Free Complaint - District Court of Delaware - Delaware

Case 1:08-mj-00117-UNA Document 1 Filed 07/11/2008 Page 1 of 4
AO 91 (Rev. 12/93) Criminal Complaint E
In United States District Court
For the District of Delaware
UNITED STATES OF AMERICA
Criminal Complaint
v.
CASE NUMBER: 08- /l 7 " /G/i
RASHEEM DOLLARD,
Defendant
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 July 1 1, 2008 in the District of Delaware, Defendant
did knowingly:
1) possess in and affecting interstate and foreign commerce, a firearm, after having been convicted of a felony crime
punishable by imprisonment for a term exceeding one year,
in violation of Title 18 United States Code, Section(s) 922Q gQ( 1Q and 924QaQQ2 Q; and
2) possess with intent to distribute cocaine base,
in violation of Title 21 United States Code, Section(s) 841Q aQQ 1 Q and QbQQ 1 QQC Q.
I further state that I am sworn as a Special Deputy U.S. Marshal and am assigned to the ATF
and that this complaint is based on the following facts:
y attached Affidavit
Continued on the attached sheet and made a part hereof: Yes
David Rosenblum
Special Deputy U.S. Marshal assigned to the ATF
Sworn to before me and subscribed in my presence,
July 11, 2008 at Wilmington, DE
Date City and State
Honorable Leonard P. Stark Q
United States Magistrate Judge ‘
Name & Title of Judicial Officer Signature of Judicial Officer

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AFFIDAVIT OF PROBABLE CAUSE: ATF Task Force Officer and Special Deputy U.S
Marshal David C. Rosenblurn
Your Affiant Detective David C. Rosenblum has been a Wilmington Police Officer for over
9 years and is currently assigned as a Task Force Officer (TFO) 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, Califomia 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 andf 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 11 July 2008, in the City of Wilmington,
State and District of Delaware, as stated to Your Affiant by a Wilmington Police
Officer.
3. On 11 July 2008, a Wilmington Police Officer told Your Affiant that he, along with his
partner, observed the defendant remove a black firearm from his waistband and toss the
same onto a residential rooftop.
4. A Wilmington Police Officer told Your Affiant that the officers apprehended the
defendant and that the firearm was recovered from the rooftop by assisting Wilmington
Police Department Officers. Your Affiant personally inspected the firearm which is
described as a Taurus INT MFG. (Miami FL) PT 138 Millennium, .380 ACP bearing
serial number KUB224l5 which was made in Brazil. When the firearm was recovered, it
had 1 live round in the chamber and l0 in the magazine.

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5. A Wilmington Police Officer told Your Affiant that the defendant was subsequently
searched by Wilmington Police Officers. The defendant was found to possess l bag of a
white substance that field tested positive for cocaine with a weight of 5 grams. The
Wilmington Police Officer believed it was cocaine base, and from the description
provided by said Wilmington Police Officer, your affiant believes the substance to be
cocaine base. The bag containing the substance was concealed in his right front pants
pocket. In Your Affiant’s opinion, through my training and experience, the manner in
which the cocaine base was packaged (as described by the reporting officer), in
conjunction with the lack of paraphernalia, the defendant’s possession of a firearm, and
the area that the incident occurred as being well known for drug sales, Your Affiant can
say to a degree of certainty that this cocaine base was intended for distribution.
6. Your Affiant responded to WPD and interviewed the defendant. Your Affiant issued the
defendant his Miranda warning and after verbally acknowledging he understood his
rights verbally consented to an interview. During the interview, the defendant stated,
among other things, that he did possess the firearm and that he discarded the firearm by
tossing same onto a roof top.
7. Your Affiant reviewed the Delaware Justice information System Database (DELJIS) and
verified that Defendant RASHEEM DOLLARD has a previous felony conviction in the
New Castle County Superior Court for Possession With Intent to Deliver a Schedule
Controlled Substance on or about 29 March 2004 which Your Affiant knows is
punishable by more then l 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 92l(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.

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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 term exceeding
one year, and also violated 2l U.S.C. §§ 84l(a)(l) and (b)(l)(C) by possessing with intent to
distribute cocaine base. Accordingly, Your Affiant respectfully requests that the Court issue a
Criminal Complaint charging these offenses.
f ¢
Davitpi C. Rosenblum
Task Force Officer, ATF
Special Deputy U.S. Marshal
Sworn to and subscribed in my presence
this [Hay of SLA Lx 2008
The Honorable Leonard P. Stark
United States Magistrate Judge

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