Free Redacted Document - District Court of Delaware - Delaware

_ , Case 1 207-Cf-00140-Gb/§EwA1C6fED Filed 12/27/2007 Page 1 of 3 1
IN THE UNITED STATES DISTRICT COURT t
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) I
I Plaintiff, g
v. g Criminal Action No. 07- /70 ·@ MS
A MANUEL MEDLEY, i
Defendant. i
SUPERSEDING IN DICTMENT
The Grand Jury for the District of Delaware charges that:
A COUNT ONE
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 tenn exceeding
one year, in the Superior Court ofthe State of Delaware, in violation of Title 18, United States Code,
Sections 922(g)(l) & 924(a)(2). e
COUNT TWO I
On or about October 19, 2007, in the State and District of Delaware, Manuel Medley, i
. defendant herein, did knowingly possess in and affecting interstate and foreign commerce, a firearm,
that is, a EEG, 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 1
Court of the State of Delaware, in violation of Title 18, United States Code, Sections 922(g)(1) &
924(a)(2). I E L E D `
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I DEC 2 7 200/ R ‘ .
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_ Case 1:07-cr-00140—G|\/IS Document 11 Filed 12/27/2007 Page 2 of 3 I
l
COUNT THREE
· 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 Y
I and substance containing a detectible amount of cocaine base, a Schedule H narcotic controlled
substance, in violation of Title 2l, United States Code, Sections 84l(a)(l) and (b)(l)(A).
COUNT FOUR
On or about March 15, 2007, in the State and District of Delaware, Manuel Medley,
i defendant herein, did knowingly distribute a mixture and substance containing a detectible amount
of cocaine base, a Schedule II narcotic controlled substance, in violation of Title 2l, United States
Code, Sections 84l(a)(l) and (b)(l)(C). ·
concur Frvn
_ On or about March 27, 2007, in the State and District of Delaware, Manuel Medley,
defendant herein, did knowingly distribute a mixture and sub stance containing a detectible amount Q
of cocaine base, a Schedule II narcotic controlled substance, in violation of Title 21, United States
Code, Sections 84l(a)(l) and (b)(l)(C).
COUNT SIX .
On or about April 6, 2007, in the State and District of Delaware, Manuel Medley, defendant
herein, did knowingly distribute a mixture and substance containing a detectible amount of cocaine
base, a Schedule II narcotic controlled substance, in violation of Title 21, United States Code,
Sections 84l(a)(l),and (b)(l)(C).
NOTICE OF FORFEITURE
Upon conviction of one or more of the offenses alleged in Counts One through Six 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

A Case 1 :07-cr-00140-GMS Document 1 1 Filed 12/27/2007 Page 3 of 3
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 f
used to facilitate the commission of the offense(s); and, all firearms and ammunition involved in the
commission of the offense(s), including but not limited to the following: I i
A Sig Sauer, .40 caliber pistol, Model 229, serial number AM67479, and any ammunition
contained therein; -
A PEG, 9 mm caliber, Model MAK, serial number V1 1665, and any ammunition j
contained therein;
$49,585 in cash.
l
lf 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;
_ i ` (b) has been transferred or sold to, or deposited with, a third party; A
(c) has been placed beyond the jurisdiction of the court; i
(d) has been substantially diminished in value; or i
(e) has been commingled with other property which cannot be divided without difficulty;
it is the intent of the United States, pursuant to 18 U.S.C. § 924(d) and 2l 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
to the value of the forfeitable property described above. - n
' roreperson
COLM F. I ll p OLLY E
United St = ttomey
BY:
S A. Weede ‘
Assistant United States Attorney
Dated: December 27, 2007 V

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