A memorandum in aid of sentencing spells out the government’s requested range.
The memo filed Wednesday in the federal court record does not include an outline for the first person to take a plea in the case, Wardie Vincent Jr. Previous documents filed indicate he could face 9 to 11 ½ years in the case.
Clanton could face 11 ¼ years to 14 years. Jacobs could face 10 years, according to the document filed by United States States Attorney John Stuart Brice.
Antonio Tillmon, the only person to not take a plea, was recently found guilty and will be sentenced in September.
In the preface to the 32-page document Brice writes, “Honorable law enforcement officers take risks and make sacrifices to secure public safety and to honor the trust the public bestows on them. The defendants before the court instead exploited their law enforcement affiliations for personal gain, accepting thousands of dollars in bribes to serve as an armed guard service for what they believed was a criminal drug trafficking organization.
“Such a gross abuse of the public trust demands serious punishment. Accordingly, the government recommends that each defendant receive a custodial sentence commensurate with his or her role in the drug, weapons, and bribery crimes committed.”

Sentencing is expected next week in Greenville.

Offense conduct

In April 2013, in response to allegations of systemic corruption in the Northampton County Sheriff’s Office, the Federal Bureau of Investigation opened an undercover investigation in which undercover agents posed as members of a drug trafficking organization.
In their roles, the undercover agents informed the defendants that the DTO sought law enforcement officers who would act as armed guards for illegal narcotics and narcotics proceeds as the drugs and money were moved along the East Coast.
“The defendants willingly joined the enterprise and in many cases, recruited others to join as well,” the document says. “In the course of the investigation, fifteen individuals were recorded transporting purported illegal narcotics and narcotics proceeds for the DTO in exchange for bribe payments. Many defendants carried firearms and their law enforcement credentials during the illicit activity.”

Clanton: Recommended sentence 11 ¼ to 14 years

The FBI initiated its investigation because of reports Clanton, a sworn law enforcement officer, was involved in selling illegal drugs and associated with known drug dealers.
“Throughout the investigation, which began in August 2013 and lasted almost two years, Clanton, a former police officer with the Weldon Police Department, proved that those allegations were true,” Brice wrote.
Clanton started on August 22, 2013, when he extorted $10,000 in an armed robbery of an undercover agent whom he thought was a drug courier. “Stretching to his arrest in April 2015, Clanton participated enthusiastically in repeated operations as an armed guard for purported illegal drugs and drug proceeds across state borders.
“Perhaps more importantly, Clanton was the corrupt root from which the conspiracy grew to include fourteen other individuals willing to aid what they believed was a drug trafficking organization.”
Clanton’s first involvement with the DTO was to willingly commit armed robbery.
On August 22, 2013, having been told by an FBI undercover agent that a money courier for the DTO would be staying at a hotel, Clanton planned to rob the purported courier.
He went to the hotel room with his gun and handcuffs and announced that he was a police officer. Clanton then announced to the courier — who, unbeknownst to Clanton, was another undercover agent — that “we can do this two ways: I can take the money and go, or I can call my friends,” implying the courier could give Clanton the money and remain silent, or he could be arrested.
The undercover agent provided Clanton the $10,000 in cash he had demanded, and he took it and left the room. “Notably, the words that Clanton used as he conducted this robbery echoed the words he had previously told an FBI source that he had used when he was an on-duty police officer and extorted those he stopped, keeping their contraband for himself.”

