Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-cr-00140-GIVIS ocument 5 Filed 10/23/2007 Page 1 of 3 I
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i IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff] g
v. g Criminal Action N0. 07- / */0
MANUEL MEDLEY, i
Defendant. 3 F I I- E D
INDICTMENT I OCT 2 3 2007 {
The Grand Jury for the District of Delaware charges that:
us. Dzsmlcr COURT
COUNT ONE mstmct OF DELAWARE
On or about October 19, 2007, in the State and District of Delaware, Manuel Medley,
defendant herein, did knowingly possess in and affecting interstate and foreign commerce, a firearm,
that is, a Sig Sauer, .40 caliber pistol, Model 229, serial number AM67479, after having been
convicted on or about June 10, 2002, of a crime punishable by imprisonment for a term exceeding
one year, in the Superior Court ofthe State of Delaware, in violation of Title 18, United States Code,
Sections 922(g)(1) & 924(a)(2).
COUNT TWO
On or about October 19, 2007, in the State and District of Delaware, Manuel Medley,
defend g nt hésjgin, did knowingly possess in and affecting interstate and foreign commerce, a firearm,
th {EG, 9 mm caliber pistol, serial number V1 1665, after having been convicted on or about
June 10, 2002, of a crime punishable by imprisonment for a term exceeding one year, in the Superior
Court of the State of Delaware, in violation of Title 18, United States Code, Sections 922(g)(1) &
924(a)(2).

Case 1:07-cr-00140-GIVIS Document 5 Filed 10/23/2007 Page 2 of 3
COUNT THREE at
On or about October 19, 2007, in the State and District of Delaware, Manuel Medley,
defendant herein, did knowingly possess with the intent to distribute 50 grams or more of a mixture
and substance containing a detectible amount of cocaine base, a Schedule H narcotic controlled
substance, in violation of Title 21, United States Code, Sections 841(a)(l) and (b)(l)(A).
NOTICE OF FORFEITURE
Upon conviction of one or more of the offenses alleged in Counts One through Three of this
Indictment, defendant Manuel Medley shall forfeit to the United States pursuant to 18 U.S.C. §
924(d), 21 U.S.C. § 853 and 28 U.S.C. § 246l(c), any property, real and personal, that constitutes
or is derived from or is traceable to proceeds obtained directly or indirectly from the commission of
the above offense(s); all property, real or personal, that was used to facilitate, or was intended to be
used to facilitate the commission ofthe offense(s); and, all firearms and ammunition involved in the
commission of the offense(s), including but not limited to the following:
A Sig Sauer, .40 caliber pistol, Model 229, serial number AM67479, and any ammunition
@ \ U conéawherern;
A SEG, 9 mm caliber pistol, serial number V1 1665, and any ammunition contained
therein; .
$49,585 in cash.
If any of the above-described forfeitable property, as a result of any act or omission of the
defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which carmot be divided without difficulty;
it is the intent of the United States, pursuant to 18 U.S.C. § 924(d) and 21 U.S.C. § 853(p) as
incorporated by 28 U.S.C. § 246l(c), to seek forfeiture of any other property of said defendant up

, Case 1:07-cr-00140-GIVIS Document 5 Filed 10/23/2007 Page 3 of 3 ‘
to the value ofthe forfeitable property described above.
A BALL:
Horeperson
COLM F. C OLLY
United St ttorney
BY: ·
Sh A. Weede
Assistant United States Attomey
Dated: October 23, 2007

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