USA v. Harris et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA CRIMINAL ACTION
VERSUS NO. 24-105
RYAN J. HARRIS, ET AL. SECTION: D (1)
This Order applies to
Jason F. Giles and The
King Firm, LLC
ORDER AND REASONS
Before the Court is Defendants Jason Giles and The King Firm’s Motion to
Dismiss Count 1(D), Paragraph 8 (To the Extent It Alleges a Conspiracy to Utilize
“Runners”) or, In the Alternative, to Strike Count 1(D), Paragraph 8 as Surplus and
Prejudicial Language as to the Third Superseding Indictment.1 The Government
opposes the Motion,2 and Giles and the King Firm have filed a Reply.3
After careful consideration of the parties’ memoranda and the applicable law,
the Court DENIES the Motion to Dismiss.
I. FACTUAL AND PROCEDURAL BACKGROUND4
This case involves several defendants who are charged with various crimes
stemming from a years-long scheme to stage fake automobile collisions in the New
Orleans metropolitan area and file fraudulent insurance claims and fraudulent
1 R. Doc. 583.
2 R. Doc. 634.
3 R. Doc. 669.
4 In the interest of judicial economy, and because the factual background of this case was extensively
detailed in several prior Orders and Reasons issued by this Court (See R. Docs. 357, 481, 489, 641, 647,
& 692), the Court will limit its recitation of the factual and procedural background to matters relevant
to the instant Motion.
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lawsuits based on the staged collisions.5 That scheme allegedly involved “slammers”
who drove automobiles and intentionally collided with 18-wheeler tractor-trailers
and other commercial vehicles in order to stage collisions. Jason F. Giles and The
King Firm, LLC (collectively, “Defendants”) are charged in the Third Superseding
Indictment with conspiracy to commit mail and wire fraud (Count 1), mail fraud
(Count 2), obstruction of justice (Count 8), and witness tampering (Count 9).6 The
Government alleges in Count 1 that Damian Labeaud and Roderick Hickman staged
automobile collisions for Defendants between 2011 and 2017, that Defendants knew
the collisions were staged, and that Defendants paid Labeaud and Hickman for
bringing them staged collisions.7 In Counts 8 and 9, the Government alleges that
Defendants secretly recorded Hickman and manipulated him into falsely stating that
the collisions he and Labeaud staged were legitimate, and did so to obstruct or impede
the grand jury’s investigation into the staged collision scheme.8
Pertinent to the instant Motion, Count 1(D), Paragraph 8 of the Third
Superseding Indictment states that, “[i]n addition to staging collisions, Labeaud and
Hickman worked as illegal ‘runners’ for GILES and THE KING FIRM. As runners,
Labeaud and Hickman referred individuals involved in automobile collisions to
GILES and THE KING FIRM for money.”9 Defendants have now moved to dismiss
or, alternatively, to strike Count 1(D), Paragraph 8 of the Third Superseding
5 R. Docs. 1, 78, 256, & 517.
6 R. Doc. 517 at pp. 1–18 & 21–22.
7 Id. at pp. 7–10.
8 Id. at pp. 21–22.
9 Id. at p. 7.
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Indictment pursuant to Rules 7(d) and 12(b)(3) of the Federal Rules of Criminal
Procedure.10 Defendants seem to assert that Paragraph 8 will confuse the jury into
convicting them for paying runners, a violation of Louisiana law, instead of convicting
them for committing the charged conspiracy to commit mail and wire fraud.11
Defendants argue that Paragraph 8 should be dismissed for failure to state an offense
under Rule 12(b)(3) because it fails to describe a fraudulent scheme aimed at
obtaining money or property in the hands of the victim, as required by Supreme Court
and Fifth Circuit precedent.12 Alternatively, Defendants ask the Court to strike
Paragraph 8 pursuant to Rule 7(d) because it constitutes “highly prejudicial
surplusage.”13
The Government argues that the Motion should be denied because the Third
Superseding Indictment describes the object of the conspiracy charged in Count 1 as
knowingly filing fraudulent lawsuits based on staged collisions to obtain money from
insurance, trucking, and transportation companies, and describes the defendants’
scheme to pay slammers for collisions that they knew were staged.14 The Government
claims that the Third Superseding Indictment does not seek to punish Defendants for
violating Louisiana law by paying runners, and further asserts that the Government
will not argue to the jury that it should convict Defendants for that reason.15 The
