Free Redacted Document - District Court of Delaware - Delaware

Case 1 :08-cr-00137-UNA Document 15 Filed O9/O2/2008 Page 1 of 2 `
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, 1
Plaintiff, :
v. Criminal Action No. 08- /3 7·· ALL-
JEFFREY DANIELS
KENNETH KILSON :
Defendants. 1 _, { t'“S
I? E0 [Wl E ID
S J rt I ,
INDICTMENT
The Federal Grand Jury for the District of Delaware charges that:
Count One
From on or about August l2, 2008 to on or about August 15, 2008, in the State and District
of Delaware, and elsewhere, JEFFREY DANIELS and KENNETH KILSON, defendants herein, did
knowingly conspire with one another and with persons known and unknown to the Grand Jury to
possess with intent to distribute a controlled substance, to wit, five hundred (500) grams or more of
a mixture and substance containing a detectable amount of cocaine, a violation of Title 21, United
States Code, Sections 841 (a)(I) & (b)(1)(B), all in violation of Title 21, United States Code, Section
846.
Count Two
On or about August 15, 2008, in the State and District of Delaware, JEFFREY
DANIELS, defendant herein, did knowingly possess with the intent to distribute more than fifty
(50) grams of a mixture and substance containing a detectable amount of cocaine base, a

Case 1:O8—cr—OO137-UNA Document 15 Filed O9/O2/2008 Page 2 of 2
controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1) and
(b)(1)(A)-
NOTICE OF FORFEITURE
Upon conviction ofthe controlled substance offense alleged in Counts One and Two of this
Indictment, JEFFREY DANIELS and KENNETH KILSON, 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.
A TRUE BILL:
COLM F. CONNOLLY
United States Attorney
BY: i / »—-····—’
na H. Eisenstein
Assistant United States Attorney
Dated: Z} gwg

Case 1:08-cr-00137-UNA

Document 15

Filed 09/02/2008

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Case 1:08-cr-00137-UNA

Document 15

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