Assisting the DTO

From that time, Clanton not only continued to assist the DTO with the transportation of purported drugs or drug proceeds on more than 10 separate occasions, he assumed a leadership role and actively recruited five additional defendants, whose roles he assigned and whose participation he supervised.
In January 2014, as he began to recruit additional co-conspirators, Clanton attended an interdiction class taught by Vincent, one of Clanton’s recruits. “This class used Clanton’s and Vincent’s law enforcement training and experience for the perverse purpose of teaching the members of the conspiracy to avoid legitimate law enforcement detection while transporting illegal narcotics,” the memorandum says.
In addition to the five people he successfully recruited, Clanton unsuccessfully tried to bring another Northampton County deputy sheriff into the conspiracy in May 2014, going so far as to arrange a meeting between the undercover agents and the potential recruit. “After the deputy sheriff heard the description of the organization, and even that he would be paid $2,000 per operation, he refused to participate.”
In April 2014, Clanton and his co-conspirators started to transport purported drugs as well as purported drug proceeds.
Clanton accepted from the DTO a trip to Miami where he met on a yacht with undercover agents posing as members of the DTO and accepted from them a Rolex watch worth $9,000.
“Early in the investigation, Clanton told an undercover FBI agent that he would be useful to the DTO because he had a police shirt and gun, and, as he ultimately admitted upon his arrest, he followed through on this promise and carried a firearm during the operations.”
At the time of his arrest, Clanton was carrying a .40-caliber semiautomatic pistol with ample ammunition.
In total, Clanton attempted to transport 65 kilograms of cocaine, 40 kilograms of heroin, and $2,250,000 in illegal narcotics proceeds. For these actions, he received $41,350 in extortion proceeds and payments.

Jacobs: Recommended sentence 10 years

Jacobs, a deputy sheriff with the Northampton County Sheriff’s Office, was the second defendant to participate in the investigation. “After she was recruited by Lann Tjuan Clanton, Jacobs quickly established herself as an eager participant in the DTO’s activities, and ultimately recruited and organized her own team of co-conspirators,” Brice wrote.
Clanton introduced Jacobs to the undercover agents posing as drug traffickers in October 2014, at a meeting she attended in uniform and in her patrol car, while on duty. “In the ensuing months, Jacobs assisted Clanton in transporting purported drug proceeds and helped him recruit additional co-conspirators, including Adrienne Moody, who would ultimately form a separate team with Jacobs.”
In April 2014, Jacobs traveled to Miami on a trip funded by the purported DTO, met undercover agents posing as drug traffickers on a yacht, and accepted a Rolex watch worth more than $2,000.
In the summer of 2014, Jacobs asked the DTO pay to send her to the 2014 North Carolina Narcotics Officer Conference, a law enforcement training session to which her sheriff’s office would not pay to send her. “Jacobs stated that she would share the information she received with the DTO to help avoid detection. The DTO agreed to pay for the conference and Jacobs attended.”

Previous DTO ties

Jacobs also stated to undercover agents that she had previously worked with a different DTO doing similar work and proposed she begin regularly purchasing large kilogram amounts of cocaine that she would then resell on her own.
“Jacobs understood that the DTO was seeking law enforcement officers to assist it, and she and her teammate Adrienne Moody successfully recruited corrections officers Alaina Sue-Kam-Ling and Kavon Phillips, as well as Antonio Tillmon, a Windsor police officer.
“Because undercover agents had rebuffed Jacobs’ efforts to introduce individuals without law enforcement affiliations into the organization, Jacobs coached Crystal Pierce, who had no connection to law enforcement, to lie to the agents and claim she was a correctional officer.”
Brice said Jacobs participated in operations with the DTO with full understanding that she was expected to use her gun and badge if necessary. “Undercover agents observed that Jacobs was armed during the operations, and on the day she was arrested, Jacobs possessed a loaded semi-automatic handgun.”
In total, Jacobs participated in eight operations, attempting to transport 35 kilograms of cocaine, 30 kilograms of heroin, and $2,250,000 in illegal drug proceeds. In return, she accepted approximately $25,250 in bribes.

Jason Boone: Recommended sentence 9 to 11 ¼ years

A deputy sheriff with the NCSO, Boone was recruited early in the course of the investigation by Clanton.
Beginning in February 2014, Boone went on to participate in seven operations over the course of more than a year.
Boone attended the interdiction class given by Vincent “in which the conspirators with law enforcement experience, including Boone, turned that training on its head and used it to subvert the law rather than uphold it.”
Boone also assisted in the recruitment of co-conspirators Jimmy Pair and Cory Jackson, who were respectively a current and former deputy sheriff with the Northampton County Sheriff’s Office.
Boone had with him a loaded semi-automatic pistol and ankle holster on day of arrest.
In total, Boone attempted to transport 55 kilograms of cocaine, 40 kilograms of heroin, and $1,500,000 in illegal drugs.
In return, he accepted approximately $15,500 in bribes.