10 R. Doc. 583.
11 Id. at p. 2; R. Doc. 583-1 at pp. 2–3.
12 R. Doc. 583 at pp. 2–3; R. Doc. 583-1 at pp. 3–5 (citing Cleveland v. United States, 531 U.S. 12, 15,
121 S.Ct. 365, 148 L.Ed.2d 221 (2000); Kelly v. United States, 590 U.S. 391, 394, 140 S.Ct. 1565, 206
L.Ed.2d 882 (2020); United States v. Greenlaw, 84 F.4th 325, 343–44 (5th Cir. 2023)).
13 R. Doc. 583-1 at pp. 6–7.
14 R. Doc. 634 at p. 20 (citing R. Doc. 517 at pp. 6–16).
15 R. Doc. 634 at p. 20.
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Government asserts that Paragraph 8 accurately states that Labeaud and Hickman
were both slammers who brought staged and “legitimate” cases to Defendants for
payment.16 The Government claims that Paragraph 8 provides necessary context for
understanding the relationship between Defendants and Lebeaud and Hickman, and
will be relevant and helpful to the jury’s determination of Defendants’ knowledge of
Labeaud and Hickman’s other illegal conduct.17
The Government further asserts that the fact that Defendants paid Labeaud
and Hickman to be illegal runners is significant to the obstruction of justice and
witness tampering allegations in Paragraphs 16 through 20 of Count 1, as well as
Counts 8 and 9.18 The Government points out that those portions of the Third
Superseding Indictment include allegations that Defendants manipulated Labeaud
and Hickman into making false statements during conversations that Defendants
secretly recorded and that Giles made false statements during the recordings
regarding paying Labeaud and Hickman for referrals, which are relevant to whether
Defendants acted with corrupt intent when they made the recordings, as charged in
Counts 8 and 9.19 The Government argues that the cases cited by Defendants in their
Motion are inapposite because the object of the conspiracy in this case was to deprive
insurance, trucking, and transportation companies of money and not some other form
of property.20 The Government also asserts that Defendants ignore the presumption
16 R. Doc. 634 at p. 20 (citing R. Doc. 517 at pp. 6–7).
17 R. Doc. 634 at p. 21.
18 Id. at pp. 21–22 (citing R. Doc. 517 at pp. 10–11 & 21–22).
19 R. Doc. 634 at p. 22.
20 Id. (citing United States v. Ryan, 156 F.4th 583, 592–94 (5th Cir. 2025)).
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that the jury will follow the Court’s instructions,21 and asserts that the Court can give
a curative instruction if necessary.22
In response, Defendants assert that, contrary to the Government’s assertion in
its Opposition brief, the documents produced by the Government in discovery indicate
that it will suggest to the jury that Defendants should be convicted for paying illegal
runners.23 As such, Defendants maintain their request to strike Count 1(D),
Paragraph 8 because it references “illegal runners.”24
II. LEGAL STANDARD
A. Motion to Dismiss Indictment
Federal Rule of Criminal Procedure 7(c) requires an indictment to contain “a
plain, concise and definite written statement of the essential facts constituting the
offense charged,” and to state for each count, “the official or customary citation of the
statute, rule, regulation or other provision of law which the defendant is alleged to
have violated.”25 As explained by the Fifth Circuit, “[u]nder the Sixth Amendment,
an indictment must ‘(1) enumerate each prima facie element of the charged offense;
(2) inform the defendant of the charges filed against him; and (3) provide the
defendant with a double jeopardy defense against future prosecutions.’”26 According
to the Fifth Circuit, “an indictment is sufficient if it ‘contains the elements of the
offense charged and fairly informs the defendant of the charge against which he must
21 R. Doc. 634 at p. 22 (citing United States v. Reed, 908 F.3d 102, 115 n.42 (5th Cir. 2018)).
22 R. Doc. 634 at pp. 22–23.
23 R. Doc. 669 at pp. 1–2.
24 Id. at p. 2.
25 Fed. R. Crim. P. 7(c)(1).
26 United States v. Guzman-Ocampo, 236 F.3d 233, 236 (5th Cir. 2000) (quoting United States v.
Gaytan, 74 F.3d 545, 551 (5th Cir. 1996)).
