WARREN Tyiese Govt Sentencing Memo

Case 3:20-cr-00058-KAD Document 388-1 Filed 03/02/22 Page 1 of 40
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA Crim. No. 3:20CR058 (KAD)
v.
TYIESE WARREN, a.k.a. “Loose Screw,” March 2, 2022

a.k.a. “KG LS”
GOVERNMENT=S SENTENCING MEMORANDUM
The Government respectfully submits this sentencing memorandum in connection with
defendant Tyiese Warren’s sentencing hearing, currently scheduled for March 9, 2022 at 10:00
a.m. For the reasons detailed below, the Government asks that the Court adopt the findings of
fact in the Presentence Report (“PSR”) and sentence Warren to a term of fifty years of
imprisonment for the RICO Conspiracy charge, with the special circumstance of murder to which
Warren admitted. What is perhaps most galling about this case is that Warren committed the eight
predicate acts to which he admitted during his plea allocution – including narcotics trafficking,
carjacking, Hobbs Act Robbery, attempted murder and murder -- in the seven months after his
release from Manson Youth Institution. Warren’s violent role in the Original North End (“ONE”)
RICO conspiracy, which has continued even during his pre-sentence detention, enabled him to
promote chaos and a vigilante system of justice. His actions merit a sentence of imprisonment of
at least fifty years to reflect the seriousness of the offense conduct at issue here and the purposes
of a criminal sanction as set forth in 18 U.S.C. § 3553(a).
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I. BACKGROUND
A. Procedural History
After an investigation spanning over a year and a multi-month grand jury presentation, a
New Haven grand jury returned three separate indictments against Tyiese Warren, the last of which
was a one-count Third Superseding Indictment charging Warren with Racketeering Conspiracy,
with the special circumstance of murder, in violation of 18 U.S.C. §§ 1962(d) and 1963. See
Indictment 3:20CR58(KAD). In Indictment 3:20CR126(JBA), Warren was also charged with
VICAR Murder for his role in the January 26, 2020 shooting of four East End gang members on
the steps of the Golden Hill Courthouse of Connecticut Superior Court GA2.
On October 25, 2021, just before jury selection was to begin in 3:20CR126(JBA), Warren
pled guilty to Count One of Indictment 3:20CR58(KAD). See PSR ¶ 1. In the plea agreement,
the parties agreed that eight groups – a conspiracy to distribute controlled substances, the
December 8, 2019 murder of Ty’Quess Moore, the January 26, 2020 attempted murders of Trevon
Wright, Jaheim Warren, Jaffar Ali and Khalil Heard, the March 25, 2020 Hobbs Act Robbery and
the March 25, 2020 carjacking – constituted conduct to be used in determining the
Guidelines. See PSR ¶ 5. Although the Government had prepared substantially – indeed it was
ready to try for over four weeks – the charge against Warren in 3:20CR126(JBA), in the plea
agreement, the Government recognized that Warren’s plea to the Third Superseding Indictment in
this case demonstrated an acceptance of responsibility to the broader charge contained therein, so
after a three-level reduction for acceptance of responsibility, the parties agreed that Warren’s
conduct warranted a total offense level of 41. Id. ¶ 194.
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B. Underlying Facts
Had the case proceeded to trial, the Government would have proven beyond a reasonable
doubt that Warren conspired with his co-defendants and other ONE members and associates, as
well as Greene Homes Boyz or GHB allies, to commit a pattern of racketeering activity, which
included conspiring to possess with the intent to sell and to sell narcotics, carjackings, armed
robberies of businesses, and attempting to murder and murdering rival gang members. The
underlying offense conduct is laid out in detail in the PSR. Accordingly, the relevant facts are
only summarized herein for ease of reference.
Tyiese Warren was a member of the Original North End, or alternatively “Only North
End,” either arrangement shortened to the “ONE” gang, a local Bridgeport street gang, which was
engaged in an active rivalry with the East End gang after the September 2013 murder of
L’Christopher Pettway in the North End of Bridgeport by East End gang members. The focus of
ONE’s activities is the Trumbull Gardens Housing Complex, which spans a large portion of
Trumbull Avenue between Chopsey Hill Road and Reservoir Avenue, and provides a fortress into
which gang members can retreat when chased by police or rival gang members. There are certain
smaller groups within O.N.E., including a group called the “Say Less Gang” (“SLG”) and the
“Outta Control Crew.” These groups are made up of a handful of young and particularly violent
gang members who possess firearms, commit robberies, steal cars, deal in drugs, and shoot often
at opposition gang members and associates. The suggestion with the first is that they “say less”
but act more, and with the second, that their acts of violence are out of control. Warren and co-
defendants Newsome, Gilbert and Dedrick are all self-declared members of SLG.
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Members of ONE, like Warren, self-identified as such on social media and through videos
and pictures and text messages. Although the SLG subset of ONE claim to “say less,” they still
make their fair share of music videos bragging about their exploits. For example, on March 2,
2020, Warren put out a finished video of himself and fellow ONE members discussing the monies
they made from drug dealing and their murders of opposition members. The Government expects
to play the video at Warren’s sentencing. Members of ONE wear clothing bearing the word “one”
in various forms, use images of “one” on their social media, make distinctive gang signs specific
to the ONE gang, and reference ONE in their posts via images, videos, words, and emojis.
There have been numerous acts of violence perpetrated by and against ONE members and
associates, particularly against East End gang members and P.T. Barnum gang members. For
example, on August 13, 2018, Len Smith, who was mistaken for a member of the East End/East
Side/PT Barnum gang alliance, believed to be “Holla,” was fatally shot in in front of the Sunshine
Deli in the East End of Bridgeport. The evidence points to three ONE members – Ta’ron Pharr,
Luis Garcia, and Lorenzo Carter -- as the shooters. Those three, along with other ONE members
and associates, destroyed the stolen Jeep they used to do the fatal drive-by. On March 10, 2019,
Tyron Heard, an East End gang member previously injured by GHB gunfire, was fatally shot, by
ONE members, including Dedrick and Newsome, according to sources. On July 12, 2019, Sean
Warren (a/k/a “Kujo”), the brother of Tyiese Warren, was shot and killed on the East Side of
Bridgeport by two East End gang members. See Ind. 3:21CR008(VAB). On September 24,
2019, ONE member Marquis Isreal was shot at the Flavorzz Restaurant in Bridgeport over 12
times by East End gang member Trevon Wright. See id.
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a. Narcotics Conspiracy
Seized phones from Warren on multiple occasions and Facebook search warrant returns
show that Warren was dealing narcotics along with fellow O.N.E. members on a recurring basis.
Soon after his release, he was supplied by fellow ONE member Shakale Brantley and then Warren
turned around and redistributed to customers. In February 2020, Jawaun Edwards was arrested
with Warren in Milford in a Mercedes stolen from Middletown. At that time, police found
distribution quantities of heroin in Edwards’ possession. As detailed in the PSR, Warren had
other conversations with Edwards detailing narcotics transactions. Cooperating defendants and
other witnesses at any trial in this matter could have testified regarding Warren’s drug dealing.
b. Warren’s Murder of Ty’Quess Moore in the East End
On December 8, 2019, in the morning, East End gang member Trevon Wright shot ONE
associate Arvan Smith in the back multiple times, leaving Smith paralyzed. ONE members
discussed retaliating. That evening, at approximately 6:12 p.m., Shotspotter detected
approximately eight rounds at 588 Newfield Avenue in the East End section of Bridgeport,
Connecticut (territory controlled by the East End gang alliance). When BPD officers arrived, they
located multiple spent shell casings (9 mm and .45 caliber) at the scene. These shell casings have
been preliminarily linked through ballistics testing to a number of other recent shots-fired incidents
in Bridgeport. Officers also found the shooting victim, Ty’Quess Moore, who was taken directly
to the hospital, but despite lifesaving efforts, was pronounced dead at 6:55 p.m.
Officers reviewed video surveillance from the area of the homicide and determined that a
dark-colored Lexus had been driven by the shooters. Video surveillance further showed that the
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Lexus had been involved in a shots-fired incident near the P.T. Barnum Housing Complex twenty
minutes before the Moore homicide. In addition, the same car appeared on video surveillance
during a shots-fired incident at P.T. Barnum three days earlier on December 5, 2019. Officers
responding to that incident found three 9-millimeter spent shell casings and five spent .40 caliber
shell casings. The video captured the license plate on the Lexus, Connecticut registration 837-
