Free Complaint - District Court of Delaware - Delaware

Case 1:07-cr-00165-SLR Document 1 Filed 12/O3/2007 Page 1 of 3
AO 91 (Rev. 12/93) Criminal Complaint _ ,

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In United States District Court I
For the District 0f Delaware E
UNITED STATES OF AMERICA l
Criminal Complaint
v. ‘
CASE- NUMBER: 07- [
Jermane Vessels ,
Defendant
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I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. On or I
about November 30, 2007, in the District of Delaware, Defendant Jermane Vessels, did knowingly possess in and affecting interstate
commerce, a firearm, after having been convicted on or about July 2, 2001, of a crime punishable by imprisonment for a term
exceeding one year, in violation of Title 18 United States Code, Seotion(s) 922(g)g1 I and 924ga)(2) and further
state that I am a(n) Special Agent, Bureau of Alcohol, Tobacco, Firearms, and Explosives and that this complaint is based on the
following facts;
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S tt h cl Aff'dav't o ,, 2 ~ . ,
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U.S. DISTRICT COURT
Continued on the attached sheet and made a part hereof: ? Ul§_l;§lQLQ‘_§ DELAWARE
Veronica Nl. Hnat
Special Agent, ATF
Sworn to before me and subscribed in my presence,
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Case 1:07-cr-00165-SLR Document 1 Filed 12/O3/2007 Page 2 of 3
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I, Veronica M. Hnat, being duly sworn, state as follows:
1. I am a Special Agent with the U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives ’
(ATF) and have been so employed for over eighteen years. During that time, my duties have
included the investigation of firearms offenses at both the State and Federal levels. Your
Affiant is currently assigned to the Operation Disarm Task Force and has been so assigned
since October, 2003. During the course of your affiant’s law enforcement career, your affiant V B
has received law enforcement trainingon the investigation of firearms offenses on over fifty
occasions. Your affiant has participated in over one hundred investigations of firearms Q
offenses and participated in the seizure of over fifty firearms. You Affiant has also had over i
one hundred conversations with police officers and Federal agents about the facts and ,
circumstances of firearms offenses. Your Affiant has been employed as a law enforcement A
officer in various capacities since 1989. l
2. Unless otherwise stated, the information in this affidavit is based upon your affiant’s personal 1
knowledge. _ j
3. The seizure of all the below stated evidence occurred on November 30, 2007, in the City of {
Wilmington, State and District of Delaware, as stated to me by Wilmington Police Officers {
who have personal knowledge of the stated facts. l
4. On November 30, 2007, at approximately 1954 hours, Wilmington Police were on patrol and i
stopped a vehicle in the 1600 block of West 5th Street, in the city of Wilmington, New Castle `
County, State of Delaware that was driving the wrong way on a one way street. When the
vehicle came to a stop, the back seat passenger, later identified as Jermane Vessels, ("the
defendant" here on), _ . opened the back passenger door, directly behind the
driver, and fled on foot.
5. A short foot pursuit ensued and the defendant was tackled in the 1600 block of West 4th
Street by Wihnington Police. During the tackle, the Officer observed the defendant throw an
object across the street. Another Officer observed the defendant toss the obj ect and saw that
it was a firearm. That Officer recovered the firearm that the defendant tossed and saw that it
was a Beretta, .25 caliber firearm, serial number 42158C, loaded with eight rounds in the
magazine.
6. The defendant was transported to the Wilmington Police Department, he was read his
Miranda Warnings and agreed to speak to the Officers. The defendant told the Officers that
he had the gun for protection. _ .
7. Your affiant reviewed the computer criminal history information for the defendant from the
Delaware Justice Information System and learned that the defendant has a prior felony
conviction and was found guilty of Maintaining a Vehicle for Keeping a Controlled
Substance, on or about 07/02/2001, in the Superior Court of Delaware, New Castle County,
which is a crime punishable by imprisonment for a term exceeding one year.
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Case 1:07-cr-00165-SLR Document 1 Filed 12/O3/2007 Page 3 of 3
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8. From you affiant’s training and experience, and from prior discussions with ATF Agents who
are expertly trained and experienced in determining the interstate nexus of firearms, your i
affiant knows that the above mentioned firearm 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 commerce.
9. Based upon your afiiant’s training and experience, your affiant submits that there is probable
cause to believe that the above—mentioned seized firearm contained the frame and receiver of
a firearm, and that the firearm appeared to be capable of expelling a projectile by action of an
explosive.
l0. Wherefore, based upon your affiant’s training and experience, your affiant believes that there
A ` is probable cause to believe that the defendant violated 18 U.S.C. 922(g) and 924(a)(2) by
_ Qpossessing in and affecting interstate commerce a firearm, after having previously been
Q convicted of a felony and respectfully requests that the Court issue a Criminal Complaint
charging that offense. Q
. Veronica M. Hnat i
Special A%ta"$TF ~
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SWO111 to and subscribed in my P J'; p
This 30th day of November, 200 gi -._- ,,i§E;,__ I i
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Case 1:07-cr-00165-SLR

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Case 1:07-cr-00165-SLR

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Case 1:07-cr-00165-SLR

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