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defend.’”27 “It is not necessary for an indictment to go further and to allege in detail
the factual proof that will be relied upon to support the charges.”28 “Generally, an
indictment which follows the language of the statute under which it is brought is
sufficient to give a defendant notice of the crime of which he is charged.”29
Rule 12(b) of the Federal Rules of Criminal Procedure permits a defendant to
raise by a pretrial motion, “[a]ny defense, objection, or request that the court can
determine without a trial on the merits.”30 In the instant Motion, Defendants seek
dismissal of Count1(D), Paragraph 8 of the Third Superseding Indictment for failure
to state an offense under Fed. R. Crim. P. 12(b)(3)(B)(v).31 According to the Fifth
Circuit, “[t]he propriety of granting a motion to dismiss an indictment . . . by pretrial
motion is by-and-large contingent upon whether the infirmity in the prosecution is
essentially one of law or involves determinations of fact . . . . If a question of law is
involved, then consideration of the motion is generally proper.”32 When considering
a motion to dismiss the indictment for failure to state an offense, a court is required
to “take the allegations of the indictment as true and to determine whether an offense
27 United States v. Lawrence, 727 F.3d 386, 397 (5th Cir. 2013) (quoting Unites States v. Fuller, 974
F.2d 1474, 1480 (5th Cir. 1992)).
28 United States v. Crippen, 579 F.2d 340, 342 (5th Cir. 1978).
29 United States v. Thomas, 348 F.3d 78, 82 (5th Cir. 2003) (quoting United States v Ramirez, 233 F.3d
318, 323 (5th Cir. 2000), overruled on other grounds by United States v Longoria, 298 F.3d 367 (5th
Cir. 2002)) (citation modified)); See United States v. Massey, 849 F.3d 262, 264 (5th Cir. 2017) (same).
30 Fed. R. Crim. P. 12(b)(1).
31 R. Doc. 583-1 at p. 3.
32 United States v. Fontenot, 665 F.3d 640, 644 (5th Cir. 2011) (quoting United States v. Flores, 404
F.3d 320, 324 (5th Cir. 2005), abrogated on other grounds as recognized by United States v. Garcia,
707 Fed.Appx. 231 (5th Cir. 2017)).
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has been stated.”33 Additionally, “[a] court must deny a motion to dismiss if the
motion relies on disputed facts.”34
B. Motion to Strike Surplusage
Federal Rule of Criminal Procedure 7(d) provides that, “[u]pon the defendant’s
motion, the court may strike surplusage from the indictment or information.” “The
mere fact that information in an indictment does not constitute an element of the
charged offense does not require that it be stricken.”35 Instead, “[s]urplusage in an
indictment may generally be disregarded where the charge is not materially
broadened and the accused is not misled.”36 The Fifth Circuit has held that, “[f]or
language to be struck from an indictment, it must be irrelevant, inflammatory, and
prejudicial.”37 According to the Fifth Circuit, “[t]he inclusion of clearly unnecessary
language in an indictment that could serve only to inflame the jury, confuse the
issues, and blur the elements necessary for conviction under the separate counts
involved surely can be prejudicial.”38 The Fifth Circuit has made clear, however that,
“[w]here information in an indictment is sufficiently relevant to the charged offense,
33 United States v. USPlabs, LLC, 338 F. Supp. 3d 547, 557 (N.D. Tex. 2018) (quoting United States v.
Kay, 359 F.3d 738, 742 (5th Cir. 2004)) (citation modified).
