Free Complaint - District Court of Delaware - Delaware

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THE UNITED STATES DIS'TRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
CRIMINAL COMPLAINT
v.
CASE NUMBER: 08- (0qM
RASHIE T. HARRIS
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 March 30, 2008 inthe State and District of Delaware, RASHIE T.
HARRIS did knowingly possess in and affecting interstate commerce, a firearm, after having been convicted
on or about March 20, 2006, and September 20, 2006, each crime punishable by imprisonment for a term
exceeding one year, in violation of Title 18 United States Code, Section(s) 922(gli1) 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:
y attached Affidavit.
Continued on the attached sheet and made a part hereof: Yes
David C. Rosenblum ___ _______: g ,_
Task Force Officer, A F` I {
Special Deputy U.S. rshYl__ L
:
J "I. ·
Sworn to before me and subscribed in my presence, Q MAH 3 1 20/8
I
- ¤&fIJ\r\ \ v atWilmin ton DE. i""’”`”&;”;’;‘I“";"MéEf ‘"" `
Date City and State
The Honorable Leonard P. Stark [ $ i E * K
Name of Judicial Officer Signature o Judicial Officer

Case 1:08-cr-00068—G|\/IS Document 1 Filed 03/31/2008 Page 2 of 4
AFFIDAVIT OF PROBABLE CAUSE
ATF Task Force Officer and Special Deputy U.S Marshal David C. Rosenblum, being
duly sworn, states as follows:
Your affiant Detective David C. Rosenblum ("Your Af`fiant") has been a Wilmington Police
Officer for approximately 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 Of`ficer 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 Of`ficer, Your Affiant has received over 275 days of training from the
DOI, 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 to
provide expert testimony with regard to 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
of`ficers with knowledge and/or expertise in the interstate nexus required for certain federal
firearms offenses.
l. Unless otherwise stated, the information in this affidavit is based upon Your Af`fiant’s
personal knowledge and conversations with other Wilmington Police Officers. Because
this af`fidavit 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 March 30, 2008, in the City of
Wilmington, State and District of Delaware, as stated to me by two Wilmington Police
Of`ficers.
3. Your Affiant learned from the officers that they were partners operating in the same
vehicle, and were working routine patrol on March 30, 2008. As part of their patrol
duties, they conducted a vehicle registration check through the Delaware Justice
information System Database ("DELJIS") on an occupied vehicle traveling in the area of
2“d and Greenhill Avenue. Through their inquiry, the officers learned that the vehicle
was reported stolen. The officers reported their activity through WHJCOM (dispatch)
and followed the vehicle while they waited for back—up officers.

Case 1:08-cr-00068—G|\/IS Document 1 Filed 03/31/2008 Page 3 of 4
4. After following the vehicle for several blocks, the officers then decided to perform a
motor vehicle stop. The suspected stolen automobile did not stop, however, but
attempted to flee. The officers reported that they pursued the vehicle at speeds
exceeding 50 mph. The vehicle later stopped, at which point two individuals -- the
driver and passenger -- exited the vehicle and fled on foot.
5. One of the officers pursued the driver, later identified as the defendant RASHIE T
HARRIS, while the second officer chased the passenger. The officer chasing HARRIS
reported that as HARRIS ran, he was holding both hands against his left side, as if he
were securing a concealed obj ect. HARRIS ran between two parked vehicles and was
observed crouching down. After discarding an item at that location, HARRIS continued
to flee. HARRIS was apprehended a short distance later after being tazed. The
passenger was able to elude capture.
6. Once HARRIS was in custody, a search incident to arrest was performed. HARRIS was
found to possess a blue rubber latex glove in his pants pocket. This glove was found to
contain forty- seven .22 caliber rounds. After securing HARRIS, the officer responded
back to where HARRIS was observed discarding an item. At that location, the officer
discovered a chrome revolver on the ground. The firearm was photographed at that
location and identified as an Imperial Metal Products Inc. .22 caliber short model,
bearing serial number 79919. The officer reported that, during the incident, he did not
see any other individuals in the area or any vehicular traffic.
7. HARRIS was transported to Wilmington Hospital where he was treated for minor
injuries as a result of the incident; thereafter, he was transported to Wilmington Police
Turnkey. HARRIS provided the name Raheem White with a date of birth in 1987 to the
officers and was treated under the same name. The officers were unable to locate this
identity in DEL] IS, so they obtained HARRIS’ finger prints, which were dispatched to
an FBI processing center for analysis. Once a response from the FBI processing center
was received, the officers discovered HARRIS’ true identity.
8. Your Affiant responded to Wilmington Police Turnkey on March 30, 2008, and
interviewed HARRIS in the presence of one of the officers involved. Your Affiant
issued HARRIS his Miranda Warnings and HARRIS verbally and voluntarily consented
to an interview. HARRIS stated that he was driving the above described vehicle, which
he referred to as a "bl00p ride. " This officer knows from experience that a bloop ride is
a conunonly used term describing a vehicle that has been loaned to a stranger in
exchange for drugs. This officer also knows from experience that bloop rides are seldom
returned by the possessor as agreed upon during the transaction, and are often reported
stolen. HARRIS stated that while he was driving the vehicle, the passenger (who was
not apprehended) handed him both the firearm and glove containing the described
ammunition. HARRIS indicated that he enthusiastically accepted the firearm and
ammunition despite the fact he was aware that he was a felon and therefore prohibited
from doing so. HARRIS refused to identify the passenger other than the name "c0w. "

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10. From my training and experience, and prior 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 a state other than Delaware such
that its possession in Delaware would have necessarily required that the firearm 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. Further, Your Affiant
examined the firearm and it appeared operable.
Wherefore, based upon Your Affiant’s training and experience, Your Affiant believes that there
is probable cause to believe that the defendant violated: (1) 18 U.S.C. 922(g)(l), by possessing
in and affecting interstate commerce a firearm, after having previously been convicted of a felony
crime punishable by imprisonment for a term exceeding one year, and respectfully requests that
the Court issue a Criminal Complaint charging this offense.
Q,/i/@
David C. Rosenblum
Task Force Officer, ATF
Special Deputy U.S. Marshal
Swo to d sub cribed in my presence
this gsi; of 2008
The Honorable Leonard P. Stark
United States Magistrate Judge

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