Moody: Recommended sentence 8 to 10 years

Moody, a correctional officer with the North Carolina Department of Public Safety, first joined in activities with the DTO in February 2014, when she transported what she believed to be illegal drug proceeds.
Ultimately, Moody participated in six operations guarding what she believed to be drugs and drug proceeds.
On more than one operation, Moody traveled in the vehicle in which purported drugs were hidden for transportation.
She also demonstrated a willingness to become more deeply involved in the drug trade; on March 26, 2015, Moody asked one of the undercover agents, whom she believed to be a drug trafficker, to sell her 10 kilograms of cocaine so she could resell it herself.
Moody understood the DTO was seeking law enforcement officers to assist it, and she helped Jacobs successfully recruit corrections officers Alaina Sue-Kam-Ling and Kavon Phillips. In order to expand the conspiracy and to collect a bonus recruitment bribe, Moody represented to undercover officers that Crystal Pierce, who had no connection to law enforcement, was a correctional officer.
In total, Moody attempted to transport 35 kilograms of cocaine, 30 kilograms of heroin, and $2,000,000 in illegal drug proceeds. In return, she accepted approximately $14,500 in bribes.

Jackson: Recommended sentence 9 to 11 ¼ years

Jackson, a former deputy sheriff with the NCSO, joined the conspiracy early in the investigation, in February 2014, and ultimately strategized and recruited for the purported drug trafficking organization.
Upon payment in his very first operation on February 20, 2014, Jackson warned his co-conspirators to watch their speed when driving, presumably to avoid detection by legitimate law enforcement.
On October 22, 2014, he assisted in loading packages of sham drugs into a tractor-trailer. He actively and successfully recruited two other co-conspirators, Jimmy Pair Jr. and Thomas Jefferson Allen II, both deputy sheriffs in the Northampton County Sheriff’s Office.
At the time of his arrest, Jackson was carrying his NCSO credentials, even though he was no longer employed as a law enforcement officer.
In total, Jackson participated in six operations and attempted to transport 30 kilograms of cocaine and 40 kilograms of heroin.
In return,he accepted approximately $11,000 in payments.

Pair: Recommended sentence 7 ¼ to 9 years

Pair was a deputy with the NCSO when he was recruited by Jackson in May 2014.
Over the course of the six operations in which he participated, Pair took an active role, carrying a firearm and, on one occasion, driving the vehicle in which the sham drugs had been loaded.
In addition, Pair recruited into the conspiracy Tohsa Dailey, a 911 emergency dispatch operator with whom he had a romantic relationship.
At the time of his arrest on April 30, 2015, Pair had with him his badge as well as a semi-automatic rifle, semi-automatic pistol, and two magazines and sufficient ammunition for each firearm.
In total, Pair attempted to transport 30 kilograms of cocaine and 40 kilograms of heroin. In return, he accepted approximately $11,000 in bribes.

Curtis Boone: Recommended sentence 7 ¼ to 9 years

Curtis Boone, a deputy sheriff with the NCSO, first agreed to meet with the undercover officers posing as drug traffickers in February 2014, and he arranged to do so at Northampton County High School, where he was working as an off-duty officer in uniform and wearing his service weapon.
In that meeting, Boone expressed his willingness to participate in operations. During one operation, Boone drove the car in which the purported drugs had been hidden; on another date, he displayed his firearm to an agent.
Over the course of the investigation, Boone participated in six operations, and attempted to transport 30 kilograms of cocaine, 30 kilograms of heroin, and $1,500,000 in illegal drug proceeds. In return, he accepted approximately $10,000 in bribes.
At the time of his arrest, Boone had with him his Northampton County Sheriff’s Office identification, as well as a semi-automatic pistol with sufficient ammunition.