YFD. Officers determined that the plate had been stolen off a car in Hamden, Connecticut and
placed on the Lexus which had been stolen from Rye, New York on November 15, 2019.
Videos posted on Snapchat by ONE members on December 5, 2019 showed Warren
driving the Lexus, with Newsome in the back seat. ONE member Dedrick was shown in the
Lexus in a video posted on Snapchat on December 8, 2019. Two days after the Moore homicide,
officers executed two search warrants, one at the home of Warren. In Warren’s bedroom, officers
found the Lexus key fob that matched the stolen Lexus. They also found a Glock .40 caliber, 15-
round magazine and two 9mm Luger live cartridges. 9mm casings had been recovered at the scene
of both the Moore homicide and the P.T. Barnum shots-fired incident that occurred shortly before
it. Forty caliber casings had been recovered at the P.T. Barnum scene as well.
The Infotainment system in the Lexus was subscribed to Warren’s mother, Tangula
Dunbar, connected to the Lexus. That phone was seized by Milford Police in February 2020 and
searched pursuant to warrant. It contained substantial data, including numerous posts, videos,
contacts, and other information that pertain to Warren and ONE.
c. The January 27, 2020 Attempted Murder of Jaheim Warren, Trevon Wright, Jafar
Ali and Khalid Heard by Gaines, Calderon, Jones, Blackwell, Isreal and Warren
i. Motive for shooting
Because Moore was from the P.T. Barnum housing projects and not from the East End
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(whose gang members had killed Warren’s brother Sean), Warren and other ONE members
considered Ty’Quess Moore’s murder not to be a true retaliation. In order to raise his status
within ONE, Warren believed he needed to retaliate against his brother’s killers’ gang. Thus, on
January 26, 2020, Warren told a fellow ONE member in a message, “Im Off a E Nigga,” meaning
he was going to kill an East End gang member.
Later that day, Myreke Kenion was killed inside the Green Homes Housing complex.
Through social media, gang members knew that the murder had been committed by East End gang
members Trevon Wright and Jaheim Warren, and GHB members wanted to retaliate. Warren,
who had just expressed his plan to retaliate against East End gang members, decided to aid and
abet them and fellow ONE member Marquise Israel, who had also been shot in September of 2019
by Trevon Wright.
At 8:12 p.m. on January 26, 2020, Warren messaged his girlfriend about how “Lil Bro
[Kenion] died.” At 9:54 p.m., GHB gang member Asante Gaines communicated with Bert Carter,
Kenion’s brother, on Facebook messenger. Gaines wrote, “Ion want call you bro cuz ion want
hear you hurting but I love you Gang rs and whenever you ready to talk I’m here fa you but I can’t
tell u what to do but think everything out before u make that choice to pack ya bags I no what u
on Nd think about ya mom before you make that choice.” In this message, Gaines was advising
Carter to be careful and to think about any retaliatory acts before he did them. He also advised
that they were real gang brothers (“Gang rs”) and that Gaines was ready to take care of things for
Carter (“I’m here fa you”) but he understood if Carter wanted to retaliate himself (“I can’t tell u
what to do”) but he should understand that if he does do something, his mother may lose two sons
(“Nd think about ya mom before you make that choice.”)
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At 10:08 p.m., Gaines text messaged an (as of yet) unidentified number writing “yea shit
crazy cuz u told me be safe Nd I saw lil bro get stretched” (referring to Kenion being killed and
carried out on a stretcher). Isreal also has a post on Instagram on January 26, 2020 at 11:16 p.m.
with a picture of what is believed to be Myreke Kenion and the message, “This one hurtin a lil
different. I love you bro.” The picture is taken in front of the area where the shooting occurred.
At 12:05 a.m. on January 27, 2020, he posted again on Instagram a picture of Myreke Kenion in
front of what looks like a crime scene flashing gang signs with the message, “damn lil bro I though
you was straight (crying emojis) I love you like you was my lil bro.”At 1:03 a.m., Isreal called
Warren.
ii. Courthouse Shooting
The next morning, at 9:46 a.m., three hours before the courthouse shooting, GHB gang
member Fabian Francis sent the following messages to Chaz Dear (another GHB member and co-
conspirator): “Dey aint on shit bro only mire lor heavy nd tyeise gon drop suttin for em they on
dat shit u was sleep when wss on ft wit me ina car last night.” In this message, Francis was telling
Dear that Amire Newsome, Joshua Gilbert (lor heavy) and Tyiese Warren were going to drop off
guns to the GHB members planning to retaliate.
At 10:59 a.m., Gaines sent a snapshot message to Joshua Gilbert: “I said I’m put another
Niqqa on the news regardless this shit just make me step harder that’s it bro but if Niqqas not on
that shit gotta stay away from Niqqas that it and tre and jd at court.” Agents understand the
message to mean (and Gaines admitted what it meant in his plea allocution) that he was going to
kill opposition members (“I’m put another Niqqa on the news”) and that he did not care who was
with them (“if Niqqas not on that shit gotta stay away from Niqqas”) but that Tre and JD were at
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the Golden Hill courthouse in Bridgeport. “[T]re” was a reference to Trevon Wright and “JD” is
Jaheim Warren, both East End gang members.
At 11:44 a.m., GHB gang member Diomie Blackwell can be seen on the video from the
courthouse making a call (which law enforcement officers later learned was a FaceTime call to
Gaines). At 11:45 a.m., Blackwell can be seen exiting the courthouse and returning to the blue
Volkswagen. At 11:57 p.m., a gray 2014 Subaru Forester (stolen out of Stamford, Connecticut
on January 8, 2020), which is the car from which the shooters fired, can be observed parked outside
the courthouse. At approximately 12:10 p.m., the video footage shows Jaheim Warren and
Trevon Wright, both East End gang members, exit the courthouse and walk to a waiting black
2000 Chevrolet Impala, which was being driven by Khalil Heard with Jaffar Ali in the front
passenger seat. The following timeline provides more detail on the contact between the co-
conspirators.
• 1105: M. Isreal calling T. Warren’s cell 15 times (13 calls, 2 messages)
• 1108: M. Isreal texts Nina McKoy’s cell (T. Warrens GF) – “Call me shit head”
• 1106: M. Isreal calls Nina KcKoy’s cell two times
• 1139: D. Blackwell exits VW Golf and enters courthouse
• 11:41 D. Blackwell physically enters courthouse (GA-2 Video)
• 1142 D. Blackwell checking court list (GA-2 Video)
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• A. Gaines GPS – arriving at courthouse – 207 Golden Hill Street
• 1142: A. Gaines FB Messenger A. Newsome “Wya”
• 1143: A. Gaines to M. Israel aka “freeziggy Garf” “Still here”
• 1144: D. Blackwell FaceTime call to A. Gaines (2:23)
• 1145: D. Blackwell exits courthouse and returns to VW Golf
• 1149: T. Warren texts Nina McKoy cell – “I love you more”
• 1150: T. Warren calls M. Isreal
• 1153: Nina McKoy texts T. Warren – “garf said call him” “he said its important”
(“garf” is Isreal).
• 1153: T. Warren calls M. Isreal
• 1156: Dc Foster to M. Isreal “Oh ok you GG” (GG = Good to Go)
• 1157: Subaru Forester (shooter car) parked for several minutes on Golden Hill
Street prior to shooting (still photo)
• 1158: M. Isreal calls Derrick Ford
• 1205: A. Gaines FaceTime to L. Jones (1:02)
• 1211: Victims Warren and Wright exit the courthouse (GA-2 Video)
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• 1211: Shot-Spotter activation detected
At 12:11 p.m., the Bridgeport Police Department (“BPD”) responded to the courthouse
shooting and discovered that Trevon Wright and Khalil Heard had been shot multiple times.
Heard had sustained multiple gunshot wounds to his back, shoulder and wrist, and Wright had
been shot in the side of his chest. Wright was left paralyzed from the waist down. Jaffar Ali was
grazed in the head and shot in the left thumb, and Jaheim Warren was grazed in the ribs. The
vehicle that the victims had been sitting in had sustained approximately 23 entry bullet holes in
the driver’s side and windshield area. Members of the BPD were able to collect video surveillance
from Bridgeport City cameras from various locations near, in, and around the courthouse, as well
as cameras from a number of local businesses in close proximity to the courthouse. Those
cameras show much of the activity in and around the courthouse before and after the shooting.
The video of the shooting shows the flash from the firearms being fired from the Subaru.
The vehicle that the victims had been sitting in had sustained approximately 23 entry bullet
holes in the driver’s side and windshield area as depicted in the below photographs taken by the
BPD showing the carnage left behind at the scene of the crime.
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The yellow markers indicate the shell casings sprayed across the crime scene. The below
picture shows the steps of the courthouse as the victims tried to run inside for help and the inside
of the courthouse as the court security officers and emergency medical technicians attempted to
keep the victims alive.
Members of the BPD were able to collect video surveillance from Bridgeport City
