Free Redacted Document - District Court of Delaware - Delaware

F Case 1 :08-cr-00005-SLR Document 2 Filed O1 /1 O/2008 Page 1 of 2
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{ - * _ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) D
)
v. )
) Criminal Action No. 08- O 5 ·
TERRENCE ROSS )
are srurrmtatrr ) F 5 {_ E D
Defendant. ) r""—·—·——·I
mnrcrivrnur I 000 l 0 2008
The Grand Jury for the District of Delaware charges that: U.S. Dt$TRiCT COURT
ursjajgt gg DELAWARE
COUNT I
On or about October 12, 2007, in the State and District of Delaware, TERRENCE ROSS, aka T
"Turkman," the defendant herein, did knowingly possess with the intent to distribute, more than hfty
(50) grams of a mixture and substance containing a detectable amount of cocaine base (“crack"), a
controlled substance, in violation of 21 U.S.C. §§ S41(a)(1) and (b)(1)(A).
` COUNT II
On or about October 12, 2007, in the State and District of Delaware, TERRENCE ROSS, aka
"Turk;rnan," the defendant herein, did knowingly possess with the intent to distribute a mixture and
substance containing a detectable amount of cocaine, a control-led substance, in violation of 21
U.S.C. §§ 841(a)(1) and (b)(1)(C).
T coursir nr
_ On or about October 12, 2007, inthe State and District of Delaware, TERRENCE ROSS,
aka "Turkman," the defendant herein, did knowingly possess a firearm, that is a Smith and Wesson
12 gauge shotgun, serial number FS09874, in hrrtherance of a drug trafficking crime for which he

Case 1:08-cr-OOOO5-SLR Document 2 Filed O1/10/2008 Page 2 of 2
I * may be prosecuted in a court of the United States, to wit, the offenses described in Counts I and H
of this Indictment, incorporated herein _by reference, in violation of 18 U.S.C. § 924(c)(1)(A).
COUNT IV
On or about October 12, 2007, in the State and District of Delaware, TERRENCE ROSS,
aka "Turk:man," defendant herein, having been convicted of a crime punishable by imprisonment for
a term exceeding one year on November 9, 1990, in the Superior Court for the State of Delaware,
did knowingly possess in and affecting interstate commerce a firearm, that is a Smith and Wesson
12 gauge shotgun, serial number FS09874, in violation of 18 U.S.C. §§ 922(g)(l) and 924(a)(2).
FORFEITURE ALLEGATION
Upon convictionof the offense alleged in Counts IH or IV of this Indictment, defendant shall i
i forfeit to the United States pursuant to 18 U.S.C. § 924(d) and 28 U.S.C. § 2461(c), all firearms and
ammunition involved in the commission ofthe offense, including but not limited to the following:
(1) a Smith and Wesson 12 gauge shotgun, serial number FS09874; (2) 1 box of 12 gauge shotgun
shells; (3) 1 box of 16 gauge shotgun shells; and (4) 1 box of .22 caliber rim fire ammunition.
A True Bill
I’i§·son *_WF-M-
COLM F. CONNOLLY
UNITED STATES ATTORNEY
BY? Q
lana H. Eisenstein
Assistant United States Attorney
Dated: January 10, 2008
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