Q AO“9l (Rev. I2/93) Criminal Complairlt__
{ In United States District Court
I - For the District of Delaware
UNITED STATES OF AMERICA
i Criminal Complaint
____ V.
I ¤ ws] CASE NUMBER: '
l ° ers0n
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 11 November 2007 in the District of Delaware, Defendant
Tarel Anderson did knowingly: i
1) possess in and affecting interstate commerce, a nrearm, after having been convicted on or about 14
August 2007 of a crime punishable by imprisonment for a tenrn exceeding one year, Assault Second Degree
in violation of Title 18 United States Code, Sectlon(s) 922lg)(1 l and 924(a)l2)·,
l further state that I am a(n) Sgecial Agent, ATF David DiBetta and that this complaint is based
on the following facts;
ge attached Affidavit
Continued on the attached sheet and made a part hereof: Yes
Special Agent, ATF
Sworn to before me and subscribed In my presence,
r .
7) if/MW/9wQ gn 7at Wilmington, DE ,a~s"‘q"“g`â€'E'"â€â€™,,"’â€5—‘=ia,
Date City and Stat? -···
Honorable Paul smith
M8QlSlli`@€_;iLldQ€, Justice of the Peace Court 20 _
Name s Iriila of Judicial Officer / la g
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DELAWARE
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Q 1. Your affiant is David DiBetta Your afdant has been a Special Agent for over nineteen
and a half years with the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives
(ATF). During that time, my duties have included the investigation of federal and state
Q firearms offenses. During the course of your affiant’s law enforcement career, your
. affiant has received law enforcement training on the investigation of firearms offenses
on numerous occasions but not limited to the ATF Academy, Firearms identification
· classes, Firearms Nomenclature classes, and Firearms identification classes at the
r Federal Law Enforcement Training Center. During the course of your af`fia.nt’s law
A enforcement career, your affrant has participated in over 900 seizures of firearms and
L well over 1000 investigations of firearms offenses, as well as numerous conversations
, about the facts and circumstances of Hrearms offenses with the investigating officers of
; those firearms offenses.
i 2. Unless otherwise stated, the information in this affidavit is based upon your affiant’s
, personal knowledge and conversations with Wilmington Police Officers.
3. The seizure of all the below stated evidence occurred on 9 November, 2007, in the City
` of Wilmington, State and District of Delaware, as stated to me by one or more
{ Wilmington Police Officers with personal knowledge of the seizure ofthe below items.
; 4. Your affiant learned from Wilmington Police Officers thbggrl 9 November 2007
Wilmington Police officers stopped a vehicle for a motor ve `ch=:·vicfatierrat'C€ncord
ai_1@om Street. The vehicle was stopped for disregarding a red light in the Of`ficer’S
presence
5. After stopping the vehicle, the Officers reported to Your Affiant that they requested the
operator later identified as TARREL ANDERSON DOB provide a drivers
license, insurance card and registration for the vehicle. The operator provided a photo
copy of a temporary insurance card which the Officers stated was inadequate proof of
insurance. A DEL] IS check also revealed the operator’s license was
suspended/revoked.
6. The Officers further stated that the vehicle had an odor of alcohol coming from within.
Based on the original 3 traffic offenses (No proof of insurance, Red Light infraction,
and Driving Suspended) a decision was made to impound the vehicle. The driver was
removed from the vehicle. The Officers reported they detained the driver which is
cornrnon practice for this type of incident.
7. The Officers determined that the vehicle was to be impounded for the traffic violations.
The driver was removed at which point the arresting Officer observed in plain view on
a the rear passenger side floor board black semi»automatic firearm. lt should be noted that
Case 1 :07-cr-00159-JJF Document 2 Filed 1,1/13/2007 Page 3 of 3
W ` ' VEROM US ATTORNEYS OFFICE DISTRICT OF DELAWARE (TUE) 11. 13 O7 10 z 59/ST. 10:5 /NO. 4864638407 P 4
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Q the driver seat was leaned all the way back giving the driver a clear view ofthe firearm
= from his seated position. The officers reported the suspect was read his Miranda
. Warning after the discovery of the weapon brit did not mention the firearm. The suspect
replied to the Miranda Warning "that is not mhmi.-
, 8. Inspection ofthe firearm revealed it to beta HyPoint 9mm black in color with 2 ronmie
T in the magazine.
. 9. 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
V affrant knows that the HyPoint 9mm semi automatic handguniaaiixe as defined in
18 U.S.C., Chapter 44, Section 92l(a)(3) and vg manufactured in a s than
j Delaware, or in a foreign country such that its po ' in Degvyareavo have
necessarily required that the firearm had crossed state or foreign lines prior to its
S possession in Delaware and such that the possession of that firearm in Delaware
affected interstate commerce. V
10. Your affiant reviewed the computer criminal history information for the defendant from
T the nerewere ruenee rnremrenen
prior felony conviction on or abc! _ / 14/2007 for Assault 2nd inthe Superior Court 0
the State of Delaware, a crime punis a e y rmprisonment for a term exce ing one
y€2lI. _
?Wherefore, based upon your affiant’s training and experience, your afharrt believes that there is
probable cause to believe that the defendant violated:(l) 18 U.S.C. 922(g) and 924(a)(2), 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 those offenses.
David DiBetta i
Special Agent, ATF l
“m\I\}I}Im[â€
Sworn to an$¢&$` · " • _ » esence
this Q da)§ $p _y{__; ` g e-s
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Justice of Court 20
Case 1:07-cr-00159-JJF
Document 2
Filed 11/13/2007
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Case 1:07-cr-00159-JJF
Document 2
Filed 11/13/2007
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Case 1:07-cr-00159-JJF
Document 2
Filed 11/13/2007
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