cameras from various locations near, in, and around the courthouse, as well as cameras
from a number of local businesses in close proximity to the courthouse. Those cameras
show much of the activity in and around the courthouse before and after the shooting.
The video of the shooting shows the flash from the firearms being fired from the Subaru.
As discussed in more detail below in the victim impact statement section, at the
sentencing hearing in this matter, the Government expects that the Judicial Marshals who
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were present during the shooting and witnessed the attempted murders to attend the
sentencing. It is the Government’s understanding that they wish to speak to explain the
carnage they saw, the trauma they personally felt and the fear expressed by other
bystanders as depicted in the below still image from the surveillance video.
iii. Post-shooting conduct
Video surveillance from city cameras further shows that, after the shooting, the Subaru
used in the shooting fled eastbound toward Main Street in Bridgeport, Connecticut and then headed
to the Route 8 turnpike heading northbound. As the shooting occurred, the blue Volkswagen
pulled away, making a U-turn, and then turned west onto Golden Hill Street towards Lyon Terrace.
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At 12:14 p.m., Gaines called Laheem Jones who did not answer, because as later
determined through video surveillance, Jones was purchasing a container of lighter fluid and
bleach at Hidalgo Market at 175 Pequonnock Street in Bridgeport (minutes away from the
courthouse). At 12:15 p.m., Gaines tried calling Jones again, who again did not answer,
presumably because he was still buying the bleach and lighter fluid. At 12:17 p.m., Jones was
captured on video inside the store and outside putting a black bag inside a silver Volkswagen Jetta,
which is the car he was driving at the shooting. Meanwhile, at 12:20 p.m., Gaines did an internet
search on his cellphone for information about the courthouse shooting.
At 12:23 p.m., Jones was captured on video footage arriving at the E&M Park Mobil Gas
station at 1705 Park Avenue in Bridgeport in the silver Volkswagen Jetta and was captured on
video inside the store purchasing a red gas can and filling it with gasoline. This gas can matches
the appearance of the gas can found, partially burnt, in the gray Subaru in Naugatuck. From 12:34
to 12:37 p.m., there was a relevant text message exchange between Jones and Gaines in which
Gaines told Jones to meet at the Walmart in Naugatuck and sent him the exact address.
Approximately, ten minutes later they were in contact in the Walmart parking lot and as of 12:38
p.m., Gaines’ GPS bracelet also shows that he was in this location.1 At 12:45 p.m., Isreal made a
Facetime call to Calderon for 46 seconds and at 12:46 p.m., he called Blackwell for 12 seconds.
At 12:53 p.m., Isreal’s telephone had activity off a tower in Naugatuck approximately half a mile
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Shortly after the shooting, a parole officer contacted the detectives and told them that a parolee he was
supervising, Asante Gaines, was at the scene of the courthouse shooting based on his GPS data. The GPS device,
that Gaines had been required to wear as a condition of his parole, showed that Gaines was in front of the
courthouse for about half an hour prior to the shooting and that he left the area at the exact time the shooting
occurred. Immediately after the shooting, Gaines’ GPS then showed travel consistent with him being in the blue
Volkswagen that had been parked at the courthouse prior to the shooting and that, after the shooting, he went to
Rennell Street in the South End of Bridgeport and then to Naugatuck.
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from the Walmart.
At 12:55 p.m., video surveillance shows the Volkswagen Golf (Gaines) and the
Volkswagen Jetta (Jones) leaving the Walmart parking lot. At approximately 12:57 p.m., without
being aware of the shooting in Bridgeport, a Naugatuck police officer engaged a 2014 gray Subaru
Forester in a short pursuit after attempting to stop the car for not having a front plate. The suspect
car eluded the officer and was last seen on Route 8 North approaching Exit 28 and the police
officer also noted that the gray Subaru was being followed by a gray 2007 Dodge Charger, which
was determined to be registered to Blackwell. The Charger continued to follow behind the police
car during the chase, passing cars to keep up with them. The Naugatuck police officer captured
the gray Subaru and Charger during the chase on his body camera. Upon reviewing the video,
BPD officers determined that this was the same gray Subaru used in the courthouse shooting.
From 12:57 p.m. to 1:38 p.m., Isreal called Calderon in seven FaceTime calls only two of which
were answered. At 12:59 p.m., Jones called Gaines by Facetime. At 1:00 p.m., Jones texted
Gaines to “send location of the car I’ll do the rest” and Gaines responded, “I’m good now.” At
1:01 p.m., Blackwell FaceTime called Gaines and there was further contact between Gaines and
Jones until finally, at 1:05 p.m., Gaines texted Jones “Greenwood Street.”
A little over an hour later, at 2:14 p.m., Thomas Perez called the Naugatuck Police to report
a suspicious vehicle parked in front of their house at 98 Greenwood Street. When Naugatuck
police officers arrived, they located the gray Subaru that was involved in the attempted murders,
which was partially burnt with an accelerant and a one-gallon gas can on the passenger seat floor.
The gray Subaru was processed for evidence by the BPD, and DNA swabs were taken from areas
in the car and evidence found within it. Located in the Subaru were two spent shell casings and
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one live round of ammunition. Also seized from the vehicle were partially burnt medical
documents bearing the name of “LAHEEM JONES.” A bottle of bleach and lighter fluid were
also found at the scene and the cap from the bleach was found in the vehicle. Below are pictures
of the Subaru as it was found in Naugatuck.
Finally, at 2:23 p.m. on January 27, 2020, BPD officers located the blue Volkswagen on
the west side of Bridgeport. BPD officers attempted to stop the car, but it fled, ultimately crashing
into a fence in the area of Pine Street and Fairfield Avenue in Bridgeport. Three of the four
occupants were arrested as they ran from the car and the fourth eluded capture—Asante Gaines
(front passenger); Destine Calderon (driver) and Marquis Isreal (rear passenger) were arrested.
The fourth individual who eluded capture at the time was subsequently identified as Tyiese
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Warren.
While in lock-up in the Trumbull Police Department, Isreal called Warren’s girlfriend Nina
McCoy and asked for “Tyiese.” Warren then got on the phone and Isreal told Warren that he had
not snitched on Warren and had taken one for him.
DNA evidence taken from the front driver’s door interior of the Subaru used in the
shooting, when compared to Warren’s DNA, showed that it was at least 600,000 times more likely
to have originated from Tyiese Warren.
d. Warren’s March 2, 2020 video
On March 2, 2020, Warren finalized a video, called “Get Back at Shit.” The video shows
him, co-defendant Amire Newsome and other masked individuals holding guns and, at one point,
Warren holding a fan of cash. The video lyrics discuss the ongoing gang rivalry and threatens
opposing gang members. For example, between 1:30 and 1:59 of the video, Warren says the
following:
And I’m from the North end where we chase more deads’
Both/bro been smok’en on my Opps like they ain’t more left
Keep it pushing I don know you beat that as if I owe you
We know that this aint really the old you this beef I ain’t going to hold you
And bitch I’m at war with yall up at PT ain’t no more E
The niggas is Done, the opps want to be me
Bitch no you can’t see me and bitch we in GG you know how we come
And that’s word to ya dads
nigga (one of / word to) my dad’s?
why you all in your feelings?
Cause these niggas is dead and I’m trying to be killer so I aim for his head
Kujo that bitch you heard what I said…. GANG
In these verses, Warren identifies himself as ONE (“im from the North”) and brags about
how ONE members, especially co-defendant Joshua Gilbert, have killed the most opposition
members to the point that there are not any remaining (“we chase more deads. Both/bro been
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smoken on my Opps like they ain’t more left”). He taunts the opposition to keep trying to shoot
ONE members (“Keep it pushing”) and states that he is at war with only those in the PT Barnum
gang (“im at war with yall up at PT”), apparently justifying the reason he killed PT Barnum
associate Ty’Quess Moore, because everyone in the East End gang was dead or in jail (“ain’t no
more E. The niggas is Done.”). Warren then says that because all the East End gang members
were dead (“Cause these niggas is dead”) and because his goal was to be a killer (“I’m trying to
be a killer”), so he shot Ty’Quess Moore in the head (“so I aim for his head”). Warren then pays
homage to his deceased brother Sean (“Kujo”) and to his Gang- ONE.
e. March 25, 2020 Hobbs Act Robbery and Carjacking
On March 20, 2020, Connecticut Governor Ned Lamont ordered all non-essential
