Free Redacted Document - District Court of Delaware - Delaware

, Case`1 :05-er-00051 - ¤ 9 /24/2005, Page 1 of 4
I I IN THE UNITED STATES DISTRICT COURT A
‘ I FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, : I
a f I Plaintiff, . 2 I O O
I v. h Criminal Action No; 05- 5 I I
n ‘ MICHAEL J. ANDERSON, I
` Defendant.
I INDICTMENT
The Grand Jury for the District of Delaware charges that:
I I COUNT ONE
On or about January 20, 2005, in or near Claymont, in the State and District of Delaware,
MICHAEL J. ANDERSON, defendant herein, did unlawfully obstruct, delay and affect
commerce and the movement of articles and commodities in such commerce, by robbery, in that
the defendant did unlawfully take and obtain personal property consisting of cash in the custody
and possession of the victim, a person working at Cumberland Farms, 1310 Philadelphia Pike,
Claymont, Delaware, against his will by means of threatened force, violence, and fear of injury,
immediate and future, to his person, in violation of Title 18, United States Code, Section 1951.
COUNT TWO
" On or about January 21, 2005, in or near Claymont, in the State and District of Delaware,
MICHAEL J. ANDERSON, defendant herein, did unlawfully obstruct, delay and affect
commerce and the movement of articles and commodities in such commerce, by robbery, in that

‘ _ Case·1:O5-cr-00051-GMS Document 2 Filed 05/24/2005 Rage 2 0f4 t
the defendant did unlawfully take and obtain personal property consisting of cash in the custody
A and possession of the victim, a person working at Seven Eleven, 2409 Philadelphia Pike,
Claymont, Delaware, against his will by means of threatened force, violence, and fear of injury,
. immediate and future, to his person, in violation of Title 18, United States Code, Section 1951.
1 · COUNT THREE · A
On or about January 23, 2005, in or near Claymont, in the State and District of Delaware,
MICHAEL J. ANDERSON, defendant herein, did unlawfully obstruct, delay and affect
commerce and the movement of articles and commodities in such commerce, by robbery, in that
the defendant did unlawfully take and obtain personal property consisting of cash in the custody
and possession of the victim, a person working at Cumberland Farms, 1310 Philadelphia Pike,
Claymont, Delaware, against her will by means of threatened force, violence, and fear of injury,
immediate and future, to her person, in violation of Title 18, United States Code, Section 1951.
COUNT FOUR
On or about January 24, 2005, in or near Wilmington, in the State and District of
Delaware, MICHAEL J. ANDERSON, defendant herein, did unlawfully attempt to obstruct,
A delay and affect commerce and the movement of articles and commodities in such commerce, by
robbery, in that the defendant did unlawfully attempt to take and obtain personal property
consisting of cash in the custody and possession of the victim, a person working at Arby’s, 4004
Concord Pike, Wilmington, Delaware, against his will by means of threatened force, violence,
and fear of injury, immediate and future, to his person, in violation of Title 18, United States
Code, Section 1951. ·

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_ I . COUNT FIVE . I
" I On or about January 26, 2005, in or near Wilmington, in the State and District of
V l Delaware, MICHAEL J. ANDERSON, defendant herein, by intimidation, did take from the
person and presence of a bank employee a sum of money belonging to and in the care, custody,
A control, management, and possession of Citizens Bank, 20841Namaans Road, Wilmington,
A Delaware, a bank whose deposits were then insured by the Federal Deposit Insurance
I Corporation, in violation of Title 18, United States Code, Section 21 13(a).
I . COUNT SIX I A
~ On or about January 28, 2005, in or near Wilmington, in the State and District of
A Delaware, MICHAEL J. ANDERSON, defendant herein, by intimidation, did take from the I
person and presence of a bank employee a sum of money belonging to and in the care, custody,
control, management, and possession of Commerce Bank, 401,0 Concord Pike, Wilmington,
l Delaware, a bank whose deposits were then insured by the Federal Deposit Insurance
Corporation, in violation of Title 18, United States Code, Section 2113(a).‘
COUNT SEVEN
On or about February 4, 2005, in or near Newark, in the State and District of Delaware,
MICHAEL J. ANDERSON, defendant herein, by intimidation, did take from the person and
presence of a bank employee a sum of money belonging to and in the care, custody, control,
management, and possession of Citizens Bank, 1 University Plaza, Newark, Delaware, a bank
whose deposits were then insured by the Federal Deposit Insurance Corporation, in violation of
Title 18, United States Code, Section 2113(a). 1

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On or about February 5, 2005, in or near Wilmington, in the State and District of . -
Delaware, MICHAEL J. ANDERSON, defendant herein, by intimidation, did take from the
· person and presence of a bank employee a sum of money belonging to and in the care,. custody, V
i control, management, and possession of Citizens Bank, 100 Suburban Drive, Newark, Delaware,
. a bank whose deposits were then insured by the Federal Deposit Insurance Corporation, in
. violation of Title 18, United States Code, Section 21 l3(a).
A TRUE BILL: I
A - Forepgoq
COLM F. CONNOLLY A
UNITED STATES ATTORNEY
By: . _ ‘
Y. Park _
sistant United St s Attomey l A 4 ·
Dated: May 24, 2005