53. At approximately 6:15 p.m., defendant KEITH GIDELSON spoke to
“Tony” on the telephone and discussed the sale of anabolic steroids.
54. At approximately 6:26 p.m., defendant KEITH GIDELSON called
defendant JAY GIULIANO on the telephone and to
ld him that he would stop by the vitamin
store to pay defendant GIULIANO a $500 referral fee.
On or about March 29, 2011:
55. At approximately 3:15 p.m., defe
ndant KEITH EBNER called defendant
KEITH GIDELSON to arrange a purchase of st
eroids for himself and his customers.
56. At approximately 5:09 p.m., defendant KEITH EBNER arrived at
defendant KEITH GIDELSON’s home and purchased anabolic steroids.
On or about April 1, 2011:
57. Defendant KEITH GIDELSON placed a large order of anabolic steroids
with his foreign supplier.
58. Defendant ROBERT JAMES WALTERS sent defendant KEITH
GIDELSON a package through the United States
Postal Service containing one hundred and
sixty seven bottles of various types of steroi
ds and two thousand six hundred steroid tabs.
On or about April 7, 2011:
59. At approximately 2:38 p.m., defendant KEITH GIDELSON called the
United States Postal Service multiple times to inquire about the location of a package of anabolic
steroids he was expecting. During this call,
defendant GIDELSON identified himself as a
Philadelphia Police Detective and said his wife was expecting something she bought through
eBay.
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60. At approximately 6:51 p.m., defendant ROBERT JAMES WALTERS
called defendant KEITH GIDELSON about the missi
ng package of steroids. During this call,
defendants GIDELSON and WALTERS discusse
d how GIDELSON should deal with the
missing package.
On or about April 18, 2011:
61. Defendant ROBERT JAMES WALTERS sent defendant KEITH
GIDELSON a new shipment of steroids through the United States mail to replace the missing
shipment of steroids defendant WALTERS sent
to defendant GIDELSON on or about April 1,
2011.
All in violation of Title 21, United States Code, Section 846.
14
COUNT TWO
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 1 and 2 of Count One of this
indictment are incorporated here.
2. On or about October 15, 2010, in Philade
lphia, in the Eastern District of
Pennsylvania, defendant
KEITH GIDELSON
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
15
COUNT THREE
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 3 and 4 of Count One of this
indictment are incorporated here.
2. On or about October 29, 2010, in Philade
lphia, in the Eastern District of
Pennsylvania, defendant
KEITH GIDELSON
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
16
COUNT FOUR
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 12, and Overt Acts 5 and 6 of Count One of this
indictment are incorporated here.
2. On or about November 22, 2010, in Philadelphia, in the Eastern District of
Pennsylvania, defendant
KEITH GIDELSON
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
17
COUNT FIVE
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 7 and 8 of Count One of this
indictment are incorporated here.
2. On or about December 15, 2010, in Philadelphia, in the Eastern District of
Pennsylvania, defendant
KEITH GIDELSON
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
18
COUNT SIX
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 9 through 11 of Count One of
this indictment are incorporated here.
2. On or about January 27, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and CHRISTIAN KOWALKO
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
19
COUNT SEVEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 12 and 13 of Count One of this
indictment are incorporated here.
2. On or about February 3, 2011, in Phila
delphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and WILLIAM SCHIAVO
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
20
COUNT EIGHT
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 14 through 16 of Count One of
this indictment are incorporated here.
2. On or about February 7, 2011, in Phila
delphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and JOSEPH McINTYRE
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
21
COUNT NINE
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 17 through 20 of Count One of
this indictment are incorporated here.
2. On or about February 11, 2011, in Phila
delphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and GEORGE SAMBUCA
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
22
COUNT TEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 21 and 22 of Count One of
this indictment are incorporated here.
2. On or about February 13, 2011, in Phila
delphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and JOEL LEVIN
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
23
COUNT ELEVEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 29 and 30 of Count One of
this indictment are incorporated here.
2. On or about March 4, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and LUKE LORS
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
24
COUNT TWELVE
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 33 and 34 of Count One of
this indictment are incorporated here.
2. On or about March 9, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and MICHAEL BARCLAY
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
25
COUNT THIRTEEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 38 and 39 of Count One of
this indictment are incorporated here.
2. On or about March 11, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and JOSEPH McINTYRE
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
26
COUNT FOURTEEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 40 and 41 of Count One of
this indictment are incorporated here.
2. On or about March 13, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and VAIDOTAS VERIKAS, a/k/a “Lucas,”
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
27
COUNT FIFTEEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 46 and 48 of Count One of
this indictment are incorporated here.
2. On or about March 18, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and WILLIAM SCHIAVO
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
28
COUNT SIXTEEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 47 and 49 of Count One of
this indictment are incorporated here.
2. On or about March 18, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and JOEL LEVIN
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
29
COUNT SEVENTEEN
THE GRAND JURY FURTHER CHARGES THAT:
1. Paragraphs 1 through 13, and Overt Acts 55 and 56 of Count One of
this indictment are incorporated here.
2. On or about March 29, 2011, in Philadelphia, in the Eastern District of
Pennsylvania, defendants
KEITH GIDELSON,
and KEITH EBNER
knowingly and intentionally possessed with intent
to distribute anabolic steroids, a Schedule III
controlled substance.
In violation of Title 21, United States Code, Section 841(a)(1), (b)(1)(E).
30
NOTICE OF FORFEITURE
THE GRAND JURY FURTHER CHARGES THAT:
1.
1. As a result of the violations of Title 21, United States Code, Sections
841(a)(1) and 846, set forth in this indictment, defendants
KEITH GIDELSON,
KIRSTEN GIDELSON,
ROBERT JAMES WALTERS,
JAY GIULIANO,
MIKE SUPILOWSKI,
MICHAEL BARCLAY,
KEITH EBNER,
JEFFREY FILOON,
CHRISTIAN KOWALKO,
JOEL LEVIN,
LUKE LORS,
JOSEPH MCINTYRE,
GEORGE SAMBUCA,
WILLIAM SCHIAVO,
VAIDOTAS VERIKAS,
a/k/a “Lucas”
shall forfeit to the United States of America:
(a) Any property used or intended to be used, in any manner or part, to
commit, or to facilitate the commission of such violations.
2. If any of the property described above as being subject to forfeiture, as a
result of any act of 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 person;
(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
subdivided without difficulty; it is the intent of the United States, pursuant to Title 21, United
31
States Code, Section 853(p), to seek forfeiture of
any other property of said defendants up to the
value of the above forfeitable property.
All pursuant to Title 21, United States Code, Section 853.
A TRUE BILL:
GRAND JURY FOREPERSON
ZANE DAVID MEMEGER
United States Attorney
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