businesses closed. Gas stations, grocery stores and take-out restaurants were deemed essential,
though the streets of Bridgeport and Stratford, like their larger neighbor to the southwest, were
essentially empty. See https://www.ctpost.com/news/article/Photos-New-York-City-s-empty-
streets-and-15134771.php
At approximately 8 p.m. on March 25, 2020, Stratford Police heard a dispatch that a
Chevrolet Malibu had been stolen in the area of Stratford Avenue at Davenport Street in
Bridgeport, near the Perez Deli and Grocery. Police later learned that the Malibu’s owner, ST,
went inside the store, leaving her car running out front. When she came back outside, her car was
gone.
A little later, JB parked his white Honda Accord at the front of the Citgo Station on Barnum
Avenue in Stratford. As he waited in line to buy some green tea, he noticed two people, one of
average height and one fairly tall, getting inside his car. JB ran out of the Citgo Station and
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grabbed the rear passenger seat door. The driver continued to drive and JB was dragged
approximately 300 to 400 feet before he let go of the car. JB was in significant pain and had cuts
and bruises all over his body, losing a significant amount of skin off his left glute and his left arm.
On reporting to the Citgo Station, Stratford Detective John Therina noticed the stolen white
2010 Chevrolet Malibu parked in the Citgo Station parking area. Checking surveillance video
from Citgo, Detective Therina saw that the two car thieves wore black hooded sweatshirts and
black sneakers, and that one of the thief’s sneakers had a white Nike emblem on the side. One of
the thieves was taller than the other and was wearing a black jacket with an emblem on the left
sleeve. The Citgo stations video tshows the two men steal JB’s white Honda, and JB is also
captured as he is dragged out of the parking lot.
At approximately 9:48 p.m., on the same day, Bridgeport Officer Jamar Edwards went to
the Mainport Fish & Chips, located at 1010 North Avenue, Bridgeport on a report of an armed
robbery. The victim, MS, was the driver of a 2018 Toyota Corolla, bearing license plate AM84952
Agents interviewed the driver about the incident. He stated that he had come out of the store with
food, entered his car, and was queuing music on his cellular telephone when he saw two people
dressed in black sprinting towards him. One got into the front seat, beside him, and the other got
into the back of the car. They both were wearing masks. The person in front pointed a black
handgun at the driver and shouted, “Drive or I will shoot the shit out of you!” The gun was held
near the driver, and he was terrified. The robber continued to demand that the man drive, and,
fearing for his life, he jumped out of the car and ran towards the store. The front-seat robber
grabbed his shirt to try to keep him in the car, but the victim was able to get away. He saw the
front passenger jump over into the driver’s seat, and his Toyota was driven away with both robbers
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inside in the direction of Stratford.
At approximately, 9:57 p.m., less than ten minutes later, Stratford Police received a call
from the Citgo Station on Barnum Avenue reporting an armed robbery. Surveillance video showed
that a 2018 Toyota Corolla, bearing license plate AM84952 – the same car stolen from the
Mainport Fish & Chips in Bridgeport just minutes before – backed into the same spot that had
been occupied previously by the stolen Chevrolet Malibu prior to its removal by police. The video
showed two men with handguns, one of whom was wearing black sneakers with a white Nike
symbol on the side of the shoe, and a black jacket with a white and red emblem on the left sleeve,
enter the Citgo, forcibly take cash while manhandling the clerk and then leave.
At approximately 10:11 p.m., less than 15 minutes later, Bridgeport Police was dispatched
to 2519 Fairfield Avenue in Bridgeport on a complaint of a stolen vehicle. Upon arrival, the
victim advised the officer that he had left his white BMW 328xi with the engine running (he kept
the key fob on him) while he went inside a store to retrieve a friend. Moments later, he observed
his vehicle leaving the parking lot and driving east on Fairfield Avenue.
At approximately 10:24 p.m., Bridgeport Police received a 911 call from yet another victim
whose vehicle, a brown BMW X5 bearing Connecticut registration AV34226, had just been stolen.
The victim advised the operator that his vehicle had been stolen from outside the victim’s store
located on the corner of Hollister Avenue and Stratford Avenue. Agents interviewed the victim
and he stated that he had started his car to warm it up and returned for a moment to the front of his
store when he saw a white BMW next to his brown BMW. His car pulled away from the street
and followed the white BMW down Stratford Avenue.
Shortly thereafter, Stratford dispatch put out a broadcast for the brown 2014 BMW X5,
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bearing license plate AV34226 that had just been stolen in Bridgeport. Stratford Police Officer
Iodice stationed himself at the intersection of Stratford Avenue and Beardsley Avenue, where two
gas stations are located. Minutes later, Officer Iodice saw a brown BMW X5 pull into and out of
one of the gas stations and then start to enter the station lot again. Officer Iodice confirmed that
the license plate matched that of the stolen BMW and tried to stop the car. Instead of stopping, the
BMW sped away in the direction of the on-ramp for I-95 South, toward Bridgeport, but the BMW
hit another car and came to a stop on the on-ramp.
After the BMW became disabled, the driver and passenger got out of the vehicle and ran,
and Officer Iodice, who was alone, followed the driver. Officer Iodice was able to apprehend the
driver, who was identified as Tyiese Warren. The officer found more than $600 in cash, a
Mercedes key fob, and black gloves on Warren. In the path taken by Warren after fleeing the
brown BMW, police recovered a black ski mask and a black Apple iPhone XR. The next day,
officers found four sets of keys in Warren’s path: keys for a Toyota, a Kia, two GMC keys, and
some keys that appeared to be for a residence. Stratford Police also seized the clothing Warren was
wearing at the time he was apprehended. That clothing, including a black Tommy Hilfiger jacket
with red and white emblem on the left sleeve and Nike sneakers with the white swish, is the same
clothing worn by one of the suspects in the Citgo robbery some 45 minutes earlier. More than
$1300 in cash was found inside the brown BMW.
Search warrants for cellular telephones that were used by Newsome showed that earlier in
the day, Newsome sent a text message to his mother: “Im here w tyiese [Warren] and 2 friends.”
Hours later, Newsome sent a message to (203) 526-2123: “I think Tyiese got caught, we got chased
in Stratford.” Newsome’s phone sent his location to O.N.E. member Ashan Langston after the
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Stratford officer apprehended Warren. The location was near I-95 and consistent with the place
where Newsome would have run to avoid capture.
Newsome also communicated with Warren’s girlfriend Nina McCoy. McCoy connected
Warren with Newsome when Warren called her from jail. Newsome told McCoy to tell Warren
they were getting money together for his bond. Warren told Newsome to “lay low and stay low.”
C. Warren’s Post-Plea Conduct
As noted above, on October 25, 2021, Warren pleaded guilty to RICO Conspiracy with a
special circumstance of murder. Pending sentencing, he was returned to the Donald W. Wyatt
Detention Facility (“Wyatt”). On December 18, 2021, Officer J. Torres was posted at the Delta
Pod housing unit of Wyatt; Warren was a resident of Delta Pod. Around 5:17 p.m., Officer
Torres, who was in the lower level of the Pod distributing meal trays, noticed a commotion in Cell
D-8, which was in the upper area of the Pod. Officer Torres notified other correctional officers,
locked down the unit and went to Cell D-8. As Officer Torres walked up the stairs toward the
cell, he saw co-defendant Amire Newsome punch another detainee, Antoine Snell, in the head.
Simultaneously, Officer Torres saw Tyiese Warren kick Snell in the head. As Officer Torres got
closer to the cell, Warren, Newsome, co-defendant Jauvan Edwards and another detainee Jason
Scott, ran out of Cell D-8. Inside Cell D-8, Officer Torres found Snell “bleeding profusely on the
ground.” Sergeant C. Delgado who followed Officer Torres into the cell reported that Snell was
unconscious on the floor near the cell toilet. It should be noted that although the PSR states that
“Mr. Newsome was transported to the Rhode Island Hospital by ambulance,” PSR ⁋ 8, it was Mr.
Snell who was transported to Rhode Island Hospital by ambulance. Mr. Newsome remained in
the facility uninjured and in a separate cell.
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D. PSR Calculations
The Presentence Report applied the November 1, 2020 Sentencing Guidelines. PSR ¶ 90.
The Probation officer determined that the conspiracy to distribute narcotics resulted in a base
offense level of 20. Id. ¶¶ 92-97. Probation further determined that the offense level for the
murder of Ty’Quess Moore was 43. Id. ¶¶ 99-103. With regard to the courthouse shooting
attempted murders, the adjusted offense level for Trevon Wright was 37 due to Wright’s paralysis
