Case 2:24-cr-00122-RDP-NAD Document 1 Filed 03/28/24 Page 1 of 7 FILED

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GJ #3 U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION

UNITED STATES OF AMERICA )

) No.
v. )
)
CARLTON LENARD ADAMS, )
)
Defendant. )

INDICTMENT

The Grand Jury charges:

INTRODUCTION

At all times relevant to this Indictment:

1. An “animal fighting venture” was “any event, in or affecting interstate

or foreign commerce, that involves a fight conducted or to be conducted between at

least 2 animals for purposes of sport, wagering, or entertainment.” 7 U.S.C.

§ 2156(f)(1).

2. Defendant Carlton Lenard Adams lived part-time at a residence in

Adger, Alabama, and part-time at a residence in Bessemer, Alabama, both residences

located within the Northern District of Alabama.

3. Defendant Carlton Lenard Adams maintained a stock of sixty-two

fighting dogs at the property where he resided part-time in Adger, Alabama.

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4. Defendant Carlton Lenard Adams maintained a stock of ten additional

fighting dogs at the property where he resided part-time in Bessemer, Alabama.

5. Defendant Carlton Lenard Adams maintained a stock of six additional

fighting dogs at the home of an acquaintance who lived near Adams’s residence in

Bessemer, Alabama.

6. Defendant Carlton Lenard Adams, at his residences in Adger and

Bessemer, maintained tools and supplies used in the training and keeping of dogs

used for fighting, including: modified treadmills to hold dogs in place for dog fight

conditioning, injectable veterinary steroids, suture materials and syringes, skin

staplers, intravenous bags and lines, a weighted dog vest, a home-made “breeding

stand” used to immobilize female dogs for breeding who are too dog-aggressive to

mate naturally, and a “break stick” device used to break the bite hold of a dog during

specified intervals in a dog fight.

COUNTS ONE THROUGH FIFTEEN

Knowingly Possessing a Dog for Purposes of Having the Dog
Participate in an Animal Fighting Venture
[7 U.S.C. § 2156(b); 18 U.S.C. §§ 49 & 2]

7. Paragraphs 1 through 6 of this Indictment are incorporated and re-

alleged herein.

8. On or about September 12, 2023, in Jefferson County, within the

Northern District of Alabama, the defendant,

CARLTON LENARD ADAMS,

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knowingly possessed a dog for the purpose of having the dog participate in an animal

fighting venture, namely:

COUNT DOG INVENTORY NO.

1 USM-1384
2 USM-1385
3 USM-1386
4 USM-1387
5 USM-1388
6 USM-1389
7 USM-1392
8 USM-1399
9 USM-1406
10 USM-1415
11 USM-1419
12 USM-1431
13 USM-1442
14 USM-1446
15 USM-1460

All in violation of Title 7, United States Code, Section 2156(b) and Title 18,

United States Code, Sections 49 and 2.

COUNT SIXTEEN
Felon in Possession of a Firearm
[18 U.S.C. § 922(g)(1)]

9. On or about September 12, 2023, in Jefferson County, within the

Northern District of Alabama, the defendant,

CARLTON LENARD ADAMS,

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knowing he had previously been convicted of a crime punishable by imprisonment

for a term exceeding one year, knowingly possessed at least one of the following

firearms, that is, a Smith & Wesson, Bodyguard model, .38 caliber pistol and a Bravo

Company Manufacturing, Inc., model KMR-A, .300 BLK pistol, said firearm having

been shipped and transported in interstate commerce. The defendant was previously

convicted of First Degree Assault, which is a crime punishable by imprisonment for

a term exceeding one year, on or about September 22, 2000, in the Circuit Court of

Jefferson County, Alabama, in Case No. 1999-004873.

All in violation of Title 18, United States Code, Section 922(g)(1).

COUNT SEVENTEEN
Felon in Possession of a Firearm
[18 U.S.C. § 922(g)(1)]

10. On or about September 12, 2023, in Jefferson County, within the

Northern District of Alabama, the defendant,

CARLTON LENARD ADAMS,

knowing he had previously been convicted of a crime punishable by imprisonment

for a term exceeding one year, knowingly possessed a firearm, that is, a

Cobray/SWD Co., Street Sweeper model, 12-gauge shotgun, said firearm having

been shipped and transported in interstate commerce. The defendant was previously

convicted of First Degree Assault, which is a crime punishable by imprisonment for

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a term exceeding one year, on or about September 22, 2000, in the Circuit Court of

Jefferson County, Alabama, in Case No. 1999-004873.

All in violation of Title 18, United States Code, Section 922(g)(1).

NOTICE OF FORFEITURE
[18 U.S.C. § 924(d)(1) and 28 U.S.C. § 2461]

1. The allegations contained in Counts Sixteen and Seventeen of this

Indictment are hereby re-alleged and incorporated by reference into this Notice for

the purpose of alleging forfeiture to the United States of America, pursuant to the

provisions of Title 18, United States Code, Section 924(d)(l), in conjunction with

Title 28, United States Code, Section 2461(c).

2. Upon conviction of any of the offenses in violation of Title 18, United

States Code, Sections 922(g)(l), set forth in Counts Sixteen and Seventeen of this

Indictment, the defendant, Carlton Lenard Adams, shall forfeit to the United States

of America pursuant to Title 18, United States Code, Section 924(d)(l), in

conjunction with Title 28, United States Code, Section 2461(c), any firearms and

ammunition involved in the commission of the offense(s).

3. If any of the property subject to forfeiture, as a result of any act or

omission of the defendant:

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

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

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

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(d) has been substantially diminished in value; or

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

without difficulty,

the United States of America shall be entitled to forfeiture of substitute property

pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title

28, United States Code, Section 246l(c), through Title 18, United States Code,

Section 924(d)(l).

All pursuant to 18 U.S.C. § 924(d)(l) and 28 U.S.C. § 246l(c).

A TRUE BILL

/s/ Electronic Signature_______________

FOREPERSON OF THE GRAND JURY

PRIM F. ESCALONA
United States Attorney

/s/ electronic signature ___________

Ryan S. Rummage
Assistant United States Attorney

TODD S. KIM
Assistant Attorney General

/s/ Electronic Signature_______________

ETHAN EDDY

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Senior Trial Attorney

U.S. Department of Justice
Environment and Natural Resources Division
Environmental Crimes Section