U.S. Department of Justice United States Attorney District of Maryland Robert R. Harding Suite 400 DIRECT: 410-209-4845 Chief of Narcotics 36 S. Charles Street MAIN: 410-209-4800 Robert.Harding@usdoj.gov Baltimore, MD 21201-3119 FAX: 410-962-3124 June 6, 2014 ALL DEFENSE COUNSEL, Hon. Ellen L. Hollander Via Email Re: United States v. White et al, Criminal NO. ELH-13-0151 Dear Counsel and Judge Hollander: We write to inform you that the government will ask the Grand Jury to supersede the Superseding Indictment in the captioned case within a few weeks. Because of the motions and trial schedule, no new defendants will be added. Defendants who have pled will not be included. There will be new substantive counts resulting from the search warrants executed last November. Specifically, there will be new charges under 21 U.S.C. 841 against defendants Ricks and Wortham. In addition, the time period of the conspiracy counts will be extended to encompass the time of the search warrant executions, and there will be some minor changes to the language of the speaking section of Count One to discuss methods, means and purposes of the RICO enterprise that have come into clearer light as the investigation has progressed. There may be some other minor changes. We have previously written to all counsel to provide dates for the review of physical evidence at the FBI offices in Woodlawn. The subpoenaed personnel files for DPSCS employees should be available on these days. As these are confidential, absent a court order, we will make available to each attorney only the personnel file for that attorneys client. These files were initially screened by a taint AUSA to remove compelled statements. Undersigned counsel have not seen these compelled statements, but they too will be provided to the counsel for any DPSCS employee who requests them. We will pass along the request to the taint AUSA, who is Barbara Sale. Very truly yours, Rod J. Rosenstein United States Attorney By:_____/s/______________________ Robert R. Harding Ayn B. Ducao Assistant United States Attorneys

Case 1:13-cr-00151-ELH Document 852 Filed 06/06/14 Page 1 of 1