from the waist down, the adjusted offense level for Jaheim Warren was 33, the adjusted offense
level for Jaffar Ali was 35, due to the degree of injury, and the adjusted offense level for Khalil
Heard was 35. Id. ¶¶ 109, 115, 121, 127. The PSR determined an adjusted offense level of 26
for the Hobbs Act robbery of the Citgo station and an adjusted offense level for the carjacking,
both of which took place on March 25, 2020. Id. ¶¶ 133, 140. Because groups three, five and
six – the attempted murders of Trevon Wright, Jaffar Ali and Khalid Heard -- were each within
eight levels of the murder of Ty’Quess Moore, and the other groups were more than eight levels
removed from the murder adjusted offense level, the PSR calculates Warren’s total offense level
as 43, after subtracting three levels for acceptance of responsibility. Id. ¶¶ 141-48. The PSR
further calculated Warren as Criminal History Category III. Id. ¶ 153. Based on a total offense
level of 43 and a Criminal History Category III, Warren’s advisory Guidelines are 720 months,
due to the maximum term of imprisonment for murder under Connecticut law as charged in the
Third Superseding Indictment. Id. ¶ 177.
In the plea agreement, the parties agreed that Warren’s total offense level was 41, which
with a criminal history category of III, yielded an advisory Guidelines term of 360-720 months of
imprisonment. Doc. 327. While ordinarily, the Government would move for a Fernandez
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departure due to the variance in the Guidelines as determined by Probation and the parties’
calculation, in the same plea agreement, the parties expressly agreed that “the Government
expressly reserves the right to seek denial of the adjustment for acceptance of responsibility if the
defendant engages in any acts, unknown to the Government at the time of the signing of this
agreement, which (1) indicate that the defendant has not terminated or withdrawn from criminal
conduct or associations (§ 3E1.1 of the Sentencing Guidelines) . . . .” Id. at 4. Warren’s conduct
in beating Snell to a point of unconsciousness along with fellow ONE member Newsome and at a
minimum in the presence of fellow ONE member Edwards demonstrates that Warren has not
terminated or withdrawn from criminal conduct or associations, and accordingly, the Government
will not be moving for the third point for acceptance of responsibility and will be recommending
that the Court not afford Warren the other two points. Accordingly, the Government understands
that this withdrawal of the third point and recommendation that the Court not grant the other two
points for acceptance will have no impact on his Guidelines, may moot the motion for a Fernandez
departure.
Regardless of whether the Court determines the Guidelines range to be 360-720 months or
720 months, for the reasons set forth below, the Government seeks a sentence of at least fifty years
based, primarily, on “the nature and circumstances” and “seriousness of the offense;” the need “to
promote respect for the law, and to provide just punishment;” the need “to accomplish specific and
general deterrence;” and the need “to protect the public.”
E. Victim Impact
The FBI has had difficulty being in contact with Ty’Quess Moore’s mother, Ms. Woodruff,
having left cards and messages at her residence, but are continuing to try to reach her to see if she
25
wishes to participate in the sentencing. Jaheim Warren was unfortunately murdered in December
of 2020 after he was almost killed on January 27, 2020.
Trevon Wright (who is currently paralyzed from the waist down and is separately charged)
has indicated through his lawyer that he does not wish to participate in this case. Khalil Heard
does not intend to attend sentencing, but the Government will provide a report of a recent interview
of him to defense counsel and the Probation Officer and intends to read from that report at the
sentencing. Heard was struck in the back six times and the right wrist one time. He suffered a
collapsed lung and had to have an emergency chest tube inserted to keep him alive and he also had
to undergo emergency exploratory surgery upon his arrival. He was in the hospital for two and a
half weeks after the incident and still has bullet fragments in his back as well has having a loss of
sensation to his fingers and numbness to his back. Heard stated he suffers from PTSD as a result
of having been shot and to this day, becomes anxious and nervous when he hears a car backfire.
Jaheim Warren was unfortunately murdered in December of 2020 after he was almost
killed on January 27, 2020. Jaffar Ali also does not wish to participate in this case, but, as with
Heard, the Government will provide a report of a recent interview of him to defense counsel and
the Probation Officer and intends to read from that report at the sentencing. Ali was shot in his
lower thumb and hand and received a bullet wound in his head. He still cannot fully bend his
thumb and suffers from a lack of sensation int that area and he had to have his head stapled after
the shooting. Ali has bullet fragments in his head and suffers migraines, which he never suffered
before the shooting. Ali further recounted that he cannot play and interact with his nine-year-old
son the way he did before he was shot and that he has been diagnosed with PTSD following the
shooting. It is also still “stressful” for him to travel to the courthouse as it brings up painful
26
memories.
The Citgo employee, who was working on March 25, 2020, AK has informed the
Government that he was terrified by the robbery and due to that lingering fear and belief that he
was not safe in Connecticut, moved to Texas. MS, the victim of the carjacking, too, was terrified
and feared for his life as the robbers pointed a gun at him.
II. DISCUSSION
Following the Supreme Court’s holding in United States v. Booker, 543 U.S. 220, 243-245
(2005), which rendered the Sentencing Guidelines advisory rather than mandatory, a sentencing
judge is required to: “(1) calculate[] the relevant Guidelines range, including any applicable
departure under the Guidelines system; (2) consider[] the Guidelines range, along with the other
§ 3553(a) factors; and (3) impose[] a reasonable sentence.” See United States v. Fernandez, 443
F.3d 19, 26 (2d Cir. 2006). The § 3553(a) factors include: (1) “the nature and circumstances of
the offense and history and characteristics of the defendant;” (2) the need for the sentence to serve
various goals of the criminal justice system, including (a) “to reflect the seriousness of the offense,
to promote respect for the law, and to provide just punishment,” (b) to accomplish specific and
general deterrence, (c) to protect the public from the defendant, and (d) “to provide the defendant
with needed educational or vocational training, medical care, or other correctional treatment in the
most effective manner;” (3) the kinds of sentences available; (4) the sentencing range set forth in
the guidelines; (5) policy statements issued by the Sentencing Commission; (6) the need to avoid
unwarranted sentencing disparities; and (7) the need to provide restitution to victims. See 18
U.S.C. § 3553(a).
The Second Circuit reviews a sentence for reasonableness. United States v. Canova, 412
27
F.3d 331, 350 (2d Cir. 2005). The reasonableness standard is deferential and focuses “primarily
on the sentencing court’s compliance with its statutory obligation to consider the factors detailed
in 18 U.S.C. § 3553(a).” Id. Here, there is no basis for the departure requested by defense
counsel and all of the relevant factors weigh in favor of a sentence above the Guidelines range.
See 18 U.S.C. § 3553(a).
A. No Basis for a Downward Departure or Variance
In his sentencing memorandum, Warren argues that the Court should depart from the
Guidelines sentence due to his youth, the significant mental trauma caused by the murder of his
younger brother, Sean Warren, and the significant pretrial detention he has had to undergo. Doc.
382 at 5-8. Warren specifically argues that a sentence of ten years of imprisonment is warranted.
Id. at 11.
With regards to Warren’s argument that his brain—and specifically the area that regulated
impulse control—had not fully developed at the time of the offense conduct warrants a departure
from the Guidelines sentence here, the argument should be rejected here. First, Warren’s conduct
grew progressively worse as he aged. Starting with larceny and robbery when he was a juvenile,
and then progressing to firearms’ possession during an incident when a person was shot at, Warren
was jailed for 16 months. Apparently, his time in jail did nothing to deter Warren. To the
contrary, in the seven months after his release, Warren committed the worst of all crimes – murder
– and made every effort to make that murder appear minor by trying to kill at least four people in
front of a public courthouse during working hours. Then, when the COVID-19 pandemic shut
the State down, Warren and Newsome decided to spend an evening stealing cars, whether occupied
or not, and robbing establishments, injuring at least one person in the process, further preying on
28
a populace already traumatized by a virulent pandemic. Perhaps most telling, even once arrested,
detained at a federal contract facility and having pleaded guilty to his crime, Warren and at least
two other ONE members beat up a fellow inmate to the point of unconsciousness. Far from
