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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, i
v. g Criminal Action No. 08- I
CHARLES L. BROWN, a.k.a. g
CHAS BROWN )
Defendant. )
INDICTMENT
The Grand Jury for the District of Delaware charges that:
COUNT ONE
On or about July ll, 2008, in the State and District of Delaware, Charles L. Brown, a.k.a.,
Chas Brovm, defendant herein, did knowingly possess in and affecting interstate and foreign
commerce, a firearm, that is, a Taurus 9 mm model Pl ll handgun, serial number TZC0l092, after
having been convicted on or about July 7, 1999, of a crime punishable by imprisonment for a term
exceeding one year, in the Delaware County, Pennsylvania, Court of Common Pleas, in violation of
Title 18, United States Code, Sections 922(g)(l) & 924(a)(2).
COUNT TWO .
On or about July ll, 2008, in the State and District of Delaware, Charles L. Brown, a.k.a.,
Chas Brown, defendant herein, did knowingly possess with the intent to distribute five grams or
more of a mixture and substance containing a detectible amount of cocaine base, a Schedule H
narcotic controlled substance, in violation of Title 21, United States Code, Sections 84l(a)(l) and
On or about July 1 l, 2008, in the State and District of Delaware, Charles L. Brown, a.k.a.,
· _ Case 1:08-cr—00136-GIVIS Document 2 Filed 08/26/2008 Page 2 of 3
Chas Brown, defendant herein, did knowingly possess with the intent to distribute a mixture and
substance containing a detectible amount of cocaine, a Schedule II narcotic controlled substance, in
violation of Title 21, United States Code, Sections 841(a)( 1) and (b)(1)(C).
NOTICE OF FORFEITURE
Upon conviction of one or more of the offenses alleged in Counts One, Two and Three of
this Indictment, defendant Charles L. Brown, a.k.a., Chas Brown, shall forfeit to the United States
pursuant to 18 U.S.C. § 924(d), 21 U.S.C. § 853 and 28 U.S.C. § 2461(c), any property, real and
personal, that constitutes or is derived from or is traceable to proceeds obtained directly or indirectly
from the commission of the above offense(s); all property, real or personal, that was used to
facilitate, or was intended to be used to facilitate the commission ofthe offense(s); and, all firearms
and ammunition involved in the commission of the offense(s), including but not limited to the
following:
a Taurus 9 mm model P1l1 handgun, serial number TZC01092, and any ammunition
contained therein; and
$1,900 in United States currency.
If any of the above-described forfeitable property, as a result of any act or omission of the
defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided without difficulty;
it is the intent of the United States, pursuant to 18 U.S.C. § 924(d) and 21 U.S.C. § 853(p) as
incorporated by 28 U.S.C. § 2461(c), to seek forfeiture of any other property of said defendant up
Case 1:08-cr—00136-GIVIS Document 2 Filed 08/26/2008 Page 3 of 3
to the value of the forfeitable property described above.
A TRUE BILL:
Vléoreperson
COLM F. CONNOLLY
United States Attorney
A- 1 Z.
BY ‘·~ • 2 who e ·
Sha t o nson
Assistant • - d States Attorney
Dated: August 26, 2008
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