Case 1:22-cr-00245-CBA *SEALED* Document 1 Filed 05/26/22 Page 1 of 9 PageID #: 1

FJN:ADW
F. #2020R00682


 



UNITED STATES DISTRICT COURT

12:10 pm, May 26, 2022

EASTERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA INDICTMENT

- against - 1:22-cr-00245(CBA)(CLP)
Cr. No. - -- - - - - --
(T. 21, U.S.C., §§ 841(a)(l),
EDISON HERNANDEZ, 841 (b )(1 )(B)(viii), 841 (b )(1 )(C),
also known as "dragoncove," 841 (b )( 1)(E), 841 (h)(l )(A),
"originaldragoncove," 841(h)(l)(B), 846, 853(a) and 853(p);
"theoriginaldragoncove" and T. 18, U.S.C., §§ 2 and 3551 et~-)
"Nino,"
MICHAEL CARUSO and
RAYMER YNOA,

Defendants.

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THE GRAND JURY CHARGES:

INTRODUCTION

At all times relevant to this Indictment, unless otherwise indicated:

1. Individuals established online marketplaces for narcotics and other illegal

items. These marketplaces commonly existed on the dark web, a part of the internet located

beyond the reach of traditional internet browsers and accessible only through the use of networks

designed to conceal user identities.

2. Silk Road, AlphaBay, Dream Market and Wall Street Market were large

global dark web marketplaces. All of these marketplaces functioned like conventional e-

commerce websites but were geared towards the trafficking of contraband. Vendors advertised

the sale of illegal narcotics and other contraband, among other things. Buyers purchased the

illegal narcotics and contraband and paid for the purchased goods using digital currency.
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Vendors then shipped the goods through the United States mail and other means of delivery.

These dark web marketplaces required their users to trade in digital currencies, primarily Bitcoin,

and did not allow for transactions in official, government-backed fiat currency.

3. Vendors and buyers on Silk Road, AlphaBay, Dream Market and Wall

Street Market operated under anonymous monikers. However, vendors received ratings from

buyers based on, among other things, the quality of the contraband, reliability of delivery and

volume of traffic. In addition, vendors received rankings from the marketplace administrators

based on user input.

4. Vendors on dark web marketplaces encrypted their communications with

buyers through a methodology known as PGP encryption. Secure communication using PGP

encryption required the use of what is known as a "public key," which is a string of

alphanumeric characters that enabled a user to receive encrypted messages from others. Public

keys were included in dark web listings for illegal narcotics and contraband and were associated

with specific anonymous monikers.

HERNANDEZ' S SALE OF NARCOTICS OVER THE DARK WEB

5. From at least in or about and between January 2013 to September 2013 ,

the defendant EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

"theoriginaldragoncove" and "Nino," operated as a vendor of illegal narcotics on Silk Road

under the username "dragoncove." Using Silk Road, HERNANDEZ advertised and sold heroin

and cocaine to customers in the United States.

6. From at least in or about and between September 2016 to June 2017, the

defendant EDISON HERNANDEZ operated as a vendor of illegal narcotics on AlphaBay under

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the username "theoriginaldragoncove." Using AlphaBay, HERNANDEZ advertised and sold

heroin and cocaine to customers in the United States.

7. From at least in or about and between January 2019 to February 2019, the

defendant EDISON HERNANDEZ operated as a vendor of illegal narcotics on Dream Market

under the username "originaldragoncove." Using Dream Market, HERNANDEZ advertised and

sold heroin and cocaine to customers in the United States.

8. In or about April 2019, the defendant EDISON HERNANDEZ operated as

a vendor of illegal narcotics on Wall Street Market under the username "dragoncove." Using

Wall Street Market, HERNANDEZ advertised and sold heroin and cocaine to customers in the

United States.

9. The defendant EDISON HERNANDEZ employed the same unique PGP

public key to operate the "dragoncove" account on Silk Road, the "theoriginaldragoncove"

account on AlphaBay, the "originaldragoncove" account on Dream Market and the "dragoncove"

account on Wall Street Market.

