Free Redacted Document - District Court of Delaware - Delaware

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
v. i Criminal Action N 0. 08- l QQ
JIMMY LEE PIERCE, g
Defendant. i
INDICTMENT
The Grand Jury for the District of Delaware charges that:
Count One
On or about July 15, 2008, in the District of Delaware, JIMMY LEE PIERCE, defendant
herein, did knowingly possess with the intent to distribute 500 grams or more of a mixture and
substance containing a detectable amount of cocaine, a schedule II controlled substance, in
violation of Title 21, United States Code, Section 84l(a)(l) and (b)(l)(B).
NOTICE OF FORFEITURE
Upon conviction of the controlled substance offense alleged in Count One of this
Indictment, defendant, Jimmy Lee Pierce, 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 violation, including but not limited to the
following:

S (( E l| ocu Ti )8/1 TT
A. CURRENCY
Approximately $23,000 in United States currency.
B. SUBSTITUTE ASSETS
If 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;
it is the intent of the United States, pursuant to 21 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:
Hjnreperson -
COLM F. CONNOLLY
United States omey V
B $ _ ¢
· ·¤ i nson
Assistant • ed‘States Attorney
Dated: August 14,2.008 V V A U

Case 1:08-cr-00126-JJF

Document 13

Filed 08/14/2008

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Case 1:08-cr-00126-JJF

Document 13

Filed 08/14/2008

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