isolated or impulsive criminal acts, his conduct demonstrates a steadfast commitment to unfettered
violence. Second, while Warren wants his life back due to his “youthful indiscretions,” his
victims will never have theirs’ back. Ty’Quess Moore, too, was only eighteen when he was
brutally gunned down simply for standing on Newfield Avenue. Should Ms. Woodruff grieve
less because the two individuals who killed her son were in their late teens? Will Jaffar Ali’s and
Khalid Heard’s PTSD be cured because Warren’s brain was not fully developed? Should ST, JB
and MS write off each of their significant trauma and recovery times as just a risk of living in or
doing business in a City in which young men without fully developed brains need cars from which
to use their guns to shoot their peers in other parts of the City simply because of where they live?
Should AK laugh off the fear that caused him to flee the State after he was robbed and return to
the Bridgeport area to start a business? Warren’s relative youth does nothing to cleanse the
trauma that his crimes have inflicted on numerous persons – people who deserve to know that their
tormentor will be incarcerated for many, many years to come. Third, Warren’s Facebook
postings, text messages and March 2, 2020 video make it abundantly clear that he was aware of
what he was doing and promoted and instigated others to join and revel in his violent conduct.
Despite a co-defendant’s efforts to exclude as irrelevant hip hop or rap videos that Warren and his
co-defendant’s made, see Doc. 379, Warren’s video was plainly factual, even if put to music in a
video and described his murder, his reasons for the murder and his allegiance to his the ONE gang.
The posts and the video portray an individual who was fully aware of his actions and who behaved
29
as if the law did not apply to him—bragging about his role in ONE and his murder of a PT Barnum
associate, threatening rival gang members with drive-by shootings and perpetuating a cycle of
violence that has taken so many lives in the City of Bridgeport.
Nor should a downward departure be granted because Warren was retaliating against his
brother’s murderers. First, such a downward departure would only promote vigilantism.
Warren and his ONE brethren and GHB allies believed that they were a law onto themselves, not
only ignoring but also impeding legitimate law enforcement efforts to arrest and prosecute violent
crime in Bridgeport. They determined who should be punished for transgressions against their
gang and served as judge, juror and executioner. Displeased with merely sowing havoc in the
East End, PT Barnum and Park Avenue neighborhoods of Bridgeport, Warren, Isreal and their
GHB allies determined to show their hegemony in the City by bringing the violence to the very
seat of court – the institution of justice – which they sought to displace. Second, Warren was not
retaliating against his brother’s murderers, both of whom he knew and were later arrested and
charged for the murder. See Indictment 3:21CR008(VAB). Both were incarcerated on other
charges just after Warren was released from Manson. In fact, few, if any of ONE’s and GHB’s
quarries were persons who had committed wrongs against ONE or GHB. Rather, they chose to
shoot any Black male who happened to be in the territory frequented by his brother’s killers.
Thus, Ty’Quess Moore, a resident of the West Side of Bridgeport, near the PT Barnum housing
complex, could be assassinated simply because he gallingly stood on Newfield Avenue in the East
End of Bridgeport on a cold December evening.
Finally, Warren’s argument that his “significant pre-trial detention” merits a downward
departure because Wyatt is a “high-security facility on every level,” Doc. 382 at 7, should be
30
dismissed outright. Warren was far from a state of isolation when he and his fellow gang
members pummeled fellow detainee Antoine Snell to a state of unconsciousness. And Warren’s
complaint that he was afforded “minimal opportunity for rehabilitative activities, programs or
work,” Id., is certainly belied by other Presentence Reports the undersigned has read in which
detainees at Wyatt serve as cooks, runners, kitchen staff and earn certificates for anger
management, mental health awareness, anxiety, COVID-19 anxiety, Criminal Lifestyles classes
(among others) and workbook completions. The fact that Mr. Warren “is not working or engaged
in any programming,” PSR ⁋8, is a choice he has made to defy the expectations of the legitimate
criminal justice system that those who have pled guilty seek to better themselves for a future
reentry into society. That Warren has not shed his vigilante beliefs and his derision of the
legitimate criminal justice system should be a reason to incapacitate him and not a reason to release
him prematurely as his counsel requests.
B. Section 3553(A) Factors
Instead of the significant downward departure that Warren requests, it is the Government’s
position that a below Guidelines sentence of at least 600 months is necessary to adequately reflect
the nature and circumstances/seriousness of the offense; to promote respect for the law and provide
just punishment; to deter other similar conduct; and to protect the public.
a. Nature and circumstances/seriousness of the offense
As noted above, the Government is not disputing that Warren was young, albeit an adult
under the law, when the relevant offense conduct was committed. However, the nature and
circumstances of the offense conduct that Warren was involved in here far outweigh any mitigating
factors derived from his youth or lack of criminal history. There is no more serious offense than
31
killing another person. Warren bragged about the murder not only in a music video he paid to
create but also in jail following his arrest. Warren was proud of the murder – it provided him
status and an enormity in the minds of his murderous peers that he refused to earn through
academic, athletic or socially positive manner. The gravity of his murder of a young Black man,
who himself had led a hard life, is compounded by the fact that Newfield Avenue, the area Warren
and his fellow ONE members targeted as the site of their shooting, is a densely packed residential
area. But on that cold December evening, it was not crowded as ONE’s and GHB’s feud with the
East End gang had made sojourns in the area a dangerous prospect. Warren’s murder of Moore
merely confirmed and cemented the fear in which residents of that area had to live.
As Warren’s video shows, he taunted and threatened rival gang members, practiced a code
of not snitching or cooperating with authorities and sold narcotics—including heroin and cocaine.
The social media posts and videos of Warren and other ONE members only served to escalate
feuds and to instigate further violence. Nor was Warren’s murder of Ty’Quess Moore the only
murder ONE perpetrated. The Third Superseding Indictment is replete with names of rival gang
members and innocent civilians killed by Warren and his ONE comrades. One cannot join a gang,
reap the “benefits” of such membership and then be absolved of responsibility for foreseeable
criminal acts perpetrated by co-conspirators in furtherance of the conspiracy. A significant term
of imprisonment is necessary to reflect the seriousness of the offense conduct at issue here.
But Warren was not satisfied with the status he achieved amongst his murderous crew for
the murder of Moore. Undeterred, and in fact emboldened, Warren agreed with fellow ONE
member Isreal and GHB members to assassinate Trevon Wright and Jaheim Warren and anyone
who was with them on the steps of the Golden Hill Courthouse in Bridgeport immediately after
32
they left a court appearance. The recording of the shooting which the Government will play at
sentencing is haunting – justice being served, then over twenty shots being fired and justice being
interrupted. The fact that Warren did not add to his murderous toll is a miracle – Trevon Wright
could not even crawl away from the car as it was riddled with bullets as his spine had already been
hit. Ali survived a gun shot to his head and Heard is still alive despite six bullets hitting him in
his back.
Nor was Warren’s racketeering activity limited to murders and attempted murders of rivals.
On a March Day in which citizens of Connecticut struggled with the trauma of a burgeoning
pandemic and all nonessential work and travel was halted, Warren and his co-defendant Newsome
went on spree of car thefts, carjackings, and robberies of essential businesses that traumatized
multiple citizens of the Newfield and Bridgeport areas, directly causing one of them, AK, to leave
the State forever.
Finally, , Warren and at least two other fellow ONE members battered a fellow detainee at
Wyatt into a state of unconsciousness. Warren’s beating of a fellow inmate after he had pleaded
guilty knowing full-well that he was being recorded demonstrates that Warren has utter contempt
for rules and societal norms. His actions show that being accepted by violent peers and having a
violent reputation is the most important thing for him. Warren’s decision not to forsake violence
or ONE even in the face of a potential sixty-year sentence shows that he is incapable of operating
within legal limitations, even when detained in what his counsel calls the tightest security.
Warren must be punished to the fullest extent possible.