34 USPlabs, LLC, 338 F. Supp. 3d at 557 (citing United States v. Covington, 395 U.S. 57, 60, 89 S.Ct.
1559, 23 L.Ed.2d 94 (1969) (holding that a court can resolve a pretrial motion to dismiss the indictment
only when “trial of the facts surrounding the commission of the alleged offense would be of no
assistance in determining the validity of the defense”)).
35 United States v. Solomon, 273 F.3d 1108 (5th Cir. 2001) (citing United States v. Scarpa, 913 F.2d
993, 1013 (2d Cir. 1990)).
36 United States v. Trice, 823 F.2d 80, 89 n.8 (5th Cir. 1987).
37 United States v. Graves, 5 F.3d 1546, 1550 (5th Cir. 1993) (citing United States v. Bullock, 451 F.2d
884, 888 (5th Cir. 1971).
38 Bullock, 451 F.2d at 888.
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the court should not strike it, no matter how prejudicial it may be.”39 Further, “[t]his
standard is ‘exacting’ and strict, and as a result, the motion is rarely granted.”40
III. ANALYSIS
A. Motion to Dismiss Count 1(D), Paragraph 8
Defendants are charged in Count 1 of the Third Superseding Indictment with
conspiracy to commit mail and wire fraud, in violation of 18 U.S.C. § 1349.41 Section
1349 provides that, “[a]ny person who attempts or conspires to commit any offense
under this chapter shall be subject to the same penalties as those prescribed for the
offense, the commission of which was the object of the attempt or conspiracy.”42
According to the Fifth Circuit, the elements of conspiracy under § 1349 are: (1) two
or more persons made an agreement to commit an unlawful act; (2) the defendant
knew the unlawful purpose of the agreement; and (3) the defendant joined in the
agreement willfully, with the intent to further the unlawful purpose.43 “An
agreement may be inferred from concert of action, voluntary participation may be
inferred form a collection of circumstances, and knowledge may be inferred from
surrounding circumstances.”44 The Fifth Circuit has further held that the elements
of mail fraud under 18 U.S.C. § 1341 are: (1) a scheme to defraud; (2) use of the mails
39 Solomon, 273 F.3d 1108 (citing Scarpa, 913 F.2d at 1013).
40 United States v. Edwards, 72 F. Supp. 2d 664, 667 (M.D. La. 1999) (citing Bullock, 451 F.2d at 888;
United States v. Johnson, Crim. A. No. 98-276, 1999 WL 551332 (E.D. La. June 10, 1999) (Sear, J.);
United States v. Oakar, 111 F.3d 146, 157 (D.C. Cir. 1997)). See also 1 Charles A. Wright, Federal
Practice and Procedure, § 127 at p. 639 (3d ed. 1999).
41 R. Doc. 517 at p. 18.
42 18 U.S.C. § 1349.
43 United States v. Simpson, 741 F.3d 539, 547 (5th Cir. 2014) (citing United States v. Grant, 683 F.3d
639, 643 (5th Cir. 2012)).
44 Simpson, 741 F.3d at 547 (quoting Grant, 683 F.3d at 643) (citation modified).
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to execute the scheme; and (3) the specific intent to defraud.45 Similarly, the elements
of wire fraud under 18 U.S.C. § 1343 are: (1) a scheme to defraud; and (2) the use of,
or causing the use of, wire communications in furtherance of the scheme.”46
In Count 1 of the Third Superseding Indictment, the Government alleges the
following conspiracy to commit mail and wire fraud:
Beginning at a time unknown, but as early as approximately December
12, 2011, and continuing until on or about December 6, 2024, in the
Eastern District of Louisiana and elsewhere, the defendants, SEAN
ALFORTISH, VANESSA MOTTA, MOTTA LAW, LLC, JASON F.
