Free Complaint - District Court of Delaware - Delaware


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Pages: 3
Date: June 17, 2008
File Format: PDF
State: Delaware
Category: District Court of Delaware
Author: unknown
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Page Size: 610 x 792 pts
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ln United States District Court
For the District 0fDelaWn1•e
UNITED STATES OF AMERICA
Criminal Complaint
V.
cAse NUMBER: oa- {()’—fM
· BRANDON WIGGINS,
_ Defendant
, l, the undersigned complainant, being duly sworn, state the following is true and correct to the best of
my knowledge and belief. On or about June 13, 2008, in the District of Delaware, Defendant did;
knowingly possess in and affecting interstate 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,
Secticn(s) 922[g)(1) and §24(a)(2).
I further state that l am sworn as a Special Deguy U,S. Marshal and am assigned tg the ATF
and that this complaint is based on the following facts:
See attached Affidavit
Continued on the attached sheet and made a part hereof; Yes
David C. Rosenblum
Special Deputy U.S. Marshal assigned to the ATF
Sworn to before me and subscribed in my presence,
June 13 20gs ,. , at Wil tcn E .. Mr r..
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The Honorable Robert Lopez _ I _ I: . ._ _ 6
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AFF IDAVIT OF PROBABLE CAUSE: ATF Task Force Officer and Special Deputy U.S
Marshal David C. Rosenblum ·
Your Affiant Detective David C. Rosenblum has been a Wilmington Police Officer for
approximately 10 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
fo1·ee through Deputization by the United States M.arshal’s Service. During this Ofl:icer’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 Afiianfs 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 Afiiant 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 Aftiant has had conversations with federal agents
and law enforcement oHicers 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 Affianfs.
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 J une 2008, in the City of Wilmington,
State and District of Delaware, as stated to me by at least two Wilmington Police
Officers.
3. On 13 June 2008, WPD Patrol Ofhcers were on routine patrol and observed the
defendant BRANDON WIGGINS in the 200 block of Connell Street. The officers
reported they were familiar with WIGGINS and knew him on sight. The officers iiirther
reported that they confirmed WIGGlNS’ status as having active capiases.
4. The Officers reported that upon observing WIGGINS walking in the block they stopped
their vehicle next to him and attempted to initiate contact. WIGGINS immediately fled
on foot and the officers gave chase.

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5. J T he officer in pursuit reported to Your Affiant that he-observed WIGGIN S remove a
firearm nom his waistband, run with the gun in his hand and discard the weapon while
continuing to flee. The officer reported taking mental note of where the firearm landed
and also that there were no other individuals in the vicinity. The suspect was
subsequently taken into custody and the firearm recovered. .
6. Your Afftant reviewed the Delaware Justice Information System Database (DELJIS) and
verified that WIGGIN S has a previous felony conviction in the New Castle County
Superior Court for Carrying a Concealed Deadly Weapon on or about 14 January 2008.
7. 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 defmed in 18 U.S.C., Chapter 44, Section 92l(a)(3] and was
manufactured in a state other than Delaware suchdthat its possession in Delaware would
have necessarily required that the Ereann had crossed 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 Affianfs 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 commerce a firearm, after having previously
been convicted of a felony crime punishable by iniprisonment for a term exceeding one year and
respectiiilly requests that the Court issue a Criminal Complaint charging this offense.
Daé C. Rosenblum
Task Force Officer, ATF.
Special Deputy U.S. Marshal
Sworn to and subscribed in my presence _ ‘ `¥“\TgHg'”’*
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Justice ofthe Peace Magistrate Judge ·i·. · Je - ···¢
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