b. History and characteristics of Warren
The well-researched PSR shows that Warren was never exposed to violence or drug use at
33
home. Unlike many defendants who had learning disabilities, a PPT revealed that Warren had
none. Despite being exposed to sports and playing for the Trumbull High School football team,
he chose the “carefree” life of the streets of the North End of Bridgeport. PSR ⁋⁋159-160.
Although Warren’s father was not part of his life, his mother tried her best to steer him clear of the
streets. Nonetheless, Warren chose the streets over her advice.
Warren’s brother’s death was no doubt traumatic to him. But rather than use the murder
as a wake-up call to remove himself from the streets, Warren sought to establish or raise his street
reputation, murdering a similar-aged peer from another part of Bridgeport, who had nothing to do
with his brother’s murder. Finding the murder of Moore unsatisfying, Warren sought to murder
four members and associates of the gang that had murdered his brother and chose to do it in the
most public of fashions -- driving a car loaded with gang members to the front steps of the Golden
Hill courthouse and then firing multiple times into a car two to three feet away. As noted above,
it is a miracle that Warren did not add to his bloody toll.
Warren seeks to explain his March 25, 2020 spree of car thefts, carjackings and robberies
by saying that he had “removed his house arrest anklet” and was in need of “some bread.” PSR
⁋ 161. Notably, the removal of the bracelet simply confirms why Warren had not committed a
crime before March 25, 2020. Had he not removed his bracelet, his parole officer would have
realized that he was the perpetrator of the various robberies, further demonstrating that Warren
cannot be free in legitimate society. With regard to his need for “bread,” Warren’s explanation
discounts the professional video for which he paid just three weeks earlier and the large amount of
cash he displayed in a fanned-out fashion in that video. His professed need for money also fails
to explain the sheer number of cars he and Newsome stole. Surely if he needed money he could
34
have sold one of the stolen cars (they also stole a cashier’s iPhone XR), rather than just using it to
drive to a different place from which he and Newsome stole another car. If he simply needed
money, why did he and Newsome have to tell MS, “Drive or I will shoot the shit out of you,” as
they stole his car? Why did they have to drag JB 300 to 400 feet as he tried to save a car that
Warren and Newsome planned to abandon shortly thereafter? He certainly knew, as his actions
later that night proved, how to run away from the car once it stopped. Warren’s inability to
provide a rationale for his March 25, 2020 crime spree demonstrates that he cannot operate within
societal norms.
c. Need for sentence to promote respect for the law, and to provide just
punishment
The actions of Warren and his fellow ONE members are not the actions of individuals who
exhibited any respect for the law. They dealt drugs—including heroin—with total disregard for
the consequences of their actions and the toxicity of the substances they were selling. Most
perversely, they sought to control the City of Bridgeport. They sought to undermine legitimate
law enforcement and to create a culture in which they were to be feared and thereby gain respect,
a culture where speaking to legitimate law enforcement about crimes warrants a death sentence.
ONE members like Warren sought to intimidate their rivals – simply people their own age who
lived in different parts of the City – by threatening to gun them down for such arbitrary actions as
mentioning the name of a dead ONE member or having a party to celebrate the return of an
incarcerated gang member.
Warren thrived in the environment of fear he created – shooting people in front of a public
courthouse, robbing essential businesses and stealing cars from ordinary citizens already
traumatized by the COVID-19 pandemic. In order for our system of justice to survive, anti-social
35
persons like Warren who seek to create chaos through violence need to be punished severely so
that citizens can understand that the law will protect them. The public needs to know that
vigilantism will not be countenanced by legitimate authority and that the court system is the place
in which justice prevails.
d. Need to accomplish specific and general deterrence and incapacitation
In the Government’s view, deterrence is also a factor that warrants a Guidelines sentence,
despite its severity. It is impossible to know how many additional shootings, attempted murders
and murders were prevented by the arrests made as a result of this investigation. However, based
on the history of ONE and statistics maintained by the Bridgeport Police Department, it is beyond
contention that future acts of violence were avoided by the investigative efforts of the Bridgeport
Police Department, the Federal Bureau of Investigation and the Bureau of Alcohol, Tobacco,
Firearms and Explosives, and the arrest and prosecution of the ONE defendants, their allies and
their foes. Thus, although there were 85 gang related gunshot victims and 13 gang related
homicides in 2020 in the City of Bridgeport, in 2021, after the arrests of ONE, Greene Homes
Boys and East End gang members, there were 35 gang related gunshot victims and 5 gang related
homicides (four of which occurred early in the year prior to arrest of many Bridgeport gang
members). That significant reduction has been achieved through the incapacitation of those
violent gang members, including Warren.
Warren’s prior juvenile incarceration of sixteen months appears to have had no beneficial
impact on him. As noted above, in the seven months following his release on parole, he
committed nearly every violent crime in the statute book as well as dealing narcotics and controlled
substances. Likewise, those who seek to emulate Warren and might contemplate murdering
36
another person simply because they live in a different part of Bridgeport should know that the
legitimate justice system will punish such conduct severely. Warren’s sentence should also deter
his peers in Bridgeport and elsewhere who might think it is permissible to shoot rival gang
members or join gangs without accepting punishment for the gang’s criminal activity. As noted
above, unlike other major cities around the country and in Connecticut, violence in Bridgeport has
ebbed significantly since the over 30ederal arrests of East End, ONE and Greene Homes gang
members and associates. Gang members have indicated to the Government that the federal
indictments have put a chill in gang activity. A significant sentence will ensure that other young
men will think twice before joining gangs and engaging in senseless violence that disrupts and
sometime permanently alters the lives of law-abiding citizens.
e. The need to avoid unwanted sentencing disparity
In imposing a sentence, the Court must determine a sentence that considers unwarranted
nationwide disparities. See United States v. Frias, 521 F.3d 229, 236 (2d Cir. 2008). Adults who
commit federal murder throughout the country, and are not subject to the death penalty are usually
subject to terms of up to life imprisonment. Warren, who was nineteen at the time murdered
Moore, not only killed another to raise his standing in a gang, but he tried to kill four others for
that same purpose, and then robbed, stole and pummeled pandemic-shocked citizens of Bridgeport
and Stratford. The sentence the Government recommends of at least fifty years, while severe, is
relatively mild when compared to the sentences meted on similarly situated defendants, who have
committed similarly heinous crimes, and has been found reasonable for juveniles much younger
than Warren. See, e.g., United States v. Portillo, 981 F.3d 181, 184 (2d Cir. 2020)(“ A sentence
of fifty-five years is unquestionably severe. And it is fairly deemed especially harsh for a defendant
37
fifteen years of age at the time of the crime. At the same time, the offense for which this sentence
was imposed is heinous, indeed, especially heinous. Four people were murdered, the killing was
brutally accomplished, and the defendant not only actively participated in the murders but planned
the crime in retaliation for a petty grievance. Acknowledging the broad scope of a sentencing
judge’s discretion and taking into account the care taken by Judge Bianco in exercising that
discretion, we conclude that the sentence is not unreasonable in any legally cognizable sense);
United States v. Friend, 2 F.4th 369, 372, 380-81 (4th Cir. 2021)(52 year sentence for defendant
who at age fifteen participated in his family-led “series of carjackings, beatings and murders in
Virginia” where fifteen year old bound and beat victims begging for mercy and maimed one for
life was substantively and procedurally reasonable); United States v. Barraza, 982 F.3d 1106, 1116
(8th Cir. 2020)(Barraza’s 50-year sentence for a kidnapping when he was 16 resulting in death of
a mother and her five-year-old son was substantively and procedurally reasonable).
38
III. CONCLUSION
For the reasons stated above, the Government respectfully asks the Court to adopt the
factual findings in the Presentence Report and to impose a sentence of fifty years of imprisonment
in order to reflect all the 3553(a) factors.
Respectfully submitted,
LEONARD C BOYLE
UNITED STATES ATTORNEY
/s/ Rahul Kale

