Free Redacted Document - District Court of Delaware - Delaware

T r Case 1 :08-cr-OOOO7-SLR Document 11 Filed O1/22/2008 Page 1 of 3
I REDACTED
I ' IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff, I
I v. Criminal Action N0. 08- O7
RYAN EVANS
Defendant.
I INDICTMENT
I The Grand Ju1y for the District of Delaware charges that: -
COUNT I
I On or about J anuaiy 10, 2008, in the State and District of Delaware, RYAN EVANS,
defendant herein, did knowingly possess with intent to distribute heroin, a Schedule I controlled
I substance, in violation of Title 2l, United States Code, Sections 84l(a)(l) and (b)(l)(C). 2
I COUNT II ` I I
On or about January 10, 2008, in the State and District of Delaware, RYAN EVANS,
defendant herein, during and in relation to a drug trafficking crime for which he may be
I prosecuted in a court of the United States (to wit, the knowing possession with intent to distribute
Heroin, as set forth in Count I of this Indictment and incorporated by reference as if fully set I
forth herein), knowingly carried a firearm, to wit, a Walther 1*-99, 9mm semi-automatic pistol
and knowingly possessed said firearm in furtherance of said drug trafficking crime, all in
‘ violation of 18 U.S.C. § 924(c)(l)(A). I A E
A F l L E D I
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I ' I COUNT III
M On or about January l0, 2008, in the State and`Dis1;rict of Delaware, RYAN EVANS,
defendant herein, having been convicted of a crime punishable by a term of imprisonment
exceeding one year, to wit, a conviction on or about December 16, 2004, in the United States
District Court, District of Delaware, did knowingly possess a firearm in and affecting interstate
commerce, to wit, a Walther P-99, 9mm semi-automatic pistol, serial number 043798, in
, violation of Title 18, United States Code, Sections 922(g)(l) and 924(a)(2).
n NOTICE OF FORFEITURE A
Upon conviction of the controlled substance offense alleged in Count I of this Indictment,
RYAN EVANS, defendant herein, shall forfeit to the United States pursuant to Title 21, United
States Code, Section 853, any property constituting or derived from proceeds obtained, directly
or indirectly, as a result of said violation, and any property used, or intended to be used, in any
` mmer or part to commit, or to facilitate the commission of] said violation.
Up on conviction of the firearms offenses alleged in Count H of this Indictment, RYAN I
· . EVANS, defendant herein, shall forfeit to the United States pursuant to Title 18, United States
Code, Sections 924(d) and Title 28, United States Code, Section 2461(c) any firearm involved or
used in the commission of said offenses.
If any of the above-described forfeitable property, as a result of any act or omission ofthe
defendant:
(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; I

j, — · Case 1:08-cr-OOOO7-SLR Document 11 Filed O1/22/2008 Page 3 of 3
i ‘ ‘ (4) has been substantially diminished in value; or
_ (5) has been commingled with other property which cannot be divided without
o difficulty; A
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of said defendant up to the value of the forfcitable property
p described above. .
p Foreperson
COLM F. CONNOLLY n
- United States Attorney
A ly I A
‘ BYZ _ I
Shawn Martyniak Q A
A Special Assistant Unite = es Attorney
Dated: January 22, 2008

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