10. The defendant EDISON HERNANDEZ directed customers on Silk Road,

AlphaBay, Dream Market and Wall Street Market to pay him in Bitcoin.

11. The defendant EDISON HERNANDEZ completed more than one

thousand transactions on Silk Road, AlphaBay, Dream Market and Wall Street Market and

regularly received high ratings and positive reviews from buyers.

THE DEFENDANTS ' OPERATION OF A DOOR-TO-DOOR DRUG DELIVERY SERVICE

12. In or about and between February 2019 and January 2022, the defendants

EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

"theoriginaldragoncove" and "Nino," MICHAEL CARUSO and RAYMER YNOA operated a

Case 1:22-cr-00245-CBA *SEALED* Document 1 Filed 05/26/22 Page 4 of 9 PageID #: 4

door-to-door drug delivery service in the New York City area. The defendants communicated

with customers via an encrypted communication platform and called their service "Nino &

Viktor's Pastry Shoppe." Together, the defendants sold and distributed cocaine,

methamphetamine, ketamine and 3,4-Methylenedioxymethamphetamine, also known as MDMA

or Ecstasy, to others through the delivery service.

13. Customers placed orders with "Nino & Viktor' s Pastry Shoppe" by

exchanging written messages with a particular phone number over an encrypted communication

platform. The delivery service's order number was controlled by the defendant EDISON

HERNANDEZ, who used the name "Nino." The delivery service had a set menu of available

drugs, and customers ordered particular drugs by using the code names assigned to them on the

business 's menu. For example, the defendants referred to cocaine as "grapes" and to

methamphetamine as "tic tacs."

14. In addition, customers ordered drugs not by weight, but by " unit," with

each unit costing $100, regardless of the drug. Hence, a customer who ordered "two grapes"

and "two tic tacs" would pay a total of $400 for two " units" of cocaine and two " units" of

methamphetamine.

15 . After receiving orders for a particular day, either of the defendants

MICHAEL CARUSO and RAYMER YNOA, or both, would drive a vehicle to and within

Brooklyn, New York and New York, New York, to make door-to-door deliveries to narcotics

customers at addresses provided by the customers.

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COUNT ONE
(Distribution and Possession with Intent to Distribute Heroin and Cocaine)

16. The allegations contained in paragraphs one through 11 are realleged and

incorporated as if fully set forth in this paragraph.

17. In or about and between May 2017 and April 2019, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant

EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

"theoriginaldragoncove" and "Nino," together with others, did knowingly and intentionally

distribute and possess with intent to distribute one or more controlled substances, which offense

involved (a) a substance containing heroin, a Schedule I controlled substance; and (b) a

substance containing cocaine, a Schedule II controlled substance, contrary to Title 21 , United

States Code, Section 841(a)(l).

(Title 21 , United States Code, Sections 841(a)(l) and 84l(b)(l)(C); Title 18,

United States Code, Sections 2 and 3551 et~-)

COUNT TWO
(Delivery and Distribution of Heroin and Cocaine by Means of the Internet)

18. The allegations contained in paragraphs one through 11 are realleged and

incorporated as if fully set forth in this paragraph.

19. In or about and between May 2017 and April 2019, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the defendant

EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

"theoriginaldragoncove" and "Nino," together with others, did knowingly and intentionally

deliver and distribute one or more controlled substances by means of the Internet, and did aid

and abet such activity, in such a manner not authorized by Subchapter I of Chapter 13 of Title
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21, United States Code, which offense involved (a) a substance containing heroin, a Schedule I

controlled substance; and (b) a substance containing cocaine, a Schedule II controlled substance,

contrary to Title 21, United States Code, Section 84l(h)(l)(A).

(Title 21, United States Code, Sections 841(h)(l)(A), 841(h)(l)(B) and

841(b)(l)(C); Title 18, United States Code, Sections 2 and 3551 et_llil.)

