Case 1:16-cr-00137-LJV-MJR Document 7 Filed 11/03/16 Page 1 of 5

IN THE DISTRICT COURT OF THE UNITED STATES

for the Western District of New York

____________________

MAY 2015 GRAND JURY

(Impaneled 05/08/2015)

THE UNITED STATES OF AMERICA INDICTMENT

-vs-
Violations:
Title 18, United States Code,
RUDOLPH DWIGHT HANCHARD Section 201(b)(1);
a/k/a Fines Title 21, United States Code,
Sections 841(a)(1) and 846
(6 Counts and Forfeiture Allegation)

COUNT 1

(Conspiracy to Distribute Marijuana)

The Grand Jury Charges That:

Beginning in or before April 2014, the exact date being unknown to the Grand Jury,

and continuing until on or about September 30, 2016, in the Western District of New York,

and elsewhere, the defendant, RUDOLPH DWIGHT HANCHARD a/k/a Fines, did

knowingly, willfully, and unlawfully combine, conspire, and agree with others, known and

unknown to the Grand Jury, to commit the following offenses, that is, to possess with intent

to distribute, and to distribute, a quantity of marijuana, a Schedule I controlled substance, in

violation of Title 21, United States Code, Sections 84l(a)(l) and 841(b)(1)(D).

All in violation of Title 21, United States Code, Section 846.

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COUNT 2

(Possession with Intent to Distribute Marijuana)

The Grand Jury Further Charges That:

On or about August 13, 2014, in the Western District of New York, the defendant,

RUDOLPH DWIGHT HANCHARD a/k/a Fines, did knowingly, intentionally, and

unlawfully possess with the intent to distribute a quantity of marijuana, a Schedule I

controlled substance.

All in violation of Title 21, United States Code, Sections 841(a)(1) and

841(b)(1)(D).

COUNT 3

(Bribery of Public Official)

The Grand Jury Further Charges That:

Beginning in or before August 2015, the exact date being unknown to the Grand Jury,

and continuing until on or about October 15, 2015, in the Western District of New York, the

defendant, RUDOLPH DWIGHT HANCHARD a/k/a Fines, did, directly and indirectly,

corruptly give, offer, and promise a thing of value to a public official, that is, Briana Fugate,

a mail carrier of the United States Postal Service, with intent to influence an official act and

to induce said public official to do an act and omit to do an act in violation of the public

officials official duty, that is, by offering and making payments of United States currency to

the public official in exchange for the public official to:

a. deliver mail packages to the defendant at locations other than the locations to

which the packages were addressed; and

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b. open packages that had been entrusted to the public official for delivery, and to

deliver to the defendant marijuana found in such packages by the public official.

All in violation of Title 18, United States Code, Section 201(b)(1).

COUNT 4

(Possession with Intent to Distribute Marijuana)

The Grand Jury Further Charges That:

On or about September 10, 2015, in the Western District of New York, the defendant,

RUDOLPH DWIGHT HANCHARD a/k/a Fines, did knowingly, intentionally, and

unlawfully possess with the intent to distribute a quantity of marijuana, a Schedule I

controlled substance.

All in violation of Title 21, United States Code, Sections 841(a)(1) and

841(b)(1)(D).

COUNT 5

(Possession with Intent to Distribute, and Distribution of, Marijuana)

The Grand Jury Further Charges That:

On or about August 25, 2016, in the Western District of New York, the defendant,

RUDOLPH DWIGHT HANCHARD a/k/a Fines, did knowingly, intentionally, and

unlawfully possess with the intent to distribute, and distribute, a quantity of marijuana, a

Schedule I controlled substance.

All in violation of Title 21, United States Code, Sections 841(a)(1) and

841(b)(1)(D).

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COUNT 6

(Attempt to Possess with Intent to Distribute Marijuana)

The Grand Jury Further Charges That:

On or about September 30, 2016, in the Western District of New York, the defendant,

RUDOLPH DWIGHT HANCHARD a/k/a Fines, did knowingly, intentionally, and

unlawfully attempt to possess with the intent to distribute a quantity of marijuana, a Schedule

I controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and

841(b)(1)(D).

All in violation of Title 21, United States Code, Section 846.

FORFEITURE ALLEGATION

The Grand Jury Alleges That:

Upon conviction of any offense alleged in Counts 1, 2, 4, 5, and 6 of the Indictment,

the defendant, RUDOLPH DWIGHT HANCHARD a/k/a Fines, shall forfeit to the United

States of America all of his interest in any and all property, real or personal, constituting or

derived from any proceeds that he obtained, directly or indirectly, as the result of such

violation, including, but not limited to, the following property:

a. The sum of nine thousand nine hundred and sixty dollars ($9,960) in
United States currency seized by federal law enforcement officers from
the defendant on September 30, 2016.

All pursuant to Title 21, United States Code, Sections 853(a)(1) and 853(a)(2).

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DATED: Buffalo, New York, November 3, 2016.

JAMES P. KENNEDY, JR.

Acting United States Attorney

BY: S/WEI XIANG

Assistant United States Attorney
United States Attorneys Office
Western District of New York
138 Delaware Avenue
Buffalo, New York 14202
716/843-5806
Wei.Xiang@usdoj.gov

A TRUE BILL:

S/FOREPERSON