During a lengthy, three-month long RICO trial in Buffalo, New York before now ChiefUnited States District Court Judge Elizabeth A. Wolford, members of the Outlaws attendedevery day of the trial, sat prominently in the gallery, and took notes.See United States v.Willson, et al., Case No. 1:15cr142. In that case — a RICO prosecution of the KingsmenMotorcycle Club — the Outlaws were not specifically mentioned in the Indictment, but thecase involved testimony and matters that related to a support club affiliated with the Outlaws.Despite no direct link to the Outlaws, they monitored the proceedings daily, and theirpresence at trial created a stressful dynamic in the courtroom, caused issues with witnesses,and risked the orderly administration of justice.Here, unlike in the Kingsmen case, the Outlaws are specifically referenced in theIndictment, see Dkt. 89, Introduction ¶ 4, and they likely have a strong interest in supportingGerace at trial. Indeed, the National President of the Outlaws is the manager o fPharaoh’sGentlemen’s Club and was present there when federal authorities executed a search warranton December 12, 2019. Other members of the Outlaws are employed in various positions atPharaohs — a location where sex trafficking, drug trafficking, and other unlawful activities arealleged to have occurred. Further, the National President of the Outlaws submitted anaffidavit in support of Gerace’s motion to amend his conditions of release in this case. seeDkt.108-2. Therefore, the Outlaws have an even greater interest in this case than they did in theKingsmen Motorcycle Club case. As a result, there is reason to believe that the Outlaws willattend trial daily and cause great risk to the orderly administration of justice.Case 1:19-cr-00227-LJV-MJR Document 619 Filed 09/06/23 Page 14 of 23
15Moreover, the Outlaws themselves do not even need to attend the trial to accomplishtheir goals if it is held in Buffalo. As the dominant 1%er MC in the Buffalo area, the Outlawshave a network of smaller support clubs who can also cause security and logistical issuesassociated with the trial, even if the Outlaws themselves do not attend.7. Indeed, as thegovernment has explained in previous submissionsrelated to Gerace’s release or custodialstatus, see Doc. No. 110, at n. 7, law enforcement considers the Outlaws MC to be a dangerousand violent criminal organization, which has been subject to numerous prosecutionsnationally.See, e.g.,United States v. Starrett , 55 F.3d 1525, 1533 (11th Cir. 1995) (noting that“The Outlaw Motorcycle Club (the “Outlaws”) is one of the four largest national ‘one-percenter’ motorcycle clubs[,] . . . who are known to cause the most trouble, or ‘raise the most hell.’”); see also United States v. Bowman, 302 F.3d 1228, 1231 (11th Cir. 2002) (formerinternational president of the Outlaws convicted of racketeering, conspiracy to murder, andvarious other offenses);United States v. Lawson, 535 F.3d 434, 438 (6th Cir. 2008), as amended(Oct. 9, 2008) (RICOprosecution relating to Outlaws MC “Green Region”, including amurder at a strip club.)