COUNT THREE
(Conspiracy to Distribute and Possess with Intent to Distribute
Cocaine, Methamphetamine, Ketamine and MOMA)

20. The allegations contained in paragraphs 12 through 15 are realleged and

incorporated as if fully set forth in this paragraph.

21. In or about and between February 2019 and January 2022, both dates

being approximate and inclusive, within the Eastern District of New York and elsewhere,

the defendants EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

"theoriginaldragoncove" and "Nino," MICHAEL CARUSO and RAYMER YNOA, together

with others, did knowingly and intentionally conspire to distribute and possess with intent to

distribute one or more controlled substances, which offense involved (a) a substance containing

cocaine, a Schedule II controlled substance; (b) a substance containing methamphetamine, a

Schedule II controlled substance; (c) a substance containing ketamine, a Schedule III controlled

substance; and (d) a substance containing 3,4-Methylenedioxymethamphetamine, also known as

MDMA or Ecstasy, a Schedule I controlled substance. The amount of methamphetamine

involved in the conspiracy attributable to the defendants as a result of their own conduct, and the
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conduct of other conspirators reasonably foreseeable to them , was five grams or more of

methamphetamine, its salts, isomers and salts of its isomers.

(Title 21 , United States Code, Sections 846, 841(b)(l)(B)(viii), 84l(b)(l)(C) and

84l(b)(l)(E); Title 18, United States Code, Sections 3551 et~.)

CRIMINAL FORFEITURE ALLEGATION

22. The United States hereby gives notice to the defendants that, upon their

conviction of any of the offenses charged herein, the government will seek forfeiture in

accordance with Title 21, United States Code, Section 853(a), which requires any person

convicted of such offenses to forfeit: (a) any property constituting, or derived from , any proceeds

obtained directly or indirectly as a result of such offenses, and (b) any property used, or intended

to be used, in any manner or part, to commit, or to facilitate the commission of, such offenses,

including but not limited to approximately one hundred four thousand four hundred fifty-four

dollars and zero cents ($104,454.00) in United States currency seized on or about July 31 , 2020,

from a property located on Cooper Street in Brooklyn, New York.

23 . If any of the above-described forfeitable property, as a result of any act or

omission of the defendants:

(a) cannot be located upon the exercise of due diligence;

(b) has been transferred or sold to, or deposited with, a third party;

(c) has been placed beyond the jurisdiction of the court;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty;

it is the intent of the United States, pursuant to Title 21 , United States Code, Section 853(p), to
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seek forfeiture of any other property of the defendants up to the value of the forfeitable property

described in this forfeiture allegation.

(Title 21 , United States Code, Sections 853(a) and 853(p))

A TRUE BILL

EON PEACE
ITED STA TES ATTORNEY
EASTERN DISTRICT OF NEW YORK
Case 1:22-cr-00245-CBA *SEALED* Document 1 Filed 05/26/22 Page 9 of 9 PageID #: 9

F.#: 2020R00682
FORMDBD-34 No.
JUN. 85
UNITED STATES DISTRICT COURT

EASTERN District ofNEW YORK

CRIMINAL DIVISION
THE UNITED STATES OF AMERICA

vs.

EDISON HERNANDEZ, also known as "dragoncove," "originaldragoncove,"

and "theoriginaldragoncove," MICHAEL CARUSO and RAYMER YNOA,

Defendants.
INDICTMENT

(T. 21, U.S.C., §§ 841(a)(l), 84l(b)(l)(B)(viii), 84l(b)(l)(C), 841(b)(l)(E),

841 (h)(l )(A), 841 (h)(l)(B), 846, 853(a) and 853(p ); T. 18, U.S.C., §§ 2 and 3551
~~-)

A true bill.
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Foreperson

Filed in open court this ___ ______________ day,

of ____________ A.D. 20 ____ _

Clerk

Bail, $ __________ _

Andrew D. Wang, Assistant U.S. Attorney (718) 254-6311