Text of The New Orleans Indictment

United States District Court Eastern District of New Orleans

Indictment for Violation Of The Federal Controlled Substances Act

United States of America * Criminal Docket No. 01-010 v. * Section: C MAG 4 Robert J. Brunet * Violation 21 U.S.C. sec 846 Brian J. Brunet 21 U.S.C. sec 856 (a) (2) James D. Estopinal, 18 U.S.C. sec 2 a/k/a/ Donnie * * * * *

The Grand Jury charges that:

Count 1 A. AT ALL TIMES MATERIAL HEREIN: 1. ROBERT J. BRUNET was the lessee and manager of the State Palace Theater located at 1108 Canal Street, New Orleans, Louisiana, 70112. 2. BRIAN J. BRUNET was the brother of the defendant, ROBERT J BRUNET, and his employee. The defendant, JAMES D. ESTOPINAL a/k/a/ Donnie, was a Rave event ("Rave") promoter at the State Palace Theater and an employee of ROBERT J. BRUNET. 3. The State Palace Theater sponsored or conducted "Raves" participated in by the defendants ROBERT J. BRUNET, BRIAN J. BRUNET AND JAMES D ESTOPINAL, a/k/a Donnie. 4. A "Rave" is an all night dance event, generally operating from approximately from 10:00 p.m. till 7:00 a.m. the following morning that are characterized by loud, rapid tempo ("techno music"), 140 to 200 beats per minute, light and laser shows, smoke or fog, and psychedelic screen images. B. THE CONSPIRACY: Beginning in the year 1995 and continuously thereafter until or about August 27, 2000 in the Eastern District of Louisiana and elsewhere, ROBERT J. BRUNET, defendant herein, did knowing and intentionally combine, conspire and confederate with divers other persons known and unknown to the Grand Jury to manage and to control the State Palace Theater, located at 1108 Canal Street, New Orleans, Louisiana 70112 as lessee, and to knowingly and intentionally make available for use, without compensation, said building for the purpose of unlawfully distributing and using controlled substances, more particularly, 400 milligrams of 3, 4-methylenedioxymethamphetamine (MDMA) (ECSTASY) a schedule I narcotic drug controlled substance and 100 milligrams of lysergic acid diethylamide (LSD) a schedule I narcotic drug controlled substance, in violation of Title 21, United States Code, Section 856 (a)(2); all in violation of Title 21, United States Code, Section 846.

Count 2 A. The allegations of part A of Count 1 are incorporated herein by reference. B. Beginning in the year 1995 and continuously thereafter until on or about August 27, 2000 in the Eastern District of Louisiana and elsewhere, BRIAN J. BRUNET and JAMES D. ESTOPINAL, a/k/a Donnie, defendants herein, while controlling a building, the State Palace Theater, located at 1108 Canal Street, New Orleans, Louisiana 7112, as an employee, did knowing and intentionally make available for use without compensation, said building for the purpose of unlawfully distributing and using controlled substances, more particularly, 75 milligrams of 3,4-methylenedioxymethamphetamine (MDMA) (ECSTASY) a Schedule 1 narcotic drug controlled substance and 50 milligrams of lysergic acid diethylamide (LSD) a schedule I narcotic controlled substance all in violation of Title 21 United States Code, Section 856 (a) (2) and Title 18 United States Code, Section 2.

A True Bill:

Signed by submitter Foreperson

Signed by Eddie J Jordan, Jr. Eddie F. Jordan, Jr. United States Attorney Bar Roll No. 1450