GILES, THE KING FIRM, LLC, LEON M. PARKER, a/k/a
“Chunky,” DIAMINIKE F. STALBERT, CARL G. MORGAN,
TIMARA N. LAWRENCE, and others known and unknown to the
Grand Jury, did knowingly and willfully combine, conspire, confederate,
and agree:
a. to devise a scheme and artifice to defraud and to obtain money
and property from insurance companies and commercial
vehicle companies by means of materially false and fraudulent
pretenses, representations, and promises, and cause mail
matter to be delivered by the United States Postal Service and
by any private or commercial interstate carrier for the purpose
of executing or attempting to execute the scheme to defraud,
in violation of Tile 18, United States Code, Section 1341; and
b. devise a scheme and artifice to defraud and to obtain money
and property from insurance companies and commercial
vehicle companies by means of materially false and fraudulent
pretenses, representations, and promises, and cause signals
and sounds to be transmitted by means of wire communication
in interstate commerce for the purpose of executing or
45 Simpson, 741 F.3d at 547 (quoting Grant, 683 F.3d at 643) (citation modified).
46 Simpson, 741 F.3d at 547–48 (quoting United States v. Stalnaker, 571 F.3d 428, 436 (5th Cir. 2009))
(citation modified).
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attempting to execute the scheme to defraud, in violation of
Title 18, United States Code, Section 1343.47
The Government then lists the members of the conspiracy, to include Defendants,48
and sets forth the manner and means of the conspiracy, alleging that there was a
conspiracy by all of the defendants to intentionally stage automobile collisions,
including with 18-wheeler tractor-trailers, for the purpose of filing fraudulent
insurance claims or lawsuits, that the defendants recruited other people to
participate in staged collisions, and that the defendants utilized the mail and
interstate wirings to file and pursue fraudulent insurance claims and lawsuits based
on staged collisions.49 The Third Superseding Indictment then describes a scheme
whereby Labeaud and Hickman staged accidents for Defendants who filed fraudulent
lawsuits based on the staged accidents,50 and a scheme in which Cornelius Garrison
and Ryan Harris staged accidents for Defendants, Alfortish, Motta, and Motta Law
who then filed fraudulent lawsuits based on those staged accidents.51 As part of the
scheme involving the collisions that Labeaud and Hickman staged for Defendants,
the Government alleges in Count 1(D), Paragraph 8 that, “[i]n addition to staging
collisions, Labeaud and Hickman worked as illegal ‘runners’ for GILES and THE
KING FIRM. As runners, Labeaud and Hickman referred individuals involved in
automobile collisions to GILES and THE KING FIRM for money.”52
47 R. Doc. 517 at pp. 3–4.
48 Id. at pp. 4–6.
49 Id. at p. 6.
50 Id. at pp. 7–11.
51 Id. at pp. 12–18.
52 Id. at p. 7.
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Taking the allegations of the Third Superseding Indictment as true, as the
Court is required to do,53 the Court finds that Count 1 sufficiently states an offense
for conspiracy under 18 U.S.C. § 1349, and sufficiently states, as the objects of the
conspiracy, mail fraud in violation of 18 U.S.C. § 1341 and wire fraud in violation of
18 U.S.C. § 1343. The Court specifically finds that Count 1 sets forth all of the
elements of the offense of conspiracy to commit mail and wire fraud by alleging that
the named defendants acted in concert to hire individuals to stage accidents so that
they could file fraudulent insurance claims and fraudulent lawsuits based upon the
staged accidents, and that they used the mails and wire communications to file the
fraudulent claims and lawsuits. Notably, Defendants fail to address the elements of
a conspiracy to commit mail and wire fraud claim in their briefs.54 While Defendants
challenge Paragraph 8 of Count 1(D) because it alleges that Defendants paid
Hickman and Labeaud to illegally refer clients to them for both staged and
“legitimate” accidents, Count 1 does not charge Defendants with a conspiracy to
commit mail and wire fraud based upon their alleged use of illegal runners. The
Court agrees with the Government that the object of the conspiracy charged in Count
1 is to deprive insurance and commercial vehicle companies of money, and not some
other form of property. Defendants likewise fail to mention that Paragraph 8 is part
of the 32 paragraphs in Count 1 that set forth the manner and means of the
53 United States v. Kay, 359 F.3d 738, 742 (5th Cir. 2004) (quoting United States v. Hogue, 132 F.3d
1087, 1089 (5th Cir. 1998)).
