Free Exhibit List - District Court of Delaware - Delaware

Case 1:07-mj—00168 Document 7 Filed 08/31/2007 Page 1 014
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Case :07-mj-00168 Document 7 Filed 08/31/2007 Page 2 of 4
in 91 um. tires; criminal Complaint ¤ I
‘ In United States District Court
For the District of Delaware
UNITED STATES OF AMERICA I `
p Criminal Complaint
v.
I CASE NUMBER: Oi/Q /6. 8* iq
TARIREEF WHITE, I
Defendant
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 Augg st 28, 2007 in- the District of Delaware, Defendant TARIREEF WHITE did
knowingly possess in and affecting interstate and foreign commerce, a firearm, after having been convicted of a felony
crime punishable by imprisonment for a term exceeding one year,
in violation of Title 18 United States Code, Section(s) 922( gg 1) and 924(a)g2 Q.
I further state that I am a(n) Special Agent, ATF and that this complaint is based
` Official Title
on the following facts: I
E attached Affidavit _ `
Continued on the attached sheet and made a part hereof: Yes
b L " _,___
Tat Shum I
A Special Agent, ATF
Sworn to before me and subscribed in my presence, I I I
Augggt 28, 2007 A . A at il/ilmingt on, DE A . .
Date I ' _ E ‘ - City and State _ -
- ‘ E I _ I ` GOVERNMENT
Honorable Leonard P. Stark ,_ K 3 EXHIBIT
United States Magistrate Judge p _ § ig
Name & Title of Judicial Officer Signature of Judicial Officer E

Case 1 :07-mj-00168 Document 7 Filed 08/31 /2007 Page 3 of 4
l
AFFIDAVIT OF SPECIAL AGENT TAT SHUM i
l. Your affiant is Special Agent Tat S. Shurn. Your affiant has been a law enforcement E
officer for over seven years with the Bureau of Alcohol, Tobacco, Firearms, and Explosives
(ATF). As part of my duties, responsibilities and training, and in the course of my investigative E
experience, I have become familiar with the statutes, rules and regulations, policies and -
_ procedures, relating to the Bureau of Alcohol, Tobacco, Firearms and Explosives, including but
. not limited to the possession of firearms by persons prohibited, and other laws enforced by the
Bureau of Alcohol, Tobacco, Firearms and Explosives. I am a graduate of the Federal Law
Enforcement Training Center, Glynco, GA, Criminal Investigation Course and the Bureau of
Alcohol, Tobacco and Firearms New Professional Training Course. Prior to my employment
with ATF, your affiant was employed by the Pennsylvania State Attorney’s Office as a State
Narcotics Agent and has previously received training and conducted investigations involving the -
illegal use of firearms. Your affiant was also previously employed by the First Judicial District
of Pennsylvania, Common Pleas and Municipal Cotuts, as a warrant unit investigator for the
County of Philadelphia. During the course of my law enforcement career, I have participated in
over 100 seizures of firearms and conducted over 150 criminal investigations involving federal
firearms violations.
2. Unless otherwise stated, the information in this affidavit is based upon your affiant’s l
personal knowledge. r
3. The seizure of the below stated firearm occurred on August 28, 2007, in the City of
Wilmington, State and District of Delaware, as stated to me by one or more Wilmington Police
Officers with personal knowledge of the seizure of the below firearm.
4. Your affiant reviewed the computer criminal history information of the Defendant
TARIREEF WHITE from the Delaware Justice Information System (DELJIS) and the National
Crime Information Center (N CIC) and learned that the defendant has prior felony convictions for
Assault in the First Degree and Possession of a Deadly Weapon during the Commission of a
Felony on or about 12/07/98 in the Superior Court of the State of Delaware, crimes punishable by
imprisonment for a term exceeding one year. V
5. Your affiant also reviewed an ATF office file record and the computer criminal history
information of WHITE from the The Enforcement Communications Systems (T ECS) and
confirmed that the defendant also has a prior federal conviction for Felon in Possession of a
Firearm on or about 5/08/03 in the United States District Corut, Judicial District of Delaware.
WHITE was sentenced to 40 months imprisonment and supervised release. According to the
NCIC, his federal probation will not expire until·6/16/08. I p
6. As stated to me by one or more Wilmington Police Officers with personal knowledge of
the above facts, I, leamed the following? On August 28, 2007, Wilmington Police Officers started
to surveil a person that they later identified as the Defendant Tarireef WHITE and observed the
Defendant WHITE suspiciously riding on his bicycle with his left hand holding on the bicycle

Case 1 :07-mj-00168 Document 7 Filed 08/31/2007 Page 4 of 4
handle while his right hand was placed in his front waistband area. The Wilmington Police were ¤
in uniform and in a marked police car and continued to follow Defendant WHITE. As the
officers followed him, WHITE kept looking back and checking on the officers. The officers l
observed Defendant WHITE accelerate on his bicycle. The Wilmington Police Officers A
continued to surveil Defendant WHITE and observed Defendant WHITE appeared to hold an l
unknown item in his waist area. The Wilmington Police Officers believed, that, based upon ‘
training, Defendant WHITE’S conduct was consistent with that of persons attemptingto hide or
conceal illegalfirearms while they were in physical motion such as riding a bicycle. As one
, officer exited his patrol vehicle to attempt to initiate an investigative stop on Defendant WHITE, 1
both Wilmington Police Officers observed Defendant WHITE throw a handgun onto the ground E
on a sidewalk and flee from the area. From the area in which Defendant Tarireef WHITE threw
the firearm, one of the officers immediately recovered a Glock, Model 23, .40 caliber pistol,
_ serial number AVT93 OUS that was loaded with eight rounds of .40 caliber arnmtmition. The
other officer pursued Defendant WHITE, but temporarily lost sight of him in the nearby area;
Other assisting officers apprehended Defendant WHITE less than one minute later; The original
two Wilmington Police officers observed the person apprehended by the assisting officers and
identified him as the person who threw the handgun on the street in Wilmington, DE earlier that
morning. That person is Defendant Tarireef WHITE.
7. From training and experience, and your aftiant’s inspection of the above firearm, your
affiant knows that the above - mentioned firearm is a firearm as defined in 18 USC, Chapter 44,
Section 92l(a)(3). Based upon an engraving mark on the above firearm and your affiant’s
training and experience, your affiant believes the above firearm was manufactured in the country
of Austria and would have crossed a state line before its seizure in Delaware and thus, the .
firearm would have affected interstate or foreign commerce before its seizure. _
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 andeaffecting interstate and/or foreign commerce a firearm, after having previously
been convicted of a felony crime punishable by imprisonment for a term exceeding one year and
respectfully requests that the Court issue Cri inal Complaint charging that offense. "
T t S. Shum I
Special Agent, ATF
Sworn to and subscribed in my presence
this 28th day of August, 2007 I ‘ D y _ _
Honorable Leonard P. Stark ‘ -
United States Magistrate Judge l ‘ .
District of Delaware _

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