Allen: Recommended sentence 7 ¼ to 9 years

When he first participated in an operation in May 2014, Allen was a deputy sheriff at the NCSO. “And though Allen participated in only one operation, his participation was notable: he enthusiastically attempted to further the DTO by offering advice and strategy, and by attempting to recruit others. In particular, he stated to the undercover officers, whom he believed to be drug traffickers, that he had ties to criminal associates in Russia and that he wanted to connect the DTO to a criminal network in Russia.”
He provided advice on how to avoid being monitored through GPS functions on cell phones. Allen tried unsuccessfully to recruit a former Halifax County Deputy Sheriff, who declined to participate, and Allen told undercover agents that he wanted to recruit others into the organization.
In total, Allen attempted to transport 20 kilograms of cocaine and accepted approximately $2,000 in bribes.
At the time of his arrest, Allen was carrying his badge, a semi-automatic pistol and ammunition, and he admitted to having carried the pistol during his operation with the DTO.

Sue-Kam-Ling: Recommended sentence 4 ¼ to 5.9 years

Sue-Kam-Ling, a correctional officer with the North Carolina Department of Public Safety, was recruited by Jacobs and Moody to participate in activities with the DTO in August 2014.
She was one of the members of “Team Two,” the separate team started by Jacobs and Moody in a split from Clanton’s “Team One.”
Sue-Kam-Ling ultimately participated in three operations, guarding purported heroin across state borders, before returning a fourth time on her arrest date.
In October 2014, she rode in the car in which the sham drugs were hidden.
During her third operation on March 26, 2015, Sue-Kam-Ling accepted a gun from her co-conspirator, Tillmon. On the day of her arrest, Sue- Kam-Ling had her North Carolina Department of Public Safety identification, a semi-automatic pistol, and ammunition.
In total, Sue-Kam-Ling attempted to transport 10 kilograms of cocaine and 30 kilograms of heroin. In return, she accepted approximately $6,500 in payments.

Kavon Philips: Recommended sentence 4 ¼ to 5.9 years

Phillips, a correctional officer with the North Carolina Department of Public Safety, was recruited by Jacobs and Moody to join “Team Two” in August 2014.
During his second operation in October 2014, Phillips assisted with the unloading of packages of sham drugs from one car to be moved to a hidden compartment in another car.
On the day of his arrest, Phillips was carrying a semi-automatic handgun and ammunition.
In total, Phillips participated in three operations and attempted to transport 10 kilograms of cocaine and 30 kilograms of heroin. He accepted approximately $6,500 in payments.

Ponton: Recommended sentence 4 ¼ to 5.9 years

When he was recruited by Clanton in December 2014, Ponton was a correctional officer at the Lawrenceville Correctional Center in Lawrenceville, Virginia.
In total, Ponton participated in two operations, attempting to transport 10 kilograms of heroin. Immediately following his first operation, Ponton attempted unsuccessfully to recruit another law enforcement official, who declined to participate after Ponton described the way the organization worked.
In total Ponton accepted approximately $2,500 in payments.

Dailey: Recommended sentence 3.8 to 4 ¾ years

Dailey was a 911 dispatch operator in Northampton County who was recruited into the organization in February 2015 by Pair.
Although she was not a law enforcement official, Dailey demonstrated a willingness to aid the trafficking organization through her official position, agreeing to access and search law enforcement databases to help the DTO in return for cash payments.
In total, Dailey participated in two operations, attempting to transport 10 kilograms of cocaine and 10 kilograms of heroin, and accepting approximately $3,000 in payments.
At the time of her arrest, Dailey had a semi-automatic pistol and ammunition.

Pierce: Recommended sentence 12 to 18 months

Pierce, who had no law enforcement affiliation, was recruited by Jacobs and Moody to join “Team Two” in August 2014.
Because Jacobs and Moody understood that the DTO would reject recruits who were not law enforcement officers, they coached Pierce to represent to the undercover agents posing as drug traffickers that she was a correctional officer, which she did.
In total, Pierce participated in two operations, attempting to transport 20 kilograms of heroin and accepting approximately $4,000 in payments.
Pierce returned on the day of her arrest, expecting to perform another operation.