Free Redacted Document - District Court of Delaware - Delaware

Case 1 :06-cr—OOO50-GIVIS Document 7 Filed 05/O2/2006 Page of 4 I _
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff, .
v. Criminal Action No. 06- ·* A
WILLIE BROWN, MARK TATMAN, :
‘ MARTY EATON a/k/a "Dmx", : .ii ,. . -U_..Ha..
CRAIG DURHAM, I III ll iii ;I,IIl `IIILIII III [I" I
JOHN DOE a/k/a "Auk", ASHLEY N. 1 ‘ ---- *-.-'_,?;IrQI '-.."i_; l Q ·
HARRISON a/k/a "Nil·;l BRITTNEY ROBINSON, : -
Defendants. I l,. D
i V""—*`""I___`l
INDICTMENT ’ i __ . .,
.I L·.'·-.'L=
l
The Grand J ury for the District of Delaware charges that: I __i
us. rizsitrict Colm
COUNT I i _g.·;;..tm at- an-IRE
Conspiracy to Distribute Crack Cocaine
in and around Dover, Delaware
I. From in and around November, 2005, through in or around April, 2006, WILLIE
BROWN engaged in the distribution of more than 50 grams of a mixture and substance
containing a detectable amount of cocaine base, also known as "crack", in and around Dover,
Delaware. MARK TATMAN, MARTY EATON a/k/a "Dmx", CRAIG DURHAM, and
JOHN DOE, a/k/a "Auk", participated in this enterprise by distributing crack cocaine on
BROWN's behalf. ASHLEY N. HARRISON a/k/a "Nikki" made her Dover residence
available to BROWN for use as a location where some sales to BROWN's customers were
made. BRITTNEY ROBINSON used her apartment to secrete drugs for BROWN, and acted
as a courier for BROWN. »

Case 1 :06-cr—OOO50-GIVIS Document 7 Filed 05/O2/2006 Page _of 4 A _,
Charging Paragraph
2. From in or about November 2005 through in or about April 2006, in the State
and District of Delaware, WILLIE BROWN, MARK TATMAN, MARTY EATON a/k/a
"Dmx", CRAIG DURHAM, JOHN DOE, a/ka "Auk", ASHLEY N. HARRISON a/k/a
"Nikki" and BRITTNEY ROBINSON, defendants herein, did knowingly conspire together
and with each other, and with other persons known and unknown to the Grand Jury, to
distribute fifty (50) grams or more of a mixture and substance containing a detectable amount
of cocaine base, a Schedule H narcotic controlled substance, in violation of Title 21, United
States Code, Sections 841(a)(l) and (b)(1)(A). V
All in violation of Title 21, United States Code, Section 846 and Title 18, United
States Code, Section 2.
_ COUNT II
3. On or about November 30, 2005, in the State and District of Delaware, WILLIE
‘ BROWN, defendant herein, did knowingly distribute fifty (50) grams or more of a mixture ·
and substance containing a detectable amount of cocaine base, a Schedule II narcotic
controlled substance, in violation of Title 21, United States Code, Sections 841(a)(l) and
(b)(l)(A), and Title 18, United States Code, Section 2.
COUNT III
4. On or about December 7, 2005, in the State and District of Delaware, WILLIE
BROWN, MARK TATMAN, and MARTY EATON a/k/a "Dmx", defendants herein, did
knowingly distribute fifty (50) grams or more of a mixture and substance containing a
detectable amount of cocaine base, a Schedule H narcotic controlled substance, in violation of _

§ Case 1 :06-cr—OOO50-GIVIS Document 7 Filed 05/O2/2006 Page 3,of 4
Title 21, United States Code, Sections 841(a)(l) and (b)(l)(A), and Title 18, United States
Code, Section 2.
COUNT IV
5. On or about March 16, 2006, in the State and District of Delaware, WILLIE
BROWN and JOHN DOE, a/k/a "Auk", defendants herein, did knowingly distribute fifty (50)
grams or more of a mixture and substance containing a detectable amount of cocaine base, a
Schedule H narcotic controlled substance, in violation of Title 21, United States Code,
Sections 84l(a)( 1) and (b)(l)(A), and Title 18, United States Code, Section 2.
K ` COUNT V I
6. On or about March 30, 2006, in the State and District of Delaware, WILLIE
BROWN and CRAIG DURHAM, defendants herein, did knowingly distribute fifty (50)
grams or more of a mixture and substance containing a detectable amount of cocaine base, a
Schedule H narcotic controlled substance, in violation of Title 21, United States Code,
Sections 84l(a)(l) and (b)(l)(A), and Title 18, United States Code, Section 2.
NOTICE OF FORFEITURE
7. Upon conviction of one or more of the controlled substance offenses alleged in Counts
I-V above, WILLIE BROWN, MARK TATMAN, MARTY EATON a/k/a "Dmx", CRAIG
DURHAM, JOHN DOE, a/ka "AUI<", ASHLEY N. HARRISON a/ld "Nil BRITTNEY ROBINSON, defendants herein, shall forfeit to the United States pursuant to
21 U.S.C. § 853, any property constituting, or derived from, proceeds obtained, directly or
indirectly, as a result of the said violations and any property used, or intended to be used, in
any manner or part, to commit, or to facilitate the commission of the said violations.

Case 1 :06-cr-OOO50-GIVIS Document 7 Filed 05/O2/2006 Page 4iof 4
8. If any of the above-described forfeitable property, as a result of any act or omission of
the defendants:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third party;
(3) has been placed beyond the jurisdiction of the court; ~
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot be divided without
` difficulty; A _
it is the intent of the United States, pursuant to 2l U.S.C. § 853-(p), to seek forfeiture of any
_ other property of said defendant up to the value of the forfeitable property described above.
A TRUE BILL:
Foreperson
COLM F. CONNOLLY
United States Attomey
BY: ZL l
Douglas . McCann “
Assistant United States Attorney
Dated: May 2, 2006