RAHUL KALE
FEDERAL BAR NO. phv 02526
1000 LAFAYETTE BLVD., 10th Floor
BRIDGEPORT, CT 06604
203-696-3000
39
CERTIFICATION
I hereby certify that on March 2, 2022, the foregoing Sentencing Memorandum was filed
electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court=s
electronic filing system or by mail to anyone unable to accept electronic filing. Parties may access
this filing through the Court=s system.
/s/ Rahul Kale

RAHUL KALE
ASSISTANT UNITED STATES ATTORNEY
40

WARREN Tyiese Govt Sentencing Memo

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Case 3:20-cr-00058-KAD Document 388-1 Filed 03/02/22 Page 1 of 40

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA Crim. No. 3:20CR058 (KAD)

TYIESE WARREN, a.k.a. “Loose Screw,” March 2, 2022

GOVERNMENT=S SENTENCING MEMORANDUM

The Government respectfully submits this sentencing memorandum in connection with

of a criminal sanction as set forth in 18 U.S.C. § 3553(a).

Indictment 3:20CR58(KAD). In Indictment 3:20CR126(JBA), Warren was also charged with

conduct warranted a total offense level of 41. Id. ¶ 194.

only summarized herein for ease of reference.

times by East End gang member Trevon Wright. See id.

b. Warren’s Murder of Ty’Quess Moore in the East End

discussed retaliating. That evening, at approximately 6:12 p.m., Shotspotter detected

Videos posted on Snapchat by ONE members on December 5, 2019 showed Warren

contacts, and other information that pertain to Warren and ONE.

i. Motive for shooting

he was going to kill an East End gang member.

(“Nd think about ya mom before you make that choice.”)

ii. Courthouse Shooting

guns to the GHB members planning to retaliate.

Jaheim Warren, both East End gang members.

• 1105: M. Isreal calling T. Warren’s cell 15 times (13 calls, 2 messages)

• 1106: M. Isreal calls Nina KcKoy’s cell two times

• 1139: D. Blackwell exits VW Golf and enters courthouse

• 11:41 D. Blackwell physically enters courthouse (GA-2 Video)

• 1142 D. Blackwell checking court list (GA-2 Video)

• A. Gaines GPS – arriving at courthouse – 207 Golden Hill Street

• 1142: A. Gaines FB Messenger A. Newsome “Wya”

• 1143: A. Gaines to M. Israel aka “freeziggy Garf” “Still here”

• 1144: D. Blackwell FaceTime call to A. Gaines (2:23)

• 1145: D. Blackwell exits courthouse and returns to VW Golf

• 1149: T. Warren texts Nina McKoy cell – “I love you more”

• 1150: T. Warren calls M. Isreal

• 1153: T. Warren calls M. Isreal

• 1156: Dc Foster to M. Isreal “Oh ok you GG” (GG = Good to Go)

Street prior to shooting (still photo)

• 1158: M. Isreal calls Derrick Ford

• 1205: A. Gaines FaceTime to L. Jones (1:02)

• 1207: A. Gaines FaceTime to L. Jones (0:19)

• 1208: A. Gaines FaceTime to L. Jones (0:51)

• 1211: Shot-Spotter activation detected

keep the victims alive.

iii. Post-shooting conduct

search on his cellphone for information about the courthouse shooting.

from the Walmart.

of the Subaru as it was found in Naugatuck.

not snitched on Warren and had taken one for him.

to have originated from Tyiese Warren.

d. Warren’s March 2, 2020 video

e. March 25, 2020 Hobbs Act Robbery and Carjacking

essentially empty. See https://www.ctpost.com/news/article/Photos-New-York-City-s-empty-

captured as he is dragged out of the parking lot.

inside in the direction of Stratford.

and followed the white BMW down Stratford Avenue.

hit another car and came to a stop on the on-ramp.

$1300 in cash was found inside the brown BMW.

where Newsome would have run to avoid capture.

C. Warren’s Post-Plea Conduct

the facility uninjured and in a separate cell.

Third Superseding Indictment. Id. ¶ 177.

conduct or associations (§ 3E1.1 of the Sentencing Guidelines) . . . .” Id. at 4. Warren’s conduct

general deterrence;” and the need “to protect the public.”

of 2020 after he was almost killed on January 27, 2020.