Free Complaint - District Court of Delaware - Delaware

Case 1:07-mj—OO239—UNA Document 1 Filed 12/O3/2007 Page 1 of 3
AO 91 (gev. 12/93) fjriminaét Complaint _
In United States District Court
For the District of Delaware
UNITED STATES OF AMERICA ‘ I
Criminal Complaint
V. · ·
cAsE NUMBER: or- 23 QM
Deoddrick Purnell ,
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 November 30, 2007 in the District of Delaware, Defendant Deoddrlck Purnell, did knowingly possess in and affecting interstate
commerce, a firearm, after having been convicted on or about October 21 , 2002, of a crime punishable by imprisonment for a term
exceeding one year, in violation of Title 18 United States Code, Section(s) 922(g)(1) and 924(al(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:
_Sgg attached Affidavit
Continued on the attached sheet and made a part hereof: Yes U
Veronica M. I-lnat
Special Agent, ATF
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Case 1:07-mj—OO239—UNA Document 1 Filed 12/O3/2007 Page 2 of 3
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I, Veronica M. Hnat, being duly sworn, state as follows:
l. 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
has received law enforcement training on the investigation of firearms offenses on over fifty
occasions. Your affiant has participated in over one hundred investigations of firearms
offenses and participated in the seizure of over fifty firearms. You Affiant has also had over
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
officer in various capacities since 1989.
2. Unless otherwise stated, the information in this affidavit is based upon your affiant’s personal
knowledge.
‘ 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.
4. On November 30, 2007, at approximately 1954 hours, Wilmington Police were on patrol and
stopped a vehicle in the 1600 block of West Sth Street, in the city of Wilmington, New Castle
County, State of Delaware that was driving the wrong way on a one way street. The
occupants of the vehicle were questioned and it was revealed that the front seat passenger, as
well as, the driver was wanted for capias. The front seat passenger was wanted for Failure to
Pay, out of the Court of Common Pleas. .
5. The front seat passenger, Deoddrick Purnell, $(“the defendant" here on),
was transported to Wilmington Police Department. The vehicle was also transported to
Wilmington Police Department, located in the vehicle between the two front seats, in plain
view was a Ruger, P95DC, 9mm pistol, serial number 31415125 loaded with fifteen rounds
in the magazine. The Officer stated that the handle of the firearm was sticking out in plain
view.
6. The defendant, while at Wilmington Police Department, 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 pled guilty to Forgery 2“d, on or about 10/21/02, in the Superior Court of
Delaware, New Castle County, which is a crime punishable by imprisonment for a term
exceeding one year.

Case 1:07-mj—OO233—UI;1Am 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
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 affiant’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.
_ T 10. Wherefore, based upon your affiant’s training and experience, your affiant believes that there
g is {probable cause to believe that the defendant violated 18 U.S.C. 922(g) and 924(a)(2) by
_. ‘ possessing in and affecting interstate commerce a firearm, after having previously been
= cqnvicted of a felony and respectfully requests that the Court issue a Criminal Complaint
- charging that offense.
Veronica M. Hnat n
Special Agent, ATF
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Case 1:07-mj-00239-UNA

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Filed 12/03/2007

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Case 1:07-mj-00239-UNA

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Case 1:07-mj-00239-UNA

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