A0 91 (Rev'.†12/93) Criminal Complaint _ .
In United States District Court
For the E)ist1·ict 0f])elawa1·c
UNITED STATES OF AMERICA I
Criminal Complaint
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lVlAT|l\/IA l\/IILLER , D
Deéndant _I\~.__t_ _
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and
belief. On or about 8/11/07 in the District of Delaware, Defendant l\/lATllt/IA MILLER did
knowingly possess in and affecting interstate commerce, a firearm, after having been convicted on or about 10/15/2002 of a crime
punishable by imprisonment for a term exceeding one year,
in violation of Title 18 United States Code, Section(s)_ 922(g)(1 I and 924ta)(2l.
I further state that I am a(n) Special Agent Bureau of Alcohol Tobacco Firearms and Explosive and that this complaint is based
Official Title
on the following facts:
See attached Affidavit
Continued on the attached sheet and made a part hereof: Yes }
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‘ Special Agent, ATF
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Sworn to before me and subscribed in my presence, §C)Of/.~—~-~`,___`
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Name & Title of Judicial Officer Signature of!udictal’Officer·%//E9 X Lq§`E{§*'
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U.S. BISTFIICT CGIIRT
DISTRICT GF DiL.¤t't’ARF
Case 1:07-cr-00114-JJF Document 2 Filed 08/13/2007 Page 2 of 3
l, Veronica M. Hnat, being duly sworn, state as follows;
l. l am a Special Agent with the US. Bureau of Alcohol, Tobacco, Firearms, and Explosives
(ATF) and have been so employed for over seventeen years. During that time, my duties have
included the investigation of firearms offenses at both the State and Federal levels. Your
Affiant is currently assigned to the Operation Disami Task Force and has been so assigned
since October, 2003. During the course of your afhant’s law enforcement career, your affiant
has received law enforcement training on the investigation of fireanns offenses on over
hundred occasions. Your affiant has participated in over one hundred investigations of
nrearms offenses and participated in the seizure of over hfty firearms. You Affiant has also
had over one hundred conversations with police officers and Federal agents about the facts
and circumstances of firearms offenses. Your Affiant has been employed as a law -
enforcement officer in various capacities since l989.
2. Unless otherwise stated, the information in this affidavit is based upon your affiant’s personal
knowledge. . p
3. The seizure of all the below stated evidence occurred on August ll, 2007, in the City of
Wilrriington, State and District of Delaware, as stated to me by the Officers ofthe V _
Wilmington Department of Police who have personal knowledge of the stated facts.
4. On August ll, 2007, at approximately 0114 hours, the Wilmington Department of Police
were in the area ofthe 2800 block of Northeast Boulevard, Wilmington, Delaware when they
heard shouts coming from the Thunderguards Club, a private club located in the 2800 block
~ of Northeast Boulevard and observed several people chasing someone_ and yelling to them
that he has a gun. `
5_ The Wilmington Police Officers joined in the chase of the was seen having a
Hreaini. The subject, Matima Miller, black male,.date of i‘·i- i.-_ was apprehended
. in the 1200 block of East 27th Street, Wilmington, Delaware, aft Ie eing hot by a tazer gun.
The witness showed the Police the route in which they chased Matima Miller and the Police
as well as, the witness retraced l\/liller’s path. ln the alley of the l200 block of East 28th
Street, Wilmington, Delaware the Police located a loaded New England Firearms, model
R73, .32 caliber revolver, serial number NB004888 iri a pile of trash. The firearm was taken
into custody by the V/ilmington Police.
6. Matima Miller was transported to Wilmington Hospital, according to the Wilmington
Department of Police protocol when an individual is shot by a tazer gun. Shortly after being
admitted to Wilmington Hospital, Miller was released and turned back over to the _
Wilmington Department of Police.
7. An interview of the witness, by the Wilmington Police, indicated that Matima Miller wanted
to enter into the Thunderguards Private Club, the witness told Miller that he needed to be
patted down before he entered into the club. The witness stated that Miller did not want to be
F’““€6§§é†1;t>"‘/%§Rt>’t>i‘]?)Et’il?1r§n€?K "t‘3§&?6%%1é‘r%§1“b“ “?T=llâ€Ã©@ dgli él§8t`ff $***1*-=%‘g%>â€Ã© ell?
started to mn an they c ase him ye ing to t e Polrcet at e ha a gun.
8. Your aftiant reviewed the computer criminal history information for the defendant from the
Delaware Justice Information System (DELJIS), and leamed that the defendant has a prior
felony conviction for Trafficking Cocaine, for which he pled guilty to on 10/15/2002 in the
New Castle County Superior Court for the State of Delaware, which is a crime punishable by
imprisomnent for a tenn exceeding one year. -
9. From you afHant’s training and experience, and from prior discussions with ATF Agents who
i are expertly trained and experienced in determining the interstate nexus of firearms, your
affiant knows that the above mentioned firearrn was manufactured in a state other than
Delaware such that its possession in Delaware would have necessarily required that the
hrearm had crossed state lines prior to its possession in Delaware and such that the
possession of that fireann in Delaware affected interstate commerce.
10. Based upon your affiant’s training and experience, your affiant submits that there is probable
cause to believe that the above-mentioned seized firearm contained the frame and receiver of
a firearm, and that the fireanri appeared to be capable of expelling a projectile by action of an
explosive.
1 1. Wherefore, based upon your affiant’s training and experience, your affiant believes that there
is probable cause to believe that the defendant violated 18 U.S.C. 922(g) and 924(a)(2) by
possessing in and affecting interstate commerce a firearm, after having previously been
convicted of a felony and respectfully requests that the Court issue a Criminal Complaint
charging that offense.
Lt f“,*i.lQ-li.-M Y` il!.}
Veronica M. Hnat Q i `
Special Agent, ATF
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Swom to and subscribed in my pr%ass®`i`gU RTJIT/"#q@
This lllh day of August, 2007 §OQ/Q.-··""`" ''°' â€*-._j"<’>g,,7%a
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Case 1:07-cr-00114-JJF
Document 2
Filed 08/13/2007
Page 1 of 3
Case 1:07-cr-00114-JJF
Document 2
Filed 08/13/2007
Page 2 of 3
Case 1:07-cr-00114-JJF
Document 2
Filed 08/13/2007
Page 3 of 3
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