS LAWRENCE, SEAN CHRISTIAN TARRANT and CHRISTOPHER BARRY GREER threatened and chased Felix Sherrard, a Black man, and Fanny Wilson, a Black woman, from Robert E. Lee Park. In or about August, 1988, DANIEL ALVIS WOOD joined the Confederate Hammerskins and accompanied his co-conspirators to Robert E. Lee Park intent upon chasing Black and other minority persons from the park. In or about the fall of 1988, MICHAEL LEWIS LAWRENCE, aided by DANIEL ALVIS WOOD and other co-conspirators from the Confederate Hammerskins, beat a Black man with a baseball bat in Robert E. Lee Park. All in violation of Title 18, United States Code, Section 241. COUNT TWO Beginning in or about August, 1988, and continuing until on or about November 9, 1989, in Garland, Texas, within the Northern District of Texas, defendants SEAN CHRISTIAN TARRANT, JON LANCE JORDAN, MICHAEL LEWIS LAWRENCE, CHRISTOPHER BARRY GREER, and DANIEL ALVIS WOOD did willfully conspire and agree with each other and others to injure, oppress, threaten and intimidate Jewish citizens of the United States in the free exercise and enjoyment of the right secured to them by the Constitution and laws of the United States to hold real and personal property in the same manner as that right is enjoyed by all citizens. It was part of the purpose and plan of the conspiracy to vandalize Jewish properties in the Dallas area and through such intimidation and threats of force to prevent Jewish persons from enjoying the holding of such property. OVERT ACTS In furtherance of the conspiracy and to accomplish its objectives the conspirators did commit the following overt acts, among others, within the Northern District of Texas: During the month of August, 1988, SEAN CHRISTIAN TARRANT, JON LANCE JORDAN and DANIEL ALVIS WOOD and a juvenile co-conspirator vandalized the property of the Temple Shalom located at 6930 Alpha Road in Dallas, Texas. On or about October 9, 1988, DANIEL ALVIS WOOD, JON LANCE JORDAN and MICHAEL LEWIS LAWRENCE vandalized the property of the Temple Shalom located at 6930 Alpha Road in Dallas, Texas, and the property of the Jewish Community Center located at 7900 Northaven Road in Dallas, Texas. On or about November 9, 1988, DANIEL ALVIS WOOD, JON LANCE JORDAN, MICHAEL LEWIS LAWRENCE, and CHRISTOPHER BARRY GREER met at 817 Nash Street in Garland, Texas and agreed with each other and other co-conspirators from the Confederate Hammerskins to vandalize Jewish businesses to commemorate the anniversary of Kristallnacht, a night when Jewish property was destroyed in Nazi Germany. On or about November 9, 1988, DANIEL ALVIS WOOD and JON LANCE JORDAN drove away from 817 Nash Street in Garland, Texas, in a truck carrying baseball bats, ball bearings, concrete blocks and spray paint with the intent to use them to vandalize Jewish businesses, but they were intercepted by police officers. All in violation of Title 18, United States Code, Section 241. COUNT THREE On or about October 9, 1988, in Dallas, Texas, within the Northern District of Texas, the defendants DANIEL ALVIS WOOD, MICHAEL LEWIS LAWRENCE and JON LANCE JORDAN, aiding and abetting each other, did willfully use a firearm during and in relation to a crime of violence prosecutable in a court of the United States, that is, conspiracy against rights of citizens in violation of Title 18, United States Code, Section 241 as charged in Count Two of this Indictment. All in violation of Title 18, United States Code, Section 924(c) and 2. A TRUE BILL ______________________________ ____________________________ Marvin Collins FOREPERSON United States Attorney ______________________________ Richard H. Stephens Assistant U.S. Attorney ______________________________ Barry F. Kowalski Attorney, Criminal Section U.S. Department of Justice Washington, D.C. 20530 [cited in Civil Rights Resource Manual 60]