54 See R. Docs. 583 & 669.
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conspiracy, all of which detail how the scheme to defraud was carried out by each
named defendant.
According to the Fifth Circuit, “[a]s long as the statutory language of the
charged offense unambiguously sets out all the necessary elements, an indictment
setting forth the offense in the words of the statute itself is generally sufficient.”55
The Court finds that Count 1 tracks the language of 18 U.S.C. §§ 1341, 1343, & 1349,
and that all of the required elements are included in the statutory language. The
Court further finds that Count 1 of the Third Superseding Indictment contains the
essential elements of a conspiracy to commit mail and wire fraud under 18 U.S.C. §
1349, where the objects of the conspiracy are mail fraud and wire fraud, and fairly
informs Defendants of the charge against them so that Defendants can defend against
the charge. Accordingly, to the extent Defendants seek to dismiss Count 1(D),
Paragraph 8 of the Third Superseding Indictment pursuant to Fed. R. Crim. P.
12(b)(3)(B)(v), the Motion is denied.
B. Alternative Motion to Strike Surplus Language in Count 1(D),
Paragraph 8
In the alternative, Defendants assert that if the Court does not dismiss Count
1(D), Paragraph 8, it should strike the entire paragraph as “highly prejudicial
surplusage” that may confuse and mislead the jury.56 The Court finds that this
language could potentially be confusing to the jury since it alleges that Defendants
violated the law by paying Hickman and Labeaud for referring clients, without
55 United States v. Hagemann, 950 F.2d 175, 183 (5th Cir. 1991).
56 R. Doc. 583-1 at pp. 6–7.
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specifying that this activity is illegal under Louisiana law. Nonetheless, to be
stricken, the alleged surplusage must be irrelevant, inflammatory, and prejudicial.57
While the contested language may be potentially confusing, the Court does not find
that the language is irrelevant, inflammatory, and prejudicial. Instead, the Court
finds that it may be relevant as helpful context for the crimes charged in Counts 1, 8,
and 9 of the Third Superseding Indictment. As the Government points out, this
information may be relevant to the jury’s determination regarding Defendants’
knowledge of Hickman and Labeaud’s other illegal conduct for purposes of Count 1.
It may also be relevant to the obstruction of justice and witness tampering charges
in Counts 8 and 9, and the allegations that Defendants manipulated Labeaud and
Hickman into making false statements during conversations that Defendants
secretly recorded. The Government alleges that during these recorded conversations,
Giles made several false representations, including the suggestion that he never paid
Labeaud or Hickman for referrals. As the Fifth Circuit has pointed out in similar
cases, “intent ‘will almost always have to be established by circumstantial
evidence.’”58 Further, and importantly, the jury will be given instructions that will
make clear to them what Defendants are actually charged with and the elements of
each charge that must be proven by the Government. This cures any potential
prejudice from any alleged surplusage. As such, the Court finds that Defendants
have failed to satisfy the “exacting” and strict standard required to strike information
57 United States v. Graves, 5 F.3d 1546, 1550 (5th Cir. 1993) (citing United States v. Bullock, 451 F.2d
884, 888 (5th Cir. 1971).
58 United States v. Jena, 478 Fed.Appx. 99, 101–02 (5th Cir. 2012) (quoting United States v. Sandlin,
589 F.3d 749, 755 (5th Cir. 2009)).
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from the Third Superseding Indictment, and denies their request to strike Count
1(D), Paragraph 8.
IV. CONCLUSION
For the reasons set forth above, Defendants Jason Giles and The King Firm’s
Motion to Dismiss Count 1(D), Paragraph 8 (To the Extent It Alleges a Conspiracy to
Utilize “Runners”) or, In the Alternative, to Strike Count 1(D), Paragraph 8 as
Surplus and Prejudicial Language as to the Third Superseding Indictment59 is
DENIED.
New Orleans, Louisiana, February 27, 2026.
______________________________
WENDY B. VITTER
United States District Judge
59 R. Doc. 583.
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