Free Complaint - District Court of Delaware - Delaware

Case 1:08-mj-00139 Document 1 Filed 08/13/2008 Page 1 of 3
AO 91 (Rev. 12/93) Criminal Complaint _
THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
CRIMINAL COMPLAINT
v.
CASE NUMBER: 08-
THOMAS BUTCHER
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of
my knowledge and belief. On or about August 13, 2008 in the State and District of Delaware, THOMAS
BUTCHER did knowingly possess in and affecting interstate commerce, a firearm, after having been convicted
on or about May 27, 1992, of a crime punishable by imprisonment for a term exceeding one year, in violation
of Title 18 United States Code, Section(s) 922(g)l1) and 924(a)(2).
I further state that I am a(n) Task Force Officer, ATF and a Special Deputy U.S Marshal and that this
complaint is based on the following facts:
g attached Affidavit.
Continued on the attached sheet and made a part hereof: Yes
4 r,..
David C. Rosenblum
Task Force Officer, ATF
Special Deputy U.S. Marshal
Sworn to before me and subscribed in my presence,
fg 23/22 at Wilmington, DE.
Date City and State
The Honorable Ma Pat Th n e A _
Name ¤i Judicial orricei iai oiricei ] r

Case 1:08-mj-00139 Document 1 Filed 08/13/2008 Page 2 of 3
AFFIDAVIT OF PROBABLE CAUSE: ATF Task Force Officer and Special Deputy U.S
Marshal David C. Rosenblum
Your Affiant Detective David C. Roserrblunr has been a Wilmington Police Officer for over
9 years and is currently assigned as a Task Force Officer (TF O) with the U.S. Bureau of
Alcohol, Tobacco, Firearms and Explosives (ATF), whose duties include the investigation
into firearms offenses committed in Wilmington, Delaware. Your Affiant has been
authorized to seek and execute arrest and search warrants supporting a federal task force
through Deputization by the United States Marshal’s Service. During this Officer’s
employment as a Law Enforcement Officer, Your Affiant has authored in excess of 400
felony arrests warrants for crimes, some of which involved illegal narcotics and firearms.
Prior to Your Affiant’s current assignment, this Officer was assigned to the Wilmington
Police Drug, Organized Crime, and Vice Division, Operation Safe Streets Task Force where
Your Affiant has conducted over an estimated 1000 investigations into illegal narcotics and/
or firearms offenses whereby, this Officer seized numerous weapons along with large
amounts of narcotics and suspected drug proceeds. During Your Affiant’s tenure as a Law
Enforcement Officer, Your Affiant has received over 275 days of training from the DOJ,
FBI, ATF, DEA, DSP, WPD, DOC, Royal Canadian Mounted Police, North East Counter
Drug Training, Homeland Security, California Highway Patrol and other law enforcement
agencies. Your Affiant has been qualified in Delaware Superior Court and Federal Court,
District of Delaware to provide expert testimony on the intent to distribute controlled
substances and has testified as an expert in approximately 15 felony drug trials. During the
course of previous investigations, Your Affiant has had conversations with federal agents
and law enforcement officers with knowledge and/ or expertise in firearms offenses dealing
with interstate nexus of firearms crossing state lines thereby affecting interstate commerce.
1. Unless otherwise stated, the information in this affidavit is based upon Your Affiant’s
personal knowledge and conversations with other Wilmington Police Officers. Because
this affidavit is solely for establishing probable cause, not all facts related to this
investigation are included herein.
2. The events stated below occurred on or about 13 Aug 2008, in the City of Wilmington,
State and District of Delaware, as stated to Your Affiant by a Wilmington Police
Officer.
3. On 13 Aug 2008, a Wilmington Police Officer told Your Affiant that he performed a
motor vehicle stop on a vehicle for disregarding a red light. The vehicle was operated by
a female and the defendant THOMAS BUTCHER was seated in the passenger seat. The
driver of the vehicle was found to have an outstanding capias for her arrest and was
taken into custody.
4. THOMAS BUTCHER was found to have an active capias for his arrest as well.
BUTCHER removed himself from the vehicle and while being patted down advised the
officer that he had a weapon on him.

Case 1:08-mj-00139 Document 1 Filed 08/13/2008 Page 3 of 3
5. The Officer advised that BUTCHER had a Raven Arms .25 caliber model MP-25 semi-
automatic handgun loaded with 6 rounds in his cargo pocket. The weapon was reported
to have an obliterated serial number.
6. Your Affiant was contacted by the officer and reported to the Wilmington Police
Station. Your Affiant personally inspected the weapon and verified that the description
of the weapon was accurate, which it was.
7. Your Affiant reviewed the Delaware Justice Information System Database (DELJIS) and
verified that Defendant THOMAS BUTCHER has at least one previous felony
conviction in the New Castle County Superior Court for Criminal Mischeif Over $15 00
Damage on or about 5/27/92 which Your Affiant knows is a felony punishable by more
then one year in prison.
8. After physically inspecting the weapon and from my training and experience, and after
discussion with an ATF Agent who is expertly trained and experienced in determining
the interstate nexus of firearms, Your Affiant believes that the above described weapon
is a firearm as defined in 18 U.S.C., Chapter 44, Section 921(a)(3) and was
manufactured in another country or state other than Delaware such that its possession in
Delaware would have necessarily required that the firearm had crossed national or state
lines prior to its possession in Delaware and such that the possession of that firearm in
Delaware affected interstate or foreign commerce.
Wherefore, based upon Your Affiant’s training and experience, Your Affiant believes that there
is probable cause to believe that the defendant violated 18 U.S.C. §§· 922(g)(l) and 924(a)(2), by
knowingly possessing in and affecting interstate and foreign commerce a firearm, after having
previously been convicted of a felony crime punishable by imprisonment for a tenn exceeding
one year, / 0 q,
Accordingly, Your Affiant respectfully requests that the Court issue a gi I 5
Criminal Complaint charging these offenses.
David C. Rosenblum
Task Force Officer, ATF
Special Deputy U.S. Marshal
Sworn to and subscribed in my presence
this li day or /· 2008
agar.,
The H le Mary Pat ,*7 ge
United ` s · s Magistrate Judge

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